ML20128D868

Recommends That Insp Team Members Be Excused from Other Work in Order to Devote 5 man-wks to Preparation,Insp,Appraisal & Rept Writing

ML20128D868
Person / Time
Site:	Monticello
Issue date:	06/02/1972
From:	Sears J US ATOMIC ENERGY COMMISSION (AEC)
To:	Thompson D US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 9212070407
Download: ML20128D868 (6)

Text

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PR June 2, 1972 Dudley Thompson, Chief, Operational Safety Branch, L MONTICELLO MANAGEMENT APPRAISAL From May 22 through May 26, 1972, I was a member of the inspection team making a management inspection of Northern States Power (NSF) Monticello Plant. Following are the team members:

Max Hildreth, CO, Headquarters, team leader Robert Dodds, CO, San Francisco Robert Carlson, CO, Newark Carl Seyfrit, CO, Chicago, assigned inspector Leo Higinbotham, CO, Newark John Sears, OSB, L It is planned that some team members will continue the inspection by visiting NSP's home office on June 7-8, 1972, and a final report to NSF top management will be made- by some team members, and possibly other Regulatory representatives, a week or two later.

For management inspections of this type, CO recoassends that each team member be excused from other work so that he can devote 5 man-weeks to preparation; inspection, appraisal and report writing. In'this instance, Carl Seyfrit assembled, for each team member, 2 volumes (each as big as the Washington phone book) of back up material. Max Hildreth broke the total job up into a amber of different areas of interest, and assigned each man a portion of these jobs. I was assigned to the team only 2 days before the inspection so that I did not have the back up material. My assigned areas were Baergency Plans, Industrial Security, Adequacy of Abnormal Operating Procedures, and Competence of Operating Crews. A brief stannary of my findings - follows.

1. Emergency Plans I visited both the Principal and the Alternate Emergency Assembly Shelters, the Control Room, the Energency Room of the M aticello Big Lake Hospital, examined emergency kits, reviewed NSP correspond-ence with' local agencies, and reviewed a draft Minneso'.a State Plan.

Not all local agencies have confimed their as-Lasent to assist in writing.

No decisional aids are available (e.g. isopleths).

Hospital arrangements appear to be adequate. The only high volume CFFtCE > . . . . . . . . . . . . . . . - . . . . . . . ~ . . . .

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D. Thompson i air samplers available must be opersted on 110 VAC, and the only

{ vehicles with 110 VAC power outlets are stationed at St. Claud approximately half an hours travel from the plant.

4 I urged the Health Physicist to rewrite the plan to comply with all aspects of 10 CFR 50 Appendix E and its Guide, and suggested that he consult the connecticut Yankee plan for a model. I also suggested that he consider procuring battery operated air samplers.

2. Security Plan i

j Monticello's original plan included only a lighted perimeter fence and s key system for opening gates in the fence and doors in the building.

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Monticello now employs two armed Pinkerton guards on shift, around the clock, 7 days a week. All outside doors and gates are locked. The shif t supervisor controls all keys.

i Plant physical layout has cooling towers near the river, then the security fence with one light at mid point. Just inside the fence is a one story warehouse which extenda nearly the whole length of the fence, except for truck access space on both sides of the j

warehouse. The guard's shack is about 100 feet still further into l

the security area, about even with one end of the warehouse. I visited the site about 3 a.m. on a rainy night when the effluent i from the cooling towers was blowing toward the warehouse. The l

whole area was blanketed in vapor and concealment appeared to be no problem.

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The fence at the intake structure stopped about 10' short of the end of the sea wall on each side of the intake. . The purpose of the blank space was said to afford access to clean out the area i in front of the intake.

I made the following suggestions.

a. A derailer should be installed on the tracka entering the i

plant area. Monticello agreed.

b.

The fence at the intake structure should be extended to com-l plate the barrier. Other arrangesenta can be made.for cleaning in f ront of the intake. NSP's Security Manager agreed and l

i stated that the D00 inspector had made the same sunnestiam.

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! e. The fence behind the warehouse is vulnerable. So warehouse j itself can be used as a barrier if a fence is installed from each of its ends across the truck access space. We NSF i

Security Manager stated that he would have a response to this idea within two weeks'.

3. Adequacy of Abnormal Operating procedures.

t Each of the transients analyzed in the FSAR is cove ed by an l Abnormal Operating Procedure, in a separate section of the j operations Manual.

t The procedures in the Operations Manual are categorized by

system, and each system includea.a tabulation of annunciator i alarms relative to that system. . The tabulation includes'the name I of the system and sub-systems, the loestion of the annunciator

! unit on the panel, the location and type of sensor, and the corrective action to be taken in response to the alarm. operators are not required to memorise the immediate corrective action in j

response to alarms. No drills are conducted, on shift, en either i

abnormal operating procedures or responses to alarms. In the i stasmary meeting, I pointed out- that such drills would be a require--

! ment in the new version of Technical Specifiaations.

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j 4. Competence of Operating Crews.

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Judgeset of competence is subjective. I did this part of.eg job i by evaluating the tools-svailable to the operator and by observing

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ed conversing with all- levels of operators during routine opera-

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tion and during shift change.

i Voltase A of the Operators Manual contains Administrative Pro--

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I eedures. There is no written procedure describing shift turnover.

I observed two shift turnovers. . ome from days to the 3-11, and one from 3-11 to graveyard. Turnover..in both instances, consisted

} of a' walk through by both operators of instr - tation and con-l trols a review of los books by both in concert, and finally an i extended conversation between the two.

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Volume F of the Operators Manual consists of temporary procedures.

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- The original concept of this document was good; however Volume F i

now consists of - - 250 procedures, some of- which are 2 years-'old.

The Ead Waste system has a separate Control. Room. .There have

been many minor changes in design since installation. The

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operating procedures are not up t6 date. M e plant is now operated l with zero liquid radwaste. The final discharge is a radioactive

• sludge which is used in a concrete slurry and barreled as solid

waste.

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, I visited the plant at night _ to observe back shift operations fro:n about 10 p.ni. to 3.a.m. This afforded an opportunity to -

chat privaccly and informally with rural route operators as I f accompanied them on their rounds.  ;

j Host surveillance testing is done on the graveyard shif t. Une j shif t supervisor encourages lower grade operators to operate the

! control room knobs and switt hes during testing. Cther shift

[ supervisors and . older 'opers ors discourage such training. The-

! plant laborers, whose title is nuclear plant helper, and who do i the decontamination of the radwaste concrete barrels, feel that

! their yearly 10-hour training in radiation protection is too

} academic, and. consequently they do not retain the information.

4 In attmapting to evaluate crew competence, I took one incident -

i the Ceptember 5, 1971 screa - and tried to reconstruct the event i from docusentation. There were many gaps in the doctamentation.

The shift supervisor's log of the shift following the-incident i

had the following final entry "Too busy .to keep 's good'1c3."

j I esamined the minutes of the meetings of the Plant _ Operations l Committee and the Safety Audit Committee-(SAC) relative to the Septecaber 5 incident and_ did further spot-checking through these i records. There was more then one_ instance where the loop of

( incident, investigation, evaluation and corrective actior was

! not closed. In- discussing the september 5 incident, the SAC noted that an air failure was the initiating event, and that a previous study of the adequacy-of the plant air system had resulted

! in a asamber of reconseadaticas for improvement, but there had i been no follow through in seeing that the recossendations _were

! carried out. There are no controls for the plant air system in

! the control room, only a recorder. The incident was caused by an

! error by the suailiary operator at the. air cogressorocontrol; the control room operators responded properly.

' My evaluation of operating crew ccupotence:is best stunned up by saying that I had a feeling of ceafidence in the control room.

There appeared to be discipline, immediate response to-alarms, good morale, pride in detailed knowledge of the plant, copperation between shifts.

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! The data logger properly used, is an entremely useful tool. NBp

is fortunate in having an extremely competest computer engineer i

who uses the computer to analyze trends, and who manages to keep

. the computer on stream oncept for about two hours per month. - Mere is one problem, since the coaguter does such a good job, the operator's and shif t supervisor's logs suf fer. There does not i seem to be a good positive policy on what information must be logged.

l The Plant Supervisor was responsive in giving each of us his l opinion of upper NSP management competence. He thought that the

} V.P. level had little or no appreciation for nuclear plant problems.

l He has recently hired 8 young engineers all of whom just passed l SRO exams. As yet these enginers do not have clearly defined l

I responsibilities. They maybe reserve troops in case of labor problems - this is an IBEW shop; or the hope may be that they will mature into a strong on-site technical support group, he off-site technical support group - under Lee Mayer, Director of L Nuclear Support Services, still consists only of Mayer and one engineer, he inspection team visit to the NSF home office on June 7-8 will permit further evaluation of technical support.

C- - te oc Mamanement Ascraisal Effort.

Our team consisted of 6 people. We were almost universally agreed that

' there were toomany of us. . ne team should consist of no more than 3_-

mature reactor people, each with an appreciation for the interdependsece of management and operator. he assigned CO inspector should gp_ttbe a member of the team; he is inclined to feel defensive if the team unearths management deficiencies. Detailed inspection of health physics, emergency planaias l

and industr&al security, as was done by Higinbothan and Sears, should not be a part of the team effort - these concerns should be covered by-regular -

l CO inspections.

There was much overlapping in our efforts because there were so many of us.

nis resulted in many of us discussing the same topic with the sanas NSP man, but from a different view point. Some overlap is useful, since a finding by one may be reinforced by anothers investigation. For example, almost all of us found some example of a lack of " gap-closing" on the part of NSP.

We all agreed that this was the most serious management deficiency.

My principal contribution was investigation of- the lower grade operator situation. I volunteered for this ' effort, since it did not seem to be emphasized in the team plana. M is area is sometimes neglected, but I believe that it is important to get the operator's opinions on how upper and middle management policies are translated into- the kind of procedures -

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which can be underntood and followed. The team members sust reatud them.

selves regularly of the goal of the effort - management appraisal - and should not get bogged down in lengthy discussions on whether a particular incident should have been reported, or whether an individual item was or was not a 50.59 ite:r, or whether some words in the Tech Specs should be

changed. Tech Specs changes may result from the inspection, but time at the plant should be devoted to find ing out how the licensee's controls really work.

A fundamental precept of reactor regulation has always been that the licensee has the primary responsibility for safety. The licensee discharges that responsibility through management controls. The regulator should then i fulfill his own resp.sisibility by continuously appraising how licensee l management is performing. The interest of ' the regular inspection program is of ten focused on specific mechanical problems and management aspects are reicgated to the background. P.anagement inspections then are not only useful, but may well be .one of the most important features of the Regulatory program. Independence of the inspection auditors imust be as complete as possible to insure their objectivity.- The final interview with licensee upper management crowns the effort with thorns or gold depending on how the team findings are presented. If there is an overemphasis on legal aspects

, that only results in top management requiring the plant staff to produce more paper to keep the AEC quiet, then we have failed. If instead tha appraisal findings can be presented strictly frein the point of view of

our mutual interest in safety of operations and results in top management

taking the necessary measures to assure itself of the couplete validity of i all management controls, then the whole effort has been worthwhile.

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1 John R. Sears operational Safety Branch, 1.

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