ML20138N675

Forwards Sys Operational Performance Insp Rept 50-263/96-09 on 961118-970108 & Nov.Violation of Concern Because of Continuing Problems W/Test Control & Incorporation of Corrective Design Limits

ML20138N675
Person / Time
Site:	Monticello
Issue date:	02/20/1997
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Wadley M NORTHERN STATES POWER CO.
Shared Package
ML20138N678	List: ML20138N675 ML20138N693 ML20138N699
References
EA-97-032, EA-97-32, NUDOCS 9703030094
Download: ML20138N675 (3)

See also: IR 05000263/1996009

Text

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February 20,1997

EA 97-032

Mr. M. D. Wadley

Vice President, Nuclear Generation ,

Northern States Power Company I

414 Nicollet Mall

Minneapolis, MN 55401 i

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SUBJECT: NRC SYSTEM OPERATIONAL PERFORMANCE INSPECTION (SOPI) REPORT

50-263/96009(DRS)  !

Dear Mr. Wadley:

This refers to the system operational performance inspection (SOPI) completed January 8, l

1997, at the Monticello Nuclear Generating facility. The inspection team assessed the

residual heat removal (RHR) system's operational performance by a detailed review of the

RHR's design, maintenance, operation, and surveillance and testing. The enclosed report

presents the results of this inspection. ,

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Overall the results of the SOPl inspection raised concerns about an apparent gradual  !

erosion of the Monticello plant's design and licensing basis. While engineering personnel l

appeared competent, the team's review of calculations identified a lack of rigor and j

attention to detail that did not correlate with our previous view of Monticello's l

performance. Safety evaluations, performed in accordance with 10 CFR 50.59, were not

always explicit in stating facts that supported the conclusion that an unreviewed safety

question did not exist. In one case, an unreviewed safety qJestion apparently did exist

and was not identified by your engineering staff. Although the Design Basis Documents

have long been considered a good effort on your part, the way your staff resolved

concerns identified during the design basis reconstitution appears to have been less than  ;

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adequate in some cases.

Additionally, we are concerned about the continuing problems with test control, especially

incorporation of correct design limits. We have brought test control issues to your j

attention in several inspection reports over the last year, including 50-263/96005, 96006, I

and 96008. The continued occurrence of prc Mms eppears to indicate that broader i

corrective actions are required to resolve the issues. l

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The team did note knowledgeable performance by auxiliary operators and good adherence

j to procedures in the operations area. Additionally, the team judged maintenance to be

generally well performed, although procedures were considered to be weak. I

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M. D. Wadley -2- February 20,1997

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Based on the results of this inspection, the NRC has determined that violations of NRC

requirements occurred. These violations are cited in the enclosed Notice of Violation

(Notice) and the circumstances surrounding them are described in detail in the subject l

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inspection report.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part,

to determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

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In addition, an apparent violation was identified and is being considered for escalated

enforcement action !n accordance with the " General Statement of Policy and Procedure for

NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. This apparent violation l

involves an inadequate safety review item performed in 1995 which did not identify that

the change involved an unreviewed safety question. The safety review item concluded

that no unreviewed safety question existed when changing the required post accident

emergency core cooling pump configuration, even though (1) the technical specifications

and technical specification bases explicitly defined the post accident ECCS pump

configuration, (2) the containment temperature increased by ten degrees shoit term and

two degrees long term, and (3) a different, unapprov3d, computer code was used in the

analyses although the safety analysis report had specifically noted that the previous code

was approved by NRC. Accordingly, no Notice of Violation is presently being issued for

this inspection finding. In addition, please be advised thet the number and characterization

of apparent violations described in the enclosed inspection report may change as a result

of further NRC review.

An open predecisional enforcement conference to discuss this apparent violation has been  !

I scheduled for 1:00 p.m. on Wednesday, March 5,1997. The decision to hold a j

predecisional enforcement conference does not mean that the NRC has determined that a l

l violation has occurred nr that enforcement action will be taken. This conference is being

held to obtain information to enable the NRC to make an enfor.:ement decision, such as a

common understanding of the facts, root causes, missed opportunities to identify the  !

apparent violation sooner, corrective actions, significance, of the issues and the need for

lasting and effective corrective action. In particular, we expect you to address the

changes necessary to improve the safety evaluation process to ensure that, in the future,

issues involving unreviewed safety questions are properly characterized and appropriately

submitted to the NRC. Ir: ddition, this is an opportunity for you to point out any errors in

our inspection report and for you to provide any information concerning your perspectives

on 1) the severity of the violation,2) the application of the factors that the NRC considers

when it determines the amount of a civil penalty that may be assessed in accordance with

Section VI.B.2 of the Enforcement Policy, and 3) any other application of the Enforcoment

Policy to this case, including the exercise of discretion in accordance with Section Vll.

Following the conference, you will be advised by separate correspondence of the results of

our deliberations on the apparent violation. Therefore, no response regarding the apparent

violation is required at this time.

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M. D. Wadley -3- February 20, 1997

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,

its enclosure (s), and your response will be placed in the NRC Public Document Room.

Sincerely,

Original Signed by Geoffrey E. Grant

Geoffrey E. Grant, Director

Division of Reactor Safety

Docket No. 50-263

Enclosures: 1. Notice of Violation

2. Inspection Report 50-263/96009(DRS)

cc w/encis: Plant Manager, Monticello

John W. Ferman, Ph.D.

Nuclear Engineer, MPCA

State Liaison Officer, State

of Minnesota

Distribution:

Docket File w/enci SRIs, Monticello CAA1 w/ encl

PUBLIC IE-01 w/enct Prairie Island w/enci J. Lieberman, OE w/en l

OC/LFDCB w/ encl LPM, NRR w/enct J. Goldberg, OGC w/ encl

DRP w/ encl A. B. Beach, Ritt w/enci R. Zimmerman, NRR w/ encl

DRS w/enci W. L. Axelson, Rlll w/ encl

Rlli PRR w/enci Enf. Coordinator, Rlll w/enci

DOCUMENT NAME: G:\DRS\ MON 96009.DRS

To reoolve a copy of this document. Indicate in the box: 'C" = Copy w/o attachment / enclosure 'E" = Copy with attachment / enclosure *N' = No copy

0FFICE RIII:DRS lg Rlll:DRS lE RIIIM mM RIII:EICS le

. RIII:DRS_ .

NAME Lougheed/kjc M Rincr A Jaq6bsoNW\ Cl ayton g,,c_ Leach /GrWW

DATE 02//3 /97 02/ s q /97 02/ b /fC) 02// 4 /97 02/ 2.0 //9 7 )

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