ML20206K197

Forwards Emergency Operating Procedure Insp Rept 50-263/88-200 on 880711-22.Deficiencies Noted.Executive Summary of Insp W/Overview of Insp Team Findings in Areas Reviewed Encl

ML20206K197
Person / Time
Site:	Monticello
Issue date:	11/14/1988
From:	Holahan G Office of Nuclear Reactor Regulation
To:	Larson C NORTHERN STATES POWER CO.
Shared Package
ML20206K199	List: IR 05000263/1988200 ML20206K197
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8811290310
Download: ML20206K197 (8)

See also: IR 05000263/1988200

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NUCLEAR REGULATORY COMMISSION

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/ November 14, 1988

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Docket No. 50-263

Mr. C. Larson, Vice President, Nuclear Generation -

Northern States Power Company

414 Nicollet Mall

Minnebpolis, Minnesota 55401

Dear Mr. Larson:

- SUBJECT: EMERGENCYOPERATINGPROCEDURE(E0P) INSPECTION (50-263/88-200)

This letter forwards the report and the executive sumary for the emergency

operating procedure (EOP) inspection performed by an NRC inspection team at

Monticello Nuclear Generating Plant July 11-22, 1988. This inspection was

conducted by members of the NRC Office of Nuclear Reactor Regulation and

contractors. At the conclusion of the inspection the team discussed the

inspection findings with you and the members of your staff identified in

Appendix A of the enclosed inspection r@ ort.

The purpose of the inspection was to verify that your emergency operating

procedures were technically correct for the Monticello facility and conformied

to owners group gutt-lines; that their specified actions could physically be

accomplished using existing equipment and instrumentation; end that the

operating staff had received sufficient trainir.J to accomplish the required

actions.

The inspection effort involved a review of your program for E0P development

and implementation, your validation and verification of E0Ps in use at the

facility, and an evaluation of your E0P related training activities. The

inspection team accomplished these tasks through use of your site specific

simulator, walkthroughs of your procedures with operators in the plant,

interviews with key plant staff, and a review of E0Ps and supporting

,

documentation.

Two documents are enclosed with this letter. The Executive Sumary of this

inspection provides an overview of the team's findings in each area reviewed,

while a more detailed explanation of the findings is provided in the enclosed

inspection report and appendices. No response is required to this letter.

Resolution of any potential enforcement actions, concerns, and recomendations

contained in the report will be the subject of future correspondence by the

NRC Region Ill office.

The inspection team concluded that, although there were deficiencie' in the

E0P development and implementation r,rocesses that require prompt c oagement

attention, the existing E0Ps were technically correct and could be accomplished

in the plant by licensee operating shift personnel. The deficiencies noted

during the inspection included (1) the absence of a formal program for E0P

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maintenance, including Quality Assurance involvement, (2) inadequate

verification and validation of the C.5 - 3000 E0P Support Procedures, (3)

specific human factors deficiencies related to control room lighting and

layout, (4) discrepancies in plant labeling and nomenclature used to identify l

plant components within the body of procedures, (5) inadequate verfilcation of

plant parameter data used in setpoint calculations, and (6) an apparent

training deficiency related to operator use of support procedures outside the

control room. The team concluded that the observed performance of a newly

qualified individual shif t supervisor in implementing E0Ps during simulator

scenarios was sufficiently weak to constitute a safety con crn. However, the

team's concern was downgraded from a safety issue to identification of a

programatic weakness in the E0P training for newly qualified shift

supervisors after conducting additional simulator observations of other

operating crews. With the involvement and concurrence of NRC Regional and

Headquarters management Northern States Power Company immediately undertook the

,

actions necessary to address the problem.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures

will be placed in the NRC Public Document Room.

Should you have any questions concerning this inspection we would be pleased

to discuss them with you.

Sincerely,

Y v

Gary M. Holahan. 4cting Director

Divisinn of Reactor Projects III IV, V,

and Special Projects

Office of Nuclear Reactor Regulation

Enclosures:

1. Executive Sumary

2. NRC Inspection Report 50-263/88-200

cc w/ enclosures: See next page

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Mr. C. Larson - 3 November 14, 1988

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cc w/ enclosures:

Gerald Charnoff, Esquire

Shaw, Pittman, Potts and

Trowbridge

2300 N Street, NW

Washington, D. C. 20037

U. S. Nuclear Regulatory Commission

Resident inspector's Office

Box 1200

Monticello, Minnesota 55362 ,

Plant Manager

Monticello Nuclear Generating Plant

Northern States Power Company

Monticello, Minnesota 55362 ,

Russell J. Hatling

Minnesota Environmental Control

Citizens Association (MECCA)

Energy Task Force

144 Melbourne Avenue, S. E.

Minneapolis, Minnesota 55113

Dr. John W. Ferman

Minnesota Pollution Control Agency

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520 Lafayette Road

St. Paul, Minnesota 55155-3898

Regional Administrator, Region III

U. S. Nuclear Regulatory Commission

799 Roosevelt Road

Glen Ellyn, Illinois 60137

Commiss4 2 rar of Health  !

Minnesota Department of Health  !

717 Delaware Street, S. E.

Minneapolis, Minnesota 55440

t

. O. J. Arli6n, Auditor

Wright County Board of

Commissioners

10 NW Second Street

Buffalo, Minnesota 55313  ;

Institute of Nuclear Power Operations i

1100 Circle 75 Parkway

Atlanta, Georgia 30339

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EXECUTIVE SUmARY

INSPECTION REPORT 50-263/88-200

MONTICELLO NUCLEAR GENERATING PLANT

During the period July 11-22, 1988, a team of NRC inspectors and contractor

personnel inspected the Monticello Nuclear Generating Station to evaluate its

program for development and implementation of emergency operating procedures

(EOPs). The inspection was conducted to (1) verify that the procedures were

technically accurate for the facility and that they were consistent with

owners group guidelines, (2) verify that the procedures could physically be

carried out in the plant using existing tools, equipment, and instrumentation

and controls assuming minimum authorized shift crew composition, and (3)

verify that operating rews had been adequately trained to perform the -

procedures. *

To evaluate the E0Ps, the inspection team:

o Reviewed the E0P development process as described it. the procedure

generation pack.ge (PGP) submitted to the NRC.

o Compared the E0Ps and deviation documentation to the Boiling Water

Reactors Owners Group (BWROG) Generic Emergency Procedure Guidelines

(EPGs).

o Validated the ability of the plant operating staff to implement the

E0Ps and E0P support procedures, through use of the site-specific

simulator and through plant walkdowns of E0Ps and opport procedures,

o Performed a human factors evaluation of all aspects of E0P

development and implementation.

o Performed a review of setpoint and calculation documentation that

supported the E0Ps,

o Reviewed the E0P training program through lesson plan reviews,

operator and instructor interviews, and simulator observations.

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o Reviewed the licensee's actions to address containment integrity and

venting in light of the known design characteristics of the Mark I

containment.

Sumary of Significant Findings

The inspection team found that the licensee had no formal program for

aoministrative maintenance of E0Ps and their supporting documentation,

although an administrative control procedure had been in draft for some time.

Although no items of immediate safety significance resulting from inadequate

controls were identified, a formal administrative control program that

included Qua'ity Assurance review and audit functions likely would have

prevented many of the programmatic deficiencies identified during the

inspection,

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Although plant walkthroughs performed during the inspection confirmed that

E0Ps could be carried out from the control room using existing equipment and  ;

instrumentation, the team identified deficiencies in the validation and '

verification of E0Ps and support procedures nomally performed in the plant

and considered essential to the successful implementation of E0Ps. Procedures

performed in the plant were found to have labeling in:onsistencies,

incorrectly specified equipnent, and confusing procedural steps. Operators r

were of ten unfamiliar with the procedural requirements and unclear about what  :

actions would be expected of them or how those actions would be accomplished.

The licensee had not given adequate consideration to accessibility of the areas :

in which actions must be performed or the adequacy of equipment and supplics

needed to perform the actions.

Plant walkdowns identified one item of safety significance that warranted

prompt management attention. The team determined that failure of ventilation

dampers in the diesel generator room, combined with operator unfamiliarity

with appropriate' action to manually operate the dampers, could result in loss

of the generator due to high room temperature. The licensee imediately

implemented a temporary solution and comitted to resolve the issue before the

onset of cold weather.

Based on simulator observations, interviews, and plant walkdowns with three

different operating crews, the team identified a significant disparity between

the crews with regard to their familiarity Mth the procedures and their skill

in responding to complex, multiple failure scenarios. Performance of one crew

was of particular concern to the inspectors, who concluded that the group was

not sufficiently prepared to use the procedures in the course of their

licensed duties during an actual emergency. However, the exemplary perfomance

of the other two operating crews prompted deeper investigation into the

underlying cause of the broad disparity. The team concluded that inadequate

training had been prOvided to one Shift Supervisor, who had only recently been

promoted to that po3ition. The inspectors concluded that licensee management

bore responsibility Mr assigning managerial responsibility for E0P

performance to a newly promoted and inexperienced Shift Supervisor without

sufficient exposure to flow chart usage in a dynamic training environment.

With the involvement and concurrence of NRC regional and headquarters

management th7 licensee imediately undertook actions necessary to address the

problem.

The inspection team concluded that the licensee's approach to containment

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Integrity and venting issues was consistent with the owners group guidelines.

The licensee was encouraged to identify additional vent paths as backups for

the single path now specified for operators, and to integrate into their

simulator training complex scenarios that would expose operators to venting

decisions. The present approach of venting to the Standby Gas Treatment System

is expected to damage that system's ductwork and increase the likelihood of

secondary containment inaccessibility and ground release. The licensee had not

addressed the question of containment isolation valve operability under the

anticipated flow and differential pressure conditions.

Human factors reviews determined that in the event of loss of control room

lighting there was insufficient illumination in the area where E0P flowcharts

woulo be used.

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Conclusions

The E0Ps were found to be technically adequate for the Monticello facility and

capable of being perfonned using the minimum shift crew complement defined by

Technical Specifications. Given the inadequate validation and verification for

performance of procedurally required actions outside the control room,

identified deficiencies would likely contribute to delays in operator actions

that could degrade the program's effectiveness. With the resolution of the

training deficiency described above the team concluded that licensee staff had

been adequately trained in the use of E0Ps. However, training for operators

performing actions outside the control room was found to be deficient and

deserves prompt management attention.

The licensee staff demonstrated that adequate administrative controls and

qualified personnel were available to address the deficiencies identified by

the inspectors, and that managerial involvement and support for deficiency

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resolution was appropriate.

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