ML20245L216
| ML20245L216 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 06/29/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20245L209 | List: |
| References | |
| 50-282-89-01, 50-282-89-1, 50-306-89-01, 50-306-89-1, NUDOCS 8907050408 | |
| Download: ML20245L216 (30) | |
See also: IR 05000282/1989001
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SALP 8-
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SALP BOARD REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
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SYSTEMATIC-ASSESSMENT OF LICENSEE PERFORMANCE-
50-282/89001; 50-306/89001
Inspection Report Nos.
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Northern States. Power' Company
Name of Licensee .
Pr'airie Island Nuclear Generating Plant
Name of Facility
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December 1, 1987,'through April 30, 1989
Assessment Period j
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8907050400 890629
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TABLE OF CONTENTS
Page No.
I -. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . I
II. SUMMARY OF RESU LTS . . . . . . . . . . . . . . . . . . . . . 3
A. Overview . . . . . . . . . . . . . . . . . . . . . . . . 3
B. Other Areas of Interest . ............... 3
III. CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . 4
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IV. PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . 6
A. Plant Operations . . . . . . . . . . . . . . . . . . . . 6
B. Radiological Controls . . . . . . . . . . . . . . . . . 8
C. Maintenance / Surveillance . . . . . . . . . . . . . . . 10
D. Emergency Preparedness . . . . . . . . . . . . . . . . 13
E. Security . . . . . ..................14-
F. Engineering / Technical. Support . ............ 16
G. Safety Assessment / Quality Verification . . . . . . . . 20
V. SUPPORTING DATA AND SUMMARIES . . . . . . . ... . . . . . . 24
A. Licensee Activities . . . . . . . . . . . . . . . . . . 24
B. Inspection Activities . . . . . . . . . . . . . . . . . 25
C. Escalated Enforcement Actions . . . . . . . . .. . . . . 26
D. Confirmatory Action Letters (CALs)' . . . . . . . . . . 27
E. License Amendments Issued . . . . . . . . . . . . . . . 27
F. Review of Licensee Event Reports . . . . . . . . . . . 27
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. I. INTRODUCTION
L The Systematic Assessment of Licensee Performance (SALP) program is an
l integrated NRC staff effort to collect available observations and data
l on a periodic basis and to evaluate licensee performance on the basis
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of.this information. The i rogram is supplemental to normal regulatory
processes used to ensure compliance with NRC rules and regulations. SALP
is intended to be sufficiently diagnostic to provide a rational basis for
allocating NRC resources and to provide meaningful feedback to the licensee's
management regarding the NRC's assessment of their facility's performance
in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on
June 15, 1989, to review the observations and data on performance, and to
assess licensee performance in accordance with the guidance in NRC Manual
Chapter 0516, " Systematic Assessment of Licensee Performance." The
guidance and evaluation criteria are summarized in Section III of this
report. -The Board's findings and recommendations were forwarded to the
NRC Regional Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance
at Prairie Island Nuclear Generating Plant for the period December 1, '1987,
through April 30, 1989.
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The SALP Board for Prairie Island was composed of: -
Name Title
C. J. Paperiello Deputy Regional Administrator
- C. E. Norelius SALP Board Chairman, Director, Divi.; ion-
of Radiation Safety and Safeguards (DRSS)
- E. G. Greenman Director, Divison of Reactor Projects (DRP)
- H. J. Miller Director, Division of Reactor Safety (DRS)
- W. L. Axelson Chief, Reactor Projects Branch No. 2
- L. R. Greger Chief, Reactor Programs Branch
- R. W. Cooper, II Chief, Engineering Branch
- G. C. Wright Chief, Operations Branch.
B. L. Burgess Chief, Projects Section 2A l'
- J. E. Hard Senior Resident Inspector, Prairie Island
- L. A. Yandell Acting Project Director, Project
Directorate III-1, NRR l
- D. C. Dilanni Project Manager, NRR
M. P. Phillips Chief, Operational Programs Section
D. H. Danielson Chief, Materials and Processes Section
M. C. Schumacher Chief, Radiological Controls and Chemistry
Section
T E. Vandel Reactor Inspector, DRS j
M. A. Kunowski Radiation Specialist, DRSS
R. N. Sutphin Project Inspector, DRP -
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.. C.'D.'Pederson Reactor Engineer, DRP. l
P. L..Hartman Senior. Resident Inspector, Monticello l
M. J. Smith Emergency Preparedness Specialist, DRSS
D. Funk Security Specialist, DRSS
J. L. Belanger Security. Specialist, DRSS
T. J. Madeda Security Specialist, DRSS
M. Moser Operations Engineer, NRR
T. Tella Reactor Inspector, DRS
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- Denotes voting members. (
- Denotes voting member for Ra?lological Controls, Security and
- Denotes voting member for Maintenance and Surveillance.
- Denotes voting member for Engineering and Technical Support.
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II. SUtiMARY OF RESULTS
A. Overview
This assessment period is from December 1,1987, through April 30,
1989. During this period, both units at Prairie Island operated
continuously, indicative of the licensec's effort and commitment to
the trip reduction program.
The areas of Radiological Controls, Emergency Preparedness and,
Maintenance and Surveillance each received a SALP Category 1,
remaining at a consistent level of good performance. Overall
performance in the Maintenance area was determined to be stronger.
than the performance observed in the Surveillance area. The area of.
Plant Operations improved to a SALP Category 1, primarily due to the
improvement in management oversight of this area. Two new areas
were rated this SALP period; Engineering / Technical Support and
Safety Assessment / Quality Verification, receiving SALP 2 and
SALP 1 ratings respectively. Security was rated a SALP 2, a decline
from the previous assessment period. The decline in this area was
attributed to a. lack of timely corrective action to address equipment
aging problems and a decline in enforcement history.
The performance ratings during the previous assessment period and
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this assessment period according to functional areas are given below:-
Rating Last Rating This
Functional Area Period Period Trend
Plant Operations 2 1
Radiological Controls 1 1
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Maintenance / Surveillance 1/1 1
1 1
Security 1 2
Engineering / Technical Support NR -2
Safety Assessment / Quality NR 1
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Verification 1
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B. Other Areas of Interest
None.
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III. CRITERIA
Licensee performance is assessed in selected functional areas. Functional
areas normally represent areas significant to nuclear safety and the
environment. 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.
The following evaluation criteria were used to assess each functional
area:
1. Assurance of quality, including management involvement and control;
2. Approach to the resolution of technical issues from a safety
standpoint;
3. Responsiveness to NRC initiatives;
4. Enforcement history;
5. Operational events (including response to, analyses of, reporting
of, and corrective actions for);
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6. Staffing (including management); and ,
7. Effectiveness of trcining and qualification program.
However, the NRC is not limited to these criteria and others may have
been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is
rated according to three performance categories. The definitions of
these performance categories are as follows:
Category 1: Licensee management attention and involvement are readily
evident and place emphasis on superior performance of nuclear safety or
safeguards activities, with the resulting performance substantially
exceeding regulatory requirements. Licensee resources are ample and
effectively used so that a high level of plant and personnel performance
is being achieved. Reduced NRC attention may be appropriate.
Category 2: Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are good. The
licensee has attained a level of performance above that needed to meet
regulatory requirements. Licensee resources are adequate and reasonably
allocated so that good plant and personnel performance is being
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Category 3: Licensee management attention to and involvement in the l
performance of nuclear safety or safeguards activities are not* '
sufficient. The licensee's performance does not significantly exceed
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. that needed to meet minimal regulatory requirements. Licensee resources
appear to be strained or not effectively used. NRC. attention should be
. increased above normal levels.
' The SALP report may include an appraisal of the performance trend in a
functional area for use as a predictive indicator if near-term performance
is of interest. Licensee performance during the last quarter of the
assessment period should be examined to determine whether a trend exists.
Normally, this performance trend should only be used if both a definite
trend is discernible and continuation of the' trend may result'in a change
in performance rating.
The trend, if used, is defined as:
Improving: Licensee performance was determined to be improving near the
close of the assessment period.
Declining: Licensee performance was determined to be declining near the
close.of the assessment period, and the licensee had not taken meaningful
steps to address this pattern.
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IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
Evaluation of this functional area was based on the results of
112 inspections by the resident-inspectors and two inspections
by regional inspectors.
Enforcement history in this' function &1 area during the'
assessment period was excellent with no violations identified.
During the previous assessment period,.five violations were
identified.
No reactor trips were experienced by either unit during the i
17-month assessment period. .The last reactor trip: occurred {
prior to the beginning of the SALP. period in July.1987. During'
the previous assessment period, there'_were four reactor trips
and in the-period beforeLthat one, there were six. trips. ~ Thus, .
continuous improvement'has been made regarding this area over j
the past three years. .)
Plantwide housekeeping. continues to. improve. Paint crews were ~
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active continually,'especially in the auxiliary building.
Improvement was seen in the rate of cleanup following outages. ,
During the regional fire protection inspection, a walkthrough of- i
the screenhouse and the turbine and auxiliary buildings determined '
that the presence of combustibles.and other fire hazards were
kept to a minimum. Also witnessed during the fire protection
inspection were two firefighting training evolutions .that were .
conducted, in part, to satisfy the NRC annual . fire brigade - -
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training requirements. .This type of. training was viewed.as J
very realistic and was conducted in a professional . manner by l
knowledgeable fire instructors.
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Staffing for plant operations continues to improve. At the.end
of the assessment period, the operations staff numbered 207, up ;
from 99 at the end of the last period. Also, new employees were '
hired into Operations only after' satisfactorily passing !
comprehensive psychological and aptitude examinations, which is a !
procedure that was instituted during the period. Although
the total number of licensed reactor operators (R0s) and senior
reactor operators (SR0s) remained about constant, the number
of operator license candidates more than tripled from 6'to
19 during the period. This interest in. obtaining licenses
ultimately will relieve, to some extent, the amount of overtime
currently being worked by the' licensed operators. Of the 24%
overtime expended during the assessment period, 63% is outage
related and 37% non-outage. Another improvement instituted was
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the full implementation of the Shift-Manager program on
September 1,1988. With this program, ecch crew has assigned
to it a-degreed Shift Manager in addition to the Shift Supervisor
for each unit.
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During the assessment period, five SR0 and six R0 replacement i
examinations were given. Three SR0 and four RO candidates passed l
the examinations for a passing rate of 64%. As these results
were below the industry average, the licensee closely analyzed .
the examination results, reviewed the training practices, and i
established more rigorous standards for candidates in training !
for NRC examinations. ,
The licensee was generally very responsive to NRC initiatives. f
The following are examples of licensee's responsiveness; i
improvements in the control room arrangements per human factors j
engineering recommendations; modernization of work stations for '
reactor operators; incorporation of Westinghouse Owners
Group Emergency Response Guidelines IA (ERG-1A) into updated )
Emergency Operating procedures; installation of continuous i
monitoring of thermal reactor power and meetings with the
operations staffs of other 2-loop Westinghouse designed plants.
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Luring the assessment period, Licensee Event Reports (LERs) ,
were written for three events involving errors by Operations
personnel. All of these were relatively minor events: the )
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automatic start of a d.esel-driven cooling water pump when an j
improper valving sequunce was used, the failure to log one
reactor: parameter over a 2-hour period when the plant process
computer was temporarily inoperable, and the automatic start of
the D1 diesel generator as the result of missing a step _in a
test procedure. In the previous assessment period, there were
five such events involving personnel error.
The operating crews continue to perform in a professional
manner. New signs have been posted in the control room that
direct all control room visitors to obtain permission before
entering the operators' area. This control- of visitors helps
to minimize distractions to the operators. Another example of
good professional performance was the discovery by operators of
Foxboro controllers that were not performing their intended
safety function. The controllers in question monitor axial
flux tilt and are to initiate protection system action when a
tilt becomes severely pronounced. During a period of severe
flux tilt, the operators noted that one of four such controllers
was not responding as it should. This observation led to the
detection of an installation error that had been in existence
for several years. Another positive attribute that has been
noted is that senior Operations management is closely involved
with plant operation and interacts with the operatint) crews
nearly daily.
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Unit availabilities at Prairie Island during the assessment
period were 92.1% and 85.6% respectively for Units 1 and 2.
Forced outage rates for the two units were 0.4% and 0.78% for
the period.
2. Performance Rating
The licensee's performance is rated Category 1 in this
functional area. The licensee's performance was rated
Category 2 in the previous assessment period.
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3. Recommendations
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None.
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B. Radiological Controls _
l 1. Analysis
Evaluation of this functional area was based on the results of
three inspections by regional inspectors and observations by
the resident inspectors.
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Enforcement history in this functional area remained excellent -
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with no violations in the current 17-month assessment period
and none during the previous 18-month assessment period.
Staffing continues to be a licensee strength. The radiological
control staff is well-trained, experienced, with low turnover.
Strained labor management relations in the chemistry group were
noted early in the SALP period; however, work performance does
not appear to have been affected and the problems were essentially
resolved by the end of the SALP period. An experienced,
professionally certified health physicist was added to the
radiation protection staff late in this assessment period.
Although the radiological control staff is relatively small, it
communicates well internally and with other departmental staffs.
A total of five LERs related to this functional area were
submitted during the assessment period. Only one of these, a
late analysis of the contents of the gas decay tanks, was the
result of personnel error. One licensee event was reported in
this functional area during the previous assessment period.
Management involvement in ensuring quality was good during this
period. The strained labor / management relations in the chemistry
area revealed some management weaknesses, however, licensee-initiated
corrective actions were comprehensive and appeared to have
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resolved the issues. During non-outage times, there are frequent-
short discussions with the staff on current work activities,
future plans and improvement items.
Licensee responsiveness to NRC concerns was good. The licensee
improved laundry equipment and monitoring techniques and i
significantly reduced the number of personnel contaminations
resulting from laundered protective clothing. Good performance
also included prompt correction of NRC-identified errors in
effluent release reports and a licensee commitment to evaluate
and correct, as appropriate, the air cleaning . systems' charcoal
absorber testing program.
The licensee's approach to resolution of technical issues
continues to be good. Collective person-rem doses for the last
two years (1987-1988) were 134 and 199 respectively. These were
very low cumulative doses which reflect the effectiveness of the 1
as-low-as-is-reasonably-achievable (ALARA) program and an - ;
experienced plant staff. The licensee's contamination control 4
program continues to be very effective in maintaining the clean. '
areas of the plant, keeping the contamination in contaminated-
areas very low, and minimizing the number of personnel
contaminations. No problems were identified with solid radwaste
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or the radioactive waste transportation programs. Liquid and. ,,
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gaseous releases continue to be very low with resulting offsite
doses generally less than 0.1% of allowed limits. Good
performance also included increased use of computer technology
to generate radiation work permits, calculate air sample data,
improve oversight of the gaseous and liquid radioactive
effluent release program, schedule work, and trend data. It
was noted, however, that certain chemistry records were maintained
only on electronic media without hard copy backup and were not 'j
protected from deletion or change. This practice is a weakness '
and is inconsistent with normally accepted quality assurance
(QA) practices.
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Revision 9 to the Northern States Power Company (NSP) Offsite
Dose Calculation Manual (0DCM) has been reviewed and 13
discrepancies were identified, most of which were of a technical
nature and should have been addressed by the licensee in the
original submittal. This report has been transmitted to the
licensee with a request to consider the comments and suggestions
made, and to revise the ODCM as appropriate.
The effectiveness of the licensee's training and qualification
program has been good. Appropriate continuing training is
provided for the staff.
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The quality of radiological confirmatory measurements is very
good with 45 agreements in 47 comparisons. The licehsee's
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counting room quality control (QC) program was instrumental in
detecting an irregularity in one of the monitored gamma
spectroscopy parameters and effecting an investigation into
the cause.
2. Peformance Rating
The licensee's performance is rated Category 1 in this
functional area. The licensee's performance was rated
Category 1 during the previous assessment period.
3. Recommendations
None.
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C. Maintenance / Surveillance
1. Analysis
Evaluation of this functional area was based on the results of
12 inspections conducted by the resident inspectors and seven by
regional inspectors. Maintenance and surveillance were separate
functional areas in the previous assessment period but have
been combined as one functional area for this assessment period.
Enforcement history in this functional area during this
assessment period indicated a decline. Seven Severity Level IV
violations were issued, compared to a total of three Severity
Level IV violations in the maintenance and surveillance areas
in the previous assessment period.
All of the violations were in the surveillance area. Four of
the violations resulted from the inspection of Unit I containment
integrated leak rate testing in 1988. The violations involved
failure to perform required local leak rate testing of selected
penetrations (electrical penetrations going back to 1983),
improper calibration of the flow meters, lack of required
capability to perform data reduction calculations, and improper
valve lineup. One violation was the result of engisiaered safety
features (ESF) bus relay testing which momentarily disabled the
bus while one of the emergency diesel generators (DG) was out of
service. Other violations were for routine testing not being
performed on the double doors to the shield building and on the
auxiliary building special ventilation zone, and failure to
perform testing of a containment airlock door. These violations,
related to surveillance activities during the assessment period,
are not indicative of a significant generic weakness in the
administration of the program. Routine surveillance are
generally performed on schedule and the results carefully
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reviewed by cognizant personnel to assure that regulatory and
performance requirements are met.
Operational events in this area did not indicate any pervasive
problems in the licensee's control of maintenance or surveillance
activities affecting plant operations. Of the 18 LERs issued
during this period, six involved this functional area. Four
were in the maintenance area including one due to equipment
failure. .Two LERs involving missed surveillance were the
result of personnel error. The reported events were not
considered to be safety significant except for the failure to
close of the Unit 2 emergency DG output breaker. None of these
events.resulted in a reactor trip. The,11censee's performance
in this area was slightly better than the previous'SALP period,
during which nine LERs were issued and two reactor scrams
occurred.
Management involvement to assure quality in the maintenance area
was very good. The maintenance program was effective and
properly implemented during this assessment period, although
some procedures for motor operated valve (MOV) maintenance were
noted as needing improvements. Work backlogs remained very low-
as in previous assessment periods. At the end of.this period,
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only one week's backlog of safety-related and balance-of plan.t .
maintenance was outstanding. Additionally, none of the preventive
maintenance items (PMs) was overdue and very little rework (less
than 0.5%) was required during this assessment period.
In the area of surveillance, plant management was actively
involved in assuring water quality. Water chemistry data was
reviewed daily by laboratory management and weekly by plant
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management. Corporate management committed to the Pressurized
Water Reactor (PWR) Owners Group Guidelines and overall quality
was generally maintained well below action levels. However, in-
the area of leak rate testing, the licensee's performance during
the early part of the assessment period required improvement,
since the licensee's consultant did not.have the capability to
perform all the required data reduction calculations that
resulted in improper implementation of the Type B and C leak
rate testing program. Improvement was noted in this area during j
the performance of leak rate testing in the latter part of the ?
assessment period. As mentioned previously, routine surveillance
were conducted in accordance with regulatory and performance
requirements.
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Plant staffing in the areas of maintenance and surveillance,
including inservice inspection (ISI) and chemistry appeared to
be adequate. One exception noted was during the Unit 1 leak
rate test. The engineer in charge of the test had to cover
other areas of work. This problem was. corrected during the
leak rate test of Unit 2 conducted during the latter part of
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. the assessment period. The engineers assigned to the leak rate i
tests had a good knowledge'of the equipment.used but only a i
fair knowledge of the regulations (10 CFR 50, Appendix J). )
The maintenance and surveillance staffs including ISI and
chemistry staff appeared to be qualified and adequately trained j
in their fields. The effectiveness and experience of the- ]
craftsmen at Prairie Island were reflected in the excellent
overa11' performance of the plant. Forced outage rates were very
low and the plant experienced no reactor trips during the
period. Emergency DG availability was also good.
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Overtime hours for the craftsmen assigned to Prairie Island i
remained low. Overtime worked at the plant amounted to about 7% j
of the regular hours for.these individuals. Of this 7%, 65% was ;
outage related and 35% non-outage. Turnover rates of staff were i
very low.
The licensee's responsiveness to NRC initiatives was generally I'
good. Some examples were the licensee's actions in providing a
continuous pre-lube for the Fairbanks-Morse engines of the ;
DGs, improvements in Limitorque valve maintenance program, and 1
prompt corrective actions for the problems identified during- J
Unit 1 containment leak rate tests. The'. licensee joined the ~
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Westinghouse Owner's Group and.also promptly instrumented the~' {
Unit 2 surge line with resistance temperature detectors during j
the April 1989 refueling outage. .j
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The licensee's identification-and resolution of technical issues
in this area was generally timely and adequate. The system
engineer concept has worked well at this station.' The system
engineers were involved in all phases of maintenance activities -
including review of completed mintenance. The engineering.
group was involved in failure tri.nding and predictive maintenance,
which has contributed well to the goals of low equipment i
unavailability and reduction in forced outage rate.
Several plant improvements made during the assessment period !
were expected to improve the plant availability. The improvements
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included a pre-lube system for the DGs, improved seals' for the ' ,
charging pumps, and Unit 1 steam generator tube sleeving. i
2. Performance Rating
The licensee's performance is rated Category 1-in this area.
The licensee's performance was rated Category 1 in both Maintenance
and Surveillance 4 the previous assessment period.
3. Recommendations
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1. Analysis q
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Evaluation of this functional area was based on the results of j
one emergency preparedness (EP) exercise evaluation and ;
one routine inspection conducted by regional inspectors.
Enforcement history in this functional area remained the same,
with no violations identified during this or the previous
assessment period. All concerns identified during the previous
assessment period were resolved in a timely manner.
No inspection concerns were identified during the 1988 routine
inspection; however, one concern identified during the 1988 exercise 1
remained open for evaluation during the next annual exercise. i
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Management support of the EP program remains excellent at this
facility- and various program requirements remain part of daily j
plant surveillance and operations. Plant management has- l
approved and developed several EP program enhancements during ;
this assessment period. The Technical Support Center (TSC) was j
evaluated by an outside human factors consulting firm. This 1
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evaluation led to the relocation of emergency response system- ~
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computers, the development of a command and control area,_
enlargement of the NRC work area and the addition of telephone
jacks in the command and control area for NRC use. As a~ result
of the most recent emergency exercise, concerns remain relative
to the noise level in the TSC and the physical size of the EOF
to adequately accommodate a large response of licensee, State, )
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County and Federal personnel during an actual emergency. )
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The licensee's resolution of technical issues from a safety' )
standpoint was good as evidenced by the timeliness and i
thoroughness of corrective actions of all NRC and self-identified ;
concerns. Tracking systems were used effectively to track
corrective actions taken on items identified during previous
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inspections and also on items identified by a strong plant
audit program.
Events that resulted in the activation of the emergency plan
were properly identified and classified. Offsite notifications,
including those to the NRC, were made within the required time
frame. The prompt notification system was upgraded to prevent
operational problems that were encountered during ice storms.
This upgrade was accomplished within four weeks of self-
identification of the problem and was considered timely in view
of the amount of research and procurement that was necessary to
solve this concern.
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Staffing of the Emergency Response Organization (ER0) has
remained excellent throughout the assessment period. The
licensee has maintained a current roster of qualified personnel
to fill key positions in the emergency organization. A strong
offsite liaison program that supports the States of Minnesota
and Wisconsin and their respective counties is maintained by-
corporate management. The licensee assisted offsite support
groups in their efforts to improve their 1989 performance in
several ways. -A questionnaire was distributed to all offsite
groups to assess their needs, joint workshops were held to
coordinate work efforts, and cross training with each State was
conducted quarterly in an effort to improve communications
between utility personnel and offsite support groups.
Training and drill records indicated an excellent level of- staff
participation in training and drills. Interviews with various i
ERO personnel indicated a good awareness.of their emergency.
responsibilities. These results indicate an excellent.in-depth-
,
training and drill program and strong management support ~for
l the EP program. The licensee also successfully used the
!
training center simulator for emergency plan drills and
exercises. The simulator was programmed to drive actual l
displays'in the TSC and emergency offsite facility to enhance
'
! the realism of the drills and exercises. This program includes ~
F -
the capability to run the E0Ps on the plant simulator. The
,
exercise performance was very good, although the scenario was
l of average difficulty.
j. 2. performance Rating
The licensee's performance is rated Category 1 in this area.
The licensee's performance was rated ; Category 1 in the
previous SALP assessment period.
3. Recommendations
None.
E. Security
1. Analysis
l
Evaluation of this functional area was based on the results of
three routine security inspections by regional inspectors and
on routine observations of security force activities by the
resident inspectors.
A decline in the licensee's enforcement history was noted
during the assessment period. One Severity Level III and
three Severity Level IV violations were identified compared
14
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]
,
.
..
..
.
with no violations identified during the previous assessment
period. The Severity Level III violation involved the
. premature granting of unescorted access.to an unauthorized
individual as a result of a corporate administrative error.
The civil penalty for this violation was mitigated _in its i
entirety because of tSe licensee's' prompt and extensive j
corrective _ action and past excellent performance in the area- 1
of security. Although the violation was discovered and .!
logged by the licensee,-the licensee failed to. recognize the 'l
deportability of the issue. '
j
Management's role in assuring quality was mixed. Both corporate
and plant management were supportive of the security program as
evidenced by the allocation of additional personnel and material
resources. In response to an NRC identified weakness, the . 1
licensee, with the assistance of a security consultant, conducted
..
an assessment of the protected area barrier and intrusion alarm
system which resulted in the installation of several upgrades.
The exterior barrier upgrade project resulted in an innovative
and effective deterrent.to prevent penetrations-of.the perimeter. !
In contrast, cencerns identified in the previous assessment
period, for the Secondary Alarm Station (SAS) relocation and
computer replacement still remain open.
- - ~
The licensee's security event reporting program was genera 11y'
adequate and reports were timely andLaccurate. There was !
one security event report made during the assessment period. 11
As noted previously, one _ security' event was not reported as it. l
should have been which_ detracted from an otherwise sound program. )
This action resulted.in a violation and a procedural modification j
to the licensee's sec: rity' reporting program. In general, ;
security-related records were complete, adequately maintained,
'
j
and available for NRC review. !
The licensee's approach to the resolution;of technical issues
l
was good. The perimeter alarm system is aging bat with frequent
attention, generally continues to provide the necessary detection !
capability. Maintenance support was closely monitored and a
consultant was retained to conduct'a complete component
evaluation of the system. The technical support to the computer
replacement project has been excellent. The implementation of
the miscellaneous safeguards amendments were technically sound
and timely. ,
The licensee's responsiveness to NRC initiatives.was exec 11ent.
Security management, both at a corporate and site level, is
cognizant of and responsive to security findings. The licensee's
response to enforcement issues, licensing matters, and inspection
findings were generally technically sound and timely. The
security superintendent's reviews of five published'HRC
15
.
!
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. . 1
..
1
i
l
1
- Information Notices were comprehensive. However, the SAS issue 1
identified by the Regulatory Effectiveness Review (RER) team has
.
]
remained open since 1985. Although extensive, the project has j
gone beyond the established schedule and the licensee failed to _ j
notify the NRC of having exceeded the commitment date. Additionally, i
the computer replacement project has continued for two years.
The licensee is in the early stage of developtag a performance
monitoring program, which should improve licensee response in .,
this area. 'l
Security staffing levels are adequate to ensure a level of
performance that meets regulatory requirements. The site
security. staff was increased in order to address a problem
similar to a problem identified at Monticello. Although the
contractor providing uniformed security services was changed-
during the assessment period, the transition was smooth and j
without impediments as a result of close coordination with i
various levels of licensee management. . Security force training I
continues to be good. The tactical contingency training drill
involving FBI, local law enforcement and site security exceeded
the licensee's commitment.
2. Performance Rating ,
l
H- The licensee's performance is rated Category 2 in this area. -
l- The licensee's performance was rated Category 1 in the previous ,
SALP assessment period. This decline in performance was due to
lack of timely corrective action to address equipment aging
problems and a decline in enforcement history.
l 3. Recommendations
None.
J
l
l F. Engineering / Technical Support
]
1. Analysis
!
This is a new functional area and consequently was not rated in 1
l previous SALPs. Evaluation of this functional area was based J
on the results of eight routine inspections, including an ,
E0P inspection by regional inspectors, a procurement inspection i
by the Office of Nuclear Reactor Regulation (NRR) and several
inspections by the resident inspectors. ;
Enforcement history during this SALP period included three
severity level IV violations. Since this area was not rated
during previous assessment periods, no prior enforcement
history is available for comparison. Confirmatory Action
Letter (CAL) RIII-87-013 relating to operator licenstng issues
l in the previous SALP period was satisfactorily closed during
l this period.
16
_ _ _ _ _ _ _ - _ ___-__ __________________ _
._.
-
. .
, .
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i
Two events requiring the submittal of LERs in this' functional
area occurred during this assessment period. One resulted from
an incorrect change made to a surveillance procedure and the
other involved incorrect bolting materials on the secondary
side steam generator manways. The latter' event stemming from
an initial construction error was of limited safety significance.
i
Management involvement to easure quality in this functional area
was mixed. The system engineer concept utilized by the licensee
contributed significantly to the plant's ability to routinely
conduct refueling and maintenance outages in 30 to 35 days'.
Examples of system engineer contributions included identifying
the wrong bolting material for steam generator secondary manways
before installation and a special analysis of a Unit 2 extraction-
bellows that identified a fatigue failure design weakness. For- 1
IE Bulletin (IEB) 79-14, there was consistent evidence of prior ;
planning and assignment of priorities for activities, and the 3
activities were controlled by well-stated and explicit procedures.
NSP corporate management has been actively involved in improving
the training program and has maintained interaction to address
operator licensing problems in the performance of operator
exams.
- - On the negative side, the results of the NRR Vendor Inspection .
Branch inspection indicate that weaknesses' existed in the areas l
of procurement and dedication of. commercial grade items and l
interfaces between NSP and its vendors. The inspection team I
identified significant deficiencies-in the procurement of
commercial grade items for eventual use in-safety-related
application.s. The deficiencies included the failure to properly
dedicate and provide documentation for commercial grade items
procured for use in safety-related applications. NSP failed to'
perform documented technical evaluations to identify attributes
such as the components' safety functions and critical-
characteristics, verifications of design and manufacturing / material
changes, and receipt inspection requirements beyond, generally,
a part number verification and a check for physical damage and
cleanliness. This resulted 1- the utilization of numerous
components of indeterminate quality and qualification in
safety"related applications.
The review of the vendor interface program also identified a
weakness in which certain vendor communications received at NSP
describing potential safety concerns were improperly and
incompletely assessed for their applicability. The inspectors
also identified several assessments that lacked the necessary
l level of documentation to permit clear understanding of the
- disposition. For example, NSP failed to perform documented
- e
17
_ _ _ _ _ _ _ _ _ _
_
_ _ _ _ _ _ _ _ _ _ _ _ - _ -
.
.
..
.
assessment of 17 Colt /FMED Services Information Letters (SIls)
for their applicability to the emergency diesel generators.
The licensee's resolution of technical issues was mixed. The
backlog of safety-related plant modifications remained manageable.
About 150 modifications were in process at the end of the
period. Of this amount, 47 were considered significant based on
cost or regulatory impact. Reevaluations of as-built safety-related
piping systems, performed by the licensee as a result of discrepancies
identified by the vendor regarding weight and center of gravity
with Copes Vulcan valves, in some cases exceeded USAS B.31.1.0 1976
i allowable stresses. As a result, the licensee was requested to
I submit to the NRC a justification for continued operation (JCO)
I
'
including acceptance criteria when encountering similar stress
level discrepancies. The licensee's initial response was found
to be unacceptable, and revised criteria were proposed and
ultimately accepted by the NRC. All post-fire safe shutdown
capability (10 CFR Part 50, Appendix R) technical issues were
resolved during this period. Technical support for those
resolved issues was excellent. One nontechnical issue remains
open.
During the SALP period, many examples of good quality engineering
- ~
work were evident in the management and resolution of licensing
issues. A licensee submittal in response to 10 CFR 50.62 ~ ~
anticipated transient without scram requirements, a Technical
Specifications (TS) change request based on the new 10 CFR Part 50,
Appendix K evaluation model for upper plenum injection, a
submittal involving the periodic surveillance requirement for
turbine valve testing, and the high flux range monitor low
setpoint submittal were all examples of high quality engineering.
The licensee's responsiveness to NRC initiatives was generally
good. Resident inspector questions related to the plant design
maximum cooling water inlet temperat.ures raised during the 1988
summer drought were researched and satisfactorily answered
in just a few days. Prairie Island was one of the first plants
to be audited by the NRC E0P inspection team that had incorporated
the Westinghouse Owners Group Emergency Response Guidelines 1A
(ERG-1A). In anticipation of this inspection, the licensee
conducted in April 1988 an audit of their E0P program,
procedures and activities. A1 action plan to correct the
numerous program and operations deficiencies was developed.
Additional concerns identified during the NRC E0P inspections
were subsequently added to those licensee items identified for
resolution. The licensee has implemented a very thorough and
technically sound approach to resolve the recent IEB 79-14
related issues. Major weaknesses in the requalification
examinations results were addressed during this SALP period
,
18
._.
. .. . _ . . . . . . . . . . .. .. .
. ._. . . .
. i
..
l
-1
'
l
-
and partially through program provisions the CAL was closed '
l
.. subsequent to an inspection performed in January 1988. Since
that time, further inspection of the current requalification
program has been conducted'. The licensee has now begun to
successfully implement the requalifica". ion program.
Staffing for engineering and technical support was good. For
complex plant modifications, significant reliance is placed on .!
consultants to conduct design and analytical efforts. Examples- I
of such modifications are the digital feedwater control system, l
the new plant computer, and the revised control room panels for
both units. Staffing considerations for the configuration
management program are in progress and, with the Superintendent
and the Lead Design Ergineer on board, activities are commencing.
'
Training and qualification effectiveness was. mixed. Although the
training and qualifications program did not ensure a high degree.
of success in passing NRC administered operator. licensing
examinations, the-licensee's evaluation and proposed corrective
actions appear to be' appropriate. .-In addition, although the ,
effectiveness of the new requalification program has not yet j
been evaluated, the licensee's developmental efforts and j
implementation of the revised requalification program are i
, ,
progressing very well. ,,
The licensee has demonstrated a generally conservative approach
to the engineering resolution of_ technical problems. However,
there are indications that thorough, aggressive engineering / technical
- evaluation is not being conducted within all elements of the. ;
l licensee engineering organization. Vendor interface, commercial i
grade dedication, and proper disposition and response to industry j
information notices are areas of concern that require management l
attention.
2. Performance Rating
The licensee's performance is rated Category 2 in'this area.
Since this is a new functional area, it was not rated in the l
previous assessment period. I
L 3. Recommendations l
/
None. )
!
..
1
!
19
l
l _ _ _ _ - . _ _ _ _
,
.
..
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'
G. Safety Assessment / Quality Verification
1. Analysis
This is a new functional area and consequently was not rated in
previous SALPs. Evaluation of this area was based on results
of 12 inspections conducted by the resident inspectors,
one inspection by a Region III E0P team, and reviews by the
NRR Licensing Project Manager.
One Severity Level IV violation was noted during the assessment
period for failure to perfonn planned and periodic audits of
the E0Ps. During the previous assessment period. no violations
were identified in 'the functional area of Quality Programs and
Administrative Controls Affecting Quality.
One licensee event was assigned to this functional area for
the procedural inadequacy noted when the licensee was
reviewing the applicability of Information Notice No. 87-63,
" Inadequate Net Positive Suction Head in Low Pressure Safety
Systems," to Prairie Island. During this review, it was
discovered that in one of the E0Ps, under certain conditions,
the residual heat removal pumps could not support the flow
- -
demands that might be placed on them. The licensee responded -
to this discovery immediately by issuing a Special Order that
provided guidance on this subject to the operating crews.
Audits for quality are performed formally by two organizations: I
the plant Quality Engineering (QE) group and the corporate
QA group. Results of audits by these two groups were promptly ;
brought to the attention of plant management. Immediate action '
was frequently taken by plant groups when an unsatisfactory
condition is pointed out by the auditors. In some instances,
written responses were required regarding corrective actions-
that have been or were to be taken. This system appeared to be
effective in tracking items raised by the auditors although the
plant QE organization reported some problems with the timeliness
of the 30-day responses required by plant procedures. Both QE
and QA were judged to be very effective in the performance
of their duties. For example, plant QE auditors uncovered
failures to meet company brazing requirements, incomplete
modification packages being turned over to Operations, mislabeled
and improperly fused electrical panels, damaged safety-related
instrumentation (during an outage), mispositioned process
valves, an improperly rebuilt governor for a diesel-powered
l cooling water pump, and many other items. Similarly, examples
of corporate QA effectiveness included the following: protection
'
system instrumentation and circuits were found not to be
response-time tested as required by TS (this area is1 till being
examined by the NRC), QA performed.significant research on the
.
4
20
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a
!
. 1
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!
historical saquences that resulted in Foxboro controllers being. I
improperly installed _for monitoring axial flux tilts, and
full-time auditors have been assigned directly to the Prairie
~
Island site, one in April 1988 and the other in March 1989. One 1
of these auditors had significant knowledge of the plant, having !
worked in Operations for many years. l
The onsite safety committee (Operations Committee or OC) k
continued to be very involved in the review of significant '
plant activities, including plant events. As evidence of the l
OC's active participation, this committee met 194 times during j
the assessment period, an average of 2.8 meetings per week. j
Safety evaluations required by 10 CFR 50.59 in general have i
been carefully' prepared and received close scrutiny by the OC
before approval. Minutes that summarize the DC discussions
improved during the period regarding the amount of detail i
included. '
The offsite safety committee (Safety Advisory Committee or l
SAC) also operated during the period in a generally effective {
manner. All areas required by plant TS to be reviewed by SAC ?
appear to have been appropriately discussed. Membership of the
'
SAC, though of individuals very experienced in the nuclear i
~ ~
industry, did not change on any regular basis. For example,
there has not been a new member of SAC from outside the licensee's
organization for more than 10 years. A lack of new individuals
on the committee is a potential concern which the NRC feels the
licensee should consider. 4
i
Some minor weaknesses in the membership of the SAC regarding
the balance of NSP versus non-hSP members and the lack of detail
in the minutes of the SAC meetings were'noted. .Also, records of i
the experience and qualifications of the SAC members were not
uniform, maintained current, nor responsive to the need to
clearly establish the basis for the members' level of expertise.
,
An area in which the licensee can improve is keeping the NRC
better informed of plant activities and management concerns.
,
I
Several examples of failures to keep the NRC fully informed on
matters of interest were noted during the assessment period.
Many discussions were held with the plant manager and others on
this subject in an attempt to improve these communications. l
Examples included: station blackout project planning and policy- l
l decisions; untimely notification of occurrences such as the
345kV breaker failure, fire protection audit findings and a l
security. violation; changes in radiation protection practices- I
and an allegation the licensee received relevant to radiochemistry
issues. The latter example was significant in that the allegation
was also received in the Region III Office. This caused duplication
of efforts and coordination problems for the NRC. -
1
1
!
21
I
l
_ _ _ _ - -
- 1
!
!
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"..
,
During the SALP assessment period, the licensee's management ,
'
actively supported licensing actions and their participation
indicated an indepth knowledge of the issues. The licensee's
submittals were maintained'at a high quality level and did not
require significant rework. In the upper plenum injection case,
the licensee took the initiative and assumed a lead role in
resolving long standing technical issues in conjunction with
industry groups. The licensee's submittal, describing the
evaluation model, was well prepared and the information was
adequate to prepare a safety evaluation requiring only minor
additional input. The licensee worked closely with the staff ,
in resolving various safety issues related to the TS upgrade i
that were initiated as a result of our requesting modifications j
to the licensee's proposed change. Answers to questions raised 1
during the course of preparing the safety evaluation were ,
technically sound and served to resolve the NRC's safety {
concerns. These activities resulted in six license amendments J
for each unit and an exemption to Appendix J of 10 CFR 50.
In most cases, the licensee has responded to the generic letters I
and bulletins in a timely manner and an examination of the j
responses indicated that the quality is generally adequate and 1
the responses are complete. These responses are currently under !
review by the staff. One exception noted was the licensee's ~
{
~ ~
response to Bulletin 85-03 which was not thorough; and some !
inconsistencies were found in the documentation during a field I
verification. Regarding NRC Information Notices, the licensee l
has in place a system for receiving, logging, assigning, and
tracking actions taken on every Information Notice received.
This system is working properly and effectively.
During this assessment period, the licensee submitted changes
to the Plant Security Plan in response to the rule change
pertaining to 10 CFR 73.55, Miscellaneous Amendments and Search
Requirements. The licensee also submitted a plan change
addressing vital equipment. Review of these submittals
indicated that the licensee had a clear understanding of the
Commission's security regulations, demonstrated by the quality
of the submittals received, and that there was clear evidence
of prior planning in developing the proposed changes.
Several areas of self-improvement were initiated by the licensee
during the assessment period such as the " Pursuit of Excellence"
program. Some examples from that program include the following:
week-long visits'are being made by all operating crews to other
operating nuclear plants; plant managers have begun meetings
with managers of other 2-loop Westinghouse plants; a
Configuration Management program that includes Safety System
Functional Inspection efforts is under way; and an Error
22
______ -_ 3
- ;*
.
. Reduction Task Force is active in the investigation of all
events in which personnel error may have been involved.
Another self-improvement effort, that also was partly initiated
in response to NRC observations on the reduction of reactor
trips, is the installation of a digital feedwater control j
system. Unit 2 now has such a system which was installed and ]
tested during the April 1989 outage.
'
Another voluntary improvement being made partly in response to j
NRC interest is the installation of two new emergency DG. These
DG5 are scheduled for installation in late 1991 or early 1992
and will satisfy current NRC requirements for reliability of the
onsite power supply system.
The Prairie Island staff also has taken the lead in resolving
questions raised by NRC regarding the reliability of Fairbanks-Morse
opposed piston diesels. Units of this manufacture are used to I
drive the. existing emergency generators. Specifically, a
Fairbanks-Morse owners' group has been organized by NSP. The
initial meeting of this owners' group was held in mid-May 1989.
Recently the staff issued Generic _ letter 89-04 establishing
guidance for obtaining the required approval for implementation
- -
of the inservice testing (IST) of pumps and valves program ~
relief requests for those plants that do not have an NRC approved
program. Prairie Island is one of the few plants in the country
that has IST relief approved by the NRC. Specifically Prairie
Island had its first ten year period as well as the present
second ten. year period approved by the staff. The second
ten year period will end on December 16, 1993, for Unit I and
December 21, 1994, for Unit 2.
An area of weakness was identified regarding the licensee's
resolution of allegations forwarded by the NRC. An allegation
was investigated by the licensee following receipt by the NRC,
and the licensee reported its investigation results to the NRC.
However, the agency staff was unable to make a judgement on the
corrective actions taken from the contents of that report, so
supplemental information had to be obtained from the licensee.
Improvements need to be made in the area of allegation handling.
2. Performance Rating
The licensee's performance is rated Category 1 in this area.
Since this is a new functional area, it was not rated in the
previous assessment period.
3. Recommendations
..
None.
23
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. ., 0
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.
')
l
1
V. SUPPORTING DATA AND SUMMARIES
A.. . Licensee Activities
1. Unit 1-
Prairie Island' Unit I began the assessment period operating at
routine power levels up to 100%. On. August 23, 1988, the unit
was' shut down-for its annual refueling and maintenance outage.
'
(Cycle 12-13). The unit operated routinely-with no major
reactor outages or.significant load reductions through the end 4
of the SALP assessment period. 1
Unit 1 experienced four ESF actuations and no reactor trips.
Significant outages'and events that occurred during the i
assessment period'are summarized below, j
'
Unit 1 Significant Outages and Events
a '. During March 10-12, 1988, Unit l' shut down from 80% power
to repair'a reactor coolant leak that resulted from a
corroded canopy seal weld on an instrument column in the
reactor head.
b. During July'26-28,-1988, Unit 1 experienced a forced outage 1
and remained shutdown to repair generic problems with the
'
flux tilt controllers,
c. During August 23 - September 28, 1988, Unit-I was shut down
for its Cycle 12-13 ~ refueling and maintenance outage.
Activities included installation of new fuel assemblies, l
eddy current- tests, fuel shuffle, replacement of- the i
control roomE' panel, snubber testing, integrated leak
rate testing (ILRT) of containment, and inspection of 1
all steam generator (SG) tubes. 4
2. Unit 2
Prairie Island Unit 2 began the assessment period coasting down
in preparation for its Cycle 11-12{ refueling and maintenance
outage, which began on January 5, 1988. On February 13, 1988,
Unit 2 resumed routine operation, but was subsequently-taken
off line briefly to allow closure of transformer disconnects. ,
The unit operated as' load demands dictated at' power levels up. i
to 100%. On March 28, 1989, Unit 2 began its Cycle 12-13
'
refueling and maintenance outage and returned to service on
April 29, 1989. The assessment period ended with the unit ,
operating routinely.
..
24
i
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There were no ESF actuations or reactor trips of Unit 2 during
the assessment period.
Significant outages and events that occurred during the assessment
period are summarized below.
' Unit 2 Significant Outages and Events
a. During January 5-February 13, 1988, Unit 2 was shut down
for its Cycle 11-12 refueling and maintenance outage.
Activities included a fuel shuffle, a feedwater piping
inspection, replacement of source range detectors, eddy
current test of all SG tubes, containment ILRT, testing
of Limitorque valve. operators, and measurement of thimble-
tube wear.
b. On Februtry 13, 1988, Unit 2 was taken off line to allow
closure of the transformer discontents,
c. During November 8-11, 1988, Unit 2 was shut down for
condenser repairs. Activities included repairs to a
feedwater line leak and a condenser tube leak,
- ~
d. During March 28-April 29, 1989, Unit 2 was shut down for.. ,
its Cycle 12-13 refueling and maintenance outage.
Activities included a fuel shuffle,. eddy current test of-
SG tubes, inspection of the installed SG tube plugs,
feedwater piping' inspection, replacement of the feedwater
control system, and. installation of anticipated transient
without scram mitigating circuitry.
B. Inspection Activities
Thirty-eight inspection reports are discussed in this SALP report
(December 1, 1987, through April 30,1989) and are listed in paragraph l
1 of this section, " Inspection Data." ' Table ~1 lists the -violations ,
per' functional area and their severity levels. Significant inspection i
activities are listed in paragraph 2 of this section, "Special
Inspection Summary."
.
1. Inspection Data
a. Unit =1
Docket No.: 50-282
Inspection Reports Nos.: 87017, 87018, 88001 through
88023, 88025, 88200, 89002, 89003, 89007 through 89012, and
89014. ,
Unit 2
'
b.
Docket.No.: 50-306 "*
l Inspection Reports Nos.: 87016, 87017, 88001 through
l
88014, 88016 through 88023, 88025, 88200, 89002, 89003,
89007 through 89013, and 89015.
i
25
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Table I
Number of Violations in Each Severity Level
Unit 1 Unit 2 COMMON
Functional Areas III IV V III IV V III IV V
A. Plant Operations - - - - - - - - -
B. Radiological Controls - - - - - - - - -
C. Maintenance / Surveillance -
1
- - - - -
6 -
D. Emergency Preparedness - - - - - - - - -
E. Security -
1
- - - -
1 2 -
F. Engr / Tech Support - - - -
1 - -
2 -
G. Safety Assessment /
Quality Verification - - - - - - -
1 -
Unit 1 Unit 2 Common
IIT IV V III IV V III IV V
TOTALS -
2 - -
1
-
1 11 -
2. Special Inspection Summary
~ "'
a. During January 20-February 10, 1988, a special inspection ,
was conducted on the corrective actions taken regarding
the Operator Requalification Program, as described in
CAL-87-013-010A (Inspection Report Nos. 282/88003,306/88002).
b. During June 22-22, 1988, the annual EP exercise was
conducted (Inspection Report Nos. 282/88006,306/88006).
c. During June 6-21, :.988, a special inspection was conducted
to verify that the E0Ps were tec'mir sily correct (Inspection
Report Nos. 282/88010, 306/88010).
d. During September 1-16, 1988, an ISI inspection was conducted ,
(Inspection Report No. 282/88015). I
e. During September 16-October 26, 1938, an ILRT/ local leak
rate testing inspection was conducted (Inspection
Report Nos. 282/88016,306/88016).
f. During October 25-November 4,1988, a vendor inspection was i
conducted relating to the interface of procurement program "
(Inspection Report Nos. 282/88200,306/88200).
C. Escalated Enforcement Actions
A Severity Level'III violation was issued for a security event
involving improper access authorization and inadequate scteening of
individuals; however, no civil penalty was levied (Inspection Report
Nos. 282/88023, 306/88023; Enfor': ment Case No. EA-88-292).
26
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D. Confirmatory Action Letters i
None. ,
. E. License Amendments Issued
Amendments No. Description Date
82/75 Administrative Control 4/18/88
change, Figure TS 6.1-2 1
83/76' High Flux Power. Range. Low 5/31/88 q
Set Point changed
84/77 Change gF and FAg Using 9/16/88
The New Evaluation Model !
for Appendix K j
85/78 Security Plan Revision -1/5/89
10 CFR Part 73-
4
86/79 Reduction in Turbine: 2/7/89 l
Valve Testing '
- .
F. Review of Licensee Event. Reports'
Unit'l LER Nos.: 87020, 88001 through G8011,.88013, 89001 and 89002.
Unit 2 LER Nos.: 88001, 88002, and 89001
Collectively, 18 LERs were issued in accordance with NUREG-1022
guidelines during this assessment period and are addressed in this
SALP 8 report.
Table 2
Licensee Event Reports
Causes Unit I- Unit 2
Personnel Errors 4 2
Design Deficiencies 7 0
External 0 0
Procedure Inadequacies 2 0
Equipment / Component 1 1
Other/ Unknown- 1 0
Totals 15 3
Table 3 shows a cause code comparison of SALP 7 and SALP 8. ..
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Table 3
LERs Comparison
( 18-MO) .- -(17-MO)
Personnel Errors 16 (57.0%) '6 (33.3%) l
Design Problems 3-(11.0%) 7 (38.9%) .I
External Causes l'( 4.0%) -0 ( 0.0%) l
Procedure Inadequacies 4 (14.0%) 2 (11.1%) 1
Equipment / Component 2 ( 7.0%) 2 (11.1%)'
Other/ Unknown 2 ( 7.0%) I'( 5.6%) 4
i
TOTALS 28* 18 8
FREQUENCY (LERs/MO) 1.6 1.16
)
- Includes 4 voluntary LERs.
.
. -
,
NOTE: The.above'LER information was derived from a review of LERs 1
performed by NRC resident staff and may not completely coincide with'
the. licensee's cause code assignments. .
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