ML20238C693
| ML20238C693 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/12/1987 |
| From: | Haughey M Office of Nuclear Reactor Regulation |
| To: | Kane W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20238A944 | List:
|
| References | |
| FOIA-87-438 NUDOCS 8709100305 | |
| Download: ML20238C693 (9) | |
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Docket No.~50-410 PEPORANDUM FOR: William F. Kane, Director Division of Project and Resident Progrer.s THRU:
R. Wayne Houston, Deputy Director Division of FMR Licensing FR0t':
F.ary F. Haugtey, Proiect F.anager Project Directorate No. 3 Division of BWR Licensing SUFJFCT:
tiRR SALP INPUT - NINE PILE POINT NUCLEAR STATION UNIT ?
Encic5cd is NRR input for the ts'ine Mile Point Unit 2 SALP for the period of february 1, 1?P.6, through-Januery 31, 1987.
As discussed in our' enclosure,
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our evaluation ws conducted according to $RRl Office. Letter No. 44 dated December 22, 1906, and NPC Fanual Chapter 0516, Systetr4 tic l Assessment of Licensee Perfonnance.
p Mary F. Haughey,' Project Manager froject Directorate No. 3 rivision of BWR Licensing
Enclosure:
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Docket No. 50-410 FACILP :
Nine Mile Point Nuclear Station Unit 2 LICENSEE:
Niagara Mohawk Power Corporation EVALUATION FER100:
February 1, 1986, to January 31, 1987 PP0 JECT MANAGER:
Mary F. Faughey 1.
INTP.0 DUCT 10N This report contains NPR's input to the SALP review for the Nine File Point Nuclear Station Unit 2 (NMP-2).
The assessment of the licensee's performance was conducted according to NPR Office Letter No. 44, NP.R
. Inputs to SALP Process, dated December 22, 1986. This Office Letter incorporates FPC Manual Chapter 0516, Systematic Assessment o' Licensee Performance.
11.
SUMMAFY NRC Manual Cbspter 0516 specifies that each functional aree evaluated e
will be assigned a performer.ce category (Category 1, 2, or 3) based on a compesite of a number of attributes. The performance of the Aliagara P.ohawk Power Corporation in the functional aree of Licensing Activities for NMP-2 is rated Category 3.
Ill.
CRITERIA The evaluation criteria used in this assessment are given in $RC.Fanual Chapter 0516 Appendix, Table 1, Evaluation Criterialwith Attributes for Assessment of Licensee Perfomance.
IV.
METHODOLOGY This evaluation represents the integrated inputs of the Licensing Pro.iect Manager (LPP) and those fechnical reviewers who expended significant l
amounts of effort on NMP-2 licensing actions during the current ratirg period. Using the guidelines of NP.C Fanual Chapter 0516, %e 1.PM; each I
~ he~re1Rantllicensee..$gement applied specific
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reviewer and the.ir mana t
rfohbince3nijbktisZa1, f, or 3 to each attribute. The reviewers included this information as rett of each Safety Evaluation Report transmitted to the Project Director. The LPM, after reviewina the inputs of the technical reviewers, combined this infoma-tion with her own assessment of licensee performance end, arrived at a composite rating #or the applicant. A written evaluetion Was then prepared by the LPM and circulated to MF.R ranagement for coments. These comments were incorporated in the final draft.
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l The basis for this appreisal was the licensee's performance in. support; of licensing actions thtt were either completed or bad a significant level i'
of Etivity during 'the" current'r'ating' period. These actions are as
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follows:
fd. RespcNes_to the staff requests for information.Responms to outstan (IT
('3)~ Support for completion of, the staff review required to issue the
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~ low power license.
(4) Response to the downcomer supports issue.
(5)_ Support of the Main Steam Isola ion Valve (FSIV) review, t
Y.
ASSESSMENT OF pEPFORt%ME ATTRIBUTES The applicart's performance evalurtion is ba< sed on a consideration of four of the seven attributes specified in NRC Fanual Chapter 0516. There are:
Maragement Involvement and Control in Assuring Quality Approech to Resolution of Technical Issues from a Safety Standpoint.
Responsiveness to NRC Initiatives 5
Staffing events), no basis exists for an NpR(training, enforcement, and repo For the remaining three ettributes evaluation' for'the functional area of Licensing Activities.
Licensing Activities 1.
Management Involvement and Control ir Assuring Ouality Ucensing activities during this period were at a h~ieb level. Ihree safety evaluation supplements, several revisions' of thTTicEnical c
Specifications and the low power license were issued.during this period.
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Throughout the SALP period the licensingLstaff has not done an effec-tive.ich in_ keeping aware of events and problems that might affect licensing schedules and 'inf6fming 'NRC licEnsin'g inanaiement of those events. Evidence of this lack of effectiveness is as follows:
a) Despite a prearranged call the night before to check status, when the Licensing pro.icct Manager arrived on rite the next morning, she was informed the PSIV. ball she had travelled to see had been shipped out of town.
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l b) Since the low power operating license was issued for Nine Mile Point 2 on October 31, 1986, the licensing staff at Niagara Pohawk hr.s seemed generally unawere.of operating plant events. On a number of occasions, the NRC ProjectWeger has had to inform the licensing staff that an event has occurred when seeking additional information. These have included' events such as.MSIV actuations
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i and MSIV inplant tests.
c)
In the last few months, the plant staff began a practice of logging MSIV actuations in the plant. Recently, the NRC inquired attut how the licensing steff coordinating the prototype test pronram kept aware o' the number of actuations. When it appeared none had been established, the.WRC staff; reouested the licensee -
compile that information.and compare it to the predicted.actuations used'to establish the" number [of val _ve. cycles for the prototype,
test program.
Subsequently, the licensee reviewed the number of..
plant actuations'and agreed that,the number'of valve cycles'in the prototype program would need to be increased.
Inadequate exemption requests were provided by the license'e on more than one occasion. On May 7, 1986, the licensee submitted a request for an exemption to_1LCFR_50.57 for_ preoperational test deferrals despite the fact that the project manager had earlier informed the i
licensee thet 50.57 was an incorrect regulation to cite for the exemption. This regulation was also cited in similar exemption requests on July 2, 1986, and June 13, 1986 The August 22, 1986, exemption request for MSIVs also had to be resubmitted because the original request did not include such information as 11 for which regulations ttp exemption was being requested and 21 for what period of time.
(Reference 9/2/E6 summary of 8/27/86 meeting on this subject).
During the development of the Technical Specifications two key licensee individuals coordinated the efforts.
Frequent contact was provided with department managers, operations persont.el and consultants at Stone and Webster Engineering Corporation (SWEC). _ Communications on arameters for the Technical the subject of finalizing as-built plant p~dVi~ri"fWiie3 incre times S3ecificetionsweressitimes.c6MUsEfen than necessary but did~not~ affect ths~oie~ all' schedule. The licensee
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r provided extensive effort to certify consistency betw(en the Technical Specifications, the FSAR and the as-built plant.
The licensee management was ! supportive of the,1nanagement site visit in I
August 1986, and they have exhibited a continued interest in the status 1
of major critical issues that mipht affect plant operation schedules
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such as downcomers and.MSIVs.
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- , -7t In summary, additional manecement' attentioniisipeededjn the" licensing area'to ensure licepsi_.ng submittals are adequate and timely and that' licensing personnel maintain _an..a.wareness_of events that have a potential of. affecting licensing schedules.-
The rating for this attribute is Category 3.
2.
Approach to Resolution of Technical Issues from a Sefety Standpoint I
While the licensee's responses were geherally technically viable and l
sound, some incidences have irdicated a $.endency to. react to symptoms rather root causes. An example of this is the hydrogen recombiner issue where at least four separate; root causes were identified before i
l the problem was resolved.
Another example is the FSIVs' where concerns.were. addressed.on a piece-meal' basis only after a failure occurred, rather than performing a
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detailed design review to anticipate problems or improve maintenance.
For example, in the case of the NSIV actuator hydraulic fluid, it was discovered that the review of, and revisions to, procedures for maintenance and surveillance of the hydraulic fluid following the redesign of the actuator were to be delayed untilzafter the prototype test pronran (and after operation of the MSIVs1. When the 1.ieensing
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Project Manager questioned this she was told that $he delay'wes because this had not been specifically identified by'the NPC as an issue requked;foWritiEility;
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Another concern with the MS!Vs involved the Januaryil7,1987, sub-nittal on these valves. That submittal discus's'ed f, hie tests on the PSIVs which resulted in a final leakage of about 17 SCFH.
In a sub-secuent conference cell, the engineering manager identified that shirring had been used duripp the testing to simulate thermal growth.
This shiming was not discussed in any of the FSIV subnittals. It is not known if other technical details such as the shimming may have been left out of technical submittals.
On January 23, 1987, the applicent certified that the.MSIVs were operable. Subsequent to the rating period, on February 9, 1987, the NRC inquired about the environmental ~qdlification of the MSIV packing following its failure in the prototype test. On February 13, 1987, the licensee responded that environmentaliqualification of the packing was completed subseouent~ to the NRC's inquiry.
In conclusion, while extensive effort has been provided by the licensee in resolvirg MSIV problems and semelof theltechnical evalu-ations have been excellent, it does not appear that a well coordinated
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and thorough program has been developed for the review and control of these valves.
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Often where technical approaches are sound, several iterations of submittals are required because they are lacking in thoroughness or depth.
Extensive staff effort, therefore, has oft 6n been reouired to determine that the technical approach is sound. Examples of this were the review of Generic Letter 83-28 (ATWS), where panagement attention was reouested of the licensee by the NPC (Subsequent to that the sub-nittal was greatly improved.) and the f. ire protection program changes srbnitted shortly before licensing. This was also evident in the p comments to the SER submitted by the licensee.
Licensee proposed changes to the BWR standard. technical specifications were cenerally technically scund and showed a clear understanding of the effect of technical specifications on the safe operation of the plent.
In renclusion, while the luensee's. solutions and.. proposals are generally technically viable mod sound," additional. effort is needed to ensure submittals are complete and clear therehy reducing the iterctive review process.
The rating for this attribute is Category 3.
3.
Responsiveness to NRC Initiatives The licensee's submittals have frequently been untimely.
Pecause of I
poor planning by the licensee and a reluctance to provide realistic schedules, the staff's review of issues to support licensing milestones were constantly in a reactive / crisis mode through mest of the SALP period. Low power licensing occurred on October 31, 1986; and, while some of the delay may have been attributable to problems with the main steam isolation valves (MSIVs) discovered late in the summer, the delay from February to August 1986, should have been nore foreseeable.
In spite of this, the licensee would only admit to'a fuel load readiness schedule slippage in monthly or weekly increments. The result was inefficiently used NRC staff resources.
Exanples of this problem are:
- 1) the fire protection review (The staff was told a nurber of times that it~had the final submittal on the fire protection program only to be handed another one just as the safety evaluation was about to be issued. Evidence of this is the large number of letter commitments called out in the Fire Protection License Condition (15 letters)h
?) 155 SER comments were submitted Jul mainly on the,SER which was published in February 1985 (y 16, 1986,many of the referenc for requested SER changes were incorrect otunclear reouiring signifi-cant staff time for clarification 1; ard,3) MSIV. prototype valve test program comments were requested from the statf within one day of formal receipt of the program. While the above mentioned incidents were examples of the problem, there were many more incidents of this type durire the SAlp rating period.
In addition, elthough the licensee was requested by NRC management in Decenber 1985, to provide FSAR changes in a timely manner to avoid a
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large number of last ninute FSAR changes, resulting in a ),000_page FSAR amendment submitted December 24, 1985, the licensee subsequently submit'ted four sizable FSAR amendments and over 1,000 pages of FSAR changes by letter prior to licensing. These late subnitted FSAR changes required extensive staff efforts to gggplete_ reviews on a schedule consistent with' available~fUeT' load readiness schedules.
1 The licensee did provide technically sound and thorough responses concerning centrol room habitabil.i_ty when additional infomation was required as a result of containment bypass leakage rates revised by the licensee.
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In conclusion, while responses are generally.. technically viable they l
frecuently. require repeated submittals before a complete and clear response is received.
In addition'submittals are often not received ir a timely manner to support requested resporise dates.
The rating for this attribute is. Category 3.
4.
Enforcement History No basis exists for an NRR evaluation for the functional area of w
l.icensing Activities.
5.
_Peportine erd Analysis of Reportable Events No basis exists for an NPR evaluation for the functional area of "7
Licensing Activities.
6.
f t r.f fing While some members of the licensing staff were fa'miliar with plant design, the licensing staff did not display an in depth knowledge of liter. sing practices. Exemptions were frequently peorly written (e.g.,
MSI\\' and preoperational test deferrals).
The NMPC licensing staff did respond to a request by NRC staff to include "roadmaps" categorizing FSAR amendment changes but these roadmaps did not always prove _ reliable as_they occasionally referenced changes that were not submitted, neglected to include j
changes, or identified a significant safety change as editorial.
In addition, many o# the comments submitted'to the SER appeared to have been made by individuals who did not understand the. issue; and the comment had to be withdrawn.
While the licensee's staff has indeavored to be available and responsive to the staff on critical issues such as MSIVs and down-comers, they have frecuently requested even greater responsiveness
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For example, the licensee's staff has incently.shown up from out-of-town requesting unscheduled meetings with selected
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staff reviewers without prior notice ~. Also, es discussed earlier, the licensing staff does not maintain,a., current knowledge of plant _
events.
In conclusion, additional training in licensing practices:and NRC-regulations is recommended for the licensing staff as well as a mechanism for alerting the licensing. staff to events at the plant that may have an effect on'licerising schedules.
The rating for this ettribute is a Category 3.
7.
Training No basis exists for an NPP evaluation for the functional area of Licensing Activities.
8.
Conclusion On the basis of the above discussion an overall rating of'3 is' assigned in the Licensing Category.
Other Peview Areas Other areas identified by J. Linville for the SALP were:
Operations Maintenance Surveillance Radiation protection Emeroency preparedness Security and safeguards Assurance of quality Training Preoperational testing There is no basis for an NRR evaluation for these functional areas for this SALP rating period.
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I'nfomatinn to be Added to Section V of the SALP Repnrt
" Supporting Data and Sumnary" i
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NRR Licensee Peetings i
A large number of meetings were held with the applicant in Bethesda to resolve / discuss staff concerns. These are documented by meeting summaries.
2.
NRR Site Visits & Audits Licensing Project Manager Site Visit June 1986 Venagement Site Visit August 1986 Licensing Project Mar >ager Site Visit Septecher 1986 3.
Licensine Documents issued Final Draft Technical Specifications June 27, 1986 July 1986 SSER-3 Revisions to Final Draft Technical Specifications September 10, 11, & ?9, 1986 SSFP-4 September 1986 SSER-5 October 1986 October 31,;1986 Operating License Final Technical Specifications October 31, 1986
' Several Environmental Assessments in support of Throughout rating exemption requests period
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Licenser. Responses a.
Responses to requests for information b.
Resperses to SER concerns c.
Responses to concerns on MSIVs and dnwncomers d.
Major FSAR revisions e.
Comments on the draft Technical Specifications f.
Comments on the SER and supplements l
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