ML20137G748
| ML20137G748 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 03/24/1997 |
| From: | Hill W NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9704010497 | |
| Download: ML20137G748 (13) | |
Text
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l Northem States Power Company Monticello Nuclear Generating Plant 2807 West Hwy 75 Monticello, Minnesota 55362-9637 March 24,1997 US Nuclear Regulatory Commission 10 CFR Part 2 Attn: Document Control Desk Section 2.201 Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DP9-22 Reply to Notice of Violation NRC System Operational Performance insoection (SOPI) Report No. 50-263/96009(DRS)
Pursuant to the provisions of 10 CFR Part 2, Section 2.201, our reply to the notice of violation contained in your letter of February 20,1997, is provided in Attachment A.
Attachment A contains the following new NRC commitments:
Violation 1.b 10 CFR 50.59 implementation processes will be enhanced. Process enhancement, including training on the revised processes and management's expectations regarding the quality nf engineering work, will be completed by March 31,1997 Violation ll.a,b,c,d Special training will be provided to Monticello engineering and technical staff personnel on the importance of rigor and attention to detail in performing, revising, reviewing, approving, and documenting calculations. This training will be complete by March 31,1997.
Violation Ill.a All Technical Specification Section 3/4 procedures will be examined over the next three year period to ensure that a basis for design document requirements and
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q;nnyo acceptance limits is properly documented.
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March 24,1997 Page 2 Plant AWis goveming procedure content and format will be reviewed and revised as necessary to require that bases for design document requirements and acceptance limits is provided within each procedure or by reference to an acceptable bases document.
Procedure revisions will be completed by June 1,1997.
All Technical Specification Section 3/4 procedures will be examined over the next three year period to ensure that a basis for design document requirements and acceptance limits is properly documented.
This will be accomplished by describing the i
source of the design document requirement or-acceptance limit within the procedure, or by i
reference to an acceptable bases document.
The procedures will be reviewed and revised j
as necessary by March 31,2000. Other procedures will be checked, as resources allow, to ensure that a basis for cesign document requirements and acceptance limits is properly documented.
Violation Ill.b All surveillance procedures will be examined to determine if the wording of the procedure could trap personnelinto signing off the procedure as completed before all required data analysis and engineering evaluation is complete.
Changes will be made to these surveillance procedures to ensure that they are tracked by the surveillance coordinator through completion of all required analysis and data evaluation. AWis goveming procedure content and format will be reviewed and revised as necessary to eliminate these potential traps.
All actions will be completed by March 31, 1998.
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US Nuclear Regulatory Commission March 24,1997 Page 3 1
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Please contact Mr' Samuel Shirey, Sr Licensing Engineer, at (612) 295-1449 if
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j you require further information.
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William J Hill j
i Plant Manager Monticello Nuclear Generating Plant c:
Regional Administrator-Ill, NRC isRR Project Manager, NRC Sr Resident inspector, NRC State of Minnesota Attn: Kris Sanda 4
Attachment a
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Monticello Nucle:r Genir: ting PI:nt R: ply to Notice of Viol tion March 24,1997 4
j Attachment A REPLY TO NOTICE OF VIOLATION 1.
Violation 10 CFR 50.59 (a)(1) stated, in part, that the holder of a license authorizing operation of a production facility may make changes in the facility as described in the safety analysis report without prior Commission approval unless the proposed change involves a change in the technical specification incorporated in the license or an unreviewed safety question.
10 CFR 50.59(b)(1) stated, in part, that the licensee shah maintain records of 1
changes in the facility. These records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
Contrary to the above:
a.
On August 14,1996, during closeout of Design Change Package
- 85M042, "RHR System Pressure Upgrade Modification," Revision 1, the safety evaluation failea to provide the bases for the determination that the physical plant changes, that were not retumed to their original values following the modification's cancellation, did not involve an unreviewed safety question, b.
On October 23, Safety Review item 96-016, "1996 FOl Identified USAR Changes," Revision 0, Addendum 4, failed to provide the bases for the determination that each change identified in the safety review item did not involve an unreviewed safety question.
NSP Response to item I.a NSP acknowledges example 'a' cited in the above Notice of Violation.
Reason for Violation:
In the case of Modification 85M042, a safety evaluation was performed and a USAR submittal was prepared in 1986 for this modification in its original form. After completing part of the work in 1986, the modification was put on hold when questions arose concerning the change. Plant management later cancelled the modification and the pending USAR change. Engineering failed to recognize in 1986 that the scope of work actually completed under Modification 85M042 prior to its cancellation Page A-1
Monticello Nucle:r Gener: ting Pl nt R: ply to Notice of Vioittion March 24,1997 l
constituted a change to the facility as described in the Updated Safety Analysis Report (USAR). At that time the plant should have revised the existing safety evaluation and prepared a change to the USAR.
The resulting USAR discrepancy was discovered in 1990 as part of design basis document reviews. After making operability and reportability
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determinations, a safety evaluation was performed to support a correction I
of the discrepancy between the USAR and design documents. This safety evaluation, however, did not consider the cause of the discrepancy (i.e., the lack of an adequate safety evaluation for the original 1986 modification). Consequently the safety evaluation incorrectly focused on the USAR change itself and whether it was consistent with the facility.
The safety evaluation should have focused on the changes made to the facility by the 1986 modification and whether those changes involved an i
unreviewed safety question.
it was recognized that this particular modification was a special situation because there were no procedures which covered closure of an incomplete modification. Because it was also one of the oldest open modifications in the backlog, it received increased management attention.
There were several meetings among plant management to determine how best to address the work which was not completed by the original modification. After much discussion it was decided in 1996 that the best course of action was to close out the modification by revising the modification package to reflect the reduction in scope (i.e., to reflect the work actually accomplished in 1986). However, since no additional physical plant changes were associated with the 1996 revision of the modification package, and because by 1996 the USAR was in agreement with the actual plant configuration, we again did not recognize that the original 1986 safety evaluation was deficient.
Therefore, the Monticello technical staff failed to recognize in 1986, when the modification was partially completed, or in the early 1990s when the USAR discrepancy was corrected, or in 1996 when the modification was revised and closed out, that an adequate safety evaluation addressing the actual scope of work was never performed. The situation was aggravated by delay in closing out the modification and the lack of procedures to cover the unusual and complicated situation of a partially completed and cancelled modification.
Corrective Action Taken and Results Achieved:
Plant procedures have been revised to require a new or revised safety evaluation whenever a change in the scope of a modification affects an existing safety evaluation.
Page A-2
i Mohticello Nucle:r Generating Pirnt Reply to Notics of Viol: tion March 24,1997 i
A Monticello Condition Report has been initiated to address the failure of j
the 198610 CFR 50.59 safety evaluation to cover the scope of work actually accomplished under Modification 85M042 (Condition Report 97000239).
l Durhg review of this issue, an additional discrepancy in the safety evaluation for the 1986 modification was discovered. A relief valve setpoint was changed and this change was inconsistent with an earlier NRC Safety Evaluation Report (SER). An operability evaluation was completed and it was determined that the setpoint change did not affect the operability of the RHR system. This issue is being assessed and resolved through the Monticello Condition Report process (Condition Report 97000692).
Corrective Action to be Taken to Avoid Further Violations:
Additional corrective actions are aescribed in the response to item 1.b below.
Date When Full Comoliance Will Be Achieved Full Compliance has been achieved.
i NSP Response to item 1.b NSP acknowledges example 'b'in the above Notice of Violation.
Reason for Violation:
Safety Review Item (SRI)96-016, Addendum 4, was one portion of an SRI that attempted to evaluate several unrelated activities at once. The
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result was a confusing, incomplete, and difficult to review evaluation which did not clearly address each activity using all of the 10 CFR 50.59(a)(2)
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criteria.
Corrective Action Taken and Results Achieved:
Safety Review item 96-016, Addendum 4, is being revised to correct the deficie :cies described in the SOPl report. This is being tracked as a Management Commitment (A97012A).
Page A-3
i Monticello Nuclecr G:ner ting Plint R: ply to Notice of Viol: tion March 24,1997 l
Corrective Action to be Taken to Avoid Further Violations:
Both examples cited in the Notice of Violation indicate poor implementation of 10 CFR 50.59. These examples and recent industry experience prompted Monticello management to examine all 10 CFR 50.59 implementing procedures and practices. This review concluded j
that applicable plant Administrative Work Instructions (AWis) need to be 1
revised to provide significantly more detail and to clearly communicate management expectations regarding the content and level of detail of 10 CFR 50.59 evaluations.
1 Training will also be presented to plant engineering and technical staff on 4
l the nature of this violation, the new and enhanced 10 CFR 50.59 evaluation processes, and management's expectations regarding quality j
of engineering work. AWis will be revised and training will be completed by March 31,1997.
Date When Full Comoliance Will Be Achieved Full compliance has been achieved.
II.
Violation 10 CFR Part 50, Appendix B, Criterion Ill, " Design Control," states, in part, that measures shall provide for verifying or checking the adequacy of the destgr;, and that changes shall be subject to design control measures commensurate with those applied to the original design.
Contrary to the above:
1 a.
On March 14,1996, changes were made to General Electric Calculation EqDE-34-0687, " Core Spray System Operational Capability Report," and these changes were not commensurate with those applied to the original design. Changes were " penciled-in" on a copy of the calculation, the " revised" calculation was not entered into the documo d control system, and a record of the
" revised" calculation was not identifiable or retrievable within the quality assurance records system.
b.
On June 24,1996, calculation CA-96-090, " Evaluation of ECCS Net Positive Suction Head," Revision 0, was approved although the design verification activities were not adequate. The calculation reached an incorrect conclusion as to the amount of available net Page A-4
Monticella Nucler Generating PI nt Reply to Notice of Violation March 24,1997 positive suction head because the vapor pressure value used in the calculation for water at 191 F was incorrect.
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c.
On December 6,1996, calculation CA-96-166, "Drywell Flooding Evaluation for Post DBA LOCA," Revision 0, was approved to resolve non-conservative and non-verified assumptions contained in calculation CA-93-056 " Suppression Pool Drawdown Calculation." The verification for the 1996 calculation was not i
adequate in that the calculation still contained non-verified, non-conservative assumptions, d.
On May 19,1995, calculation CA-94-20, "RHR/RHR Service Water Heat Exchanger Pe formance," Revision 1, was approved although the design verificatior, activities were not adequate. The verification consisted of confirming that a computer could perform mathematical computations rather than verifying that the formulae input to the computer were accurate.
NSP Response to item II.a NSP acknowledges example 'a' cited in the above Notice of Violation.
Reason for Violation The Monticello calculation control process was not adhered to in this instance. Changes to the calculation should have been formalized and controlled in accordance with Monticello 4 awl-05.01.25.
" Calculation / Analysis Control." Use of this process would have assured that the revised calculation was properly prepared, reviewed, approved, and entered into the Monticello document control system. The cause of this event was, therefore, failure to follow prescribed plant administrative processes and lack of attention to detail.
Corrective Action Taken and Results Achieved:
Changes to General Electric Calculation EqDE-34-0687 have been formalized and processed in accordance with 4 awl-05.01.25.
I Corrective Actions to be Taken to Avoid Further Violations:
Special training will be provided to Monticello engineering and technical staff personnel on the importance of rigor and attention to detat in performing, revising, reviewing, approving, and documenting caiculations.
The expectations of Monticello management, that the Calculation / Analysis Page A-5
Montic:lla Nu irr G:nerating PI:nt Reply to Notice of Viol: tion March 24,1997 1
Control process will be followed to the letter, will be emphasized at this special training. This training will be complete by March 3'i,1997.
Date When Full Comoliance Will be Achieved:
4 Full compliance has been achieved.
4 NSP Response to item II.b NSP acknowledges example 'b' cited in the above Notice of Violation.
I Reason for Violation I
While this error was small and somewhat subtle, it should not have j
occurred. The engineer who performed this calculation may have lacked i
sufficient experience in pump net positive suction head (NPSH) design i
calculations. The engineer reviewing the calculation did not detect the j
error. And finally, the error was not detected by the engineering supervisor who approved the calculation. The cause of this event was lack of attention to detail.
Corrective Action Taken and Results Achieved:
Calculation CA-96-090 has been revised to correct the error noted in the Violation.
1 ECCS pump NPSH calculations have been independently redone and verified by an outside engineering consultant. Additional, more detailed, 4
NPSH calculations have been requested from the engineering consultant.
Corrective Actions to be Taken to Avoid Further Violations:
Special training will be provided to all Monticello engineering and technical staff personnel on the importance of rigor and attention to detailin performhg, revising, reviewing, approving, and documenting calculations as deuibed in the re.sponse to item II.a above.
l Date When Full Comoliance Will be Achieved:
Full compliance has been achieved.
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M:nticello Nucicer Generating PI nt Reply to Notice of Viol tion March 24,1997 NSP Response to item II.c NSP acknowledges example 'c' cited in the above Notice of Violation.
Reason for Violation Again, while these errors were small and somewhat subtle, they should not have occurred. The errors were caused by lack of attention to detail.
Corrective Action Taken and Results Achieved:
Calculation CA-96-166 has been revised to address the inspector's concems.
Corrective Actions to be Taken to Avoid Further Violations:
Special training will be provided to all Monticello engineering and technical staff personnel on the importance of rigor and attention to detail in performing, revising, reviewing, approving, and documenting calculations as described in the response to item II.a above.
Date When Full Comoliance Will be Achieved:
Full compliance has been achieved.
NSP Response to item II.d NSP acknowledges example 'd' cited in the above Notice of Violation.
Reason for Violation The Monticello calculation control process was again not adhered to in this instance. The verification of the computer code change failed to independently confirm the validity of an equation used to derive a fundamental parameter used in the calculation. The cause of this event was failure to follow prescribed plant administrative processes and lack of attention to detail.
Corrective Action Taken and Results Achieved:
Independent verification of CA-94-20 has been reperformed by an experienced senior Monticello engineer.
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Monticells Nucle r Gener ting PI:nt Reply to N:tice of Viol: tion March 24,1997 Corrective Actions to be Taken to Avoid Further Violations:
Refer to the description of special training that will be performed in the
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response to item II.a above. This training will be complete by March 31, 1997.
Date When Full Comoliance Will be Achieved:
Full compliance has been achieved.
lil.
Violation 10 CFR Part 50, Appendix B, Criterion XI, " Test Control," states, in part, that a test program shall be established to assure testing is performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in design documents. Test results shall be documented and evaluated to assure test requirements have been satisfied.
Contrary to the above:
a.
On March 16,1995, surveillance procedure 1136, "RHR Heat i
Exchanger Efficiency Test" was revised such that the acceptance limits contained in design documents were no longer incorporated into the surveillance procedure. Specifically, the procedure was revised to incorporate a heat exchanger area not contained in any 1
design document.
j b.
On March 23,1995, surveillance procedure 1136, "RHR Heat Exchanger Efficiency Test," Revision 15, was signed by the shift engineer as complete without the test results being evaluated to assure test requirements were satisfied. The "HXPERF" computer program output sheets, showing that the test results were 1
acceptable and required by the procedure to be attached, were dated October 22,1996, and were based on Revision 1 of the computer program rather than on Revision 0 as specified by the test procedure.
NSP Response to item lil.a NSP acknowledges example 'a' cited in the above Notice of Violation subject to l
the following clarifying information.
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Montic:llo Nude.:r G:ner ting Pl:nt Reply to Notice of Violation March 24,1997 Reason for Violation:
We believe that the Monticello RHR heat exchanger efficiency test acceptance criteria were correct and conservative. The criteria were I
based on the results of Calculation CA-94-066, Revision 0, " Determination of RHR Heat Exchanger K value," and were used in the evaluation of 4
containment response as provided in NEDO-32418, "Monticello Design i
Basis Accident Containment Pressure and Temperature Response for USAR Update," December,1994. However, the heat exchanger vendor's technical manual was not updated with revised heat exchanger surface area data at the time of the inspection. Additional guidance related to timely update of documents in the Condition Report Process AWI is needed to ensure prompt update of this manual.
It is also acknowledged that Monticello test procedures do not always provide the basis for test requirements and test acceptance criteria or link such requirements and acceptance criteria to design documents.
Corrective Action Taken and the Results Achieved A Monticello Condition Report has been initiated to address updating of the RHR heat exchanger vendor manual (Condition Report 97000770).
Corrective Action That Will Be Taken to Avoid Further Violations The Condition Report Process AWI will be reviewed and additional guidance provided as necessary to help ensure corrective actions are identified and tracked related to updating of plant documents. This will be completed by April 30,1997.
Plant AWis governing procedure content and format will be reviewed and revised as necessary to require that bases for design document requirements and acceptance limits is provided within each procedure or by reference to an acceptable bases document. Procedure revisions will be completed by June 1,1997.
All Technical Specification Section 3/4 procedures will be examined over the next three year period to ensure that a basis for design document requirements and acceptance limits is properly documented. This will be accomplished by describing the source of the design document requirement or acceptance limit within the procedure, or by reference to an acceptable bases document. The procedures will be reviewed and revised as necessary by March 31,2000. Other procedures will be checked, as resources allow, to ensure that a basis for design document requirements and acceptance limits is properly documented, Page A-9
M:ntic Ilo Nuclerr Generating Plant R: ply to Notke of Violation March 24,1997 i
Date When Full Comoliance Will Be Achieved Full compliance has been achieved.
4 NSP Response to item lli.b NSP acknowledges example 'b' cited in the above Notice of Violation.
Reason for Violation:
Approximately 18 months elapsed between collection of heat exchanger test data and completion of analysis of the data.
The engineering analysis section of the test procedure was improperly signed off as "NA" after the heat exchanger test data was collected. With the "NA" entry, the test was considered as complete even though the test data had not been analyzed by engineering. Since the procedure was considered complete, it was not called out for follow-up by the surveillance coordinator as would normally be the case for a late test. This procedure, and other similar procedures, are formatted in such a way that they increase the likelihood of prematurely signing off a procedure as complete.
Corrective Action Taken and the Results Achieved See a description of the corrective actions to be taken below.
Corrective Action to Be Taken to Avoid Further Violations AWis goveming procedure content and format will be reviewed and revised as necessary to eliminate the potential trap descripted above. All surveillance procedures will be examined over the next year to determine if the wording of the procedure could trap personnelinto signing off the proce sure as completed before all required data analysis and engineering evaluation is complete. Changes will be made to these surveillance procedures to ensure that they are tracked by the surveillance coordinator through completion of all required analysis and data evaluation. All actions will be completed by March 31,1998.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
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