ML20140D277

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-263/96-09

ML20140D277
Person / Time
Site:	Monticello
Issue date:	04/15/1997
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Wadley M NORTHERN STATES POWER CO.
References
EA-97-032, EA-97-32, NUDOCS 9704230102
Download: ML20140D277 (2)

See also: IR 05000263/1996009

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April 15,1997

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EA 97-032

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Mr. M. D. Wadley l

Vice President, Nuclear Generation i

Northern States Power Company

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414 Nicollet Mall j

Minneapolis, MN 55401  ;

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-263/96009(DRS)) I

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Dear Mr. Wadley:

This will acknowledge receipt of your March 24,1997 letter in response to our

February 20,1997 letter transmitting a Notice of Violation associated with the above

mentioned inspection report. This report summarized the results of the system operational

performance inspection at your Monticello Plant. We have reviewed your corrective

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actions and have no further questions at this time. These corrective actions will be

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examined during future inspections. J

Sincerely,

/s/ M. Leach (for)

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Geoffrey E. Grant, Director l

Division of Reactor Safety

Docket No. 50-263

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Enclosure: Ltr 03/24/97, W. J. Hill,

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NSP, to US NRC w 'encI

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DOCUMENT NAME: G:\ MON 041_7 DRS l

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Ta receive a copy d thle document. Indicate in the box: "C" = Copy w/o attachment / enclosure "E" = Copy with attachmet t/ enclosure *N" = No copy

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OFFICE Rill:DRS lE Rlli:DRS g Rill:DRP ,_ A ,- Rlll:EICS A/ Rill:DRS l# I

l NAME Lougheed/kjck/Mg Ringt7#L Jacobso M (\ Clayton gc., Leach / Grant #

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DATE 04//q /97 04//1/97 04/1W97 )\ ) 04//.F/97 04/d797

9704230102 970415 mi ~~~'CIAL RECORD COPY

PDR ADOCK 05000263 lllll}llIIIlhE,$h,

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M. D. Wadley 2 April 15, 1997

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cc w/o encl: Plant Manager, Monticello

cc w/ encl: John W. Ferman, Ph.D.

Nuclear Engineer, MPCA  !

State Liaison Officer, State

of Minnesota

Distribution: ,

Dock SRis, Monticello, TSS w/enci i

%et File w/enciIC IE-01.w/encir#

OD/LFD'CB'w/enci '

? Prairie Island w/enci

LPM, NRR w/enci

J. Lieberman, OE w/enci

J. Goldberg, OGC w/ encl

DRP w/enci A. B. Beach, Rlli w/enci R. Zimmerman, NRR w/ encl

DRS w/enci C. D. Pederson, Rlll w/ encl

Rlli PRR w/enci Rlli Enf. Coordinator w/ encl

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Northem states Power Company

Monticello Nuclear Generating Plant

2807 West Hwy 75

Monticello. Minnesota 55362-9637

March 24,1997

US Nuclear Regulatory Commission 10 CFR Part 2

Attn: Document Control Desk Section 2.201

Washington, DC 20555

MONTICELLO NUCLEAR GENERATING PLANT

Docket No. 50-263 License No. DPR-22

Reply to Notice of Violation

NRC System Operational Performance

inspection (SOPI) Reoort No 50-263/96009(DRS)

Pursuant to the provisions of 10 CFR Part 2, Section 2.201, our reply to the

notice of violation contained in your letter of February 20,1997, is provided in

Attachment A.

Attachment A contains the following new NRC commitments:

Violation I.b 10 CFR 50.59 implementation processes will

be enhanced. Process enhancement,

including training on the revised processes and

management's expectations regarding the

quality of engineering work, will be completed

by March 31,1997

Violation ll.a,b,c,d Special training will be provided to Monticello

engineering and technical staff personnel on

the importance of rigor and attention to detail in

performing, revising, reviewing, approving, and I

documenting calculations. This training will be  ;

complete by March 31,1997.

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Violation Ill.a All Technical Specification Section 3/4

procedures will be examined over the next  !

three year period to ensure that a basis for

design document requirements and

acceptance limits is properly documented.

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l US Nuclear Regulatory Commission

1 March 24,1997  :

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Plant AWis goveming procedure content and ' '

l format will be reviewed and revised as  !

! necessary to require that bases for design

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document requirements and acceptance limits

is provided within each procedure or by

- reference to an acceptable bases document. -

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Procedure revisions will be completed by June .  !

1,1997.

All Technical Specification Section 3/4 . 1

i procedures will be examined over the next

three~ year period to ensure that a basis for

design document requirements and

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acceptance limits is properly documented.

This will be accomplished by describing the

source of the design document requirement or

acceptance limit within the procedure, or by

reference to an acceptable bases document.

The procedures will be reviewed and revised

as necessary by March 31,2000. Other

procedures will be checked, as resources I

allow, to ensure that a basis for design i

document requirements and acceptance limits l

Is properly documented. J

Violation Ill.b All surveillance procedures will be examined to

determine if the wording of the procedure could

trap personnelinto signing off the procedure as

completed before all required data analysis

and engineering evaluation is complete.

Changes will be made to these surveillance

procedures to ensure that they are tracked by

the surveillance coordinator through  !

completion of all required analysis and data

evaluation. AWis goveming procedure content

and format will be reviewed and revised as  !

necessary to eliminate these potential traps.

All actions will be completed by March 31,

1998.

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US Nuclear Regulatory Commission

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Please contact Mr Samuel Shirey, Sr Licensing Engineer, at (612) 295-1449 if

you require furtherinformation.

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William J Hill

Plant Manager

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, Monticello Nuclear Generating Plant

c: Regional Administrator- 111, NRC

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NRR Project Manager, NRC

Sr Resident inspector, NRC

State of Minnesota

Attn: Kris Sanda

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Attachment

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M:nticello Nucle:r G:n:rsting Pl nt Reply to Nstice of VI:liti:n

March 24,1997  ;

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Attachment A I

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REPLY TO NOTICE OF VIOLATION )

1. Violation i

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10 CFR 50.59 (a)(1) stated, in part, that the holder of a license authorizing

operation of a production facility may make changes in the facility as described in

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the safety analysis report without prior Commission approval unless the

proposed change involves a change in the technical specification incorporated in

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Te license or an unreviewed safety question.

10 CFR 50.59(b)(1) stated, in part, t lat the licensee shall maintain records of

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changes in the facility. These records r.1ust include a written safety evaluation

which provides the bases for the determination that the change does not involve l

an unreviewed safety question.

Contrary to the above:

a. On August 14,1996, during. closeout of Design Change Package  !

1. 85M042, "RHR System Pressure Upgrade Modification," Revision

l 1, the safety evaluation failed to provic's the bases for the

determination that the physical plant changes, that were not

retumed to their original values following the modification's

cancellation, did not involve an unreviewed safety question.

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b. On October 23, Safety Review item 96-016, "1996 FOl Identified l

USAR Changes," Revision 0, Addendum 4, failed to provide the l

bases for the determination that each change identified in the

safety review item did not involve an unreviewed safety question.

NSP Resoonse to item 1.a

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NSP acknowledges example 'a' cited in 6 above Notice of Violation.

Reason for Violation:

In the case of Modification 85M042, a safety evaluation was performed

and a USAR submittal was prepared in 1986 for this modification in its

original form. After completing part of the work in 1986, the modification

was put on hold when questions aroso concerning the change. Plant

management later cancelled the modification and the pending USAR

change. Engineering failed to recognize in 1986 that the scope of work

actually completed under Modification 85M042 prior to its cancellation

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Monticello Nuclear G:nerating Plant R: ply to Natics of VI:liti:n

March 24,1997 ,

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constituted a change to the facility as described in the Updated Safety

Analysis Report (USAR). At that time the plant should have revised the

f existing safety evaluation and prepared a change to the USAR.'

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[ The resulting USAR discrepancy was discovered in 1990 as part of design

basis document reviews. After making operability and reportability

j detcrminations, a safety evaluation was performed to support a correction

i of the discrepancy between the USAR and design documents. This

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safety evaluation, however, did not consider the cause of the discrepancy

[ - (i.e., the lack of an adequate safety evaluation for the original 1986

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modification). Consequently the safety evaluation incorrectly focused on

l the USAR change itself and whether it was consistent with the facility <

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The safety evaluation should have focused on the changes made to the

facility by the 1986 modification and whether those changes involved an

j] ' unreviewed safety question.

! It was recognized that this particular modification was a special situation

! because there were no procedures which covered closure of an

incomplete modification. Because it was also one of the oldest open )

l modifications in the backlog, it received increased management attention.

l There were several meetings among plant management to determine how

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best to address the work whicn was not completed by the original

l modification. After.much discussion it was decided in 1996 that the best

course of action was to close out the modification by revising the )

modification package to reflect the reduction in scope (i.e., to reflect the

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l work actually accomplished in 1986). However, since no additional I

i physical plant changes were associated with the 1996 revision of the l

modification package, and because by 1993 the USAR was in agreement i

with the actual plant configuration, we again did not recognize that the l

original 1986 safety evaluation was deficient. j

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! Therefore, the Monticello technical staff failed to recognize in .1986, when  !

the modification was partially completed, or in the early 1990s when the l

j USAR discrepancy was corrected, or in 1996 when the modification was ]

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revised and closed out, that an adequate safety evaluation addressing the

t actual scope of work was never pedormed. The situation was aggravated

by delay in closing out the modification and the lack of procedures to j

j cover the unusual and complicated situation of a partially completed and j

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cancelled modification. l

I Corrective Action Taken and Results Achieved: I

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Plant procedures have been revised to require a new or revised safety

) evaluation vihenever a change in the scope of a modification affects an

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! existing safety evaluation. -

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M:nticalls Nuclear G:nerating Plant R: ply to N:tice cf VI:lition

March 24,1997

' A Monticello Condition Report has been initiated to address the failure of

the 198610 CFR 50.59 safety evaluation to cover the scope of work

actually accomplished under Modification 85M042 (Condition Report

'97000239).

During review of this issue, an additional discrepancy in the safety I

evaluation for the 1986 modification was discovered. A relief valve

setpoint was changed and this change was inconsistent with an earlier

NRC Safety Evaluation Report (SER). An operability evaluation was

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completed and it was determined that the setpoint change did not affect

the operability of the RHR system. - This issue is being assessed and

resolved through the Monticello Condition Report process (Condition

Report 97000692). '

Corrective Action to be Taken to Avoid Further Violations: I

Additional corrective actions are described in the response to item 1.b

below.

Date When Full Comoliance Will Be Achieved

Full Compliance has been achieved.

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NSP Resoonse to item I.b

NSP acknowledges example 'b' in the above Notice of Violation.

Reason for Violation:

Safety Review item (SRI)96-016, Addendum 4, was cne portion of an

SRI that attempted to evaluate several unrelated activities at once. The

result was a confusing, incomplete, and difficult to review evaluation which

did not cleady address each activity using all of the 10 CFR 50.59(a)(2)

criteria.

Correctivo,Ap;un Taken and Results Achieved:-

Safety Review item 96-016, Addendum 4, is being revised to correct the

deficiencies described in the SOPl report. This is being tracked as a

Management Commitment (A97012A).

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M:nticella Nucisar Gen:rzting Pirnt R: ply to Nctice of VI:lition

March 24,1997

Corrective Action to be Taken to Avoid Further Violations:

Both examples cited in the Notice of Violation indicate poor

implementation of 10 CFR 50.59. These examples and recent industry

experience prompted Monticello management to examine all 10 CFR

50.59 implementing procedures and practices. This review concluded

that applicable plant Administrative Work Instructions _(AWis) need to be

revised to provide significantly more detail and to clearly communicate

management expectations regarding the content and level of detail of 10

CFR 50.59 evaluations.

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Training will also be presented to plant engineering and technical staff on

the nature of this violation, the new and enhanced 10 CFR 50.59

evaluation processes, and management's expectatiens 'regarding quality

of engineering work. AWis will be revised and training will be completed

by March 31,1997.

Date When Full Comoliance Will Be Achieved

Full compliance has been achieved.

II. Violation

10 CFR Part 50, Appendix B, Criterion Ill, " Design Control," states, in part, that

measures shall provide for verifying or checking the adequacy of the design, and

that changes shall be subject to design control measures commensurate with

those applied to the original design.

Contrary to the above:

a. On March 14,1996, changes were made to General Electric

Calculation EqDE-34-0687, " Core Spray System Operational

Capability Report," and these changes were not commensurate

with those applied to the original design. Changes were " penciled-

In" on a copy of the calculation, the "revi:. ed" calculation was not

entered into the document control system, and a record of the

" revised" calculation was not identifiable or retrievable within the

quality assurance records system.

b. . On June 24,1996, calculation CA-96-090, " Evaluation of ECCS

Net Positive Suction Head," Revision 0, was approved although the

design verification activities were not adequate. The calculation

reached an incorrect conclusion as to the amount of available net

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Monticella Nucl:cr G:n:r: ting Pl nt Reply to Notice cf Vi:1:ti:n

March 24,1997

positive suction head because the vapor pressure valuc used in the

calculation for water at 191*F was incorrect.

c. On December 6,1996, calculation CA-96-166, "Drywell Flooding  !

Evaluation for Post DBA LOCA," Revision 0, was approved to l

resolve non-conservative and non-verified assumptions contained '

in calculation CA-93-056 " Suppression Pool Drawdown

Calculation." The verification for the 1996 calculation was not l

adequate in that the calculation still contained non-verified, non-

conservative assumptions.

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d. On May 19,1995, calculation CA-94-20, "RHR/RHR Service Water i

Heat Exchanger Performance," Revision 1, was approved although  ;

the design verification activities were not adequate. The  !

verification consisted of confirming that a computer could perform

mathematical computations rather than verifying that the formulae

input to the computer were accurate.

NSP Response to item ll.a

NSP acknowledges example 'a' cited in the above Notice of Violation.  !

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Reason for Violation

The Monticello calculation control process was not adhered to in this l

Instance. Changes to the calculation should have been formalized and

controlled in accordance with Monticello 4 awl-05.01.25,

" Calculation / Analysis Control." Use of this process would have assured

. that the revised calculation was properly prepared, reviewed, approved,  ;

and entered into the Monticello document control system. The cause of

this event was, therefore, failure to follow prescribed plant administrative  ;

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processes and lack of attention to detail.

Corrective Action Taken and Results Achieved:

Changes to General Electric Calculation EqDE-34-0687 have been

formalized and processed in accordance with 4 awl-05.01.25.

Corrective Actions to be Taken to Avoid Further Violations:

Special training will be provided to Monticello engineering and technical

staff personnel on the importance of rigor and attention to detail in

performing, revising, reviewing, approving, and documenting calculations.

The expectations of Monticello management, that the Calculation / Analysis

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Muntic lla Nucinr G:nsrtting Plint R ply to Notice of Vichti:n

March 24,1997 -

Control process will be followed to the letter, will be emphasized at this

special training. This training will be complete by March 31,1997.

Date When Full Comoliance Will be Achieved:

Full compliance has been achieved.

NSP Resoonse to item il.b l

NSP acknowledges example 'b' cited in the above Notice of Violation. l

Reason for Violation

While this error was small and somewhat subtle, it should not have

occurred. The engineer who performed this calculation may have lacked

sufficient experience in pump net positive suction head (NPSH) design

calculations. The engineer reviewing the calculation did not detect the

error. And finally, the error was not detected by the engineering - ,

supervisor who approved the calculation. The cause of this event was  !

lack of attention to detall. l

Corrective Action Taken pnd Results Achieved:

Calculation CA-96-090 has been revised to correct the error noted in the

Violation.

ECCS pump NPSH calculations have been independently redone and

verified by an outside engineering consultant. Additional, more detailed,

NPSH calculations have been requested from tha engineering consultant.

Corrective Actions to be Taken to Avoid Further Violations:

Special training will be provided to all Monticello engineering and technical

staff personnel on the importance of rigor and attention to detail in

. performing, revising, reviewing, approving, and documenting calculations

as described in the response to item II.a above.

Date When Full Comoliance Will be Achieved:

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Full compliance has been achieved.

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Mentic:llo Nuclear G:ntrzting Pirnt Reply to Nctica cf VI:liti:n

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March 24,1997

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NSP Resoonse to item II.c

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NSP acknowledges example 'c' cited in the above Notice of Violation.

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Reason for Violation

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i Again, while these errors were small and somewhat subtle, they should j

! not have occurred. The errors were caused by lack of attention to detail. 1

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j Corrective Action Taken and Results Achieved: .

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Calculation CA-96-166 has been revised to address the inspector's

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concems.

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Corrective Actions to be Taken to Avoid Further Violations

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! Special training will be provided to all Monticello engineering and technical

i staff personnel on the importance of rigor and attention to detail in

[ performing, revisir.g, reviewing, approving, and documenting calculations  ;

as described in the response to item II.a above. i

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! pate When Full Comoliance Will be Achieved: l

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Full compliance has been achieved. l

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NSP Response to item II.d

NSP acknowledges example 'd' cited in the above Notice of Violation.  !

Reason for Violation  :

The Monticello calculation control process was again not adhered to in i

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this instance. The verification of the computer code change failed to

independently confirm the validity c: an equation used to derive a

fundamental parameter used in the calculation. The cause of this event

was failure to follow prescribed plant administrative processes and lack of

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attention to detail.  ;

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Corrective Action Taken and Results Achieved:

Independent verification of CA-94-20 has been reperformed by an

experienced senior Monticello engineer. ,

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M:ntic:lla Nucle:r Gin:riting PI:nt Reply to N::tice cf VI:ltti:n

March 24,1997

Corrective Actions to be Taken to Avoid Further Violations:

Refer to the description of special training that will be performed in the

response to item ll.a above. This training will be complete by March 31,

1997.

Date When Full Comoliance Will be Achieved:

Full compliance has been achieved.

Ill. Violation

10 CFR Part 50, Appendix B, Criterion XI, " Test Control," states, in part, that a

test program shall be established to assure testing is performed in accordance

with written test procedures which incorporate the requirements and acceptance

limits contained in design documents. Test results shall be documented and

evaluated to assure test requirements have been satisfied.

Contrary to the above:

a. On March 16,1995, surveillance procedure 1136, "RHR Heat

Exchanger Efficiency Test" was revised such that the acceptance

limits contained in design documents were no longer incorporated

. into the surveillance procedure. Specifically, the procedure was

revised to incorporate a heat exchanger area not contained in any

design document.

b. On March 23,1995, surveillance procedure 1136, "RHR Heat

Exchanger Efficiency Test," Revision 15, was signed by the shift

engineer as complete without the test results being evaluated to

assure test requirements were satisfied. The "HXPERF" computer

program output sheets, showing that the test results were

acceptable and required by the procedure to be attached, were

dated October 22,1996, and were based on Revision 1 of the

computer program rather than on Revision 0 as specified by the

test procedure.

NSP Resoonse to item Ill.a

NSP acknowledges example 'a' cited in the above Notice of Violation subject to

the following clarifying information.

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March 24,1997

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i Reason for Violation:

, We believe that the Monticello RHR heat exchanger efficiency test  ;

. acceptance criteria were correct and conservative. The criteria were

based on the results of Calculation CA-94-066, Revision 0, " Determination -

. 'of RHR Heat Exchanger K value," and were used in the evaluation of

l containment response as provided in NEDO-32418, "Monticello Design

i Basis Accident Containment Pressure and Temperature Response for

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USAR Update," December,1994. However, the heat exchanger vendor'e

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technical manual was not updated with revised heat exchanger surface

area data at the time of the inspection. Additional guidance related to +

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timely update of documents in the Condition Report Process AWI is

needed to ensure prompt update of this manual.

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it is also acknowledged that Monticello test procedures do not always l

i' provide the basis for test requirements and test acceptance criteria or link i

) such requirements and acceptance criteria to design documents. l

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Corrective Action Taken and the Results Achieved )

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l A Monticello Condition Report has been initiated to address updating of

j the RHR heat exchanger vendor manual (Condition Report 97000770).

Corrective Action That Will Be Taken to Avoid Further Violations

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The Condition Report Process AWI will be reviewed and additional  !

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guidance provided as necessary to help ensure corrective actions are  !

identified and tracked related to updating of plant documents. This will be i

completed by April 30,1997. i

Plant AWis goveming procedure content and format will be reviewed and

revised as necessary to require that bases for design document

requirements and acceptance limits is provided within each procedure or

by reference to an acceptable bases document. Procedure revisions will  ;

be completed by June 1,1997.

All. Technical Specification Section 3/4 procedures will be examined over

- the next three year period to ensure that a basis for design document

requirements and acceptance limits is properly documented. This will be

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accomplished by describing the source of the design document

requirement or acceptance limit within the procedure, or by reference to ,

an acceptable bases document. The procedures will be reviewed and '

revised as necessary by March 31,2000. Other procedures will be

checked, as resources allow, to ensure that a basis for design document

requirements and acceptance limits is properly documented.

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Date When Full Comoliance Will Be Achieved

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Full compliance has been achieved. '

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L NSP Resoonse to Item Ill.b '

NSP acknowledges example 'b' cited'in the above Notice of Violation.

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Beason for Violation:

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Approximately 18 months elapsed between collection of heat exchanger .  ;

} test data and completion of analysis of the data. i

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The engineering analysis section of the test procedure was improperly i

j signed off as "NA" after the heat exchanger test data was collected. With  ;

l. the "NA" entry, the test was considered as complete even though the test

i data had not been analyzed by engineering.' Since the procedure was

i considered complete, it was not called out for follow-up by the surveillance .

coordinator as would normally be the case for a late test. This procedure,  !

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and other similar procedures, are formatted in such a way that they  ;

increase the likelihood of prematurely signing off a procedure as

complete.

, Corrective Action Taken and the Results Achieved

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j See a description of the corrective actions to be taken below.

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Corrective Action to Be Taken to Avoid Further Violations

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AWis goveming procedure content and format will be reviewed and

revised as necessary to eliminate the potential trap descripted above. All

'survaillance procedures will be examined over the next year to determine

if the wording of the procedure could trap personnel into signing off the

procedure as completed before all required data analysis and engineering

evaluation is complete. Changes will be made to these surveillance

procedures to ensure that they are tracked by the surveillance coordinator

through completion of all required analysis and data evaluation. All

actions will be completed by March 31,1998.

Date When Full Comoliance Will Be Achieved

Full compliance has been achieved.

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