IR 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:
Report Number:
Enterprise Identifier: I-2019-002-0062
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.
REACTOR SAFETY
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.
- 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,
RADIATION SAFETY
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
- 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
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
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
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
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
Ultrasonic (UT) Examination of ESW-B Loop Piping
Component No. NF-93492-B P7
01/23/2019
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
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
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
Corrective Action
Documents
501000021904
Discharge Canal Temp Monitoring Failure
501000027462
Tailgate into Vital Area
501000027532
Engineering
Evaluations
600000477574
600000477592
Engineering Change Approval
600000477601
CFR 50.59 Applicability and Det. Review
611000001543
Computer Work Order
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
HPCI Torus Suction Valve Interlock High Level Switches &
HPCI Pump Min Flow Control Flow Switch Channel
Functional Test and Channel Calibration
HPCI High Steam Flow Pressure Sensor Test and
Calibration
HPCI Low Steam Supply Pressure Sensor Test and
Calibration
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
Corrective Action
Documents
501000025585
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
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
SRM and IRM Functional and Logic System Functional Test
Special Operations Checklist or Technical Specification LCO 3.10.2
P-1043-03
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
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
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
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