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| issue date = 03/27/2007
| issue date = 03/27/2007
| title = IR 05000263-07-006( Drs); 02/12/2007 Through 03/01/2007; Monticello Nuclear Generating Plant. Evaluations of Changes, Tests, Experiments and Permanent Plant Modifications
| title = IR 05000263-07-006( Drs); 02/12/2007 Through 03/01/2007; Monticello Nuclear Generating Plant. Evaluations of Changes, Tests, Experiments and Permanent Plant Modifications
| author name = Hills D E
| author name = Hills D
| author affiliation = NRC/RGN-III/DRS/EB1
| author affiliation = NRC/RGN-III/DRS/EB1
| addressee name = Conway J
| addressee name = Conway J
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| page count = 19
| page count = 19
}}
}}
See also: [[followed by::IR 05000263/2007006]]
See also: [[see also::IR 05000263/2007006]]


=Text=
=Text=
{{#Wiki_filter:March 27, 2007Mr. J. ConwaySite Vice President
{{#Wiki_filter:March 27, 2007
Mr. J. Conway
Site Vice President
Monticello Nuclear Generating Plant
Monticello Nuclear Generating Plant
Nuclear Management Company, LLC
Nuclear Management Company, LLC
2807 West County Road 75
2807 West County Road 75
Monticello, MN 55362-9637SUBJECT:MONTICELLO NUCLEAR GENERATING PLANT NRC EVALUATION OFCHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT
Monticello, MN 55362-9637
MODIFICATIONS BASELINE INSPECTION REPORT 05000263/2007006(DRS)Dear Mr. Conway:
SUBJECT:
On March 1, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed a combinedbaseline inspection of the Evaluation of Changes, Tests, or Experiments and Permanent Plant
MONTICELLO NUCLEAR GENERATING PLANT NRC EVALUATION OF
CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT
MODIFICATIONS BASELINE INSPECTION REPORT 05000263/2007006(DRS)
Dear Mr. Conway:
On March 1, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed a combined
baseline inspection of the Evaluation of Changes, Tests, or Experiments and Permanent Plant
Modifications at the Monticello Nuclear Generating Plant.  The enclosed report documents the
Modifications at the Monticello Nuclear Generating Plant.  The enclosed report documents the
results of the inspection, which were discussed with Mr. J. Grubb, and others of your staff at the
results of the inspection, which were discussed with Mr. J. Grubb, and others of your staff at the
completion of the inspection on March 1, 2007.The inspectors examined activities conducted under your license as they relate to safety andcompliance with the Commission's Rules and Regulations, and with the conditions of your
completion of the inspection on March 1, 2007.
The inspectors examined activities conducted under your license as they relate to safety and
compliance with the Commissions Rules and Regulations, and with the conditions of your
license.  The inspectors reviewed selected procedures and records, observed activities, and
license.  The inspectors reviewed selected procedures and records, observed activities, and
interviewed personnel.Based on the results of the inspection, one NRC identified finding, which involved a violation ofNRC requirements of very low safety significance, was identified.  Because of the very low
interviewed personnel.
safety significance of the violation and the fact that the issue was entered into the licensee's
Based on the results of the inspection, one NRC identified finding, which involved a violation of
NRC requirements of very low safety significance, was identified.  Because of the very low
safety significance of the violation and the fact that the issue was entered into the licensees
corrective action program, the NRC is treating the finding as a Non-Cited Violation (NCV) in
corrective action program, the NRC is treating the finding as a Non-Cited Violation (NCV) in
accordance with Section VI.A.1 of the NRC's Enforcement Policy. In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC PublicDocument Room, or from the Publicly Available Records (PARS) component of NRC's
accordance with Section VI.A.1 of the NRCs Enforcement Policy.  
J. Conway-2-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/David E. Hills, ChiefEngineering Branch 1
In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter
Division of Reactor SafetyDocket No. 50-263License No. DPR-22Enclosure:Inspection Report 05000263/2007006(DRS) w/Attachment:  Supplemental Informationcc w/encl:M. Sellman, President and Chief Executive OfficerManager, Nuclear Safety Assessment
and its enclosure will be available electronically for public inspection in the NRC Public
Document Room, or from the Publicly Available Records (PARS) component of NRC's  
 
J. Conway
-2-
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/
David E. Hills, Chief
Engineering Branch 1
Division of Reactor Safety
Docket No. 50-263
License No. DPR-22
Enclosure:
Inspection Report 05000263/2007006(DRS)
  w/Attachment:  Supplemental Information
cc w/encl:
M. Sellman, President and Chief Executive Officer
Manager, Nuclear Safety Assessment
J. Rogoff, Vice President, Counsel, and Secretary
J. Rogoff, Vice President, Counsel, and Secretary
Nuclear Asset Manager, Xcel Energy, Inc.
Nuclear Asset Manager, Xcel Energy, Inc.
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Commissioner, Minnesota Department of Commerce
Commissioner, Minnesota Department of Commerce
Manager - Environmental Protection Division
Manager - Environmental Protection Division
   Minnesota Attorney General's Office  
   Minnesota Attorney Generals Office
J. Conway-2-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/David E. Hills, ChiefEngineering Branch 1
 
Division of Reactor SafetyDocket No. 50-263License No. DPR-22Enclosure:Inspection Report 05000263/2007006(DRS) w/Attachment:  Supplemental Informationcc w/encl:M. Sellman, President and Chief Executive OfficerManager, Nuclear Safety Assessment
J. Conway
-2-
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/
David E. Hills, Chief
Engineering Branch 1
Division of Reactor Safety
Docket No. 50-263
License No. DPR-22
Enclosure:
Inspection Report 05000263/2007006(DRS)
  w/Attachment:  Supplemental Information
cc w/encl:
M. Sellman, President and Chief Executive Officer
Manager, Nuclear Safety Assessment
J. Rogoff, Vice President, Counsel, and Secretary
J. Rogoff, Vice President, Counsel, and Secretary
Nuclear Asset Manager, Xcel Energy, Inc.
Nuclear Asset Manager, Xcel Energy, Inc.
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Commissioner, Minnesota Department of Commerce
Commissioner, Minnesota Department of Commerce
Manager - Environmental Protection Division
Manager - Environmental Protection Division
   Minnesota Attorney General's OfficeDOCUMENT NAME:C:\FileNet\ML070860170.wpd
   Minnesota Attorney Generals Office
DOCUMENT NAME:C:\\FileNet\\ML070860170.wpd
G Publicly Available
G Publicly Available
G Non-Publicly Available
G Non-Publicly Available
G Sensitive
G Sensitive
G Non-SensitiveTo receive a copy of this document, indicate in the concurrence  box "C" = Copy without attach/encl "E" = Copy with attach/encl  "N" = No copyOFFICERIIIRIII  RIIINAMEADunloplsDHillsDATE03/27/0703/27/07OFFICIAL RECORD COPY  
G Non-Sensitive
J. Conway-3-DISTRIBUTION
To receive a copy of this document, indicate in the concurrence  box "C" = Copy without attach/encl "E" = Copy with attach/encl  "N" = No copy
:TEB
OFFICE
PST
RIII
RIII
 
RIII
NAME
ADunlopls
DHills
DATE
03/27/07
03/27/07
OFFICIAL RECORD COPY
 
J. Conway
-3-
DISTRIBUTION:
TEB
PST
RidsNrrDirsIrib
RidsNrrDirsIrib
GEG
GEG
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GLS
GLS
CST1
CST1
CAA1
CAA1
LSL
LSL
CDP1
CDP1
DRPIII
DRPIII
DRSIII
DRSIII
PLB1
PLB1
TXN
TXN
ROPreports@nrc.gov
ROPreports@nrc.gov  
U.S. NUCLEAR REGULATORY COMMISSIONREGION IIIDocket No:50-263License No:DPR-22Report No:05000263/2007006(DRS)
 
Licensee:Nuclear Management Company, LLC
U.S. NUCLEAR REGULATORY COMMISSION
Facility:Monticello Nuclear Generating Plant
REGION III
Location:Monticello, Minnesota
Docket No:
Dates:February 12, 2007 through March 1, 2007
50-263
Inspectors:A. Dunlop, Senior Reactor InspectorT. Bilik, Reactor InspectorObservers:V. Meghani, Reactor InspectorApproved by:D. Hills, ChiefEngineering Branch 1
License No:
Division of Reactor Safety (DRS)  
DPR-22
Enclosure 1SUMMARY OF FINDINGSIR 05000263/2007006(DRS); 02/12/2007 through 03/01/2007; Monticello Nuclear GeneratingPlant.  Evaluations of Changes, Tests, Experiments and Permanent plant modifications. The inspection covered a 2-week announced baseline inspection on evaluations of changes,tests, or experiments and permanent plant modifications.  The inspection was conducted by
Report No:
05000263/2007006(DRS)
Licensee:
Nuclear Management Company, LLC
Facility:
Monticello Nuclear Generating Plant
Location:
Monticello, Minnesota
Dates:
February 12, 2007 through March 1, 2007
Inspectors:
A. Dunlop, Senior Reactor Inspector
T. Bilik, Reactor Inspector
Observers:
V. Meghani, Reactor Inspector
Approved by:
D. Hills, Chief
Engineering Branch 1
Division of Reactor Safety (DRS)
 
Enclosure
1
SUMMARY OF FINDINGS
IR 05000263/2007006(DRS); 02/12/2007 through 03/01/2007; Monticello Nuclear Generating
Plant.  Evaluations of Changes, Tests, Experiments and Permanent plant modifications.  
The inspection covered a 2-week announced baseline inspection on evaluations of changes,
tests, or experiments and permanent plant modifications.  The inspection was conducted by
two regional based engineering inspectors.  One Green finding associated with a Non-Cited
two regional based engineering inspectors.  One Green finding associated with a Non-Cited
Violation (NCV) was identified.  The significance of most findings is indicated by their color(Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance
Violation (NCV) was identified.  The significance of most findings is indicated by their color
Determination Process (SDP)." Findings for which the SDP does not apply may be Green, or
(Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance
Determination Process (SDP).  Findings for which the SDP does not apply may be Green, or
be assigned a severity level after NRC management review.  The NRC's program for
be assigned a severity level after NRC management review.  The NRC's program for
overseeing the safe operation of commercial nuclear power reactors is described in
overseeing the safe operation of commercial nuclear power reactors is described in
NUREG-1649, "Reactor Oversight Process," Revision 3; dated July 2000.A.Inspector-Identified and Self-Revealed FindingsCornerstone:  Mitigating SystemsGreen.  The inspectors identified a Severity Level IV NCV for an inadequate 10 CFR50.59, "Changes, Tests, and Experiments," evaluation resulting in failure to receive
NUREG-1649, Reactor Oversight Process, Revision 3; dated July 2000.
A.
Inspector-Identified and Self-Revealed Findings
Cornerstone:  Mitigating Systems
Green.  The inspectors identified a Severity Level IV NCV for an inadequate 10 CFR
50.59, Changes, Tests, and Experiments, evaluation resulting in failure to receive
prior NRC approval for changes in licensed activities associated with protection of
prior NRC approval for changes in licensed activities associated with protection of
the emergency diesel generator exhaust stacks against tornado generated missiles.  
the emergency diesel generator exhaust stacks against tornado generated missiles.  
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part of the corrective actions, the licensee verified that the emergency diesel generators
part of the corrective actions, the licensee verified that the emergency diesel generators
remained operable and initiated actions to submit a licensee amendment request for use
remained operable and initiated actions to submit a licensee amendment request for use
of the new methodology.Because the Significance Determination Process is not designed to assess thesignificance of violations that potentially impact or impede the regulatory process, this
of the new methodology.
Because the Significance Determination Process is not designed to assess the
significance of violations that potentially impact or impede the regulatory process, this
issue was dispositioned using the traditional enforcement process in accordance with
issue was dispositioned using the traditional enforcement process in accordance with
Section IV of the NRC Enforcement Policy.  However, the results of the violation, that is,
Section IV of the NRC Enforcement Policy.  However, the results of the violation, that is,
the failure to demonstrate that the proposed change did not result in a departure from a
the failure to demonstrate that the proposed change did not result in a departure from a
method of evaluation, were assessed using the Significance Determination Process. The finding was determined to be greater than minor because the change had thepotential for impacting the NRC's ability to perform its regulatory function as the
method of evaluation, were assessed using the Significance Determination Process.  
The finding was determined to be greater than minor because the change had the
potential for impacting the NRCs ability to perform its regulatory function as the
inspectors determined the change would have required prior NRC approval.  The
inspectors determined the change would have required prior NRC approval.  The
finding was of very low safety significance based on the completed analysis for the
finding was of very low safety significance based on the completed analysis for the
emergency diesel generator exhausts.  This was determined to be a Severity Level IV
emergency diesel generator exhausts.  This was determined to be a Severity Level IV
NCV of 10 CFR 50.59.  (Section 1R02)B.Licensee-Identified ViolationsNo findings of significance were identified.  
NCV of 10 CFR 50.59.  (Section 1R02)
Enclosure 2REPORT DETAILS1.REACTOR SAFETYCornerstones:  Initiating Events, Mitigating Systems, and Barrier Integrity1R02Evaluations of Changes, Tests, or Experiments (71111.02).1Review of 10 CFR 50.59 Evaluations and Screenings a.Inspection ScopeFrom February 12, 2007, through March 1, 2007, the inspectors reviewed twoevaluations performed pursuant to 10 CFR 50.59.  The inspectors reviewed the
B.
Licensee-Identified Violations
No findings of significance were identified.
 
Enclosure
2
REPORT DETAILS
1.
REACTOR SAFETY
Cornerstones:  Initiating Events, Mitigating Systems, and Barrier Integrity
1R02
Evaluations of Changes, Tests, or Experiments (71111.02)
.1
Review of 10 CFR 50.59 Evaluations and Screenings
  a.
Inspection Scope
From February 12, 2007, through March 1, 2007, the inspectors reviewed two
evaluations performed pursuant to 10 CFR 50.59.  The inspectors reviewed the
evaluations to confirm that they were thorough and that prior NRC approval was
evaluations to confirm that they were thorough and that prior NRC approval was
obtained as appropriate.  The inspector could not review the minimum sample size of
obtained as appropriate.  The inspector could not review the minimum sample size of
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evaluations and screenings were chosen based on risk significance, safety significance,
evaluations and screenings were chosen based on risk significance, safety significance,
and complexity.  The list of documents reviewed by the inspectors are included as an
and complexity.  The list of documents reviewed by the inspectors are included as an
attachment to this report.The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, "Guidelines for 10 CFR 50.59 Implementation," and Revision 1, to determine acceptability of the
attachment to this report.
The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for  
10 CFR 50.59 Implementation, and Revision 1, to determine acceptability of the
completed evaluations, and screenings.  The NEI document was endorsed by the
completed evaluations, and screenings.  The NEI document was endorsed by the
NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59,
NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59,
Changes, Tests, and Experiments," dated November 2000.  The inspectors also
Changes, Tests, and Experiments, dated November 2000.  The inspectors also
consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR
consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR
50.59, Changes, Tests, and Experiments.b.FindingsInadequate 10 CFR 50.59 Evaluation for Diesel Generator Exhaust Missile Protection Introduction:  The inspectors identified an inadequate evaluation performed pursuant to10 CFR 50.59 associated with the vulnerability of the emergency diesel generator (EDG)
50.59, Changes, Tests, and Experiments.
  b.
Findings
Inadequate 10 CFR 50.59 Evaluation for Diesel Generator Exhaust Missile Protection  
Introduction:  The inspectors identified an inadequate evaluation performed pursuant to
10 CFR 50.59 associated with the vulnerability of the emergency diesel generator (EDG)
exhaust stacks to tornado generated missiles.  Specifically, the licensee did not provide
exhaust stacks to tornado generated missiles.  Specifically, the licensee did not provide
an adequate response to the question posed in 10 CFR 50.59(c)(2)(viii) and did not
an adequate response to the question posed in 10 CFR 50.59(c)(2)(viii) and did not
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evaluation described in the USAR used in establishing the design bases or in the safety
evaluation described in the USAR used in establishing the design bases or in the safety
analyses.  This issue was considered to be of very low safety significance (Green) and
analyses.  This issue was considered to be of very low safety significance (Green) and
was dispositioned as a Severity Level IV Non-Cited Violation (NCV).  
was dispositioned as a Severity Level IV Non-Cited Violation (NCV).
Enclosure 3Description:  The inspectors reviewed 10 CFR 50.59 safety evaluation (SE) 03-004,concerning the utilization of the "TORMIS" probabilistic risk assessment (PRA)
 
Enclosure
3
Description:  The inspectors reviewed 10 CFR 50.59 safety evaluation (SE) 03-004,
concerning the utilization of the TORMIS probabilistic risk assessment (PRA)
methodology (per Electric Power Research Institute (EPRI) Report NP-2005,
methodology (per Electric Power Research Institute (EPRI) Report NP-2005,
Volumes 1 and 2).  This methodology was to verify that the risk from tornado
Volumes 1 and 2).  This methodology was to verify that the risk from tornado
generated missiles was sufficiently small to justify leaving the EDG exhaust
generated missiles was sufficiently small to justify leaving the EDG exhaust
unprotected.  On page 7 of SE 03-004 in Section III.8, the licensee responded to thequestion posed in 10 CFR 50.59(c)(2)(viii).  This question asked, "Does the proposed
unprotected.  On page 7 of SE 03-004 in Section III.8, the licensee responded to the
question posed in 10 CFR 50.59(c)(2)(viii).  This question asked, "Does the proposed
change result in a departure from a method of evaluation described in the Final Safety
change result in a departure from a method of evaluation described in the Final Safety
Analysis Report (as updated) used in establishing the design bases or in the safety
Analysis Report (as updated) used in establishing the design bases or in the safety
analyses"?  The licensee justified the "No" answer to this question by citing the NRC
analyses?  The licensee justified the No answer to this question by citing the NRC
acceptance of the EPRI methodology for specific plant features and subject to resolution
acceptance of the EPRI methodology for specific plant features and subject to resolution
of specific concerns in the NRC's safety evaluation for EPRI Report NP-2005, dated
of specific concerns in the NRCs safety evaluation for EPRI Report NP-2005, dated
October 26, 1983.  The licensee's evaluation included addressing the specific
October 26, 1983.  The licensees evaluation included addressing the specific
concerns and stated that the resolutions of these concerns for the Monticello plant
concerns and stated that the resolutions of these concerns for the Monticello plant
were consistent with those accepted by the NRC for the D. C. Cook Nuclear Plant
were consistent with those accepted by the NRC for the D. C. Cook Nuclear Plant
(Amendment No. 247 to DPR-58 and Amendment No. 228 to DPR-74). The NRC's safety evaluation concluded that the PRA methodology as contained in theEPRI report was an acceptable probabilistic approach for demonstrating compliance
(Amendment No. 247 to DPR-58 and Amendment No. 228 to DPR-74).  
The NRCs safety evaluation concluded that the PRA methodology as contained in the
EPRI report was an acceptable probabilistic approach for demonstrating compliance
with the requirements of General Design Criteria 2 and 3 regarding protection of
with the requirements of General Design Criteria 2 and 3 regarding protection of
safety-related plant features from the effects of tornado and high wind generated
safety-related plant features from the effects of tornado and high wind generated
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specific plant feature where additional costly tornado missile protective barriers or
specific plant feature where additional costly tornado missile protective barriers or
alternative systems were under consideration.  The inspectors contacted the staff in the
alternative systems were under consideration.  The inspectors contacted the staff in the
Office of Nuclear Reactor Regulation (NRR) to determine the basis for the NRC's safety
Office of Nuclear Reactor Regulation (NRR) to determine the basis for the NRCs safety
evaluation and the acceptability of the licensee using this methodology that was not in
evaluation and the acceptability of the licensee using this methodology that was not in
accordance with the current licensing basis.  Based on this discussion, although the
accordance with the current licensing basis.  Based on this discussion, although the
methodology had been reviewed and could be used as a basis for not having to
methodology had been reviewed and could be used as a basis for not having to
physically protect specific plant features from tornado generated missiles, it was
physically protect specific plant features from tornado generated missiles, it was
considered a change to the plant's current licensing basis, which required a licenseamendment.Based on the above, the inspectors concluded that the licensee use of NRC's safetyevaluation on the EPRI methodology was incorrect and that the licensee's "No" answer
considered a change to the plants current licensing basis, which required a license
to 10 CFR 50.59(c)(2)(viii), and the conclusion that "no activity requiring prior NRC
amendment.
approval per 10 CFR 50.59 was identified" were not justified.  The inspectors also determined that the results of the calculations based on the EPRImethodology discussed above were utilized for responses to the questions for
Based on the above, the inspectors concluded that the licensee use of NRCs safety
10 CFR 50.59(c)(2) (i) through (vi) in Section III of the SE 03-004 and that a USARchange was implemented to incorporate the use of TORMIS methodology.  This finding
evaluation on the EPRI methodology was incorrect and that the licensees No answer
also affected the licensee's 10 CFR 50.59 screening SCR-04-0069, Revision 0, which
to 10 CFR 50.59(c)(2)(viii), and the conclusion that no activity requiring prior NRC
approval per 10 CFR 50.59 was identified were not justified.   
The inspectors also determined that the results of the calculations based on the EPRI
methodology discussed above were utilized for responses to the questions for
10 CFR 50.59(c)(2) (i) through (vi) in Section III of the SE 03-004 and that a USAR
change was implemented to incorporate the use of TORMIS methodology.  This finding
also affected the licensees 10 CFR 50.59 screening SCR-04-0069, Revision 0, which
was used to screen out activities involving subsequent application of the EPRI
was used to screen out activities involving subsequent application of the EPRI
methodology for evaluation of other plant specific features from tornado generated
methodology for evaluation of other plant specific features from tornado generated
missiles.


missiles.
Enclosure
Enclosure 4In response to the finding, the licensee initiated Action Request (AR) 01079705.  Thelicensee determined that the NRC's 1983 safety evaluation endorsing the EPRI TORMIS
4
In response to the finding, the licensee initiated Action Request (AR) 01079705.  The
licensee determined that the NRCs 1983 safety evaluation endorsing the EPRI TORMIS
methodology was misinterpreted by the licensee as a generic NRC approval for use and
methodology was misinterpreted by the licensee as a generic NRC approval for use and
was inappropriately used in the 50.59 evaluation to conclude that prior NRC approval
was inappropriately used in the 50.59 evaluation to conclude that prior NRC approval
was not required.  The licensee determined the EDGs remained operable based on the
was not required.  The licensee determined the EDGs remained operable based on the
existing completed analysis and acceptance of similar technical approach by the NRC
existing completed analysis and acceptance of similar technical approach by the NRC
for other operating plants.  The inspectors concluded that the licensee's determination
for other operating plants.  The inspectors concluded that the licensees determination
was acceptable as the existing analysis using the TORMIS methodology did appear to
was acceptable as the existing analysis using the TORMIS methodology did appear to
address the limitations noted in the NRC's safety evaluation.  The AR also
address the limitations noted in the NRCs safety evaluation.  The AR also
recommended an action to submit an license amendment request to the NRC to
recommended an action to submit an license amendment request to the NRC to
incorporate the TORMIS methodology into the license basis for all the affected plant
incorporate the TORMIS methodology into the license basis for all the affected plant
specific features. Analysis:  This issue was determined to involve a performance deficiency because thelicensee incorrectly concluded that the TORMIS methodology had been approved for
specific features.  
Analysis:  This issue was determined to involve a performance deficiency because the
licensee incorrectly concluded that the TORMIS methodology had been approved for
generic application and consequently concluded that prior NRC approval was not
generic application and consequently concluded that prior NRC approval was not
required when such a conclusion could not be supported by the documented 50.59
required when such a conclusion could not be supported by the documented 50.59
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traditional enforcement process instead of the significance determination process (SDP)
traditional enforcement process instead of the significance determination process (SDP)
described in Inspection Manual Chapter (IMC) 0609, "Significance Determination
described in Inspection Manual Chapter (IMC) 0609, "Significance Determination
Process." The finding was determined to be greater than minor because the change
Process.  The finding was determined to be greater than minor because the change
had the potential for impacting the NRC's ability to perform its regulatory function as the
had the potential for impacting the NRCs ability to perform its regulatory function as the
inspectors determined the change would have required prior NRC approval. The inspectors evaluated the finding using IMC 0609, Appendix A, "SignificanceDetermination of Reactor Inspection Findings for At-Power Situations," Phase 1
inspectors determined the change would have required prior NRC approval.  
The inspectors evaluated the finding using IMC 0609, Appendix A, Significance
Determination of Reactor Inspection Findings for At-Power Situations, Phase 1
screening, and determined that the finding screened as Green because it was not a
screening, and determined that the finding screened as Green because it was not a
design issue resulting in loss of function per Part 9900, Technical Guidance,
design issue resulting in loss of function per Part 9900, Technical Guidance,
"Operability Determinations, and Functionality Assessments for Resolution of Degraded,
Operability Determinations, and Functionality Assessments for Resolution of Degraded,
or Nonconforming Conditions Adverse to Quality or Safety," did not represent an actual
or Nonconforming Conditions Adverse to Quality or Safety, did not represent an actual
loss of a system safety function, did not result in exceeding a technical specification
loss of a system safety function, did not result in exceeding a technical specification
allowed outage time, and did not affect external event mitigation.  This was based on the
allowed outage time, and did not affect external event mitigation.  This was based on the
licensee's operability determination that concluded that their use of the TORMIS
licensees operability determination that concluded that their use of the TORMIS
methodology appeared to be consistent with the guidance provided in the NRC's safety
methodology appeared to be consistent with the guidance provided in the NRCs safety
evaluation of the methodology and that NRC had accepted its' use at other plants when
evaluation of the methodology and that NRC had accepted its use at other plants when
used for the intended purpose.  The inspectors did not identify a cross-cutting aspect
used for the intended purpose.  The inspectors did not identify a cross-cutting aspect
with this finding.Enforcement:  Title 10 CFR 50.59(c)(2)(viii) states, in part, that a licensee shall obtain alicense amendment pursuant to Section 50.90 prior to implementing a proposed change,
with this finding.
Enforcement:  Title 10 CFR 50.59(c)(2)(viii) states, in part, that a licensee shall obtain a
license amendment pursuant to Section 50.90 prior to implementing a proposed change,
test, or experiment if the change, test, or experiment would result in a departure from a
test, or experiment if the change, test, or experiment would result in a departure from a
method of evaluation described in the Final Safety Analysis Report (as updated) used in
method of evaluation described in the Final Safety Analysis Report (as updated) used in
establishing the design bases or in the safety analyses.Contrary to the above, on July 28, 2003, the licensee approved a 10 CFR 50.59evaluation (SE-03-004) incorporating a change to the tornado missile protection
establishing the design bases or in the safety analyses.
Contrary to the above, on July 28, 2003, the licensee approved a 10 CFR 50.59
evaluation (SE-03-004) incorporating a change to the tornado missile protection
methodology for the EDG exhaust system, which resulted in a departure from a method
methodology for the EDG exhaust system, which resulted in a departure from a method
of evaluation described in the USAR, without obtaining a license amendment.  However,  
of evaluation described in the USAR, without obtaining a license amendment.  However,
Enclosure 5because this violation was of very low safety significance and it was entered into thelicensee's corrective action program, this Severity Level IV violation is being treated as
 
Enclosure
5
because this violation was of very low safety significance and it was entered into the
licensees corrective action program, this Severity Level IV violation is being treated as
an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy
an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy
(NCV 05000263/2007006-01(DRS)).  The licensee entered the finding into their
(NCV 05000263/2007006-01(DRS)).  The licensee entered the finding into their
corrective action program as AR01079705.1R17Permanent Plant Modifications (71111.17B).1Review of Permanent Plant Modifications a.Inspection ScopeFrom February 12, 2007, through March 1, 2007, the inspectors reviewed tenpermanent plant modifications that had been installed in the plant during the last two
corrective action program as AR01079705.
1R17
Permanent Plant Modifications (71111.17B)
.1
Review of Permanent Plant Modifications
  a.
Inspection Scope
From February 12, 2007, through March 1, 2007, the inspectors reviewed ten
permanent plant modifications that had been installed in the plant during the last two
years.  This included two engineering changes, three equivalency evaluations, and five
years.  This included two engineering changes, three equivalency evaluations, and five
setpoint changes.  The modifications were chosen based upon risk significance, safety
setpoint changes.  The modifications were chosen based upon risk significance, safety
Line 217: Line 376:
testing aspects were verified to ensure the functionality of the modification, its
testing aspects were verified to ensure the functionality of the modification, its
associated system, and any support systems.  The inspectors also verified that the
associated system, and any support systems.  The inspectors also verified that the
modifications performed did not place the plant in an increased risk configuration.The inspectors also used applicable industry standards to evaluate acceptability of themodifications.  The list of modifications and other documents reviewed by the inspectors
modifications performed did not place the plant in an increased risk configuration.
is included as an attachment to this report. b.FindingsNo findings of significance were identified.4.OTHER ACTIVITIES (OA)4OA2Identification and Resolution of Problems.1Routine Review of Condition Reports a.Inspection ScopeFrom February 12, 2007, through March 1, 2007, the inspectors reviewed 18 CorrectiveAction Process documents that identified or were related to 10 CFR 50.59 evaluations
The inspectors also used applicable industry standards to evaluate acceptability of the
modifications.  The list of modifications and other documents reviewed by the inspectors
is included as an attachment to this report.
  b.
Findings
No findings of significance were identified.
4.
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
.1
Routine Review of Condition Reports
  a.
Inspection Scope
From February 12, 2007, through March 1, 2007, the inspectors reviewed 18 Corrective
Action Process documents that identified or were related to 10 CFR 50.59 evaluations
and permanent plant modifications.  The inspectors reviewed these documents to
and permanent plant modifications.  The inspectors reviewed these documents to
evaluate the effectiveness of corrective actions related to permanent plant modifications
evaluate the effectiveness of corrective actions related to permanent plant modifications
and evaluations for changes, tests, or experiments issues.  In addition, corrective action
and evaluations for changes, tests, or experiments issues.  In addition, corrective action
documents written on issues identified during the inspection were reviewed to verify
documents written on issues identified during the inspection were reviewed to verify
adequate problem identification and incorporation of the problems into the corrective  
adequate problem identification and incorporation of the problems into the corrective
Enclosure 6action system.  The specific corrective action documents that were sampled andreviewed by the inspectors are listed in the attachment to this report. b.FindingsNo findings of significance were identified.4OA6Meetings.1Exit MeetingThe inspectors presented the inspection results to Mr. J. Grubb and others of thelicensee's staff, on March 1, 2007.  Licensee personnel acknowledged the inspection
 
Enclosure
6
action system.  The specific corrective action documents that were sampled and
reviewed by the inspectors are listed in the attachment to this report.
  b.
Findings
No findings of significance were identified.
4OA6 Meetings
.1
Exit Meeting
The inspectors presented the inspection results to Mr. J. Grubb and others of the
licensees staff, on March 1, 2007.  Licensee personnel acknowledged the inspection
results presented.  Licensee personnel were asked to identify any documents, materials,
results presented.  Licensee personnel were asked to identify any documents, materials,
or information provided during the inspection that were considered proprietary.  No
or information provided during the inspection that were considered proprietary.  No
proprietary information was identified.ATTACHMENT:  SUPPLEMENTAL INFORMATION  
proprietary information was identified.
ATTACHMENT:  SUPPLEMENTAL INFORMATION
 
Attachment
Attachment
1SUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACT
1
LicenseeR. Baumer, LicensingF. Domke, Electrical Design Supervisor
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
R. Baumer, Licensing
F. Domke, Electrical Design Supervisor
J. Grubb, Engineering Director
J. Grubb, Engineering Director
B. Guldemond, Nuclear Safety Assurance Manager
B. Guldemond, Nuclear Safety Assurance Manager
Line 238: Line 429:
J. Ohotto, Design Engineering Supervisor
J. Ohotto, Design Engineering Supervisor
D. Pennington, Design Engineer
D. Pennington, Design Engineer
B. Sawatzke, Plant ManagerNuclear Regulatory CommissionD. Hills, Chief, Engineering Branch 1, Division of Reactor SafetyS. Thomas, Senior Resident Inspector
B. Sawatzke, Plant Manager
L. Haeg, Resident InspectorITEMS OPENED, CLOSED, AND DISCUSSEDOpened/Closed05000263/2007006-01NCVInadequate 10 CFR 50.59 Evaluation for Diesel GeneratorExhaust Missile Protection (Section 1R21.3.b)  
Nuclear Regulatory Commission
D. Hills, Chief, Engineering Branch 1, Division of Reactor Safety
S. Thomas, Senior Resident Inspector
L. Haeg, Resident Inspector
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened/Closed
05000263/2007006-01
NCV
Inadequate 10 CFR 50.59 Evaluation for Diesel Generator
Exhaust Missile Protection (Section 1R21.3.b)
 
Attachment
Attachment
2LIST OF DOCUMENTS REVIEWEDThe following is a list of licensee documents reviewed during the inspection, includingdocuments prepared by others for the licensee.  Inclusion on this list does not imply that NRC
2
LIST OF DOCUMENTS REVIEWED
The following is a list of licensee documents reviewed during the inspection, including
documents prepared by others for the licensee.  Inclusion on this list does not imply that NRC
inspectors reviewed the documents in their entirety, but rather, that selected sections or
inspectors reviewed the documents in their entirety, but rather, that selected sections or
portions of the documents were evaluated as part of the overall inspection effort.  Inclusion of a
portions of the documents were evaluated as part of the overall inspection effort.  Inclusion of a
document in this list does not imply NRC acceptance of the document, unless specifically statedin the inspection report.IR02Evaluation of Changes, Tests, or Experiments 71111.0210 CFR 50.59 EvaluationsSE-03-004; Diesel Exhaust Missile Protection Design Consideration; datedJuly 28, 2003SE-06-003; SBO Operator Actions Associated with the HPCI System; dated September 19, 200610 CFR 50.59 ScreeningsSCR-04-0283; SRV Air Actuator Model Change; dated November 23, 2005
document in this list does not imply NRC acceptance of the document, unless specifically stated
SCR-04-0859; HPCI Turbine Steam Supply Low Pressure Isolation; datedSeptember 11, 2006SCR-05-0161; Set Point for RHR Minimum Flow Switches FS-10-2-121, A, B, C and D;dated August 23, 2006SCR-05-0242; Instrument Setpoint Calculation 4.16KV Degraded Voltage; datedMarch 28, 2006SCR-05-0266; ITS Setpoint Change - HPCI Steam Line Area Temperature - High;dated  August 26, 2006SCR-05-0689; Calc CA-05-146, Evaluation of Wall Thinning on FW2B-10-ED; datedOctober 11, 2005SCR-05-0738; Calc CA-05-028, Evaluation of HPCI Condensate Drain Line D13-2"-HEin the HPCI Room; dated November 9, 2005SCR-05-0739; Calc 05-147, Evaluation of HPCI Module E.2; dated November 9, 2005
in the inspection report.
SCR-05-0757; Chilled Water Expansion Tank V-CT-1 Replacement; datedNovember 15, 2005SCR-05-0822; CA-05-155, Evaluation of Offgas Stack for SSE Seismic Loads; datedDecember 22, 2005  
IR02
Evaluation of Changes, Tests, or Experiments 71111.02
10 CFR 50.59 Evaluations
SE-03-004; Diesel Exhaust Missile Protection Design Consideration; dated
July 28, 2003
SE-06-003; SBO Operator Actions Associated with the HPCI System; dated  
September 19, 2006
10 CFR 50.59 Screenings
SCR-04-0283; SRV Air Actuator Model Change; dated November 23, 2005
SCR-04-0859; HPCI Turbine Steam Supply Low Pressure Isolation; dated
September 11, 2006
SCR-05-0161; Set Point for RHR Minimum Flow Switches FS-10-2-121, A, B, C and D;
dated August 23, 2006
SCR-05-0242; Instrument Setpoint Calculation 4.16KV Degraded Voltage; dated
March 28, 2006
SCR-05-0266; ITS Setpoint Change - HPCI Steam Line Area Temperature - High;
dated  August 26, 2006
SCR-05-0689; Calc CA-05-146, Evaluation of Wall Thinning on FW2B-10-ED; dated
October 11, 2005
SCR-05-0738; Calc CA-05-028, Evaluation of HPCI Condensate Drain Line D13-2"-HE
in the HPCI Room; dated November 9, 2005
SCR-05-0739; Calc 05-147, Evaluation of HPCI Module E.2; dated November 9, 2005
SCR-05-0757; Chilled Water Expansion Tank V-CT-1 Replacement; dated
November 15, 2005
SCR-05-0822; CA-05-155, Evaluation of Offgas Stack for SSE Seismic Loads; dated
December 22, 2005
 
Attachment
Attachment
3SCR-06-0062; Less than Full Thread Engagement on RWCU AO Valve Actuator BonnetNuts; dated February 15, 2006SCR-06-0103; HPCI Steam Void Elimination; dated April 6, 2006
3
SCR-06-0106; Service Water Pump Replacement; October 30, 2006SCR-06-0165; Replace AO-1575(6) and Check Valves with Normally Closed Valve
SCR-06-0062; Less than Full Thread Engagement on RWCU AO Valve Actuator Bonnet
SW-228(9); dated October 31, 2006SCR-06-0166; Replace Rotork Actuators on Five MOVs with Limitorque Actuators;dated April 26, 2006SCR-06-0310; Technical Requirements Manual - Appendix B - Secondary ContainmentIsolation Valves; dated September 12, 2006SCR-06-0557; Suppression Chamber Inspection; dated December 4, 2006
Nuts; dated February 15, 2006
SCR-07-0043; Fuel Storage and Handling Systems, Design Basis; datedJanuary 22, 200710 CFR 50.59 Applicability DeterminationsSCR-05-0645; Drawing Classification Level Change to '3'; dated September 19, 2005
SCR-06-0103; HPCI Steam Void Elimination; dated April 6, 2006
SCR-06-0106; Service Water Pump Replacement; October 30, 2006
SCR-06-0165; Replace AO-1575(6) and Check Valves with Normally Closed Valve
SW-228(9); dated October 31, 2006
SCR-06-0166; Replace Rotork Actuators on Five MOVs with Limitorque Actuators;
dated April 26, 2006
SCR-06-0310; Technical Requirements Manual - Appendix B - Secondary Containment
Isolation Valves; dated September 12, 2006
SCR-06-0557; Suppression Chamber Inspection; dated December 4, 2006
SCR-07-0043; Fuel Storage and Handling Systems, Design Basis; dated
January 22, 2007
10 CFR 50.59 Applicability Determinations
SCR-05-0645; Drawing Classification Level Change to 3'; dated September 19, 2005
SCR-05-0657; Combustible Loading Calculation; dated September 22, 2005
SCR-05-0657; Combustible Loading Calculation; dated September 22, 2005
SCR-05-0663; Replace Fusible Link on V-DF-SBGT-2 with One of a HigherTemperature Rating; dated September 28, 2005SCR-05-0791; Evaluation of Fire Detector Locations in the Reactor Building; datedDecember 5, 2005SCR-05-0819; Setpoint Change Request for the Safety/Relief Valve Low-Low Set Logicto Incorporate the New Trip Settings; dated December 21, 2005SCR-05-0830; Setpoint Change Request for the 4KV Bus-15 and Bus 16 UndervoltageRelays to Incorporate the New Trip Setting; dated January 3, 2006SCR-06-0308; Update USAR for Improved Technical Specification Project; datedJuly, 29, 2006IR17Permanent Plant Modifications 71111.17BModificationsEC8819; HPCI Steam Line Area Temperature - High; dated October 27, 2006
SCR-05-0663; Replace Fusible Link on V-DF-SBGT-2 with One of a Higher
EC7583; Degraded Voltage Relays for Safety-Related 4KV Busses ; datedAugust 7, 2006  
Temperature Rating; dated September 28, 2005
SCR-05-0791; Evaluation of Fire Detector Locations in the Reactor Building; dated
December 5, 2005
SCR-05-0819; Setpoint Change Request for the Safety/Relief Valve Low-Low Set Logic
to Incorporate the New Trip Settings; dated December 21, 2005
SCR-05-0830; Setpoint Change Request for the 4KV Bus-15 and Bus 16 Undervoltage
Relays to Incorporate the New Trip Setting; dated January 3, 2006
SCR-06-0308; Update USAR for Improved Technical Specification Project; dated
July, 29, 2006
IR17
Permanent Plant Modifications 71111.17B
Modifications
EC8819; HPCI Steam Line Area Temperature - High; dated October 27, 2006
EC7583; Degraded Voltage Relays for Safety-Related 4KV Busses ; dated
August 7, 2006
 
Attachment
Attachment
4Equivalency EvaluationsEC910; Replacement Blower Wheel; Revision 1EC933 (05A099); HPCI Auxiliary Lube Oil Pump; Revision 0
4
EC7828; Engine Driven Fuel Pump Suction Line; Revision 0Setpoint ChangesEC8818; HPCI Turbine Steam Line Pressure - Low; dated  October 27, 2006EC8792; LPCI Pump Discharge Flow - Low; dated October 27, 2006
Equivalency Evaluations
EC910; Replacement Blower Wheel; Revision 1
EC933 (05A099); HPCI Auxiliary Lube Oil Pump; Revision 0
EC7828; Engine Driven Fuel Pump Suction Line; Revision 0
Setpoint Changes
EC8818; HPCI Turbine Steam Line Pressure - Low; dated  October 27, 2006
EC8792; LPCI Pump Discharge Flow - Low; dated October 27, 2006
SCR 05-022; 4KV Bus-15 and Bus-16 Undervoltage Relays; dated December 1, 2005
SCR 05-022; 4KV Bus-15 and Bus-16 Undervoltage Relays; dated December 1, 2005
SCR 05-023; Main Steam Line Steam Chase High Temp Group 1 Isolation; datedDecember 1, 2005SCR 05-028; SRV Low Low Set Pressure Interlock; dated December 1, 2005Other Documents Reviewed During InspectionCorrective Action Program Documents Generated As a Result of InspectionAR01076896; List to NRC Screened out All 50.59 Screening using the 3283 Form;
SCR 05-023; Main Steam Line Steam Chase High Temp Group 1 Isolation; dated
AR01077202; SCR-05-0830 Description Contains Incorrect Value; datedFebruary 14, 2007AR01077855; Action to Correct Drawing Error was Cancelled; dated February 19, 2007
December 1, 2005
AR01078665; Error in Calculation CA-05-146, Evaluation of Wall Thinning inFW2B-10"-ED; dated February 22, 2007AR01079705; LAR Required for Use of TORMIS Code Methodology; datedFebruary 28, 2007AR01080049; SCR-05-0161 Activity Incorrectly Categorized; dated March 1, 2007
SCR 05-028; SRV Low Low Set Pressure Interlock; dated December 1, 2005
Corrective Action Program Documents Reviewed During the Inspection AR00824446; NDE Thickness < 87.5 percent TNOM on FW2B-10"-ED, "B" Feedwaterto Reactor Line; March 25, 2005AR00891838; Evidence of Water Leakage on 11 and 12 EDG Exhaust Pipe Insulation;dated September 28, 2005AR01000610; Replacement Part does not Match the Part Removed; datedOctober 10, 2005  
Other Documents Reviewed During Inspection
Corrective Action Program Documents Generated As a Result of Inspection
AR01076896; List to NRC Screened out All 50.59 Screening using the 3283 Form;
AR01077202; SCR-05-0830 Description Contains Incorrect Value; dated
February 14, 2007
AR01077855; Action to Correct Drawing Error was Cancelled; dated February 19, 2007
AR01078665; Error in Calculation CA-05-146, Evaluation of Wall Thinning in
FW2B-10"-ED; dated February 22, 2007
AR01079705; LAR Required for Use of TORMIS Code Methodology; dated
February 28, 2007
AR01080049; SCR-05-0161 Activity Incorrectly Categorized; dated March 1, 2007
Corrective Action Program Documents Reviewed During the Inspection  
AR00824446; NDE Thickness < 87.5 percent TNOM on FW2B-10"-ED, B Feedwater
to Reactor Line; March 25, 2005
AR00891838; Evidence of Water Leakage on 11 and 12 EDG Exhaust Pipe Insulation;
dated September 28, 2005
AR01000610; Replacement Part does not Match the Part Removed; dated
October 10, 2005
 
Attachment
Attachment
5AR01000746; Inconsistency Between Line Design Table and Plant; datedOctober 11, 2005AR01001520; Operation past One Cycle Not Assured for Fw Pipe; datedOctober 20, 2005AR01003632; RC-44-2 Replacement Noticed 3000 No. vs. 6000 No.; datedNovember 14, 2005AR01004032; RWC Pipe Support Discrp and Indad Thread Engage on Act Nuts; datedNovember 17, 2005AR01006064; CV-1728 Plug Replaced, No Section XI Repair/Replacement Plan; datedDecember 1, 2005AR01008347; Some SW Mods May Inadvertently Create New Problems; datedDecember 21, 2005AR01022687; SW 1-18"-JF Does Not Meet Class 1 Design Criteria ; dated April 6, 2006
5
  AR01026395; Potential Exists for Failure to Manually Start ECCS Room Coolers; dated
AR01000746; Inconsistency Between Line Design Table and Plant; dated
April 26, 2006AR01040014; Inadequate Closeout Activities for Design Change 99Q160; datedJuly 17, 2006AR01059716; Change to PM Frequency not Considered; dated November 3, 2006
October 11, 2005
AR01001520; Operation past One Cycle Not Assured for Fw Pipe; dated
October 20, 2005
AR01003632; RC-44-2 Replacement Noticed 3000 No. vs. 6000 No.; dated
November 14, 2005
AR01004032; RWC Pipe Support Discrp and Indad Thread Engage on Act Nuts; dated
November 17, 2005
AR01006064; CV-1728 Plug Replaced, No Section XI Repair/Replacement Plan; dated
December 1, 2005
AR01008347; Some SW Mods May Inadvertently Create New Problems; dated
December 21, 2005
AR01022687; SW 1-18"-JF Does Not Meet Class 1 Design Criteria ; dated April 6, 2006
   
AR01026395; Potential Exists for Failure to Manually Start ECCS Room Coolers; dated
April 26, 2006
AR01040014; Inadequate Closeout Activities for Design Change 99Q160; dated
July 17, 2006
AR01059716; Change to PM Frequency not Considered; dated November 3, 2006
AR01059908; Adverse Trend in Modification Implementation; dated November 6, 2006
AR01059908; Adverse Trend in Modification Implementation; dated November 6, 2006
AR00891237; No Column Gaskets Found on RHRSW Pump Columns; datedSeptember 27, 2005AR1040142; B.03.04-05 Issued Prior to Completion of Revision Process; datedJuly 18, 2006AR0780295; Revise USAR Section 10.2.4.3 to Reflect the Results of CA-95-028; datedNovember 26, 2006AR01045206; 50.59 Screening SCR-05-210 Missed USAR Impact; datedAugust 18, 2006CalculationsCA-03-038; Instrument Setpoint Calculation, 4.16 KV Loss of Voltage; Revision 1
AR00891237; No Column Gaskets Found on RHRSW Pump Columns; dated
CA-03-039; Instrument Setpoint Calculation - SRV Low-Low Set, Reactor CoolantSystem Pressure; Revision 0CA-04-110; Determination of HPCI Area High Temperature Setpoints; Revision 1  
September 27, 2005
AR1040142; B.03.04-05 Issued Prior to Completion of Revision Process; dated
July 18, 2006
AR0780295; Revise USAR Section 10.2.4.3 to Reflect the Results of CA-95-028; dated
November 26, 2006
AR01045206; 50.59 Screening SCR-05-210 Missed USAR Impact; dated
August 18, 2006
Calculations
CA-03-038; Instrument Setpoint Calculation, 4.16 KV Loss of Voltage; Revision 1
CA-03-039; Instrument Setpoint Calculation - SRV Low-Low Set, Reactor Coolant
System Pressure; Revision 0
CA-04-110; Determination of HPCI Area High Temperature Setpoints; Revision 1
 
Attachment
Attachment
6CA-05-108; Evaluation of Wall Thinning on FW2B-10-ED Piping; Revision 0CA-05-146; Evaluation of Wall Thinning on FW2B-10"-ED Piping; Revision 0
6
DrawingsEC-811-01; Monticello Nuclear Generating Plant Installation of HPCI Void Resolution;Revision 1NH-36250; Monticello Nuclear Generating Plant P&ID (Water Side) High PressureCoolant Injection System; Revision AF  
CA-05-108; Evaluation of Wall Thinning on FW2B-10-ED Piping; Revision 0
CA-05-146; Evaluation of Wall Thinning on FW2B-10"-ED Piping; Revision 0
Drawings
EC-811-01; Monticello Nuclear Generating Plant Installation of HPCI Void Resolution;
Revision 1
NH-36250; Monticello Nuclear Generating Plant P&ID (Water Side) High Pressure
Coolant Injection System; Revision AF
 
Attachment
Attachment
7LIST OF ACRONYMS USEDADAMSAgency-Wide Document Access and Management SystemARAction Request
7
CFRCode of Federal Regulations  
LIST OF ACRONYMS USED
DRPDivision of Reactor Projects
ADAMS
DRSDivision of Reactor Safety
Agency-Wide Document Access and Management System
EDGEmergency Diesel Generator
AR
ECEngineering Change
Action Request
EPRIElectric Power Research Institute IMCInspection Manual Chapter
CFR
IRInspection Report
Code of Federal Regulations  
NCVNon-Cited Violation
DRP
NEINuclear Energy Institute
Division of Reactor Projects
NRCNuclear Regulatory Commission
DRS
NRROffice of Nuclear Reactor Regulation  
Division of Reactor Safety
PARSPublicly Available Records
EDG
PRAProbabilistic Risk Assessment
Emergency Diesel Generator
SCRScreening (50.59)  
EC
SCRSetpoint Change Request
Engineering Change
SDPSignificance Determination Process
EPRI
SESafety Evaluation (50.59)  
Electric Power Research Institute  
TSTechnical Specifications
IMC
USARUpdated Safety Analysis Report
Inspection Manual Chapter
IR
Inspection Report
NCV
Non-Cited Violation
NEI
Nuclear Energy Institute
NRC
Nuclear Regulatory Commission
NRR
Office of Nuclear Reactor Regulation  
PARS
Publicly Available Records
PRA
Probabilistic Risk Assessment
SCR
Screening (50.59)  
SCR
Setpoint Change Request
SDP
Significance Determination Process
SE
Safety Evaluation (50.59)  
TS
Technical Specifications
USAR
Updated Safety Analysis Report
}}
}}

Latest revision as of 02:34, 15 January 2025

IR 05000263-07-006( Drs); 02/12/2007 Through 03/01/2007; Monticello Nuclear Generating Plant. Evaluations of Changes, Tests, Experiments and Permanent Plant Modifications
ML070860170
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 03/27/2007
From: Dave Hills
NRC/RGN-III/DRS/EB1
To: Conway J
Nuclear Management Co
References
IR-07-006
Download: ML070860170 (19)


See also: IR 05000263/2007006

Text

March 27, 2007

Mr. J. Conway

Site Vice President

Monticello Nuclear Generating Plant

Nuclear Management Company, LLC

2807 West County Road 75

Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT NRC EVALUATION OF

CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT

MODIFICATIONS BASELINE INSPECTION REPORT 05000263/2007006(DRS)

Dear Mr. Conway:

On March 1, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed a combined

baseline inspection of the Evaluation of Changes, Tests, or Experiments and Permanent Plant

Modifications at the Monticello Nuclear Generating Plant. The enclosed report documents the

results of the inspection, which were discussed with Mr. J. Grubb, and others of your staff at the

completion of the inspection on March 1, 2007.

The inspectors examined activities conducted under your license as they relate to safety and

compliance with the Commissions Rules and Regulations, and with the conditions of your

license. The inspectors reviewed selected procedures and records, observed activities, and

interviewed personnel.

Based on the results of the inspection, one NRC identified finding, which involved a violation of

NRC requirements of very low safety significance, was identified. Because of the very low

safety significance of the violation and the fact that the issue was entered into the licensees

corrective action program, the NRC is treating the finding as a Non-Cited Violation (NCV) in

accordance with Section VI.A.1 of the NRCs Enforcement Policy.

In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter

and its enclosure will be available electronically for public inspection in the NRC Public

Document Room, or from the Publicly Available Records (PARS) component of NRC's

J. Conway

-2-

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/

David E. Hills, Chief

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-263

License No. DPR-22

Enclosure:

Inspection Report 05000263/2007006(DRS)

w/Attachment: Supplemental Information

cc w/encl:

M. Sellman, President and Chief Executive Officer

Manager, Nuclear Safety Assessment

J. Rogoff, Vice President, Counsel, and Secretary

Nuclear Asset Manager, Xcel Energy, Inc.

State Liaison Officer, Minnesota Department of Health

R. Nelson, President

Minnesota Environmental Control Citizens

Association (MECCA)

Commissioner, Minnesota Pollution Control Agency

D. Gruber, Auditor/Treasurer,

Wright County Government Center

Commissioner, Minnesota Department of Commerce

Manager - Environmental Protection Division

Minnesota Attorney Generals Office

J. Conway

-2-

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/

David E. Hills, Chief

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-263

License No. DPR-22

Enclosure:

Inspection Report 05000263/2007006(DRS)

w/Attachment: Supplemental Information

cc w/encl:

M. Sellman, President and Chief Executive Officer

Manager, Nuclear Safety Assessment

J. Rogoff, Vice President, Counsel, and Secretary

Nuclear Asset Manager, Xcel Energy, Inc.

State Liaison Officer, Minnesota Department of Health

R. Nelson, President

Minnesota Environmental Control Citizens

Association (MECCA)

Commissioner, Minnesota Pollution Control Agency

D. Gruber, Auditor/Treasurer,

Wright County Government Center

Commissioner, Minnesota Department of Commerce

Manager - Environmental Protection Division

Minnesota Attorney Generals Office

DOCUMENT NAME:C:\\FileNet\\ML070860170.wpd

G Publicly Available

G Non-Publicly Available

G Sensitive

G Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE

RIII

RIII

RIII

NAME

ADunlop: ls

DHills

DATE

03/27/07

03/27/07

OFFICIAL RECORD COPY

J. Conway

-3-

DISTRIBUTION:

TEB

PST

RidsNrrDirsIrib

GEG

KGO

GLS

CST1

CAA1

LSL

CDP1

DRPIII

DRSIII

PLB1

TXN

ROPreports@nrc.gov

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No:

50-263

License No:

DPR-22

Report No:

05000263/2007006(DRS)

Licensee:

Nuclear Management Company, LLC

Facility:

Monticello Nuclear Generating Plant

Location:

Monticello, Minnesota

Dates:

February 12, 2007 through March 1, 2007

Inspectors:

A. Dunlop, Senior Reactor Inspector

T. Bilik, Reactor Inspector

Observers:

V. Meghani, Reactor Inspector

Approved by:

D. Hills, Chief

Engineering Branch 1

Division of Reactor Safety (DRS)

Enclosure

1

SUMMARY OF FINDINGS

IR 05000263/2007006(DRS); 02/12/2007 through 03/01/2007; Monticello Nuclear Generating

Plant. Evaluations of Changes, Tests, Experiments and Permanent plant modifications.

The inspection covered a 2-week announced baseline inspection on evaluations of changes,

tests, or experiments and permanent plant modifications. The inspection was conducted by

two regional based engineering inspectors. One Green finding associated with a Non-Cited

Violation (NCV) was identified. The significance of most findings is indicated by their color

(Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance

Determination Process (SDP). Findings for which the SDP does not apply may be Green, or

be assigned a severity level after NRC management review. The NRC's program for

overseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, Reactor Oversight Process, Revision 3; dated July 2000.

A.

Inspector-Identified and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green. The inspectors identified a Severity Level IV NCV for an inadequate 10 CFR 50.59, Changes, Tests, and Experiments, evaluation resulting in failure to receive

prior NRC approval for changes in licensed activities associated with protection of

the emergency diesel generator exhaust stacks against tornado generated missiles.

Specifically, the licensee did not provide an adequate response to the question posed

in 10 CFR 50.59(c)(2)(viii), and did not demonstrate that the proposed change did not

result in a departure from a method of evaluation described in the Final Safety Analysis

Report (as updated) used in establishing the design bases or in the safety analyses. As

part of the corrective actions, the licensee verified that the emergency diesel generators

remained operable and initiated actions to submit a licensee amendment request for use

of the new methodology.

Because the Significance Determination Process is not designed to assess the

significance of violations that potentially impact or impede the regulatory process, this

issue was dispositioned using the traditional enforcement process in accordance with

Section IV of the NRC Enforcement Policy. However, the results of the violation, that is,

the failure to demonstrate that the proposed change did not result in a departure from a

method of evaluation, were assessed using the Significance Determination Process.

The finding was determined to be greater than minor because the change had the

potential for impacting the NRCs ability to perform its regulatory function as the

inspectors determined the change would have required prior NRC approval. The

finding was of very low safety significance based on the completed analysis for the

emergency diesel generator exhausts. This was determined to be a Severity Level IV

NCV of 10 CFR 50.59. (Section 1R02)

B.

Licensee-Identified Violations

No findings of significance were identified.

Enclosure

2

REPORT DETAILS

1.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R02

Evaluations of Changes, Tests, or Experiments (71111.02)

.1

Review of 10 CFR 50.59 Evaluations and Screenings

a.

Inspection Scope

From February 12, 2007, through March 1, 2007, the inspectors reviewed two

evaluations performed pursuant to 10 CFR 50.59. The inspectors reviewed the

evaluations to confirm that they were thorough and that prior NRC approval was

obtained as appropriate. The inspector could not review the minimum sample size of

five evaluations because the licensee only performed one evaluation during the biennial

sample period. One additional safety evaluation was reviewed that was performed in

the previous sample period for a total of two samples. The inspectors also reviewed

18 screenings where licensee personnel had determined that a 10 CFR 50.59

evaluation was not necessary. In addition, seven applicability determinations were

reviewed to verify they did not meet the applicability requirements for a screening. The

evaluations and screenings were chosen based on risk significance, safety significance,

and complexity. The list of documents reviewed by the inspectors are included as an

attachment to this report.

The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for

10 CFR 50.59 Implementation, and Revision 1, to determine acceptability of the

completed evaluations, and screenings. The NEI document was endorsed by the

NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59,

Changes, Tests, and Experiments, dated November 2000. The inspectors also

consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.

b.

Findings

Inadequate 10 CFR 50.59 Evaluation for Diesel Generator Exhaust Missile Protection

Introduction: The inspectors identified an inadequate evaluation performed pursuant to

10 CFR 50.59 associated with the vulnerability of the emergency diesel generator (EDG)

exhaust stacks to tornado generated missiles. Specifically, the licensee did not provide

an adequate response to the question posed in 10 CFR 50.59(c)(2)(viii) and did not

demonstrate that the proposed change did not result in a departure from a method of

evaluation described in the USAR used in establishing the design bases or in the safety

analyses. This issue was considered to be of very low safety significance (Green) and

was dispositioned as a Severity Level IV Non-Cited Violation (NCV).

Enclosure

3

Description: The inspectors reviewed 10 CFR 50.59 safety evaluation (SE)03-004,

concerning the utilization of the TORMIS probabilistic risk assessment (PRA)

methodology (per Electric Power Research Institute (EPRI) Report NP-2005,

Volumes 1 and 2). This methodology was to verify that the risk from tornado

generated missiles was sufficiently small to justify leaving the EDG exhaust

unprotected. On page 7 of SE 03-004 in Section III.8, the licensee responded to the

question posed in 10 CFR 50.59(c)(2)(viii). This question asked, "Does the proposed

change result in a departure from a method of evaluation described in the Final Safety

Analysis Report (as updated) used in establishing the design bases or in the safety

analyses? The licensee justified the No answer to this question by citing the NRC

acceptance of the EPRI methodology for specific plant features and subject to resolution

of specific concerns in the NRCs safety evaluation for EPRI Report NP-2005, dated

October 26, 1983. The licensees evaluation included addressing the specific

concerns and stated that the resolutions of these concerns for the Monticello plant

were consistent with those accepted by the NRC for the D. C. Cook Nuclear Plant

(Amendment No. 247 to DPR-58 and Amendment No. 228 to DPR-74).

The NRCs safety evaluation concluded that the PRA methodology as contained in the

EPRI report was an acceptable probabilistic approach for demonstrating compliance

with the requirements of General Design Criteria 2 and 3 regarding protection of

safety-related plant features from the effects of tornado and high wind generated

missiles, but subject to the additional concerns identified. It further stated that use of

the EPRI or any tornado missile probabilistic study should be limited to the evaluation of

specific plant feature where additional costly tornado missile protective barriers or

alternative systems were under consideration. The inspectors contacted the staff in the

Office of Nuclear Reactor Regulation (NRR) to determine the basis for the NRCs safety

evaluation and the acceptability of the licensee using this methodology that was not in

accordance with the current licensing basis. Based on this discussion, although the

methodology had been reviewed and could be used as a basis for not having to

physically protect specific plant features from tornado generated missiles, it was

considered a change to the plants current licensing basis, which required a license

amendment.

Based on the above, the inspectors concluded that the licensee use of NRCs safety

evaluation on the EPRI methodology was incorrect and that the licensees No answer

to 10 CFR 50.59(c)(2)(viii), and the conclusion that no activity requiring prior NRC

approval per 10 CFR 50.59 was identified were not justified.

The inspectors also determined that the results of the calculations based on the EPRI

methodology discussed above were utilized for responses to the questions for

10 CFR 50.59(c)(2) (i) through (vi) in Section III of the SE 03-004 and that a USAR

change was implemented to incorporate the use of TORMIS methodology. This finding

also affected the licensees 10 CFR 50.59 screening SCR-04-0069, Revision 0, which

was used to screen out activities involving subsequent application of the EPRI

methodology for evaluation of other plant specific features from tornado generated

missiles.

Enclosure

4

In response to the finding, the licensee initiated Action Request (AR) 01079705. The

licensee determined that the NRCs 1983 safety evaluation endorsing the EPRI TORMIS

methodology was misinterpreted by the licensee as a generic NRC approval for use and

was inappropriately used in the 50.59 evaluation to conclude that prior NRC approval

was not required. The licensee determined the EDGs remained operable based on the

existing completed analysis and acceptance of similar technical approach by the NRC

for other operating plants. The inspectors concluded that the licensees determination

was acceptable as the existing analysis using the TORMIS methodology did appear to

address the limitations noted in the NRCs safety evaluation. The AR also

recommended an action to submit an license amendment request to the NRC to

incorporate the TORMIS methodology into the license basis for all the affected plant

specific features.

Analysis: This issue was determined to involve a performance deficiency because the

licensee incorrectly concluded that the TORMIS methodology had been approved for

generic application and consequently concluded that prior NRC approval was not

required when such a conclusion could not be supported by the documented 50.59

evaluation. Because violations of 10 CFR 50.59 are considered to be violations that

potentially impede or impact the regulatory process, they are dispositioned using the

traditional enforcement process instead of the significance determination process (SDP)

described in Inspection Manual Chapter (IMC) 0609, "Significance Determination

Process. The finding was determined to be greater than minor because the change

had the potential for impacting the NRCs ability to perform its regulatory function as the

inspectors determined the change would have required prior NRC approval.

The inspectors evaluated the finding using IMC 0609, Appendix A, Significance

Determination of Reactor Inspection Findings for At-Power Situations, Phase 1

screening, and determined that the finding screened as Green because it was not a

design issue resulting in loss of function per Part 9900, Technical Guidance,

Operability Determinations, and Functionality Assessments for Resolution of Degraded,

or Nonconforming Conditions Adverse to Quality or Safety, did not represent an actual

loss of a system safety function, did not result in exceeding a technical specification

allowed outage time, and did not affect external event mitigation. This was based on the

licensees operability determination that concluded that their use of the TORMIS

methodology appeared to be consistent with the guidance provided in the NRCs safety

evaluation of the methodology and that NRC had accepted its use at other plants when

used for the intended purpose. The inspectors did not identify a cross-cutting aspect

with this finding.

Enforcement: Title 10 CFR 50.59(c)(2)(viii) states, in part, that a licensee shall obtain a

license amendment pursuant to Section 50.90 prior to implementing a proposed change,

test, or experiment if the change, test, or experiment would result in a departure from a

method of evaluation described in the Final Safety Analysis Report (as updated) used in

establishing the design bases or in the safety analyses.

Contrary to the above, on July 28, 2003, the licensee approved a 10 CFR 50.59

evaluation (SE-03-004) incorporating a change to the tornado missile protection

methodology for the EDG exhaust system, which resulted in a departure from a method

of evaluation described in the USAR, without obtaining a license amendment. However,

Enclosure

5

because this violation was of very low safety significance and it was entered into the

licensees corrective action program, this Severity Level IV violation is being treated as

an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy

(NCV 05000263/2007006-01(DRS)). The licensee entered the finding into their

corrective action program as AR01079705.

1R17

Permanent Plant Modifications (71111.17B)

.1

Review of Permanent Plant Modifications

a.

Inspection Scope

From February 12, 2007, through March 1, 2007, the inspectors reviewed ten

permanent plant modifications that had been installed in the plant during the last two

years. This included two engineering changes, three equivalency evaluations, and five

setpoint changes. The modifications were chosen based upon risk significance, safety

significance, and complexity. As per inspection procedure 71111.17B, two modifications

were chosen that affected the barrier integrity cornerstone. The inspectors reviewed the

modifications to verify that the completed design changes were in accordance with the

specified design requirements, and the licensing bases, and to confirm that the changes

did not adversely affect any systems' safety function. Design and post-modification

testing aspects were verified to ensure the functionality of the modification, its

associated system, and any support systems. The inspectors also verified that the

modifications performed did not place the plant in an increased risk configuration.

The inspectors also used applicable industry standards to evaluate acceptability of the

modifications. The list of modifications and other documents reviewed by the inspectors

is included as an attachment to this report.

b.

Findings

No findings of significance were identified.

4.

OTHER ACTIVITIES (OA)

4OA2 Identification and Resolution of Problems

.1

Routine Review of Condition Reports

a.

Inspection Scope

From February 12, 2007, through March 1, 2007, the inspectors reviewed 18 Corrective

Action Process documents that identified or were related to 10 CFR 50.59 evaluations

and permanent plant modifications. The inspectors reviewed these documents to

evaluate the effectiveness of corrective actions related to permanent plant modifications

and evaluations for changes, tests, or experiments issues. In addition, corrective action

documents written on issues identified during the inspection were reviewed to verify

adequate problem identification and incorporation of the problems into the corrective

Enclosure

6

action system. The specific corrective action documents that were sampled and

reviewed by the inspectors are listed in the attachment to this report.

b.

Findings

No findings of significance were identified.

4OA6 Meetings

.1

Exit Meeting

The inspectors presented the inspection results to Mr. J. Grubb and others of the

licensees staff, on March 1, 2007. Licensee personnel acknowledged the inspection

results presented. Licensee personnel were asked to identify any documents, materials,

or information provided during the inspection that were considered proprietary. No

proprietary information was identified.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Attachment

1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Baumer, Licensing

F. Domke, Electrical Design Supervisor

J. Grubb, Engineering Director

B. Guldemond, Nuclear Safety Assurance Manager

N. Haskell, Engineering Design Manager

T. Hurrle, Configuration Management Supervisor

D. Nordell, Configuration Management Engineer

J. Ohotto, Design Engineering Supervisor

D. Pennington, Design Engineer

B. Sawatzke, Plant Manager

Nuclear Regulatory Commission

D. Hills, Chief, Engineering Branch 1, Division of Reactor Safety

S. Thomas, Senior Resident Inspector

L. Haeg, Resident Inspector

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened/Closed

05000263/2007006-01

NCV

Inadequate 10 CFR 50.59 Evaluation for Diesel Generator

Exhaust Missile Protection (Section 1R21.3.b)

Attachment

2

LIST OF DOCUMENTS REVIEWED

The following is a list of licensee documents reviewed during the inspection, including

documents prepared by others for the licensee. Inclusion on this list does not imply that NRC

inspectors reviewed the documents in their entirety, but rather, that selected sections or

portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a

document in this list does not imply NRC acceptance of the document, unless specifically stated

in the inspection report.

IR02

Evaluation of Changes, Tests, or Experiments 71111.02

10 CFR 50.59 Evaluations

SE-03-004; Diesel Exhaust Missile Protection Design Consideration; dated

July 28, 2003

SE-06-003; SBO Operator Actions Associated with the HPCI System; dated

September 19, 2006

10 CFR 50.59 Screenings

SCR-04-0283; SRV Air Actuator Model Change; dated November 23, 2005

SCR-04-0859; HPCI Turbine Steam Supply Low Pressure Isolation; dated

September 11, 2006

SCR-05-0161; Set Point for RHR Minimum Flow Switches FS-10-2-121, A, B, C and D;

dated August 23, 2006

SCR-05-0242; Instrument Setpoint Calculation 4.16KV Degraded Voltage; dated

March 28, 2006

SCR-05-0266; ITS Setpoint Change - HPCI Steam Line Area Temperature - High;

dated August 26, 2006

SCR-05-0689; Calc CA-05-146, Evaluation of Wall Thinning on FW2B-10-ED; dated

October 11, 2005

SCR-05-0738; Calc CA-05-028, Evaluation of HPCI Condensate Drain Line D13-2"-HE

in the HPCI Room; dated November 9, 2005

SCR-05-0739; Calc 05-147, Evaluation of HPCI Module E.2; dated November 9, 2005

SCR-05-0757; Chilled Water Expansion Tank V-CT-1 Replacement; dated

November 15, 2005

SCR-05-0822; CA-05-155, Evaluation of Offgas Stack for SSE Seismic Loads; dated

December 22, 2005

Attachment

3

SCR-06-0062; Less than Full Thread Engagement on RWCU AO Valve Actuator Bonnet

Nuts; dated February 15, 2006

SCR-06-0103; HPCI Steam Void Elimination; dated April 6, 2006

SCR-06-0106; Service Water Pump Replacement; October 30, 2006

SCR-06-0165; Replace AO-1575(6) and Check Valves with Normally Closed Valve

SW-228(9); dated October 31, 2006

SCR-06-0166; Replace Rotork Actuators on Five MOVs with Limitorque Actuators;

dated April 26, 2006

SCR-06-0310; Technical Requirements Manual - Appendix B - Secondary Containment

Isolation Valves; dated September 12, 2006

SCR-06-0557; Suppression Chamber Inspection; dated December 4, 2006

SCR-07-0043; Fuel Storage and Handling Systems, Design Basis; dated

January 22, 2007

10 CFR 50.59 Applicability Determinations

SCR-05-0645; Drawing Classification Level Change to 3'; dated September 19, 2005

SCR-05-0657; Combustible Loading Calculation; dated September 22, 2005

SCR-05-0663; Replace Fusible Link on V-DF-SBGT-2 with One of a Higher

Temperature Rating; dated September 28, 2005

SCR-05-0791; Evaluation of Fire Detector Locations in the Reactor Building; dated

December 5, 2005

SCR-05-0819; Setpoint Change Request for the Safety/Relief Valve Low-Low Set Logic

to Incorporate the New Trip Settings; dated December 21, 2005

SCR-05-0830; Setpoint Change Request for the 4KV Bus-15 and Bus 16 Undervoltage

Relays to Incorporate the New Trip Setting; dated January 3, 2006

SCR-06-0308; Update USAR for Improved Technical Specification Project; dated

July, 29, 2006

IR17

Permanent Plant Modifications 71111.17B

Modifications

EC8819; HPCI Steam Line Area Temperature - High; dated October 27, 2006

EC7583; Degraded Voltage Relays for Safety-Related 4KV Busses ; dated

August 7, 2006

Attachment

4

Equivalency Evaluations

EC910; Replacement Blower Wheel; Revision 1

EC933 (05A099); HPCI Auxiliary Lube Oil Pump; Revision 0

EC7828; Engine Driven Fuel Pump Suction Line; Revision 0

Setpoint Changes

EC8818; HPCI Turbine Steam Line Pressure - Low; dated October 27, 2006

EC8792; LPCI Pump Discharge Flow - Low; dated October 27, 2006

SCR 05-022; 4KV Bus-15 and Bus-16 Undervoltage Relays; dated December 1, 2005

SCR 05-023; Main Steam Line Steam Chase High Temp Group 1 Isolation; dated

December 1, 2005

SCR 05-028; SRV Low Low Set Pressure Interlock; dated December 1, 2005

Other Documents Reviewed During Inspection

Corrective Action Program Documents Generated As a Result of Inspection

AR01076896; List to NRC Screened out All 50.59 Screening using the 3283 Form;

AR01077202; SCR-05-0830 Description Contains Incorrect Value; dated

February 14, 2007

AR01077855; Action to Correct Drawing Error was Cancelled; dated February 19, 2007

AR01078665; Error in Calculation CA-05-146, Evaluation of Wall Thinning in

FW2B-10"-ED; dated February 22, 2007

AR01079705; LAR Required for Use of TORMIS Code Methodology; dated

February 28, 2007

AR01080049; SCR-05-0161 Activity Incorrectly Categorized; dated March 1, 2007

Corrective Action Program Documents Reviewed During the Inspection

AR00824446; NDE Thickness < 87.5 percent TNOM on FW2B-10"-ED, B Feedwater

to Reactor Line; March 25, 2005

AR00891838; Evidence of Water Leakage on 11 and 12 EDG Exhaust Pipe Insulation;

dated September 28, 2005

AR01000610; Replacement Part does not Match the Part Removed; dated

October 10, 2005

Attachment

5

AR01000746; Inconsistency Between Line Design Table and Plant; dated

October 11, 2005

AR01001520; Operation past One Cycle Not Assured for Fw Pipe; dated

October 20, 2005

AR01003632; RC-44-2 Replacement Noticed 3000 No. vs. 6000 No.; dated

November 14, 2005

AR01004032; RWC Pipe Support Discrp and Indad Thread Engage on Act Nuts; dated

November 17, 2005

AR01006064; CV-1728 Plug Replaced, No Section XI Repair/Replacement Plan; dated

December 1, 2005

AR01008347; Some SW Mods May Inadvertently Create New Problems; dated

December 21, 2005

AR01022687; SW 1-18"-JF Does Not Meet Class 1 Design Criteria ; dated April 6, 2006

AR01026395; Potential Exists for Failure to Manually Start ECCS Room Coolers; dated

April 26, 2006

AR01040014; Inadequate Closeout Activities for Design Change 99Q160; dated

July 17, 2006

AR01059716; Change to PM Frequency not Considered; dated November 3, 2006

AR01059908; Adverse Trend in Modification Implementation; dated November 6, 2006

AR00891237; No Column Gaskets Found on RHRSW Pump Columns; dated

September 27, 2005

AR1040142; B.03.04-05 Issued Prior to Completion of Revision Process; dated

July 18, 2006

AR0780295; Revise USAR Section 10.2.4.3 to Reflect the Results of CA-95-028; dated

November 26, 2006

AR01045206; 50.59 Screening SCR-05-210 Missed USAR Impact; dated

August 18, 2006

Calculations

CA-03-038; Instrument Setpoint Calculation, 4.16 KV Loss of Voltage; Revision 1

CA-03-039; Instrument Setpoint Calculation - SRV Low-Low Set, Reactor Coolant

System Pressure; Revision 0

CA-04-110; Determination of HPCI Area High Temperature Setpoints; Revision 1

Attachment

6

CA-05-108; Evaluation of Wall Thinning on FW2B-10-ED Piping; Revision 0

CA-05-146; Evaluation of Wall Thinning on FW2B-10"-ED Piping; Revision 0

Drawings

EC-811-01; Monticello Nuclear Generating Plant Installation of HPCI Void Resolution;

Revision 1

NH-36250; Monticello Nuclear Generating Plant P&ID (Water Side) High Pressure

Coolant Injection System; Revision AF

Attachment

7

LIST OF ACRONYMS USED

ADAMS

Agency-Wide Document Access and Management System

AR

Action Request

CFR

Code of Federal Regulations

DRP

Division of Reactor Projects

DRS

Division of Reactor Safety

EDG

Emergency Diesel Generator

EC

Engineering Change

EPRI

Electric Power Research Institute

IMC

Inspection Manual Chapter

IR

Inspection Report

NCV

Non-Cited Violation

NEI

Nuclear Energy Institute

NRC

Nuclear Regulatory Commission

NRR

Office of Nuclear Reactor Regulation

PARS

Publicly Available Records

PRA

Probabilistic Risk Assessment

SCR

Screening (50.59)

SCR

Setpoint Change Request

SDP

Significance Determination Process

SE

Safety Evaluation (50.59)

TS

Technical Specifications

USAR

Updated Safety Analysis Report