IR 05000263/2003009

IR 05000263-03-009; 11/3/2003 -12/05/2003; Nuclear Management Company, LLC; Monticello Nuclear Generating Plant; Identification and Resolution of Problems

ML040140684
Person / Time
Site:	Monticello
Issue date:	01/14/2004
From:	Burgess B NRC/RGN-III/DRP/RPB2
To:	Thomas J. Palmisano Nuclear Management Co
References
IR-03-009
Download: ML040140684 (25)

Text

ary 14, 2004

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 50-263/2003009

Dear Mr. Palmisano:

On December 5, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at the Monticello Nuclear Generating Station. The enclosed report documents the inspection results which were discussed on December 5, 2003, with you and members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel. No findings were identified.

On the basis of the sample selected for review, the team concluded that in general, problems were being properly identified, evaluated, and corrected. While no findings were identified during the inspection, the team had several observations regarding the effectiveness of corrective action program implementation as detailed in the enclosed report. The observations are not limited to one or two organizations, indicating to us that your staff may not fully understand or appreciate the importance of the corrective action process.

In addition to the observations, the team is concerned that the corrective action program at Monticello continues to be in transition. This inspection is the third PI&R inspection in the last thirty months. During the first inspection site personnel indicated the program was in transition.

We followed up the initial inspection only to find the program still in transition. At the beginning of the current inspection we were again informed that the program is in transition. While we identified a number of enhancements your staff had made to the program prior to our inspection, and a number of enhancements your staff plans to implement, we remain concerned of the protracted amount of time the program has been in a state of change. At the exit, we requested that you provide a schedule for when the corrective action program enhancements planned for implementation will be fully implemented. In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/ RA /

Bruce L. Burgess, Chief Branch 2 Division of Reactor Projects Docket No. 50-263 License No. DPR-22

Enclosures:

Inspection Report No. 50-263/2003009 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-263 License No: DPR-22 Report No: 05000263/2003009 Licensee: Nuclear Management Company, LLC Facility: Monticello Nuclear Generating Plant Location: 2807 West Highway 75 Monticello, MN 55362 Dates: November 3, 2003, through December 5, 2003 Inspectors: G. Wright, Project Engineer - Team Lead Robert Orlikowski, Resident Inspector Michael Jordan, Consultant Approved by: Bruce L. Burgess, Chief Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000263/2003009; 11/3/2003 -12/05/2003; Nuclear Management Company, LLC;

Monticello Nuclear Generating Plant; Identification and Resolution of Problems.

The inspection was conducted by one region-based inspector, one resident inspector and one consultant. No findings of significance were identified.

Identification and Resolution of Problems In general, the plant identified issues and entered them into the corrective action process at an appropriate level. Nuclear Oversight (NOS) assessment reports identified issues for the plant to resolve, including issues with corrective action follow through and effectiveness. The majority of issues reviewed were properly categorized and evaluated although some evaluations were narrowly focused, particularly for cause evaluations. In general corrective actions reviewed were appropriately implemented and appeared to have been effective. While no findings were identified during the inspection, the team developed a number of observations including:

1. Weaknesses in trending issues,

2. Level of detail and information provided in assessments was not always sufficient to allow the reader to reach the same conclusion as the author(s).

3. Actions to correct conditions (ACCs) were not always handled in a manner to ensure that corrective actions were acceptable to the original reviewer of the condition report.

4. A number of assessments were overly narrow in their focus resulting in missed opportunities to identify broader or secondary causes.

5. The quarterly performance assessment program has made a positive impact on the corrective action program. The team, during discussions with the licensee, identified program guidance and implementation enhancements which would improve the programs effectiveness.

REPORT DETAILS

4OA2 Problem Identification and Resolution

.1 Effectiveness of Problem Identification

a. Inspection Scope

The inspectors reviewed NRC inspection report findings issued over the last 2 years, selected plant corrective action documents, Nuclear Oversight (NOS) assessments, operating experience reports and trend assessments to determine if problems were being identified at the proper threshold and entered into the corrective action process.

The inspectors also conducted a focused plant walkdown of the High Pressure Coolant Injection System (HPCI) to ensure that equipment problems were entered into the corrective action system. The documents used during the review are listed in

1. b. Observations

In general, the plant identified issues and entered them into the corrective action process at an appropriate level. NOS assessment reports identified issues for the plant to resolve and entered the deficiencies into the corrective action program (CAP). The licensee appropriately used the CAP to document instances where previous corrective actions were ineffective or inappropriate. The teams review also noted the following items:

b.1 Identification Threshold The licensee had defined an adequate threshold for the identification of issues to be entered into the corrective action program. The corrective action documents are called condition reports (CR). The generation rate for CRs was appropriate with approximately 5500 general CRs written at the time of the inspection. Both the number and significancy level distribution of CRs appeared to be appropriate for the facility.

b.2 Operating Experience The inspectors reviewed a sampling of industry operating experience (OPEX) reports and concluded that the licensee was appropriately including the issues in the CAP.

Refer to Section

.2. b.3 for additional information on operating experience.

b.3 Nuclear Oversight The inspectors reviewed a sample of NOS assessment reports from the past 2 years and determined that the NOS staff, in general, was effectively identifying plant performance issues including issues with implementation of the CAP.

.2 Prioritization and Evaluation of Issues

a. Inspection Scope

The team reviewed previous NRC inspection reports and associated corrective action documents to verify that identified issues were appropriately characterized and entered into the CAP.

Inspection team members attended management meetings to observe the assignment of CR categories for current issues and the review of root, apparent, and common cause analyses, and corrective actions for existing CRs.

The team conducted an independent assessment of the prioritization and evaluation of selected CRs. The assessment included a review of the category assigned, the operability and reportability determinations, the extent of condition evaluations, the cause investigations, and the appropriateness of assigned corrective actions. Other attributes reviewed by the team included the quality of the licensees trending of conditions and the corresponding corrective actions. The team also assessed licensee corrective actions stemming from Non-Cited Violations (NCVs) and Licensee Event Reports (LERs). This review included the controlling procedures, selected records of activities, and observation of various licensee meetings. In addition, the team conducted several interviews with cognizant licensee personnel.

The team likewise reviewed the licensees efforts to capture industry operating experience (OPEX) issues in the CAP. Documents reviewed included the licensees assessment of industry operating event reports, NRC, and vendor generic notices.

Information reviewed by the team dated back to the previous problem identification and resolution inspection conducted in 2001.

b. Observations The team verified that in general the issues reviewed through the CR process were properly categorized and evaluated. However, the team had several observations regarding the licensees trending program and the quality of its documentation. Details of the teams observations are described in the following subsections.

b.1 Overview of Prioritization and Evaluation Process The corrective action process included a review of newly initiated CRs by the Management Review Committee (MRC) composed of senior plant management. The MRC reviewed the investigation class assigned to each CR. Within the licensees program, an 1 was assigned to a Significant Condition Adverse to Quality (SCAQ)requiring a root cause evaluation, a 2 was assigned to a Condition Adverse to Quality (CAQ) requiring an apparent cause evaluation, and 3 was a CAQ requiring a condition evaluation to determine the proper corrective actions. A significance level 4 was also available for conditions that were not adverse to quality.

The team noted a number of assessments that were overly narrow in their focus resulting in missed opportunities to identify broader or secondary causes. For example:

-CR 02010480; Prim Cont Isolation function of TIP(Transverse Incore Probe) ball valves not considered during maintenance activity; dated 11/07/02 - This CR was written when maintenance on a TIP was conducted and a licensed operating crew recognized the LCO entry and took proper actions: however, during previously conducted maintenance on a TIP, a separate licensed operating crew did not recognize the entry into the LCO. The actions to prevent recurrence included changing a procedure to identify entering an LCO when performing this surveillance; however, neither the assessment nor the corrective actions addressed why a fully licensed crew did not recognize the LCO entry when the TIP was manually operated.

-XOE 03003868; OE15909 Uncontrolled locked high radiation area discovered in drywell resulted in tech spec violation; dated 4/11/03 - The condition report addressed the concern with the drywell not being posted as a high radiation area which was one of the issues in the OE. However, no actions were taken to address the cause for the high radiation area, which was flushing of a hydraulic line.

-CR 03008607; Corrective action for QAF 02000867 was not effective in resolution of FME concerns and deficiencies; dated 8/20/03 - Quality Assurance conducted an audit of FME concerns and determined the action to be not effective, and identified a potential cause to be ... that the supervisors are not enforcing or promoting higher standards. This potential cause was not addressed in the actions to close this CR.

The team also identified one CR where all available options did not appear to have been evaluated prior to formulating a corrective action.

-CR 03002298 Unexpected HPCI Turbine Inlet Hi Drain Pot Level Alarm C3-B-10

- The CR was written to evaluate actions regarding a recurring HPCI high level drain alarm. The recommended corrective action was to perform a vibration analysis on the system and then add additional bracing to the system to stop the vibration. It did not appear that alternatives were considered in addressing the sporadic alarm including alarm circuitry or consideration of age degradation on the alarm. A subsequent CR 03010262 provided additional solutions to the issue.

b.2 Trending Program The team performed an in-depth examination of the licensees trending activities as a follow-on to an observation made in the previous problem identification and resolution inspection.

With respect to the quality of the trending program, the team had the following observations:

• In the CAP coding area, the team noted that the licensees trend analysis relied primarily on individuals. While the licensee used the computer system to generate lists of potentially related issues, it did not use the computer to identify potential trends. The lack of such computer enhanced trending tools limits the trending programs effectiveness.

• On a number of occasions, the team identified where an item was not included in a trend analysis because it was classified as legacy. The team agreed with the logic; however, the team noted that the licensee had not provided any explanation as to why the item couldnt be a problem today. For example:

In Design Engineerings 2nd Quarter 2003 Effectiveness Report is a statement: of the remaining eight CRs, two are old design documentation issues, one was determined to be a non-issue and one was due to issues not part of design engineering. No description was offered as to why the old design documentation issues couldnt be a current problem.

• The quarterly performance assessment program oversight panels (Process, Human Performance, and Equipment Performance), were appropriately reviewing their respective areas for trends and when appropriate, requesting further evaluations from individual site organizations.

b.3 Documentation In general, the team found the licensees documentation practices associated with the CAP to be weak. In several instances, the team was only able to successfully understand the licensees actions because key individuals recalled details of what had occurred and, more importantly, why it had occurred. The team noted that this documentation weakness leaves the licensee vulnerable to the loss of key information.

For example:

• OPEX items,

-XOE 03007050; IN 200-08 Potential flooding through unsealed concrete floor cracks; dated 7/03/03 - The documentation that closed this CR did not clearly document that the Monticello procedure included the inspections of the floors for cracks and spalling which were identified in the original IN.

-XOE 02000709; OE13172 Diesel Generator foundation hold down bolt found broken; dated 1/28/02 - The action addressed in the OE was to periodically check the torque on the hold down bolts for the diesel generator. The action implemented by Monticello was a walkdown inspection of the foundation bolts.

This action did not included a check of the bolts torque and no explanation as to why the torque was not checked.

• Cause analysis,

-CR 03002719; Unplanned LCO entered when both Rx Bldg air locks doors were opened at the same time; dated 3/13/03 - The CR did not document which doors were found open, thus it was difficult to determine if the corrective action taken to prevent recurrence from a previous CR was ineffective or if this was a problem with another set of doors.

-CR 02000867; Deficiencies in ME (Foreign Material Exclusion) practices have resulted in control rod not functioning and have potential to damage Rx system; dated 2/01/02 - The CR did not provide sufficient information to substantiate that an evaluation to identify actions to prevent recurrence and actions to correct cause were properly conducted as required by station procedures for a Level 1 CR.

-CR 02000889; Human performance error assessment, dated 02/01/2002 - Two documentation issues were identified with this CR. The first being the connection between causes and corrective actions was unclear. There were numerous corrective actions which appeared to provide positive actions; however, there was little direct correlation to the identified causes. Second, the actual level of assessment was not documented in the CR. This lack of documentation made it very difficult to understand whether an analysis had been performed or only a computer search on cause codes. Discussions with the licensee on both points identified appropriate actions and assessments had taken place.

.3 Effectiveness of Corrective Action

a. Inspection Scope

The inspectors reviewed past inspection results, selected CRs, root cause reports and common cause evaluations to verify that corrective actions, commensurate with the safety significance of the issues, were specified and implemented in a timely manner.

The inspectors evaluated the effectiveness of corrective actions. The inspectors also reviewed the licensees corrective actions for Non-Cited Violations (NCVs) documented in NRC inspections in the past 2 years. The inspectors conducted a walkdown of the High Pressure Coolant Injection (HPCI) system to assess the material condition of the system and verify that the licensee appropriately identified degraded conditions within the corrective action program.

b. Observations In general, the licensees corrective action for the sample reviewed were appropriate and appeared to have been effective. The team noted that the licensee appropriately used the CAP to document instances where previous corrective actions were ineffective or inappropriate.

b.1 Effectiveness of Corrective Actions The team noted that actions in Condition Reports which requested only a review/assessment or evaluation did not have a formal feedback loop to the original CR review panel before closeout. Sometimes the review/assessment or evaluation resulted in actions which were different than what had been recommended. This may be appropriate, however, the original CR reviewer was not appraised of the changes or evaluation results. For example:

-TCC 03002388; Evaluate the following plant operating conditions for incorporation into plant procedures; dated 3/04/03 - This TCC listed four operating conditions which the review panel felt needed to be changed in the plant procedures. The direction was to evaluate, and the evaluation determined two of the four actions were needed and the others were not. The TCC was then closed with no indication as to whether the Panel agreed with the action.

-Monticello Nuclear Generating Plant Human Performance Panel Trend Analysis Report for 1st Quarter 2003 generated CR 03004592 to evaluate the use of error reduction tools and documents in the System Engineering organization. In the 2nd quarter evaluation the Human Performance Panel generated another CR on the same subject with the following comment: This is the second consecutive quarter that a CR was written on indications of written document quality. The previous CR was closed with no action required. Discussions with the licensee indicated that the Panel had not seen System Engineerings response to the first CR. A similar situation occurred with the Maintenance department.

.4 Work Orders and the Corrective Action Program

a. Inspection Scope

The inspection team reviewed condition reports which had been closed to work requests or other condition reports to assess whether the original issue was appropriately addressed in the follow-on document. The team also assessed the licensee review of work orders for additional issues which might be adverse to quality.

b. Observations b.1.

Practice of Closing CRs to Work Requests or other CRs The team verified that the issues addressed in the initial CR were appropriately addressed in subsequent work requests or CRs.

b.2 Post Activity Work Order Reviews The team identified that the post activity work order reviews were being conducted to ensure that administrative requirements were being followed. The team was concerned that information provided on the work order was not being reviewed with an eye towards identifying additional issues which might warrant condition reports by themselves. Further, the team could not identify any guidance regarding review of narrative information on CRs provided by the individual who performed the work.

.5 Corrective Action Program Enhancements

Discussions with the licensee identified the following enhancements being implemented at Monticello:

a.

Designation of department CAP coordinators; b.

Enhanced membership and meeting frequency of the Corrective Action Review Board; c.

Enhancements to the condition report screening team; and d.

Designating CAP attribute ownership to site organizations.

.6 Quarterly Performance Assessment Reviews:

a. Inspection Scope

The team reviewed the quarterly performance assessment program at Monticello, concentrating on the past years reports.

b. Observations The site has had in place for approximately the past two years a quarterly performance assessment program. The program has each department assess their performance and provide the results to senior management. In addition, the program defines three Panels which look across organizations in the areas of human performance, process, and equipment performance. The team believed that the program has been beneficial and has the potential to be a very valuable part of the corrective action process.

In reviewing the output from the quarterly reviews the team had the following observations:

There is no site wide guidance on format or content;

Often the organizational assessments provide numbers and statistics, and may identify issues; however, they dont always address corrective actions - ongoing, in-development, or planned; and

Actions by organizations in response to a Panel generated condition report is not reviewed by the Panel.

The team concluded that the above items limited the effectiveness of the quarterly review process.

.6 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspectors conducted interviews with plant staff to assess whether there were impediments to the establishment of a safety conscious work environment. During these interviews, the inspectors used Appendix 1 to Inspection Procedure 71152, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R Issues, as a guide to gather information and develop insights. The inspectors also discussed the implementation of the Employee Concerns Program (ECN) and selected concerns with the plants ECN Coordinator. Additional discussions with the ECN Coordinator centered on integration of the ECN and CAP programs.

b. Observations Plant staff interviewed did not express any concerns regarding the safety conscious work environment. The staff was aware of and generally familiar with the corrective action program and other plant processes including the Employee Concerns Program through which concerns could be raised. Further, a review of the types of issues in the ECN indicated that site personnel were appropriately using the corrective action and employee concerns programs to address their concerns. The inspectors discussed the results of a survey conducted by the ECN earlier in 2003 and actions taken by the licensee based on the survey results. Based on interviews, the ECN Coordinator was appropriately focused on ensuring all site individuals were aware of the program, reviewing individual concerns, and integrating where appropriate the ECN and CAP programs to resolve concerns.

4OA6 Management Meetings

.1 Exit Meeting Summary

The inspectors presented the inspection results to Mr. T. Palmisano and other members of licensee management in an exit meeting on December 5, 2003. The licensee acknowledged the observations presented and indicated that no proprietary information was provided to the inspectors.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

P. Albares Programs Engineering Manager

M. Antony Design Engineering Supervisor

R. Balmer Regulatory Affairs, Compliance Engineer

K. Booth Performance Assessment, CAP Coordinator

G. Bregg Nuclear Oversight, Manager

T. Crippes Equipment Panel Lead

D. Crofoot Training Manager

R. Von Dell Business Support Manager

R. Goransan Human Performance Coordinator

J. Grubb Business Manager

S. Halbert Performance Improvement Manager

M. Holmes Chemistry Supervisor

D. Horgen Corrective Action Program Coordinator

K. Jepson Radiation Protection/Chemistry Manager

B. MacKissock Operations Manager

G. Mathiasen Health Physicist

J. Mestad Employee Concerns Program Coordinator

D. Neve Regulatory Affairs Manager

R. Olson Maintenance Manager

T. J. Palmisano Site Vice President

M. Petitclair Design Engineering (Equipment Process Control Chairman)

S. Porter Electrical Engineering Supervisor

J. Purkis Plant Manager

B. Sawatzke Performance Assessment Manager

S. Sharp System Engineering Manager

Mike Winters Mechanical Maintenance Supervisor

ITEMS OPENED, CLOSED, AND DISCUSSED

Items Opened: None Items Closed: None Attachment

LIST OF ACRONYMS ACC Action to Correct Cause AFI Area for Improvement AO Air Operated App Appendix APRM Average Power Range Monitor AWI Administrative Work Instruction Bldg Building CARB Corrective Action Review Board CAQ Condition Adverse to Quality CHAMPS Computerized History and Maintenance Planning System CGCS Combustible Gas Control System CR Condition Report CRS Control Room Supervisor CRD Control Rod Drive CRV Control Room Ventilation DRP Division of Reactor Projects ECP Employee Concern Program EDG Emergency Diesel Generator FME Foreign Material Exclusion GEMAC General Electric Manual/Automatic Controller INPO Institute of Nuclear Power Operation LCO Limiting Condition for Operation LPRM Linear Power Range Monitor LS Limit Switch Lvl Level MAPP Management Assessment and Plant Performance MDI Maintenance Department Instruction MNGP Monticello Nuclear Generating Plant MRC Management Review Committee MSIV Main Steam Isolation Valve NMC Nuclear Management Company NRC Nuclear Regulatory Commission OA Other Activity OCD Operations Control Document ODBC Open Data-Base Connect OQAP Operational Quality Assurance Plan PHC Plant Health Committee QA Quality Assurance QAF Quality Assurance Finding RFO Refueling Operations RBM Rod Block Monitor RBV Reactor Building Ventilation RPV Reactor Pressure Vessel RHR Residual Heat Removal RX Reactor SBGT StandBy Gas Treatment Attachment

SCAQ Significant Condition Adverse to Quality SCT Secondary Containment SCTMT Secondary Containment SJAE Steam Jet Air Ejector SPOTMOS Suppression Pool Temperature Monitoring Operating System Surv Surveillance TIP Transverse Incore Probe WEC Work Execution Center WO Work Order WRGM Wide Range Gas Monitor XOE External Operating Event Attachment