IR 05000263/2008008
| ML083330412 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 11/28/2008 |
| From: | Riemer K R NRC/RGN-III |
| To: | O'Connor T J Northern States Power Co |
| References | |
| IR-08-008 | |
| Download: ML083330412 (35) | |
Text
November 28, 2008
Mr. Timothy Site Vice President Monticello Nuclear Generating Plant Northern States Power Company, Minnesota 2807 West County Road 75 Monticello, MN 55362-9637
SUBJECT: MONTICELLO NUCLEAR GENERATING PLANT PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000263/2008008
Dear Mr. O'Connor:
On November 7, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at your Monticello Nuclear Generating Plant.
The enclosed report documents the inspection results, which were discussed on November 7, 2008, with you and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The inspection concluded that your staff was effective at identifying problems and incorporating them into the corrective action program. In general, issues were appropriately prioritized, evaluated, and corrected, audits and self-assessments were thorough and probing, and operating experience was appropriately screened and disseminated. Your staff was aware of the importance of having a strong safety-conscious work environment and expressed a willingness to raise safety issues.
However, your staff not always effective in ensuring that issues, once identified, were properly resolved. The inspectors identified an apparent lack of sensitivity to internal corrective action program performance indicators, examples of inadequate documentation of issues, and inadequate oversight of the Differing Professional Opinions program to ensure that Issues were appropriately addressed and tracked. These were recurring problems, as they had been previously identified during the 2006 PI&R inspection. The inspectors also observed that despite having had several opportunities, your staff had not taken appropriate actions to correct an adverse trend in Human Performance, which had begun in late 2006. Based on the results of this inspection, two NRC-identified findings of very low safety significance were identified. The findings involved violations of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your corrective action program, the NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with Section VI.A.1 of the NRC Enforcement Policy. If you contest the subject or severity of a NCV, 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Monticello Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA by N. Shah, Acting For /
Kenneth Riemer, Chief Branch 2 Division of Reactor Projects
Docket No. 50-263 License No. DPR-22
Enclosure:
Inspection Report 05000263/2008008
w/Attachment:
Supplemental Information DISTRIBUTION
- See next page Letter to
SUMMARY OF FINDINGS
IR 05000263/208008; (October 20, 2008 - November 7, 2008), Monticello Nuclear Generating Station; Biennial Baseline Inspection of the Identification and Resolution of Problems.
This team inspection was performed by three regional inspectors and the senior resident inspector. Two findings of very low safety significance (Green) were identified during this inspection. Each of the findings was classified as a NCV. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC) 0609, ASignificance Determination Process
@ (SDP). The NRC
=s program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, AReactor Oversight Process,@ Revision 4, dated December 2006.
Identification and Resolution of Problems The licensee was effective at identifying problems and incorporating them into the corrective action program (CAP). In general, issues were appropriately prioritized, evaluated, and corrected. Licensee audits and self-assessments were generally thorough, probing, and made good use of outside resources to maintain independence. Operating Experience (OE) was appropriately screened and disseminated and was considered as a potential precursor during cause evaluations. Plant staff was aware of the importance of having a strong safety-conscious work environment (SCWE) and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for safety issues raised, or knew of anyone who had failed to raise issues. All persons interviewed had an adequate knowledge of the CAP and the employee concerns program (ECP).
However, the inspectors identified several concerns that were similar to those noted during prior PI&R inspections. The licensee had a continued lack of sensitivity to internal CAP performance indicators, in that some of these indicators, which showed potential deficiencies in the program, had not been evaluated. There were also continued concerns with the proper documentation of issues. Specifically, the inspectors found several examples where the documentation of an issue was insufficient to verify whether it had been appropriately evaluated or resolved. There were also continued problems with the handling of issues identified through the licensee's Differing Professional Opinion (DPO) process. The inspectors also observed that the station had not taken appropriate corrective action to address an adverse trend in Human Performance.
There were two Green findings identified during this inspection. One finding was for failing to properly identify and evaluate a Maintenance Rule Functional Failure associated with the High Pressure Coolant Injection (HPCI) system. The second finding was for failing to capture a Conditions Adverse to Quality (CAQ) in the CAP, during a licensee review of OE. Both findings also had associated NCVs.
A. NRC-Identified
and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Green: The NRC identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," for the failure to identify a Condition Adverse to Quality (CAQ). Specifically, the licensee did not identify a maintenance preventable functional failure (MPFF) associated with the HPCI system. The MPFF was associated with the in-service test (IST) failure of the HPCI accumulator check valve (AI-611) during the 2007 refueling outage. The failure was caused by debris that was lodged in the valve seat. Of particular significance, was the fact that the issue was the subject of three licensee-initiated action requests (ARs) between March 2007 to February 2008, regarding the test failure, the failure to evaluate past-operability and the failure to evaluate the maintenance rule aspects, none of which properly evaluated the issue. The licensee identified the MPFF after an NRC inspector questioned the adequacy of the previous evaluations, in particular, why the source of the debris had never been evaluated. This finding also has an associated cross-cutting aspect associated in the area of PI&R, Corrective Action Program for the failure to properly evaluate the HPCI accumulator check valve IST failure. [P.1(C)] The finding is more than minor because it affects the Equipment Performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding is of very low safety significance, because the HPCI system remained operable and available. (Section 4OA2.1(2))
Cornerstone: Initiating Events and Mitigating Systems
- Green: The NRC identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure to identify and correct a Condition Adverse to Quality (CAQ). Specifically, the licensee failed to capture in the CAP a concern with the potential corrosion of magnesium motor rotor fan blades associated with safety-related motor operated valves (MOVs). The MOVs were associated with the reactor recirculation and residual heat removal (specifically the low pressure core injection mode) systems. The concern was identified during an internal licensee review of OE. The failure to capture this item in the CAP resulted in the licensee not being able to utilize the CAP process to ensure that the CAQ had been properly evaluated and corrected. This finding has an associated cross-cutting aspect associated in the area of PI&R, Corrective Action Program for the failure to properly evaluate the potential impact of the CAQ on the affected, safety-related MOVs. [P.1(C)] The finding is more than minor because it directly affected the Human Performance attribute of the Initiating Events Cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions while at power. The finding also directly affected the Equipment Performance attribute of the Mitigating System Cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The finding is of very low safety significance, because the issue only involved the potential degradation, but not the actual loss of a plant component (i.e., there was no actual initiating event nor loss of a mitigating system). (Section 4OA2.2)
B. Licensee-Identified Violations
No violations of significance were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution (PI&R)
The activities documented in sections
.1 through .4 constituted one biennial sample of PI&R as defined in IP 71152.
.1 Assessment of the Corrective Action Program (CAP) Effectiveness
a. Inspection Scope
The inspectors reviewed the licensee's CAP implementing procedures and attended CAP program meetings to assess the implementation of the CAP by site personnel.
The inspectors reviewed risk and safety significant issues in the licensee's CAP since the last NRC PI&R inspection in November 2006. The selection of issues ensured an adequate review of issues across the NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed ARs generated as a result of facility personnel's performance in daily plant activities. In addition, the inspectors reviewed ARs and a selection of completed investigations from the licensee's various investigation methods, including root, apparent and common cause evaluations.
The inspectors performed a more extensive review of station efforts to resolve high temperature concerns with the number 12 reactor feedwater pump and for managing aging/obsolete equipment. This review consisted primarily of a five year search of related issues identified in the CAP and discussions with appropriate licensee staff to assess the licensee's efforts in address the above equipment concerns.
During the reviews, the inspectors evaluated whether the licensee staff's actions were in compliance with the facility's CAP and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors evaluated if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the station's CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also evaluated whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings, including NCVs.
b. Assessment
- (1) Effectiveness of Problem Identification In general, the inspectors considered the licensee's identification of equipment deficiencies to be good. Workers were encouraged to identify issues and were familiar with the various avenues available (NRC, CAP, etc). This was evident by the large number of ARs generated annually, which were reasonably distributed across the 4 Enclosure various departments. A shared computerized database was used for creating individual reports and for subsequent management of the processes of issue evaluation and response. This included determining the issue's significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate.
However, the inspectors identified a continued lack of sensitivity with the licensee's evaluation of some of the internal performance indicators monitoring the CAP. A similar issue had been identified during the 2003 and 2006 PI&R inspections and was documented in AR 01064612. One notable example was the licensee's indicator for CAP action items that were open greater than 90, 120 or 180 days. Normally the licensee expects CAP actions to be completed within 90 days, however, the indicator showed that about 40 percent of the open items had exceeded this goal as of August 2008. The inspectors noted that there was no explanation or evaluation of why this had occurred or whether this result was acceptable. The inspectors also identified other indicators having similar issues. The licensee documented this issue in AR 1158446.
The licensee was generally effective at identifying and resolving trends. This was apparent by the large number of trend ARs generated either through "binning" of issues or through evaluation via the quarterly department roll-up meeting (DRUM) reports. However, the inspectors noted that the licensee's trending program was somewhat limited in that it did not always identify trends involving issues affecting the same functional area, but having dissimilar aspects. The inspectors noted that the licensee had reached a similar conclusion in a recent self-assessment and had generated AR 1129683 to address this concern.
For example, the inspectors noted that the licensee had been slow to identify an adverse trend in human performance. Since late 2006, the plant has experienced numerous issues in this area. These issues were primarily of low significance and did not result in NRC findings. These issues continued through 2007 and 2008, with the significance of the findings increasing, until a sufficient number of NRC findings had accrued (around mid-2008) that an adverse trend in human performance had become evident.
The inspectors noted that the licensee's trending program had identified trends having multiple issues in the same human performance aspect (such as procedural adherence), but was less effective at identifying trends having multiple issues crossing over several aspects (such as procedural adherence, work coordination, training, etc). This limitation resulted in the licensee believing that the human performance issues were limited to specific behaviors or work groups, instead of recognizing that it was a more widespread concern involving fundamental human behaviors.
During the NRC PI&R inspection, the licensee was in the process of completing a self-assessment of human performance. Although the results had not yet been entered into the CAP, they were discussed with the inspectors and during a Management Review Committee meeting held on October 22, 2008. The licensee identified that the CAP trending program had been ineffective at identifying the human performance trend and that the issues were principally due to a lack of resources and an inappropriate tolerance for risk among workers. The inspectors concluded that while the licensee had achieved a better understanding of the human performance issue, more effort was needed to understand the reasons behind the underlying causes.
5 Enclosure Findings No findings of significance were identified.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors attended several daily CAP screening meetings and observed that issues were being appropriately screened and challenged. The majority of issues were of low level and were either closed to trend or at a level appropriate for a condition evaluation.
Many of these issues were closed to a work request or to another AR, but the inspectors noted that both the parent and daughter documents had the necessary verbiage to document the interrelationship. Although fewer in number, the inspectors did not have any concerns with those issues assigned an apparent cause evaluation (ACE) or root cause evaluation. There were no items in the operations, engineering, or maintenance backlogs that were risk significant, individually or collectively. There were no classifications or immediate operability determinations with which the inspectors disagreed.
The inspectors noted that while root cause evaluations were generally of good quality, there continued to be problems with the quality of documentation of ACEs. Similar issues were noted during the 2006 PI&R inspection. For example, ACEs were required to be reviewed and approved by a licensee ACE screening inspector prior to issuance. The screening inspectors comprised management representatives from each of the major plant departments (operations, maintenance, etc). The inspectors identified several examples where the screening inspectors had identified issues with the evaluation quality, but had nevertheless assigned the evaluation a passing grade. While this was acceptable under the licensee's procedures, there was no requirement to ensure that the screening team observations were addressed. This meant that potential, recurring issues with ACE documentation went uncorrected, and that licensee standards for ACE quality were not reinforced. The inspectors noted that similar issues had been identified in recent station audits as documented in AR 1144130.
The inspectors identified that the licensee had failed to identify a Maintenance Preventable Functional Failure (MPFF) of the HPCI system, due to an improper evaluation following an in-service test failure of the HPCI accumulator check valve. Because the HPCI is a safety-related system, the MPFF was considered a SCAQ.
The test failure occurred during the 2007 refueling outage and was the subject of three ARs, written between March 2007 and February 2008. These ARs collectively concluded that the issue did not affect the HPCI system. In August 2008, the licensee initiated AR 1148193, after an NRC inspector questioned the adequacy of the licensee's review. The licensee subsequently concluded that the HPCI system availability had been affected and that the test failure should have been identified as an MPFF. This was considered a Finding (Green) and NCV.
Findings Failure to Identify a CAQ and to Take Corrective Actions to Prevent Recurrence
Introduction:
A finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," was identified by the inspectors for the failure to identify a CAQ. Specifically, the licensee did not properly 6 Enclosure evaluate the failure of the HPCI accumulator check valve (AI-611) after it failed its in-service test. This resulted in the licensee not identifying a MPFF of the safety-related HPCI system.
Description:
On March 31, 2007, the licensee identified that the AI-611 valve had failed its in-service test due to a piece of debris lodged in the valve seat preventing it from closing. The valve was subsequently repaired and successfully retested. The test failure was documented in AR 1086927, but was closed with no evaluation. On August 29, 2007, the licensee initiated AR 1109246, after identifying that the effect of the test failure on the past operability of the HPCI system had not been evaluated.
The AR identified that the debris on the valve seat was not caused by any past events and that therefore, there were no past operability concerns. On February 23, 2008, the licensee initiated AR 1128442 after identifying that the leak test failure had not been evaluated against the maintenance rule program. The AR concluded that since the test failure had not resulted from any past activity, it was not a MPFF. On August 21, 2008, the licensee initiated AR 1148193, after an NRC inspector found that the licensee had failed to identify the source of the valve debris and that, therefore, the conclusions regarding the affect of the test failure were potentially inaccurate. The licensee subsequently identified that the valve debris was brazing material likely originating from work on instrument air valve AI-221, located directly upstream of the AI-611 valve. This work occurred from June 10-14, 2005. Since the debris had resulted from a planned maintenance activity, the licensee subsequently concluded that the test failure should be reevaluated as a potential MPFF. The AI-611 valve had last been successfully tested during the March/April 2005 refueling outage.
The AI-611 is a safety-related valve that has a safety function to close. It allowed instrument air (which is a non-safety related system) to supply a safety-related accumulator that, in turn, supplied air to the HPCI minimum flow valve (CV-2065). The CV-2065 valve is safety-related and has safety functions to both open and close. If the AI-611 valve fails to close, then upon a loss of the instrument air system, air would bleed out of the accumulator resulting in the CV-2065 valve failing open. If this occurred, then part of the HPCI flow would be diverted to the torus instead of the reactor vessel. Because this is an unevaluated condition, it is possible that there would be insufficient flow to the reactor vessel to meet the design basis. The CV-2065 valve is required to remain operable during a station blackout (where instrument air would be lost) and a small break loss of coolant accident coincident with a loss of instrument air. Both of these are design basis accidents.
The licensee subsequently reclassified the in-service test failure as a MPFF that had affected the availability of the HPCI system. The licensee also identified that other in-service test failures occurring during the 2007 refueling outage also needed to be reevaluated. These actions were being tracked under AR 1148193.
Analysis The failure to properly evaluate the in-service test failure was considered a performance deficiency. Specifically, by not considering the source of the debris in the AI-611 valve seat, the licensee failed to identify a MPFF affecting the safety-related HPCI system. This prevented the licensee from properly evaluating the affect of the MPFF on the HPCI system and implementing any corrective actions to prevent recurrence.
7 Enclosure The finding is more than minor because it directly affected the Equipment Performance attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to identify the MPFF prevented the licensee from evaluating the affect on the HPCI system and implementing any corrective actions to prevent recurrence.
The inspectors conducted a Phase I characterization and screening of the finding in accordance with IMC 0609, Appendix A, "Determining the Significance of Reactor Inspection Findings for At-Power Situations." Because there had been no loss of the instrument air system during the period that the AI-611 valve may have been unable to close, the HPCI system remained operable, therefore, the finding screened out as having very low safety significance (Green).
The performance deficiency has a cross-cutting aspect in the area of PI&R, Corrective Action Program, because the licensee did not evaluate the source of the debris in the AI-611 valve and therefore, did not identify a MPFF of the HPCI system. P.1(c)
Enforcement:
10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Licensee procedure FP-PA-ARP-01, "CAP Action Request Process," revision 20, defines a CAQ (step 4.23), in part, as "Failures, malfunctions, deficiencies, deviations, defective material and equipment and non-conformances that have the potential to affect operability or functionality of safety-related systems, structures or components." This same step required that CAQs be captured in the CAP.
Contrary to the above, on March 31, 2007, the licensee failed to identify that the in-service test failure of the AI-611 valve was due to prior maintenance and was therefore a MPFF. Because this MPFF potentially prevented the safety-related HPCI system from performing its design function, this met the licensee's definition of a CAQ that should have been captured in the CAP. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program as AR 1148193, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000263/2008008-01 - Failure to Identify a Condition Adverse to Quality and Implement Corrective Actions to Prevent Recurrence).
- (3) Effectiveness of Corrective Actions The inspectors concluded that over the two year period encompassed by the inspection, the licensee implemented effective corrective actions. Corrective actions were generally well implemented, effective in addressing the parent issues, and timely. The inspectors identified no significant examples where problems recurred.
Findings No findings of significance were identified.
8 Enclosure
.2 Assessment of the Use of Operating Experience (OE)
a. Inspection Scope
The inspectors reviewed the licensee's implementation of the facility's OE program. Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors' review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented.
b. Assessment In general, OE was effectively used at the station. The inspectors observed that OE was discussed as part of the daily station planning meetings, at shift turnover meetings, and at maintenance pre-briefings. Also, the inspectors determined that OE was appropriately reviewed during causal evaluations. During interviews, several licensee personnel commented favorably on the use of OE in their daily activities.
The inspectors noted that OE was not always effectively utilized by the licensee. For example, the ineffective use of OE was a precursor to the vessel overfilling event and the underground cabling issues that were reviewed during an NRC Special Inspection conducted in September 2008 (Inspection Report 05000263/2008009). The inspectors also identified two examples where OE evaluations were poorly documented, in part due to a lack of sufficient oversight regarding the quality of OE evaluations. These examples were associated with the licensee's review of NRC Information Notices (IN) 2006-26, "Failure of Magnesium Rotors in Motor-Operated Valve Actuators," and 2006-29, "Potential Common Cause Failure of Motor-Operated Valves as a Result of Stem Nut Wear." The inspectors further noted that the licensee had identified a potential CAQ in one of these evaluations, but had failed to enter it in the CAP. This was considered a finding and NCV.
The licensee issued AR 1158444 to address the failure to properly document and make CAP entries for the above two INs.
Findings Failure to Capture a CAQ In the CAP
Introduction:
A finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified by the inspectors, for the failure to identify and correct a CAQ. Specifically, during a review of OE, the licensee identified a concern with the potential corrosion of magnesium motor rotor fan blades and shorting rings associated with some 9 Enclosure safety-related motor operated valves (MOVs). The licensee did not enter this concern into the CAP, resulting in a CAQ not being identified or corrected.
Description:
On December 11, 2006, the licensee initiated AR 1066797 to review NRC IN 2006-26, "Failure of Magnesium Rotors in Motor-Operated Valve Actuators." The IN described recent failures of MOV actuators due to oxidation and corrosion of the magnesium motor rotor fan blades and shorting ring resulting from exposure to high humidity and temperatures. The licensee's evaluation concluded that a similar concern existed at Monticello and identified five safety-related MOVs that were "at risk" due to the operating environment (i.e., temperature and humidity) and duty cycle. These MOVs included:
- Division 1 Residual Heat Removal (Low Pressure Core Injection) Outboard MOV;
- Division 2 Residual Heat Removal (Low Pressure Core Injection) Outboard MOV;
- Division 1 Residual Heat Removal (Low Pressure Core Injection) Inboard MOV;
- #11 reactor recirculation pump discharge MOV; and
- #12 reactor recirculation pump discharge MOV.
This review had been performed by a licensee engineer who was no longer working at the station. The engineer had not documented this review or entered it into the CAP. Instead, the engineer had initiated a General Action Request (GAR) to track industry resolution of the concern and initiated work requests to examine the MOVs during a subsequent outage.
Issues potentially affecting safety-related components were required to be identified in the CAP as CAQs, in accordance with station procedure FP-PA-OE-01, "Operating Experience Program," revision 9. As stated in station procedure FP-AR-ARP-03, "Non-CAP Action Request Process," revision 2, a GAR is not considered part of the CAP. A GAR is typically used to track low level items that don't meet the threshold of the CAP. Unlike CAP items, they are not screened or otherwise evaluated for operability, reportability or otherwise required to have corrective actions.
The lack of a CAP entry meant that this issue was not identified a CAQ and that, therefore, there was no independent review of the engineer's conclusions or recommended corrective actions. This also meant that the work requests could be cancelled without justification as there was no indicator that they were necessary to address a CAQ.
Analysis The failure to follow the procedural requirement to identify this issue as a CAQ in the CAP is a performance deficiency. This deficiency resulted in the licensee failing to ensure that a CAQ had been properly identified and corrected.
The finding is more than minor because it directly affected the Human Performance attribute of the Initiating Events Cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions while at power. The finding also directly affected the Equipment Performance attribute of the Mitigating System cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, by not identifying this issue as a CAQ in the CAP, the 10 Enclosure licensee was unable to ensure that the affect on the above safety-related MOVs were properly evaluated and that the appropriate corrective actions were implemented.
The inspectors conducted a Phase I characterization and screening of the finding in accordance with IMC 0609, Appendix A, "Determining the Significance of Reactor Inspection Findings for At-Power Situations." Because the issue only involved the potential degradation, but not the actual loss of plant components, there was no actual initiating event or loss of a mitigating system function; therefore, this finding screened out as having very low safety significance (Green).
The performance deficiency has a cross-cutting aspect in the area of PI&R, Corrective Action Program, because the licensee did not enter the item into the CAP preventing it from being properly evaluated. P.1(c)
Enforcement:
10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Licensee procedure FP-PA-ARP-01, defines a CAQ (step 4.10), in part, as "failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances that have the potential to affect nuclear safety, operability or functionality of safety-related systems." Station procedure FP-PA-OE-01 required that CAQs identified through OE review be entered into the CAP.
Contrary to the above, on December 11, 2006, the licensee failed to identify a potential concern associated with some safety-related MOVs as a CAQ in the CAP. Specifically, the licensee identified that some MOVs may have experienced corrosion of the magnesium motor rotor fan blades and shorting ring based on their operating history. Because these MOVs were safety-related, this issue would be considered a CAQ that is required to be identified in the CAP. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program as AR 1158444, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000263/2008008-02 - Failure to Identify a Condition Adverse to Quality).
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors assessed the licensee staff's ability to identify and enter issues into the CAP program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits.
b. Assessment The inspectors considered the quality of the nuclear oversight (NOS) audits to be thorough and critical. The self-assessments were acceptable but, as expected, they were not at the same level of quality as the audits. The inspectors observed that ARs had been initiated for issues identified through the NOS audits and self-assessments.
11 Enclosure The inspectors attended a meeting of the Performance Assessment Review Board on November 5, and reviewed board meeting minutes from January to June 2007 and from April to October 2008. The Board provided oversight for the CAP including the self-assessment program. The inspectors identified no issues with the Board's performance during the inspection.
Findings No findings of significance were identified.
.4 Assessment of Safety-Conscious Work Environment (SCWE)
a. Inspection Scope
The inspectors assessed the licensee's safety-conscious work environment through the reviews of the facility's ECP implementing procedures, discussions with ECP coordinators, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results of licensee safety culture surveys.
b. Assessment The inspectors determined that the plant staff were aware of the importance of having a strong SCWE and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for safety issues raised, or knew of anyone who had failed to raise issues. All persons interviewed had an adequate knowledge of the CAP and ECP.
Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable SCWE.
The inspectors observed that there continued to be a concern with the level of rigor over the DPO process. A similar issue had been identified during the 2006 PI&R inspection and documented in ARs 01062966 and 01063040. Specifically, in 2006, the inspectors had identified that there was no designated site individual to assist program users and that typically those wanting to use the programs had to assume the burden in ensuring that the issues were properly resolved. In addition, there was no clear interface between the DPO and the CAP, in that DPO issues were not captured in the CAP nor were related CAP issues generally linked to DPO items. The inspectors were concerned that the overall lack of rigor over the DPO process may result in some workers feeling reluctant to raise concerns and/or some issues not being properly evaluated or documented.
During a self-assessment of the CAP done in preparation for the 2008 NRC PI&R inspection, the licensee identified that DPO initiators continued to bear the burden for issue resolution. In addition, the NRC inspectors noted that while DPOs were now entered into the CAP, there was no specific designator or identifier such that the DPOs were easily tracked or retrievable. In fact, the inspectors identified one example of a DPO that, while it was in the CAP, had not been identified by the licensee during a review of the CAP entries in preparation for the NRC inspection. The licensee documented both of these issues in ARs 1147604 and 1158451, respectively.
12 Enclosure Findings No findings of significance were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On November 7, 2008, the inspectors presented the inspection results to Mr. O'Connor and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- T. Blake, Regulatory Affairs Manager
- A. Brown, Performance Assessment Coordinator
- W. Flaga, Maintenance Manager
- J. Grubb, Engineering Director
- D. Horgan, Performance Assessment Supervisor
- K. Jepson, Business Support Manager
- T. O'Connor, Site Vice-President
- S. Radebaugh, Acting Plant Manager
- L. Taufen, Self-Assessment Coordinator
- E. Weinkam, Nuclear Licensing and Emergency Preparedness Director Nuclear Regulatory Commission
- K. Riemer, Chief, Branch 2, Division of Reactor Projects
Other
- J. Ruff, Institute of Nuclear Power Operations
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000263/2008008-01 NCV Failure to Adequately Identify a Condition Adverse to Quality and Identify Corrective Actions to Prevent Recurrence (4OA2.1(2))
- 05000263/2008008-02 NCV Failure to Identify a Condition Adverse to Quality (Section 4OA2.2)
Closed
- 05000263/FIN-2008008-01 NCV Failure to Adequately Identify a Condition Adverse to Quality and Identify Corrective Actions to Prevent Recurrence (4OA2.1(2))
- 05000263/FIN-2008008-02 NCV Failure to Identify a Condition Adverse to Quality (Section 4OA2.2)
- Attachment
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection.
- Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
- Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
- PLANT PROCEDURES Number Description or Title Date or Revision
- EWI-05.01.01 Monticello Maintenance Rule Program Document 11
- FG-PA-ACE-01 Apparent Cause Evaluation Manual 11
- FG-PA-CCE-01 Common Cause Evaluation Manual 4
- FG-PA-CTC-01 CAP Trend Code Manual 10
- FG-PA-DRUM-01 Department Roll Up Meeting (DRUM) Manual - Department Performance Trending
- FG-PA-PAR-01 Performance Assessment Review Board Guideline
- FG-PA-RCE-01 Root Cause Evaluation Manual 14
- FP-OP-OL-01 Operability Determination January 16, 2008
- FP-NO-QC-02 Quality Control Inspection and Peer Verification Planning 1
- FP-NO-QC-03 Inspection/Verification Performance 2
- FP-PA-ARP-01 CAP Action Request Process 20
- FP-PA-ARP-03 Non-CAP Action Request Process 2
- FP-PA-OE-01 Operating Experience Program 9
- FP-PA-SA-01 Focused Self-Assessment Planning, Conduct and Reporting
- FP-PA-SA-02 Focused Self-Assessment and Formal Benchmarking Scheduling
- FP-PA-SA-03 Snap-Shot Evaluation 3
- FP-PA-SA-04 Benchmarking Process 3
- PEI-06.01 Maintenance Rule Coordinator Activities 3
- CP 0060 Differing Professional Opinions 4
- CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 819463 Extensive Repairs to Casing of #12 Reactor Feed Pump (P-2B) Will be Required March 15, 2005
- 834615 12 RFP Inbd Bearing Temp Reading 30 Deg F Less than Expected April 18, 2005
- 1000146 The NMC Fleet Has Not Demonstrated Sufficient and Consistent Oversight to Sustain Training Excellence October 4, 2005
- Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 1001676 QC Process Interpretations May Not Meet Regulatory Intent
- 1053159 Training Value Lost by Running Fire Drills w/o a Controller October 1, 2006
- 1053789 CAPR Not Institutionalized in Site Procedures October 4, 2006
- 1053881 Incorrect Acceptance Criteria Specified in ITS SR 3.5.1.3.b October 4, 2006
- 1054166 Adverse Trend in Material Issues October 5, 2006
- 1054428 Tracking and Trending Low Level/Near Miss Events October 7, 2006
- 1054920 Unexpected Results from 11 EDG Overspeed Trip Test October 11, 2006
- 1055213 P-223 Has a Minor Fuel Oil Leak When 11 EDG is Running October 12, 2006
- 1055915 Ops DRUM Report Potential Adverse Trend in Work Control/Mgmt October 16, 2006
- 1056116 Fire Brigade Announced Drills May Not Comply with Appendix R October 17, 2006
- 1056182 Motor Terminal Voltages Could Drop Below 90% Rated October 17, 2006
- 1056297 Ladder Found Obstructing Access to Fire Extinguisher October 18, 2006
- 1057719 Resident NRC Inspector Question Regarding Possible Release Path October 25, 2006
- 1058110 Excessive LOR Cycle Exam Failures October 27, 2006
- 1058219 Unqualified Instructors Performed Simulator Instruction October 27, 2006
- 1059020 ACE Quality Improvement Progress Insufficient November 1, 2006
- 1059454 Bases for Inspection of Fire Dampers Unclear November 2, 2006
- 1059620 Construction Practices for Radiation Monitors Questioned November 3, 2006
- 1059908 Adverse Trend in Modification Implementation November 6, 2006
- 1059908
- Adverse Trend in MOD Implementation November 6, 2006
- 1060535 Ops Training Comprehensive Identified Issure November 8, 2006
- 1061159
- TCV-8027 Not Maintaining V-MZ-1 Temp Above Trip Setpoint November 11, 2006
- 1062083 Procedures Issued Without Appropriate Approvals per Process November 16, 2006
- 1062274 Worker Injures Finger While Threading Pipe at Pipe Machine November 16, 2006
- 1062541 Adverse Trend in Control of Contractor November 30, 2006
- 1062986 Lack of Rigor in Differing professional Opinion Process November 20, 2006
- Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 1063193 Inspector Independence DPO Tracking
- 1063937 Lack of Specified Crteria for PARB Review of
- ACE November 27, 2006
- 1064189 CAP Number Not Cross Referenced in Work Request November 28, 2006
- 1064261 Documentation Shortcomings with
- AR 01024239 Downgrade November 29, 2006
- 1064422 NRC IN Action Closed without Action Taken November 29, 2006
- 1064422 NRC IN Action Closed Without Action Taken November 29, 2006
- 1064612 Sensitivity to CAP Indicators
- November 30, 2006
- 1065327 Contaminated Drain Hose Improperly Contained December 4, 2006
- 1066632 Adverse Trend in Emergent Work December 9, 2006
- 1069549 Breaker Trips During Service Water Modification Testing December 30, 2006
- 1069920 Loss of EPR, Entered C.4.B.05.09.B January 4, 2007
- 1070581 Instructor Did Not Complete Annual Requirements per FL ICT January 8, 2007
- 1070596 H-2, Crane Chair Badly Degraged, Has Exposed Lead January 8, 2007
- 1070767 Sheared Pin On F-100A, 11 Traveling Screen January 9, 2007
- 1071128 Root Cause Evaluation of January 10, 2007 Group 1 Isolation and Automatic Scram January 10, 2007
- 1071669 Worker Received Intake of radioactive material and PCE January 13, 2007
- 1072679 Weld Rod Control Not in Accordance With the Procedure January 19, 2007
- 1073031 Abnormal Behavior of
- CRD 42-11 January 21, 2007
- 1073225 Calculation
- CA-07-001 Inappropriate Analysis Assumption January 22, 2007
- 1073813
- ILT 2007 Audit Exam Results Were Below Expectations January 25, 2007
- 1074016 Out of Spec Low SBLC Tank Temp Challenges Operators January 26, 2007
- 1074246 Welder Did Not Have the Proper Qualification for Welding January 26, 2007
- 1075283 Combustible Loading Change Request Form is Confusing February 2, 2007
- 1075452 Continuing Adverse Trend in Procedure Use and Compliance February 3, 2007
- Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 1075455 Potential Adverse Trend in Number of Open CAP Evals February 3, 2007
- 1076385 Broken Shear Pin on F-100C #13 Traveling Screen February 9, 2007
- 1076419 PORC Members and Alternates Not Verified Qualified as Required February 9, 2007
- 1076706
- QAF-Recurring Programmatic Issues with Site Welding Program February 12, 2007
- 1076852 Stack WRGM A Maximum High Flow Rate Not As Expected February 21, 2007
- 1077567 Inadequate Procedure Exists for Temp Heating Boiler Install February 16, 2007
- 1078193 Procedure Step Performed Incorrectly February 20, 2007
- 1078482 Source Shield Container for Cs SRC#246 Does not Close January 31, 2007
- 1078606 NRC Question Concerning Temp Heating Boiler Install Time February 21, 2007
- 1078872 Maint. Rule (a)(3) Periodic Evaluations Late Per
- PEI-06.01 February 22, 2007
- 1078881 NRC Comments on OPR for 14 ESW Pump February 22, 2007
- 1078997 Exam Scores or Pass Rates for Licensed Operators in Training Lower Than Expected February 19, 2007
- 1080056 Remaining in ODCM Action Challenges Chemistry Unnecessarily March 1, 2007
- 1080889 Missed Opportunity by NOS to Identify Incomplete QAF CA March 7, 2007
- 1081038 ESW Surv Test Doesn't Verify Perf at Worst Design Condition March 7, 2007
- 1082005 IRM Half-Scram Received When
- MO-4085A Opened During Shutdown March 14, 2007
- 1082168 Cords Staged Outside Combustible Loading Permit Zone March 14, 2007
- 1082734 Lost Essential Bus 16 During Isolation Activities March 18, 2007
- 1083862 13 Air Compressor Shutdown during Procedure
- 1335 March 24, 2007
- 1084697 Worker Entered Drywell on Wrong Work Order March 29, 2007
- 1084821 55 Gal. Oil Drum Near
- MCC-121 931' TB West March 29, 2007
- 1084873 Rad Worker Practices March 29, 2007
- 1085284 Inadvertent introduction of Water into Torus April 1, 2007
- 1086332
- AO-14-13A Failed IST Seat leakage and Close Exercise Test April 6, 2007
- 1086584 Valves
- MO-2373 and
- MO-2374 Not Installed per Design April 7, 2007
- Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 1086927
- AI-611 Failed the Leak Rate Test on 0255-06-ID-3 April 10, 2007
- 1087156 RX Head was Incorrectly Oriented during Installation April 11, 2007
- 1088981 Adv Trd: Monitoring Fails to Pre-Identify Pipe Wall Failures April 22, 2007
- 1092436 Inadequate Corrective Action Program Implementation May 15, 2007
- 1092929 Chemistry Procedures in Conflict Re:
- Chlorine Analysis May 16, 2007
- 1093098 Perform Evaluation of NRC Violation May 17, 2007
- 1093105 Perform Evaluation of NRC Violation May 17, 2007
- 1093378 Negative Trend in Simulator Interruptions May 20, 2007
- 1093863 Adverse Trend on Control of Items Important to
- EP May 23, 2007
- 1093869 Adverse Trend in ACEs Failing Grading May 23, 2007
- 1093939 Maintenance Rework Program Not Maintained for Approx. 1 Year May 24, 2007
- 1094396 Trend in Events Attributed to management Oversight May 29, 2007
- 1094761 Loss of Motor Cooling Flow to Div 1 RHRSW Pumps June 1, 2007
- 1095058 Adverse Trend in Vehicle Barrier Performance June 4, 2007
- 1095107 Wrong Due Date Given to
- ITS-Extended Freq. Surveillance June 4, 2007
- 1095330 Drain Lines on Contaminated Tanker Trailer Rusted Through June 5, 2007
- 1095951 Negative Trend in Ops Performance using Jumpers and Boots June 8, 2007
- 1096071 Several Rad Material Control Events in Last 2 years --Trend June 8, 2007
- 1096082 Common Fire Brigade Turnout Gear Could Result in Unsafe PPE June 8, 2007
- 1097253 QAF:
- Continuing Ineffective Actions for Rad Material Storage June 18, 2007
- 1099499 PCR1075517 Changes Conflict with Fire Prot. Requirements June 27, 2007
- 1099797 Departmental NRC Cross-Cutting KPI Turns Red for June 2007 June 29, 2007
- 1100713 Continuing Trend in Critical Relay Failures July 8, 2007
- Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 1101396 F100D, #14 Traveling Screen Sheared a Pin July 11, 2007
- 1101494 Non-compliant manual Actions in 4kV Rooms July 12, 2007
- 1102121 Adverse Trend Noted in Engineering Verification and Validation July 16, 2007
- 1102728 EP Work Process Code Trend is Negative July 20, 2007
- 1102947 Adverse Trnd in Security Staffing July 23, 2007
- 1104401 Possible Non-Factual Information in NRC Submittal July 31, 2007
- 1104540 NRC Identified Problems with
- LER 2007-03 Following Review July 31, 2007
- 1105662
- LER 2007-003 Required Revision August 7, 2007
- 1106470 Adverse Trend in Events Caused by Inadequate Knowledge August 11, 2007
- 1106519 Adverse Trend in Equipment Performance August 12, 2007
- 1107470 Adverse Trend in Numbers of Ops Burdens August 17, 2007
- 1107640 Adverse Trend/Ineffective Actions ACE Quality August 19, 2007
- 1107707 V-AC-4, B4305, Found INOP August 20, 2007
- 1108192 Drain Valve Closed Unexpectedly Due to I&C Calibration August 22, 2007
- 1108516 Adverse Trend for Entry into Tech Spec 3.0.3 August 23, 2007
- 1109246 Past Operability of HPCI Not Addressed in CAP on
- AI-611 Failure August 29, 2007
- 1110297 Conflict Between Tech Specs and USAR on RHR Intertie Line [Condition Evaluation] September 7, 2007
- 1111293 Grounds for Work on 1N6 Not Hung per Procedure September 13, 2007
- 1111840 Broken Shear Pin on F-100B, #12 Traveling Screen September 18, 2007
- 1113483 Screen Wash / Fire Pump Panel C-115 Degraded Cable September 28, 2007
- 1114068 Maintenance Rule HTV System Disposition to a(1) Status October 5, 2007
- 1114724 Change in Indicated Reactor Power Following Replacement of Data Acquisition Module
[Root Cause Evaluation] November 12, 2007
- 1115003 Craftsmen Did Not Follow Procedure Use and Adherence October 16, 2007
- 1116351 Ability to Extinguish Charcoal Fire in EFT Filter Trains October 29, 2007
- 1116586 Unplanned rise in Offgas Radiation and Stack WRGMs October 31, 2007
- 1117340 Station Review of NRC Violation 2007-04-01
- Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 1117341 Station Review of NRC Violation 2007-04-02 November 7, 2007
- 1117812
- CV-1059 Positioner Bypass Valve Gasket Missing November 12, 2007
- 1117976 Door-27, Upper Latch on West Door is Broken November 13, 2007
- 1118596
- MO-1750 as Left Settings Do Not Meet Desired Values November 20, 2007
- 1119106 Station review of NRC Violation for ISFISI Pad November 27, 2007
- 1119165 Broken Shear Pin on F-100C, #13 Traveling Screen November 27, 2007
- 1119242 Heating Coils Leak on V-MZ-1 November 28, 2007
- 1119377 Maintenance Rule RPV System Dispostion to a(1) Status October 31, 2007
- 1119932 Component Labeling Program Not Being Maintained-Repeat Issue December 3, 2007
- 1120435 Crew Self-Assessment DEP Classification Failure December 7, 2007
- 1120865 V-AC-5 Failure Due to Blown Line Fuse December 11, 2007
- 1122500 Facts for
- CAP 1121728 Are in Question January 1, 2008
- 1122907 Refueling Bridge Struck and Bent Actuator Pole January 7, 2008
- 1123141 Adverse Trend in Improperly Closing out Level B Assignments January 8, 2008
- 1123141 Adverse trend in Improperly Closing Out Level B Assignments
- 23673 11 Cond Demin Holding Pump Motor has Bearing Defects January 14, 2008
- 1124113 Incorrect Procedure Steps Leads to Significant Near Miss January 17, 2008
- 1124434 Excessive Seal Leakage in SW Pumps January 21, 2008
- 1124439 Fleet Procedures May Contain Contrary Guidnace January 21, 2008
- 1124469 Cannot Determine Appropriate Action to Satisfy
- PCR 1094218 January 21, 2008
- 1124744
- PI-7332 Reads 0 PSIG
- 24779 Multiple Issues with Restore 13 DG Reported by Operations January 24, 2008
- 1125950 "A" FW Reg Valve Locked Up While Reducing Reactor Power February 2, 2008
- 1125950 "A" FW Reg Valve Locked-up while Reducing Reactor Power February 2, 2008
- 1126064 V-AH-4B Tripped While isolating V-AH-4A February 4, 2008
- 25675 February 8,. 2008
- Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 27222
- MO-3502 RCIC Test Return Valve Did Not Operate as Expected February 14, 2008
- 1127232 Another Component Incorrectly Categorized as Critical 1 February 14, 2008
- 1127242 Adverse Trend: Inadequate Maintenance of Quality Records
- 27489
- MO-3502 Automatically Closed During RCIC Surveillance February 15, 2008
- 1127954 Extension Cord Found to be Going Through Metal Doors February 19, 2008
- 1128185 Adverse Trend of #12 RFP Inboard Bearing Temp February 12, 2008
- 1128442 Full Impact of
- AI-611 Failure on Performance Indicator not Considered February 23, 2008
- 1128547 Unannounced Fire Drills Can be a Safety Issue for Personnel February 24, 2008
- 1129669 Area for Improvement
- 29678 Area for Improvement
- 29683 Area for Improvement
- 1129998 Received 2 Unexpected Alarms in Control Room
- 1130761
- CV-1729 Not controlling at 7000gpm Results in Unplanned LCO March 12, 2008
- 1130834 Adverse Trend in Important Equipment Failures March 12, 2008
- 1131417 MSIV Stroke Time Tests Not Performed Prior to 2007 RFO Maint March 17, 2008
- 1131482 155,000 Gallons of Excess Water Diverted to Radwaste March 18, 2008
- 1131600 SQAS Documents are Not Controlled, Not Applicable to ADL/AEL March 18, 2008
- 1131700 Level B CAP Closed without Completing Identified Action March 19, 2008
- 1131914
- Safety Concern Associated with HELB Maintenance March 20, 2008
- 1132227 Deviations From Overtime Work Restrictions Were Approved for Situations that Did Not Align with the Requirements of 4 AWI-08.10.01.
- 1132446 Guidance to Restrictive in
- FP-E-EVL-01 March 27, 2008
- 1133249 V-EF-26 Damper
- DO-8000A-33 Found in Open Position April 3, 2008
- 1133354 14 Traveling Screen Shear Pin Broken April 4, 2008
- 1133755 Complex Isolation Interactions De-energize Panel P-52 April 8, 2008
- 1134058 Downward Trend in Human Performance Index April 10, 2008
- 1134601 Tech Spec Bases 3.3.3.2 is Misleading April 15, 2008
- 1134645 USAR Appendix J.5 Fire Hazards Analysis is Inaccurate April 16, 2008
- Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 1134671 A.8 Procedure Quality Does Not Meet Expectations April 16, 2008
- 1134676 A.8-05.06 to Maximize CRD Flow Includes Incorrect Assumptions April 16, 2008
- 1134681 A.8-05.02 Does Not Specify Opening of LPCI Injection Valves April 16, 2008
- 1134747 NRC Questioned Lack of Compensatory Measures April 16, 2008
- 1134770
- CA-03-052, Diesel Oil Storage Tank-Level Temperature Error April 17, 2008
- 1135282 Discrepancies Between LMS-id'ed Quals and Other Qual Matrices April 22, 2008
- 1135335 Adverse Trend in EP Drill Report Timeliness April 22, 2008
- 1136793 Leakage Into Torus Requires Periodic Pumpdown May 5, 2008
- 1136879 Oil Flush on 11 Service Water Motor Ineffective May 6, 2008
- 1136919 Loss of Motor Cooling to Div II RHRSW Pumps May 6, 2008
- 1136955 Adverse Trend in Service Water Rad Monitor Flow Alarms May 7, 2008
- 1136955 Adverse Trend In Service Water Rad Monitor Flow Alarms May 7, 2008
- 1136991 Workers Contaminated with 1500 cpm Particle on Bottom of Shoe May 7, 2008
- 1137059 B5b SFP Internal Floodup Strategy Found Inadequate by NRC May 7, 2008
- 1137191 Trend in Security Injuries and Near Misses May 8, 2008
- 1137245 Document Quality Issues June 12, 2008
- 1137297 D10 Exhibits Erratic Voltage Output During Surveillance May 9, 2008
- 1137382 Shear Pin on #12 Traveling Screen Replaced May 10, 2008
- 1137953 Unauthorized Personnel had Access to Exam Materials May 16, 2008
- 1138006 Fire Brigade Responsibilities can be a Danger to Employees May 16, 2008
- 1138236
- Received RBCCW Surge Tank Low Level Alarm May 20, 2008
- 1138609 Scaffolding Obstructs Access to Fire Hose Reel May 23, 2008
- 1138824 Battery Chargers Maintenance Rule Status Declining May 27, 2008
- 1139423 Negative Trend in Number of Maintenance HU
- CAPs May 30, 2008
- 1139427 Potential Adverse Trend in Significant and Noteworthy Events May 30, 2008
- 1139428 Negative Trend in Equipment Performance and Failure Events May 30, 2008
- 1139430 Negative Trend in Engineering Personnel Related Events May 30, 2008
- 1139715 Operability Determination Assessment Issues June 3, 2008
- Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 1139881 The Difference in Stack WRGM Release Rates is Getting Larger June 4, 2008
- 1139974 Received REC008 While Trying to Adjust Reactor Power June 4, 2008
- 1140073 P-105 Diesel Small Fuel Leak June 5, 2008
- 1140154 Adverse Trend in Rigor of Operational Risk Assessment June 6, 2008
- 1140237 Differential Pressure Switch Discovered Out of As-Found Spec June 6, 2008
- 1140362 Danger Tags for
- EC-746 Remain Hanging for 1 1/2 Years June 9, 2008
- 1140582 17 250v Battery, Cell 19 Specific Gravity Out of Spec June 11, 2008
- 1140675 Combustible Material Not Properly Stored in reactor Building June 11, 2008
- 1140836 Unintentional Transfer of Y-71 to Alternate Source June 12, 2008
- 1141206 EP Procedure Revised without Notifying Users June 17, 2008
- 1141296 Adverse Trend in Training Committee Performance June 18, 2008
- 1141433 On-going Coolant Sample Testing Issues June 19, 2008
- 1141638 No PMs Created for V-EAC-18 and V-CH-28 June 20, 2008
- 1141662 Items Outside Door-201 Possible Fire Brigade Obstruction June 21, 2008
- 1142254 Adverse Trend in Human Performance Related Events June 27, 2008
- 1143567 Inadequate Conclusion Stated in Calculation 05-
- 104 June 30, 2008
- 1143647 Operability Questions During Maintenance on A EFT/CRV July 9, 2008
- 1144039 For Components Not Yet Accepted Unclear How to Treat in CAP July 14, 2008
- 1144130 ACE Grading Critiques are Not Evaluated for Trends July 14, 2008
- 1144214 Trend-RCE Grades Low in 2 Areas July 15, 2008
- 1144794 Safety- Possible Trip Hazard on Torus Walkway July 21, 2008
- 1144926 Ops HU Data Shows Adverse Trend in Work Activity Engagement July 22, 2008
- 1145135 Shear Pin Found Broken on #12 Traveling Screen (F-100B) July 24, 2008
- 1145203 Performance Trend of #12 REC Pump Seal July 24, 2008
- 1146758 Deficiencies in Troubleshooting Process Identified By Site August 6, 2008
- 1147201 Unexpected Classification During Simulator Evaluation August 11, 2008
- 1147604 DPO Process Lacks Rigor August 15, 2008
- 1147861 Refuel Bridge Contacted Pole During Procedure
- 9010 August 19, 2008
- Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- 1148148 Oral Boards Not Completed per the ILT Program Description August 21, 2008
- 1148731 EDG: Document Power Factor Testing Limitation August 27, 2008
- 1148801 Adverse Trend in Megger Results on V-EF-18B August 27, 2008
- 1150410 SR 3.8.1.1 Not Completed in 1 Hour Following Scram September 12, 2008
- 1190115 NRC Potential Green NCV on
- PEI-02.03, 12 Inadequate August 28, 2007
- OPERATING EXPERIENCE Number Description or Title Date or Revision
- OEE 01085499-04 (OEER 01085499) Perform OE Evaluation of NRC
- IN 2007-11 April 2, 2007
- 1064910 NRC Information Notice 2006-23 December 1, 2006
- 1068900 Station Requested OE Evaluations of Industry
Documents
- December 21, 2006
- 10889203 Air Leak Found on
- CV-1729 April 23, 2007
- Attachment OPERATING EXPERIENCE Number Description or Title Date or Revision
- 1092063 Required LCO Not Entered During Performance of 0424 May 10, 2007
- 1126257 Part 21 GE Fuel Rod Thermal-Mechanical Methodology February 5, 2008
- 1104436 EDG Lister Battery Temp Above 90 deg F July 31, 2007
- 1088223 Percon-Operator 200 ncpm on Shoe From Clean Area in TB Bldg April 17, 2007
- 1114859 11/12 EDG Air Bank XTIE Valve Position Op Implic Not Doc October 16, 2007
- 1117957 Unattended Gun Sent Through X-Ray Machine November 13, 2007
- 1121432 Over Estimated the Dose Estimate for WO
- 00334970 December 17, 2007
- 1130291 PORC Open Items Not Tracked to Closure March 7, 2008
- 1135418 Small, Short-Term Increase in Reactor Water Iodines Noted April 23, 2008
- 1135949 11 & 12 MG Sets April 29, 2008
- 1140476 HPCI Unavailability Window Runs 3 Hours Longer Than Scheduled June 10, 2008
- AUDITS, ASSESSMENTS AND
- SELF-ASSESSMENTS Number Description or Title Date or Revision
- MT-FSA-06-21 (SAR 01022090) Monticello Operations Training Self Evaluation October 23, 2006 thru October 27, 2006
- SAR 01117506 Reportability August 14, 2008
- AR 01116699 PI&R Self-Assessment June 16-20, 2008
- NOS 2 nd Quarter 2008 Assessment Report for Monticello July 29, 2008 NOS 2008-03-
- 007 Corrective Action Program July 1, 2008 to
- July 16, 2008 NOS 2008-01-
- 015 Plant Operations Review Committee January 10, 2008 to March 7, 2008 NOS 2008-03-
- 017 Security August 4, 2008 to
- August 8, 2008 NOS 2008-01-
- 004 Radiation Protection February 25, 2008 to March 3, 2008
- NOS Assessment Report for Monticello 4th Quarter 2006
- Attachment AUDITS, ASSESSMENTS AND
- SELF-ASSESSMENTS Number Description or Title Date or Revision
- NOS 2007-03-
- 001 Fleet Security Assessment September 24, 2007 to September 28, 2007 NOS 2007-04-
- 007 Operating Experience Self-Assessment October 1, 2007 to October 12, 2007
- AR 01053873 Focused Self-Assessment of SOER Recommendation Implementation Review January 8, 2007 to January 12, 2007
- MT-FSA-01054545 Radiation Contamination Control November 12, 2007 to
- November 16, 2007
- MT-FSA-06-25 Security Training December 11, 2006 to December 14, 2006
- AR 01092379 Service Water Assessment May 14, 2007 to May 23, 2007
- CONDITION REPORTS GENERATED DURING INSPECTION Number Description or Title Date or Revision
- 1158451 DPO Process Lacks Documentation Rigor and Retrievability November 6, 2008
- 1156990 Recommendations of OEER
- 1068900-06 Not Implemented October 27, 2008
- 1158446 Some CAP Indicator Lack Goals and Action Levels November 6, 2008
- 1158444 OEE Potentiallly Adverse to Quality Not Entered Into CAP November 6, 2008
- 1158435 No Guidance for Required Maintenance Rule a(3) Report Approval November 6, 2008
- 1148193 RFO23 IST Failure Not Evaluated for Aggregate System Impact August 21, 2008
- 1157395 Error Likely Situation Exists for Potential Maintenance Rule CAPs October 29, 2008
- MISCELLANEOUS
- Number Description or Title Date or Revision Performance Assessment Review Board Minutes January 3, 2007 to June 20, 2007
- Performance Assessment Review Board Minutes April 8, 2008 to October 10, 2008 Alteration 05A-
- 034 P2-B Casing and Diaphragm Alteration March 31, 2005
- NMC-1 Quality Assurance Topical Report 4
- OR 2008-01-032 Corrective Action Program 1st Quarter 2008
- Attachment MISCELLANEOUS
- Number Description or Title Date or Revision
- OR 2008-03-007 Corrective Action Program 3rd Quarter 2008
- OR 2008-02-032 Quarterly Results Review 2nd Quarter 2008
- OR 2008-03-029 Quarterly Results Review 3rd Quarter 2008
Work Orders
- Number Description or Title Date or Revision
- 0311868 P-2B Overhaul and Rotating Assembly Replacement December 17, 2003
- 00140416 #12 RFP Inbd Bearing T/C Not Properly Installed February 16, 2007
- 00330862 P-2B Repair Excessive Oil Leaks on Pump and Motor April 26, 2008
- Department Roll-Up Meeting Reports Number Description or Title Date or Revision Engineering nd Quarter 2008
- MNGP Security st Quarter 2008
- MNGP Security nd Quarter 2008
- Monticello (site wrap-up)
st Quarter 2008
- Monticello (site wrap-up)
th Quarter 2007
- Radiation Protection/Chemistry th Quarter 2007
- Radiation Protection/Chemistry st Quarter 2008
- Radiation Protection/Chemistry nd
- Quarter 2008
- Security 4 th Quarter 2007
- Site Roll-Up Performance Results nd Quarter 2007
- Site Roll-Up Performance Results rd Quarter 2007
- Site Roll-Up Performance Results th Quarter 2007
- Site Roll-Up Performance Results st Quarter 2008
- GAR 01115556 Training Department Roll-Up Meeting Report 4
th Quarter 2007
- GAR 01122510 Business Support Department Roll-Up Meeting Report 4 th Quarter 2007
- GAR 01122683 Maintenance Dept 4Q07 DRUM January 30, 2008
- GAR 01124582 Operations Department Roll-Up Meeting Report 4
th Quarter 2007
- GAR 01132938 Business Support Department Roll-Up Meeting Report 1 st Quarter 2008
- GAR 01133099 Maintenance Dept 1Q08 DRUM May 1, 2008
- GAR 01134253 Operations Department Roll-Up Meeting Report 1
st Quarter 2008
- GAR 01137681 Training Department Roll-Up Meeting Report 1
st Quarter 2008
- GAR 01142527 Maintenance Dept 2Q08 DRUM July 31, 2008
- GAR 01142942 Business Support Department Roll-Up Meeting Report 2 nd Quarter 2008
- GAR 01143547 Training Department Roll-Up Meeting Report 2
nd Quarter 2008
- GAR 01144520 Operations Department Roll-Up Meeting Report 2
nd Quarter 2008
- Attachment
LIST OF ACRONYMS
- USED [[]]
- NRC [[]]