IR 05000263/2002003

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IR 05000263/2002-003(DRP), on 02/14-03/31/2002; Nuclear Management Company, LLC; Monticello Nuclear Generating Plant. Occupational Radiation Safety. Non-cited Violations Identified
ML021060263
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 04/15/2002
From: Burgess B
NRC/RGN-III/DRP/RPB2
To: Forbes J
Nuclear Management Co
References
IR-02-003
Download: ML021060263 (28)


Text

ril 15, 2002

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT NRC INSPECTION REPORT 50-263/02-03(DRP)

Dear Mr. Forbes:

On March 31, 2002, the NRC completed an inspection at your Monticello Nuclear Generating Plant. The results of this inspection were discussed on March 26, 2002, with you and other members of your staff. The enclosed report presents the results of that inspection.

The inspection was an examination of activities conducted under your license as they relate to reactor safety, verification of performance indicators, event followup, physical security, radiation protection, licensed operator requalification and compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations of activities, and interviews with personnel.

Based on the results of this inspection, the inspectors identified one issue of very low safety significance (Green). This issue was determined to involve a violation of Technical Specifications. However, because of its very low safety significance and because it has been entered into your corrective action program, the NRC is treating this issue as a Non-Cited Violation, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you deny this Non-Cited Violation, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Monticello facility. 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/NRC/ADAMS/index.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

Enclosure:

Inspection Report 50-263/02-03(DRP)

REGION III==

Docket No: 50-263 License No: DPR-22 Report No: 50-263/02-03(DRP)

Licensee: Nuclear Management Company, LLC Facility: Monticello Nuclear Generating Plant Location: 2807 West Highway 75 Monticello, MN 55362 Dates: February 14 through March 31, 2002 Inspectors: S. Burton, Senior Resident Inspector D. Kimble, Resident Inspector S. Ray, Senior Resident Inspector - Prairie Island Station G. Pirtle, Physical Security Inspector M. Mitchell, Radiation Specialist Inspector D. McNeil, Operator Licensing Examiner Approved by: Bruce L. Burgess, Chief Branch 2 Division of Reactor Projects

SUMMARY OF FINDINGS IR 05000263/02-03(DRP), on 02/14-03/31/2002; Nuclear Management Company, LLC; Monticello Nuclear Generating Plant. Occupational Radiation Safety.

The inspection was conducted by resident inspectors and regional inspectors. The report covers a 61/2-week period of resident inspection. The inspection identified one Non-Cited Violation Green finding. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609 Significance Determination Process (SDP). The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described at its Reactor Oversight Process website at http://www.nrc.gov/NRR/OVERSIGHT/index.html. Findings for which the SDP does not apply are indicated by No Color or by the severity level of the applicable violation. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described at its Reactor Oversight Process website at http://www.nrc.gov/NRR/OVERSIGHT/index.html.

A. Inspector Identified Findings Cornerstone: Occupational Radiation Safety and Public Radiation Safety Green. The inspector reviewed incidents related to access control deficiencies and radiation worker practices. During an on-the-job training tour of vital areas, workers failed to follow the requirements of the radiation work permit resulting in a small unintended dose. The failure of the workers to follow licensee procedures constitutes a Non-Cited Violation of Technical Specification 6.5.1. The finding was of very low safety significance as the event did not involve an overexposure or a substantial potential for an overexposure and did not compromise the licensees ability to assess personnel dose (Section 2OS1).

B. Licensee Identified Violations None.

Report Details Summary of Plant Status The plant operated at or near full power throughout the entire inspection period.

1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R04 Equipment Alignment (71111.04)

a. Inspection Scope The inspectors performed a partial walkdown of the following equipment trains to verify operability and proper equipment lineup. The systems were selected based upon risk significance, plant configuration, system work or testing, or inoperable or degraded conditions.

The inspectors verified the position of critical redundant equipment and looked for any discrepancies between the existing equipment lineup and the required lineup.

Due to the systems risk significance, the inspectors selected the control rod drive system for a complete walkdown. The inspectors walked down the system to verify mechanical and electrical equipment lineups, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation.

b. Findings No findings of significance were identified.

1R05 Fire Protection (71111.05)

a. Inspection Scope The inspectors walked down the following risk significant areas looking for any fire protection issues. The inspectors selected areas containing systems, structures, or components that the licensee identified as important to reactor safety.

  • Fire Zone 12A, Lower 4 kV Bus Area
  • Fire Zone 14A, Upper 4 kV Bus Area
  • Fire Zone 14B, Isophase Bus Area The inspectors reviewed the control of transient combustibles and ignition sources, fire detection equipment, manual suppression capabilities, passive suppression capabilities, automatic suppression capabilities, and barriers to fire propagation.

b. Findings No findings of significance were identified.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope The inspectors reviewed the licensee's flooding mitigation plans and equipment to determine consistency with design requirements and the risk analysis assumptions related to seasonal external flooding. Walkdowns and reviews performed considered design measures, seals, drain systems, contingency equipment condition and availability of temporary equipment and barriers, performance and surveillance tests, procedural adequacy, and compensatory measures.

b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification (71111.11)

a. Inspection Scope The inspectors reviewed the pass/fail results of individual written tests, operating tests, and simulator operating tests (required to be given per 10 CFR 55.59(a)(2))

administered by the licensee during calendar year 2002.

b. Findings No findings of significance were identified.

1R12 Maintenance Rule Implementation (71111.12)

a. Inspection Scope The inspectors reviewed the licensee's implementation of the Maintenance Rule (10 CFR 50.65) to ensure rule requirements were met for the selected systems.

The following systems were selected based on being designated as risk significant under the Maintenance Rule, or being in the increased monitoring (Maintenance Rule category a(1)) group:

  • Reactor Vessel Pressure Control System
  • Reactor Building Closed Cooling Water The inspectors verified the licensee's categorization of specific issues, including evaluation of the performance criteria. The inspectors reviewed the licensee's implementation of the maintenance rule requirements, including a review of scoping, goal-setting, and performance monitoring; short-term and long-term corrective actions; functional failure determinations associated with the condition reports reviewed; and current equipment performance status.

b. Findings No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope The inspectors reviewed and observed emergent work, preventive maintenance, or planning for risk significant maintenance activities. The inspectors observed maintenance or planning for the following activities or risk significant systems undergoing scheduled or emergent maintenance.

  • Weekly Scheduling and Planning Meetings
  • Daily Planning and Emergent Work Review
  • Inspection of EDG Floor Drain Line Backwater Check Valves The inspectors also reviewed the licensee's evaluation of plant risk, risk management, scheduling, and configuration control for these activities in coordination with other scheduled risk significant work. The inspectors verified that the licensee's control of activities considered assessment of baseline and cumulative risk, management of plant configuration, control of maintenance, and external impacts on risk. In-plant activities were reviewed to ensure that the risk assessment of maintenance or emergent work was complete and adequate, and that the assessment included an evaluation of external factors. Additionally, the inspectors verified that the licensee entered the appropriate risk category for the evolutions.

b. Findings No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope The inspectors reviewed the technical adequacy of the following operability evaluations to determine the impact on Technical Specifications (TS), the significance of the evaluations, and to ensure that adequate justifications were documented.

  • Isokinetic Probe Used for Building Differential Pressure Measurement Reads Inaccurate
  • Support SR-360 on Torus Ring Header is Binding Operability evaluations were selected based upon the relationship of the safety-related system, structure, or component to risk.

b. Findings No findings of significance were identified.

1R16 Operator Workarounds (OWA) (71111.16)

a. Inspection Scope The inspectors reviewed OWA No. 02-07, "Unable to Operate HWC [Hydrogen Water Chemistry] at Rated Conditions with Both Recombiner Trains in Service." The inspectors reviewed each workaround's potential to impact the operators' ability to respond to an offgas system problem, and general potential as a transient initiator.

Additionally, the inspectors reviewed various selected operations logs and records to verify that no undocumented OWAs were present.

b. Findings No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope The inspectors selected the following post-maintenance activities for review. Activities were selected based upon the structure, system, or component's ability to impact risk.

  • Leaking Scram Outlet Valve for Hydraulic Control Unit 18-31
  • Transformer 1AR Abnormal Voltage Indications
  • Reactor Manual Control Relay Card Replacement
  • Repair of Alternate Nitrogen Supply Check Valve AI-700 The inspectors verified by witnessing the test or reviewing the test data that post-maintenance testing activities were adequate for the above maintenance activities.

The inspectors reviews included, but were not limited to, integration of testing activities, applicability of acceptance criteria, test equipment calibration and control, procedural use and compliance, control of temporary modifications or jumpers required for test performance, documentation of test data, TS applicability, system restoration, and evaluation of test data. Also, the inspectors verified that maintenance and post-maintenance testing activities adequately ensured that the equipment met the licensing basis, TS, and USAR design requirements.

b. Findings No findings of significance were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope The inspectors selected the following surveillance test activities for review. Activities were selected based upon risk significance and the potential risk impact from an unidentified deficiency or performance degradation that a system, structure, or component could impose on the unit if the condition were left unresolved.

  • No. 11 EDG Monthly Surveillance
  • Shutdown Cooling High Pressure Isolation Interlock The inspectors observed the performance of surveillance testing activities, including reviews for preconditioning, integration of testing activities, applicability of acceptance criteria, test equipment calibration and control, procedural use, control of temporary modifications or jumpers required for test performance, documentation of test data, TS applicability, impact of testing relative to performance indicator reporting, and evaluation of test data.

b. Findings No findings of significance were identified.

1R23 Temporary Plant Modifications (71111.23)

a. Inspection Scope The inspectors reviewed the following temporary modifications.

  • Jumper/Bypass No. 02-07, Bypass of Main Turbine Generator High Vibration Trips
  • Jumper/Bypass No. 02-09, Temporary Fall Protection for Work on 14 Residual Heat Removal (RHR) Pump The inspectors reviewed the safety screening, design documents, USAR, and applicable TS to determine that the temporary modifications were consistent with modification documents, drawings, and procedures. The inspectors also reviewed the post-installation test results to confirm that tests were satisfactory and the actual impact of the temporary modifications on the permanent systems and interfacing systems were adequately verified.

b. Findings No findings of significance were identified.

2. RADIATION SAFETY Cornerstone: Occupational Radiation Safety 2OS1 Access Control to Radiologically Significant Areas (71121.01)

.1 Plant Walkdowns and RWP Reviews a. Inspection Scope The inspector reviewed the radiological conditions of work areas within radiation areas and high radiation areas (HRA) in the reactor, radwaste, and turbine buildings.

The inspector performed walkdowns and reviewed licensee controls to determine if the controls (i.e., surveys, postings, and barricades) were adequate to meet 10 CFR Part 20 and Technical Specification (TS) requirements. Additionally, the inspector selectively reviewed year 2001 and year to date 2002 condition reports (CR), including CR20022533, that described access control deficiencies and radiation worker practices, to verify that the licensee had effectively implemented the corrective action program.

b. Findings Inspector identified one finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV).

On March 14, 2002, two of three security personnel, conducting an on-the-job training tour of vital areas, climbed on the top of a security storage cabinet and accessed the HRA above the 8 foot high radiation shield wall on turbine building elevation 951 while attempting to visually locate specific building structures. The personnel were granted access to the radiologically controlled area (RCA) under radiation work permit (RWP)

Number 1, Revision 23, which authorizes general entry into the radiologically controlled area (RCA) to perform tasks which are passive in nature. The RWP specifically required personnel to obtain approval from the Radiation Protection Coordinator prior to accessing areas above 8 feet on the turbine floor when the plant is operating.

Additionally, signs located on the radiation shield adjacent to the storage cabinet direct personnel that they are not to access areas above 8 feet in the area. One of the individuals electronic dosimeter (ED) activated in the 124 millirem/hour exposure field.

The employees immediately left the area, exited the RCA and upon logging out and returning the EDs to storage were directed by the ED computer system to notify radiation protection personnel of exposure to an excessive dose rate. One individual received 1 millirem, another received 2 millirem total exposure and the third individual did not receive a measured dose.

The licensee immediately restricted access to the RCA by these individuals and counseled the individuals regarding the station procedures and RWP requirements.

Further, the licensee implemented a radiation protection radiological controlled area orientation checklist and initial entry review for all personnel entering the RCA for the first time. The event was entered in the licensees corrective action system (CR20022533). The inspector reviewed the licensees assessment of ED functionality, personnel training, and immediate corrective actions to prevent recurrence.

The inspector evaluated this finding using NRC Inspection Manual Chapter IMC 0610*,

Appendix B, Thresholds for Documentation, and determined it to be more than minor in that the failure of personnel to follow established RWPs could be reasonably viewed as a precursor to a significant event. Specifically, the occurrence involved individual workers unplanned and unintended dose as a result of actions contrary to the licensees procedures and the RWP. During the screening process, the inspector determined that the finding was not an As-Low-As-Is-Reasonably-Achievable (ALARA) finding, did not involve an overexposure or a substantial potential for an overexposure and did not compromise the licensees ability to assess personnel dose. Therefore, the finding was of very low safety significance (Green).

TS 6.5.1 required the establishment of procedures as recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Regulatory Guide 1.33, Revision 2, Appendix A, recommends procedures for access control to radiation areas including a radiation work permit system. Procedure MNGP 4AWI-08.04.01, Revision 12, Section 4.6.5.B.1, required site personnel performing work in the RCA to perform the work in accordance with a valid RWP. RWP Number 1, Revision 23, authorized general entry into the radiologically controlled area (RCA) to perform tasks which were passive in nature and specifically required personnel to obtain approval from the Radiation Protection Coordinator prior to accessing areas above 8 feet on the turbine floor when the plant is operating. Contrary to the above, on March 14, 2002, two security personnel, conducting an on-the-job training tour of vital areas, climbed on the top of a security storage cabinet and accessed the HRA above the 8 foot high radiation shield wall on

turbine building elevation 951 while attempting to visually locate specific building structures. This violation is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy (NCV 50-263/02-03-01).

Cornerstone: Public Radiation Safety 2PS1 Radioactive Material Processing and Transportation (71122.02)

.1 Walkdown of Radioactive Waste Systems a. Inspection Scope The inspector reviewed the liquid and solid radioactive waste system description in the Updated Safety Analysis Report (USAR) and the most recent information regarding the types and amounts of radioactive waste generated and disposed. The inspector performed walkdowns of the liquid and solid radwaste processing systems to verify that the systems agreed with the descriptions in the USAR and the process control program, and to assess the material condition and operability of the systems. The inspector reviewed the current processes for transferring waste resins into transportation containers to determine if appropriate waste stream mixing and/or sampling procedures were utilized. During this inspection, the licensee was not conducting waste processing.

b. Findings No findings of significance were identified.

.2 Waste Characterization and Classification a. Inspection Scope The inspector reviewed the licensees radiochemical sample analysis results for each of the licensees waste streams, including dry active waste and resins. The inspector also reviewed the licensees use of scaling factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emitting radionuclides). The reviews were conducted to verify that the licensees program assured compliance with 10 CFR 61.55 and 10 CFR 61.56, as required by Appendix G of 10 CFR Part 20. The inspector also reviewed the methodologies for waste concentration averaging to determine if representative samples of the waste product were provided for the purposes of waste classification in accordance with 10 CFR 61.55. The inspector also reviewed the licensees waste characterization and classification program to ensure that the waste stream composition data accounted for changing operational parameters and thus remained valid between the annual sample analysis updates.

b. Findings No findings of significance were identified.

.3 Transportation Records a. Inspection Scope The inspector reviewed five non-exempted package shipment manifests completed in year 2001 to verify compliance with NRC and Department of Transportation requirements (i.e., 10 CFR Parts 20 and 71 and 49 CFR Parts 172 and 173). The licensee had one non-exempt package preparation underway during the inspection.

The inspector observed radiation workers in the process of shipment package loading, and interviewed the shipping staff regarding the procedures used for regulatory compliance.

b. Findings No findings of significance were identified.

.4 Identification and Resolution of Problems a. Inspection Scope The inspector reviewed quality assurance audits of the radioactive waste and transportation program, along with departmental self-assessments of the radioactive waste and transportation program to evaluate the effectiveness of the self-assessment process to identify, characterize, and prioritize problems. The inspector also reviewed corrective action documentation to verify that previous radioactive waste and radioactive materials transportation related issues were adequately addressed. The inspector selectively reviewed year 2001 and 2002 CRs that addressed radioactive waste and radioactive materials transportation program deficiencies, to verify that the licensee had effectively implemented the corrective action program.

b. Findings No findings of significance were identified.

3. SAFEGUARDS Cornerstone: Physical Protection 3PP1 Access Authorization (AA) Program (Behavior Observation Only) (71130.01)

a. Inspection Scope The inspectors interviewed five supervisors and five non-supervisors (both licensee and contractor employees) to determine their knowledge level and practice for implementing the licensees behavior observation program responsibilities. Selected procedures pertaining to the Behavior Observation Program and associated training activities were reviewed. Also licensee fitness-for-duty semi-annual test results were reviewed. In addition, the inspectors reviewed a sample of licensee self-assessments and security logged events. The inspectors also interviewed security managers to evaluate their knowledge and use of the licensees corrective action program.

b. Findings No findings of significance were identified.

3PP2 Access Control (Identification, Authorization and Search of Personnel, Packages, and Vehicles) (71130.02)

a. Inspection Scope The inspectors reviewed the licensees protected area access control equipment testing and maintenance procedures. The inspectors observed licensee testing of all access control equipment to determine if testing and maintenance practices were performance based. On two occasions, during peak ingress periods, the inspectors observed in-processing search of personnel, packages, and vehicles to determine if search practices were conducted in accordance with regulatory requirements. Interviews were conducted and records were reviewed to verify that security staffing levels were consistently and appropriately implemented. Also the inspectors reviewed the licensee's process for limiting access to only authorized personnel to the protected area and vital equipment. The inspectors reviewed the licensee's program to control security keys and security-related computer data.

The inspectors reviewed a sample of licensee self-assessments, maintenance request records, and security logged events for identification and resolution of problems. In addition, the inspectors interviewed security managers to evaluate their knowledge and use of the licensee's corrective action system.

b. Findings No findings of significance were identified.

3PP4 Security Plan Changes (71130.04)

a. Inspection Scope The inspector reviewed Revision 17 (dated May 31, 2001) and Revision 18 (dated September 12, 2001) to the Security Training and Qualification Plan. Additionally, the inspector reviewed Revision 51 (dated May 31, 2001) and Revision 52 (dated September 7, 2001) to the Monticello Nuclear Plant Physical Security Plan. The review was conducted to verify that the changes did not decrease the effectiveness of the security plans. The referenced revisions were submitted in accordance with 10 CFR 50.54(p).

b. Findings No findings of significance were identified.

4. OTHER ACTIVITIES 4OA1 Performance Indicator Verification (71151)

Cornerstone: Physical Protection, Initiating Events

.1 Physical Protection Performance Indicators a. Inspection Scope The inspector verified the data for the Physical Protection Performance Indicators (PI)

pertaining to Fitness-For-Duty Personnel Reliability, Personnel Screening Program, and Protected Area Security Equipment. Specifically, a sample of plant reports related to security events, security shift activity logs, fitness-for-duty reports, and other applicable security records were reviewed for the period between January 1 and December 31, 2001.

b. Findings No findings of significance were identified.

.2 Unplanned Transients per 7000 Critical Hours a. Inspection Scope The inspectors verified the accuracy and completeness of the Unplanned Transients per 7000 Critical Hours performance indicator data submitted by the licensee from January 1, 2001, through December 31, 2001. The inspectors reviewed data reported to the NRC since the last verification. The review was accomplished, in part, through evaluation of the TS requirements, plant records, procedural reviews, and reactor coolant sample data.

b. Findings No findings of significance were identified.

.3 (Closed) Unresolved Item 50/263/01-07-05: Unplanned Transient per 7000 Critical Hours Performance Indicator.

a. Inspection Scope Unresolved Item 50/263/01-07-05 identified a potential discrepancy with reporting data associated with the Unplanned Transient per 7000 Critical Hours Performance Indicator. The issue related to the transients terminated by a Notice of Enforcement Discretion (NOED). NRR has indicated in resolutions to frequently asked questions that this issue does not count against the performance indicator. This data was incorporated during the above review (Section 4OA1.2) of the performance indicator thereby closing URI 50/263/01-07-05.

b. Findings No findings of significance were identified.

4OA6 Meetings Exit Meetings The results of the Safeguards Inspection were presented to Mr. B. Sawatzke (Acting Plant Manager) and other members of the licensee management at the conclusion of the inspection on March 8, 2002. The results of Licensed Operator Requalification Testing for Calendar Year 2002 and Applicability of NRC Inspection Manual Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process (SDP)" were presented to Mr. G. Lashinski on March 19, 2002.

The results of the Occupational Radiation Safety Program inspection were presented to Mr. and other members of the licensee management at the conclusion of the inspection on March 22, 2002. The inspectors presented the routine resident inspection results to Mr. and other members of licensee management on March 26, 2002. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. Proprietary information was controlled properly.

KEY POINTS OF CONTACT Licensee G. Bregg, Manager, Quality Services D. Fadel, Director of Engineering J. Forbes, Site Vice-President R. Frederickson, Superintendent Material Inspection and Repair J. Grubb, General Superintendent, Operations K. Jepson, General Superintendent, Chemistry and Radiation Services D. Neve, Acting Licensing Project Manager J. Purkis, Plant Manager B. Sawatzke, General Superintendent, Maintenance C. Schibonski, General Superintendent, Safety Assessment E. Sopkin, General Superintendent, Engineering C. Johnson, Nuclear Security Consultant B. Linde, Security Manager T. Gallagher, Nuclear Security Consultant G. Lashinski, Operations Training Supervisor NRC B. Burgess, Chief, Reactor Projects Branch 2 ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-263/02-03-01 NCV Radiation Worker Violated Radiation Work Permit Requirements (Section 20S1)

Closed 50-263/01-07-05 URI Unplanned Transients per 7000 Critical Hours Performance Indicator (Section 4OA1.3)

50-263/02-03-01 NCV Radiation Worker Violated Radiation Work Permit Requirements (Section 20S1)

Discussed None.

LIST OF ACRONYMS USED AA Access Authorization ALARA As-Low-As-Is-Reasonably-Achievable ASME American Society of Mechanical Engineers AWI Administrative Work Instruction CAM Continuous Air Monitor CFR Code of Federal Requirements CR Condition Report CRD Control Rod Drive DC Direct Current d/p Differential Pressure DRP Division of Reactor Projects DRS Division of Reactor Safety EDG Emergency Diesel Generator ESW Emergency Service Water EWI Engineering Work Instruction FFD Fitness For Duty HELB High Energy Line Break HRA High Radiation Area HWC Hydrogen Water Chemistry IP Inspection Procedure IPE Individual Plant Examination IPEEE Individual Plant Examination of External Events IR Inspection Report kV Kilovolt NCR Non-Conformance Report NCV Non-Cited Violation NMC Nuclear Management Company NRC Nuclear Regulatory Commission NUMARC Nuclear Management and Resources Council OWA Operator Workaround OWI Operations Work Instruction PI Performance Indicator PIDS Perimeter Intrusion Detection System RFO Refueling Outage RHR Residual Heat Removal RMC Reactor Manual Control RPS Reactor Protection System RWP Radiation Work Permit SAP Security Administrative Procedure SCR Screening SDP Significance Determination Process SIP Security Implementing Procedure SWI Scheduling Work Instruction TS Technical Specification USAR Updated Safety Analysis Report WO Work Order

LIST OF DOCUMENTS REVIEWED 1R04 Equipment Alignment Operations Manual:

B.1.2 - Control Rod Drives B.1.3 - Control Rod Drive Hydraulic System B.3.1 - Core Spray System B.9.8 - Emergency Diesel Generators B.8.1.2 - EDG Emergency Service Water Prints and Drawings:

M-118 - Control Rod Hydraulic System Revision AW M-119 - Control Rod Hydraulic System Revision S M-121 - Core Spray System Revision AH NL-95926-1 - 20 Inch Suction Header Supports SS-359 and Revision B SR-360 NL-95926-2 - 20 Inch Suction Header Supports SS-359 and Revision A SR-360 NL-95926-3 - 20 Inch Suction Header Supports SS-359 and Revision B SR-360 NL-95926-4 - 20 Inch Suction Header Supports SS-359 and Revision B SR-360 NL-95926-5 - 20 Inch Suction Header Supports SS-359 and Revision A SR-360 M-133 - Diesel Oil System Revision AD M-811 - Service Water System Intake Structure Revision CE M-112 - RHR and Emergency Service Water Systems Revision BF USAR: Revision 18 Section 3.5 - Reactivity Control Mechanical Characteristics Section 8.4.1 - Safeguards EDG Systems Section 10.4.4 - Emergency Service Water System Design Basis Document:

B.1.2/3 - Control Rod Drive Mechanical and Hydraulic Revision B System Technical Specifications and Bases:

3/4.3 - Control Rod Drive System 3/4.9.B.3 - Standby Diesel Generators Procedures and Forms:

0081 - Control Rod Drive Scram Insertion Time Test, Revision 35 Performed 1/22/02 0081 - Control Rod Drive Scram Insertion Time Test, Revision 35 Performed 1/27/02 2145-09 - Control Rod Drive Prestart Valve Checklist Revision 27 0000-J - Operations Daily Log, Part - J, Outplant

1R05 Fire Protection NX-16991 Monticello Updated Fire Hazards Analysis Technical Manual Monticello Fire Strategies:

A.3-12-A - Lower 4 kV Bus Area Revision 6 A.3-14-A - Upper 4 kV Bus Area Revision 6 A.3-12-B - Hydrogen Seal Area Revision 4*

A.3-14-B - Isophase Bus Area Revision 2*

Procedures and Forms:

4AWI-08.01.01 - Fire Prevention Practices Revision 17 4AWI-08.01.02 - Combustion Source Use Permit Revision 6 4AWI-08.01.04 - Fire Protection Combustible Loading Revision 0 0271 - Fire Hose Station and Yard Hydrant Hose Revision 27 House Equipment Inspection 0274 - Fire Hose Hydrostatic Test Interior Hose Revision 19 Stations 0275-1 - Fire Barrier Penetration Seal Visual Inspection Revision 9 0275-2 - Fire Barrier Wall, Damper, and Floor Inspection Revision 16 QUAD-5-80-009 Specifications for Installation of Electrical and Revision 7 Mechanical Penetration Seals at the Monticello Nuclear Generating Plant by Quadrex Corporation Operations Manual:

A.3 - Fire Fighting Procedures B.08.05 - Fire Protection 1R06 Flood Protection Measures Design Basis Documents:

T.5 - External Flooding Revision 3 T.8 - Internal Flooding Revision 2 NSPLMI-95001 Individual Plant Examination of External Events Revision 1 (IPEEE)

NSPNAD-92003 Individual Plant Examination (IPE) Revision 0 USAR: Revision 18 Section 12.2.1.7.1 - External Flooding Section 12.2.1.7.2 - Internal Flooding Section 2.4.1 - Surface Water Section 1.3.1.4 - Hydrology Operations Manual:

A.6 - Acts of Nature Revision 13*

B.7.1 - Liquid Radwaste

Procedures:

1478 - Annual Flood Surveillance Revision 0 4AWI-04.02.01 - Housekeeping Revision 6 1252 - RHR Pump Room Sump Pump Surveillance Revision 6 1306 - Portable Diesel Oil Pump Operability Test Revision 8 1R12 Maintenance Rule Implementation NUMARC:

- Nuclear Energy Institute Industry Guideline for 93-01 Monitoring the Effectiveness of Maintenance at Revision 2 Nuclear Power Plants

- Assessment of Risk Resulting from the 93-01, Section 11 Performance of Maintenance Activities February 22, 2000 Regulatory Guides:

1.160 - Monitoring the Effectiveness of Maintenance at Revision 2 Nuclear Power Plants 1.182 - Assessing and Managing Risk Before May 2000 Maintenance Activities at Nuclear Power Plants Engineering Work Instruction:

05.02.01 - Monticello Maintenance Rule Program Revision 5 Document Operations Manual:

B.2.5 - Reactor Building Closed Cooling System B.5.6 - Plant Protection System B.5.9 - Main Steam Pressure Control Maintenance Rule Program System Basis Document:

B.2.5 - Reactor Building Closed Cooling System Revision 1 B.5.6 - Plant Protection System - Reactor Protection Revision 1 System B.5.9 - Main Steam Pressure Control System Revision 0 USAR: Revision 18 Section 7.6.1 - Reactor Protection System Section 7.7 - Turbine Generator System Instrumentation and Control Section 10.4.3 - Reactor Building Closed Cooling Water System CR 20020480 Received B RPS Half Scram While Placing Reactor Mode Switch to Refuel CR 20020457 Reactor Scram 113 While at 100 Percent Power CR 20020516 Calculated As-Found Value Outside Stated Band for MPR During Test 1045

CR 20020599 Test 1045 Halted Due to Turbine Control System Oscillations CR 20020608 Turbine Control System Oscillation During Performance of Test 1045 on 1/25/02 WO 0105762 MO-3501 Failed Open 1R13 Maintenance Risk Assessments and Emergent Work Control Procedures:

4AWI-04.01.01 - General Plant Operating Activities Revision 28 SWI-14.01 - Risk Management of On-line Maintenance Revision 0 4001-11-01 - Swing Check Valve Inspection Revision 6 CR 20022543 During Disassembly and Inspection of 11 EDG Room Backwater Check Valve, the Bottom 30 Percent Was Covered in Fine Silt CR 20022403 The EDG Room Backwater Check Valves Have Not been Inspected and Cleaned Since 1995.

Corrective Actions For Prior Issue Not Completed WO 0201715 Inspect EDG Room Backwater Check Valves NW-7, NW-8, and NW-9 Drawings and Prints:

A-10159-K - Josam Manufacturing Company - Series 1100 and 1100-S Backwater Sewer Line Valves NF-36753 - Plumbing and Drainage - EDG Building Revision D 02-10 Jumper/Bypass - Temporary Floor Drain Covers March 13, 2002 in No. 12 EDG Room SCR 02-0153 10 CFR 50.59 Screening - Inspect EDG Room Revision 0 Backwater Check Valves 1R15 Operability Evaluations CR 20021384 Online Maintenance Performed On MCC-311 and MCC-312 May Require MO-2035 Be Declared Inoperable NF-36298-2 DC Electrical Load Distribution One Line Revision A Diagram WO 0201683 Investigate Potential Problem With Isokinetic Probe

CR 20012892 Investigate Potential Problem With Isokinetic Sensing Probe for Reference Side of d/p Instruments CR 19991350 Low Reactor Building Differential Pressure Indication On Panel C-24B. DPI-4424 @ -0.15 Inch Water Column While DPI-4425 @ -1.07 Inch Water Column CR 19991362 Add Instructions to Operations Manual B.4.2 or B.8.7 for How to Purge Moisture From the Reactor Building d/p instrument Reference Tubing CR 20021972 Support SR-360 on Torus Ring Header is Binding NCR N94-366 SR-360 Configuration Concern Prints and Drawings:

NL-95926-1 - 20 Inch Suction Header Supports SS-359 and Revision B SR-360 NL-95926-2 - 20 Inch Suction Header Supports SS-359 and Revision A SR-360 NL-95926-3 - 20 Inch Suction Header Supports SS-359 and Revision B SR-360 NL-95926-4 - 20 Inch Suction Header Supports SS-359 and Revision B SR-360 NL-95926-5 - 20 Inch Suction Header Supports SS-359 and Revision A SR-360 1R16 Operator Workarounds OWA 02-07 Unable to Operate HWC at Rated Conditions with Both Recombiner Trains in Service CR 20021116 Operation with One Recombiner Train in Service and the Other in Standby to Allow Full HWC is and Operator Workaround OWI-01.07 Operations Department Self Assessment Revision 16 1R19 Post-Maintenance Testing Thermography Records (multiple) 2/20/2002 Operations Manual B.1.2 - Control Rod Drive B.1.3 - Control Rod Drive Hydraulic System

Prints and Drawings:

M-118 - Control Rod Hydraulic System Revision AW M-119 - Control Rod Hydraulic System Revision S Procedures and Forms:

0045 - Rod Block Monitor Functional Test and Revision 28 Calibration Test 0074 - Control Rod Drive Exercise - Weekly Control Revision 29 Rod Drive Exercise 0081 - Control Rod Drive Scram Insertion Time Test Revision 35 3069 - Post Maintenance Testing Activities Control Revisions 9 and 10 Cover Sheet 4001-11-03 - Lift Check Valve Inspection Revision 5 0137-30 - Alternate Nitrogen Supply Pressure and Local Revision 8 Leak Rate Test 0255-17-IA-5 - Alternate Nitrogen System Train A Valve Test Revision 15 3/4.9 Technical Specification and Basis - Auxiliary Electrical Systems 3186-G-01-03 Quality Control Inspection Record for Revision 5 WO 0200350 4858-04-OCD 1AR Transformer Maintenance Isolation Revision 4 Isolation 02-00350 Scram Valve Leaks By Seat. CRD Temperature Version 1 Elevated.

NX-7831-341 Reactor Manual Control Subsystem of Cont Rod Revision 25 Drive System - Technical Manual NX-7866-85 Rod Position Information System - Technical Revision 1 Manual RFO 154265 Repair Monticello Plant 1AR Voltage Regulator Revision 2 WO 0201541 Investigate Abnormal 1AR Voltage Indications WO 0005221 RMC Pushbutton Select Relay Card Replacement WO 0200350 Scram Valve Leaks By Seat. CRD Temperature Elevated.

WO 0201892 AI-700 Has Excessive Leakage CR 20023052 AI-700 Failed to Properly Close During the Performance of 0255-17-IA-5

1R22 Surveillance Testing Operations Manual:

B.9.8 - Emergency Diesel Generators B.8.1.2 - EDG Emergency Service Water B.3.4 - Residual Heat Removal System Prints and Drawings:

M-133 - Diesel Oil System Revision AD M-811 - Service Water System Intake Structure Revision CE M-112 - RHR and Emergency Service Water Systems Revision BF M-120 - Residual Heat Removal System Revision BH M-121 - Residual Heat Removal System Revision BL USAR: Revision 18 Section 8.4.1 - Safeguards EDG Systems Section 10.4.4 - Emergency Service Water System Section 10.2.4 - Reactor Shutdown Cooling and Reactor Vessel Head Spray Technical Specifications and Bases:

3/4.9.B.3 - Standby Diesel Generators 3/4.2 - Protective Instrumentation 3/4.5 - Core and Containment Cooling Systems Procedures and Forms:

0187-01 - 11 EDG and 11 ESW System Tests Revision 38 0255-04-IA-1 - RHR System Valve Tests Revision 53 0391 - RHR Shutdown Cooling Supply Revision 8 1R23 Temporary Plant Modifications Jumpers/Bypasses:

02-07 - Bypass Turbine Generator High Vibration Trip February 27, 2002 02-09 - Temporary Fall Protection for 14 RHR Pump March 11, 2002 Motor Work 01-29 - Temporary Fall Protection for 14 RHR Pump June 15, 2001 Motor Work 10 CFR 50.59 Screenings:

SCR 02-0129 - Bypass of Turbine Generator High Vibration Revision 0 SCR 01-0121 Trip June 15, 2001

- Temporary Beam For 14 RHR Motor Fall Protection NRC IN 92-47 Intentional Bypassing of Automatic Actuation of June 29,1992 Plant Protective Features 4AWI-04.04.03 Bypass Control Revision 17

USAR: Revision 18 Section 11.2 - Turbine Generator System Section 12.2 - Plant Principle Structures and Foundations Operations Manual:

B.6.1 - Turbine Alarm Response Procedure:

7-B-34 - Turbine Supervisory Instrument No Voltage Revision 1 2OS1 Access Control to Radiologically Significant Areas (71121.01)

MNGP 5841 Electronic Dosimeter Alarm Record Revision 0 MNGP 5842 Radiation Protection Radiological Revision 0 Controlled Area Orientation Checklist RWP Number 1 Radiation Work Permit-General Entry Revision 23 RWP Number 118 985 Reactor - Radwaste Pump and Tank Revision 0 Room CR20022533 Two Individuals Entered the Overhead March 13, 2002 Area of TB 951 without Contacting RPC as Required by RWP #1 2PS1 Radioactive Material Processing and Transportation (71122.02)

MNGP R.11.08 Selection and Entry of 10 CFR Part 61 Revision 4 Correlation Factors MNGP 4AWI 08.03.03 Software Quality Assurance Requirements Revision 3 MNGP 4AWI 08.05.01 Radwaste Management Program Revision 6 MNGP 4AWI 08.05.02 Radioactive Material Shipping Revision 5 MNGP 8084 Procedure for Shipping Excepted Revision 11 Packages of Radioactive Material MNGP 8110 Master Radioactive Material Shipping Revision 30 Procedure MNGP 8178 Procedure for Shipping Radioactive Waste Revision 15 Using the 14-210H, 14-215H or 14-215 MNGP 8205 High Integrity Container Handling Revision 18 Procedure

CR20012330 Hazwaste Shipment 01-001 Was Allowed May 15, 2001 to Leave Site on a Vehicle That Did Not Meet Safety Requirements CR20015865 ALARA Dose Rates Higher than Expected December 14, for Work on Radwaste Valves 2001 CR20022775 Radwaste Inventory Discrepancy with March 20, 2002 Actual Drums in Barrel Storage Aisle Audit No. AG 2001-S-2 Remp/Radioactive Waste and Sealed July 20, 2001 Sources Radioactive Waste Characterization and Classification Team Performance Assessment Report - First Quarter 2001 Radioactive Waste Shipping Packages 01-27, 01-30, 01-41, 01-51, 02-07 3PP1 Access Authorization Program CR 20017536 Explosive Vapor Detector Test November 26, 2001 CR 20017979 FFD Testing December 10, 2001 FFD Performance Data June 30, 2001 FFD Performance Data December 31, 2001 N1ACD 2.12 FFD Program Nuclear Generation FFD Handbook 3PP2 Access Control 0305 Metal Detector Performance Test Procedure November 12, 2001 0307 Access Control System Functional Test December 5, 2001 0483 Explosive Vapor Detector Performance Test November 12, 2001 Annual Security Key Audit Letter July 19, 2001 CR 20012817 Repetitive Failures For Explosive Detector B May 24, 2001 4AWI08.06.02 Plant Security Key Control May 19, 1999 4AWI08.06.03 Unescorted Access Authorization and September 30, 1999 Processing

Master Listing of Security Condition Reports April 1 through December 27, 2001 Master Listing of Security Work Orders April 1, 2001 through February 26, 2002 Security Event Report Master Listing April 1, 2001 through February 28, 2002 Self Assessment Audit M 2401 Access June 5- July 27, Authorization 2001 Self Assessment Audit M3101 Key Control August 1-19, 2001 SIP 01.02 Admittance and Exit of Personnel February 12, 2002 SIP 01.03 Admittance and Control of Vehicles February 12, 2002 SIP 01.05 Escort Responsibilities June 26, 2000 SIP 02.02 System Descriptions February 12, 2001 SIP 04.01 Testing and Inspection of Systems and February 12, 2002 Equipment WO 0109105 Set up and Adjust X-Ray B 3PP4 Security Plan Changes Revision 17 to Security Training and May 31, 2001 Qualification Plan Revision 18 to Security Training and September 12, 2001 Qualification Plan Revision 51 to Security Plan May 31, 2001 Revision 52 to Security Plan September 7, 2001 4OA1 Performance Indicator Verification CR 20014522 Resource to Repair Security Equipment July 31, 2001 SAP 02.09 NRC Physical Protection Cornerstone August 2, 2000 Performance Indicators Guard Force Utilization - PIDS Forms January through December 2001 Performance Indicator Physical Protection January 1 through Worksheets December 31, 2001

Security Shift Activity reports April, July, October and November 2001 3530-04 NRC Performance Indicator Initiating Events Revision 0 Worksheets ( 1st, 2nd, 3rd, 4th Quarters 2001)

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