IR 05000263/2019002

Integrated Inspection Report 05000263/2019002

ML19214A147
Person / Time
Site:	Monticello
Issue date:	08/02/2019
From:	Hironori Peterson NRC/RGN-III
To:	Church C Northern States Power Company, Minnesota
References
IR 2019002
Download: ML19214A147 (23)

Text

August 2, 2019

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANTINTEGRATED INSPECTION REPORT 05000263/2019002

Dear Mr. Church:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Monticello Nuclear Generating Plant. On July 16, 2019, 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.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance or severity of the violation documented in this inspection report, 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 Monticello.

If you disagree with a cross-cutting aspect assignment 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 Monticello. 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/

Hironori Peterson, Chief Branch 3 Division of Reactor Projects

Docket No. 05000263 License No. DPR-22

Enclosure:

As stated

Inspection Report

Docket Number:

05000263

License Number:

DPR-22

Report Number:

05000263/2019002

Licensee:

Northern States Power Company, Minnesota

Facility:

Monticello Nuclear Generating Plant

Location:

Monticello, MN

Inspection Dates:

April 01, 2019 to June 30, 2019

Inspectors:

S. Bell, Health Physicist

E. Fernandez, Reactor Inspector

T. Go, Health Physicist

L. Haeg, Senior Resident Inspector

D. Krause, Senior Resident Inspector

T. McGowan, Reactor Engineer

J. Nance, Resident Inspector

T. Ospino, Reactor Engineer

K. Pusateri, Resident Inspector

C. St. Peters, Reactor Engineer

M. Ziolkowski, Sr Physical Security Inspector

P. Zurawski, Senior Resident Inspector

Approved By:

Hironori Peterson, Chief

Branch 3

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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

Failure to Follow Procedures Resulting in Operating in a Mode Prohibited by Technical Specifications.

Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000263/2019002-01 Open

[H.5] - Work Management 71153 A self-revealed Green finding and associated NCV of Technical Specification (TS) 5.4.1(a)was identified on June 11, 2019, for the failure of the licensee to follow licensee procedure FP-OP-COO-17, Equipment Manipulation and Status Control, Revision 3. Specifically, the licensee failed to track the manipulation of two primary containment isolation valves, which resulted in failure to verify their closure and the two valves being left open when the plant transitioned from operating Mode 4 to Mode 2. As a result, the requirements of TS 3.6.1.3 were not met prior to entering Mode 2, which was also a violation of TS 3.0.4(a). This finding had an associated cross-cutting in Work Management. [H.5]

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000263/2018-002-00 LER 2018-002-00 for Monticello Nuclear Generating Plant, C Outboard Main Steam Line Isolation Valve Delayed Closure Due to Foreign Material in the Air Valve 71153 Closed

PLANT STATUS

Monticello began the inspection period operating at approximately 76 percent power in coast-down. On April 13, 2019, the unit was shutdown for Refueling Outage 29 (RFO29), which lasted until May 12, 2019. The unit commenced start-up on May 12, 2019, and attained 100 percent power on May 15, 2019. On June 1, 2019, the unit was down-powered to 73 percent for quarterly turbine and main steam isolation valve (MSIV) testing. The unit returned to 100 percent the same day. On June 11, 2019, the unit was down-powered to 80 percent for a flexible power operation demonstration. The unit returned to 100 percent power the same day and remained there for the remainder of the inspection period. The unit ended the inspection period at 100 percent power.

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.

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.04) (1 Sample)

Potential Flooding - High River Level at 112.4 ft. - Season to date Max/Crest on April 1, 2019

(1) The inspectors evaluated readiness to cope with external flooding for the following areas:

• Intake Basin and Circulating Water House, Emergency Service Water, and Diesel Fire Pump Areas

Summer Readiness Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated summer readiness of offsite and alternate Alternating Current power systems on May 15, 2019

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Residual Heat Removal Hardening - Division 1 on April 17, 2019 (2)12 Diesel after Emergency Core Cooling System (ECCS) Testing/Auto-start on May 7, 2019

(3) Eleven and twelve Emergency Diesel Generator Electrical on May 14, 2019

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01) (6 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire zone FZ 30, Turbine Deck on April 24, 2019

(2) Fire zone FZ 02-E, TIP Drive Cubicle on April 25, 2019

(3) Fire zone 200 Drywell on April 29, 2019

(4) Fire zone 02-F Main Steam Chase on April 29, 2019

(5) Fire zone 12-C Condenser on May 2, 2019

(6) Fire zone 12-E Steam Jet Air Ejector on May 2, 2019

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Circulating Water Bay flooding event on May 2, 2019

71111.08G - Inservice Inspection Activities (BWR)

BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding

Activities (IP Section 03.01)

(1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from April 15 to April 18:

03.01.a - Nondestructive Examination and Welding Activities.

• Ultrasonic (UT) Examination of Mainsteam A Component Weld W-29A

• Ultrasonic (UT) Examination of Mainsteam A Component Weld W-30

• Ultrasonic (UT) Examination of Mainsteam A Component Weld W-31

• Magnetic Particle (MT) Examination of Feedwater Component Lug H-8-WA

• Examination record with relevant indications accepted for continued service

==1R29 -MIC-042, Ultrasonic (UT) Examination of RHRSW-B-Loop Piping

• ==

Examination record with relevant indications accepted for continued service

==1R29 -MIC-009, Ultrasonic (UT) Examination of ESW-B Loop Piping

• ==

Repair/Replacement work order for welding of high point vents (NGAT) for voiding prevention on HPCI Water Discharge Piping

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during reactor shutdown and cool down for refueling outage on April 13, 2019

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Refurbishment of safety-related snubbers during refueling outage on April 18, 2019

(2) Maintenance Rule (a)(3) Periodic Evaluation Review on April 18, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 Samples 1 Partial)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Emergency Diesel Generator 11 missing lube oil check valve nut on April 10, 2019

(2) Reactor and Fuel Pool Level instruments found unprotected during increased shut-down risk period on April 15, 2019 (3)

(Partial)

Loss of 1 sub-system of shutdown cooling from residual heat removal hardening - Division 1 on April 16, 2019 (4)12 Residual Heat Removal pump seal water leak on May 13, 2019

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02) (3 Samples 1 Partial)

The inspectors evaluated the following operability determinations and functionality assessments:

(1)

(Partial)

Loss of 13 Residual Heat Removal Pump due to residual heat removal hardening

(2) Emergency Diesel Generator 11 missing lube oil check valve nut on April 10, 2019

(3) Source Range Monitoring Operability on April 16, 2019

(4) Load Center 104 inadvertently de-energized on April 23, 2019

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) T-Mod for Heating & Ventilation (HTV) in support of Motor Control Center (MCC) 132 on April 2, 2019

(2) Discharge Canal Temperature point bypass on May 29, 2019

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post-maintenance tests:

(1) Emergency Diesel Generator 11 / 4108 Surveillance Post Maintenance Test on April 12, 2019

(2) Reactor Building Closed Cooling Water (RBCCW) to Dry Well (DW) Isolation Post-Maintenance Test on April 23, 2019

(3) MO-2-53A Post-Maintenance Test on April 29, 2019

(4) Control Rod Drive Leakage Post-Maintenance Test on May 12, 2019

(5) High Pressure Coolant Injection Post-Maintenance Test on June 18, 2019

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated Refueling Outage 1R29 activities from April 12, 2019 through May 13, 2019

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Inservice Testing (IP Section 03.01)

(1)0255-11-llC-2, Emergency Service Water B Leakage Test on April 23, 2019

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1) Emergency Diesel Generator 11 / 4108 Surveillance Test on April 8, 2019

(2) P-1043-03 Main Turbine Overspeed Trip on May 13, 2019

(3) OSP-NIS-0013, SRM/IRM Functional Test on April 15, 2019

(4) Standby Liquid Control Functional Test 0086, Post-Maintenance Test on April 16,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Contamination and Radioactive Material Control (IP Section 02.03) (1 Sample)

The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.

(1) The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material. The inspectors verified the following sealed sources are accounted for and are intact:

• J.L. Shepherd and Associates Cs-137

• Drywell Area Radiation Monitor Check Source Cs-137

High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)

(1) The inspectors evaluated risk-significant high radiation area and very high radiation area controls.

Instructions to Workers (IP Section 02.02) (1 Sample)

The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.

(1) The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas:

Radiation work packages

• Radiation Work Permit (RWP) - 195503; 1R29 - Drywell Snubber Activities

• RWP-195508; 1R29 - Drywell Safety Relief Valve Change Out

• RWP-195117; 1R29 - Torus Diving - Inspect and Clean

• RWP-195114; 1R29 - Main Steam Isolation Valve Repairs Steam Chase

• RWP-195210; 1R29 - MO-1615 Replacement Activities and Radiography

• RWP-195118; Reactor 962 Reactor Water Clean-up Pump Room

Electronic alarming dosimeter alarms

• CAP-501000025882; An Individual Received Dose Rate Alarm for Entrance in to the Reactor Water Clean-up Pump Rooms

• CAP-501000025617; Unexpected Dose Rate Alarm Under Vessel

• CAP-501000025705; Individual Received a Valid Dose Alarm because not Logging Out

Labeling of containers

• 920 Drywell Area

• Reactor Building 962 Elevation Reactor Water Clean-up Pump Room

• Radwaste and Refuel Floors Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06) (1 Sample)

(1) The inspectors evaluated radiation worker performance and radiation protection technician proficiency.

Radiological Hazard Assessment (IP Section 02.01) (1 Sample)

The inspectors evaluated radiological hazards assessments and controls.

(1) The inspectors evaluated radiological hazards assessments and controls. The inspectors reviewed the following:

Radiological surveys

• VSDS-M-20190413-21; Reactor Water Clean-up Pump and Heat Exchanger Rooms

• VSDS-M-20190416-19; Drywell 962 MO-2397 and RC-104 Work Area Dose Rates

• VSDS-M-20190413-7; Drywell 920 Initial Surveys at Pressure Inspection

• VSDS-M-20190417-8; Drywell 985 Feedwater B Nozzle 4-Mirror Insulation Removal

• VSDS-M-20190423-27; Drywell 920 Pre-job Survey of XR-5-2 Cut Out

• VSDS-M-20190413-19; Drywell 985 Initial Survey

Risk significant radiological work activities

• Reactor Water Clean-up Flow Accelerated Corrosion Pipe Replacement

• Main Steam Isolation Valve Repair Steam Chase

• Torus Diving Inspection and Cleaning

• Drywell Safety Relief Valve Change-out

Air sample survey records

• Replace Reactor Water Clean-up Heat Exchanger Piping Respirator Evaluation

• Rebuild and Refurbished Outboard Main Steam Isolation Valve

• Main Steam Isolation Valve Repairs - Inside the Steam Chase

Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

(1) The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

Radiological work package for areas with airborne radioactivity

• RWP-195117; 1R29 - Torus Diving - Inspect and Clean

• RWP-195114; 1R29 - Main Steam Isolation Valve Repairs Steam Chase

• RWP-195210; 1R29 - MO-1615 Replacement Activities and Radiography

• RWP-195118; Reactor 962' Reactor Water Clean-up Pump Room - Fit up and welding Activities on Reactor Water Clean-up Heat Exchanger Pipe Replacement

71124.02 - Occupational ALARA Planning and Controls

Implementation of ALARA and Radiological Work Controls (IPSection 02.03) (1 Sample)

The inspectors reviewed as low as reasonably achievable practices and radiological work controls.

(1) The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:

• RWP-195210; 1R29 - MO-1615 Repalcement Activities and Radiography

• RWP-195118; Reactor 962 Reactor Water Clean-up Activities and Heat Exchanger Pipe Replacement

Radiation Worker Performance (IP Section 02.04) (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance during:

(1) MO-1615 radiography activities and reactor water clean-up heat exchanger pipe replacement activities

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

BI02: RCS Leak Rate Sample (IP Section 02.11)===

Performance Indicator data, April 1, 2018 through March 31, 2019

(1) Reactor Coolant System Leakage on June 21, 2019

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

Performance Indicator data, April 1, 2018 through March 31, 2019

(1) Safety System Functional Failures on June 21, 2019

71152 - Problem Identification and Resolution

Annual Follow-Up of Selected Issues (IP Section 02.03) (1 Partial)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1)

(Partial)

Dry Cask Storage Helium Port Leakage (DSC 24, 15, 14, 12)

Semiannual Trend Review (IP Section 02.02) (1 Sample)

Transient Combustible Fire Zone Loading on May 1, 2019

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends with transient combustible loading that might be indicative of a more significant safety issue.

71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

The inspectors evaluated the following events and licensees responses/actions.

(1) Rx Building HELB door 410A found closed on April 12, 2019 - Event Notice 53997 on April 13, 2019

(2) Primary Containment Isolation Valves (PCIV) found open when required to be closed in Modes 1, 2, and 3 - Event Notice 54111 on June 11, 2019. The circumstances surrounding this EN are documented in report Section 71153

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000263/2018-002-00, C Outboard Main Steam Line Isolation Valve Delayed Closure due to Foreign Material in the Air Valve on November 16, 2018. The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors also concluded that no violation of NRC requirements occurred

INSPECTION RESULTS

Failure to Follow Procedures Resulting in Operating in a Mode Prohibited by Technical Specifications.

Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity

Green NCV 05000263/2019002-01 Open

[H.5] - Work Management 71153 A self-revealed Green finding and associated NCV of Technical Specification (TS) 5.4.1(a)was identified on June 11, 2019, for the failure of the licensee to follow licensee procedure FP-OP-COO-17, Equipment Manipulation and Status Control, Revision 3. Specifically, the licensee failed to track the manipulation of two primary containment isolation valves, which resulted in failure to verify their closure and the two valves being left open when the plant transitioned from operating Mode 4 to Mode 2. As a result, the requirements of TS 3.6.1.3 were not met prior to entering Mode 2, which was also a violation of TS 3.0.4(a). This finding had an associated cross-cutting in Work Management. [H.5]

Description:

The licensee had opened PCIVs AS-78 and AS-79 to supply breathing air to workers performing control rod drive seal replacements in the drywell. The seal replacements were the last activities performed in the drywell, prior to closing out the drywell and were running longer than scheduled. On May 10, 2019, the valves were opened under the direction of a licensed operator in lieu of a formal written procedure. While this is allowed, licensee procedure FP-OP-COO-17, Equipment Manipulation and Status Control, Revision 3, paragraph 5.3.10, requires that any such changes be formally tracked to ensure proper repositioning. This was not done in this case. Because there was no written record, the licensee was unaware that the valves were open during the mode change. During the period the valves were open, the licensee observed a higher than normal oxygen level concentration in the drywell. On June 11, 2019, the valves were finally closed after they were discovered open during subsequent troubleshooting of the higher oxygen levels. The inspectors determined that the violations were self-revealed in that the condition became apparent through a readily detectable degradation in material condition (higher than normal concentration of oxygen in the drywell).

The service-air line is a one-inch diameter line with these valves in series. Because the valves are PCIVs, they are safety-related. In order to maintain containment integrity, TS 3.6.1.3 requires that the valves be operable (i.e., closed) in Modes 1, 2, and 3. Since the valves were open from May 10, 2019, prior to making the MODE change from Mode 4 to Mode 2 on May 12, 2019, until June 11, 2019, the licensee failed to comply with TS action statements TS 3.6.1.3B and F, which requires that two PCIVs being inoperable for greater than one hour, the PCIVs should either be closed or the reactor be in Mode 3 in twelve hours and Mode 4 in thirty-six hours. Additionally, since the requirements of TS 3.6.1.3 were not met, then the mode change was not allowed per TS 3.0.4.a.

Corrective Actions: Upon discovery of the open valves, the licensee entered TS 3.6.1.3. B and closed the AS-78 and AS-79 valves. In addition, the licensee made a 50.72, 8-hour non-emergency notification to the NRC under 10 CFR 50.72(b)(3)(v)(C) and (D) Control of Radiological Release and Accident Mitigation and 10 CFR 50.72(b)(3)(ii)(B) Unanalyzed Condition. The licensee also entered the issue into its corrective action program.

Corrective Action References: CAP# 501000028365

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to ensure that the requirements of TS LCO 3.6.1.3 were met prior to going from Mode 4 to 2 was a performance deficiency that was within the licensees ability to foresee and correct and should have been prevented. Specifically, the licensee did not formally track the manipulations of AS-78 and AS-79 as required by FP-OP-COO-17, resulting in the licensee being unaware that the valves were open and that the requirements of TS 3.6.1.3 and TS 3.0.4.A were not met during the mode change.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the RCS Equipment and Barrier Performance attribute of the Barrier Integrity cornerstone. The inspectors determined that the finding was of more than minor safety significance because it was associated with the Configuration Control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that the physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Furthermore, the inspectors reviewed the examples of minor issues in IMC 0612, Issue Screening, Appendix E - Examples of Minor Issues, dated October 1, 2018, and determined the finding was similar to example 2.g and was not minor because a mode change was made without all required equipment being operable

Significance: The inspectors assessed the significance of the finding using Appendix H, Containment Integrity SDP. The inspectors reviewed IMC 0609, Significance Determination Process, Appendix H, Containment Integrity Significance Determination Process, Table 4.1 - Containment-Related SSCs Considered for LERF Implications and determined the finding to be Green because small lines (less than one to two inches in diameter) would not generally contribute to Large Early Release Frequency.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements 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.

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, Section 1 requires, in part, that administrative procedures for equipment control shall be established and implemented. Licensee Procedure, FP-OP-COO-17, Equipment Manipulation and Status Control, Revision 3, paragraph 5.3.10, states, in part, repositioning of equipment required during the conduct of maintenance and/or testing that is not covered by written instruction may be performed by qualified individuals provided these manipulations are authorized by shift supervision. Such manipulations must be formally tracked to ensure proper repositioning.

TS 3.6.1.3 states, in part, Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE in Modes 1, 2, or 3. TS 3.6.1.3 Condition B states, in part, One or more penetration flow paths with two PCIVs inoperable for reasons other than Condition D or E, isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange in 1-hour. TS 3.6.1.3 Condition F states, in part, Required Action and associated Completion Time of Condition A, B, C, D not met in Mode 1, 2, or 3, be in MODE 3 in twelve hours and be in MODE 4 in thirty-six hours.

TS 3.0.4. states, in part, When a Limited Condition for Operation (LCO) is not met, entry into a MODE or other specified condition in the Applicability shall only be made: a) When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time.

Contrary to the above, on May 10, 2019, the licensee failed to implement a written procedure for the formal tracking of the repositioning of equipment required during the conduct of maintenance to ensure proper repositioning. Specifically, the licensee failed to formally track the opening of primary containment isolation valves, AS-78 and AS-79, for service air into the drywell. As a result, from 1858 on May 12, 2019, until 1149 on June 11, 2019, the licensee operated the plant in Mode 2 and Mode 1 with manual PCIVs AS-78 and AS-79 open in violation of TS 3.6.1.3 for greater than the allowed time of one hour and failed to enter Mode 3 twelve hours later and Mode 4 in thirty-six hours as required by Condition F1 and F2.

Additionally, with PCIVs AS-78 and AS-79 in violation of TS 3.6.1.3, the Mode Change from Mode 4 to Mode 2 at 1858 on May 12, 2019, was not allowed under TS 3.0.4.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

• On April 25, 2019, the inspectors presented the Radiation Protection Inspection results to Mr. C. Church, Site Vice President, and other members of the licensee staff.

• On May 10, 2019, the inspectors presented the Monticello 1R29 ISI Inspection to Mr. D. Barker, Director of Site Performance, and other members of the licensee staff.

• On July 16, 2019, the inspectors presented the integrated inspection results to Mr. C. Church, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Corrective Action

Documents

501000013917

V-AH-4A not Available for Summer Months

501000014118

230 KV House Temperature

501000023427

Summer Reliability Challenge

Procedures

1150

Summer Checklist

B.09.03-05

Communication of Station Power Alignment to TSO

FP-OP-COO-27

Work Management

71111.04

Corrective Action

Documents

501000026056

Extra Loss of LC-104 in Procedure 0419-01

Corrective Action

Documents

Resulting from

Inspection

501000027532

NRC Questions for 12 EDG

Drawings

NF-36298-1

Electrical Load Flow One Line Diagram

117

NF-36298-2

DC Electrical Load Distribution One Line Diagram

Procedures

24

Plant Prestart Checklist Diesel Generators and Fuel Oil

System

71111.04S

E.2-06

Electrical Manual: Restore Bus 16 from Bus 14

71111.05Q Drawings

275-02

Unsealed Conduit Tip Drive Room

04/16/2019

20-01

Fire Protection-Turbine Generator/Exciter Sprinkler Test

NQ-158819

Monticello Nuclear Generating Plant Turbine Generator -

Turbine Building Fire Protection Piping (Isometric)

A

NQ-158820

Monticello Nuclear Generating Plant Turbine Generator -

Exciter Fire Protection Piping (Isometric)

A

NQ-158821

Monticello Nuclear Generating Plant Turbine Generator -

Turbine Building - Areas 1 & 2Fire Protection Mod

Instrument Air Connections

A

NX-52027-1

Fire Protection Turbine Generator/Exciter Fire Protection

Piping Isometric

B

Fire Plans

2-E

Fire Zone Loading for 2E-Tip Room; (Combustible Loading

Manager)

04/29/2019

71111.06

Procedures

C.4-I

Plant Flooding

71111.08G Calculations

1000524.302

Flaw Evaluation Support for Future Inspection of 18-Inch

2/03/2011

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Piping

Corrective Action

Documents

501000022266

Service Water Damage in ESW5-3-HBD (Div 2)

2/282019

501000024866

Service Water Pipe SW10-18-GF Wall Thinning

03/29/2019

Engineering

Evaluations

608000000239

Minimun Wall Evaluation for MIC Locations

NDE Reports

1R29-MIC-009

Ultrasonic (UT) Examination of ESW-B Loop Piping

Component No. NF-93492-B P7

01/23/2019

1R29-MIC-042

Ultrasonic (UT) Examination of RHR-1118

04/26/2019

2019MT001

Magnetic Particle Examination of Feedwater Piping

Lug

04/19/2019

2019UT012

Ultrasonic Indication Report for Mainsteam Weld W-30

04/16/2019

Procedures

FP-PE-NDE-300

Dry Magnetic Particle Examination - Yoke/Coil

PDI-UT-1

Generic Procedures for Ultrasonic Examination of Ferritic

Pipe Welds

G

WPS B31-P1P1-

GTSM-001

Welding Procedure Specification for Groove and Fillet Welds

where the Base Material Thicknesses are > 1/16 to 8

without PWHT for Joining P1 to P1 Material

10/15/2019

Work Orders

541933

Install High Point Vents (NGAT) for Voiding Prevention on

HPCI Water Discharge Piping

541933

Install High Point Vents (NGAT) for Voiding Prevention on

HPCI Water Discharge Piping Per EC-26208.Piping / Welds

Downstream of the NGAT is Considered Small Items,

Including New Supports, and not Included on the R/R Plan

05/02/2019

71111.12

Corrective Action

Documents

501000012857

Y71 Inverter Exceeds (a) (1) Limit

501000015149

RPV-Fuel Defect

Miscellaneous

Monticello Maintenance Rule Bases Document

04/12/2019

Operability

Evaluations

1555986

QF 1146; (FP-OP-OL-01) Past Operability Review Per

QIM 1555986 Snubber RV-27A-H9

Procedures

C.5-4402

Stage and Connect FLEX 480V Portable Diesel Generator

FP-IH-CS-01

Confined Space Entry

MNGP #0251

Snubber Operability Test

MNGP #0255-19

Snubber Inspection

MNGP #8005

Waterbox Entry Procedure

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Self-Assessments

Monticello Maintenance Rule (a) (3) Assessment;

April 1, 2016 to March 31, 2018

06/29/2018

Work Orders

700051674

Fuel Data May Require a Per QIM 501000015149; MN

03/19/2019

71111.13

Corrective Action

Documents

501000025764

Protected Equipment for RFP 29

501000026951

ESP-ELE-0549-02 Exceeded Overdue Date

501000027296

Seal Water Leak on 12 RHR

Engineering

Changes

608000000391

ECR - Loss of Nut Evaluation

Procedures

FP-OP-PEQ-01

Protected Equipment Program

71111.18

Corrective Action

Documents

501000021904

Discharge Canal Temp Monitoring Failure

501000027462

Tailgate into Vital Area

501000027532

Emergency Diesel Generator

Engineering

Evaluations

600000477574

Temporary Modification Tag

600000477592

Engineering Change Approval

600000477601

CFR 50.59 Applicability and Det. Review

611000001543

Computer Work Order

71111.19

Procedures

0058

HPCI Steam Line High Area Temperature Test and

Calibration Procedure

255-06-1A-1

High Pressure Coolant Injection Quarterly Pump and Valve

Tests Post Maintenance

2

4108-01

Emergency Diesel Generator 6-year Maintenance

Surveillance Post Maintenance Test

4115-PM

HPCI System Inspection

291-PM

Rebuilt CRD Leakage Measurement Post Maintenance Test

009

ISP-HPC-0553

HPCI Torus Suction Valve Interlock High Level Switches &

HPCI Pump Min Flow Control Flow Switch Channel

Functional Test and Channel Calibration

OSP-HPC-0056

HPCI High Steam Flow Pressure Sensor Test and

Calibration

OSP-HPC-0057

HPCI Low Steam Supply Pressure Sensor Test and

Calibration

OSP-HPC-0578

HPCI Pressurizing Station Check Valve Exercise Test

Work Orders

700025913

Emergency Diesel Generator-4108 Surveillance Post

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Maintenance Test

700039784

Sample Oil & Change as Required on P-209, Grease P-212

700047644

PM SV-2046A for CV-2046A

700049092

255-06-1A-1; High Pressure Coolant Injection Quarterly

Pump and Valve Tests Post Maintenance Test

700055273

HPCI Turbine EXH HI Drain Pot Level

700055626

CRD Leakage Post Maintenance Test

71111.20

Corrective Action

Documents

501000025585

DW Head Flange NRC Question

501000025613

Dropped Object in Reactor Cavity

501000025639

Rx Flange Indication Observed Via Video

50100002590

MO-2015; RHR DIV 2 LPCI Injection Inboard

501000025913

Refueling Bridge Handrails

501000025934

Inadequate 3-Way Communication

501000025941

L Rack Spent Fuel Bent Numbers

501000026098

MO-1752, 12 CS Injection Outboard

501000026970

Multiple Spikes on IRM 12 on NR-7-46A

Procedures

255-20-IIC-1

Reactor Coolant Pressure Boundary Leakage Test

2167

Plant Start-Up

2

270

Critical Safety System Checklist

AWI-08.15.03

Risk Management for Outages

260-PM

Refueling Platform Inspection and Lubrication

8005

Waterbox Entry Procedure

8146

Scaffold Control

24

Core Reload Verification Procedure

D.1-05

Fuel and Component Verification

D.2-05

Raising A Fuel Assembly

FP-IH-CS-01

Confined Space Entry

FP-S-CWH-01

CFR 26; Calculating Work Hours

FP-S-FMP-01

Fatigue Management Fleet Procedure

FP-S-FMP-01

CFR 26 Fatigue Management Fleet Procedure

FP-S-WHL-01

CFR 26; Scope of Work Hour Limits

Work Orders

700025696

MO-1752, 12 CS Injection Outboard

700025699

MO-2013; RHR Div 2 LPCI Injection Outboard

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.22

Procedures

0086

Standby Liquid Control Functional Test Post Maintenance

Test

255-11-IIC-2

Emergency Service Water B Leakage Test

4108-01

Emergency Diesel Generator 6-year Maintenance

Surveillance Post Maintenance Test

OSP-NIS-0013

SRM and IRM Functional and Logic System Functional Test

OSP-PPS-0537

Special Operations Checklist or Technical Specification LCO 3.10.2

P-1043-03

Main Turbine Overspeed Trip

Work Orders

700013979

OSP-NIS-0013 SRM and IRM Functional and Logic System

Functional Test

700019310

P-1043-03; Main Turbine Overspeed Trip

700025765

0086 Standby Liquid Control Functional Test Post

Maintenance Test

700025913

Emergency Diesel Generator 4108 Surveillance

700031715

255-11-IIC-2; Emergency Service Water B Leakage Test

700036075

OSP-NIS-0013 SRM and IRM Functional and Logic System

Functional Test

71124.01

Corrective Action

Documents

CAP-

501000025469

Drywell Dose Rates Significantly Higher at 951, 962 and

985 Elevations

04/13/2019

CAP-

501000025573

Powered Air Purifying Respirators Support Challenges due

to Personnel Resource Limitations

04/15/2019

CAP-

501000025882

Individual Received Dose Rate Alarm at RWCU Pump Room 04/18/2019

CAP-

501000025617

Unexpected Dose Rate Alarm Under Vessel

04/15/2019

CAP-

501000025643

Worker Received Dose Alarm

04/16/2019

Miscellaneous

Verification/Validation Package for Annual NSTS Inventory

Reconciliation - 2019

01/16/2019

Procedures

FP-RP-CRS-01

Control, Inventory and Leak Testing of Radioactive Sources

R.01.04

Control of Personnel in High Radiation and Airborne Areas

Radiation

Surveys

VSDS-M-

20190413-21

Reactor Water Cleanup (RWCU) Pump and Heat Exchanger

Rooms

04/13/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

VSDS-M-

20190416-19

Drywell 962' MO-2397 and RC-104 Work Area Dose Rates

04/17/2019

VSDS-M-

20190417-8

RFO 29 DW 985 Feedwater "B" Nozzle 4 Mirror Insulation

Removal

04/17/2019

Radiation Work

Permits (RWPs)

RWP-195114

1R29 - MSIV Repairs Steam Chase

RWP-195117

1R29 - Torus Diving - Inspect and Clean

RWP-195118

Reactor 962 Reactor Water Clean-Up (RWCU) Pump

Room - Fit-Up and Welding Activities on RWCU Heat

Exchanger Pipe Replacement

RWP-195210

1R29 - MO-1615 Replacement Activities and Radiography

71124.02

Corrective Action

Documents

CAP-

501000025935

ALARA Considerations for FP-MA-DIV-01; Control Diving

Requirements

4/19/2019

Miscellaneous

FP-RP-SEN-02

TEDE ALARA Evaluation; Replace RWCU Heat Exchanger

Piping

FP-RP-SEN-02

Radiological Work Assessment Form Work-in-Progress

Review

04/18/2019

FP-RP-SEN-02

Radiological Work Assessment Form Work-in-Progress

Review; RWCU Heat Exchanger Pipe Replacement

Activities

04/20/2019

Work Orders

RWP-195118

Radiological Work Assessment Form ALARA Review

Checklist; RWCU Pipe Replacement

04/01/2019

71151

Miscellaneous

QF-0445

NRC Data Collection and Submittal - Reactor Coolant

System Total Leakage (April 2018 through March 2019)

QF-0445

NRC Data Collection and Submittal - Safety System

Functional Failures (April 2018 through March 2019)

Procedures

FP-PA-PI-02

NRC/INPO/WANO Performance Indicator Reporting

71153

Corrective Action

Documents

501000028365

AS-78 and AS-79 Found Open

Procedures

FP-OP-COO-17

Equipment Manipulation and Status Control

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Work Orders

700017286

AO-2-86D; 4240-02-PM MSIV General Insp;

VALC-AO-2-86D; Perform 4240-02-PM

05/02/2019