IR 05000263/2014004
| ML14310A031 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 11/05/2014 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B2 |
| To: | Fili K Northern States Power Co |
| References | |
| IR-2014004 | |
| Download: ML14310A031 (49) | |
Text
UNITED STATES ber 5, 2014
SUBJECT:
MONTICELLO NUCLEAR GENERATING PLANT NRC INTEGRATED AND POWER UPRATE INSPECTION REPORT 05000263/2014004
Dear Ms. Fili:
On September 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Monticello Nuclear Generating Plant. The enclosed report documents the inspection findings, which were discussed on October 8, 2014, with you and other members of your staff.
Based on the results of this inspection, one self-revealed finding of very low safety significance was identified. The finding involved a violation of NRC requirements. However, because of the very low safety significance, and because the issues were entered into your corrective action program, the NRC is treating the issues as a non-cited violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy. Additionally, a licensee-identified violation is listed in Section 4OA7 of this report.
If you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, 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 Monticello Nuclear Generating Plant. In addition, if you disagree with a cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Monticello Nuclear Generating Plant. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA Nick Shah, Acting for/
Kenneth Riemer, Branch Chief Branch 2 Division of Reactor Projects Docket No. 50-263 License No. DPR-22
Enclosure:
Inspection Report 05000263/2014004; w/Attachment: Supplemental Information
REGION III==
Docket No: 50-263 License No: DPR-22 Report No: 05000263/2014004 Licensee: Northern States Power Company, Minnesota Facility: Monticello Nuclear Generating Plant Location: Monticello, MN Dates: July 1 through September 30, 2014 Inspectors: P. Zurawski, Senior Resident Inspector P. Voss, Resident Inspector M. Phalen, Senior Health Physicist J. Beavers, Emergency Preparedness Inspector S. Bell, Health Physicist Approved by: K. Riemer, Branch Chief Branch 2 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
Inspection Report 05000263/2014004; 07/01/2014-09/30/2014; Monticello Nuclear Generating
Plant Operability Determinations and Functional Assessments.
This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One Green finding was identified by the inspectors.
The finding was considered a non-cited violation (NCV) of NRC regulations. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow,
Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP) dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310,
Aspects Within the Cross-Cutting Areas effective date January 1, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.
Cornerstone: Barrier Integrity
- Green.
A finding of very low safety significance and a NCV of Technical Specification (TS) 5.4.1, Procedures, was self-revealed when the licensee failed to implement requirements specified in FP-OP-RM-01, Reactivity Management Program.
Specifically, the licensee failed to ensure that the licensed operators were aware of the consequences of the reactivity changes they were making, as required by FP-OP-RM-01. As a result, the licensed operators were unaware that their actions to increase recirculation flow would result in the plant exceeding the minimum critical power ratio (MCPR) operating limit. This issue was entered into the licensees corrective action program (CAP) 1446848. Immediate corrective actions included restoration of the plant to within the MCPR operating limit, halting of power changes, disqualification of individuals directly involved, increased management oversight, a detailed review of the reactivity plan and procedures planned for use during the reactivity plan, and site-wide communication of the event. The site initiated a root cause evaluation (RCE), which was in progress at the end of the inspection period.
The inspectors determined that the failure to perform reactivity manipulations in accordance with reactivity management requirements was a performance deficiency requiring evaluation. The inspectors determined that the finding was more than minor in accordance with IMC 0612, Appendix B, because it adversely impacted the Barrier Integrity Cornerstone attributes of Configuration Control and Procedure Quality, and affected the cornerstone objective to provide reasonable assurance that physical design barriers, including fuel cladding, protect the public from radionuclide releases caused by accidents or events. The inspectors assessed the significance of this finding in accordance with IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria and determined this finding was of very low safety significance. The inspectors concluded that this finding was cross-cutting in the Human Performance,
Documentation aspect because of the failure to ensure that the procedures being used to make the reactivity manipulations were complete, accurate, and up-to-date. [H.7]
(Section 1R15)
Cornerstone: Emergency Preparedness
- A violation of very low safety or security significance or Severity Level IV that was identified by the licensee has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees CAP. The violations and CAP tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Monticello began the inspection period operating at approximately 88 percent power (1775 MWt) of its licensed EPU power of 2004 MWt. On September 13, 2014 power reduced to approximately 50 percent due to a lockout of the 12 recirculation pump. On September 16, 2014 operators further reduced power to approximately 28 percent to place the 12 recirculation pump back in service. Shortly after placing the 12 recirculation pump in service, operators began power ascension and exceeded thermal operating limits for minimum critical power ratio.
The licensee stopped power ascension to address this operational issue. Power ascension re-commenced on September 18, 2014 with 88 percent power achieved on September 20, 2014. On September 21, 2014 the 11 circulating water pump tripped and in response power was reduced to approximately 61 percent. Power remained in the range of 61 to 63 percent for the remainder of the quarter.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
1R04 Equipment Alignment
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- 12 Emergency diesel generator (EDG) and fuel oil systems during pump P-77 being out of service;
- P-60A condensate service pump during P-60B condensate service pump motor bearing replacement; and
- Division 2 250 Volt Battery.
The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Safety Analysis Report (USAR), Technical Specification (TS)requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions.
The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
These activities constituted three partial system walkdown samples as defined in Inspection Procedure (IP) 71111.04-05.
b. Findings
No findings were identified.
.2 Semi-Annual Complete System Walkdown
a. Inspection Scope
On September 22-26, the inspectors performed a complete system alignment inspection of the circulating water system to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment lineups; electrical power availability; system pressure and temperature indications, as appropriate; 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 a sample of past and outstanding WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the Attachment to this report.
These activities constituted one complete system walkdown sample as defined in IP 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
- cable spreading room;
- refuel floor;
- turbine building corridor east and west 911 and 931;
- 250V Div 2 Battery; and
- 931 reactor building east hydraulic control unit (HCU).
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 implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan. 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 with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event.
Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the Attachment to this report.
These activities constituted five quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings were identified.
.2 Annual Fire Protection Drill Observation
a. Inspection Scope
On September 10, 2014, the inspectors observed fire brigade activation for an unannounced fire drill. Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:
- proper wearing of turnout gear and self-contained breathing apparatus;
- proper use and layout of fire hoses;
- employment of appropriate firefighting techniques;
- sufficient firefighting equipment brought to the scene;
- effectiveness of fire brigade leader communications, command, and control;
- search for victims and propagation of the fire into other plant areas;
- smoke removal operations;
- utilization of pre-planned strategies;
- adherence to the pre-planned drill scenario; and
- drill objectives.
Documents reviewed are listed in the Attachment to this report.
These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On September 9, 2014, the inspectors observed a crew of licensed operators in the plants simulator during the annual licensed operator requalification exam to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of abnormal and emergency procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.
The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11 and satisfied the inspection program requirement for the resident inspectors to observe a portion of an in-progress annual requalification operating test during a training cycle in which it was not observed by the NRC during the biennial portion of this IP.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk
a. Inspection Scope
On September 13, 2014, the inspectors observed control room operators during a down power to support scram time testing and a rod pattern adjustment. This was an activity that required heightened awareness and was related to increased risk. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions.
The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant systems:
- maintenance rule program a 2 year evaluation for 2012-2014; and
- plant level systems.
The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
.1 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
- 11 EDG inoperable due to P-77 fuel oil transfer pump failure;
- MO-2373 main steam drain valve back-seating;
- radiation monitors being out of service;
- fuse F-21 replacement of the A-TIP valve control monitor for traversing in-core probe No. 2 ball valve;
- radiography of buried liquid radioactive waste pipe;
- B recirculation pump lockout troubleshooting while at 52 percent power; and
- power changes and recovery of tripped recirculation pump during single loop operations.
These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Documents reviewed during this inspection are listed in the Attachment to this report.
These maintenance risk assessments and emergent work control activities constituted seven samples as defined in IP 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functional Assessments
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- limiting condition for operation (LCO) 3.0.3 (loss of both CFEF Trains);
- extended power uprate (EPU) level 1 curve exceeded;
- HPCI steam line drain trap bypass CV-2043 leaking;
- RCIC hi steam flow outside calibration criteria; and
- unplanned violation of MCPR operational limit.
The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and USAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.
These operability inspections constituted five samples as defined in IP 71111.15-05.
b. Findings
Failure to Follow Reactivity Management Procedure Introduction A self-revealed finding of very low safety significance (Green) and NCV of TS 5.4.1, Procedures, occurred on September 16, 2014, due to the licensees failure to implement requirements specified in FP-OP-RM-01, Reactivity Management Program. Specifically, the licensee failed to ensure that the licensed operators were aware of the consequences of the reactivity changes they were making, as required by FP-OP-RM-01.
Description On September 16, 2014, the licensee performed activities to retrieve a tripped recirculation pump. They had been operating in single loop operations following a recirculation pump trip on September 14. The operating crew utilized procedure 2300, Reactivity Maneuvering Steps to control the reactivity adjustments. Step 15 directed plant operators to start the idle pump using procedure B.01.04-05 D.3, Restart of a Shutdown Pump While at Power or in a Hot Shutdown Condition. Per B.01.04-05 D.3, the operators restarted the tripped recirculation pump. Once the pump was online, the crew moved on to perform additional steps in B.01.04-05 D.3 to match the flows of the recirculation pumps. These steps resulted in total core flow increasing from approximately 27.5 Mlb/h to approximately 32 Mlb/h. When the recirculation pump flows had stabilized, reactor engineers checked the core thermal limits monitor to ensure that the plant was still within required core thermal limits following the reactivity manipulations. At this point, the core thermal limits monitor revealed that the plant had exceeded the operating limit for the MCPR. Reactor engineers immediately recommended that the plant be restored within the MCPR operating limits by lowering recirculation flow, and the operating crew reacted accordingly.
The operating crew entered TS 3.2.2, Minimum Critical Power Ratio, which required operators to restore the limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, or reduce power to less than 25 percent.
Inspectors noted that the licensee remained in this condition for under 15 minutes, prior to restoring compliance with the MCPR operating limit by reducing recirculation flow. The inspectors confirmed that the licensee had not exceeded any Technical Specification Safety Limits.
Investigation revealed that when operators had increased the recovered recirculation pump speed to match the flow to the running pump, they had exceeded 28.8 Mlb/h. This was determined to be an important critical parameter limit because when power is less than 40 percent and core flow is greater than 50 percent (~28.8 Mlb/h), reactor thermal limits become more limiting. This region of operation on the power to flow map is outlined by the Core Operating Limits Report (COLR), and is known as the Average Power Range Monitor/Rod Block Monitor and Technical Specification Improvement Program (ARTS) Region. During normal reactivity manipulations, the reactivity plan is prepared and takes measures to avoid this region due to the more limiting thermal limits associated with it.
Inspectors noted that this limit was not discussed during the Infrequent Test or Evolution (ITOE) brief. Inspectors reviewed procedures being used for the reactivity manipulations, and noted that Step 15 did not reference core flow as being a critical parameter with a specified limit of 28.8Mlb/h. Step 15 was the step that instructed operators to start the idle recirculation pump per the B.01.04-05 D.3 operations procedure. Inspectors noted that this limitation was specified at a later step, Step 18.
Step 18 instructed operators to raise flow, but not to exceed 28.8 Mlb/h. Inspectors reviewed the B.01.04-05 D.3 operations procedure and determined that it did not include cautions limiting core flow to prevent the plant from entering the ARTS region.
Inspectors noted that the procedures were not properly coordinated to assure that all limits were observed, and that the 2300 procedure did not set up the proper conditions to start the idle recirculation pump (i.e., when they started the pump, even prior to matching the recirculation flows, they were encroaching on the ARTS region).
Investigation also revealed that the Just-In-Time Training performed for the evolution did not include practice using the 2300 procedure, and was inadequate for the task being performed. In addition, many of the operators had little to no training or awareness of the ARTS region and its significance. The investigation also revealed that communication, awareness, and identification of critical parameters were inadequate.
The root cause evaluation was in progress at the end of the inspection period.
Reactivity Management Program, FP-OP-RM-01 states, licensed operators SHALL be aware of all activities that may affect reactivity and the consequences of these effects. Inspectors determined that during this event, as a result of several breakdowns, the licensed operators were not aware of the consequences of their reactivity manipulations. As a result, the inspectors determined that this was a violation of TS 5.4.1, Procedures.
Analysis The inspectors determined that the failure to perform reactivity manipulations in accordance with reactivity management requirements was a performance deficiency because it represented a failure to meet TS requirement 5.4.1; the cause was reasonably within the licensees ability to foresee and correct; and should have been prevented. The inspectors evaluated the issue and determined that the finding was more than minor in accordance with IMC 0612, Appendix B, because it adversely impacted the Barrier Integrity Cornerstone attributes of Configuration Control and Procedure Quality, and affected the cornerstone objective to provide reasonable assurance that physical design barriers, including fuel cladding, protect the public from radionuclide releases caused by accidents or events. Specifically, the finding resulted in the licensee exceeding the MCPR operational limit, which reduced the plants margin to the Technical Specification MCPR Safety Limit. The Safety Limit is intended to protect the fuel cladding barrier by helping to ensure that no fuel damage would result during normal operation or anticipated operational occurrences.
The inspectors assessed the significance of this finding in accordance with IMC 0609, Appendix A, Exhibit 3, for Barrier Integrity. Because this section does not include specific questions to allow directly screening to Green, the inspectors used the Reactivity Control Systems screening questions in IMC 0609, Appendix A, under the Mitigating Systems Cornerstone. The inspectors concluded that the finding resulted in a mismanagement of reactivity by operators which required a SDP evaluation using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria.
The inspectors consulted with the Region III Senior Reactor Analysts, who qualitatively concluded the finding was of very low safety significance because widespread, significant fuel damage as a result of this condition was very unlikely. The calculated MCPR was well within the TS Safety Limit and the MCPR was restored in a very short time period, under 15 minutes. The inspectors concluded that this finding was cross-cutting in the Human Performance Documentation aspect because of the failure to ensure that the procedures being used to make the reactivity manipulations were complete, accurate, and up-to-date. Specifically, the 2300 Reactivity Maneuvering Steps procedure failed to list 28.8Mlb/h core flow as a critical parameter limit for the step that directed retrieval of the tripped recirculation pump using B.01.04-05 D.3. In addition, the licensee failed to ensure that the procedure for recovery from single loop operations, B.01.04-05 D.3, contained cautions limiting core flow to prevent the plant from entering the ARTS region, and failed to ensure that flow adjustment actions were properly coordinated between this procedure and the 2300. [H.7]
Enforcement Technical Specification 5.4.1 requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978. Section 2.f of RG 1.33, Revision 2, Appendix A, February 1978, includes General Plant Operating Procedures for changing load. FP-OP-RM-01, Reactivity Management Program states, Licensed operators SHALL be aware of all activities that may affect reactivity and the consequences of these effects. Contrary to the above, on September 16, 2014, the licensee failed to implement requirements contained in a general operating procedure for changing load, FP-OP-RM-01, Reactivity Management Program. As a result, the licensed operators were unaware that their actions to increase recirculation flow would result in the plant exceeding the MCPR operating limit.
Because this violation was of very low safety significance and it was entered into the corrective action program as CAP 1446848, this issue is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000263/2014004-01: Failure to Follow the Reactivity Management Procedure).
Corrective actions for this event included restoration of the plant to within the MCPR limit, the temporary halting of power changes, disqualification of individuals directly involved, increased management oversight, a detailed review of the reactivity plan and procedures planned for use during the reactivity plan, and site-wide communication of the event. A RCE was in progress at the end of the inspection period.
1R18 Plant Modifications
.1 Plant Modifications
a. Inspection Scope
The inspectors reviewed the following modifications:
- Temporary modification for the sudden pressure relay Channel 3 bypass on the main transformer; and
- Modifications to the ODCM radiation monitors.
The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the USAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of the affected system(s). The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with the design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one temporary modification sample and one permanent plant modification sample as defined in IP 71111.18-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance (PM) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- P-77 fuel oil transfer pump failure return to service;
- A CREF return to service;
- SRV E low set tailpipe dP;
- C-80 Condensate Demin panel emergent work;
- CRD-111 HCU valve packing replacement; and
- #13 RHR motor outlet cooling flow indicator cleaning and inspection.
These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the USAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.
This inspection constituted six post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- 8216-01; MELLA+ dynamic testing at 1765 MWt (Routine);
- 0143; drywell-torus monthly vacuum breaker check (Routine); and
- 0006; scram discharge volume hi level scram test and calibration procedure (Routine).
The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the USAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for IST activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted four routine surveillance testing samples, one reactor coolant system leak detection inspection sample, and one IST sample as defined in IP 71111.22, Sections-02 and-05.
b. Findings
No findings were identified.
1EP2 Alert and Notification System Evaluation
.1 Alert and Notification System Evaluation
a. Inspection Scope
The inspectors held discussions with Emergency Preparedness (EP) staff regarding the operation, maintenance, and periodic testing of the primary and backup Alert and Notification System (ANS) in the plume pathway Emergency Planning Zone. The inspectors reviewed monthly trend reports and siren test failure records from June 2012 through June 2014. Information gathered during document reviews and interviews were used to determine whether the ANS equipment was maintained and tested in accordance with Emergency Plan Commitments and Procedures. Documents reviewed are listed in the Attachment to this report.
This ANS evaluation inspection constituted one sample as defined in IP 71114.02-06.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System
.1 Emergency Response Organization Staffing and Augmentation System
a. Inspection Scope
The inspectors reviewed and discussed with plant EP staff the Emergency Plan Commitments and Procedures for Emergency Response Organization (ERO) on-shift and augmentation staffing levels. A sample of 12 ERO training records for personnel assigned to key and support positions were reviewed to determine the status of their training as it related to their assigned ERO positions. The inspectors reviewed the ERO Augmentation System and activation process, the primary and alternate methods of initiating ERO activation, unannounced off-hour augmentation tests from June 2012 through June 2014, and the provisions for maintaining the plants ERO roster.
The inspectors reviewed a sample of corrective actions related to the facilitys ERO staffing and Augmentation System Program and activities from June 2012 through June 2014 to determine whether corrective actions were completed in accordance with the site's CAP. Documents reviewed are listed in the Attachment to this report.
This ERO staffing and augmentation system inspection constituted one sample as defined in IP 71114.03-06.
b. Findings
No findings were identified.
1EP5 Maintenance of Emergency Preparedness
.1 Maintenance of Emergency Preparedness
a. Inspection Scope
The inspectors reviewed a sample of nuclear oversight staffs audits of the EP Program to determine whether these independent assessments met the requirements of 10 CFR 50.54(t). The inspectors also reviewed critique reports and samples of CAP records associated with the 2013 Biennial Exercise, as well as various EP drills conducted, in order to determine that the licensee fulfilled its drill commitments and to evaluate the licensees efforts to identify, track, and resolve concerns identified during these activities. The inspectors reviewed a sample of EP items and corrective actions related to the facilitys EP Program and activities from June 2012 through June 2014 to determine whether corrective actions were completed in accordance with the site's CAP.
Documents reviewed are listed in the Attachment to this report.
This correction of EP weaknesses and deficiencies inspection constituted one sample as defined in IP 71114.05-06.
b. Findings
A licensee-identified violation is documented in Section 4OA7.
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine licensee emergency drill on August 21, 2014, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Simulator control room and the Technical Support Center (TSC) to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the to this report.
This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Occupational and Public Radiation Safety
2RS5 Radiation Monitoring Instrumentation
This inspection constituted a partial sample as defined in IP 71124.05-05.
.1 Inspection Planning (02.01)
a. Inspection Scope
The inspectors reviewed the plant final safety analysis report (FSAR) to identify radiation instruments associated with monitoring area radiological conditions including airborne radioactivity, process streams, effluents, materials/articles, and workers. Additionally, the inspectors reviewed the instrumentation and the associated TS requirements for post-accident monitoring instrumentation, including instruments used for remote emergency assessment.
The inspectors reviewed a listing of in-service survey instrumentation including air samplers and small article monitors, along with instruments used to detect and analyze workers external contamination. Additionally, the inspectors reviewed personnel contamination monitors and portal monitors, including whole-body counters, to detect workers internal contamination. The inspectors reviewed this list to assess whether an adequate number and type of instruments were available to support operations.
The inspectors reviewed licensee and third-party evaluation reports of the Radiation Monitoring Program since the last inspection. These reports were reviewed for insights into the licensees program and to aid in selecting areas for review (smart sampling).
The inspectors reviewed procedures that govern instrument source checks and calibrations, focusing on instruments used for monitoring transient high radiological conditions, including instruments used for underwater surveys. The inspectors reviewed the calibration and source check procedures for adequacy and as an aid to smart sampling.
The inspectors reviewed the area radiation monitor alarm setpoint values and setpoint bases as provided in the TSs and the FSAR.
The inspectors reviewed effluent monitor alarm setpoint bases and the calculational methods provided in the offsite dose calculation manual.
b. Findings
No findings were identified.
.2 Walkdowns and Observations (02.02)
a. Inspection Scope
The inspectors walked down effluent radiation monitoring systems, including at least one liquid and one airborne system. Focus was placed on flow measurement devices and all accessible point-of-discharge liquid and gaseous effluent monitors of the selected systems. The inspectors assessed whether the effluent/process monitor configurations aligned with Offsite Dose Calculation Manual descriptions and observed monitors for degradation and out-of-service tags.
The inspectors selected portable survey instruments that were in use or available for issuance and assessed calibration and source check stickers for currency as well as instrument material condition and operability.
The inspectors observed licensee staff performance as the staff demonstrated source checks for various types of portable survey instruments. The inspectors assessed whether high-range instruments were source checked on all appropriate scales.
The inspectors walked down area radiation monitors and continuous air monitors to determine whether they were appropriately positioned relative to the radiation sources or areas they were intended to monitor. Selectively, the inspectors compared monitor response (via local or remote control room indications) with actual area conditions for consistency.
The inspectors selected personnel contamination monitors, portal monitors, and small article monitors and evaluated whether the periodic source checks were performed in accordance with the manufacturers recommendations and licensee procedures.
b. Findings
No findings were identified.
.3 Calibration and Testing Program (02.03)
Laboratory Instrumentation
a. Inspection Scope
The inspectors assessed laboratory analytical instruments used for radiological analyses to determine whether daily performance checks and calibration data indicated that the frequency of the calibrations was adequate and there were no indications of degraded instrument performance.
The inspectors assessed whether appropriate corrective actions were implemented in response to indications of degraded instrument performance.
b. Findings
No findings were identified.
Whole Body Counter
a. Inspection Scope
The inspectors reviewed the methods and sources used to perform whole body count functional checks before daily use of the instrument and assessed whether check sources were appropriate and aligned with the plants isotopic mix.
The inspectors reviewed whole body count calibration records since the last inspection and evaluated whether calibration sources were representative of the plant source term and that appropriate calibration phantoms were used. The inspectors looked for anomalous results or other indications of instrument performance problems.
b. Findings
No findings were identified.
Post-Accident Monitoring Instrumentation
a. Inspection Scope
The inspectors selected containment high-range monitors and reviewed the calibration documentation since the last inspection.
The inspectors assessed whether an electronic calibration was completed for all range decades above 10 rem/hour and whether at least 1 decade at or below 10 rem/hour was calibrated using an appropriate radiation source.
The inspectors assessed whether calibration acceptance criteria were reasonable; accounting for the large measuring range and the intended purpose of the instruments.
The inspectors selected effluent/process monitors that were relied on by the licensee in its emergency operating procedures as a basis for triggering emergency action levels and subsequent emergency classifications, or to make protective action recommendations during an accident. The inspectors evaluated the calibration and availability of these instruments.
The inspectors reviewed the licensees capability to collect high-range post-accident iodine effluent samples.
As available, the inspectors observed electronic and radiation calibration of these instruments to assess conformity with the licensees calibration and test protocols.
b. Findings
No findings were identified.
Portal Monitors, Personnel Contamination Monitors, and Small Article Monitors
a. Inspection Scope
For each type of these instruments used on site, the inspectors assessed whether the alarm setpoint values were reasonable under the circumstances to ensure that licensed material is not released from the site.
The inspectors reviewed the calibration documentation for each instrument selected and discussed the calibration methods with the licensee to determine consistency with the manufacturers recommendations.
b. Findings
No findings were identified.
Portable Survey Instruments, Area Radiation Monitors, Electronic Dosimetry, and Air Samplers/Continuous Air Monitors
a. Inspection Scope
The inspectors reviewed calibration documentation for at least one of each type of instrument. For portable survey instruments and area radiation monitors, the inspectors reviewed detector measurement geometry and calibration methods and had the licensee demonstrate use of its instrument calibrator as applicable. The inspectors conducted comparison of instrument readings versus an NRC survey instrument if problems were suspected.
As available, the inspectors selected portable survey instruments that did not meet acceptance criteria during calibration or source checks to assess whether the licensee had taken appropriate corrective action for instruments found significantly out of calibration (e.g., greater than 50 percent). The inspectors evaluated whether the licensee evaluated the possible consequences of instrument use since the last successful calibration or source check.
b. Findings
No findings were identified.
Instrument Calibrator
a. Inspection Scope
As applicable, the inspectors reviewed the current output values for the licensees portable survey and area radiation monitor instrument calibrator unit(s). The inspectors assessed whether the licensee periodically measures calibrator output over the range of the instruments used through measurements by ion chamber/electrometer.
The inspectors assessed whether the measuring devices had been calibrated by a facility using National Institute of Standards and Technology traceable sources and whether corrective factors for these measuring devices were properly applied by the licensee in its output verification.
b. Findings
No findings were identified.
Calibration and Check Sources
a. Inspection Scope
The inspectors reviewed the licensees 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, source term to assess whether calibration sources used were representative of the types and energies of radiation encountered in the plant.
b. Findings
No findings were identified.
.4 Problem Identification and Resolution (02.04)
a. Inspection Scope
The inspectors evaluated whether problems associated with radiation monitoring instrumentation were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involve radiation monitoring instrumentation.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, and Occupational and Public Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance Index-Emergency Alternating Current Power System
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) Emergency Alternating Current (AC) Power System performance indicator (PI) for the period from the third quarter 2013 through the second quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, was used. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports and NRC Integrated Inspection Reports for the period of July 2013 through June 2014, to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one MSPI emergency AC power system sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index-High Pressure Injection Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the MSPI High Pressure Injection Systems PI for the period from the third quarter 2013 through the second quarter 2014.
To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99 02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, was used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports and NRC Integrated Inspection Reports for the period of July 2013 through June 2014, to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one MSPI high pressure injection system sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Mitigating Systems Performance Index-Heat Removal System
a. Inspection Scope
The inspectors sampled licensee submittals for the MSPI Heat Removal System PI for the period from the third quarter 2013 through the second quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, was used. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports, MSPI derivation reports, and NRC Integrated Inspection Reports for the period of July 2013 through June 2014, to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one MSPI heat removal system sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.4 Drill/Exercise Performance
a. Inspection Scope
The inspectors sampled licensee submittals for the Drill/Exercise Performance (DEP)
PI or the period from the second quarter 2013 through the first quarter 2014.
Performance Indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees records and processes including procedural guidance on assessing opportunities for the PI; assessments of PI opportunities during pre-designated control room simulator training sessions, performance during the 2013 Biennial Exercise, and performance during other drills associated with the PI to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the to this report.
This inspection constitutes one DEP sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.5 Emergency Response Organization Readiness
a. Inspection Scope
The inspectors sampled licensee submittals for the ERO Readiness PI for the period from the second quarter 2013 through the first quarter 2014. The inspectors used PI definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees records and processes including procedural guidance on assessing opportunities for the PI; performance during the 2013 Biennial Exercise and other drills; and revisions of the roster of personnel assigned to key ERO positions to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems were identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one ERO readiness sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.6 Alert and Notification System
a. Inspection Scope
The inspectors sampled licensee submittals for the ANS Reliability PI for the period from the second quarter 2013 through the first quarter 2014. The inspectors used PI definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees records and processes including procedural guidance on assessing opportunities for the PI and results of periodic ANS operability tests to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine whether any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one ANS reliability sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.7 Reactor Coolant System-Specific Activity
a. Inspection Scope
The inspectors sampled licensee submittals for the reactor coolant system-specific activity PI for Monticello Nuclear Generating Plant for the period from the third quarter 2013 through the second quarter 2014. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees reactor coolant system chemistry samples, technical specification requirements, issue reports, event reports and NRC Integrated Inspection Reports to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one reactor coolant system-specific activity sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.8 Occupational Exposure Control Effectiveness
a. Inspection Scope
The inspectors sampled licensee submittals for the Occupational Exposure Control Effectiveness Performance Indicator for the period from the third quarter 2013 through the second quarter 2014. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees assessment of the PI for occupational radiation safety to determine if the indicator-related data was adequately assessed and reported. To assess the adequacy of the licensees PI data collection and analyses, the inspectors discussed with radiation protection staff the scope and breadth of its data review and the results of those reviews. The inspectors independently reviewed electronic personal dosimetry dose rate and accumulated dose alarms and dose reports and the dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized occurrences. The inspectors also conducted walkdowns of numerous locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one occupational exposure control effectiveness sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.9 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual
Radiological Effluent Occurrences
a. Inspection Scope
The inspectors sampled licensee submittals for the radiological effluent Technical Specification/Offsite Dose Calculation Manual radiological effluent occurrences PI for the period from the third quarter 2013 through the second quarter 2014. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees issue report database and selected individual reports generated since this indicator was last reviewed to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous effluent summary data and the results of associated offsite dose calculations for selected dates to determine if indicator results were accurately reported. The inspectors also reviewed the licensees methods for quantifying gaseous and liquid effluents and determining effluent dose. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one Radiological Effluent Technical Specification/Offsite Dose Calculation Manual radiological effluent occurrences sample as defined in IP 71151-05.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; 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.
Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.
b. Findings
No findings were identified.
.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 CAP. This review was accomplished through inspection of the stations daily condition report packages.
These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings were identified.
.3 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue.
The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the 6-month period of March 1, 2014 through September 30, 2014, although some examples expanded beyond those dates where the scope of the trend warranted.
The review also included issues documented outside the normal CAP in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.
This review constituted one semi-annual trend inspection sample as defined in IP 71152-05.
b. Findings
No findings were identified.
.4 Annual Sample: Review of Operator Workarounds
a. Inspection Scope
The inspectors evaluated the licensees implementation of their process used to identify, document, track, and resolve operational challenges. Inspection activities included, but were not limited to, a review of the cumulative effects of the operator workarounds (OWAs) on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents.
The inspectors performed a review of the cumulative effects of OWAs. The documents listed in the Attachment to this report were reviewed to accomplish the objectives of the inspection procedure. The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into their CAP and proposed or implemented appropriate and timely corrective actions which addressed each issue.
Reviews were conducted to determine if any operator challenge could increase the possibility of an Initiating Event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of Mitigating Systems, impaired access to equipment, or required equipment uses for which the equipment was not designed. Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified operator workarounds.
This review constituted one OWA annual inspection sample as defined in IP 71152-05.
b. Findings
No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 B Recirculation Pump Trip and Automatic Runback
a. Inspection Scope
The inspectors reviewed the plants response to a B reactor recirculation pump trip and automatic runback on September 14, 2014. The inspectors responded to the control room to observe control room response, event response team initiation, technical specification entries, and plant conditions. The inspectors reviewed the circumstances leading to the recirculation pump lockout. The licensee was performing a task to adjust the voltage/hertz potentiometer associated with the 12 recirculation motor-generator (MG) set when the lockout occurred. Inspectors observed that as a result of the automatic runback, the plant had moved outside of the analyzed region of the power to flow map. Control room staff took prompt action to insert control rods per procedure in order to maneuver the plant back into the analyzed region. As a result of entering the unanalyzed region of the power to flow map, the licensee made a 50.72 8-hour report to the NRC for an unanalyzed condition that significantly affects plant safety. During the event, the licensee took action to protect the operating #11 recirculation pump MG set and its power source.
The licensee concluded that the cause of the event was associated with a faulty potentiometer switch. The switch was replaced and the licensee maneuvered the plant to allow restart of the B recirculation pump. Inspectors reviewed licensee actions in response to the event and did not identify any findings of significance. Documents reviewed are listed in the Attachment to this report.
This event follow-up review constituted one sample as defined in IP 71153-05.
b. Findings
No findings were identified.
4OA5 Other Activities
.1 Power Uprate Related Inspection Activities
a. Inspection Scope
During this inspection period, the inspectors observed several activities related to the power uprate amendment. Specific activities are documented below, and as referenced:
- Section 1R15-This section documents specific inspector reviews of extended power uprate (EPU) activities associated with operability evaluation for EPU Level 1 curve being exceeded; and
- Section 1R22-This section documents specific inspector reviews of EPU activities associated with Mella+ license requirement implementation activities.
b. Findings
No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On October 8, 2014, the inspectors presented the inspection results to Site Vice President Karen Fili, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
.2 Interim Exit Meetings
Interim exits were conducted for:
- The results of the Emergency Preparedness Program inspection were discussed with Mr. H. Hanson on July 11, 2014. The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.
- The inspection results for the areas of radiation monitoring instrumentation and Reactor Coolant System specific activity, occupational exposure control effectiveness, and Radiological Effluent Technical Specification/Offsite Dose Calculation Manual radiological effluent occurrences performance indicator verification with Mr. P. Gardner, Director, on August 8, 2014.
4OA7 Licensee-Identified Violations
The following violation of very low significance (Green) or Severity Level IV was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.
- Title 10 of the Code of Federal Regulations 50.54(q)(2) requires, in part, that a holder of a license under this part shall follow and maintain the effectiveness of an emergency plan that meets the requirements in 10 CFR Part 50, Appendix E, and the planning standards of 10 CFR 50.47(b). Title 10 CFR Part 50, Appendix E, Section IV.A.9 states, By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan, shall be included. Contrary to the above, on December 24, 2012, the licensees detailed analysis of on-shift staffing was deficient in that all assigned functions for on-site personnel were not evaluated. Specifically, the augmentation tasks identified in the licensees emergency plan assigned to on-shift personnel were not considered when performing A.2-002, Monticello On-Shift Staffing Analysis, for the Core/Thermal Hydraulics and Radiation Waste Operator positions.
The NRC determined that with no identified loss or degradation of a planning standard function, the failure to complete the detailed analysis in accordance with 10 CFR Part 50, Appendix E, Section IV.A.9 was a very low safety significance issue (Green) as indicated in IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Revision February 24, 2012.
This issue was identified in a self-assessment process on May 13, 2014, and documented in corrective action entries as action requests 01430607 and 0101437840. Immediate corrective actions included interim augmentation for both on-shift positions fully analyzing and updating the on-shift staffing analysis.
As such, the NRC determined this to be an NCV in accordance with Section 2.3.2 of the Enforcement Policy.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- K. Fili, Site Vice President
- H. Hanson, Jr., Plant Manager
- P. Albares, Operations Manager
- M. Lingenfelter, Director of Engineering
- K. Jepson, Recovery Manager
- S. Mattson, Maintenance Manager
- K. Petersen, Chemistry Manager
- C. England, Radiation Protection Manager
- D. Collins, Regulatory Affairs Manager (Interim)
- L. Anderson, Emergency Preparedness Manager
- H. Bjorseth, Business Planning Manager
- G. Brevig, Nuclear Oversight
- B. Carberry, Emergency Preparedness Coordinator
- D. Crofoot, Nuclear Oversight Supervisor
- K. Hougen, Emergency Preparedness Coordinator
- P. Kissinger, Productivity Planning Manager
- L. Narikawa, Emergency Preparedness Coordinator
- S. OConnor, Regulatory Affairs Analyst
- K. VanGrinsven, Emergency Preparedness Coordinator
- E. Weinkam, Nuclear Emergency Preparedness Director
- R. Zyduck, Design Engineering Manager
- T. Hedges, Radiation Protection General Supervisor
Nuclear Regulatory Commission
- K. Riemer, Chief, Reactor Projects Branch 2
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000263/2014004-01 NCV Failure to Follow Reactivity Management Procedure (Section 1R15)
Closed
- 05000263/2014004-01 NCV Failure to Follow Reactivity Management Procedure (Section 1R15)
Discussed
None.