05000263/FIN-2018001-02
Finding | |
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| Title | Licensee-Identified Violation |
| Description | 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
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 3.3.1.11 shall be operable. As specified in Table 3.3.1.11, 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 SCR080319, 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 The disposition of this violation closes LER 05000263/201700600.Corrective Action Reference: 501000005391 |
| Site: | Monticello  |
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| Report | IR 05000263/2018001 Section 4OA7 |
| Date counted | Mar 31, 2018 (2018Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | P Zurawski D Krause J Mancuso T Go K Riemer |
| Violation of: | 10 CFR 50.59 10 CFR 50.90 Technical Specification |
| INPO aspect | |
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Finding - Monticello - IR 05000263/2018001 | |||||||||||||||||||||||||||||||||||||
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Finding List (Monticello) @ 2018Q1
Self-Identified List (Monticello)
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