IR 05000263/2018001
| ML18108A389 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 04/18/2018 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B2 |
| To: | Church C Northern States Power Company, Minnesota |
| References | |
| IR 2018001 | |
| Download: ML18108A389 (22) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ril 18, 2018
SUBJECT:
MONTICELLO NUCLEAR GENERATING PLANTNRC INTEGRATED INSPECTION REPORT 05000263/2018001
Dear Mr. Church:
On March 31, 2018, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Monticello Nuclear Generating Plant. On April 11, 2018, the NRC inspectors 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.
Based on the results of this inspection, the NRC has identified one issue that was evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has also determined that one violation is associated with this issue.
Because the licensee initiated condition reports to address this issue, this violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy.
The NCV is described in the subject inspection report. Further, inspectors documented a licensee-identified violation which was determined to be Severity Level IV in this report. The NRC is treating this violation as a NCV consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at the Monticello Nuclear Generating Plant.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC resident inspector at the Monticello Nuclear Generating Plant. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Docket No. 50-263;72-058 License No. DPR-22 Enclosure:
Inspection Report 05000263/2018001 cc: Distribution via ListServ
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensee performance by conducting an integrated quarterly inspection at the 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. NRC and self-revealed findings, violations, and additional items are summarized in the table below.
Licensee-identified non-cited violations are documented in report section: 71153Follow-Up of Events and Notices of Enforcement Discretion.
List of Findings and Violations Failure to Follow Procedure for Storage of Equipment Near Safety-Related Equipment Cornerstone Significance Cross-Cutting Report Section Aspect Mitigating Systems Green [H.5] - Work 71111.04 NCV/2018001-01 Management Closed The inspectors identified a finding of very low safety significance (Green) with an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 50,
Appendix B Criterion V for the failure to accomplish activities affecting quality as prescribed by documented procedures. Specifically, the licensee failed to follow procedure 4 AWI-04.02.01,
Housekeeping for storage of items or equipment near safety-related equipment. On two separate occasions, the inspectors identified items being stored near safety-related equipment that did not comply with procedure requirements.
Additional Tracking Items Type Issue Number Title Report Status Section LER 05000263/2015-004-01 Past Inoperability of Turbine Stop 71153 Closed Valve Scram Function Exceeded (Other Technical Specification Activities
-
Requirements Baseline)
LER 05000263/2017-004-00 High Pressure Coolant Injection 71153 Closed Steam Stop Valve Failed to Open (Other During Test Activities
-
Baseline)
LER 05000263/2017-005-00 Diesel Generator Emergency 71153 Closed Service Water System Automatic (Other Transfer to Alternate Shutdown Activities
-
Panel Baseline)
LER 05000263/2017-006-00 Loss of Reactor Protection System 71153 Closed Scram Function During Main (Other Steam Isolation Valve and Turbine Activities
-
Stop Valve Channel Functional Baseline)
Tests Due to Use of a Test Fixture
TABLE OF CONTENTS
PLANT STATUS
...........................................................................................................................
INSPECTION SCOPES
................................................................................................................
REACTOR SAFETY
..................................................................................................................
RADIATION SAFETY
................................................................................................................
OTHER ACTIVITIES - BASELINE
............................................................................................
INSPECTION RESULTS
..............................................................................................................
EXIT MEETINGS AND DEBRIEFS
............................................................................................ 14
DOCUMENTS REVIEWED
......................................................................................................... 14
PLANT STATUS
Monticello began the inspection period operating at approximately 100 percent power and
operated at or near full power for the reminder of the inspection period, with the following
exceptions. Power was subsequently returned to 100 percent after completion of each activity.
- March 9, 2018Power was reduced to approximately 98 percent for a control rod
pattern adjustment;
- March 24, 2018Power was reduced to approximately 73 percent for control rod scram
time testing and quarterly turbine testing; and
- March 29, 2018Power was reduced to approximately 91 percent for a control rod
pattern adjustment.
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 performed plant status activities described in
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem
Identification and Resolution. 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.
REACTOR SAFETY
71111.01Adverse Weather Protection
Seasonal Extreme Weather (1 Sample)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the
onset of seasonal cold temperatures on January 10, 2018.
Impending Severe Weather (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions for predicted
heavy snowfall and high wind conditions on January 21, 2018.
71111.04Equipment Alignment
Partial Walkdown (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) A Emergency Diesel Generator Train during B Train Maintenance on January 4, 2018;
(2) Screenwash and Electric-Driven Fire Pumps during Fire Protection Piping Replacement
on January 17, 2018; and
(3) 11 Core Spray Line-up after System Surveillance on March 14, 2018.
71111.05AQFire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Control Room (Fire Zone 9) on January 30, 2018;
(2) Lower 4 Kilovolt Room (Fire Zone 12-A) on February 14, 2013;
(3) Reactor Building 985 Corridor North (Fire Zone 04-C) on February 15, 2018;
(4) High Pressure Coolant Injection (HPCI) Room (Fire Zone 01-E) on February 1, 2018;
and
(5) 12 Residual Heat Removal/Core Spray (RHR/CS) Room (Fire Zone 01-A) on
February 1, 2018.
Annual Inspection (1 Sample)
The inspectors evaluated fire brigade performance on February 24, 2018.
71111.06Flood Protection Measures
Internal Flooding (1 Sample)
The inspectors evaluated internal flooding mitigation protection in the Reactor Core Isolation
Cooling (RCIC) and HPCI rooms on February 15, 2018.
71111.07Heat Sink Performance
Heat Sink (1 Sample)
The inspectors evaluated RHR Heat Exchanger Efficiency Testing on February 13, 2018.
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated SEG # RQ-SS-15 (Bus 16 lockout with loss of CRD
causing high power Automatic Transient Without Scram with turbine trip) on February 12, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated control room activities with a downpower to 73 percent
for a control rod pattern adjustment and quarterly turbine valve testing on March 24, 2018.
71111.12Maintenance Effectiveness
Routine Maintenance Effectiveness (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the following equipment and/or safety significant functions:
(1) Secondary Containment Door Seals on March 24, 2018; and
(2) Electrical Hot Spots in Reactor Protection System (RPS) Circuitry on March 30, 2018.
71111.13Maintenance Risk Assessments and Emergent Work Control (3 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) B Control Room Ventilation Compressor V-EAC-14B trip on February 1, 2018;
(2) 14A Feedwater Heater vent steam leak on February 9, 2018; and
(3) DPIS-2-119D Main Steam "D" Hi Flow Isolation, on March 14, 2018.
71111.15Operability Determinations and Functionality Assessments (5 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Pallet stored on High Energy Line Break (HELB) Turbine Deck hatch on
February 20, 2018;
(2) Secondary Containment Door 85 Has Hole in Door Frame on March 22, 2018;
(3) H2O2 Analyzer "B" Non-Functional on March 23, 2018;
(4) Diesel Fire Pump Packing Leakage on March 29, 2018; and
(5) 12 RHR Pump Inoperable due to Low Differential Pressure on March 29, 2018.
71111.18Plant Modifications (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1) EC 601000000029 Cooling Tower temporary modification on February 22, 2018.
71111.19Post Maintenance Testing (6 Samples)
The inspectors evaluated the following post maintenance tests:
(1) 12 Reactor Protection System Motor Generator Post Maintenance Test (PMT) on
January 30, 2018;
(2) B CRV Compressor PMT on February 9, 2018;
(3) 0255-11-II-3 13 Essential Service Water Quarterly Pump and Valve Tests on
February 6, 2018;
(4) 0255-06-IA-1; HPCI MO-2034 & 2035 Cycle Testing on March 19, 2018;
(5) HPCI Turbine Driven Oil Pump Discharge Press, Ops: PI-7258 PMT, on March 19,
2018; and
(6) 14 RHR Motor Cooler PMT on March 27, 2018.
71111.22Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (3 Samples)
(1) 11 125V Direct Current Battery Testing on January 4, 2018;
(2) Turbine Stop Valve Scram Test on March 24, 2018; and
(3) SCT-0550 Secondary Containment Isolation Damper Test on February 22, 2018.
In-service (1 Sample)
(1) 0141 and 0255-10A-4 Torus Vacuum Breaker Operability/Exercise Tests on
January 8, 2018.
Reactor Coolant System Leak Detection (1 Sample)
(1) 0385-A Drywell Particulate Monitor Functional Test on February 22, 2018.
71114.06Drill Evaluation
Drill/Training Evolution (1 Sample)
The inspectors evaluated SEG# RQ-SS-62 as a training evolution on March 19, 2018.
RADIATION SAFETY
71124.01Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (1 Sample)
The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers (1 Sample)
The inspectors evaluated worker instructions.
Contamination and Radioactive Material Control (1 Sample)
The inspectors evaluated contamination and radioactive material controls.
Radiological Hazards Control and Work Coverage (1 Sample)
The inspectors evaluated radiological hazards control and work coverage.
High Radiation Area and Very High Radiation Area Controls (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area
controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician
proficiency.
OTHER ACTIVITIESBASELINE
71151Performance Indicator Verification (5 Samples)
The inspectors verified licensee performance indicators submittals listed below:
(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (1/1/2017-12/31/2017);
(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample
(1/1/2017-12/31/2017);
(3) IE04: Unplanned Scrams with Complications (USwC) Sample (1/1/2017-12/31/2017);
(4) OR01: Occupational Exposure Control Effectiveness Sample (1/1/2017-12/31/2017);
and
(5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences
Sample (1/1/2017-12/31/2017).
71152Problem Identification and Resolution
Annual Follow-Up of Selected Issues (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
(CAP) related to the following issues:
(1) CAP 501000000363 (Slight Rise in Drywell Unidentified Leakage) and CAP
501000002977 (Drywell Floor Sump Rate of Change Rising Trend) associated with an
increasing drywell unidentified leakage trend on March 12, 2018.
71153Follow-Up of Events and Notices of Enforcement Discretion
Events (1 Sample)
The inspectors evaluated CAP 501000009895 (Opened CW-16 Early During 8293) and
the licensees actions for an event on March 23, 2018, associated with degraded circulating
water intake level conditions due to opening de-icing line valve CW-16 during main
condenser amertap activities.
Licensee Event Reports (4 Samples)
The inspectors evaluated the following licensee event reports which can be accessed at
https://lersearch.inl.gov/LERSearchCriteria.aspx:
(1) Licensee Event Report (LER) 05000263/2015-004-001, Past Inoperability of Turbine
Stop Valve Scram Function Exceeded Technical Specification Requirements on
January 18, 2018;
(2) LER 05000263/2017-004-00, High Pressure Coolant Injection Steam Stop Valve
Failed to Open During Test on January 4, 2018;
(3) LER 05000263/2017-005-00, Diesel Generator Emergency Service Water System
Automatic Transfer to Alternate Shutdown Panel on January 4, 2018; and
(4) LER 05000263/2017-006-00, Loss of Reactor Protection System Scram Function
During Main Steam Isolation Valve and Turbine Stop Valve Channel Functional Tests
Due to Use of a Text Fixtures on February 26, 2018.
INSPECTION RESULTS
71111.04Equipment Alignment
Failure to Follow Procedure for Storage of Equipment Near Safety-Related Equipment
Cornerstone Significance Cross-Cutting Aspect Report Section
Mitigating Systems Green [H.5] - Work 71111.04
NCV 05000263 Management
/2018001-01
Closed
The inspectors identified a finding of very low safety significance (Green) with an associated
NCV of 10 CFR 50 Appendix B Criterion V for the failure to accomplish activities affecting
quality as prescribed by documented procedures. Specifically, the licensee failed to follow
procedure 4 AWI-04.02.01, Housekeeping for storage of items or equipment near operable
safety-related equipment. On two separate occasions, the inspectors identified items being
stored near operable safety-related equipment did not comply with procedure requirements.
Description:
On January 17, 2018, the inspectors identified a concern regarding material stored, located
on an un-chocked cart, within 3 feet of the safety-related A Residual Heat Removal Service
Water (RHRSW) piping. The material consisted of six pipe sections approximately 6 to 12
long by 10 diameter located, in some cases, 6 from operable safety-related equipment in the
Intake Building, a Class 1 structure.
Inspector review of procedure 4 AWI-04.02.01, Housekeeping, Revision 28 determined, in
part, the licensee established, in part, the following requirements for storage of items or
equipment that are not restrained or secured to prevent or minimize movement during a
seismic event:
1) 4.3.1.B - Loose material shall be stored at least three feet from any operable safety-
related equipment;
2) 4.3.1.C - Any freestanding item susceptible to toppling toward safety-related
equipment shall be stored a distance of at least the items height + 3 feet from the
safety-related equipment; and
3) 4.3.1.E - Carts or other equipment mounted on wheels or casters within Class 1
structures shall have their wheels chocked or be equivalently restrained to prevent
undesirable movement during a seismic event.
The inspector-identified issues did not comply with the above licensee requirements. The
licensee initiated CAP 501000007386 documenting the issues, which included staged piping
stored underneath and within 6 of operable safety-related A RHRSW piping, a 6 pipe
section staged on a cart with no wheel chocks, and scaffolding material staged under the A
RHRSW basket strainer.
As part of licensee follow-up to CAP 501000007386, licensee plant walkdowns identified four
additional instances where items or equipment were inappropriately stored near safety-related
equipment during the period of January 17, 2018 through February 19, 2018. These
included:
1) January 24, 2018 - Nuclear Oversight walkdown identified freestanding equipment in
the 962 elevation Reactor Building Operations Engineering room due to its proximity
to cable trays XA511 and VA311 containing safety-related cables (Reactor Pressure
Wide Range, Reactor Vessel Level, and Drywell Pressure Wide & Narrow Range).
The height to width ratio requirements of 4 AWI-04.02.01 Section 4.3.1.C and
clearance requirements of Section 4.3.1 were not met. CAP 501000007618
documented this issue.
2) January 31, 2018 - A few items on the 962 elevation of the Reactor Building were
identified within 3 feet of cable tray TA308 containing safety-related cable (RHR Valve
Opening Permissive). The clearance requirements of 4 AWI-04.02.01 Section 4.3.1
were not met. CAP 501000007910 documented this issue.
3) February 19, 2018 - A power pack was staged on the 1001 elevation of the Reactor
Building within topple distance of safety-related cable trays XA512 and VA313. Also,
a large amount of equipment for closed cooling water heat exchanger flushing is
stored within topple distance of cable trays XA512 and VA313. The height to width
ratio requirements of 4 AWI-04.02.01 Section 4.3.1.C were not met. CAP
501000008594 documented this issue.
4) March 2, 2018 - A whole body contamination monitor was found to be within the
topple distance of the safety-related 11 RHR Auxiliary Air Compressor. The height
to width ratio requirements of 4 AWI-04.02.01 Section 4.3.1.C were not met.
CAP 501000009091 documented this issue.
On March 27, 2018, the inspectors conducted a follow-up walkdown of the Reactor Building
and identified two additional instances where items or equipment were inappropriately stored
near operable safety-related equipment.
1) March 27, 2018 - A test stand on the 985 elevation of the Reactor Building was within
topple distance of cable tray sections TB312 & TB311 which contains a safety-related
power cable for C87A (A Standby Gas Treatment Panel).
2) March 27, 2018 - Flammable cabinet PSCC-03 was within 3 feet of safety-related
panel N3211 (V-EF-21 Redundant Contactor). The height to width ratio requirements
of 4 AWI-04.02.01 Section 4.3.1.C and clearance requirements of Section 4.3.1 were
not met. CAP 501000010017 documented these two issues.
Corrective Actions: Immediate corrective actions for each issue included proper storage of
the items or equipment per established requirements. Also, due to the multiple issues
identified, the licensee initiated CAP 501000008778, Inappropriately Staging Equipment, to
document an adverse trend.
Corrective Action References: CAPs 501000007386, 501000007618, 501000007910,
501000008594, 501000008778, 501000009091, and 501000010017
Performance Assessment:
Performance Deficiency: The inspectors concern regarding storage of items or equipment
near operable safety-related equipment was determined to be a performance deficiency due
to the failure to meet a standard (4 AWI-04.02.01, Section 4.3.1) and the issue was
reasonably within the licensees ability to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor
because if left uncorrected, the unsecured equipment would have the potential to lead to a
more significant safety concern. Specifically, improper storage of unrestrained items or
equipment could impact operable safety-related equipment during a design basis seismic
event. Additionally, Inspection Manual Chapter (IMC) 0612, Appendix E, Example 4.a,
establishes that low-level procedural errors without a safety consequence are more than
minor when they become a repetitive/routine occurrence.
Significance: The inspectors evaluated the significance of the finding in accordance with IMC 0609, Attachment 4, Table 2 and the finding was determined to affect the Mitigating Systems
Cornerstone. The inspectors answered No to the questions in Table 3, SDP Appendix
Router, and continued the significance evaluation in accordance with IMC 0609, Appendix A.
The inspectors answered No to the Mitigating Systems Screening Questions contained in
Exhibit 2 and determined the finding was of very low safety significance (Green).
Cross-Cutting Aspect: The finding had a cross-cutting aspect in the Work Management
component of the Human Performance cross-cutting area, which states that the licensee will
implement a process of planning, controlling, and executing work activities such that nuclear
safety is the overriding priority. The work process includes the identification and management
of risk commensurate to the work and the need for coordination with different groups or job
activities. Specifically, the licensee did not control work activities such that nuclear safety was
an overriding priority due to the multiple issues of improper storage of unrestrained items or
equipment near operable safety-related equipment. (H.5)
Enforcement:
Violation: Title 10 CFR 50, Appendix B Criterion V requires that activities affecting quality
shall be accomplished in accordance with documented instructions, procedures or drawings
appropriate to the circumstances. Licensee procedure 4 AWI-04.02.01, Housekeeping
established requirements for the storage of items or equipment that are not restrained or
secured to prevent or minimize movement during a seismic event. Specifically, section
4.3.1.B requires loose material to be stored at least three feet from any operable safety-
related equipment. Section 4.3.1.C requires freestanding items susceptible to toppling toward
safety-related equipment to l be stored a distance of at least the items height plus 3 feet from
the safety-related equipment. Lastly, Section 4.3.1.E requires carts or other equipment
mounted on wheels or casters within Class 1 structures to have their wheels chocked or be
equivalently restrained to prevent undesirable movement during a seismic event.
Contrary to the above, from January 17, 2018 through March 27, 2018, the licensee stored
unrestrained items or equipment near operable safety-related equipment.
Disposition: This violation is being treated as a Non-Cited Violation, consistent with
Section 2.3.2 of the Enforcement Policy.
71152Problem Identification and Resolution
Observation 71152
No findings/weaknesses: Through review of the licensees Corrective Action Program (CAP),
the inspectors recognized an increasing drywell unidentified leakage trend. The inspectors
selected condition reports 501000000363, Slight Rise in Drywell Unidentified Leakage, and
501000002977, Drywell Floor Sump ROC Rising trend to ensure implementation of the CAP
adequately supported nuclear safety.
The licensee initiated CAP 501000000363 to document a slight rise in drywell unidentified
leakage on July 5, 2017 and CAP 501000002977 for drywell floor sump rate of change rising
trend on September 23, 2017. As appropriate, the inspectors verified corrective action
program attributes (problem identification, evaluation/prioritization, operability, reportability,
extent of condition, and completion/effectiveness of corrective actions) associated with these
and other condition reports. The inspectors discussed the corrective actions and associated
evaluations with licensee personnel.
Overall the inspector review concluded the licensee adequately implemented its corrective
action process. Inspectors determined that a slow on-going increase in drywell unidentified
leakrate has occurred since mid-September 2017. Specifically, the leakrate has increased
from approximately 0.08 gallons per minute (gpm) in mid-September 2017 to approximately
0.200 gpm in late March 2018. Although the increasing leakrate has, and continues, to occur
the inspectors verified the existing leakrate is well below the Technical Specification and
licensee self-imposed unit shutdown limits of 5 gpm and 2.5 gpm, respectively. Inspector
review of the trend rate from mid-September 2017 through March 2018 concluded that neither
of these limits would be reached prior to the next licensee refueling outage, given a similar
trend rate throughout the remainder of the operating cycle.
The inspectors reviewed licensee actions to identify the cause of the increased leakrate.
Specifically, the licensee had backseated several inboard isolation valves, investigated
potential leakage from both residual heat removal drywell spray headers, monitored changes
in leakrate during planned control rod scram surveillance activities, and evaluated isotopes as
part of drywell floor drain sample testing. Other actions taken by the licensee included
increased awareness and monitoring through the adverse condition monitoring program and
implementing the operational decision making process in relation to a drywell entry. The
inspectors determined licensee actions to document, monitor, and investigate the source of
increased unidentified leakage have been adequate. The inspectors will continue to monitor
both leakage and trend rates and licensee actions.
71153Follow-Up of Events and Notices of Enforcement Discretion
Licensee Identified Non-Cited Violation 71153
This violation of very low safety significant was identified by the licensee and has been
entered into the licensee corrective action program and is being treated as a Non-Cited
Violation, consistent with Section 2.3.2 of the Enforcement Policy.
Enforcement:
Violation: Title 10 CFR 50.59(d)(1) requires, in part, that the licensee maintain records of
changes to the facility, of changes in procedures, and of tests and experiments made
pursuant 10 CFR 50.59(c). These records must include a written evaluation which provides
Licensee Identified Non-Cited Violation 71153
the bases for the determination that the change, test, or experiment does not require a license
amendment pursuant to Paragraph (c)(2) of this section.
Title 10 CFR 50.59(c)(2)(ii) requires that a licensee shall obtain a license amendment
pursuant to 10 CFR 50.90 prior to implementing a proposed change, test, or experiment if the
change, test, or experiment would result in more than a minimal increase in the likelihood of
occurrence of a malfunction of a structure, system, or component important to safety
previously evaluated in the Final Safety Analysis Report (FSAR) (as updated).
Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation,
states the RPS instrumentation for each function in Table 3.3.1.1-1 shall be operable. As
specified in Table 3.3.1.1-1, Function 5, Main Steam Isolation Valve (MSIV) - Closure (8
channels) and Function 8, Turbine Stop Valve (TSV) - Closure (4 channels) are required to
be operable in Mode 1. TS 3.3.1.1, Condition C.1 states with one or more functions with RPS
trip capability not maintained, to restore RPS trip capability in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and was applicable to
both the MSIV and TSV RPS logic functional testing.
Contrary to the above, on March 7, 2009 and July 11, 2009, the licensee failed to perform and
maintain a written evaluation as required by 10 CFR 50.59(d)(1) to demonstrate a change to
its facility did not require a license amendment. Specifically, the licensee incorrectly
concluded in its 10 CFR 50.59 evaluation SCR-08-0319, dated September 29, 2008, that no
license amendment was required prior to implementing two surveillance test procedures;
0009 Turbine Stop Valve Closure Scram Test Procedure, Revision 16 on March 7, 2009
and; 0008 Main Steam Line Isolation Valve Closure Scram Test Procedure, Revision 20 on
July 11, 2009. The test fixture was applied during quarterly surveillance testing through
September 16, 2017.
Implementation of procedures 0008 and 0009, respectively, resulted in the loss of RPS trip
Function 5 (MSIV) and Function 8 (TSV) by bypassing more than the TS minimum allowed
inputs per channel to maintain functionality, thereby violating the requirements of TS 3.3.1.1.
Loss of these functions resulted in more than a minimal increase in the likelihood of
occurrence of a malfunction of a structure, system, or component important to safety
previously evaluated in the FSAR (as updated) as specified by 10 CFR 50.59(c)(2)(ii).
On November 14, 2017, the licensee generated CAP 501000005391 after conducting an
operating experience evaluation of a similar event at another station concluding the event was
applicable to the Monticello Plant. The surveillance procedures were immediately
quarantined and subsequently revised on December 8, 2017 and December 11, 2017, to
remove the use of the RPS test fixture.
Significance/Severity Level: Using IMC 0609, Appendix A, Exhibit 2, the inspectors
determined this finding was of very low safety significance (Green) because it did not affect a
single RPS trip signal to initiate a reactor scram and the function of other redundant trips or
diverse methods of reactor shutdown.
The ROPs significance determination process does not specifically consider the regulatory
process impact in its assessment of licensee performance. Therefore, it is necessary to
address this violation which impedes the NRCs ability to regulate using traditional
enforcement to adequately deter non-compliance. In accordance with Section 6.1.d.2 of the
NRC Enforcement Policy, this violation was categorized as Severity Level IV.
Licensee Identified Non-Cited Violation 71153
The disposition of this violation closes LER 05000263/2017-006-00.
Corrective Action Reference: 501000005391
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public
disclosure. No proprietary information was documented in this report.
- On February 16, 2018, the inspector presented the radiological hazard assessment,
exposure control and performance indicator verification inspection results to Mr.
Director of Site Operation, and other members of the licensee staff.
- On April 11, 2018, the inspectors presented the 2018 1st Quarter Integrated inspection
results to Mr.
- C. Church, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
71111.01Adverse Weather Protection
- 1444; Pre and Post Severe Weather Inspection Checklist; Revision 15
- A.6; Acts of Nature; Revision 56
71111.04SQEquipment Alignment
- 2102; Plant Prestart Checklist Fire Protection System; Revision 5
- 2154-11; Core Spray System Pre-start Valve Checklist; Revision 25
- 2154-27; Fire Protection System Prestart Valve Checklist; Revision 35
- 4 AWI-04.02.01; Housekeeping; Revision 28
- CAP 501000007386; NRC Identified Housekeeping Issues
- CAP 501000007402; FP-12 Sealed Closed with Wrong Seal
- CAP 501000007618; NOS: FLEX RB 962 OpsEng Room Housekeeping
- CAP 501000007910; 962 Maintenance Storage Housekeeping
- CAP 501000008594; Equipment Near Safety Related Cable Tray
- CAP 501000008778; Trend: Inappropriately Staging Equipment in Plant
- CAP 501000009091; Equipment too Close to Safety Related Equipment
- CAP 501000010017; Housekeeping/Unsecured Material Question
- NH-36665; P&ID Service Water System & Make Up Intake Structure; Revision 101
- NH-36666; P&ID Screenwash, Fire, Chlorinating System Intake Structure; Revision 93
- NH-36248; P&ID Core Spray System; Revision 80
71111.05AQFire Protection Annual/Quarterly
- 2176; Fire Drill Procedure; Revision 32
- A.3-01-A Strategy; Fire Zone 1 A - 12 RHR & Core Spray Pump Room; Revision 9
- A.3-01-E Strategy; Fire Zone 1 E - HPCI Room; Revision 8
- A.3-02-C; Fire Brigade Drill Guide, Drill P-60B; 02/24/2018
- A.3-02-C Strategy; Fire Zone 2 C - West HCU Area; Revision 13
- A.3-04-C Strategy; Fire Zone 4 C - Rx Bldg Corridor, 985 EL; Revision 5
- A.3-09 Strategy; Fire Zone 9 - Control Room; Revision 10
- A.3-12-A Strategy; Fire Zone 12 A - Lower 4KV Bus Area; Revision 18
- C.4.B.08.05.A; Plant Fire; Revision 33
- C.6-300-A-07; Alarm Response Procedure, 7 Trouble - SIL; Revision 2
71111.06Flood Protection Measures
- Calculation 07-035; Internal Flooding Analysis; Revision 0
- DBD-T.08; Internal Flooding; Revision 4
- DB-S.01; Reactor Building; Revision 6
- DBD-S.06; Turbine Building; Revision 5
- DBD-T.06; High Energy Line Break; Revision 6
- USAR 01.03; Section 1, Introduction and Summary; Revision 32
71111.07AHeat Sink Performance
- 1136; RHR Heat Exchanger Efficiency Test; Revision 36
- B.03.04-05; Operations Manual, Residual Heat Removal System; Revision 85
- NX-7905-62; Residual Heat Removal System; Revision 10
- WO 700014460-0010; 1136 RHR Heat Exchanger Efficiency Test; 02/13/2018
71111.11QLicensed Operator Requalification Program and Licensed Operator Performance
- 2300; Reactivity Adjustment, C29; 03/24/2018
- SEG# RQ-SS-15E; Bus 16 Lockout with Loss of CRD Causing High Power ATWS with
Turbine Trip; Revision 1
- C.2-05.B.2; Ops Man, Power Operations, Power Adjustments ; Revision 70
71111.12Maintenance Effectiveness
- 1216-01; Fire Door Inspections; Revision 59
- 1297-01; Secondary Containment Door Interlock Check; Revision 20
- 3448; Fuse Replacement Information Form; Revision 11
- 8136-04; Secondary Containment Penetration Work Control Checklist; Revision 20
- C-157D, 03.01.2018; Thermography Report; 03/01/2018
- CAP 501000006227; S-1 Boiler Panel Hot Spot Detected
- CAP 501000008721; Door 90 Starting to Crack by Latch
- CAP 501000008932; Hot Spot Detected in C-17
- CAP 501000008943; Hot Spot Detected in C-15
- CAP 501000008947; Bottom Seal for Door 78 has Tear
- CAP 501000008973; Door 73 Hinge Seal Leakage
- CAP 501000009053; Slight Hot Spot Detected in C-157 D HCU
- CAP 501000009282; Identical Fuse not Available for WO
- CAP 501000009303; Hot Spot in C-15 Fuse Column
- CAP 501000009347; Door 49 Small Hole in the Door Seal
- CAP 501000009355; Door 73 has a Small Leak in the Seal
- CAP 501000009377; Door 78 Seal Hole/Paint Cracking
- NF-36954; Connection Diagram Scram Solenoid Fuse Panels C157A Thru C157H; Revision 2
- NX-7828-35-2; Panel 9-15 Connection Diagram; Revision 80
- NX-7834-67-12; Elementary Diagram Reactor Protection System; Revision H
- WO 700035648; Fuse for RPS Ch A Group 2 SCRAM SVS; 03/20/2018
- WO 700035655; Rx Bldg 962 MG Set Room Airlock - North, Replace Seal; 03/13/2018
- WO 700035745; FINM-Door 78, Replace Seal; 03/07/2018
- WO 700035756; HCU-10-27 SCRAM Pilot SV-117 Fuse; 03/02/2018
- WO 700036177; Rx Bldg/RW Bldg Airlock South Door Investigate/Repair; 03/10/2018
- WO 700036178; Rx Bldg 962 MG Set Room Airlock - East Investigate/Repair; 03/11/2018
71111.13Maintenance Risk Assessments and Emergent Work Control
- 1424-00016-01; 40666202, Steam Sealing Calculations; Revision 2
- 7010; Main Steam High Flow Group 1 Isolation Instrument Time Response Test; Revision 10
- B.08.13-05; Ops Man Control Room H&V and EFT; Revision 33
- CAP 500001133511; DPIS-2-117B, B MS Line Flow Gauge Noisy
- CAP 500001405740; High Oscillations of DPIS-2-116D Causing Out-Of-Band Reading
- CAP 501000007768; V-EAC-14B Compressor Not Operating
- CAP 501000009234; Main Steam D High Flow d/P Erratic
- CCN 26182-02; Setting Breaker Instantaneous Trip Higher; 01/31/2018
- EC 601000000455; Change Package, Leak Seal for E-14A FW Heater Vent Line; Revision 1
- NX-17435; Teledyne Snubber; Revision 0
- Station ALARA Committee Meeting Minutes; 02/12/2018
- Technical Specification 3.3.6.1; Primary Containment Isolation Instrumentation;
Amendment 146
- WO 00562011; Increase Dampening on MS Line High Flow Indicating Switches; 04/10/2017
- WO 7000034035; FINE-V-EAC-14B, Troubleshoot; 01/29/2018
- WO 700003608; "B" CRV Compressor Trip (V-EAC-14B); 02/02/2018
- WO 700034741; 14A Heater Vent Line; 02/23/2018
71111.15Operability Determinations and Functionality Assessments
- 0261; Fire Pump Exercise and Fuel Quantity Check; Revision 57
- 0430; Containment H2/O2 Analyzers; Revision 35
- B.08.05-06; Ops Man Fire Protection; Revision 70
- CAP 501000007179; Diesel Fire Pump Packing Leakage
- CAP 501000008597; Pallet on HELB Hatch 1/TB
- CAP 501000009801; Door-85 has Holes in Door Frame
- CAP 501000009802; Panel Meter Does Not Match Recorder/Computer
- CAP 501000010105; 12 RHRSW Pump Low Differential Pressure
- EC 22748; Justify Hatch 1 on the Turbine Deck can be Blocked; Revision 0
- EC 22871; Hatch 1 on Turbine Deck Structural Capability for HELB; Revision 0
- NF-36030; Turbine Building Operating Floor Plan, EL 951-0; Revision 78
- NF-36069; Turbine Building-Mezzanine Floor, EL 931-0; Revision 80
- NH-36666; P&ID Screen Wash, Fire and Chlorination System Intake Structure; Revision 92
- NH-91197; P&ID, Containment Atmosphere Monitoring System; Revision 78
- NX-63636; Yokogawa DAQSTATION DX1000/DX1000N Users Manual; Revision 0
- WO 700024951; 0431 Containment H2/O2 Analyzers Sensor Check; 03/20/2018
- WO 700033453; Diesel Fire Pump; 03/26/2018
71111.18Plant Modifications
- CAP 500001560615; Fault Current Exceeds Breaker Interrupting Rating
- CAP 501000008701; Temp Power to P-50 Failed
- Calculation 14-020, Auxiliary Power System Analysis; Revision 0
- EC-601000000029, Cooling Tower T-Mod, P-50; Revision 0
- EC-601000000029, Cooling Tower T-Mod, P-50; Revision 1
- NE-36170-8; Discharge Structure Misc. Controls; Revision 77
- NE-36492-2; Cooling Tower Fan 480V LC #105 and #106 Main Breaker Control;
Revision 75
- WO 00545094; 316-B, Install Temp Power; 03/29/2017
- WO 0119512; PM LC-106 Cubicles and Bus; 11/15/2011
- WO 700035309; Power Panel P-50 (W Cooling Tower Control House); 02/27/2018
71111.19Post Maintenance Testing
- 0255-06-IA-1; HPCI Quarterly Pump and Valve Tests; Revision 101
- 0255-11-III-3; 13 ESW Quarterly Pump and Valve Tests; Revision 58
- 1339; ECCS Pump Motor Cooler Flush; 03/27/2018
- 4058-02-OCD; RHR Pump 12 and 14, and Core Spray 12 Motor Cooler Chemical Cleaning
and Pressure Test; 03/27/2018
- 4822-PM; Reactor Protection System Motor Generator Set Maintenance Procedure;
01/25/2018
- CAP 501000007710; OOVR and 4K Outside of As Found
- CAP 501000007768; V-EAC-14B Compressor Not Operating
- WO 700009464-0060; PMT SW30A-2-HBD; Revision 2
- WO 700009810; HPCI Turbine Driven Oil Pump Discharge Pressure; 03/19/2018
- WO 700013630; 12 RPS MG Set; 01/30/2018
- WO 700020819; P-202D, PMT/RTS; 03/27/2018
- WO 700021107-0010; 0255-06-IA-1 HPCI Quarterly Pump and Valve Tests; 03/19/2018
- WO 700034035; OPS-V-EAC-14B/Comp, RTS-PMT; 01/29/2018
71111.22Surveillance Testing
- 4 AWI-09.04.00; Inservice Inspection Licensee Control Program; Revision 9
- 0009; Turbine Stop Valve Closure Scram Test; Revision 29
- 0141; Reactor Building to Torus Vacuum Breaker Operability Check; Revision 37
- 0255-10-IA-4; Reactor Building to Torus Vacuum Breaker Mechanical Exercise Test;
Revision 23
- 0385-A; Drywell Particulate Monitor Functional Test; Revision 24
- CAP 501000007120; NRC Questions During 0255-10-IA-4
- OSP-SCT-0550; Secondary Containment Isolation Damper Testing; Revision 9
- WO 700014173; Reactor Protection System, Turbine Stop Valve; 03/24/2018
- WO 700014641-0010; 0255-10-IA-4; Reactor Building to Torus Vacuum Breaker Mechanical
Exercise Test; 01/10/2018
- WO 700014150; Drywell Particulate Monitor; 02/22/2018
- WO 700016931; ESP-125-0614-01; 11 125V DC Battery Operability Check; 01/04/2018
- WO 700018240-0010; 0141 Reactor Building to Torus Vacuum Breaker Operability Check;
01/08/2018
- WO 700018947; OSP-SCT-0550, Secondary Containment Isolation Damper Test;
2/22/2018
71114.06Drill Evaluation
- SEG# RQ-SS-62; Title Redacted - Current Licensing Exam Material; Revision 0
71124.01Radiological Hazard Assessment and Exposure Controls
- 1279-05 Hotside Inspection; Locked High Radiation Area Entry to Look for Potential System
Leakage in the Condenser Room; 02/07/2018
- CAP 501000003171; SJAE CAM Increasing due to Potential Steam Leak
- CAP 501000003184; SJAE AMS-4 had a Higher than Normal Count Rate
- CAP 501000003502; RP Fundamentals Potential Negative Trend
- CAP 501000003715; A High Number of High Radiation Areas
- CAP 501000004530; Contamination Found in Unposted Area
- CAP 501000006626; Contamination Found Above Limits on 1027 Refuel Floor Behind
Ventilation Units Behind Ventilation Units
- CAP 501000006673; ARM at 951 Turbine Floor Spiked High and Alarming
- CAP 501000006674; Increasing Steam Chase Radioactivity due to System Leakage
- CAP 501000007175; Condition Evaluation; Regulatory Vulnerability on CAP Timeliness in RP
Department
- CAP 501000008065; Management Challenge Board in Selecting RWP Dosimetry Alarm
Setpoints for Entries into Condenser Bay
- CAP 501000008079; Management Challenge Board for Utilizing Dose Rate Alarm Setpoints
as Back out Criteria
- CAP 501000008086; RP Tech did not Wear Protective Clothing in a Contaminated Area
- CAP 501000008198; Contamination Found in RCA Clean Area
- CAP 501000008201; Contamination Found in Clean Area
- FP-RP-CRS-01; Control, Inventory and Leak Testing of Radioactive Sources; Revision 15
- Monticello General Area Alpha Classification Data; 04/2015-05/2017
- National Source Tracking System DPR-22 Docket No. 50000263; 01/06/2018
- R.01.04; Control of Personnel in High Radiation and Airborne areas; Revision 29
- R.02.01; Dose Rate Surveys; Revision 24
- R.02.02; Surface Contamination Surveys; Revision 33
- R.02.03; Airborne Radioactivity Sampling; Revision 20
- R.02.05; Personnel Contamination Assessment and Decontamination; Revision 20
- R.06.02; Unconditional Release of Equipment or Material; Revision 32
- R.12.02; Radiation Protection Key Control; Revision 35
- R.12.06; Non-Nuclear Facility Source Leak Check; Revision 9
- RPGP-01.21; Conduct of Radiological Protection; Revision 20
- RWP 180600; Hotside Inspection/Minor Maintenance; Revision 0
- RWP 180602; 14A-Feedwater Heater Pipe Leak Measurements and Associated Work;
Revision 0
- RWP 180602; Radiation Protection Job Plan 14A-Feedwater Heater Pipe Leak
Measurements and Associated Work; Revision 0
- WO 7000034585-0010; Planning and Approval of High Risk or Scheduled Risk Work
- WO 700014245; Semiannual Source Inventory and Smear Test Data; 09/18/2017
- WO 700019370; Special Nuclear Material (SNM) Physical Inventory; 11/21/2017
71151Performance Indicator Verification
- FP-PA-PI-01; Performance Indicator Control; Revision 12
- FP-PA-PI-02; NRC/INPO/WANO Performance Indicator Reporting; Revision 13
- FP-R-PI-01; Preparation of NRC Performance Indicators; Revision 6
- Monticello Station Log Entries; 01/01/2017-12/31/2017
- NEI 99-02; Regulatory Assessment PI Guideline; Revision 7
- QF-0445; NRC/INPO/WANO Data Collection and Submittal Forms Radiological Protection;
Occupational Exposure Control Effectiveness; 01/01/2017-12/31/2017
- QF-0445; NRC/INPO/WANO Data Collection and Submittal Forms Radiological Protection;
RETS/ODCM Radiological Effluent Occurrences; 01/01/2017-12/31/2017
- QF-0445; NRC/INPO/WANO Data Collection and Submittal Forms Unplanned Scrams per
7000 Critical Hours, Unplanned Power Changes per 7000 Critical Hours, and Unplanned
Scrams with Complications; 01/01/2017-12/31/2017
71152Problem Identification and Resolution
- CAP 501000000363; Slight Rise in Drywell Unidentified Leakage
- CAP 501000002977; Drywell Floor Sump ROC Rising Trend
- WO 700028072; HPCI Steam Line Inboard Isolation; 10/12/2017
- WO 700029426; Main Steam Line Drain - Inboard; 11/03/2017
71153Follow-Up of Events and Notices of Enforcement Discretion
- 0008; MSIV Closure Scram Test; Revisions 19 & 20
- 0009; Turbine Stop Valve Closure Scram Test Procedure; Revision 16
- 8293; Condenser Cleaning Using Amertap Balls; Revision 47
- A(1) Action Monitoring Plan for 13 EDG; No Date
- CAP 500001483971; SVOS-4 Failed During 0009 Stop Valve Test
- CAP 500001561403; HO-7 Failed to OPEN during HPCI Testing
- CAP 501000000922; Received Hot Engine Alarm for 12 EDG
- CAP 501000005391; RPS Tech Spec Bases Noncompliance
- CAP 501000009895; Opened CW-16 Early During 8293
- ECE 1483971; SVOS-4 Failed During 0009 Stop Valve Test; 07/14/2017
- L-MT-17-061; LER 2017-004-00; High Pressure Coolant Injection Steam Stop Valve Failed
to Open During Test; 12/16/2017
- L-MT-17-062; LER 2015-004-01; Past Inoperability of Turbine Stop Valve Scram Function
Exceeded Technical Specification Requirements; 08/22/2017
- L-MT-17-068; Diesel Generator Emergency Service Water System Automatic Transfer to
Alternate Shutdown Panel; 09/20/2017
- L-MT-18-003; LER 2017-006-00; Loss of Reactor Protection System Scram Function During
Main Steam Isolation Valve and Turbine Stop Valve Chanel Functional Tests due to Use of a
Test fixture; 01/12/2018
- Operational Logs, 03/22-23/2018
- QF1144; Operations Crew 4.0 Critique Form; 03/23/2018
- SCR-08-0319; 50.59 Screening - Procedurealized Use of Reactor Protection System (RPS)
Test Fixture; Revisions 0 & 1
- USAR-06 02; Monticello Updated Safety Analysis Report; Revision 35
- WO 362575; 0009 Turbine Stop Valve Closure Scram Test Procedure; 12/13/2008
- WO 364043; 0008 MSIV Closure Scram Test; 01/10/2009
- WO 367198; 0009 Turbine Stop Valve Closure Scram Test Procedure; 03/07/2009
- WO 369678; 0008 MSIV Closure Scram Test; 04/20/2009
- WO 376024; 0008 MSIV Closure Scram Test; 07/11/2009
19