IR 05000263/2010007

IR 05000263-10-007, on 09/13/2010 - 10/01/2010; Monticello Nuclear Generating Station; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML103140760
Person / Time
Site:	Monticello
Issue date:	11/10/2010
From:	Kenneth Riemer NRC/RGN-III/DRP/B2
To:	O'Connor T Northern States Power Co
References
IR-10-007
Download: ML103140760 (29)

Text

ber 10, 2010

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000263/2010007

Dear Mr. OConnor:

On October 1, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at your Monticello Nuclear Generating Plant.

The enclosed report documents the inspection results, which were discussed on October 1, 2010, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The inspection concluded that your staff was effective at identifying problems and incorporating them into the corrective action program (CAP). In general, issues were appropriately prioritized, evaluated, and corrected; audits and self-assessments were thorough and probing, and operating experience was appropriately screened and disseminated. Your staff was aware of the importance of having a strong safety-conscious work environment and expressed a willingness to raise safety issues. The inspectors also observed that actions taken to address a declining trend in Human Performance appeared to be effective.

However, your staff was not fully effective in addressing an adverse trend in contractor oversight and in work control and planning, which had begun earlier this year. Although both issues were captured in the CAP program, the underlying causes were not fully understood. This resulted in corrective actions being more reactive, instead of proactive, when responding to related issues.

The inspectors were concerned that this adverse trend, if not resolved, would negatively impact the significant number of work activities planned for next year. No violations or findings were identified during this inspection.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Docket No. 50-263 License No. DPR-22

Enclosure:

Inspection Report 05000263/2010007 w/Attachment: Supplemental Information

REGION III==

Docket No. 50-263 License No. DPR-22 Report No: 05000263/2010007 Licensee: Northern States Power Company, Minnesota Facility: Monticello Nuclear Generating Station Location: Monticello, MN Dates: September 13 - October 1, 2010 Inspectors: N. Shah, Project Engineer - Team Lead D. Sand, Acting Resident Inspector - Monticello C. Scott, Reactor Engineer G. ODwyer, Reactor Engineer M. Phalen, Plant Support Specialist Approved by: Kenneth Riemer, Chief Branch 2 Division of Reactor Projects

SUMMARY OF FINDINGS

IR 05000263/2010007; 09/13/2010 - 10/01/2010; Monticello Nuclear Generating Station;

Biennial Baseline Inspection of the Identification and Resolution of Problems.

This team inspection was performed by four regional inspectors and the resident inspector.

No violations or findings were identified.

Identification and Resolution of Problems Overall, the Corrective Action Program (CAP) was good. Issues were effectively identified, evaluated and corrected. Nuclear Oversight (NOS) audits and department self-assessments were generally critical and identified issues that were captured in the (CAP). Operating Experience (OE) was well communicated and appropriately evaluated. A strong safety culture was evident, based on interviews with licensee staff and a review of the types of issues captured in the CAP and Employee Concerns Program (ECP).

The inspectors observed that the evaluation of OE in Apparent Cause Evaluations (ACEs) had improved since the 2008 PI&R inspection. Specifically, ACEs now discussed whether the failure to properly evaluate previously identified OE was a potential precursor of the event.

The licensee took proactive efforts to address a declining trend in the Security Department Safety-Conscious Work Environment (SCWE). The inspectors received positive feedback during interviews with Security officers, and noted an increasing trend in the number of issues identified by the Security force.

The licensees actions to address the previous cross-cutting issues in Human Performance and a potential cross-cutting issue in Issue Evaluation appeared good. The corrective actions appeared appropriate and the inspectors noted improving performance over the last six months in these areas.

However, the inspectors noted that the licensee had recurring problems with managing the CAP backlog and with ensuring that items identified during management observations were captured in the CAP. The inspectors also identified some examples where licensee staff had changed due dates for subtasks without referencing the source CAP report.

The inspectors identified that CAP implementing procedures did not provide good guidance regarding how to evaluate critical and non-critical component failures. Specifically, some component failures, which could reasonably be considered critical, (i.e., had significant consequences) could be classified as non-critical using the current guidance.

The inspectors observed that there were continuing issues related to work planning and execution and with contractor control. Although both problems were captured in the CAP, the underlying causes were not yet fully understood, resulting in most of the corrective actions being reactive rather than proactive. For example, it was unclear whether the underlying causes that affected site human performance were the same issues that were affecting the contractor performance. In addition, as previously stated, some issues identified through management observations associated with these topics may not be captured in the CAP.

Although the station continued to evaluate the issue, it remained an area of concern given the significant outage work planned for the next year.

NRC-Identified

and Self-Revealed Findings No findings were identified.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution (PI&R)

The activities documented in sections

.1 through .4 constituted one biennial sample of

PI&R as defined in Inspection Procedure (IP) 71152.

.1 Assessment of the Corrective Action Program (CAP) Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees CAP implementing procedures and attended CAP program meetings to assess the implementation of the CAP by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CAP since the last NRC PI&R inspection in November 2008. The issues selected were appropriately varied across the NRC cornerstones, and were identified through routine daily plant activities, licensee audits and self-assessments, industry operating experience reports, and NRC inspection activities. The inspectors also reviewed a selection of apparent, common and root cause evaluations for more significant CAP items.

The inspectors performed a more extensive review of the licensees efforts to address ongoing issues with human performance and issue evaluation. This review consisted primarily of a five year search of related issues identified in the CAP and discussions with appropriate licensee staff to assess the licensees corrective actions.

During the reviews, the inspectors evaluated whether the licensee staffs actions were in compliance with the facilitys CAP and 10 CFR Part 50, Appendix B requirements.

Specifically, whether licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings.

All documents reviewed during this inspection were listed in the Attachment to this report.

b. Assessment

(1) Effectiveness of Problem Identification The licensees implementation of the CAP was generally good. Workers were encouraged to identify issues and were familiar with the various avenues available (NRC, CAP, etc). This was evident by the large number of CAP items generated annually, which were reasonably distributed across the various departments. A shared computerized database was used for creating individual reports and for subsequent management of the processes of issue evaluation and response. This included determining the issues significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate.

In reviewing licensee management observations conducted between June and October 2010, the inspectors found several examples of items that were apparently not captured in the CAP. Most of the examples were concerned with industrial safety or work planning issues that should have been captured in the CAP. In one example, a worker observing an industrial safety concern stated that because the worker had not met a management expectation, vice a procedural requirement, the issue wasnt going to be documented in the CAP. The licensee documented the inspectors concern as CAP item 1251890.

The licensee was also good at identifying and resolving trends. The inspectors noted a large number of trends identified through the binning of issues or via the quarterly department roll-up meeting (DRUM) reports.

During the November 2008, PI&R review, the inspectors identified that the licensees trending program was somewhat limited in that it did not always identify trends with issues affecting the same functional area, but having dissimilar aspects. Subsequently, the licensee initiated an effort to assign cross-cutting criteria (analogous to NRC criteria)to apparent and root cause evaluations, which were then trended. Although the inspectors considered this a positive effort, it was too early to determine its overall effectiveness.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues Overall, CAP issues were being properly screened. The majorities of issues were of low level and were either closed to trend or at a level appropriate for a condition evaluation.

Licensee staff appropriately challenged CAP items during screening meetings and were cognizant of potential trends. Most issues were closed to a work request or to another CAP item. The inspectors noted that both the parent and daughter documents had the necessary verbiage to document the interrelationship. Although fewer in number, the inspectors did not have any concerns with those issues assigned an apparent cause evaluation (ACE) or root cause evaluation. There were no items in the operations, engineering, or maintenance backlogs that were risk significant, individually or collectively. There were no classifications or immediate operability determinations with which the inspectors disagreed.

Root and apparent cause evaluations were generally of good quality and were well documented. During the 2006 PI&R inspection, the inspectors noted that ACEs did not consider whether the failure to consider industry OE was a precursor to events.

Additionally, licensee management did not always address issues with ACE quality that were identified during the evaluation grading process. The inspectors noted that subsequent ACEs now addressed whether OE was properly used prior to the event and that ACE quality issues were communicated to the originating departments.

Station Procedure FP-E-SE-02, Component Classification, was used by licensee staff to distinguish between a critical and non-critical component failure. The procedure was written specifically to address equipment reliability, but was referenced in the CAP for use during cause evaluations. Although the stated guidance was adequate for equipment reliability considerations, it was not appropriate for CAP evaluations.

For example, this procedure specifically defines any component failure that results in a significant radiological release as a non-critical component failure. From a CAP perspective, any component failure resulting in significant radiological consequences would be critical. The inspectors were concerned that this procedure may result in some component failures being treated as less significant under the CAP, then appropriate. The licensee initiated CAP item 1250116 to review this issue.

Since 2006, the licensee has experienced numerous issues in human performance.

Initially, these issues were primarily of low significance (i.e., did not result in an NRC finding). However, the issues continued through 2008, with the significance of the findings increasing, until an adverse trend in human performance had become evident.

The licensees early efforts to address this trend were largely ineffective, as the licensee originally believed that the human performance issues were limited to specific behaviors or work groups, instead of a more widespread concern involving fundamental human behaviors. Subsequently, the licensee identified that the issues were principally due to a lack of resources and an inappropriate tolerance for risk among workers. Several corrective actions were initiated, including additional training to site workers on configuration control and risk management. The inspectors noted that performance had improved among site workers in the past six months.

However, the licensee was still dealing with an adverse trend in contractor human performance, primarily related to oversight and work planning and execution.

Although this issue was captured in the CAP (items 1249158 and 1247197), the underlying causes are not yet fully understood, and many of the corrective actions, to date, have been more reactive than proactive. For example, it is unclear whether the underlying causes that affected site human performance were also affecting the contractor performance. To date, the majority of the issues have been of low significance (i.e., not resulting in an NRC finding); however, the overall trend was similar to the previous issue with site human performance.

Findings

Introduction:

The inspectors identified an Unresolved Item (URI) regarding the High Energy Line Break (HELB) Analyses.

Description:

As part of the review of the ACE for an adverse trend in double disc gate valve (DDGV) local leak rate testing (LLRT) performance documented in CAP 1202466, the inspectors noted that the ACE had determined that the valves performance degradation did not prevent the valves from performing their safety function. The ACE only addressed the valves safety function of providing containment isolation. The inspectors questioned if the safety function of the high pressure coolant injection (HPCI),reactor core isolation cooling (RCIC) and reactor water cleanup (RWCU) steam supply valves to close after detection of a HELB should have been considered. The licensee responded that the ACE did not need to consider the effect of the valves increased leakage on the HELB analyses because any leakage would not impact the alternate shutdown path. The inspectors reviewed the assumptions and acceptance criteria of the HELB calculations for HPCI, RCIC and RWCU line breaks and identified potential inconsistencies between the calculations assumptions with Technical Specifications and UFSAR allowed values for valve closure times, incorporation of delay actuations, and isolation initiation signals. The licensee entered the NRC concerns with these potential inconsistencies into the CAP by initiating CAP 01252363 on October 1, 2010.

The licensee stated that the calculations were appropriate and provided the inspectors with some original licensing documents for the HELB analyses; however, additional questions remained. This issue will be tracked as URI 05000263/201007-01 pending further NRC review of the licensee responses and the HELB analyses and determination of the original and current licensing bases.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented, commensurate with their safety significance. Those corrective actions addressing selected NRC documented violations were also generally effective and timely.

The inspectors verified that work orders were in place (and scheduled) for selected, open actions that were two years old or greater.

During interviews, the inspectors noted that some individuals did not refer back to the parent CAP when changing due dates for associated subtasks (such as work requests).

The inspectors identified several examples where the revised due dates for subtasks were inconsistent with the parent CAP. Although none of the identified examples were highly significant, the inspectors were concerned that the practice may result in other changes having a greater operational impact. The licensee initiated CAP item 1250089 to evaluate this issue.

The station has a recurring problem with managing the backlog. A recent licensee initiative to redefine the items tracked in the backlog has reduced the numbers, but didnt necessarily address the issue. The licensee currently tracks only Corrective Actions, Corrective Actions to Prevent Recurrence, and operability issues. Other items, that used to be part of the backlog, were instead tracked as CAP action items. However, the inspectors noted that there was no formal effort to determine whether the CAP action items were being addressed in a timely fashion (i.e., no performance indicator similar to the formal backlog indicator). Since these action items were corrective actions (albeit of lower significance), the inspectors were concerned that some may not get implemented.

Complicating the issue was an apparent mixed message from station management, who expressed the view that the backlog numbers werent important so long as items were being properly managed. Since this issue was already captured in the CAP, the inspectors observations were included as part of the ongoing licensee evaluation.

Findings No findings were identified.

.2 Assessment of the Use of Operating Experience (OE)

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys OE program.

Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected assessments of the OE composite performance indicators. The inspectors review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented.

Documents reviewed during this inspection are listed in the Attachment to this report.

b. Assessment In general, OE was effectively used at the station. The inspectors observed that OE was discussed as part of the daily station planning meetings, at shift turnover meetings, and at maintenance pre-briefings. Also, the inspectors determined that OE was appropriately reviewed during causal evaluations. During interviews, several licensee personnel commented favorably on the use of OE in their daily activities.

The inspectors noted that the OE evaluation for a relay failure that resulted in the inoperability of a safety-related train at Harris (Action Request (AR) 1233871) was somewhat limited in scope. The evaluation identified that similar relays were used at Monticello, but in non-safety related equipment; therefore, no actions were required.

However, there was no documented evaluation whether a failure of these relays in the affected equipment could have had any significant operational impact. The licensee documented this issue as CAP item 1252873.

Findings No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the CAP program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits.

b. Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold level. The audits and self-assessments were completed by personnel knowledgeable in the subject area, and the quality of the NOS audits was thorough and critical. The self-assessments were acceptable but were not at the same level of quality as the NOS audits. The inspectors observed that CAP items had been initiated for issues identified through the NOS audits and self-assessments.

The inspectors observed selected meetings of the Performance Assessment Review Board and reviewed board meeting minutes over the past six months. The Board provided oversight for the CAP including the self-assessment program. The inspectors identified no issues with the Boards performance during the inspection.

Findings No findings were identified.

.4 Assessment of Safety-Conscious Work Environment (SCWE)

a. Inspection Scope

The inspectors assessed the licensees SCWE through the reviews of the facilitys ECP implementing procedures, discussions with ECP coordinators, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results of licensee safety culture surveys.

b. Assessment The inspectors determined that the plant staff were aware of the importance of having a strong SCWE and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for safety issues raised, or knew of anyone who had failed to raise issues. All persons interviewed had an adequate knowledge of the CAP and ECP process. These results were similar to the findings of the licensees safety culture surveys. Based on these interviews, the inspectors concluded that there was no evidence of an unacceptable SCWE.

The inspectors noted that the licensee had taken proactive efforts to address a declining SCWE trend within the Security force. This trend had been identified through self-assessments and audits conducted in 2009. The number of issues self-identified by the security staff had increased since the corrective actions were implemented.

Additionally, during interviews with the inspectors, Security staff commented favorably on the licensee initiatives to improve the SCWE.

The inspectors determined that the ECP process was being effectively implemented.

The review of the selected ECP issues indicated that site personnel were appropriately using the CAP and ECP to identify concerns. However, many staff were unaware of the other avenues the licensee had to raise concerns (collectively known as the PEACH process). For example, most staff were unaware of the Differing Professional Opinions (DPO) program for addressing engineering issues. Additionally, some newer staff confused safety culture with industrial safety. Similar issues were identified during the 2008 PI&R inspection. The licensee captured these issues as CAP item 1252870.

Findings No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On October 1, 2010, the inspectors presented the inspection results to Mr. OConnor and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

H. Butterworth, Fleet Operations Standards Director

P. Byers, Security Manager

J. Early, Emergency Preparedness Manager

N. Haskell, Engineering Director

M. Holmes, Radiation Protection/Chemistry Manager

K. Jepson, Business Support Manager

J. Mestad, Employ Concerns Program Manager

D. Neve, Regulatory Affairs Manager

J. Ohotto, Design Engineering Manager

T. OConnor, Site Vice-President

S. Porter, System Engineering Manager

S. Radebaugh, Acting Plant Manager

S. Sharpe, Operations Manager

G. Sherwood, Program Engineering Manger

T. Toglery, Nuclear Oversight Manager

J. Windchill, Fleet Performance Assessment Manager

Nuclear Regulatory Commission

K. Riemer, Chief, Branch 2, Division of Reactor Projects

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened:

URI

05000263/201007-01 HELB Analysis Potentially Non-Conservative Attachment