ML20206K197
| 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: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8811290310 | |
| Download: ML20206K197 (8) | |
See also: IR 05000263/1988200
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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
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414 Nicollet Mall
Minnebpolis, Minnesota 55401
Dear Mr. Larson:
SUBJECT:
EMERGENCYOPERATINGPROCEDURE(E0P) INSPECTION (50-263/88-200)
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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
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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November 14, 1988
Mr. C. Larson
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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
520 Lafayette Road
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St. Paul, Minnesota 55155-3898
Regional Administrator, Region III
U. S. Nuclear Regulatory Commission
799 Roosevelt Road
Glen Ellyn, Illinois 60137
Commiss4 rar of Health
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Minnesota Department of Health
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717 Delaware Street, S. E.
Minneapolis, Minnesota 55440
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O. J. Arli6n, Auditor
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Wright County Board of
Commissioners
10 NW Second Street
Buffalo, Minnesota 55313
Institute of Nuclear Power Operations
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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
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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,
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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,
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Reviewed the E0P training program through lesson plan reviews,
operator and instructor interviews, and simulator observations.
o
Reviewed the licensee's actions to address containment integrity and
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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
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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
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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
Integrity and venting issues was consistent with the owners group guidelines.
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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
resolution was appropriate.
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