IR 05000263/2004004
| ML043010064 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 10/25/2004 |
| From: | Burgess B NRC/RGN-III/DRP/RPB2 |
| To: | Thomas J. Palmisano Nuclear Management Co |
| References | |
| IR-04-004 | |
| Download: ML043010064 (41) | |
Text
ber 25, 2004
SUBJECT:
MONTICELLO NUCLEAR GENERATING PLANT NRC INTEGRATED INSPECTION REPORT 05000263/2004004
Dear Mr. Palmisano:
On September 30, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Monticello Nuclear Generating Plant. The enclosed integrated inspection report documents the inspection findings which were discussed on October 7, 2004, with Mr. Conway and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, there was one NRC-identified finding of very low safety significance which involved a violation of NRC requirements. However, because this violation was of very low safety significance and because the issue was entered into the licensees corrective action program, the NRC is treating this finding as a Non-Cited Violation in accordance with Section VI.A.1 of the NRCs Enforcement Policy.
If you contest the subject or severity of a Non-Cited Violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -
Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Monticello Nuclear Generating Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's 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
Enclosure:
Inspection Report 05000263/2004004 w/Attachment: Supplemental Information
REGION III==
Docket No: 50-263 License No: DPR-22 Report No: 05000263/2004004 Licensee: Nuclear Management Company, LLC Facility: Monticello Nuclear Generating Plant Location: 2807 West Highway 75 Monticello, MN 55362 Dates: July 1 through September 30, 2004 Inspectors: S. Burton, Senior Resident Inspector R. Orlikowski, Resident Inspector D. Karjala, Resident Inspector, Prairie Island M. Miller, Project Engineer M. Mitchell, Radiation Specialist Observers: None Approved by: B. Burgess, Chief Branch 2 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000263/2004004; 07/01/2004 - 09/30/2004; Monticello Nuclear Generating Plant.
Surveillance Testing.
This report covers a 3-month period of baseline resident inspection and announced baseline inspections of radiation protection. The inspections were conducted by Region III reactor inspectors, a regional radiation specialist inspector, and the resident inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Inspector-Identified and Self-Revealed Findings
Cornerstone: Initiating Events
- Green.
A finding of very low safety significance was identified by the inspectors for a violation of Technical Specifications when operators failed to follow administrative procedures which require that operators notify radiation protection and chemistry personnel prior to a system alignment change that could affect exposure rates. A worker received an electronic dose rate alarm when a transient high radiation area was created while restoring the reactor core isolation cooling system after performing surveillance testing. The primary cause of this finding was related to the cross-cutting area of Human Performance. No workers exceeded their dose limits during the event.
The licensee has instituted corrective actions including procedural revisions and personnel training.
The issue was more than minor because the operators failure to anticipate plant changes prior to operating equipment could reasonably be viewed as a precursor to a significant event such as an overexposure to plant personnel. The issue was of very low safety significance because the finding did not contribute to the likelihood of a primary or secondary system loss of coolant accident initiator; the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available; and the finding did not increase the likelihood of a fire or internal or external flooding. The issue was a Non-Cited Violation of Technical Specification 6.5.A, which requires that written procedures be implemented for control of radioactivity for limiting personnel exposure. (Section 1R22)
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
Monticello operated at full power for the entire assessment period except for brief down-power maneuvers to accomplish rod pattern adjustments and to conduct planned surveillance testing activities.
- On July 25, 2004, reactor power was reduced to approximately 75 percent while performing work on the condensate demineralizer system. Reactor full power was achieved on July 25,
REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial walkdowns of accessible portions of trains of risk-significant mitigating systems equipment. The inspectors reviewed equipment alignment to identify any discrepancies that could impact the function of the system and potentially increase risk. Identified equipment alignment problems were verified by the inspectors to be properly resolved. The inspectors selected redundant or backup systems for inspection during times when equipment was of increased importance due to unavailability of the redundant train or other related equipment. Inspection activities included, but were not limited to, a review of the licensees procedures, verification of equipment alignment, and an observation of material condition, including operating parameters of equipment in-service. As part of this inspection, the documents in 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following equipment trains to assess operability and proper equipment line-up for a total of three samples:
- 11 emergency diesel generator (EDG) with 12 EDG out-of-service for maintenance, during the week ending July 31, 2004;
- reactor core isolation cooling (RCIC) following maintenance, during the week ending August 14, 2004; and
- Division II residual heat removal (RHR) system with Division I RHR system out-of-service for maintenance, during the week ending September 11, 2004.
b. Findings
No findings of significance were identified.
.2 Complete System Walkdown
a. Inspection Scope
The inspectors performed a complete walkdown of equipment for one risk significant mitigating system. The inspectors walked down the system to review mechanical and electrical equipment line-ups, 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. A review of past and outstanding work orders was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that any system equipment alignment problems were being identified and appropriately resolved. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following system to assess operability and proper equipment line-up for a total of one sample:
- 11 EDG, for the week ending September 25, 2004.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
.1 Quarterly Fire Zone Walkdowns
a. Inspection Scope
The inspectors walked down risk significant fire areas to assess fire protection requirements. The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and had implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems or features. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events (IPEEE), the potential to impact equipment which could initiate or mitigate a plant transient, or the impact on the plants ability to respond to a security event. The inspection activities included, but were not limited to, the control of transient combustibles and ignition sources, fire detection equipment, manual suppression capabilities, passive suppression capabilities, automatic suppression capabilities, compensatory measures, and barriers to fire propagation. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following areas for review for a total of ten samples:
- Fire Zone 4-A, reactor building 985' elevation south, during the week ending July 17, 2004;
- Fire Zone 4-B, reactor building closed loop cooling water (RBCCW) heat exchanger area, during the week ending July 17, 2004;
- Fire Zone 4-D, standby gas treatment (SBGT) system area, during the week ending July 17, 2004;
- Fire Zone 7-B, Division I - 250 Vdc battery room, during the week ending July 31, 2004;
- Fire Zone 7-C, Division II - 125 Vdc battery room, during the week ending July 31, 2004;
- Fire Zone 14-A, upper 4 kV bus area, during the week ending July 31, 2004;
- Fire Zone 14-B, isophase bus area, during the week ending July 31, 2004;
- Fire Zone 15-A, 12 diesel generator room, during the week ending July 31, 2004;
- Fire Zone 15-B, 11 diesel generator room, and 11 and 12 diesel generator day tank rooms, during the week ending July 31, 2004; and
- Fire Zone 34, east electrical equipment room and 13 diesel generator room, during the week ending August 14, 2004.
b. Findings
No findings of significance were identified.
.2 Annual Fire Drill Review
a. Inspection Scope
The inspectors reviewed fire drill activities to evaluate the licensees ability to control combustibles and ignition sources, the use of fire fighting equipment, and their ability to mitigate the event. The inspection activities included, but were not limited to, the fire brigades use of fire fighting equipment, effectiveness in extinguishing the simulated fire, effectiveness of communications amongst fire brigade members and the control room, command and control of the fire commander, and observation of the post-drill critique.
As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors observed the following fire drill for a total of one sample:
- the fire brigades response to an announced fire drill in the turbine building hydrogen seal oil area, on August 1, 2004.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors performed an annual review of the licensees testing of heat exchangers.
The inspection focused on potential deficiencies that could mask the licensees ability to detect degraded performance, identification of any common cause issues that had the potential to increase risk, and ensuring that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspection activities included, but were not limited to, a review of the licensees observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing criteria. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following equipment for a total of one sample:
- 12 EDG, emergency service water heat exchanger test, for the weeks ending July 24 and August 7, 2004.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
a. Inspection Scope
The inspectors performed a quarterly review of licensed operator requalification training.
The inspection assessed the licensees effectiveness in evaluating the requalification program, ensuring that licensed individuals operate the facility safely and within the conditions of their license, and evaluated licensed operator mastery of high-risk operator actions. The inspection activities included, but were not limited to, a review of high risk activities, emergency plan performance, incorporation of lessons learned, clarity and formality of communications, task prioritization, timeliness of actions, alarm response actions, control board operations, procedural adequacy and implementation, supervisory oversight, group dynamics, interpretations of Technical Specifications (TS), simulator fidelity, and licensee critique of performance. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors observed the following requalification activity for a total of one sample:
- a requalification crew during an evaluated simulator scenario that included a reactor recirculation pump seal failure and a security threat with two bomb detonations. This resulted in two emergency plan classification opportunities, an opportunity to isolate a recirculation loop, insert a manual reactor scram, and emergency depressurize the reactor pressure vessel, during the week ending September 25, 2004.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed systems to assess maintenance effectiveness, including maintenance rule activities, work practices, and common cause issues. Inspection activities included, but were not limited to, the licensee's categorization of specific issues including evaluation of performance criteria, appropriate work practices, identification of common cause errors, extent of condition, and trending of key parameters. Additionally, the inspectors reviewed implementation of the Maintenance Rule (10 CFR 50.65)requirements, including a review of scoping, goal-setting, performance monitoring, short-term and long-term corrective actions, functional failure determinations associated with reviewed corrective action program documents, and current equipment performance status. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors performed the following maintenance effectiveness reviews for a total of three samples:
C a function-oriented review of the control room ventilation (CRV) emergency filtration system because it was designated as risk significant under the Maintenance Rule, during the weeks ending August 21 and August 28, 2004; C a function-oriented review of the RHR system because it was designated as risk significant under the Maintenance Rule, during the weeks ending September 18 through September 30, 2004; and C a function-oriented review of the EDG system because it was designated as risk significant under the Maintenance Rule, during the weeks ending September 25 through September 30, 2004.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed maintenance activities to review risk assessments (RAs) and emergent work control. The inspectors verified the performance and adequacy of RAs, management of resultant risk, entry into the appropriate licensee-established risk bands, and the effective planning and control of emergent work activities. The inspection activities included, but were not limited to, a verification that licensee RA procedures were followed and performed appropriately for routine and emergent maintenance, that RAs for the scope of work performed were accurate and complete, that necessary actions were taken to minimize the probability of initiating events, and that activities to ensure that the functionality of mitigating systems and barriers were performed.
Reviews also assessed the licensee's evaluation of plant risk, risk management, scheduling, configuration control, and coordination with other scheduled risk significant work for these activities. Additionally, the assessment included an evaluation of external factors, the licensee's control of work activities, and appropriate consideration of baseline and cumulative risk. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors observed maintenance or planning for the following activities or risk significant systems undergoing scheduled or emergent maintenance for a total of four samples:
- routine scheduled maintenance and risk management when the electrical distribution system was identified as unstable by the system operator, during the week ending July 3, 2004;
- emergent maintenance to correct a cooling water leak on the main generator exciter rectifier bank, during the weeks ending July 3 and August 7, 2004;
- emergent maintenance to correct a failed pressure switch on 12 EDG, during the weeks ending July 3 and August 7, 2004; and
- routine scheduled maintenance and risk management during RCIC system maintenance, during the week ending August 14, 2004.
b. Findings
No findings of significance were identified.
1R14 Personnel Performance During Non-Routine Plant Evolutions and Events
a. Inspection Scope
The inspectors reviewed personnel performance to planned evolutions to review operator performance and the potential for operator contribution to the evolution. The inspectors observed or reviewed records of operator performance during the evolution.
Reviews included, but were not limited to, operator logs, pre-job briefings, instrument recorder data, and procedures. As part of this inspection, the documents in 1 were utilized to evaluate the potential for an inspection finding.
The inspectors observed the following evolutions for a total of one sample:
- planned diving operations, during the week ending September 4, 2004.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed operability evaluations which affected mitigating systems or barrier integrity to ensure that operability was properly justified and that the component or system remained available. The inspection activities included, but were not limited to, a review of the technical adequacy of the operability evaluations to determine the impact on TS, the significance of the evaluations to ensure that adequate justifications were documented, and that risk was appropriately assessed. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors reviewed the following operability evaluations for a total of five samples:
- installation configuration of ASCO solenoid valves, during the weeks ending July 3 through August 7, 2004;
- oil leaking from Division II core spray (CS) test return line to torus valve actuator, during the week ending July 24, 2004;
- dead legs on service water discharge header may not be operable during a seismic event, during the week ending August 21, 2004;
- Regulatory Issue Summary (RIS) 2004-12 pertaining to the use of Code revisions found to apply to Monticello Nuclear Generating Plant (MNGP), during the weeks ending August 7 through August 28, 2004; and
- winter mode of heating ventilation line-up may challenge high energy line break (HELB) analysis of record, during the weeks ending August 7 through August 28, 2004.
b. Findings
The engineering group identified that the GOTHIC computer model used to analyze a turbine building HELB failed to include four flow paths within the turbine building. The condition had the potential to affect the operability of equipment associated with the 4160 volt alternating current (AC) system (Bus-15 and Bus-16), the 480 volt AC system (LC-103 and LC-104), and the 125 volt direct current (DC) system (D111 and D211).
Specifically, the engineering group identified three heating, ventilation, and air conditioning (HVAC) flow paths that existed between a single turbine building mild environment and three turbine building harsh environments. The turbine building mild environment included both 4160 volt essential switchgear rooms, the 941' elevation cableway, and the 931' elevation Division II essential motor control centers (MCCs).
The harsh environments included the 911' elevation condenser area, the 951' elevation turbine building operating floor, and the 911' elevation feedwater pump area. The unanalyzed flow paths may allow steam to travel to the mild environment areas during a HELB via the existing HVAC ductwork.
Upon discovery, the engineering department initiated CAP033462 to document the issue. The operations department took compensatory measures to block shut three dampers to isolate the flow paths between the turbine building harsh and mild environments. An operability evaluation was performed documenting the operability of the potentially affected equipment.
The inspectors reviewed the operability evaluation and noted that it took credit for a vent path in the ventilation system that would help mitigate the consequences of a HELB by relieving steam and pressure. However, when the inspectors raised questions about the design of a damper in the vent path, it was identified that the damper failed shut on a loss of service air isolating the vent path. The engineering department initiated CAP034281 to document the issue. Subsequently, compensatory measures were taken to ensure the vent path damper remained open. A period of approximately 55 days passed from the time compensatory measures were first taken to isolate the flow paths to when the licensee took compensatory measures to block open the damper to ensure the vent path remained open.
Since HELB modeling issues have been identified in both Licensee Event Report (LER)96-003 and also in 2001 corrective action program documents, and since the licensee failed to recognize the vulnerabilities associated with the required vent path during this evaluation, a performance deficiency existed. The inspectors determined that a feedwater HELB had the potential to affect redundant trains of multiple systems of safety-related equipment in both the barrier integrity and mitigating system cornerstones; therefore, the issue was more than minor. Affected equipment included the 4160 volt AC essential switchgear which supplies power to emergency core cooling systems (ECCS) such as RHR and CS pumps; the 480 volt AC essential switchgear which supplies power to RHR and CS valves as well as standby liquid control (SBLC)pumps; and the 125 volt DC essential switchgear which supplies control power to both EDGs.
This issue is considered an unresolved item (URI) because the effect of the HELB on the equipment in the mild environment is under evaluation. The inspectors review of this evaluation will include the conditions which existed prior to the discovery of the unanalyzed ventilation flow paths and the conditions which existed after compensatory measures were taken to block the three dampers shut but failed to ensure the vent path damper remained open. (URI 05000263/2004004-01)
1R17 Permanent Plant Modifications
a. Inspection Scope
The inspectors review of permanent plant modifications focused on verification that the design bases, licensing basis, and performance capability of related structures, systems or components were not degraded by the installation of the modification. The inspectors also verified that the modifications did not place the plant in an unsafe configuration.
The inspection activities included, but were not limited to, a review of the design adequacy of the modification by performing a review, or partial review, of the modifications impact on plant electrical requirements, material requirements and replacement components, response time, control signals, equipment protection, operation, failure modes, and other related process requirements. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following permanent plant modifications for review for a total of one sample:
- replacement of gaskets for V-EAC-14A and V-EAC-14B shaft seal kits, during the weeks ending July 24 and September 4, 2004.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors verified that the post-maintenance test procedures and activities were adequate to ensure system operability and functional capability. Activities were selected based upon the structure, system, or component's ability to impact risk. The inspection activities included, but were not limited to, witnessing or reviewing the 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, 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. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following post-maintenance activities for review for a total of three samples:
- control room fire detection panel, during the week ending July 24, 2004;
- 12 EDG low turbo oil pressure alarm relay replacement, during the week ending July 31, 2004; and
- testing of valve MO-2096, RCIC barometric condenser cooling water supply, during the weeks ending August 14 and August 28, 2004.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed surveillance testing activities to assess operational readiness and to ensure that risk-significant structures, systems, and components were capable of performing their intended safety function. 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 was left unresolved. The inspection activities included, but were not limited to, a review 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. As part of this inspection, the documents in Attachment 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following surveillance testing activities for review for a total of four samples:
- instrument air compressor weekly surveillance test, during the weeks ending July 17 and July 24, 2004;
- RCIC pump and valve test, during the week ending August 14, 2004;
- accident monitoring instrumentation calibration, during the week ending September 25, 2004; and
- SBLC pump and valve quarterly tests, during the week ending September 30, 2004.
b. Findings
Introduction The inspectors identified a Non-Cited Violation (NCV) of TS having very low safety significance (Green) for failing to follow administrative work instructions (AWI). These procedures require that operators notify radiation protection and chemistry personnel prior to a system alignment change that could affect exposure rates. The issue was more than minor because the operators failure to anticipate plant changes prior to operating equipment could reasonably be viewed as a precursor to a significant event such as an overexposure to plant personnel.
Description On August 10, 2004, operators restored the RCIC system after performing surveillance testing. During this evolution, a transient high radiation condition was created in the RCIC room when the steam isolation valves were opened. Localized dose rates exceeded 100 mrem/hr for a short time, as indicated by an electronic dosimeter reading.
The worker did not exceed any exposure limits. Administrative Procedure 4 AWI-04.01.06, Conduct of Operations, FP-OP-COO-01, Attachment 7, Equipment Manipulation and Status Control, Section 3.11, requires that operators notify radiation protection and chemistry personnel prior to a system alignment change that could affect exposure rates.
Analysis The inspectors determined that the failure to notify radiation protection and chemistry personnel prior to system alignment changes which could affect exposure rates was a performance deficiency warranting further evaluation. The inspectors reviewed this finding using the guidance contained in Appendix B, Issue Disposition Screening, of IMC 0612, Power Reactor Inspection Reports. The inspectors determined that the issue was more than minor because the operators failure to anticipate plant changes prior to operating equipment could reasonably be viewed as a precursor to a significant event such as an overexposure to plant personnel.
The inspectors reviewed this finding in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations."
Using the Phase 1 SDP worksheet for the initiating events cornerstone, the inspectors determined that the finding did not contribute to the likelihood of a primary or secondary system loss of coolant accident initiator; the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available; and the finding did not increase the likelihood of a fire or internal or external flooding. Therefore, the finding was considered to be of very low safety significance (Green).
Enforcement Technical Specification 6.5.A.1 requires written procedures be established, implemented and maintained for the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33 requires written procedures be implemented for control of radioactivity for limiting personnel exposure.
Administrative Procedure 4 AWI-04.01.06, Conduct of Operations, FP-OP-COO-01, 7, Equipment Manipulation and Status Control, Section 3.11, requires that operators notify radiation protection and chemistry personnel prior to a system alignment change that could affect exposure rates. Contrary to the above, on August 10, 2004, the operating crew failed to notify radiation protection and chemistry personnel prior to restoring the RCIC system to service. Because this violation was of very low safety significance and it was entered into the licensees corrective action program, this violation is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy (NCV 05000263/2004004-02). The licensee entered this issue into their corrective action program as CAP034431 and have recommended corrective actions, including procedural revisions and personnel training.
1R23 Temporary Plant Modifications
a. Inspection Scope
The inspectors reviewed temporary modifications to assess the impact of the modification on the safety function of the associated system. The inspection activities included, but were not limited to, a review of design documents, safety screening documents, USAR, and applicable TS to determine that the temporary modification was 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 modification on the permanent system and interfacing systems were adequately verified. As part of this inspection, the documents in 1 were utilized to evaluate the potential for an inspection finding.
The inspectors selected the following temporary modifications for review for a total of two samples:
- turbine building HELB vent path damper blocked open, during the weeks ending August 14 and August 21, 2004.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety
2OS1 Access Control to Radiologically Significant Areas (71121.01)
.1 Plant Walkdowns and Radiation Work Permit Reviews
a. Inspection Scope
The adequacy of the licensees internal dose assessment process for internal exposures greater than 50 millirem committed effective dose equivalent (CEDE) was assessed.
There were no exposures greater than 50 millirem CEDE. This review represented one sample.
b. Findings
No findings of significance were identified.
.2 Problem Identification and Resolution
a. Inspection Scope
The inspectors reviewed one corrective action report related to access controls and high radiation area radiological incidents when available (non-performance indicators (PIs))
identified by the licensee in high radiation areas <1R/hr). Staff members were interviewed and corrective action documents were reviewed to verify that follow-up activities were being conducted in an effective and timely manner commensurate with their importance to safety and risk based on the following:
- initial problem identification, characterization, and tracking;
- disposition of operability/reportability issues;
- evaluation of safety significance/risk and priority for resolution;
- identification of repetitive problems;
- identification of contributing causes;
- identification and implementation of effective corrective actions;
- resolution of NCVs tracked in the corrective action system; and
- implementation/consideration of risk significant operational experience feedback.
This review represented one sample.
b. Findings
No findings of significance were identified.
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)
.1 Inspection Planning
a. Inspection Scope
The inspectors reviewed the plant FSAR to identify applicable radiation monitors associated with transient high and very high radiation areas, including those used in remote emergency assessment. The inspectors identified the types of portable radiation detection instrumentation used for job coverage of high radiation area work, other temporary area radiation monitors currently used in the plant, continuous air monitors associated with jobs with the potential for workers to receive 50 mrem CEDE, whole body counters, and the types of radiation detection instruments utilized for personnel release from the radiologically controlled area. This review represented one sample.
The inspectors verified calibration, operability, and alarm setpoint (if applicable) of the following five instruments:
- Argos 4G Personnel Contamination Monitor;
- Telescan 330A;
- Eberline AMS-4;
- Area Radiation Monitors; and
- Radios 51 Electronic Dosimeters.
This review represented one sample.
The inspectors determined what actions were taken when, during calibration or source checks, an instrument was found significantly out of calibration (>50 percent),determined possible consequences of instrument use since last successful calibration or source check, and determined if the out of calibration result was entered into the corrective action program. There were no instances where the instrument was found significantly out of calibration. The inspectors also reviewed the licensees 10 CFR Part 61 source term reviews to determine if the calibration sources used are representative of the plant source term. This review represented one sample.
b. Findings
No findings of significance were identified.
.2 Problem Identification and Resolution
a. Inspection Scope
The inspectors reviewed the licensees self-assessments, audits, LERs, and special reports that involved personnel contamination monitor alarms due to personnel internal exposures to verify that identified problems were entered into the corrective action program for resolution. All event reports involving internal exposures >50 mrem CEDE were reviewed to determine if the affected personnel were properly monitored utilizing calibrated equipment and if the data was analyzed and internal exposures properly assessed in accordance with licensee procedures. This review represented one sample.
The inspectors reviewed corrective action program reports related to exposure significant radiological incidents that involved radiation monitoring instrument deficiencies since the last inspection in this area. Staff members were interviewed and corrective action documents were reviewed to verify that follow-up activities were being conducted in an effective and timely manner commensurate with their importance to safety and risk based on the following:
- initial problem identification, characterization, and tracking;
- disposition of operability/reportability issues;
- evaluation of safety significance/risk and priority for resolution;
- identification of repetitive problems;
- identification of contributing causes;
- identification and implementation of effective corrective actions;
- resolution of NCVs tracked in the corrective action system and
- implementation/consideration of risk significant operational experience feedback.
The inspectors determined if the licensees self-assessment activities were identifying and addressing repetitive deficiencies or significant individual deficiencies in problem identification and resolution. This review represented two samples.
b. Findings
No findings of significance were identified.
.3 Radiation Protection Technician Instrument Use
a. Inspection Scope
The inspectors verified the calibration expiration and source response check currency on radiation detection instruments staged for use and observed radiation protection technicians for appropriate instrument selection and self-verification of instrument operability prior to use. This review represented one sample.
b. Findings
No findings of significance were identified.
.4 Self-Contained Breathing Apparatus Maintenance and User Training
a. Inspection Scope
The inspectors reviewed the status and surveillance records of self-contained breathing apparatus (SCBA) staged and ready for use in the plant and inspected the licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions. The inspectors determined if control room operators and other emergency response and radiation protection personnel were trained and qualified in the use of SCBAs (including personal bottle change-out). The inspectors verified the status of three individuals on each control room shift crew, and three individuals from each designated department, currently assigned emergency duties (e.g., onsite search and rescue duties). This review represented one sample.
The inspectors reviewed the qualification documentation for at least 50 percent of the onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records over the past 5 years for three SCBA units currently designated as ready for service. The inspectors also ensured that the required, periodic air cylinder hydrostatic testing was documented and up-to-date, and that the Department of Transportation (DOT) required retest air cylinder markings were in place for these three units. The inspectors reviewed the onsite maintenance procedures governing vital component work including those for the low-pressure alarm and pressure-demand air regulator and licensee procedures and the SCBA manufacturers recommended practices to determine if there were inconsistencies between them. This review represented one sample.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
Cornerstone: Barrier Integrity
.1 Reactor Safety Strategic Area
a. Inspection Scope
The inspectors review of PIs used PI guidance and definitions contained in Nuclear Energy Institute (NEI) Document 99-02, Revision 2, Regulatory Assessment Performance Indicator Guideline, to assess the accuracy of the PI data. The inspectors review included, but was not limited to, conditions and data from logs, LERs, corrective action program documents, and calculations for each PI specified. As part of the inspection, the documents listed in Appendix 1 were utilized to evaluate the accuracy of PI data.
The following PIs were reviewed for a total of two samples:
- reactor coolant system (RCS) specific activity, for the period of June 2003 through June 2004; and
- RCS leakage, for the period of June 2003 through June 2004.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, and
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
As part of the routine inspections documented above, the inspectors verified that the licensee entered the problems identified during the inspection into their corrective action program. Additionally, the inspectors verified that the licensee was identifying issues at an appropriate threshold and entering them in the corrective action program, and verified that problems included in the licensee's corrective action program were properly addressed for resolution. Attributes reviewed included: complete and accurate identification of the problem; that timeliness was commensurate with the safety significance; that evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.
b. Issues The inspectors noted several instances of operators not anticipating plant response prior to operating equipment. On August 13, 2004, operators created a transient high radiation area when they opened the RCIC system isolation valves (Section 1R22).
While searching prior corrective action program documents, the inspectors found an example of a similar occurrence where operators created a transient high radiation area while draining a tank. This occurred in August 2003. A third example of operators not anticipating plant response prior to equipment operation occurred when operators restored an average power range monitor (APRM) to service prior to completing post-maintenance testing on the APRM.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees corrective action program. This review was accomplished by reviewing daily corrective action program summary reports and attending corrective action review board meetings.
b. Findings
No findings of significance were identified.
.3 Selected Issue Follow-up Inspection: Root Cause Evaluation Report for the
Inappropriate Bypass of Average Power Range Monitor Introduction Monticello Nuclear Generating Plant performed a root cause evaluation (RCE) to determine the causes that led operators to inappropriately return an APRM to service prior to completion of its post-maintenance testing. The inspectors selected this root cause evaluation, RCE000857, for a detailed review.
a. Inspection Scope
The inspectors reviewed RCE000857 to determine whether the licensees identification of the problems were complete, accurate, and timely, and that the consideration of extent of condition review, generic implications, and common causes was adequate.
b. Issues The inspectors assessed the root causes and contributing causes listed in RCE000857.
The root cause was completed in accordance with Administrative Procedure 4 AWI-10.01.05, Investigation of Level A Action Requests. In the process of reviewing associated corrective action program documents, control room logs, and control room recorder data, the inspectors did not identify any additional root causes or contributing causes that were not discussed in the root cause evaluation. Further, the inspectors reviewed licensee corrective actions to ensure that the each of the root causes and contributing causes was appropriately addressed by the corrective action program.
Corrective actions appeared to be adequate and were focused on the apparent cause of each condition.
4OA4 Cross-Cutting Aspects of Findings
A finding described in Section 1R22 of this report had, as its primary cause, a human performance deficiency, in that operators failed to anticipate the effects on plant operations prior to operating plant equipment and caused a transient high radiation area.
4OA6 Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Mr. Conway and other members of licensee management on October 7, 2004. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
.2 Interim Exit Meetings
An interim exit meeting was conducted for:
- Radioactive gaseous and liquid effluent treatment and monitoring systems, with Mr. Conway on September 3, 2004.
4OA7 Licensee-Identified Violations
None.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- T. Palmisano, Site Vice President
- J. Conway, Site Director for Operations
- J. Purkis, Plant Manager
- R. Baumer, Licensing
- K. Jepsen, Radiation Protection Manager
- D. Neve, Regulatory Affairs Manager
- E. Sopkin, Director of Engineering
Nuclear Regulatory Commission
- B. Burgess, Chief, Reactor Projects Branch 2
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000263/2004004-01 URI Feedwater Line HELB Could Potentially Impact Multiple Safety Related Systems (Section 1R15)
- 05000263/2004004-02 NCV Failure to Follow Administrative Work Procedures Results in Transient High Radiation Condition (Section 1R22)
Closed
- 05000263/2004004-02 NCV Failure to Follow Administrative Work Procedures Results in Transient High Radiation Condition (Section 1R22)
Attachment