IR 05000263/2006008

IR 05000263-06-008; 11/30/2006 - 12/01/2006; Monticello Nuclear Generating Plant; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML063600391
Person / Time
Site:	Monticello
Issue date:	12/26/2006
From:	Burgess B Division of Nuclear Materials Safety III
To:	Conway J Nuclear Management Co
References
IR-06-008
Download: ML063600391 (23)

Text

December 26, 2006

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000263/2006008

Dear Mr. Conway:

On December 1, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at the Monticello Nuclear Generating Plant. The enclosed report documents the inspection findings which were discussed on December 1, 2006, with you and other members of your staff during an exit meeting.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved an examination of selected procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the samples selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated, and resolved within the problem identification and resolution programs. However, during the inspection, several examples of minor problems were identified where the documentation of an issue was incomplete, in that the extent of the evaluation and the status of the corrective actions could not be clearly discerned. Additionally, there were several examples where operating experience was not properly evaluated for applicability to the station. Each of these issues were also identified during prior Problem Identification and Resolution Inspections occurring in 2004 and 2005. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be 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), accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Bruce L. Burgess, Chief Branch 2 Division of Reactor Projects Docket Nos. 50-263 License Nos. DPR-22 Enclosure:

Inspection Report 05000263/2006008 w/Attachment: Supplemental Information cc w/encl:

M. Sellman, Chief Executive Officer and Chief Nuclear Officer Manager, Nuclear Safety Assessment J. Rogoff, Vice President, Counsel, and Secretary Nuclear Asset Manager, Xcel Energy, Inc.

State Liaison Officer, Minnesota Department of Health R. Nelson, President Minnesota Environmental Control Citizens Association (MECCA)

Commissioner, Minnesota Pollution Control Agency D. Gruber, Auditor/Treasurer, Wright County Government Center Commissioner, Minnesota Department of Commerce Manager - Environmental Protection Division Minnesota Attorney Generals Office

SUMMARY OF FINDINGS

IR 05000263/2006008; 11/13/2006 - 12/01/2006; Monticello Nuclear Generating Plant; biennial baseline inspection of the identification and resolution of problems. No violations or findings were identified. The inspection was conducted by a regional projects inspector, a resident inspector, and a regional electrical engineering specialist.

Identification and Resolution of Problems The team identified that the licensee was effective at identifying problems and incorporating them into the corrective action program (CAP). In general, the licensee was effectively prioritizing, evaluating, and correcting issues. However, the team identified that the licensee demonstrated a lack of sensitivity to internal CAP performance indicators, in that some of these indicators, which showed potential deficiencies in the program, had not been evaluated.

Additionally, the team identified examples where the documentation of an issue did not clearly indicate whether it had been properly evaluated, what the status of the corrective actions were, or whether it had been effectively resolved. Some of these examples were similar to those identified during prior Problem Identification and Resolution (PI&R) inspections occurring in 2004 and 2005.

Although the licensee was effective at screening and disseminating operating experience (OE), the team identified several examples where OE was not considered as a precursor to events during cause evaluations. In particular, the team noted that the licensees revised guidance for performing apparent cause evaluations specifically precluded a review of operating experience as part of the evaluation. As stated above, consideration of operating experience was also an issue identified during prior PI&R inspections.

Licensee audits and self-assessments were generally thorough, probing, and made good use of outside resources to maintain independence. The team noted that identified issues were properly tracked in the CAP.

Through interviews, the team concluded that workers at the site were encouraged to identify issues through the CAP and were generally familiar with the various other avenues available.

However, the team identified that the level of rigor associated with the Differing Professional Opinions (DPO) program was less than appropriate. Specifically, there was no clear interface between the DPO and CAP programs and documentation of how DPO issues were resolved was less than adequate. The team also noted that the originator often had to assume the burden of ensuring that their DPO was appropriately resolved. Overall, the team was concerned that these issues could result in some individuals being reluctant to use the DPO process in the future.

A.

Inspector-Identified and Self-Revealed Findings No findings of significance were identified.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a.

Assessment of the Corrective Action Program

(1) Inspection Scope The team completed one biennial PI&R inspection sample by assessing the licensees processes for identifying and correcting problems. This included a review of program procedures, interviewing plant personnel, and attending various station meetings to understand the implementation of the licensees CAP and related activities.

The team reviewed selected CAP products, such as CAP action requests (ARs),audits, self-assessments, and other documents to determine if problems were being identified at the appropriate threshold and entered into the CAP. This review primarily covered those items generated since the 2005 NRC PI&R inspection (Inspection Report No. 05000263/2005006).

The team evaluated whether issues were effectively documented, evaluated, and corrected in the CAP. The team reviewed selected ARs, apparent and root cause evaluations, prompt investigations, operability determinations, and common cause analyses. Attributes reviewed included the technical adequacy of the cause determinations and the adequacy of the extent of condition reviews including evaluations of potential common cause or generic concerns.

Other attributes reviewed by the team included the quality of the licensees trending of conditions and the corresponding corrective actions. The team searched for items or issues that looked like potential trends and assessed whether the licensee had appropriately identified and captured these trends within the corrective action program.

The team also reviewed licensee corrective actions stemming from previous Non-Cited Violations and other NRC identified issues and assessed their appropriateness.

The team also evaluated whether the licensee was appropriately tracking ARs that were closed to work requests or orders, and whether there was appropriate justification for those issues that had been downgraded since the initial screening. These were considered vulnerabilities in the CAP program due to the potential for issues to go unresolved.

During this inspection, the team reviewed 12 self-assessments, 14 audits, 62 CRs, 11 trend evaluations, and 23 apparent or root cause evaluations.

(2) Assessment No findings of significance were identified.

On November 15 and 30, 2006, the team attended meetings of the Performance Assessment Review Board. This board, comprised of senior licensee management, was responsible for reviewing the quality of root and apparent cause evaluations and for monitoring the overall health of the CAP. The team noted that the Board effectively challenged the sponsors/authors of the cause evaluations being reviewed and appeared to provide effective high-level oversight of the CAP.

Identification of Issues The licensee implemented a broad CAP governed by corporate-level policies and procedures. A shared computerized database was used for creating individual reports and for subsequent management of the processes of issue evaluation and response.

This included determining the issues significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate. Workers were encouraged to raise concerns and typically identified issues at a low threshold. This was evidenced by the large number of ARs generated annually which were reasonably distributed across the various departments. While workers were familiar with the various avenues for raising concerns (NRC, CAP, etc), most preferred to bring issues directly to their supervision.

However, the team identified an apparent lack of sensitivity with the licensees evaluation of some of the internal performance indicators monitoring the CAP. For example, the team noted that the licensee had experienced a large drop in the number of issues identified through November 2006 (about 3500) compared to the average annual number identified since 2003 (about 5300/yr). The licensee believed the drop was due to changes in the CAP made since 2005, but had not done a formal evaluation to verify this assumption. The team also observed that the licensee has been unable to meet the goal for the number of trends identified per quarter since 2005, and that about 30 percent of the total number of open items were open beyond their expected due dates. However, the licensee had not performed any evaluation to determine the cause of not meeting these goals. A similar observation was also identified in the 2003 PI&R (Inspection Report No. 05000263/2003009) report. The licensee documented this issue in AR 01064612.

The NRC had previously evaluated the licensees trending program in the inspection quarter ending June 30, 2006. The inspection results were documented in Inspection Report 05000263/2006003. As stated in this report, the licensees trending program was considered effective at identifying and resolving trends. However, the team identified one example where trends may be missed due to the rolling up of ARs.

The team noted that there had been two ARs written for similar problems with 50.59 screenings, but that one of the ARs had been closed (i.e., rolled up) to the other AR which resulted in only one being trend coded. This meant that a trend search of 50.59 screening issues in the CAP database would only identify one instance rather than two. The team was concerned that this practice could result in potential missed trends. The licensee documented this issue in AR 01064258.

Prioritization and Evaluation of Issues The team attended CAP AR screening meetings held on November 7, 8 and 9, 2006.

The inspectors noted that issues were being appropriately challenged and that reportability, repetitiveness, and trending were discussed where appropriate. The team also observed that potential operability issues were being routed to the operating shift for review. The majority of issues were screened at a level appropriate for a condition evaluation or were simply closed to trend. In some cases, a root cause evaluation had initially been proposed, but the significance of the issue had later been downgraded to an apparent cause evaluation. Many low level issues were closed to a work request; however, this required that both the initiating AR and the associated work request have the necessary verbiage to document the interrelationship. Since 2005, the licensee had initiated and/or completed 10 root cause evaluations and about 168 apparent cause evaluations.

The team identified several examples where there was a lack of rigor in enforcing expectations; introducing potential vulnerabilities in the CAP. There were examples where ARs were closed to work requests or orders without the associated verbiage and where issues had been downgraded from a root to an apparent cause evaluation without having a clearly documented justification. Similar observations were also identified by the Nuclear Oversight group during audits and by other licensee staff in the CAP. The team was concerned that if uncorrected, this lack of rigor could result in some significant issues going unresolved. This issue was documented in licensee AR 01064602.

While root cause evaluations were generally of good quality, issues were identified with some of the apparent cause evaluations reviewed by the team. These issues were similar to those identified during prior PI&R inspections occurring in 2003 and 2005.

The level of detail in the evaluations were not always sufficient to allow an independent reviewer to reach the same conclusion as the author. In some cases this was due to missing or unclear information contained in the evaluation. As discussed in Section (b),there were also examples where applicable operating experience was not evaluated.

The team noted that the most recent revision (November 10, 2006) of the licensees Apparent Cause Evaluation Manual no longer required that either operating experience or programmatic/organizational issues be reviewed as part of the evaluation. This appeared inconsistent with industry practice and raised the question whether future issues would receive an appropriate level of review. A similar issue was documented in the CAP as AR 01059029. During this inspection, the licensee implemented the following corrective actions to address this issue. First, select individuals were counseled regarding the expectations for documentation in apparent cause evaluations and second, industry benchmarking was initiated to determine the current industry practice regarding the scope of apparent cause evaluations.

Effectiveness of Corrective Actions Corrective actions were generally well implemented, effective in addressing the parent issues, and timely. The team also noted some examples where licensee staff had identified potentially inadequate corrective actions requiring revision. The team identified one minor example where a corrective action had not been assigned to an issue. Specifically, AR 01034607 regarding the alignment of emergency filtration train dampers, had an action item to verify the alignment of those dampers without bushings.

The team noted that a specific work request had not been assigned to perform this action. This was discussed with licensee staff and an work request was subsequently generated. Effectiveness reviews were generally considered good, although the team questioned the adequacy of some of the reviews. These examples were minor in nature and were subsequently discussed and resolved with licensee staff.

b.

Assessment of the Use of Operating Experience

(1) Inspection Scope The team reviewed the licensees program for handling operating experience.

Specifically, the team reviewed the implementing procedure, attended weekly operating experience screening meetings, reviewed operating experience evaluated by the plant, and verified that the licensee had adequately addressed some examples of operating experience provided to the team. The team also reviewed how the licensee considered operating experience for applicability in cause evaluations.

During this inspection, the team reviewed 18 ARs generated by the licensee addressing industry operating experience.

(2) Assessment No findings of significance were identified.

On a daily basis, the licensees corporate office provided a summary of all new operating experience information to the station operating experience coordinator.

This information was discussed during weekly screening meetings and all pertinent experience was sent to specific departments for review. Operating experience requiring review was documented in the CAP along with associated corrective actions.

In general, operating experience was being well utilized at the station. The team observed that it was discussed as part of the daily station planning meetings and as part of pre-job briefings. During interviews with the team, various licensee staff commented favorably on the use of operating experience in daily activities. The team also noted that the licensee had appropriately evaluated the specific examples of operating experience selected for review, and that operating experience was properly evaluated during the weekly screening meetings.

The team noted that operating experience was not always considered as a precursor to events in cause evaluations. The team observed several examples of cause evaluations where the review of operating experience, though applicable, was lacking. For example, AR 0860041, regarding the parallel operation of the essential service water pump with the river service water pump, listed a number of applicable operating experience reports in the evaluation, but did not discuss whether this experience had ever been evaluated prior to the event. Additionally, as noted above, the November 2006 revision to the Apparent Cause Evaluation Manual did not require that operating experience be reviewed as part of future cause evaluations. The team was concerned that by not performing these evaluations the licensee was potentially missing contributing causes for events and missing an opportunity to verify the efficacy of the operating experience program. As stated in section (a), the licensee had scheduled benchmarking trips to assess, in part, current industry practice regarding the use of operating experience in cause evaluations.

c.

Assessment of Self-Assessments and Audits

(1) Inspection Scope The team reviewed selected department self-assessments and Nuclear Oversight audits of the corrective action, operations, maintenance, engineering and plant support (radiation protection, security, and emergency preparedness) programs. The team evaluated whether these audits were being effectively managed, adequately covered the subject areas and whether identified issues were properly captured in the CAP. In addition to the document review, the team also interviewed licensee staff regarding the implementation of the audit and self-assessment programs. The team focused on those audits and assessments completed since 2004.

During this inspection, the team reviewed 12 self-assessments and 14 audits.

(2) Assessment No findings of significance were identified.

The audits and assessments were performed primarily under well-defined and focused procedures. Generally, the audits and assessments were critical and probing and used outside resources to maintain independence. There were a number of findings and observations identified across the spectrum of performance, including issues of proper CAP implementation. As appropriate, the audit/assessment findings were documented in ARs. However, the team noted that some recommendations identified in the audits or assessments were not always tied to a specific AR for resolution. The team verified, however, that in most cases the recommendations were being properly evaluated. The team also noted that self-assessments of the CAP program performed in 2005 and 2006 had identified similar, potentially recurring weaknesses to a 2004 self-assessment.

However, the later assessments did not discuss why the issues were recurring or how the stated corrective actions were different than those previously taken. The team later determined that the licensee had considered these issues, but had not documented this in the later assessments. This was considered another example of poor documentation as discussed in section (a).

d.

Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The inspectors interviewed 15 members of the plant staff, across varying major work groups and all levels of responsibility. The purpose of the interviews was to assess whether a safety-conscious work environment existed at the station. The interviews were conducted using the guidance provided in Appendix 1 of NRC Inspection Procedure 71152, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R Issues.

In addition to the interviews, the inspectors looked for evidence that plant employees might be reluctant to raise safety concerns during document reviews and observations of activities. The inspectors reviewed the station procedures related to the Employee Concerns (ECP) and DPO programs, and discussed the implementation of both programs with licensee staff. The team reviewed selected issues captured under both programs since 2004 and interviewed some employees who had utilized one of these programs.

As an aid in assessing this area, the inspectors referred to Principles for a Strong Nuclear Safety Culture, which was an industry guidance document developed in 2004.

(2) Assessment No findings of significance were identified.

The licensee had not conducted a specific assessment of safety culture since the 2005 PI&R inspection. Based on interviews with employees, the inspectors determined that employees were comfortable identifying issues and discussing concerns with supervision without fear of reprisal. The inspectors observed that all personnel interviewed were aware of the different avenues through which they could express concerns, including the CAP, DPO, and ECP programs or by coming to the NRC; however, most employees said they preferred reporting issues directly to their immediate supervisor.

The team noted that the ECP process was not readily utilized by plant staff as, typically, there were only about four issues processed annually. The team did not notice a particular trend in those issues documented since 2003 and observed that they were generally well resolved and documented. Given the generally positive feedback received during the employee interviews, the team concluded that the relatively low number of issues captured in the ECP did not indicate a potential problem with licensee safety culture.

Although the number of issues processed as DPOs was also low (about 3 since 2001),the team noted that the level of rigor over this program was significantly less than for the ECP. The licensees corporate office administered the DPO program and there was no designated site individual to assist program users. Although generally familiar with the programs existence, those wanting to use the programs typically had to assume the burden in assuring that issues were being properly resolved. The team noted that there was no clear interface between the DPO and the CAP, in that DPO issues were not captured in the CAP nor were related CAP issues generally linked to DPO items. For example, the team noted that a CAP documenting some issues with secondary containment damper testing was not linked to a similar DPO item for different secondary containment dampers. The team also had some difficulty in obtaining sufficient documentation from the corporate staff to verify that issues were appropriately resolved.

For example, in order to verify that the status of the secondary containment damper testing DPO, the team had to obtain uncontrolled documents maintained by the originator. The team was concerned that the overall lack of rigor over the DPO process may result in some workers feeling reluctant to raise concerns and/or some issues not being properly evaluated or documented. The licensee initiated ARs 01062966 and 01063040 to document this concern.

4OA6 Management Meetings

Exit Meeting Summary

The inspectors presented the inspection results to Mr. J. Conway and other members of licensee management at the conclusion of the inspection on December 1, 2006. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.

The licensee stated that all proprietary information provided to the inspectors had been returned.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

B. Cole, Nuclear Oversight Supervisor

J. Conway, Site Vice President

J. Fields, Performance Assessment Supervisor

J. Grubb, Site Engineering Director

W. Guldemond, Nuclear Safety Assurance Manager

K. Jepson, Radiation Protection and Chemistry Manger

B. MacKissock, Operations Manager

J. Mestad, Employee Concerns Program Manager

S. Radebaugh, Maintenance Manager

J. Rieder, Corrective Action Program Coordinator

B. Sawatzke, Plant Manager

Nuclear Regulatory Commission

B. Burgess, Chief, Reactor Projects Branch 2

C. Thomas, Senior Resident Inspector

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None