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{{#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:       MONTICELLO NUCLEAR GENERATING PLANT NRC EVALUATION OF
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
                CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT
Modifications at the Monticello Nuclear Generating Plant. The enclosed report documents the
                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
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.
license. The inspectors reviewed selected procedures and records, observed activities, and
The inspectors examined activities conducted under your license as they relate to safety 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
compliance with the Commissions Rules and Regulations, and with the conditions of your
safety significance of the violation and the fact that the issue was entered into the licensee's
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
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
J. Rogoff, Vice President, Counsel, and Secretary
Document Room, or from the Publicly Available Records (PARS) component of NRC's
Nuclear Asset Manager, Xcel Energy, Inc.
 
State Liaison Officer, Minnesota Department of Health
J. Conway                                     -2-
R. Nelson, President
document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-
  Minnesota Environmental Control Citizens
rm/adams.html (the Public Electronic Reading Room).
  Association (MECCA)
                                            Sincerely,
Commissioner, Minnesota Pollution Control Agency
                                            /RA/
D. Gruber, Auditor/Treasurer,
                                            David E. Hills, Chief
  Wright County Government Center
                                            Engineering Branch 1
Commissioner, Minnesota Department of Commerce
                                            Division of Reactor Safety
Manager - Environmental Protection Division
Docket No. 50-263
  Minnesota Attorney General's Office  
License No. DPR-22
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
Enclosure:   Inspection Report 05000263/2007006(DRS)
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
                w/Attachment: Supplemental Information
J. Rogoff, Vice President, Counsel, and Secretary
cc w/encl:   M. Sellman, President and Chief Executive Officer
Nuclear Asset Manager, Xcel Energy, Inc.
              Manager, Nuclear Safety Assessment
State Liaison Officer, Minnesota Department of Health
              J. Rogoff, Vice President, Counsel, and Secretary
R. Nelson, President
              Nuclear Asset Manager, Xcel Energy, Inc.
  Minnesota Environmental Control Citizens
              State Liaison Officer, Minnesota Department of Health
  Association (MECCA)
              R. Nelson, President
Commissioner, Minnesota Pollution Control Agency
                Minnesota Environmental Control Citizens
D. Gruber, Auditor/Treasurer,
                Association (MECCA)
  Wright County Government Center
              Commissioner, Minnesota Pollution Control Agency
Commissioner, Minnesota Department of Commerce
              D. Gruber, Auditor/Treasurer,
Manager - Environmental Protection Division
                Wright County Government Center
  Minnesota Attorney General's OfficeDOCUMENT NAME:C:\FileNet\ML070860170.wpd
              Commissioner, Minnesota Department of Commerce
G Publicly Available
              Manager - Environmental Protection Division
G Non-Publicly Available
                Minnesota Attorney Generals Office
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  
J. Conway                                                                   -2-
J. Conway-3-DISTRIBUTION
document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-
:TEB
rm/adams.html (the Public Electronic Reading Room).
PST
                                                                          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:
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ROPreports@nrc.gov
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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:         50-263
Dates:February 12, 2007 through March 1, 2007
License No:         DPR-22
Inspectors:A. Dunlop, Senior Reactor InspectorT. Bilik, Reactor InspectorObservers:V. Meghani, Reactor InspectorApproved by:D. Hills, ChiefEngineering Branch 1
Report No:         05000263/2007006(DRS)
Division of Reactor Safety (DRS)  
Licensee:           Nuclear Management Company, LLC
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
Facility:           Monticello Nuclear Generating Plant
two regional based engineering inspectors. One Green finding associated with a Non-Cited
Location:           Monticello, Minnesota
Violation (NCV) was identified. The significance of most findings is indicated by their color(Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance
Dates:             February 12, 2007 through March 1, 2007
Determination Process (SDP).Findings for which the SDP does not apply may be Green, or
Inspectors:         A. Dunlop, Senior Reactor Inspector
be assigned a severity level after NRC management review. The NRC's program for
                    T. Bilik, Reactor Inspector
Observers:         V. Meghani, Reactor Inspector
Approved by:       D. Hills, Chief
                    Engineering Branch 1
                    Division of Reactor Safety (DRS)
 
                                    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
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.
prior NRC approval for changes in licensed activities associated with protection of
A.     Inspector-Identified and Self-Revealed Findings
the emergency diesel generator exhaust stacks against tornado generated missiles.  
        Cornerstone: Mitigating Systems
Specifically, the licensee did not provide an adequate response to the question posed
        Green. The inspectors identified a Severity Level IV NCV for an inadequate 10 CFR
in 10 CFR 50.59(c)(2)(viii), and did not demonstrate that the proposed change did not
        50.59, Changes, Tests, and Experiments, evaluation resulting in failure to receive
result in a departure from a method of evaluation described in the Final Safety Analysis
        prior NRC approval for changes in licensed activities associated with protection of
Report (as updated) used in establishing the design bases or in the safety analyses. As
        the emergency diesel generator exhaust stacks against tornado generated missiles.
part of the corrective actions, the licensee verified that the emergency diesel generators
        Specifically, the licensee did not provide an adequate response to the question posed
remained operable and initiated actions to submit a licensee amendment request for use
        in 10 CFR 50.59(c)(2)(viii), and did not demonstrate that the proposed change did not
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
        result in a departure from a method of evaluation described in the Final Safety Analysis
issue was dispositioned using the traditional enforcement process in accordance with
        Report (as updated) used in establishing the design bases or in the safety analyses. As
Section IV of the NRC Enforcement Policy. However, the results of the violation, that is,
        part of the corrective actions, the licensee verified that the emergency diesel generators
the failure to demonstrate that the proposed change did not result in a departure from a
        remained operable and initiated actions to submit a licensee amendment request for use
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
        of the new methodology.
inspectors determined the change would have required prior NRC approval. The
        Because the Significance Determination Process is not designed to assess the
finding was of very low safety significance based on the completed analysis for the
        significance of violations that potentially impact or impede the regulatory process, this
emergency diesel generator exhausts. This was determined to be a Severity Level IV
        issue was dispositioned using the traditional enforcement process in accordance with
NCV of 10 CFR 50.59. (Section 1R02)B.Licensee-Identified ViolationsNo findings of significance were identified.  
        Section IV of the NRC Enforcement Policy. However, the results of the violation, that is,
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
        the failure to demonstrate that the proposed change did not result in a departure from a
evaluations to confirm that they were thorough and that prior NRC approval was
        method of evaluation, were assessed using the Significance Determination Process.
obtained as appropriate. The inspector could not review the minimum sample size of
        The finding was determined to be greater than minor because the change had the
five evaluations because the licensee only performed one evaluation during the biennial
        potential for impacting the NRCs ability to perform its regulatory function as the
sample period. One additional safety evaluation was reviewed that was performed in
        inspectors determined the change would have required prior NRC approval. The
the previous sample period for a total of two samples. The inspectors also reviewed
        finding was of very low safety significance based on the completed analysis for the
18 screenings where licensee personnel had determined that a 10 CFR 50.59
        emergency diesel generator exhausts. This was determined to be a Severity Level IV
evaluation was not necessary. In addition, seven applicability determinations were
        NCV of 10 CFR 50.59. (Section 1R02)
reviewed to verify they did not meet the applicability requirements for a screening. The
B.     Licensee-Identified Violations
evaluations and screenings were chosen based on risk significance, safety significance,
        No findings of significance were identified.
and complexity. The list of documents reviewed by the inspectors are included as an
                                                    1                                    Enclosure
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
                                    REPORT DETAILS
NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59,
1.   REACTOR SAFETY
Changes, Tests, and Experiments," dated November 2000. The inspectors also
    Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR
1R02 Evaluations of Changes, Tests, or Experiments (71111.02)
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)
.1  Review of 10 CFR 50.59 Evaluations and Screenings
exhaust stacks to tornado generated missiles. Specifically, the licensee did not provide
  a. Inspection Scope
an adequate response to the question posed in 10 CFR 50.59(c)(2)(viii) and did not
    From February 12, 2007, through March 1, 2007, the inspectors reviewed two
demonstrate that the proposed change did not result in a departure from a method of
    evaluations performed pursuant to 10 CFR 50.59. The inspectors reviewed the
evaluation described in the USAR used in establishing the design bases or in the safety
    evaluations to confirm that they were thorough and that prior NRC approval was
analyses. This issue was considered to be of very low safety significance (Green) and
    obtained as appropriate. The inspector could not review the minimum sample size of
was dispositioned as a Severity Level IV Non-Cited Violation (NCV).  
    five evaluations because the licensee only performed one evaluation during the biennial
Enclosure 3Description: The inspectors reviewed 10 CFR 50.59 safety evaluation (SE) 03-004,concerning the utilization of the "TORMIS" probabilistic risk assessment (PRA)
    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).
                                              2                                      Enclosure
 
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
missiles, but subject to the additional concerns identified. It further stated that use of
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
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
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.
                                          3                                        Enclosure


missiles.
In response to the finding, the licensee initiated Action Request (AR) 01079705. The
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
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
evaluation. Because violations of 10 CFR 50.59 are considered to be violations that
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
potentially impede or impact the regulatory process, they are dispositioned using the
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
                                          4                                      Enclosure
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
    because this violation was of very low safety significance and it was entered into the
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
    licensees corrective action program, this Severity Level IV violation is being treated as
years. This included two engineering changes, three equivalency evaluations, and five
    an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy
setpoint changes. The modifications were chosen based upon risk significance, safety
    (NCV 05000263/2007006-01(DRS)). The licensee entered the finding into their
significance, and complexity. As per inspection procedure 71111.17B, two modifications
    corrective action program as AR01079705.
were chosen that affected the barrier integrity cornerstone. The inspectors reviewed the
1R17 Permanent Plant Modifications (71111.17B)
modifications to verify that the completed design changes were in accordance with the
.1  Review of Permanent Plant Modifications
specified design requirements, and the licensing bases, and to confirm that the changes
  a. Inspection Scope
did not adversely affect any systems' safety function. Design and post-modification
    From February 12, 2007, through March 1, 2007, the inspectors reviewed ten
testing aspects were verified to ensure the functionality of the modification, its
    permanent plant modifications that had been installed in the plant during the last two
associated system, and any support systems. The inspectors also verified that the
    years. This included two engineering changes, three equivalency evaluations, and five
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
    setpoint changes. The modifications were chosen based upon risk significance, safety
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
    significance, and complexity. As per inspection procedure 71111.17B, two modifications
and permanent plant modifications. The inspectors reviewed these documents to
    were chosen that affected the barrier integrity cornerstone. The inspectors reviewed the
evaluate the effectiveness of corrective actions related to permanent plant modifications
    modifications to verify that the completed design changes were in accordance with the
and evaluations for changes, tests, or experiments issues. In addition, corrective action
    specified design requirements, and the licensing bases, and to confirm that the changes
documents written on issues identified during the inspection were reviewed to verify
    did not adversely affect any systems' safety function. Design and post-modification
adequate problem identification and incorporation of the problems into the corrective  
    testing aspects were verified to ensure the functionality of the modification, its
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
    associated system, and any support systems. The inspectors also verified that the
results presented. Licensee personnel were asked to identify any documents, materials,
    modifications performed did not place the plant in an increased risk configuration.
or information provided during the inspection that were considered proprietary. No
    The inspectors also used applicable industry standards to evaluate acceptability of the
proprietary information was identified.ATTACHMENT: SUPPLEMENTAL INFORMATION  
    modifications. The list of modifications and other documents reviewed by the inspectors
Attachment
    is included as an attachment to this report.
1SUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACT
  b. Findings
LicenseeR. Baumer, LicensingF. Domke, Electrical Design Supervisor
    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
                                              5                                        Enclosure
 
    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
                                              6                                    Enclosure
 
                              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 376:
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
Attachment
D. Hills, Chief, Engineering Branch 1, Division of Reactor Safety
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
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)
                                                1                                Attachment
 
                                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
Attachment
        10 CFR 50.59 Evaluations
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
        SE-03-004; Diesel Exhaust Missile Protection Design Consideration; dated
SCR-06-0106; Service Water Pump Replacement; October 30, 2006SCR-06-0165; Replace AO-1575(6) and Check Valves with Normally Closed Valve
        July 28, 2003
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
        SE-06-003; SBO Operator Actions Associated with the HPCI System; dated
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
        September 19, 2006
SCR-05-0657; Combustible Loading Calculation; dated September 22, 2005
        10 CFR 50.59 Screenings
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-04-0283; SRV Air Actuator Model Change; dated November 23, 2005
EC7583; Degraded Voltage Relays for Safety-Related 4KV Busses ; datedAugust 7, 2006  
        SCR-04-0859; HPCI Turbine Steam Supply Low Pressure Isolation; dated
Attachment
        September 11, 2006
4Equivalency EvaluationsEC910; Replacement Blower Wheel; Revision 1EC933 (05A099); HPCI Auxiliary Lube Oil Pump; Revision 0
        SCR-05-0161; Set Point for RHR Minimum Flow Switches FS-10-2-121, A, B, C and D;
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
        dated August 23, 2006
SCR 05-022; 4KV Bus-15 and Bus-16 Undervoltage Relays; dated December 1, 2005
        SCR-05-0242; Instrument Setpoint Calculation 4.16KV Degraded Voltage; dated
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;
        March 28, 2006
AR01077202; SCR-05-0830 Description Contains Incorrect Value; datedFebruary 14, 2007AR01077855; Action to Correct Drawing Error was Cancelled; dated February 19, 2007
        SCR-05-0266; ITS Setpoint Change - HPCI Steam Line Area Temperature - High;
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
        dated August 26, 2006
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  
        SCR-05-0689; Calc CA-05-146, Evaluation of Wall Thinning on FW2B-10-ED; dated
Attachment
        October 11, 2005
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
        SCR-05-0738; Calc CA-05-028, Evaluation of HPCI Condensate Drain Line D13-2"-HE
AR01026395; Potential Exists for Failure to Manually Start ECCS Room Coolers; dated
        in the HPCI Room; dated November 9, 2005
April 26, 2006AR01040014; Inadequate Closeout Activities for Design Change 99Q160; datedJuly 17, 2006AR01059716; Change to PM Frequency not Considered; dated November 3, 2006
        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
                                                2                                    Attachment
 
    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
                                            3                                  Attachment
 
      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
                                            4                                    Attachment
 
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
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
Attachment
AR1040142; B.03.04-05 Issued Prior to Completion of Revision Process; dated
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
July 18, 2006
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  
AR0780295; Revise USAR Section 10.2.4.3 to Reflect the Results of CA-95-028; dated
Attachment
November 26, 2006
7LIST OF ACRONYMS USEDADAMSAgency-Wide Document Access and Management SystemARAction Request
AR01045206; 50.59 Screening SCR-05-210 Missed USAR Impact; dated
CFRCode of Federal Regulations  
August 18, 2006
DRPDivision of Reactor Projects
Calculations
DRSDivision of Reactor Safety
CA-03-038; Instrument Setpoint Calculation, 4.16 KV Loss of Voltage; Revision 1
EDGEmergency Diesel Generator
CA-03-039; Instrument Setpoint Calculation - SRV Low-Low Set, Reactor Coolant
ECEngineering Change
System Pressure; Revision 0
EPRIElectric Power Research Institute IMCInspection Manual Chapter
CA-04-110; Determination of HPCI Area High Temperature Setpoints; Revision 1
IRInspection Report
                                      5                                  Attachment
NCVNon-Cited Violation
 
NEINuclear Energy Institute
CA-05-108; Evaluation of Wall Thinning on FW2B-10-ED Piping; Revision 0
NRCNuclear Regulatory Commission
CA-05-146; Evaluation of Wall Thinning on FW2B-10"-ED Piping; Revision 0
NRROffice of Nuclear Reactor Regulation  
Drawings
PARSPublicly Available Records
EC-811-01; Monticello Nuclear Generating Plant Installation of HPCI Void Resolution;
PRAProbabilistic Risk Assessment
Revision 1
SCRScreening (50.59)  
NH-36250; Monticello Nuclear Generating Plant P&ID (Water Side) High Pressure
SCRSetpoint Change Request
Coolant Injection System; Revision AF
SDPSignificance Determination Process
                                      6                                    Attachment
SESafety Evaluation (50.59)  
 
TSTechnical Specifications
                        LIST OF ACRONYMS USED
USARUpdated Safety Analysis Report
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
                                      7                Attachment
}}
}}

Revision as of 08:01, 23 November 2019

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)

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.

1 Enclosure

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).

2 Enclosure

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.

3 Enclosure

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,

4 Enclosure

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

5 Enclosure

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

6 Enclosure

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)

1 Attachment

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

2 Attachment

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

3 Attachment

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

4 Attachment

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

5 Attachment

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

6 Attachment

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

7 Attachment