IR 05000263/2024011
| ML24275A015 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 10/01/2024 |
| From: | Richard Skokowski NRC/RGN-III/DORS/RPB3 |
| To: | Hafen S Northern States Power Company, Minnesota |
| References | |
| IR 2024011 | |
| Download: ML24275A015 (1) | |
Text
SUBJECT:
MONTICELLO NUCLEAR GENERATING PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000263/2024011
Dear Shawn Hafen:
On September 5, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Monticello Nuclear Generating Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight process can continue to be implemented.
The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection.
October 1, 2024 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Richard A. Skokowski, Chief Reactor Projects Branch 3 Division of Operating Reactor Safety Docket No. 05000263 License No. DPR-22
Enclosure:
As stated
Inspection Report
Docket Number:
05000263
License Number:
Report Number:
Enterprise Identifier:
I-2024-011-0041
Licensee:
Northern States Power Company, Minnesota
Facility:
Monticello Nuclear Generating Plant
Location:
Monticello, MN
Inspection Dates:
August 05, 2024 to August 24, 2024
Inspectors:
D. Chyu, Project Engineer
T. McGowan, Resident Inspector
S. Obadina, Reactor Operations Engineer
P. Smagacz, Resident Inspector
Approved By:
Richard A. Skokowski, Chief
Reactor Projects Branch 3
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Monticello Nuclear Generating Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
- Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the Control Room Ventilation and Emergency Filtration Train systems.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
- Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Based on the samples reviewed, the team concluded that the licensee's implementation of the Corrective Action Program was generally effective and supported nuclear safety.
Effectiveness of Problem Identification:
Based on the samples reviewed, the team determined that the licensee continued to identify issues at a low threshold and appropriately entered these issues into the Corrective Action Program. The team also determined that the licensee usually entered problems into the Corrective Action Program completely and accurately.
The team noted that issues were being identified by all levels of organization and with varying degrees of safety significance. The licensee also utilized a number of Corrective Action Program support processes to identify problems, including the self-assessment and audit process and the Operating Experience Program. Some deficiencies were identified by external organizations, including the NRC, that had not been previously identified by licensee staff and were subsequently entered into the Corrective Action Program for resolution. For example, the licensee performed departmental self-assessments and Nuclear Oversight audits to identify issues in station processes. The identified deficiencies and improvement opportunities were entered into the Corrective Action Program for resolution. Similarly, the licensee screened issues from both NRC and industry operating experience and entered them into the Corrective Action Program when they were applicable to the station.
As low level, as well as safety significant issues were entered into the CAP, the team determined that the licensee was generally effective at identifying trends and taking appropriate corrective actions to prevent more significant problems from developing. In addition, the licensee used the Corrective Action Program to document instances in which previous corrective actions were ineffective or were inappropriately closed.
The team performed a 5-year review of the Control Room Ventilation and Emergency Filtration Train systems. As part of this review, the team interviewed the system engineer, and reviewed plant health reports, and selected corrective action and condition evaluation documents. In addition, the team performed a partial system walkdown to assess the material condition of the system piping, selected components and surrounding areas. The team concluded that deficiencies and concerns were identified and entered into the Corrective Action Program at a low threshold and the corrective actions were adequate and timely, commensurate with their safety significance.
Effectiveness of Prioritization and Evaluation of Issues:
Based on the samples reviewed, the team determined that licensee performance was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. In general, once a degraded or non-conforming issue was identified, the CAP process was effective in directing equipment operability / functionality review. The licensee pre-screened issues at the site level and the formally dispositioned the issues at the Fleet CAP Screening meeting. During the meetings the team observed, licensee staff were generally thorough and intrusive in reviewing and screening issues. The team also observed healthy dialog and good interactions among the members of the screening groups.
The members came prepared and challenged each other on disposition of the identified conditions. Actions were prioritized based on the safety significance of the issues.
Effectiveness of Corrective Actions:
Based on the samples reviewed, the team determined that the licensee was generally effective in implementing corrective actions. In general, corrective actions for deficiencies that were safety significant were implemented in a timely manner. Problems requiring the performance of a root cause evaluation or other causal evaluation methodologies were resolved in accordance with Corrective Action Program requirements. The team sampled assignments associated with violations that were identified by the NRC previously and with licensee event reports (LERs). The team determined that the corrective actions sampled were generally effective and timely.
Assessment 71152B The Use of Operating Experience Based on the samples reviewed, the team determined that licensee's performance in the use of operating experience was generally effective. The licensee screened industry and NRC operating experience information for applicability to station. Based on these initial screenings, the licensee initiated actions in the Corrective Action Program to fully evaluate the impact, if any, to the station. When applicable, actions were developed and implemented under the Corrective Action Program to prevent similar issues from occurring. Operating experience lessons learned were communicated and incorporated into plant operations. The team observed the information being used in daily activities, such as pre-job briefs, as well as Corrective Action Program issues reviews and investigations.
Assessment 71152B Self-Assessments and Audits Based on the samples reviewed, the team determined that the licensee's performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and quality assurance audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold. The self-assessments and audits reviewed by the team identified issues that were not previously known, including issues within the Corrective Action Program itself. Nuclear Oversight (NOS) had identified deficiencies with the licensee's processes and those issues were addressed by the station using the Corrective Action Program.
Assessment 71152B Safety Conscious Work Environment The team assessed the safety conscious work environment (SCWE) at Monticello Nuclear Generating Plant. The teams conducted individual interviews and facilitated supervisor and worker focus groups. The team also reviewed CAP documents, Nuclear Safety Culture Monitoring Panel reports, the results of Pulse Surveys, and Safety Culture Assessments. The team did not identify any SCWE issues. The team concluded that an environment exists at Monticello where personnel were free to raise nuclear safety concerns without fear of retaliation. No issues of concern were identified.
Minor Performance Deficiency 71152B Minor Performance Deficiency for Failure to Follow CAP Procedure Minor Performance Deficiency: While reviewing CAP 501000071555, C Outboard MSIV Packing Leak, the NRC inspectors questioned how the CAP met the requirement per licensee fleet procedure FP-PA-ARP-01, CAP Process, Attachment 3, CAP Screening Charter, step f.16 that states Causal evaluation SHALL be PERFORMED for CAPs that require LER submittal. Upon licensee review of the question, the licensee determined that screening did not assign a cause evaluation as the equipment issue cause and corrective actions were known based on FP-PA-ARP-01, Attachment 4, Severity and Evaluation Level Determination Matrix. The licensees CAP screening assigned an Organizational and Programmatic (O&P) Evaluation under a CE to gain additional insights into the CAP. Following screening, a reportability evaluation determined the issue was reportable and an LER submitted. However, the CAP was not returned to CAP screening to ensure any additional evaluation as required by the procedure PA-ARP-01. CAP 501000071555 documented the cause and corrective actions in the CE (vs a CSE) and performed an additional O&P review under a CE. The inspectors determined that the failure to follow the CAP procedure for performing a cause evaluation was a performance deficiency that was within the licensee's ability to foresee and prevent, albeit this was not considered a violation of NRC requirements.
Screening: The inspectors determined the performance deficiency was minor. The inspectors concluded that the performance deficiency was similar to IMC 0612, Appendix E, Examples of Minor Issues, example 4.a, where a different evaluation process successfully developed corrective actions for the condition identified. Specifically, the licensee performed an Organizational and Programmatic Evaluation, which developed corrective actions to address the issue, and that an upgraded Causal Evaluation would have not developed any other significant corrective actions.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Minor Violation 71152B Minor Violation for Lack of Detail and Acceptance Criteria in Work Instructions on the
'A' Outboard MSIV Minor Violation: During diagnostic testing of the outboard MSIV AO-2-86A in 1R31, the licensee discovered a source of high friction inside the 'A' Outboard MSIV. Equipment Cause Evaluation CAP 501000073068 was generated, and the evaluation identified that workers used a grinder to remove material from the feet of the lower wedge instead of machining which the ECE identified as the correct method. This resulted in a difference of 0.100 between the two wedge feet. The work instruction contained a handwritten entry to remove material, however, it did not contain direction on the correct methodology and lacked criteria for the amount to be removed. The inspectors determined that the lack of detail and acceptance criteria in the work instruction for the MSIV was a performance deficiency that was within the licensee's ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that the performance deficiency was minor. The inspectors determined that the performance deficiency was minor as it was similar to IMC 0609, Appendix E, Examples of Minor Issues, example 4.m. Specifically, the high friction caused by the work instruction did not result in inoperability of the MSIV. The licensee entered this issue into the CAP as 501000089190.
Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, the work instruction on the outboard MSIV to remove material lacked detail on the methodology to remove material from the wedge feet of the A Outboard MSIV and lacked success criteria on how much material to remove.
Enforcement:
This failure to comply with 10 CFR 50, Appendix B, Criterion V constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Observations of Corrective Actions Associated with Slow Closure Times of the 'A' Outboard MSIV 71152B On April 17, 2021, during refueling outage 1R29, the A Outboard MSIV AO-2-86A failed to meet technical specification requirements to fast-close under 10 seconds with a recorded closure time of 25.4 seconds. The licensee performed an apparent cause evaluation and determined the fast-closure solenoid pack was sticking. The pack was replaced, and the failed pack was sent for failure analysis. The replacement pack was tested prior to startup and was within specifications.
The failure analysis report was received July 7, 2021, and did not identify a failure mechanism. However, the failure analysis report recommended development of a preventive maintenance strategy to exercise the fast-closure solenoid valves during the operating cycle. On September 26, 2022, the licensee implemented an annual preventive maintenance strategy to exercise the outboard MSIVs fast-closure solenoid valves. The licensee scheduled the PM to be performed on March 10, 2023, however, the work order was cancelled. In April 2023, during refuel outage 1R30, the A Outboard MSIV experienced another failure of the fast-closure solenoid valves. The licensee reviewed the cause of the failure and identified that the cause was identical to the failure in 1R29.
Between September 26, 2022, and the refueling outage in April 2023, the licensee had opportunities to implement the corrective action of the PM strategy. Specifically, the licensee had scheduled the testing to be performed, but cancelled the work order. Also, there was a missed opportunity between September 2022 and April 2023 during a downpower for a rod pattern adjustment when this corrective action could have been implemented. In addition to the downpower in late 2022, the licensee did experience two forced outages in early 2022 that were opportunities to implement the corrective action for exercising the solenoid valves despite the PM not officially being completed. No violations of NRC requirements were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On September 5, 2024, the inspectors presented the biennial problem identification and resolution inspection results to Shawn Hafen, Site Vice President, and other members of the licensee staff.
- On August 23, 2024, the inspectors presented the biennial problem identification and resolution inspection results to Shawn Hafen, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
500000324985
Insufficient PO Requirements
01/26/2024
501000037221
20 FP Insp: Fire Flow Test Concerns
01/30/2020
501000050537
Slow Stroke Time on AO-2-86A
04/17/2021
501000050791
Actuator Dimensions Too Big
04/21/2021
501000058833
2-508 Failed to Close
2/06/2021
501000062642
Evaluate Lighting System A(1) Status
04/28/2022
501000069283
DIV II FSW Inlet Pipe Leak
2/16/2022
501000071555
C Outboard MSIV Packing Leak
03/21/2023
501000071998
Equipment Reliability - Declining Trend
04/05/2023
501000072478
Elevation-Monticello ER Performance
04/19/2023
501000072688
Two Half Blade Guides, HBGs, Released
04/23/2023
501000072858
SRV H Vac Brkr setpt outside Allowable
04/27/2023
501000073068
Unacceptable Diagnostic Results
05/03/2023
501000073154
Y-81 Failure Caused Plant Transient
05/04/2023
501000073453
AO-2-86A: Forensic Disassembly Results
05/10/2023
501000075186
Previous CA Did Not Prevent Recurrence
07/12/2023
501000075457
CGD Critical Characteristic/Banana Jack
07/25/2023
501000075506
Banana Jacks Inadequate Testing
07/26/2023
501000075538
Ineffective Closure of Corrective Action
07/27/2023
501000075980
VD-9175B Didn't Open When "B" CRV Placed
08/13/2023
501000075980
VD-9175B didn't Open When "B" CRV Placed
08/23/2023
501000076010
Repeat CRV/EFT Damper Issues
08/23/2023
501000077078
Turbine Control Valve #1 Stayed Closed
09/26/2023
501000077170
Reactor Scram Number 141
09/27/2023
501000077555
PS-2-134B Out of As Found
10/10/2023
501000077555
PS-S-134B Out of As Found
10/10/2023
501000077615
CAP Not Written in a Timely Manner
10/11/2023
501000077624
Energy Found Within Lockout Boundary
10/11/2023
501000079828
2/08/2023
501000080744
VD-9175B Failed to Open
01/10/2024
Corrective Action
Documents
501000081107
V-EAC-14B Comp. Running Unexpectedly
01/22/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
501000082361
Reactor SCRAM No. 142: ATWS Trip
2/28/2024
501000082683
RPV Bottom Head Cooldown Rate >100/hr
03/08/2024
501000082844
DGN 86 Lockout
03/14/2024
501000082844
DGN 86 Lockout
03/14/2024
501000083146
Discharge Temp High on F SRV
03/24/2024
501000083316
ARD 2024 Torus Coatings
03/26/2024
501000083534
Packing Leak A MSIV on 900# Inspection
03/31/2024
501000086682
Missed EDG Phoenix Entry
06/13/2024
501000086793
Expired Fire Brigade FOAM
06/17/2024
501000086909
HU Issue during 0187-02B
06/23/2024
501000087540
RM-7992B Is Reading Lower Than It Should
07/09/2024
501000087690
EQ - ASCO Activation Energy Issue
07/12/2024
501000088660
24 PIR - Cause Eval Process for LER
08/07/2024
501000088778
24 PIR - Functional Loc. vs Label Disc
08/13/2024
501000088807
24 PIR - Incorrect Proc Listed
08/13/2024
501000089029
08/19/2024
501000089094
24 PIR - 1224 and OSP-FIR-1489 Discrepancy
08/20/2024
501000089141
24 PIR - No Eval for AFFF Quantity
08/21/2024
501000089144
24 PIR - Fire Foam Licensing Basis
08/22/2024
501000089186
24 PIR - Potential NCV - MSIV PM
08/23/2024
Corrective Action
Documents
Resulting from
Inspection
501000089190
24 PIR - 2019 Work Instructions
08/22/2024
Drawings
NH-170037
Main Control Room CRV / EFT System
0000027183
Outboard MSIV Internals Hardfacing Upgrades
601000000231
Add Hardfacing to Outboard MSIV Wedge Set
08/20/2019
Engineering
Changes
601000003691
Replace Teledyne Emergency Lights
Monticello Pulse Survey Results for June 2024
Xcel Energy Nuclear Safety Culture Assessment 2024
05/09/2024
A-OPS-MNGP-
24-1
24 Nuclear Oversight Monticello Nuclear Generating Plant
Audit of Operations/Chemistry
05/30/2024
EQ-A
EQ Central File Part A Equipment Master List
Miscellaneous
EQ-PART-B
EQ Central File Part B Environmental Specifications
IST-Basis
Pump and Valve In-Service Testing Program Basis
IST-Plan 6th
Interval
Pump and Valve In-Service Testing Program Plan
QF0250, Rev. 0
(FP-SC-GEN-08)
Procurement Engineer Evaluation of Purchase Requisition,
QSL Vendor Name: Framatome Inc.
08/17/2023
QF0565
Maintenance Rule Functional and MSPI failure Evaluation
(Associated with CAP 501000077078)
Miscellaneous
QF0571
Troubleshooting Plan (Associated with CAP 501000077078)
0187-2B
Emergency Diesel Generator/12 ESW Monthly Pump and
Valve Tests
266
Fire Pumps Simulated Auto-Actuation and Capability Test
1061
Emergency Lighting Quarterly Operability and Capacity Test
4514-02
Outboard MSIV Disassembly and Reassembly
4514-02A
Outboard MSIV - Assembly of New Stem and Disc Pack
FG-PA-EVAL-01
Evaluation Methods
FP-E-RTC-02
Functional Location Classification
FP-EC-ECP-01
Employee Concerns Program
FP-MA-REW-01
Rework Program
FP-NO-AUD-01
Internal Audits
FP-OP-OL-01
Operability
FP-PA-APR-01
CAP Process
FP-PA-ARP-03
Management of Change (MOC) Process
FP-PA-EFR-01
Effectiveness Review Manual
FP-PA-OE-01
Operating Experience Program
FP-PA-PAR-01
Performance Assessment Review Board and Performance
Assessment Oversight
Procedures
FP-PA-RMS-01
Risk Management Screening
Self-Assessments A-OPS-MNGP-
24-1
24 Nuclear Oversight Monticello Nuclear Generating Plant
Audit of Operations/Chemistry
24
7000091294
Perform 0255-07-IA-2, ALL STEPS
04/17/2023
Work Orders
700034229
AO-2-86A Repl. Disc Trunnion Pins
01/14/2020
700089154
AO-2-86A, As Found Diagnostic Test
04/27/2021
700095862-0010
Air Quality Test for the Instrument Air System
700112844
AO-2-86C, Perform 4514-02 (Parts B-N)
01/04/2023
Work Orders
700122542
AO-2-86A As Left Diagnostic Test
04/26/2023