IR 05000263/2024011

Biennial Problem Identification and Resolution Inspection Report 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: DPR-22

Report Number: 05000263/2024011

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

Enclosure

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 71152B Times of the 'A' Outboard MSIV 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 Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action 500000324985 Insufficient PO Requirements 01/26/2024

Documents 501000037221 2020 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 152-508 Failed to Close 12/06/2021

501000062642 Evaluate Lighting System A(1) Status 04/28/2022

501000069283 DIV II FSW Inlet Pipe Leak 12/16/2022

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 LTA CAP Closure Documentation 12/08/2023

501000080744 VD-9175B Failed to Open 01/10/2024

501000081107 V-EAC-14B Comp. Running Unexpectedly 01/22/2024

Inspection Type Designation Description or Title Revision or

Procedure Date

501000082361 Reactor SCRAM No. 142: ATWS Trip 02/28/2024

501000082683 RPV Bottom Head Cooldown Rate >100/hr 03/08/2024

501000082844 13 DGN 86 Lockout 03/14/2024

501000082844 13 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

Corrective Action 501000088660 2024 PIR - Cause Eval Process for LER 08/07/2024

Documents 501000088778 2024 PIR - Functional Loc. vs Label Disc 08/13/2024

Resulting from 501000088807 2024 PIR - Incorrect Proc Listed 08/13/2024

Inspection 501000089029 2024 PIR - CAP Level of Detail 08/19/2024

501000089094 2024 PIR - 1224 and OSP-FIR-1489 Discrepancy 08/20/2024

501000089141 2024 PIR - No Eval for AFFF Quantity 08/21/2024

501000089144 2024 PIR - Fire Foam Licensing Basis 08/22/2024

501000089186 2024 PIR - Potential NCV - MSIV PM 08/23/2024

501000089190 2024 PIR - 2019 Work Instructions 08/22/2024

Drawings NH-170037 Main Control Room CRV / EFT System 84

Engineering 0000027183 Outboard MSIV Internals Hardfacing Upgrades 1

Changes 601000000231 Add Hardfacing to Outboard MSIV Wedge Set 08/20/2019

601000003691 Replace Teledyne Emergency Lights 0

Miscellaneous Monticello Pulse Survey Results for June 2024

Xcel Energy Nuclear Safety Culture Assessment 2024 05/09/2024

A-OPS-MNGP-2024 Nuclear Oversight Monticello Nuclear Generating Plant 05/30/2024

24-1 Audit of Operations/Chemistry

EQ-A EQ Central File Part A Equipment Master List 29

EQ-PART-B EQ Central File Part B Environmental Specifications 14

71152B Miscellaneous IST-Basis Pump and Valve In-Service Testing Program Basis 11

IST-Plan 6th Pump and Valve In-Service Testing Program Plan 3

Interval

QF0250, Rev. 0 Procurement Engineer Evaluation of Purchase Requisition, 08/17/2023

(FP-SC-GEN-08) QSL Vendor Name: Framatome Inc.

QF0565 Maintenance Rule Functional and MSPI failure Evaluation 17

(Associated with CAP 501000077078)

QF0571 Troubleshooting Plan (Associated with CAP 501000077078) 9

Procedures 0187-2B 12 Emergency Diesel Generator/12 ESW Monthly Pump and 49

Valve Tests

266 Fire Pumps Simulated Auto-Actuation and Capability Test 69

1061 Emergency Lighting Quarterly Operability and Capacity Test50

4514-02 Outboard MSIV Disassembly and Reassembly 32

4514-02A Outboard MSIV - Assembly of New Stem and Disc Pack 2

FG-PA-EVAL-01 Evaluation Methods 7

FP-E-RTC-02 Functional Location Classification 24

FP-EC-ECP-01 Employee Concerns Program 11

FP-MA-REW-01 Rework Program 7

FP-NO-AUD-01 Internal Audits 15

FP-OP-OL-01 Operability 22

FP-PA-APR-01 CAP Process 64

FP-PA-ARP-03 Management of Change (MOC) Process 18

FP-PA-EFR-01 Effectiveness Review Manual 5

FP-PA-OE-01 Operating Experience Program 34

FP-PA-PAR-01 Performance Assessment Review Board and Performance 20

Assessment Oversight

FP-PA-RMS-01 Risk Management Screening 2

Self-Assessments A-OPS-MNGP-2024 Nuclear Oversight Monticello Nuclear Generating Plant 2024

24-1 Audit of Operations/Chemistry

Work Orders 7000091294 Perform 0255-07-IA-2, ALL STEPS 04/17/2023

700034229 AO-2-86A Repl. Disc Trunnion Pins 01/14/2020

71152B Work Orders 700089154 AO-2-86A, As Found Diagnostic Test 04/27/2021

700095862-0010 Air Quality Test for the Instrument Air System 22

700112844 AO-2-86C, Perform 4514-02 (Parts B-N) 01/04/2023

700122542 AO-2-86A As Left Diagnostic Test 04/26/2023

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