05000263/LER-2013-007-02, Regarding Unanalyzed Condition Due to Inadequate Flooding Procedures

Regarding Unanalyzed Condition Due to Inadequate Flooding Procedures

ML15029A638
Person / Time
Site:	Monticello
Issue date:	01/27/2015
From:	Gardner P Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-15-002 LER 13-007-02
Download: ML15029A638 (5)

LER-2013-007, Regarding Unanalyzed Condition Due to Inadequate Flooding Procedures

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2632013007R02 - NRC Website

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NRC FORM 366 (02-2014)

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (02-2014)

LICENSEE EVENT REPORT (LER)

(See Page 2 for required number of digits/characters for each block)

APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017 Estimated burden per response to comply with this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.

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1. FACILITY NAME Monticello Nuclear Generating Plant

2. DOCKET NUMBER 05000 - 263

3. PAGE 1 OF 4

4. TITLE Unanalyzed Condition Due to Inadequate Flooding Procedures

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL NUMBER REV NO.

MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 05000 08 29 2013 2013 007 02 01 27 2015 FACILITY NAME DOCKET NUMBER 05000

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 1 20.2201(b) 20.2203(a)(3)(i) 50.73(a)(2)(i)(C) 50.73(a)(2)(vii) 20.2201(d) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 20.2203(a)(1) 20.2203(a)(4) 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B) 20.2203(a)(2)(i) 50.36(c)(1)(i)(A) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A)

10. POWER LEVEL 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x) 100%

20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(A) 73.71(a)(4) 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a)(2)(v)(B) 73.71(a)(5) 20.2203(a)(2)(v) 50.73(a)(2)(i)(A) 50.73(a)(2)(v)(C)

OTHER 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B) 50.73(a)(2)(v)(D)

Specify in Abstract below or in LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET Create a formal engineering program to manage MNGP External Flood Mitigation to ensure proper validation of the external flooding strategy design bases.

Clarify in appropriate station documents, including, but not limited to, the USAR, external flooding section of Procedure A.6, and Design Bases Document for External Flooding, that the PMF antecedent conditions are required to be assumed present and that actions to mitigate a PMF must be preplanned.

Revise Procedure A.6, Section 5.0 to be an 8000 Series Special procedure. Control as an Infrequently Performed Test or Evolution (IPTE).

Other corrective actions are identified in the RCE to address contributing causes, the extent of condition and the extent of cause. Effectiveness reviews have been established to ensure adequate review of the results of the corrective actions are achieved.

PREVIOUS SIMILAR EVENTS

On November 26, 1990, the site identified, in a LER, that there were procedural inadequacies with the external flooding procedure related to protective measures for the Emergency Diesel Generator Fuel Oil Transfer House. The LER was supplemented April 24, 1991 with additional detail, including the cause of the event, which was procedural inadequacy.

On September 30, 2013, the site identified in a LER, that there were inadequacies in the Procedure A.6, Acts of Nature, to protect the site from a Probable Maximum Flood (PMF). The root cause for that event was determined to be: Station personnel incorrectly understood the 1980 NRC Safety Evaluation Report licensing basis to allow time for preparation of a detailed flood plan based on the presence of identifiable preconditions required for a Probable Maximum Flood (PMF) as stated in USAR, Appendix G. This misunderstanding was institutionalized through inclusion of this position in station documentation.