ML20205F852
| ML20205F852 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 08/14/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20205F820 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-***, TASK-TM 50-263-86-01, 50-263-86-1, NUDOCS 8608190342 | |
| Download: ML20205F852 (31) | |
See also: IR 05000263/1986001
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SALP 6
SALP BOARD REPORT
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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- 50-263/86001
j Inspection Report
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Northern States Power Company
- Name of Licensee
Monticello
Name of Facility
December 1, 1984 through May 31, 1986
Assessment Period
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8608190342 860814
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ADOCK 05000263
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A
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect;available observations and data on
a periodic basis and to evaluate licencee. performance based upon this
information. SALP is supplemental to normal regulatory processes used to
ensure compliance to NRC rules and regulations. 'SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's mana
to promote quality and safety of plant construction and operation. gement
A NRC SALP Bot.rd, composed of staff members' listed below, met on August 7,
1986, to review the collection of performance observations and data to
assess the licensee's performance in accordance with the guidance in NRC
Manual Chapter 0516, " Systematic Assessment'of Licensee Performance." A
summary of the guidance and evaluation criteria is provided in Section II
of this report.
SALP Board for Monticello:
Name Title
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J. A. Hind Director, Divisica of Radiological
Safety and Safeguards
C. E. Norelius Director,DivisionofReactorProjects
N. J. Chrissotimos Deputy Director, Division of Reactor -
Safety
L. R. Greger Chief, Facilities Radiation Protection
Section '
E. R. Schweibinz Chief, Technical Support Staff
M. A. Ring Chief, Test Programs Section .
F. Hawkins Chief, Quality Assurance Programs '
Section
M. P. Phillips Chief, Operational Programs Section-
D. C. Boyd Chief,ReactorProjectsSection2D
T. M. Burdick Chief, Operator Licensing
R. B. Landsman PrcjectManager,ReactorProjects'
Section 2D
Je R. Kniceley Physical Security Inspector
J. P. Patterson Emergency Preparedness Analyst
P. Hartmann Senior Resident Inspector
S. M. Hare -
Inspector
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II. CRITERIA
Licensee performance is assessed in selected functional areas, depending
upon whether the facility is in a construction, preoperational, or
operating phase. Functional areas normally represent areas significant to
nuclear safety and the environment. Some functional areas may not be
assessed because of little or no licensee activities, or lack of meaningful
observations. Special areas may be added to highlight significant
observations.
One or mere of the following evaluation criteria were used to assess each
functional area.
1. Management involvement and control in assuring quality
2. Approach to the resolution of technical issues from a safety
standpoint
3. Responsiveness to NRC initiatives
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4. Enforcement history
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5. Operational and Construction events (including response to, analyses
of, and corrective actions for)
6. . Staffing (including management) ,.
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However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
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. Based upon the SALP Board assessment each functional area evaluated is "
classified into one of three performance categories. The definitions of '
these performance categories are.:
Category 1: Reduced NRC attention may be appropriate. Licensee
management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used so that
a high level of performance with respect to operational safety and
construction quality is being achieved.
Cateaory 2: NRC attention should be maintained at normal levels. Licensee
management attention and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably
effective so that satisfactory performance with respect to operational j
safety and construction quality is being achieved. l
Category 3: Both NRC and licensee attention should be increased. Licensee
management attention and involvement is acceptable and considers nuclear
safety, but weaknesses are evident; licensee resources appear to be strained
or not effectively used so that minimally satisfactory, performance with
respect to operational safety or construction quality is being achieved. ,
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III. SUMMARY OF RESULTS
The overall regulatory performance of the Monticello Plant has continued ^
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performance in the areas of Radiological Controls and Fire Protection is
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Rating Last Period Rating This Period
July 1, 1983 - December 1, 1984 -
- Functional Areas November 30, 1984 May 31, 1986
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A. Plant Operations 1 1
B. Radiological Controls 2 a 1
C. Maintenance 1 -
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- D. Surveillance and
- Inservice Testing 2 2
E. Fire Protection 2 1
F. Emergency Preparedness 1 1
G. Security 1 1
H. Outages 1 1
I. Quality Programs and
Administrative Controls
AffectingQuality 2 2
J. Licensing Activities 1 1
K. Training and Qualification
Effectiveness ., * 2
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- Not Rated (new functional' area for SALP 6)
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IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
Plant operations during the assessment period consisted of a j
startup from a major outage to replace recirculation system l
piping, 15 months of power operation, and one month of a i
refueling outage (which continues into the next ,issessment
period). Therefore, the analysis for this area involves
activities of the operational staff for various modes of
operation. '
Portions of routine inspections were performed by the resident
inspector covering plant operations. The inspections included
observations of control room operations, reviews of logs,
discussions with licensed and unlicensed operators, verification
of operability of emergency systems, and reviews of reactor
building and turbine building equipment status.
No violations were identified in the operations area. This
is a decrease from the previous assessment period.
Three reactor scrams from power occurred during the assessment
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period. The first resulted from an offsite power line
transformer being grounded by an electrical maintenance crew .
about 30 miles from the plant. The second occurred during
surveillance testing of the main steam line low pressure
instrument by an I&C technician improperly valving pressure
switches. The third occurred dug to low vessel level after loss
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of a recirculation pump, and the level transient tripped all
reactor feedwater pumps. These scrams involve personnel and
procedural error, but not on the part of licensed operators.
The scram frequency is less than the industry average. The
unit experienced a record 200-day run which was terminated by
a scheduled refueling outage.
Seven LERs involving personnel error were made during the
assessment period. Of these, one involving the restoration of
an uninterruptable power supply was made by a licensed operator.
The remaining personnel errors will be discussed in the
appropriate functional areas.
The licensee has demonstrated a clear understanding of technical
issues. Conservatism is routinely exhibited during application
of technical specification requirements and in determining
operability of equipment as was evidenced by the ma.cagement
decision to remain shutdown after the last scram to investigate
and repair the cause of increased drywell leakage, although well
below technical specification limits. ,
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The licensee demonstrated the ability to control and resolve
many technical and operational issues as evidenced by the smooth
progression of the startup after a long shutdown to replace
recirculation piping. The plant operating record is exemplary
with a cumulative availability of 75.6 percent (which includes
the 11.5 month shutdown), which ranks third highest of BWRs in
the nation.
During the assessment period the Emergency Filtration Train (EFT)
was actuated in the emergency mode on 21 occasions. The EFT
system supplies Control Room ventilation, and its actuation is
reportable as an Engineering Safety Feature. These actuations
resulted in 12 Licensee Event Reports (LERs) during the assessment
period. In 1985, 17 actuations occurred, mostly attributable to
detection tape breakage or tape runout. Based on an investigation
of a dedicated system engineer, the licensee took the following
corrective actions: interaction with the supplier of detector
tape for improved quality; biweekly changeout of detector tape;
and cleaning of the detector heads more frequently. In the five
months following this corrective action, EFT actuations had
dropped 41 percent from a frequency-of 1.4 to 0.8 actuations
per month.
During the assessment pericd, 32 percent of the LERs were
attributable to EFT actuations. This short-term corrective
action should reduce the total number of LERs. The long term
corrective action initiated by the licensee was started by a
Technical Specification Amendment request to remove the hydrogen
chloride, ammonia, and hydrogen sulfide detectors. Also the
licensee is studying removing all stored chlorine from the site
tnus allowing removal of the chlorine detectors. These actions
. would sharply reduce the number of unwanted actuations of the
EFT.
The licensee is responsive to NRC initiatives and timely and
technically sound responses are given in all cases. The
operations staffing remains a licensee strength. The control
room operators, shift supervisors and site superintendents are
well experienced and knowledgeable in their duties. The
operations staff has a low attrition rate which has led to the
high experience level currently enjoyed by the licensee. The
licensee has implemented a degree program for senior reactor ;
operators which will provide experienced operators with the j
opportunity to earn a technical college degree. Management of 1
operations is strong, providing a motivated, experienced, and
successful staff. i
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Plant management places importance of the professional conduct of l
operating personnel. Control room atmosphere is of a professional
nature. Operators are attentive to their duties, conduct them-
selves professionally, and present a professional image. This
professional atmosphere is enhanced by the design of the shift
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supervisor's office being adjacen't to, but separate from, the
control room. This situation provides an area for maintenance,
surveillance, and engineering, personnel to interact with the
shift supervisors without having to enter the control room. .
Thus, control room traffic is reduced to only necessary personnel.
The plant management has a " black board" policy regarding the
annunciator panels in the control room. This resulted in only
occasional lit annuciators which were typically cleared promptly.
The control board was " black" during the majority of the
assessment period resulting in a high confidence level in
the annunciator functions by the operators.
2. Conclusion
The licensee is rated Category 1 in this area which is the same
as the last assessment.
3. Board Recommendations
None.
B. R_adiological Controls
1. Analysis
Four inspections were performed during the first half of this
assessment period by region-based inspectors. These inspections
included operational radiation protection, transportation,
confirmatory measurements, chemistry / radiochemistry, radwaste,
and radiological environmental monitoring. The resident
inspector also reviewed this area during routine inspections and
performed the only NRC inspections in this area during the second
half of this assessment period. No violations or deviations were
, identified.
Staffing continues to be a licensee strength. The staff is
stable with no significant turnover other than career progression.
The staff size is adequate and authorities and responsibilities
are well defined; this results in generally good performance of i
all the necessary radiation protection, radiochemistry / chemistry, l
and radwaste functions. Nuclear plant helpers were transferred '
to the Radiation Protection Department, creating a more integrated
operation for lLundry processing and decontamination of tools,
equipment, and plant areas. This transfer of responsibility
allows management to prioritize the use of resources from a
radiological standpoint.
Management involvement in this functional area is consistently
evident. Managers and supervisors are closely involved in the
day-to-day activities of the plant. Procedures and policies are
strictly adhered to and records are complete, well maintained,
and available to personnel. A practice implemented during this
assessment period by the licensee has radiation protection personnel
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attending contractors' safety meetings to answer questions and
provide guidance in radiological matters. This practice appears
to have generated an improved understanding and cooperativeness l
on the part of the contract workers. Corrective actions for I
identified problems are prompt and consistently recognize and
address underlying cencerns. Although not specifically reviewed -
this assessment period, audits of the radiation protection ,
program have historically been conducted annually and have been
complete, timely, and thorough. A licensee audit of the
Radiological Environmental Protection Program (REMP) contractor's ,
performance identified a need to use the proper LLD values, which '
has since been corrected. None of the findings in the audit
indicated that the REMP failed to meet applicable technical
specification requirements; all findings have been closed in a
timely manner.
Responsiveness to NRC initiatives has been good during this l
assessment period. The licensee initiated aggressive contaminated j
aree and solid radwaste reduction programs. A significant j
reduction in contaminated areas, and contamination levels in the
remaining contaminated areas, has resulted. Some of the released
areas had been contaminated since early in plant operation. In
addition to the decontamination activity, modes of contamination
spread were identified and appropriate corrective actions taken ,
to reduce future contamination spread. The solid radwaste
reduction program incorporates administrative controls over '
introduction of waste material into potentially contaminated
areas and over equipment and tool use.in potentially contaminated
areas, and use of improved volume reduction equipment. The solid
radwaste reduction program has helped reduce the volume of
radwaste from 43,000 cubic feet in 1984 to 19,000 cubic feet in
1985, and has a 10,000 cubic feet goal for 1986. The licensee
has also demonstrated responsiveness to inspector concerns by
completing a procedure on waste classification which documents,
verifies, and incorporates a procedure for waste classification
computer programs, and by modifying the waste radioactive
material shipping procedure to include reference to the new
radwaste requirements.
A conservative approach to resolution of radiological control
issues is routinely exhioited. Personal radiation exposures
for 1985 were 310 person-rem which is significantly below the
800 person-rem average for U.S. boiling water reactors. The
licensee continued to upgrade its ALARA program during this
assessment period. A new ALARA program document has been written
and a committee chartered consisting of top plant management for
plant ALARA decisions. A new ALARA checklist was developed and
department goals have been established. In order to reduce
internal radiation exposure potentials, tne licensee has
purchased and set up positive containment systems for
contamination control.in the Control Rod Drive Rebuilding
and Transversing Incore Probe Drive areas.
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The licensee continues its conservative policy of prohibiting
routine liquid radioactive releases. Waste liquids are recycled
for reuse in the reactor coolant system or used in processing
solid wastes. An unusually large amount of waste water, about
800,000 gallons per u nth, was processed during the major main-
tenance outage which ended early in this assessment period.
Gaseous effluent releases remained lower than average for U.S.
boiling water reactors primarily due to the licensee's offgas
system design which utilizes waste gas storage tanks, and to
licensee efforts to maintain low condenser air in-leakage
(4-5 cfm). The number of solid radioactive waste shipments were
about average for U.S. boiling water reactors. The licensee is
satisfactorily implementing the requirements of 10 CFR 20.311 and
10 CFR 61 applicable to low-level radwaste classification, waste
form, and stabilization. No problems have been associated with
the licensee's radwaste shipments. The licensee also made
18 shipments of spent fuel to the GE-Morris storage facility
without incident during this assessment period.
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Licensee chemistry and radiochemistry programs were well
implemented during this assessment period. The licensee's
laboratory chemical instrumentation is being upgraded with the
. purchase of an atomic absorption spectrophotometer and an ion
chromatograph for analysis of nonradiological key chemical
parameters to maintain tight chemistry control.over plant systems.
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The licensee has recently prepared two procedures describing
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their QA/QC programs for chemistry and has begun to implement
these programs. They involve instrument calibration and calibra-
tion verifications, testing the proficiency of the Radiation
Protection Specialists (RPS) for non' radiological samples by ;
providing them with blind samples on a periodic basis, and
requiring the RPSs to participate in an interlaboratory round .
robin analysis program. A weakness in this area is the lack'of .
licensee participation in the cross check program for
radiochemical analyses.
Confirmatory measure.nent results during this assessment period
have declined in performance since the previous period in 1983.
The licensee had 33 agreements out of 40 comparisons. The
licensee, where possible, made timely and prompt corrections
during the analyses, such as correcting gamma spectroscopy
software to resolve one disagreement. However, the licensee
appears to have some difficulty in performing beta analyses
with disagreements for tritium, strontium-89, and gross beta
in two split samples and with disagreement for strontium-89 in
a spiked sample sent from the NRC Reference Laboratory.
Outside of the fact that in a few instances the licensee used
improper lower limits of detection (LLD) values during the first
quarter of 1983, when the new Radiological Effluent Technical
Specification became effective, implementation of the REMP has
been generally satisfactory. The licensee's contractor continues
to follow good quality control practices through participation
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in the EPA cross check program and an international comparison
thermoluminescent dosimeter program. Corporate management .
maintains trend plots of REMP sample dat'a indicating an' i
appropriate assessment for data review. No environm' ental
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trends attributable to plant operation were identified.
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2. Conclusion l
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The licensee is rated a Category 1 in this area. The licensee's l
overall performance has improved with the exception of their l
performance in confirmatory measurements which has declined i
somewhat during this assessment period. l
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3. Board Recommendations
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C. Maintenance
1. Analysis
Portions of nine routine inspections were performed by the
resident inspector covering this area. The inspections included
reviews of normal maintenance and modification activities to
ensure that approvals were obtained prior to initiating work,
activities were accomplished using approved procedures, post
maintenance testing was completed prior to returning components or -
systems to service, parts and materials were properly certified.
In addition, four inspections by regional-based inspectors were
performed in this area. These inspections examined the functional
testing and maintenance of safety-related snubbers, resolution of
. IE Bulletins',-licensee actions related to previous inspection
findings, a'10 CFR 71 report, and the review of items of concern '
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related to the replacement of Recirculation and Residual Heat
Removal system piping. In addition, work planning and scheduling
was reviewed as well as the effectiveness of administrative
controls to ensure proper priority is assigned. '
No violations were identified in this area. Equipnent problems
caused a small number of LERs which were promptly corrected.
The long continuous run after the extensive work on the :
Recirculation and Residual Heat Removal system supports a
conclusion that maintenance is of a high quality. The low
number of forced outages is also an indication that maintenance
is of a high quality.
The regional-based inspectors concluded that several of the
contractor employee concerns related to the replacement of the
Recirculation and Residual Heat Removal system piping were
substantiated. The substantiated concerns were: (1) that soft
copper tubing was used to deliver argon gas to the weld area,
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> however this is a common industry practice; (2) that stainless
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steel pipe was blackish from excess heat, however this occurred
only during welder training in the mockup area; and (3) that one l
weld was made with the wrong weld rod but it was corrected, '
however the inspector determined that it was the onl
No violations were identified and the NRC inspector'ysoccurrence.
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of all the concerns concluded that the quality of the installed ;
piping was not affected.
The visual inspection of snubbers and the evaluation of snubber i
testing were generally controlled through the use of well stated '
and defined procedures that were adhered to. The licensee's i
actions to resolve previous inspection findings were timely,
workable and technically sound. The approach used to evaluate '
and resolve IE Bulletins and a 10 CFR 21 report were conservative,
technically sound, and thorough. Deadlines were met and there
was timely resolution of issues.
Policies were well stated and understood, and decisionmaking
consistently was at an appropriate management level. When
problems arose, the licensee applied technically sound and
thorough analyses in solving them. They were responsive to
to NRC concerns and gomptly reported events that needed
reporting. In addition, the work reouest authorizations and
tagouts used by the licensee indicated that maintenance
activities were under strict control. For the areas examined,
the instector
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met regulatory requirements, and that personnel, equipment,
and material certifications were current and complete.
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Discussions with licensee and contractor personnel indicated
that they were knowledgeable in their job. Observations
indicate personnel had an adequate understanding of work
practices and adhered to procedures.
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The number of systems tagged out for maintenance during the
15 month assessment period was extremely low. During power
operation, from routine control room panel surveys, typically
no systems were tagged out for maintenance. On occasions where
equipment was tagged out, it was promptly restored. The number
of work requests has been at a manageable level throughout power
operation.
Permanent maintenance staffing is adequate with low attrition.
This has provided experienced personnel who are knowledgeable in
the performance of their duties. This experience and ability has
contributed to the success of the maintenance program.
2. Conclusion
The licensee is rated Category 1 in this area which is the same
as the last assessment. ;
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3. Board Recommendations !
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D. Surveillance and Inservice Testing
1. Analysis 1
During the assessment period, the resident inspector routinely
inspected this area. These inspections included observations
of technical specification required surveillance testing to
verify adequate procedures were used, that instruments were
calibrated, and that test results conformed with technical
specification and procedure requirements. In addition three
regional inspections were conducted in this area. These
inspections included startup core performance and Containment
Integrated Leak Rate Tests (CILRT). Four violations were
identified as follows:
a. Severity Level V - Failure to develop, implement, and
maintain a program for the control and calibration of
. timing devices; i.e., stopwatches (263/85012).
b. Severity Level IV - The CILRT procedure was inadequate and
failed to meet the requirements of technical
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specifications (263/84026).
c. Severity Level V - The licensee failed to correctly total
the isolation valve leakages as required by technical
specifications (263/84026).
d. Severity Level IV - The licensee failed to determine the
as-found containment leakage (263/85025).
Violations, Items b. through d. are evidence of a weakness
ident'. Tied in corporate management involvement in containment
leak rate testing activities. Specifically, a violation was
issued to the Monticello facility for failure to properly
incorporate local leak rate test results into the integrated
test result. This issue had been addressed appropriately at
.the utility's other nuclear plant, Prairie Island, since 1977.
This disparity in practices is indicative of a need on the part
of corporate management to become more involved in activities
common to both their facilities. l
The licensee has a well managed surveillance scheduling program.
Two LERs resulted from missed surveillances; one was due to a
missed sampling of fuel oil and the other was a missed fire l'
protection water header flush. No surveillances were missed
due to scheduling problems. The fixed surveillance schedule is i
evidence of management's dedication to performing surveillances
on a routine basis. Surveillance procedures are well written
and adhered to by the cognizant personnel. Management
involvement supports the surveillance program.
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There were several personnel errors associated with surveillance
during the assessment period. One resulted in a scram during
Main Steam Line Low pressure instrument testing. Three LERs
involved testing of radiation monitors. The licensee is
installing test switches in several of the radiation monitor
circuits which will allow testing without the need of jumper
installation. This modification will allow testing in a manner
much less prone to error. More attention to detail could result
in a lower number of occurrences. The Instrument and Control
(I&C) personnel are well trained, and the I&C staff has a low
attrition rate resulting in an experienced complement of
technicians. The staff complement is adequate and continues
to improve by hiring additional personnel of a high technical
education level. These personnel are placed in an effective
on-the-job training program.
2. Conclusion
The licensee is rated Category 2 in this functional area which
is the same as the previous assessment period.
3. Board Recommendations
None.
E. Fire Protection
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1. Analysis
During this assessment period, the resident inspector performed
routine inspections in this area, including evaluation of
potential fire hazards, plant housekeeping and cleanliness, and
compliance with the plant fire protection plan. The inspections
showed a significant improvement in housekeeping in the latter
part of the assessment period. The licensee has established a
three year painting and preservation plan for the reactor and
turbine buildings. This program will further improve the current
high standard of housekeeping and cleanliness.
Appendix R requirements haw bean completed with the exception of
the Alternate Shutdown Panel which is currently being installed
during the ongoing refueling outage. The plant will be awaiting
NRC inspection of its Appendix R modifications when this last
action is complete.
One LER as previously discussed in the Surveillance Section was
reported during the assessmant period regarding this area. It
involved missing a new technical specification surveillance
requirement to flush a turbine building fire suppression header.
This section of header always had an alternate source of water,
thus the significance of this event was minimal. No violations
or other LERs were identified during the inspection period.
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One minor fire occurred during the assessment period. This was
caused by welding sparks igniting a plastic bag lining a rubbish
barrel. The fire watch extinguished the fire, but failed to
inform the control room, After this event, the plant manager by
letter, required all contract laborers to receive additional
training on fire watch duties within one week. Procedures were
modified to more clearly define and establish fire protection and
fire watch training. This event identified an inadequacy in the
training of fire watches, and the corrective action was complete
and thorough. The strong corrective action taken is indicative
of the management's conservative attitude and approach toward
fire protection.
During the assessment period the licensee significantly
improved housekeeping. The Reactor and Turbine Buildings had
some areas which were cluttered by temporary storage. This
effort to clean out was hampered by contamination of some
material. The licensee allocated the necessary resources to
decontaminate and clear out these areas. Many areas which were
used as temporary storage for the life of the plant are now
uncluttered.
The licensee's actions in housekeeping were recognized by their
fire insurance carrier. This led to a significant reduction in
Monticello's insurance premium during the assessment period. .
Management has initiated action to hire a fire protection
engineer. This staffing will enhance the licensee's fire
protection program.
The inspector observed several fire drills during the assessment
period. The fire brigade response was timely and effective in
all cases. Fire brigade training is held annually at a fire
fighters training facility in the area and provides an excellent
training program for fire brigade members.
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The licensee resolved technical issues with appropriate !
justification and documentation and was enthusiastically '
cooperative with regard to concerns raised by the NRC.
Response time was appropriate and communications were
positive.
Visits to the plant by NRR representatives also concluded that
the plant had a clean, well ordered appearance. The workers
have been observed to behave in a disciplined manner in confor-
mance with good housekeeping practice.
2. Conclusion l
The licensee is rated Category 1 in this area. This is an
improvement over the last assessment period in which a Category 2
with an improving trend was received.
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3. Board Recommendations
None.
1. Analysis
Two inspections were performed during the assessment period, and
both of these were evaluations of annual emergency preparedness
(EP) exercises. One was conducted on December 5, 1984 and the
other on October 9, 1985. Two weaknesses were identified during
the 1984 exercise and one during the 1985 exercise.
The two 1984 weaknesses involved improper exercise controller
techniques in the Control Room and the Emergency Operations
Facility (E0F) and inadequate contamination control at the Access
Control Point and at the entrance to the E0F. Both of these items
were closed by successful demonstrations in the 1985 exercise as
evaluated by the inspectors.
The 1985 exercise weakness concerned improper removal of
protective clothing by an emergency worker when leaving a
radioactively contaminated area (simulated). This weakness
will be evaluated in the 1986 exercise.
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The 1984 exercise included a successful demonstration of a shift
change and shift augmentation. This shift change demonstrated
that required emergency response personnel, after being notified
to report to the plant, could function as an operational unit in
the Control Room, Technical Support Center (TSC), Operational-
Support Center (OSC) and E0F within the required activation
times. The capability to calculate and evaluate dose assessment
projections using the Meteorological Information aiid Dose
Assessment System (MIDAS) was adequately demonhtrated in the E0F
in the 1984 exercise. This was in contrast to an inadequate
demonstration in the 1983 exercise. This improvement in dose
assessment capabilities indicated improved training and a sound
approach to resolve this technical issue through better
understanding of the MIDAS user.'s manual in conjunction with
the emergency implementing procedures.
Correction of prior exercise weaknesses and general improvement
in other emergency preparedness areas indicated the training
program is well defined, responsive to EP issues, and implemented
with dedicated resources to adjust and reemphasize certain facets
of the EP training program when required. Decision making
has been consistently at a level that ensures adequate maningement
review.
v
15
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.
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Since annual emergency exercises rarely result in violations,
there has been no means to judge enforcement history with I
routine inspections not scheduled in the SALP 6 period. Three
significant events occurred concerning the Public Alert and
-
Notification System which provides 58 warning sirens within the
10 mile Emergency Planning Zone (EPZ) around the Monticello site.
All 24 sirens in Sherboune County failed on the monthly testing
dates in March, April, and June 1985. All sirens were repaired
and made operable in each instance in a timely manner. To detect
circuitry failures on a more frequent basis, the licensee has
installed a receiver in the Technical Support Center which
receives a signal indicating whether the circuitry is functional
or not. This test is done weekly except for the one week each
month when a full alarm test is made on all sirens. There have
been no further instances of all 24 sirens failing at one time
since June 1985.
Overall, the licensee is continuing to improve the emergency
preparedness program through attention to quality and
responsiveness not only to NRC recommendations but also to their
own drill and exercise critique findings. The licensee has
maintained a positive and cooperative attitude towards improving
all phases of the EP program.
2. Conclusions
The licensee is rated Category 1 in this area. This is the same
rating as the previous SALP assessment.
. .
3. Board Recommendations
None. .
.4
G. Security
1. Analysis
One routine physical security inspection was performed early in
the assessment period by a regional based inspector. The
resident inspector also made periodic inspections of security
activities and assessed routine program implementation. No
violations were identified by region or resident inspector
relative to the security program. 1
Senior management continues to have an awareness of security ;
issues and is effective and responsive to resolving security l
issues as demonstrated by the lack of violations reported or
identified during the previous and present SALP periods.
Excellent management support exists at both the site and
.
corporate management levels as demonstrated by the close
coordination between the corporate and site offices. Senior
-
16
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security personnel have a high degree of expertise and have
been effective in identifying problem areas and recommending
solutions. Concerns and observations receive the same
exceptionally high. level of management attention normally
associated with violations, and management is responsive to all
findings that can strengthen their security program.
There were no technical security issues with respect to plant l
safety that required resolution during the assessment period, nor .
were there any regulatory issues identified which required a l
licensee response. I
Security events were properly and adequately reported under
10 CFR 73.71(c). There were 14 such events during the assessment
period. These events pertained to computer related problems and
bomb threats. The computer problems were adequately resolved and
the individual who made the bomb threats was identified,
arrested, and determined by police and hospital professionals not
to be a threat to the plant. Corporate and site security manage-
ment have been aggressive in resolving the computer problem and
the communicated threats to the plant.
, The licensee's staffing levels are adequate to fulfill security
plan commitments and the training and qualification program is
well defined and implemented with dedicated resources which make
a positive contribution to overall implementation of the security
program.
In summary, the licensee's security staff has been effective in
the operation and implementation of the security program. The
security staffing is adequate and departmental support for the
security program has been effective. Supervision of the security
force remains aggressive which results in a stable, well trained
security force.
2. Conclusion
The licensee is rated Category 1 in this area which is the same
rating given in the previous assessment period.
3. Board Recommendations
None.
H. Outages
1. Analysis
The resident inspector performed routine inspections during
>
outages. These inspections included observation of maintenance
activities, review of planning activities, refueling activities,
startup from a 11.5 month outage, review of various modifications
17
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.
.
installation and post outage testing. tilso activities were
observed during four short outages for various maintenance
concerns. In these inspections no violations were identified.
Refueling activities were conducted in an excellent manner.
The core was off loaded and reloaded without difficulty.
Communication between the control room and refueling floor was
excellent. The licensee's use of experienced licensed operators
and senior operations personnel in refueling greatly contributes
to the plants traditionally successful operation in this area.
The use of three experienced full time schedulers has resulted in
good programmatic knowledgeable planning which accurately predicts
work requirements. This precision scheduling allows a well
orchestrated array of coordinated work activities. The effec-
tiveness of the schedulers is demonstrated by the cooperation
they receive from managers of all disciplines during daily outage
meetings. This results in cooperation and resolution to various
concerns. Delays due to lack of coordination are rarely
encountered. Corporate management is kept informed by frequent
plant visits and discussions with plant management.
The long continuous run after the extensive work on the
Recirculation and Residual Heat Removal system supports a
conclusion that post outage testing is of a high quality.
The licensee demonstrates a clear understanding of technical
issues, and conservatism is normally exhibited. This is
demonstrated by the licensee's response to concerns identified
by the NRC regarding the stub shaft assembly of the emergency
diesel generators. Although on short notice, the licensee chose
to replace the stub shafts of both emergency diesel generators
during the ongoing refueling outage.
'
Staffing is adequate with contractor support required during
outages and to support modification work. Key positions are
identified and responsibilities are defined. The licensee
utilizes an acceptable level of contractor work force and
integrates the contractor and utility work force in a controlled
manner.
2. Conclusion
The licensee is rated Category 1 in this area.
3. Board Recommendations
None.
)
1
18
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I. Quafity Pro' gram and Administrative Controls Affecting Quality
-
1. Analysis
During the assessment period, the resident inspector routinely
inspected this area, which included administrative controls for
maintenance, operations, surveillances, and training. In
addition the Quality Assurance Plan was examined regarding'
the QA audit program at Northern States Power Company's
Corporate office by a regional specialist. Also a
regional inspection of procurement activities was performed.
The resident inspector periodically reviewed QA audits and any
associated findings. One violation was identified in this i
functional area as follows: !
Severity Level IV - Failure to carryout procurement
activities in accordance with the QA manual.(263/85004).
>
The violation with nine examples was indicative of corporate
management's failure to adequately control site procurement
activities as evidenced by poorly understood policies and
procedures, incomp,lete records, and inadequate procedures.
While the procurement program was neither properly documented
nor implemented in accordance with the existing written program,
no examples were identified where the practices led to installa-
tion and use of substandard material. This item remains open
pending verification of the licensee's corrective actions during
a future inspection.
In regard to the corporate office visit, the inspector determined
that audits were being conducted on schedule, records were
complete, and management at both the site and corporate level
were frequently involved in this activity. Audit reports and
corrective action for audit findings were completed on a timely
basis. Personnel who participated as auditors were qualified.
During the 1986 refueling outage three events occurred which
resulted in NRC attention: inoperability of IRM trip functions
on one channel; squib valve detonator shortening; and LPCI loop
selection design problems. The three events resulted from design
deficiencies. The licensee did not have previous knowledge of
the IRM and LPCI loop select problems. The SBLC problems,
resulting from squib valve detonator shortening, was prenoticed
by the NRC and GE. The licensee did not adequately respond to
these notices. ;
1
Administrative control procedures provide for effective l
management control, verification and oversight activities. The l
licensee has a well developed, effective plant staff. During the '
assessment period nine LERs were attributed to procedural ^ errors.
The most significant of these allowed flow through the Residual
l
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Heat Removal (RHR) intertie line while at 100% power. During th.e
1986 refueling outage a high number of LERs occurred. Although
the outage extends into the next assessment period, it is ,
appropriate to identify'a concern regarding the number of LERs
attributed to procedural inadequacies which occurred during
'
the outage. The licensee has identified this area of concern
-
and has implemented preliminary corrective action in this area
to improve second level review. The licensee is developing this
second level review to be an independent walk-through of the
procedure. This corrective action should be adequate to correct
this concern.
The Operations Committee and Safety Review Committee review of
plant activities is detailed and effective. Control of the
design change process is generally good. Recent~ changes to the
process to improve control and documentation of the construction
work and drawings and procedure changes appear to be effective.
Corrective action systems are excellent in identifying and
documenting events / problems. The root cause and corrective
actions are well developed. Requirements for records are
adequate. No problems with incomplete or inaccurate records
were observed during the assessment period.
Decision making is usually at a level that ensures adequate
management review and corporate management has strong involvement
in site activities. -
2. Conclusion
The licensee is rated Category 2 in this area.
3. Board Recommendations
'
i
None.
'
J. Licensing Activities
_
1. Analysis
~
~
a. Methodology
The basis of this appraisal was the licensee's performance
in support of licensing actions that were either completed
or active during the current rating period. These actions,
consisting of license amendment requests, exemption requests,
relief requests, responses or generic letters, TMI items,
LER's and other actions, are summarized below-
1
(1) Amendment Requests
ISI/IST Program
ARI System
Jet Pump Operability
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Vacuum Breaker Cycling
- Containment Purge and Vent Valves
Organizational Changes
Use of Screen Wash Pump as Fire Pump
Addition to the Property Line
Clarification of Radiation Monitoring TS Requirements
Reporting Requirements
Fuel Enrichment Limits in TS
Several Administrative Changes to TS
Snubber Table
Temporary Procedure Changes
Radiation Protection Program Plan
Environmental Samples
CGCS LCO's and Surveillance Requirements
Safety / Relief Valve Simmer Margin TS Changes
Cycle 12 TS Changes
'
Single Loop Operation
.
Fire Protection Changes
Fire Protection Suppression System in the Control Room
Exemption from 10 CFR Part 73, Appendix B
Requirement for Shotgun Hip Firing Qualification
for Guard Force
(3) Relief Requests
In-Service Testing
In-Service Inspection
(4) TMI Items
I.A.3.1 Limit Overtime j
I.C.1 Emergency Operating Procedures .
I.D.1 Detailed Control Room Design Review
I.D.2 Safety Parameter Display System ;
II.F.1.1 Noble Gas Effluent Monitor '
II.F.1.2 Sampling and Analysis of Plant Effluents
II.F.1.3 Containment High Range Radiation Monitor
II.F.1.4 Containment Pressure Monitor
II.F.1.5 Containment Water Level Monitor
II.F.1.6 Containment Hydrogen Monitor
II.F.2.3 Inadequate Core Cooling Instrumentation
II.K.3.3 Reporting SV and RV Failures and
Challenges
'
II.K.3.13 RCIC Restart
II.K.3.15 Isolation of HPCI
II.K.3.18 ADS Actuation Study
21
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II.K.3.22 RCIC Suction Modifications
II.K.3.28 Qualification of Accumulators
II.A.1.2 Errergency Response Facilities
II.A.2.2. Meteorological Data Upgrade
(5) Other Licensing Actions
BWR Pipe Cracking
Salem ATWS Follow-up
Electrical Equipment Qualification
Fire Protection Modifications
Diesel Generator Reliability
During the SALP period, 51 licensing actions were completed
which consisted of 28 plant-specific actions, 13 multi plant
actions, and 10 TMI (NUREG-0737) actions.
b. Management nvolvement and Control in Assuring Quality
During the present rating period, the licensee's management
demonstrated active participation in licensing activities
and kept abreast of all current and anticipated licensing
actions. Licensee management actively participated in an
effort to work closely with the NRC staff to establish
realistic schedules for all modifications of the Monticello
facility. In addition, management's involvement in
licensing activities assured timely response to the
requirements of the commission's rules related to Fire
Protection and Environmental Qualification of Electrical
Equipment.
As presented above, there have been a significant number of
licensing actions processed, and for the most part, the
majority were completed requiring little or no additional
information or meetings. The refueling outage for Cycle 11
operation was for a long duration and overlapped the SALP 6
rating period. The major work completed during this outage
was the replacement of all recirculation system piping
susceptitile to intergranular stress corrosion cracking
(IGSCC) and completion of major Mark I containment
modifications. All modifications related to TMI action
items have been completed except for the installation of
an alternate shutdown panel, which is in the process of
being installed in the current outage. It will be operable
prior to restart. The licensee's management took an
aggressive part in assuring the satisfactory completion of
the above stated tasks and exercised good control over its
internal activities and its contractors to assure quality,
and maintained effective communication with the NRC staff.
22
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.
,
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c. Approach to Resolution of Technical Issues from a
,
Safety Standpoint
The licensee's management and its staff have demonstrated
technical understanding of issues involving licensee
,
actions. Its approach to resolution of technical issues has
demonstrated adequate technical expertise in all technical
areas involving licensing actions. The decision related to
licensing issues have exhibited conservatism in relation to
significant safety matters, such as early replacement of all
piping susceptible to IGSCC, and completion of environmental
qualification of almost all electrical equipment important
to safety.
On occasions when the licensee deviated from the staff
guidance, the licensee has consistently provided good
technical justification for such deviations. The Fire
Protection Program and the deviation from shift staffing
rule are good examples illustrating the soundness of
technical justifications for deviations from staff
guidance. .
d. Responsiveness to NRC Initiatives
'
The licensee has been responsive to NRC initiatives. During
the rating period, it made reasonable efforts to meet or
exceed commitments. Responsiveness by the licensee facili-
tated timely completion of staff review of a large number of
licensing actions and thus substantially reducing the
licensing backlog. The licensee's quality of license
amendment requests, especially the "no significant hazards
consideration" improved significantly after the counterpart
meeting held on January 30, 1986 in Bethesda, where this
topic was discussed in detail. The licensee has responded
promptly and accurately to various surveys conducted during '
the reporting period. I
1
e. Staffing
The licensee has maintained adequate licensing staff to
assure timely response to the NRC needs.
)
During this period, the licensee's performance with regard to
licensing activities was found to be above average to excellent
overall. Management attention and involvement was generally
aggressive and disciplined. This was evident by the record run.
Staffing levels and quality were adequate. The licensee has
been, in most cases, effective in dealing with significant
problems and NRC initiatives. The licensee's efforts in the
functional area of Licensing Activities has significantly
improved during this evaluation period. This is reflected in
23
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the quality of wqrk, attention to NRR concerns, and involvement
of senior management. Monticello was an active carticipant at
the counterpart meeting of January 30, 1986, in Bethesda,
Maryland. This meeting was to discuss common concerns between
Mark I reactors in BWR Project Directorate 1.
2. Conclusion
The overall rating for this functional area is Category 1.
3. Board Recommandations
None.
K. Training and Qualification Effectiveness
1. Analysis
Resident and regional inspectors have evaluated training and
qualification effectiveness during inspection of specific
program areas. No violations were identified in this area.
During inspection of operations activities, non-licensed
operators, control room operators, senior control room operators
(shift supervisors and site superintendents), and shift technical
advisors were knowledgeable and effective in carrying out their
duties.
During the assessment period, NRC examinations were administered
to three Reactor Operator candidates and 14 Senior Reactor
Operator candidates. Two Reactor Operator candidates and
11 Senior Reactor Operator candidates. passed the examinat. ions.
This passing rate is equal to the overall national average
passing rate. Based on these results, the operator licensing
, training program at Monticello is considered satisfactory.
During inspection of maintenance and outage activities,
instrument and control technicians, electrical maintenance
personnel, and mechanical maintenance personnel were highly
knowledgeable of their responsibilities. The knowledge of the
. technical staff and managers remains at a high level. The
licensee sends as many of the technical staff to Senior Reactor
Operator training as possible. This takes knowledgeable
individuals away from the organization for long periods of
time, but in the long run this practice will retain the high
knowledge and experience level of the staff.
During inspection of the radiological protection area, a
regional inspector evaluated training and qualification
effectiveness. Licensee training and qualification programs
generally improved during this assessment period. A step
24
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4
training program for new chemist and health physics radiation
protection specialists was implemented. The training program
consists of practical and academic tasks and represents the
management's commitment to provide well trained chemist and HP
radiation protection specialists for future needs.
Management's commitment to provide qualified competent
personnel to operate the facility is evidenced by the low
number of personnel errors during the assessment period. The
training staff provides an effective training program to all
disciplines which is implemented by experienced personnel. The
Monticello training staff has a good working relationship with
the plant staff. This has enhanced the training effort and is
a part of the effectiveness of the training program.
The licensee is making good progress towards INP0 accreditation
of training programs. Accreditation of the Senior Reactor
Operator, Reactor Operator, Requalification, Non-licensed
Operator, and Maintenance (Electrical and Mechanical) programs ,
was achieved on February 19, 1986; and the licensee is projecting
the remaining training programs will be ready for accreditation
-
by September 1986.
2. Conclusion
.
The licensee is rated Category 2 in this functional area.
3. Board Recommendations
.
None. *
.
25
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V. SUPPORTING DATA AND SUMMARIES
A. Licensee Activities .
The unit engaged in routine power operation throughout most of SALP 6.
A scheduled outage for plant Recirculation and Residual Heat Removal
system piping replacement and subsequent refueling was in progress
at the beginning of the assessment period and was completed on
January 20, 1985. The next refueling outage began on April 30, 1986
and was in progress at the ending of the assessment period.
The remaining outages throughout the period are summarized below:
January 26-27, 1985 Miscellaneous maintenance
May 3-8, 1985 Turbine and control rod drive
maintenance
May 15, 1985 Generator taken off-line to
investigate generator field
ground
July 30, 1985 . Repaired reactor building closed
cooling water leak
October 12-13, 1985 Replaced safety relief valve
top works and miscellaneous
maintenance
The plant scrammed three times during this assessment period. This
reactor trip frequency is much less than the national average. The
first one was caused by a failure to remove grounding cables after
completion of maintenance on an offsith substation transformer by a
non plant worker. The second scram was caused by a personnel error
during performance of a main steam line low pressure instrument
surveillance. The third scram was caused by inadequate procedures
for recirculation motor generator brush replacement.
B. Inspection Activities
No team inspections or planned emergency preparedness exercises were
conducted during this period.
Violation data for the Monticello plant is presented in Table 1,
which included Inspection Reports No. 84026, 84027, 84029-86003.
26
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TABLE 1 - ,
.
.
ENF6RCEMENT ACTIVITY
.
FUNCTIONAL NO. GF VIOLATIONS IN EACH SEVERITY LEVEL
AREA
l III IV V
A. Plant Operations
B. Radiological Controls
C. Maintenance
D. Surveillance and Inservice Testing .2 2
E. Fire Protection -
.
,
G. Security
!
H. Outages
.
I. Quality Programs and
Administrative Controls
Affectin~g, Quality 1
J. Li'censee ctivities
K. Training and Qualification ~
Effectiveness
TOTALS 3 2
M
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Investigations-and Allegations Review
'
C.
1. A contractor employee had concerns related to the replacement
. of the Recirculation and Residual Heat Removal. system piping.
Inspection concluded that the quality of the installed piping
was not affected.
2. A former material supplier employee stated that foreign made
pipe was supplied to'Monticello without heat numbers and it
did not conform to specifications. The resolution of the
allegation has extended beyond the close of this evaluation
period and will be addressed in a future inspection report.
3. An anonymous allegation stated that NSP calibrates all of its
phase angle meters and digital meters by unqualified personnel
and that QC infrequently oversees the work. The licensee is
i currently addressing the issue and the NRC will review their
investigation during a future inspection.
'
. D. Escalat_ed_ Enforcement Actions
'
There were no escalated enforcement uctions during this assessment
period.
.
E. Licensee Conferences Held During Appraisal Period
i
l 1. Januafy 11, 1985 (Glen Ellyn. Illinois)
Meeting to review and discuss the licensee's resolution to the
CRD screen plugging event. , ;
2. February 25, 1985 (Glen Ellyn, Illinoit) ,
-
,
Meeting to review Systematic Assessnent of Licensee Performance
>
(5 ALP 5).
3. April 18, 1986 (Site _and Corperate Offices)
.
Meeting to discuss the NRC Region III planned inspection
reduction program.
F. Confirmation of Acti.on Letters (CALsj
There were no CALs issued during the SALP assessa.ent.
G. Review of Licensee Event Reports, Construction Deficiency Reports,
and 10 CFR 21 Reports Submitted by the Licensee
'
1. Licensee Event Reports (LERs)
LERs issued during the 18 month SALP 6 period are presented
below:
28
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LERs No.
84-34 and 84-35
85-01 through 85-21
86-01 through 86-14
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Proximate Cause Code * Number During SALP 6
Personnel Error (A) 7
Design Deficiency (B) 0
External Cause (C) 1 ,
Defective Procedure (D) 9 1
Management / Quality Assurance
Deficiency (E) 0
Others (X) 0
No Cause Code Marked ** 20
Total 37
- Proximate cause is the cause assigned by the licensee
according to NUREG-1022, " Licensee Event Report System."
- NUREG-1022 only requires a cause code for component failures.
. In the SALP 5 period, the licensee issued 44 LERs in 17 months
for an issue rate of 2.6 per month. In the SALP 6 period the
licensee issued 37 LERs in 18 months for an issue rate of 2.1
per month. This reduction in issue rate is indicative of an
'
improving trend.
Twelve of the LER$ were submitted for various EFT actuations
due from problems with the Chlorine Monitors. The licensee has
visited the manufacturer's facility in an attempt to resolve the
tape quality problem. The licensee is also submitting a license
amendment request to remove these monitors. Ten of the reports
were due to SBGT initiation for various reasons. Three were
related to scrams. Three were due to component failures; two *
, relay failures and the HPCI flow controller. Two were caused by
missed surveillances. The remaining seven were due to various
causes; RPS actuation due to a spurious IRM spike during testing,
failure to test five TIP penetrations, flow through the RHR
intertie run, ESF bus transferred to auxiliary, both diesel
generators starting, UPS transfer to alternate power source,
,
and trip of shutdown cooling during the CILRT.
i
None of the reportable events were considered individually
significant enough to warrant detailed NRR staff followup.
None of the events included in this SALP evaluation were
discussed at the Operating Reactors Events Briefings.
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The Office for Analysis and Evaluation of Operational Data
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(AE00) reviewed the LERs for this period and concluded that,
in general.thd-LERs.are of above. average quality based on
.
the requirements contained in 10 CFR 50.73. However, they
identified some minor deficiencies. A copy of the AE00 report
has been provided to the licensee so that the specific
deficiencies noted can be corrected in future reports.
2. Construction Deficiency Reports
- ,.
No construction deficiency reports were submitted during the
assessment period.
3. 10 CFR 21 Reports
the assessment
'
No 10 CFR
period. 21 reports
However, 10 ,CFRwere submitted
21 Report SSH-M-84during /01, submitted
during the last SALP period, was closed* during an inspection
,,
during this SALP.
H. Licensing Activities *
.
,,, 1. NRR/ Licensee Meeti"ngs (at'NRC)
Discussion of.Licensirig Issues 02/05/85
, Prioritization of' Licensing Issues 04/15/85
Counterparts Meeting 01/30/86
..
2. NRR Site Visits
.
Plant Orientation 06/10-21/85
'
CRGR Visit and Licensing
i Action Prioritization ,. 08/12-14/85
Annual Emergency Preparedness
Exercise -
10/08-10/85
3. Commission Meetings
None.
- 4. Scheduler Extensions Granted
Equipment Qualification 03/28/85 l
0737-Supplement I Requirements 09/24/85 !
5. Reliefs Granted
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None. !
6. Exemptions Granted
None. I
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7. License Amendments' Issued
AMENDMENT TITLE DATE
i ,
32 Surveillance Testing Requirements 05/28/85
33 Fire Suppression Water System 10/07/85
34 Spent Fuel Storage Facility- 10/08/85
35 Combustible Gas Control System 12/03/85
36 Vacuum Breaker Cycling 12/23/85
. 37 TMI Action Items 01/22/86
38 Environmental Technical '
Specifications 02/12/86
39 Various Administrative Changes 03/13/86'
40 Clarification of Radiation
Monitorir.g Requirements 03/18/86
'
41 Additional Battery System and
Change to Site Description 03/24/86
42 Jet Pump Operability 03/27/86
43 Safety / Relief Valve Simmer
Margin Improvements 04/08/86
44 TS Changes for Cycle 12 Operation 05/27/86
.
9
$
b
8
3
4
c
h
%
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31 ,