ML20247M133

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Forwards Input to SALP 8 Rept for Units 1 & 2.Evaluation Conducted Per 880606 Rev to NRC Manual Chapter 0516, Systematic Assessment of Licensee Performance & Provides Input Per Guidelines in Rl Hague 890412 Memo
ML20247M133
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 05/24/1989
From: Diianni D
Office of Nuclear Reactor Regulation
To: Greenman E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
TAC-72580, TAC-72581, NUDOCS 8906020370
Download: ML20247M133 (7)


Text

__ _ _ _ _ _

May 24, 1989

. - j' DISTRIBUTION Docket Nos. 50-282 4 DOCKET FILEj DD11 ANNI 50-306 NRC & LOCAL PDRs OGC

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PD31 GRAY- FILE MVIRGILIO MEMORANDUM FOR: EdwardGIGreenman, Director GHOLAHAN FCONGEL Division of Reactor Projects BGRIMES WAXELSON Region III JROE CNORELIUS S

_ NJACKIW, RIII NSCHUMACKER-THRU: Lawrence A. Yanderl, Acting DirectorHMILL,ER, RIII WSNELL Project Directorate III-1 JCREED, RIII MPHILLIPS Division of Reactor Projects III, FJABLONSKI, RIII ACRS(10)

IV, V and Special Projects, NRR GWRIGHT, RIII EJORDAN ~

PSHUTTLEWORTH EROSSI FROM: Dominic C. Dilanni, Project Manager LSHA0 Project Directorate III-1 JHARD (SRI)

Division of Reactor Projects III, IV, V and Special Projects, NRR

SUBJECT:

NRR INPUT TO THE SALP 8 REPORT FOR THE PRAIRIE ISLAND NUCLEAR GENERATING PLANT (LAC N05. 72580 AND 72581) UNIT NOS. 1 AND 2 Enclosures 1 and 2 provide NRR's input to the draft SALP 0 report for the Prairie Island Nuclear Generating Plant Unit Nos. I and 2. Our evaluation was conducted according to the June 6, 1988 revision of the NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance," and provides input in accordance with guidelines given in R. L. Hague's memorandum dated April 12, 1989. If there are any questions regarding this matter, contact me at (FTS) 492-1309.

Msigned by Dominic C. Dilanni, Project Manager Project Directorate III-1 Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation (-

Enclosures:

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'4 0 May 24, 1989 Docket Nos. 50-282 i 50-306 MEMORANDUM FOR: Edward G. Greenman, Director Division of Reactor Projects Region III THRU: .,

- Lawrence A. Yandell, Acting Director Project Directorate III-1 Division of Reactor Projects III, IV, V and Special Projects, NRR FROM: Dominic C.- Dilanni, Project Manager Project Directorate III-1 Division of Reactor Projects III, IV, V and Special Projects, NRR

SUBJECT:

NRR INPUT TO THE SALP 8 REPORT FOR THE PRAIRIE ISLAND NUCLEAR GENERATING PLANT (TAC NOS. 72580 AND 72581) UNIT N05. 1 AND 2 Enclosures 1 and 2 provide NRR's input to the draft SALP 8 report for the Prairie Island Nuclear Generating Plant Unit Nos. I and 2. Our evaluation was conducted according to the June 6, 1988 revision of the NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance," and provides input in accordance with guidelines given in R. L. Hague's memorandum dated April 12, 1989. If there are,any questions regarding this matter, contact me at (FTS) 492-1309.

l em 0 - i b-t .

D"ominic C. Dilanni, Project Manager l Project Directorate III-1 Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

As stated

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, OFFICE OF NUCLEAR REACTOR REGULATION INPUT FOR SALP 8 REPORT DECEMBER 1, 1987-APRIL 30, 1989 NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNIT N05. 1 AND 2 DOCKET N05. 50-282 AND 50-306

1. Safety Assessment / Quality Verification During the SALP assessment period, the licensee's management activity supported the 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. These activities resulted in six license amendments for each unit and an exemption to Appendix J of 10 CFR 50.

A listing of all licensing actions that occurred during this assessment period are contained in Attachment No. 1.

There has been a 77% increase in the number of unresolved licensing issues (i.e.,

an increase from 9 to 16 open issues) as shown in Figure 1 of this evaluation.

Eight of the 16 unresolved licensing issues were initiated within the last six months of the assessment period. The increase in the unresolved licensing issues deals with recently issued generic letters and bulletins. In all cases, the licensee has responded to these generic letters and bulletins in a timely manner and an examination of the responses indicates that the quality is adequate and the responses are complete. These responses are under review by the staff.

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 ATWS requirements, a technical specification change request based on the new Appendix K evaluation model for upper plenum injection, a submittal involving the periodic surveillance requirement for tubine valve testing, and the high flux range monitor low set point submittal are all examples of high quality engineering. 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 engineering staff at Westinghouse received meritorious awards after the evaluation model for upper plenum was reviewed and found acceptable by ACRS and the staff. The licensee's submittal, describing the evaluation model, was well prepared and the information was adequate to prepare a safety evaluation requiring only minar additional input. The licensee worked closely with the staff in resolving various safety issues related to the Technical Specifications upgrade that were initiated as a result of our requesting modifications to the licensee's proposed change. Answers to questions raised during the course of preparing the safety evaluation were technically sound and served to resolve our  ;

safety concerns. l I

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2. Engineering / Technical Support The licensee was requested to submit an acceptance criteria to justify continued operation when encountering stress level discrepancies (i.e., calculated stress levels above the allowable stresses of USAS B 31.1.0 1967, power Piping Code) in the reanalysis of as-built safety-related pipe systems. The licensee's initial submittal adcressing the acceptance criteria was found to be unacceptable by the staff since the stress levels allowed by the criteria would be close to the ultimate stress levels of the material. However, once the licensee was made aware of our position on this matter, it promptly submitted a revised acceptance criteria that was found acceptable by the staff.

The Vendor Inspection Branch conducted a procurement and licensee / vendor interface inspection at the Prairie Island plant during the SALP period. Results of this inspection indicated weaknesses in the areas of procurement and in overall interfaces between the licensee and its vendors. The inspection team identified deficiencies in the procurement of commercial grade items intended for eventual use in safety related applications.

Improvement is needed in the vendor interface program, particularly in response to concerns communicated to the licensee by the NRC. Certain vendor communications received by the licensee describing potential safety concerns were improperly and incompletely assessed for their applicability, and several assessments lacked the necessary level of documentation to permit clear understanding of their disposition.

The licensee has demonstrated a 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 licensee engineering organization. The licensee, vendor interface, comercial grade dedication, and proper disposition and response to industry information notices are areas of concern that require management attention.

3. Security 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.

The plan revision pertaining to the 10 CFR 73.55 rule change was implemented as License Amendment Nos. 85/78 in January 5, 1989.

4 Radiological Controls Revision 9 to the NSP Offsite Dose Calculation Manual (ODCM) has been reviewed and the results are contained in Technical Evaluation Report EGG-PNY-8073. The report identified 13 discrepancies, 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.

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i i Attachment 1 4,j:.  ? ,

\' LICENSING-ISSUES COMPLETED g DURING ASSESSMENT PERIOD DECEMBER 1, 1987 p

THROUGH APRIL 30, 1989 SALP NO.'8~

DATE TAC NOS. DESCRIPTION 'COMTLETED

, 66046/66047 Amendment Nos. 82 and.75 4/18/88' Administrative Control change, Figure TS 6.1-2 66865/66866 Amendment Nos. 83 and 76- 5/31/88 High Flux Power Range Low Set Point changed 59130/59131- Compliance with ATWS. 6/8/88 Rule-10 CFR 50.62 68940/68941L MPA B101 GL 88-05 Boric 8/23/88 Ac':d Corrosion C/S Pipes 67262/67263 Steam Binding of Auxiliary 8/25/88 Feedwater Pump, B 098 68654/68655 Amendment Nos. 84 and 77 9/16/88 Change F n and F Using The New Evaluat ,idn Model for Appendix'K 66244/66245 Loss of RHR While RCS is 9/17/88 Partially Filled, GL 87-12 69172/69173 Appendix J Exemption, 9/27/88 Paragraph III. A.3 68464/68465 Pipe Stress Analysis 10/13/88 .)

Criteria for Evaluating >

As-Built Discrepancies 67318/67319 Rapidly Propagating Fatigue 12/8/88 Cracks in Steam Generator Tubes,Bulletin 88-02 65540/65541 Amendment Nos. 85 and 78 1/5/89 Security Plan Revision -

10 CFR Part 73 u__ _ _ _ _ _ _ _ _ _ . _ . _ _ - - . _ _ - - - . - _ _ _ _ i

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TAC'N05. DATE i DESCRIPTION '

C6@LETED 66867/66868 Amendment Nos. 86 and 79 2/7/89 Reduction in Turbine Valve Testing (

69174/69175 Elimination of LO Feedwater 4/3/89 Trip

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