ML20205H489
| ML20205H489 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/12/1986 |
| From: | Long W Office of Nuclear Reactor Regulation |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| NUDOCS 8608200090 | |
| Download: ML20205H489 (11) | |
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O August 12, 1986 Docket No. 50-298 MEMORANDUM FOR:
Eric H. Johnson, Director Division of Reactor Safety and Projects Region IV THRU:
Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing, NRR FROM:
William O. Long, Project Manager BWR Project directorate #2 Division of BWR Licensing SUPJECT:
NRR SALP INPUT - COOPER NUCLEAR STATION Enclosed is the NRR input for the Cooper Station SALP evaluation covering the period from February 1,1985 through July 31, 1986. As discussed in the en-closure, our evaluation was conducted according to NRR Office Letter No. 44 dated January 3,1984, and NRC manual chapter 0516, Systematic Assessment of Licensee Performance. The overall performance rating in the functional area of Licensing Activities is Category 1.
C ryc d sist.'d b William 0. Long, Project Manager BWR Project Directorate 2 Division of BWR Licensing
Enclosure:
SALP Input for Licensing Activities cc w/ enclosure R. Bernero D. Dubois (Sr. Resident Inspector)
DISTRIBUTION 10cchet:F11e 79
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Docket No. 50-298 FACILITY:
Cooper Nuclear Station LICENSEE:
Nebraska Public Power District EVALUATION PERIOD: February 1,1985 to July 31, 1986 PROJECT MANAGER:
William 0. Long
1.0 INTRODUCTION
This report presents the results of the Office of Nuclear Reactor Regulation (NRR) evaluation of the performance of Nebraska Public Power District (the District), licensee for the Cooper Nuclear Station. The assessment of the licensee's performance was conducted according to NRR Office Letter No. 44, "NRR Inputs to SALP Process", dated January 3, 1984. Office Letter No. 44 incorporates NRC Manual Chapter 0516, Systematic Assessment of Licensee Per-formance.
2.0
SUMMARY
NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2 or 3) based on a composite of a number of attributes. The performance of the District in the functional area of licensing is rated Category 1.
3.0 CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chap-ter 051b Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.
4.0 METHODOLOGY This evaluation represents the integrated inputs of the Operating Reactor Project Manager (ORPM) and those technical reviewers who expended significant of effort on Cooper Nuclear Station licensing actions during the rating period.
Using the guidelines of NRC Manual Chapter 0516, the ORPM and each reviewer 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 included this informa-tion as part of each Safety Evaluation Report transmitted to the Division of BWR Licensing. The ORPM, after reviewing the inputs of the technical re-viewers, combined this information with his own assessment of licensee per-formance and arrived at a composite rating for the licensee's performance in the functional area of Licensing Activities. This rating also reflects the comments of the Senior Executive. A written evaluation was then prepared by the ORPM and circulated to NRR management for comments, which were incorporated 1
in the final draft.
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The basis for this appraisal was the District's performance in support of sig-nificant licensing actions that were either completed or had a substantial level of activity during the rating period. These actions, consisting of amendment requests, responses to generic letters, TMI (NUREG-0737) items, and other actions, are listed below:
MULTIPLANT ACTIONS A-17 INSTRUMENTATION TO F0LLOW THE COURSE OF AN ACCIDENT A-19 HYDROGEN RECOMBINER CAPABILITY - RESPONSE TO GENERIC LETTER 84-09 B-24 CONTAINMENT VENT & PURGE B-76 SALEM ATWS - POST-TRIP REVIEW PROGRAM DESCRIPTION AND PROCEDURES - COM-PLETED - LE1TER TO PILANT DATED MAY 6, 1985 B-// SALEM ATWS - EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE - REACTOR TRIP SYS COMPONENTS B-78 SALEM ATWS - POST-MAINTENANCE 1ESTING PROCEDURES / VENDOR RECOMMENDATIONS -
REACTOR TRIP SYSTEM COMPONENTS B-79 SALEM ATWS - POST-MAINTENANCE TESTING - CHANGES TO TECH SPECS - REACTOR TRIP SYSTEM - COMPLETED - LETTER TO PILANT DATED MAY 23, 1986 B-84 INSPECTION OF STAINLESS STELL PIPING ACCORDING TO GENERIC LETTER 84 COMPLETED - LETTER TO PILANT DATED JULY 31, 1985 B-85 SALEM ATWS - POST-TRIP REVIEW - DATA AND INFORMATION CAPABILITY - COM-PLETED - LETTER TO PILANT DATED JUNE 10, 1985 B-86 SALEM ATWS - EQUIP CLASS & VEND 0R INTERFACE - ALL SAFETY RELATED COMP 0-NENTS B-8/ SALEM ATWS - POST-MAINT TESTING PROCEDURES & VEND 0R RECOMMENDATIONS B-88 SALEM ATWS - POST-MAINTENANCE TESTING - CHANGES TO TECH SPECS - ALL SAFETY-RELATED COMPONENTS - COMPLETED - LETTER TO PILANT DATED MAY 23, 1986 B-92 SALEM ATWS - REACTOR TRIP SYS FUNCTIONAL TESTING - DIVERSE TRIP FEATURES B-93 SALEM ATWS - REACTOR TRIP SYS FUNCTIONAL TESTING - ALTERNATIVES AND TEST INTERVALS D-19 DIESEL GENERATOR RELIABILITY TECHNICAL SPECIFICATIONS - RESPONSE TO GE-NERIC LETTER 84-15 (SEE PLANT-SPECIFIC ACTION BELOW - AMENDMENT 95)
D-20 DRYWELL VACUUM BREAKERS RESPONSE TO GENERIC LETTER 83-08 E-04 SINGLE-LOOP OPERATION (SEE PLANT-SPECIFIC ACTION BELOW)
F-05 PROCEDURES GENERATION PACKAGE F-09 SAFETY PARAMETER DISPLAY SYSTEM F-26 NUREG 0737 ITEM II.F.2.3 INADEQUATE CORE COOLING INSTRUMENTATION - GENER-IC LETTER 84 COMPLETED - LETTER TO PILANT DATED AUGUST 21, 1985 F-55 NUREG 0737 ITEM II.K.3.28 - VERIFY QUALIFICATION OF ACCUMULATORS ON ADS VALVES - COMPLETED - LETTER TO PILANT CATED AUGUST 9, 1985 F-71 DETAILED CONTROL ROOM DESIGN REVIEW PLANT SPECIFIC ACTIONS i
DRYWELL/WETWELL PRESSURE DIFFERENTIAL AND LEAKAGE MONITORING TECH SPEC CHANGES - COMPLETED - LETTER T0'PILANT DATED MAY 13, 1985 (AMENDMENT 91)
SNUBBERS AND RECIRC BYPASS - GENERIC LETTER 84 COMPLETED - LETTER TO PILANT DATED MAY 20, 1985 (AMENDMENT 92) 1
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CYCLE 10 RELOAD AND HYBRID CONTROL ROD ASSEMBLIES - COMPLETED - LETTER TO PILANT DATED JUNE 3, 1985 (AMENDMENT 93)
SINGLE-LOOP OPERATION TECH SPECS - COMPLETED - LETTER TO PILANT DATED SEPTEMBER 24, 1985-(AMENDMENT 94)
DIESEL GENERATOR TECH SPEC CHANGES - COMPLETED - LETTER TO PILANT DATED NOVEMBER 21, 1985 (AMENDMENT 95)
MAIN STEAMLINE HIGH FLOW ISOLATION TECH SPEC CHANGE - COMPLETED - LETTER TO PILANT DATED MARCH 17, 1986 (AMENDMENT 96)
TECH SPEC CHANGE TO CONSOLIDATE REFUELING REQUIREMENTS AND SPECIAL TEST REQUIREMENTS - COMPLETED - LETTER TO PILANT DATED APRIL 9, 1986 (AMEND-MENT 97)
HALON FIRE SUPPRESSION SYSTEM TECH SPECS - COMPLETED - LETTER TO PILANT DATED APRIL 10,1936(AMENDMENT 98)
APRM FLOW BIAS, ADS LOGIC, DEFINITION OF OPERABILITY, MISC. TECH SPEC CHANGES - COMPLETED -LETTER TO PILANT DATED MAY 19, 1986 (AMENDMENT 99)
ORGANIZATIONAL CHANGES, TURBINE STOP VALVE SCRAM, LIMITING CONTROL R0D PATTERN, INSTRUMENTATION TABLES, JET PUMP FLOW MISMATCH, TESTABLE PENE-TRATIONS, ISOLATION VALVES, AND WATER LEVEL FIGURE TECH SPEC CHANGES -
COMPLETED - LETTER TO PILANT DATED MAY 20, 1986 (AMENDMENT 100)
STATION BATTERY SURVEILLANCE PROPOSED TECH SPEC AMENDMENT - APPLICATION DATED APRIL 26, 1985 APPENDIX "R" EXEMPTION REQUESTS - COMPLETED - LETTER TO PILANT DATED AU-GUST 21, 1985 EMERGENCY PLAN EXERCISE - REQUEST FOR SCHEDULAR EXEMPTION - LETTER TO PILANT DATED APRIL 1,1985 EXTENSION OF DEADLINE TO COMPLY WITH 10CFR50.49 - COMPLETED - LETTER TO PILANT DATED MARCH 26, 1985 SECOND TEN-YEAR INSERVICE INSPECTION PROGRAM - COMPLETED - LETTER TO PILANT DATED JANUARY 27, 1986 SECOND TEN-YEAR INSERVICE TESTING PROGRAM - SUBMITTAL DATED APRIL 3, 1984 STANDBY GAS TREATMENT SYS, CONTROL ROOM VENTILATION, WATER LEVEL TRIP, E.Q., AND MISC TECH SPEC CHANGES - APPLICATION DATED APRIL 26, 1985 STATION BATTERY SURVEILLANCE TECH SPEC CHANGES - APPLICATION DATED APRIL 26, 1985 l
RECIRCULATION PIPING REPLACEMENT RADIATION PROTECTION PROGRAM - COMPLETED
- LETTER TO PILANT DATED JULY 31, 1985
i HIGH RADIATION AREA TECH SPEC CHANGES - APPLICATION DATED FEBRUARY 10, 1986 RESPONSE TO GENERIC LETTER 85-07 " IMPLEMENTATION OF INTEGRATED SCHEDULED FOR PLANT MODIFICATIONS" - LETTER TO H. THOMPSON DTD JULY 8, 1985 OTHER ACTIONS RESPONSE TO NRC REQUEST - CONTROL ROOM SURVEY BY ARGONNE NATIONAL LABORA-TORY - OCTOBER 3-4, 1985 RESPONSE TO NRC REQUEST - STATUS LISTING 0F MPA'S - LETTER FROM PILANT DTD MAY 30, 1986 RES?0NSE TO NRC REQUEST - ONE-YEAR HOURLY METEOROLOGICAL DATA ON MAGNETIC TAPE - LETTER TO PILANT DTD MAY 21, 1985
5.0 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
_ Responsiveness to NRC Initiatives
_ Staffing
_ Enforcement History Reporting and Analysis of Reportable Events
_ Statfing In addition, this evaluation includes an assessment of the District's house-keeping practices.
5.1 Management Involvement and Control in Assuring Quality The licensee's nuclear organization consists of three functional divisions reporting to the Vice-President-Nuclear. The three functional divisions are Operations, Services, and Quality Assurance (QA is a division-level organization reporting directly to the VP-Nuclear). The VP-Nuclear has a technical staff manager and senior nuclear advisor to assist in his overview of nuclear activities. The senior nuclear advisor maintains offices at both the site and general offices.
During the rating period, licensee management maintained a high level of in-volvement and attention to quality in issues of major safety significance. The licensee operates only one nuclear plant and has none under construction. The licensee's design staff is therefore relatively small and contractors are used extensively for engineering and maintenance activities. The licensee maintains blanket contracts with General Electric, Burns and Roe, and Stone and Webster to provide technical services, and calls in other contractors as necessary.
Licensee personnel thus devote most of their time to planning and to quality overview of contracted activities. This has resulted in a high level of performance.
In particular, the licensee has been relatively strong in the area of implementing plant modifications on an expeditious schedule.
The licensee's management personnel continue to maintain close contact and participation with nuclear industry groups involved in issues of safety sig-nificance. These include the BWR Owner's Group, Atomic Industrial Forum, In-stitute of Nuclear Power Operations, Seismic Qualification Utility Group, Nu-clear Transportation Group, Utility uclear Waste Management Group, Nuclear Fire Protection Owners Group, and Region IV Utility Group and Western Regional Utility Audit Group.
The licensee's nuclear management team has been effective in bargaining with the Board ot Directors for allocation ot funds to support activities which assure quality.
For example, during the rating period, the Board questioned the expense of INPO support. The licensee's management staff was effective in convincing the Board of the possible detrimental effects on safety and quality of withdrawal from INP0.
In order to further improve top management's involvement and control in nucle-ar matters, the District has hired a highly experienced consultant as special advisor to the chief executive officer.
The licensee is rated Category 1 for this attribute.
5.2. Approach to Resolution of Technical Issues from a Safety Standpoint In resolving technical issues relating to plant modifications, the licensee frequently adopts the industry position.
For example, in the case of ATWS (10 CFR 50.62) modifications, the District will perfonn the "Monticello" modifi-cations on Cooper. However, in the case of plant specific Technical Specifi-cations amendment requests, the licensee frequently requests clarifying changes which do not follow the Standard Technical Specifications (STS) guidance. In most cases, the existing level of safety would be retained or somewhat improved, but not to the extent as would be if the STS was adopted. An example is the licensee's application of February 10, 1986 relating to high radiation area administrative controls.
The licensee is rated Category 2 for this attribute.
6.3 Responsiveness to NRC Initiatives The licensee has consistently been responsive to NRC initiatives, from minor staff questions to implementation of major plant modifications. The licensee tracks all NRC initiatives and responds or complies within the requested due date, or identifies and negotiates with the NRC as necessary when unable to comply. Timely responses to NRC initiatives is considered one of the licensee's strengths. The licensee's response to our May 30, 1986, request relating to MPA status is an example. The licensee is rated Category 1 for this attribute.
5.4 Enforcement History The licensee's evaluation for t:is attribute is based on the licensees per-formance in the timely resolution and implemention of Multiplant Action Items.
The licensee provided status data for all MPA's via a letter from J. M. Pilant to W. O. Long dated July 2, 1986. The MPA's which were identified as not yet completed (excluding certain items for which the necessary actions have not yet been identified and approved in SERs) are as follows:
MPA TITLE Projected Completion A-02 Appendix I - RETS 7/86 B-41 Fire Prot Tech Specs 12/86 B-65 Pipe Breaks in Scram System 12/86 B-85 ATWS Scram Data Capability 7/86 E-86 ATWS SR Components 9/86 C-02 Recirc Pump Trip 12/86 F-09 SPDS 7/86 F-63 Technical Supp Center 12/86 F-65 E0F 12/86 F-68 Meterological Data Upgrade 12/86 F-71 DCRDR 2/87 All the above except F-71 have since been or will be completed during the 1986 outage. The licensee's performance is considered to be above average. The licensee is rated Category 1 for this attribute.
5.5 Reporting and Analysis of Reportable Events The Cooper Nuclear Station (CNS) was shutdown for scheduled refueling and maintenance outage for the first 61 months of the reporting period.
It Operated at power from July 1985 through July 1986 except for a shutdown of-
@Mt li months from September 5,1985 to November 22, 1985 due to high Mutations of the main turbine and for short periods at other times for other causes. Not counting the period of scheduled refueling outage, the plant operated with a Reactor Service Factor (Hours of Critical Operation / Total Hours) of approximately 85% during a period of about 101 months (from August 20, 1985 to June 30,1986). During the 18 months covered by this SALP eval-uation, the licensee reported 24 non-security occurrences, of which 18 were reported under the provisions of 10 CFR 50.72. The licensee also submitted 34 LERs (under 10 CFR 50.73) during this period. Eleven of these LERs related to the events reported under 10 CFR 50.72. Ot the 24 occurrences of reportable events, only two events related to scrams, eight to engineered safety feature (ESF) actuations and nine to events in which an LC0 was not met, requiring entry into a Technical Specification Action Statement.
Four of the events were classified as unusual events and five events were caused by personnel errors.
Only two scrams occurred from the last week of August 1985 to the last week of July 1985. This reactor trip frequency of two during about 12 months of actual operations of the plant is much lower than the national average of 5.9 scrams per reactor-year.
Three of the 8 events involving ESF actuations were caused by mechanical and electrical failures and the remainder were due to personnel error and other miscellaneous causes. Of the 34 LERs received during the report period, nine dealt with the inoperability of the high pressure coolant injection system, and four dealt with the reactor water cleanup system problems. Two of the 34 e
LERs were received late by about 3 m6nths beyond the-permissible 30-day periqd prescribed in 10 CFR 50.73.
Only one event was considered significant for, discuss. ion at the NRR Operatirig Reactor Eve'nts Briefing (OREB). The event occurred on June 16,.1986'and re-
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^ late'd to an excess unidentified react'or coolant system.(RCS), leakage. The; 8
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1 event was of interest because the plant operated for nearly 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> in a deinerted condition. The leakage was readily identified and repaired. No l
Technical Specifications were violated.
Availability Puring this SALP period the plant reported an overall availability factor of 51.6%. This result was arrived at by including approximately 7 months of scheduled refueling outage and about li months of plant shutdown caused by the problem of high vibrations of main turbine. The plant capacity factor for the year 1985 was only 15.7% using the design electrical rating (DER) net capaci-ty. The Year-to-Date Unit Availability Factor is 98.6%.
Dose The Cooper Nuclear Station started commercial operation in July 1974. Since 1975, the Cooper Station average occupational dose per unit electrical power production has been approximately 1.2 man-rem per MW-year.
The average total yearly dose has been approximately 590 man-rem.
Both of these dose values are significantly lower (by approximately 50%) than other operating BWRs. Howev-er, since 1983, the average total yearly dose at Cooper has been 1142 man-rem.
This is significantly higher than the average dose per BWR since 1983, which was 921 man-rem. A large portion of the additional collected dose at Cooper was the result of the recirculation pipe replacement project completed in 1985. The radiation protection plan for the pipe replacement outage was reviewed by the staff. The pipe replacement activity led to a dose of 1636 man-rem for 1985. Since a replacement project of this type has generally required approximately 1800 man-rem to complete, the Cooper total of 1636 man-rem is considered acceptabis. Excluding the 1636 man-rem pipe replacement exposure from the total man-rem makes the past three-year dose average for Cooper about equal to the average for operating BWRs. Since Cooper is an older plant a higher than average occupational dose level would normally be expected.
Conclusion Operating events at the Cooper Station appear to have been generally reported promptly, accurately and conservatively. The occupational dose history since 1975 indicates that the average doses are consistant with those for most operating BWRs. Based on our overall evaluation of the operating events and dose management the licensee is rated Category 2 for this SALP item.
5.6 Staffing During the major portion of the rating period the licensee maintained an enthusiastic, experienced licensing staff. However, toward the end of the rating period several experienced personnel were lost from the Nuclear Licensing and Safety Department, and'the forthcoming loss of the Technical Staff Manager was announced. These losses could have a detrimental effect on the next period, however, the licensee is taking actions which should have a beneficial effect. These actions include recruitment efforts and the possible physical relocation. of part of the Nuclear Licensing and Safety statt to the.
site.
In addition, the District is actively reviewing its salary and com-pensation practices for its nuclear personnel relative to those of other utilities.
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The licensee is rated Category 1 for Staffing in the area of Licensing Activi-ties.
5.7 Housekeeping The NRR Project Manager participated in an unannounced plant tour with the R-IV Branch and Section Chiefs on April 16, 1986. The plant was in power op-eration at the time. Housekeeping was observed to be above average. The licensee is rated Category 1 for this attribute.
6.0 CONCLUSION
An overall performance rating of Category 1 has been assigned for the func-tional area of Licensing Activities.
Section 042 of Manual Chapter 0516 defines the meaning of rating a licensee's performance Category 1 as follows: " Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented to-ward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or con-struction is being achieved."
Since the District was rated Category 1 in this area previously we plan no change in the less attention given by NRC to the District's licensing sub-mittals. We believe that no less management effort on the part of the licensee should be exerted in licensing activities.
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INFORMATION TO BE ADDED TO SECTION 5 0F SALP REPORT SUPPORTING DATA AND
SUMMARY
1.
NRR Site Visits / Meetings (Names refer to NRR participantsl Control Room Survey by NRR/Argonne Nat'l Laboratory, (J. Hayes) October 3-4, 1985 Emergency Preparedness Exercise, October 16, 1985 (E. Sylvester)
Inservice Testing Meeting,(W. Long & H. Shaw), April 14-17, 1986 Appendix R Audit (D. Notley and J. Kudrick), April 21-25, 1986 DCRDR Meeting (W. Long & D. Serig) May 12-16, 1986 2.
Commission Briefings None 3.
Schedular Exemptions Granted Annual Emergency Preparedness Exercise, Schedular Exemption, Letter from D. Vassallo to J. Pilant dated April 1, 1985 4.
Relief Granted Extension of Deadline for Environmental Qualification of Electrical Equipment, Letter from H. Denton to J. Pilant dated March 26, 1985 Temporary Waiver, Diesel Generator Annual Inspection, Memorandum from R.
Martin to H. Denton dated May 29, 1986 5.
Exemptions Granted None 6.
License / Technical Specifications Amendments Amendment 91, Letter from E. Sylvester to J. Pilant dated May 13, 1985 Amendment 92, Letter from E. Sylvester to J. Pilant dated May 20,-1985 Amendment 93, Letter from E. Sylvester to J. Pilant dated June 3,1985 Amendment 94, Letter form E. Sylvester to J. Pilant dated September 24, 1985 t
Amendment 95, Letter from E. Sylvester to J. Pilant dated November 21, 1985 Amendment 96, Letter from W. Long to J. Pilant dated March 17, 1986 t
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Amendment 97, Letter from W. Long to J. Pilant dated April 9, 1986 Amendment 98, Letter from W. Long to J. Pilant dated April 10, 1986 Amendment 99, Letter from W. Long to J. Pilant dated May 19, 1986 Amendment 100, Letter from W. Long to J. Pilant dated May 20, 1986 7.
Emergency / Exigent Technical Specifications Changes Single-Loop Operation, Amendment 94, Letter from E. Sylvester to J.
Pilant dated September 24, 1985 Main Steamline High Flow Sensor Setpoint, Amendment 96, Letter from W.
Long to J. Pilant dated March 17, 1986 8.
Orders Issued 3
" Order Modifying License Confirming Additional Licensee Commitments on Emergency Response Capability " letter from D.B. Vassallo to J.M. Pilant dated August 29, 1985 9.
NRR/ Licensee Management Conferences BWR Project Directorate #2 and Utilities, Licensing Issues Meeting, Bethesda, April 10, 1986 9
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