IR 05000282/2010001

03/03/2010, Prairie Island Power Plant EOC Assessment Letter (05000282-10-001; 05000306-10-001)

ML100610286
Person / Time
Site:	Prairie Island
Issue date:	03/03/2010
From:	Stephanie West Division Reactor Projects III
To:	Schimmel M Northern States Power Co
References
FOIA/PA-2010-0209, IR-10-001
Download: ML100610286 (7)

Text

rch 3, 2010

SUBJECT:

ANNUAL ASSESSMENT LETTER - PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 (05000282/2010001; 05000306/2010001)

Dear Mr. Schimmel:

On February 11, 2010, the NRC staff completed its performance review of Prairie Island Generating Plant, Units 1 and 2. Our technical staff reviewed performance indicators (PIs)

for the most recent quarter and inspection results for the period from January 1 through December 31, 2009. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "Official Use Only - Security Information" will include the Security Cornerstone review and resultant inspection plan.

Overall, Prairie Island Nuclear Generating Plant, Units 1 and 2, operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter at Prairie Island, Unit 1, was within the Regulatory Response Column of the NRCs Action Matrix based on one inspection finding in the Public Radiation Safety Cornerstone, from the first quarter of 2009, which involved a radioactive material shipment from your facility that did not conform to the applicable Department of Transportation (DOT) regulatory requirements when it arrived at the shipping destination. The supplemental inspection (95001) was successfully completed on December 4, 2009. Also, during this assessment period, the White finding in the Mitigating Systems Cornerstone (from the fourth quarter of 2008) involving the failure of the turbine driven auxiliary feedwater (TDAFW) pump to operate following a valid start signal was closed after the successful completion of a supplemental inspection (95001) on September 4, 2009. Based on the results of the two supplemental inspections performed during this assessment period, Unit 1 will move to the Licensee Response Column starting the first quarter of 2010. Plant performance for Prairie Island Unit 2 for the most recent quarter was also within the Regulatory Response Column of the NRCs Action Matrix based on two inspection findings (one in the Mitigating Systems Cornerstone and one in the Public Radiation Safety Cornerstone)

being classified as having low to moderate safety significance (White). The White finding in the Mitigating Systems Cornerstone, from the third quarter of 2009, is related to inadequate design of the component cooling water system. The inspection finding in the Public Radiation Safety Cornerstone being classified as having low to moderate safety significance (White) is the same as discussed above.

We plan to conduct a supplemental inspection (95001) in response to the White finding in the Mitigating Systems Cornerstone. Please notify us of your readiness to conduct this supplemental inspection. This supplemental inspection is in addition to Reactor Oversight Process (ROP) baseline inspections at your facility.

In the 2009 mid-cycle assessment letter, dated September 1, 2009 (ADAMS Ref.

ML092440367), we advised you of a substantive cross-cutting issue (SCCI) in the area of human performance (HP) with cross-cutting themes in the aspects of systematic process (H.1(a)), conservative assumptions (H.1(b)), procedural adequacy (H.2(c)), and procedural compliance (H.4(b)). During this assessment period, there were 26 findings documented with cross-cutting aspects in the HP area. Of these 26 findings, four shared a common cross-cutting aspect of systematic process, four findings with conservative assumptions, six findings with procedural adequacy, and seven findings with procedural compliance. The number of findings in the SCCI themes increased during this assessment period in two out of the four themes. You discussed your actions to address the ongoing HP SCCI during a December 1, 2009, public meeting and some improvement has been observed. However, these actions have not yet proven effective in mitigating the cross-cutting themes. Therefore, the NRC has a concern with your progress in addressing this cross-cutting area and has concluded that the SCCI will remain open until all cross-cutting themes have been cleared in the area of HP. To clear each of the themes, we will assess whether your corrective actions have resulted in a positive sustainable improvement in the area and will consider the number of findings in the theme.

In addition, because you have a substantive cross-cutting issue in the area of HP for two consecutive assessment cycles, we are requesting you provide a written response to the issue to include discussion of your actions undertaken, those actions planned to address the concern, and a current assessment of performance. This response should be sent to the NRC within 30 days of receipt of this letter. Also, we will discuss the substantive cross-cutting issue during the upcoming end-of-cycle meeting.

Additionally, on September 3, 2009, the staff issued a Severity Level III Notice of Violation in accordance with the NRCs Enforcement Policy. The violation was associated with a failure to provide complete and accurate information (10 CFR 50.9) regarding the medical condition of a senior reactor operator. In a letter dated September 30, 2009, you provided your response to this violation, as well as your corrective actions. The NRC plans to perform a follow up inspection on the actions taken during the first quarter of 2010. The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through June 30, 2011. We also plan on performing several special and infrequently performed inspections that include: Inspection Procedure (IP) 92709, Licensee Strike Contingency Plans, and IP 92702, Follow up on Traditional Enforcement Actions, Including Violations, Deviations, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Action Letters. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the mid-cycle review.

In accordance with 10 CFR 2.390 of the NRC=s ARules of Practice,@ a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact John (Jack) B. Giessner at 630-829-9619 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/lRA/

Steven West, Director Division of Reactor Projects Docket Nos. 50-282; 50-306;72-010 License Nos. DPR-42; DPR-60; SNM-2506 Enclosure: Prairie Island Inspection/Activity Plan cc w/encl: Distribution via ListServ

Prairie Island Inspection / Activity Plan 03/01/2010 - 06/30/2011 Planned Dates No. of Staff Start End Inspection Activity Title on Site BI ENG - TRIENNIAL HEAT SINK INSPECTION 3 02/01/2010 03/12/2010 IP 7111107T Heat Sink Performance OL EXAM - PR. ISLAND INIT EXAM - APRIL 2010 3 03/15/2010 03/26/2010 W90224 OL - INITIAL EXAM - APRIL 2010 - PRAI BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 03/22/2010 03/26/2010 IP 71124.01 Radiological Hazard Assessment and Exposure Controls BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 04/26/2010 04/30/2010 IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation BI ENG - ENGINEERING INSERVICE INSPECTION 1 04/26/2010 05/28/2010 IP 7111108P Inservice Inspection Activities - PWR BI ENG - COMPONENT DESIGN BASES INSPECTION 6 06/28/2010 07/30/2010 IP 7111121 Component Design Bases Inspection PI&R - BIENNIAL PI&R INSPECTION 4 09/20/2010 10/08/2010 IP 71152B Identification and Resolution of Problems BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 07/12/2010 07/16/2010 IP 71124.02 Occupational ALARA Planning and Controls BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 08/09/2010 08/13/2010 IP 2515/173 Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative 08/09/2010 08/13/2010 IP 71151-BI01 Reactor Coolant System Activity 08/09/2010 08/13/2010 IP 71151-OR01 Occupational Exposure Control Effectiveness 08/09/2010 08/13/2010 IP 71151-PR01 RETS/ODCM Radiological Effluent STRIKE - STRIKE CONTINGENCY-OPS/MAINT/RP/ENGR/QC 2 08/02/2010 12/31/2010 IP 92709 Licensee Strike Contingency Plans BI EP - EP EXERCISE / PI VERIFICATION 3 08/23/2010 08/27/2010 IP 7111401 Exercise Evaluation 08/23/2010 08/27/2010 IP 71151-EP01 Drill/Exercise Performance 08/23/2010 08/27/2010 IP 71151-EP02 ERO Drill Participation 08/23/2010 08/27/2010 IP 71151-EP03 Alert & Notification System BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 11/01/2010 11/05/2010 IP 71124.05 Radiation Monitoring Instrumentation BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 02/21/2011 02/25/2011 IP 2515/179 Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in NSTS 02/21/2011 02/25/2011 IP 71124.01 Radiological Hazard Assessment and Exposure Controls BI ENG - ENGINEERING INSERVICE INSPECTION - U1 1 04/30/2011 06/04/2011 IP 7111108P Inservice Inspection Activities - PWR

Prairie Island Inspection / Activity Plan 03/01/2010 - 06/30/2011 Planned Dates No. of Staff Start End Inspection Activity Title on Site BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 05/02/2011 05/06/2011 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 05/02/2011 05/06/2011 IP 71124.04 Occupational Dose Assessment BI EP - EP ROUTINE INSPECTION / PI VERIFICATION 2 06/13/2011 06/17/2011 IP 7111402 Radiological Environmental Monitoring Program 06/13/2011 06/17/2011 IP 7111403 Emergency Response Organization Augmentation Testing 06/13/2011 06/17/2011 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 06/13/2011 06/17/2011 IP 71151-EP01 Drill/Exercise Performance 06/13/2011 06/17/2011 IP 71151-EP02 ERO Drill Participation 06/13/2011 06/17/2011 IP 71151-IE03 Unplanned Power Changes per 7000 Critical Hrs