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05000263/FIN-2015003-0530 September 2015 23:59:59MonticelloNRC identifiedFailure to Provide Complete and Accurate Information in LER 05000263/2015-002-00The inspectors identified a Severity Level IV NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.9 due to the licensees failure to provide information to the NRC that was complete and accurate in all material respects in accordance with the NRCs reporting requirements in 10 CFR 50.73(a)(1), Licensee Event Report (LER) System. Specifically, on June 29, 2015, the licensee failed to include an accurate assessment of the safety consequences and implications of a loss of shutdown cooling event when they issued LER 05000263/2015-002-00. This LER included an inaccurate assessment of safety implications, stating that engineering calculations show a potential worst case maximum temperature of 115 degrees Fahrenheit (F). The inspectors identified that engineering models actually showed potential worst case temperatures of 25-26 degrees F higher, which could have challenged or exceeded fuel pool cooling design specifications. Corrective actions included issuance of a revision to LER 2015-002-00 which contained the correct engineering modeling results and associated discussion of safety implications. The licensee entered this issue into its CAP (CAP 1484633). This issue was of more than minor significance under the Traditional Enforcement Process because the NRC relies on licensees to identify and correctly report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. Because this issue affected the NRC's ability to perform its regulatory function, the inspectors evaluated it using the traditional enforcement process. The underlying technical issue (i.e., loss of shutdown cooling) was evaluated separately and determined to be a finding of very low safety significance as documented in the 2015 2nd Quarter Integrated Inspection Report (05000263/2015002-01). In accordance with Section 2.2.2.d, and consistent with the examples included in Section 6.9.d of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because it was of more than minor concern with relatively inappreciable potential safety significance and is related to a finding that was determined to be a more than minor issue. Consistent with Example 6.9.d.1, this represented an example where the licensee submitted inaccurate information in a required report, which resulted in expansion of the scope of the next regularly scheduled inspection and required LER revision. Because there was no finding evaluated with this violation, the inspectors did not assign a cross-cutting aspect to this issue.
05000263/FIN-2014009-0131 December 2014 23:59:59MonticelloNRC identifiedFailure to Satisfy 10 CFR 50.73 Reporting Requirements for an Unanalyzed ConditionThe inspectors identified a NCV of the NRCs reporting requirements in 10 CFR 50.73, Licensee Event Report System. The licensee failed to submit a required Licensee Event Report (LER) within 60 days after the discovery of a condition that resulted in the nuclear power plant being in an unanalyzed condition that significantly degraded plant safety, a condition that could have prevented the fulfillment of the safety function of structures or systems needed to mitigate the consequences of an accident, and a condition prohibited by the plants Technical Specifications (TSs). Specifically, the licensee failed to either make a separate LER or further revise an existing LER with additional information to fully describe a known unanalyzed condition affecting its ability to mitigate a design basis external flooding event based on additional problems it had discovered, the corrective actions taken to correct the condition, the safety significance, and the date when full compliance was restored. The licensee initiated a corrective action to supplement an existing LER to describe the additional issues it identified that affected its external flooding mitigation plan and to specify the noncompliance window as February 29, 2012 through January 31, 2014. Consistent with the guidance in IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, the inspectors determined the performance deficiency was not of more than minor significance based on No answers to the more-than-minor screening questions. In accordance with Section 6.9.d.9 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the licensee failed to report as required by 10 CFR 50.73(a)(1). No cross-cutting aspect is associated with this traditional enforcement violation because the associated performance deficiency was determined to be of minor significance and therefore not a finding.
05000263/FIN-2014009-0231 December 2014 23:59:59MonticelloNRC identifiedFailure to Satisfy 10 CFR 50.72 and 10 CFR 50.73 Reporting Requirements for an Unanalyzed ConditionThe inspectors identified a Severity Level IV NCV of the NRCs reporting requirements in 10 CFR 50.72(a)(1), Immediate Notification Requirements for Operating Nuclear Power Reactors, and 10 CFR 50.73(a)(1), Licensee Event Report System. The licensee failed to make a required 8-hour non-emergency notification call to the NRC Operations Center and also failed to submit a required LER within 60 days after discovery in November 2012 of a condition that resulted in the nuclear power plant being in an unanalyzed condition that significantly degraded plant safety, a condition that could have prevented the fulfillment of the safety function of structures or systems needed to mitigate the consequences of an accident, and a condition prohibited by the plants TSs. The licensee subsequently made an 8-hour notification call to the NRC Operations Center via the Emergency Notification System to report the event on August 29, 2013 (Event Notice 49314) and subsequently submitted LER 05000263/201300700, Unanalyzed Condition Due to Inadequate Flooding Procedures, on October 28, 2013. Consistent with the guidance in IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, the inspectors determined the performance deficiency was not of more than minor significance based on No answers to the more-than-minor screening questions. In accordance with Section 6.9.d.9 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the licensee failed to report as required by 10 CFR 50.72(a)(1)(ii) and 10 CFR 50.73(a)(1). No cross-cutting aspect is associated with this traditional enforcement violation because the associated performance deficiency was determined to be of minor significance and therefore not a finding.
05000263/FIN-2011005-0531 December 2011 23:59:59MonticelloNRC identifiedFailure to Make a Required 60 Day Event Report Per 10 CFR 50.73(a)(2)(vii)(A-D)The inspectors identified a Severity Level IV NCV and associated finding of very low safety significance of 10 CFR 50.73(a)(2)(vii)(A-D), Licensee Event Report System, for the failure to report an event to the NRC within 60 days, where a single cause or condition caused two independent trains to become inoperable in a single system designed to help maintain safe reactor shut down, remove residual heat, control radioactive releases, or mitigate accidents. Specifically, on September 29, 2011, the licensee identified that the surveillance test procedures being used to demonstrate load reject capabilities of both EDGs had never contained the correct load rejection testing requirements from the applicable design documents. As a result, the surveillances were considered never met, and both EDGs were declared inoperable. During their evaluation and subsequent reporting of the issue, the licensee failed to recognize that the inoperability of both diesel generators caused by a single common cause was reportable to the NRC within 60 days under the 50.73 common cause criterion. The licensee entered this issue into their corrective action program (CAP 1318116). Corrective actions for this issue included plans to revise their existing licensee event report (LER) and to perform an apparent cause evaluation to further evaluate the issue. The inspectors determined that the failure to report required plant events or conditions to the NRC in accordance with reporting requirements was a performance deficiency because it was the result of the failure to meet a requirement or a standard, the cause was reasonably within the licensees ability to foresee and correct, and should have been prevented. In addition, it had the potential to impede or impact the regulatory process. As a result, the NRC dispositions violations of 10 CFR 50.73 using the traditional enforcement process instead of the SDP. However, if possible, the underlying technical issue is evaluated using the SDP. In this case, the inspectors determined that the licensee failed to develop and implement adequate Emergency Diesel Generator (EDG) testing procedures during their transition to the Improved Technical Specifications in 2006, which resulted in both EDGs being declared TS inoperable, but available for use. The inspectors determined that the performance deficiency was more than minor because it was associated with the Mitigating Systems Cornerstone attributes of Human Performance and Procedure Quality and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Using IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined that the finding had very low safety significance because they answered No to all five questions contained in Column 2 of the Table 4a worksheet. As a result, the inspectors determined that the finding had very low safety significance (Green). In accordance with Section 6.9.d.9 and 6.9.d.10 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because it was an example where the licensee failed to make a report required by 10 CFR 50.73; it represented a failure to identify all applicable reporting codes on an LER that may impact the completeness or accuracy of other information submitted to the NRC; and the underlying technical issue was evaluated by the SDP and determined to be of very low safety significance. The inspectors determined that the contributing cause that provided the most insight into the performance deficiency affected the cross-cutting area of Problem Identification and Resolution, having corrective action program components, and involving aspects associated with properly classifying and evaluating for reportability conditions adverse to quality (P.1(c)).
05000263/FIN-2011003-0231 March 2011 23:59:59MonticelloNRC identifiedFailure to Update USAR for Cask Lift Height RestrictionsA Severity Level IV non-cited violation (NCV) of 10 CFR 50.71(e),Periodic Update of the Final Safety Analysis Report and an accompanying Green finding were identified by the inspectors for the licensees failure to update the Updated Safety Analysis Report (USAR) with the cask maximum lift height restrictions imposed by Nuclear Regulatory Commission (NRC) staff. As a result, the licensee had not adequately evaluated whether the plant licensing basis necessitated retention of cask lift height limitations when transitioning from the use of the 25 ton NFS-4 or 25 ton NAC-1 spent fuel shipping cask and 70 ton IF-300 spent fuel shipping cask to the heavier 105 ton NUHOMS cask. The licensee entered this issue into its corrective action system. The inspectors determined that the failure to update the USAR with the cask lift height restrictions for the 25 ton and 70 ton spent fuel cask was contrary to 10 CFR 50.71(e) and was a performance deficiency warranting a significance evaluation. Violations of 10 CFR 50.71 (e) are dispositioned using the traditional enforcement process instead of the SDP because they are considered to be violations that potentially impede or impact the regulatory process. However, if possible, the underlying finding is evaluated under the SDP to determine the significance of the violation. The finding was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, because, if left uncorrected, the performance deficiency could have led to a more significant safety concern. Specifically, the inspectors could not readily conclude that the absence of lift height limitations would not require additional calculational analyses and/or require a license amendment. The inspectors determined that the finding was of very low safety significance following a qualitative significance determination review. Specifically, the inspectors determined that only seismic events exceeding the level of an Operational Basis Earthquake (OBE) of 0.03g could impact core damage frequency (CDF). The licensee supplied information that the median annual probability of exceeding the peak ground acceleration for the OBE at Monticello was approximately 7.0E-4/yr. In addition, the predicted shipping cask lifts was 19.2/yr with an average lift duration of 30 minutes. Thus, the frequency of exceeding the OBE while lifting a shipping cask was estimated to be 7.7E-7/year. This value is a bounding frequency estimate for delta-CDF in that it does not imply with certainty that there will be a cask drop during an earthquake nor does it imply with certainty of core damage during an earthquake given a cask drop. The Senior Reactor Analyst (SRA) concluded that the risk due to simultaneous occurrence of an OBE or greater seismic event during use of the reactor building crane for shipping cask lifts was best characterized as very low (Green). The inspectors determined that this finding did not reflect current performance because it was a legacy issue with the failure to properly update the USAR occurring almost 30 years ago and, therefore, there was no cross-cutting aspect associated with this finding.
05000263/FIN-2010006-0131 March 2010 23:59:59MonticelloNRC identifiedFailure to Perform 10 CFR 50.59 Evaluation For Isolation of Room Cooler Which Addressed Temperature LimitationsThe inspectors identified a finding of very low safety significance and associated NCV of 10 CFR 50.59, Changes, Tests, and Experiments, Section (d) 1 for the licensees failure to perform a written evaluation, which provided the bases for the determination that a change did not require a license amendment. Specifically, the licensee failed to provide a basis which addressed room temperature limitations as to why the isolation of a high pressure coolant injection (HPCI) room cooler did not require prior NRC approval. The licensee entered this issue into their corrective action program and determined that no immediate corrective actions were necessary because administrative controls were in place to ensure that the HPCI room temperature would not exceed the calculated initial room temperature limitation. The inspectors determined that the finding was more than minor because they could not reasonably determine that the changes would not have ultimately required NRC prior approval. The inspectors determined that the finding was of very low safety significance because the finding did not result in loss of operability or functionality. The finding affected the Mitigating Systems cornerstone attribute of Equipment Performance to ensure the availability and reliability of systems (HPCI) that respond to initiating events to prevent undesirable consequences. This finding has a cross-cutting aspect in the area of human performance within the resources component because the licensee did not ensure that personnel, equipment, procedures, and other resources were available and adequate to assure nuclear safety in that training of personnel was not sufficient.
05000263/FIN-2010009-0131 March 2010 23:59:59MonticelloNRC identifiedFailure of an NDE Technician to Follow an Ultrasonic Thickness Examination ProcedureA Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified by the inspectors for a contract Non-Destructive Examination (NDE) technicians failure to follow a procedure during an Ultrasonic (UT) examination of the Reactor Core Isolation Cooling (RCIC) barometric condenser shell. Specifically, the technician failed to properly perform a calibration of the UT examination equipment. The underlying performance deficiency (PD) associated with this violation did not result in a finding due to the minor safety-significance of the PD and hence the PD was not evaluated for cross-cutting aspects. Specifically, the PD was similar to Example 4b of IMC 0612, Appendix E, Examples of Minor Issues, in that, it involved an insignificant procedural error, failure to calibrate UT equipment per procedure. The failure had minimal impact on the UT readings (within UT test equipment tolerances). However, due to the willfulness of the violation, the violation was processed through the traditional enforcement process and assigned a Severity Level IV. Specifically, the NRC Enforcement Policy states that a violation may be considered more significant than the underlying non-compliance if it includes indications of willfulness. As part of its corrective actions, the licensee re-examined the technicians prior UT examinations and found insignificant variation between re-examined UT examination results and the technicians original UT examination result
05000263/FIN-2009005-0231 December 2009 23:59:59MonticelloNRC identifiedFailure to Make Required Eight Hour Event Report per 10CFR50.72(b)(3)(v)A Severity Level IV NCV of 10 CFR 50.72(b)(3)(v)(C) was identified by the inspectors for the failure of the licensee to make an eight hour notification to the NRC for a condition that, at the time of discovery, could have prevented the fulfillment of the SBGT system safety function. The licensee entered this issue into their corrective action program as CAP 01210817. The inspectors determined that the contributing cause that provided the most insight into the performance deficiency affected the cross-cutting area of Problem Identification and Resolution, having corrective action program components, and involving aspects associated with properly classifying and evaluating for reportability conditions adverse to quality. (P.1(c)) The inspectors determined that the issue was a performance deficiency because it was the result of the failure to meet a requirement, and the cause was reasonably within the licensees ability to foresee and correct, and should have been prevented. The inspectors determined that the performance deficiency was more than minor and a finding because the failure to report the condition that could have prevented the fulfillment of the SBGT system safety function affected the NRCs ability to perform its regulatory function. Because violations of 10 CFR 50.72 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the SDP. Per NRC Enforcement Policy, Supplement I, Example D.4, a failure to make a required Licensee Event Report is categorized as a Severity Level IV violation. The inspectors considered the failure to make a required 50.72 report to meet the intent of this example. Because the violation was not repetitive or willful, and it was entered into the licensees corrective action program, this violation is being treated as a Severity Level IV NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. (Section 1R13
05000263/FIN-2008002-0231 March 2008 23:59:59MonticelloNRC identifiedImproper Overtime Restriction DeviationsA finding of very low safety significance and NCV of TS 5.2.2.d, was identified by the inspectors for the failure to properly implement procedures for controlling plant staff work hours for personnel performing safety-related activities. Specifically, several approved overtime deviations in calendar year (CY) 2007 did not conform to the guidelines contained in TS-required Administrative Procedure 4 AWI-08.10.01, Overtime Restrictions and Fitness for Duty Requirements. The inspectors determined that the performance deficiency affected the cross-cutting area of Human Performance, having resource components, and involving aspects to ensure that personnel and other resources are available and adequate to assure nuclear safety; specifically, those necessary for sufficient qualified personnel to maintain work hours within working hour guidelines. (H.2(b)) The inspectors determined that the finding was more than minor because, if left uncorrected, approval of work hour deviations under improper circumstances could increase the likelihood of human errors and would become a more significant safety concern. The finding is not suitable for Significance Determination Process (SDP) evaluation, but has been reviewed by NRC management and is determined to be a finding of very low safety significance because no significant events or human performance issues were a direct result of personnel fatigue from excessive hours worked. The licensee entered the issue into their corrective action program. In accordance with NRC Enforcement Policy, Supplement I.D, the issue is a Severity Level IV Violation. (Section 4OA2
05000263/FIN-2005012-0130 September 2005 23:59:59MonticelloNRC identifiedThe Licensee Failed to Report That the ANS Reliability PI Crossed the Green to White Threshold in the First Quarter of 2003The inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 50.9 because the licensee failed to provide complete and accurate information in a submittal of siren test data for the ANS PI. Specifically, licensee staff inappropriately added the results of weekly siren tests to the results of monthly siren tests when calculating the ANS PI for the first calendar quarter of 2003. On March 31, 2003, licensee staff changed a procedure for computing the ANS PI to include the results of weekly siren tests and inappropriately implemented the procedure revision retroactive to the first day of the quarter (January 1, 2003). By adding the weekly siren test data, the licensee changed the overall character of its quarterly siren performance indicator results. The licensee has subsequently conducted an adequate root cause evaluation and initiated adequate corrective action to correct and re-submit the first quarter 2003 ANS PI data.
05000263/FIN-2005003-0530 June 2005 23:59:59MonticelloNRC identifiedFailure to Report Inadvertent Engineered Safety System Actuations During Testing

The inspectors identified a Severity Level IV violation when the licensee failed to make a notification, within 8 hours, to the NRC Operations Center, in accordance with 10 CFR 50.72(b)(3)(iv)(A), for an event involving loss of bus 16 and actuation of engineered safety features on April 2, 2005. The licensee did not restore compliance or take any corrective actions.

Because this issue affected the NRCs ability to perform its regulatory function, it was evaluated using the traditional enforcement process. The violation of 10 CFR 50.72 is categorized in accordance with the NRC Enforcement Policy at Severity Level IV. Since the licensee failed to place the violation into a corrective action program to address recurrence, the violation was cited.