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2807 West County Road 75
2807 West County Road 75
Monticello, MN 55362-9637
Monticello, MN 55362-9637
SUBJECT:       MONTICELLO NUCLEAR GENERATING PLANT NRC EVALUATION OF
SUBJECT:
                CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT
MONTICELLO NUCLEAR GENERATING PLANT NRC EVALUATION OF
                MODIFICATIONS BASELINE INSPECTION REPORT 05000263/2007006(DRS)
CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT
MODIFICATIONS BASELINE INSPECTION REPORT 05000263/2007006(DRS)
Dear Mr. Conway:
Dear Mr. Conway:
On March 1, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed a combined
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
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.
completion of the inspection on March 1, 2007.
The inspectors examined activities conducted under your license as they relate to safety and
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
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.
interviewed personnel.
Based on the results of the inspection, one NRC identified finding, which involved a violation of
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
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
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 NRCs Enforcement Policy.
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
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
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
Document Room, or from the Publicly Available Records (PARS) component of NRC's  


J. Conway                                     -2-
J. Conway
-2-
document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-
document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
rm/adams.html (the Public Electronic Reading Room).
                                            Sincerely,
Sincerely,
                                            /RA/
/RA/
                                            David E. Hills, Chief
David E. Hills, Chief
                                            Engineering Branch 1
Engineering Branch 1
                                            Division of Reactor Safety
Division of Reactor Safety
Docket No. 50-263
Docket No. 50-263
License No. DPR-22
License No. DPR-22
Enclosure:   Inspection Report 05000263/2007006(DRS)
Enclosure:
                w/Attachment: Supplemental Information
Inspection Report 05000263/2007006(DRS)
cc w/encl:   M. Sellman, President and Chief Executive Officer
  w/Attachment: Supplemental Information
              Manager, Nuclear Safety Assessment
cc w/encl:
              J. Rogoff, Vice President, Counsel, and Secretary
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 Generals Office
Commissioner, Minnesota Department of Commerce
Manager - Environmental Protection Division
  Minnesota Attorney Generals Office


J. Conway                                                                   -2-
J. Conway
-2-
document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-
document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
rm/adams.html (the Public Electronic Reading Room).
                                                                          Sincerely,
Sincerely,
                                                                            /RA/
/RA/
                                                                          David E. Hills, Chief
David E. Hills, Chief
                                                                          Engineering Branch 1
Engineering Branch 1
                                                                          Division of Reactor Safety
Division of Reactor Safety
Docket No. 50-263
Docket No. 50-263
License No. DPR-22
License No. DPR-22
Enclosure:               Inspection Report 05000263/2007006(DRS)
Enclosure:
                            w/Attachment: Supplemental Information
Inspection Report 05000263/2007006(DRS)
cc w/encl:               M. Sellman, President and Chief Executive Officer
  w/Attachment: Supplemental Information
                          Manager, Nuclear Safety Assessment
cc w/encl:
                          J. Rogoff, Vice President, Counsel, and Secretary
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 Generals Office
Commissioner, Minnesota Department of Commerce
DOCUMENT NAME:C:\FileNet\ML070860170.wpd
Manager - Environmental Protection Division
G Publicly Available                       G Non-Publicly Available                 G Sensitive             G Non-Sensitive
  Minnesota Attorney Generals Office
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
DOCUMENT NAME:C:\\FileNet\\ML070860170.wpd
OFFICE           RIII                                       RIII                             RIII
G Publicly Available
NAME             ADunlop: ls                               DHills
G Non-Publicly Available
DATE             03/27/07                                   03/27/07
G Sensitive
                                                            OFFICIAL RECORD COPY
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-
J. Conway
-3-
DISTRIBUTION:
DISTRIBUTION:
TEB
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PLB1
PLB1
TXN
TXN
ROPreports@nrc.gov
ROPreports@nrc.gov  


          U.S. NUCLEAR REGULATORY COMMISSION
U.S. NUCLEAR REGULATORY COMMISSION
                          REGION III
REGION III
Docket No:         50-263
Docket No:
License No:         DPR-22
50-263
Report No:         05000263/2007006(DRS)
License No:
Licensee:           Nuclear Management Company, LLC
DPR-22
Facility:           Monticello Nuclear Generating Plant
Report No:
Location:           Monticello, Minnesota
05000263/2007006(DRS)
Dates:             February 12, 2007 through March 1, 2007
Licensee:
Inspectors:         A. Dunlop, Senior Reactor Inspector
Nuclear Management Company, LLC
                    T. Bilik, Reactor Inspector
Facility:
Observers:         V. Meghani, Reactor Inspector
Monticello Nuclear Generating Plant
Approved by:       D. Hills, Chief
Location:
                    Engineering Branch 1
Monticello, Minnesota
                    Division of Reactor Safety (DRS)
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
Enclosure
1
SUMMARY OF FINDINGS
IR 05000263/2007006(DRS); 02/12/2007 through 03/01/2007; Monticello Nuclear Generating
IR 05000263/2007006(DRS); 02/12/2007 through 03/01/2007; Monticello Nuclear Generating
Plant. Evaluations of Changes, Tests, Experiments and Permanent plant modifications.
Plant. Evaluations of Changes, Tests, Experiments and Permanent plant modifications.  
The inspection covered a 2-week announced baseline inspection on evaluations of changes,
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
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
Violation (NCV) was identified. The significance of most findings is indicated by their color
(Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance
(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
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.
NUREG-1649, Reactor Oversight Process, Revision 3; dated July 2000.
A.     Inspector-Identified and Self-Revealed Findings
A.
        Cornerstone: Mitigating Systems
Inspector-Identified and Self-Revealed Findings
        Green. The inspectors identified a Severity Level IV NCV for an inadequate 10 CFR
Cornerstone: Mitigating Systems
        50.59, Changes, Tests, and Experiments, evaluation resulting in failure to receive
Green. The inspectors identified a Severity Level IV NCV for an inadequate 10 CFR
        prior NRC approval for changes in licensed activities associated with protection of
50.59, Changes, Tests, and Experiments, evaluation resulting in failure to receive
        the emergency diesel generator exhaust stacks against tornado generated missiles.
prior NRC approval for changes in licensed activities associated with protection of
        Specifically, the licensee did not provide an adequate response to the question posed
the emergency diesel generator exhaust stacks against tornado generated missiles.  
        in 10 CFR 50.59(c)(2)(viii), and did not demonstrate that the proposed change did not
Specifically, the licensee did not provide an adequate response to the question posed
        result in a departure from a method of evaluation described in the Final Safety Analysis
in 10 CFR 50.59(c)(2)(viii), and did not demonstrate that the proposed change did not
        Report (as updated) used in establishing the design bases or in the safety analyses. As
result in a departure from a method of evaluation described in the Final Safety Analysis
        part of the corrective actions, the licensee verified that the emergency diesel generators
Report (as updated) used in establishing the design bases or in the safety analyses. As
        remained operable and initiated actions to submit a licensee amendment request for use
part of the corrective actions, the licensee verified that the emergency diesel generators
        of the new methodology.
remained operable and initiated actions to submit a licensee amendment request for use
        Because the Significance Determination Process is not designed to assess the
of the new methodology.
        significance of violations that potentially impact or impede the regulatory process, this
Because the Significance Determination Process is not designed to assess the
        issue was dispositioned using the traditional enforcement process in accordance with
significance of violations that potentially impact or impede the regulatory process, this
        Section IV of the NRC Enforcement Policy. However, the results of the violation, that is,
issue was dispositioned using the traditional enforcement process in accordance with
        the failure to demonstrate that the proposed change did not result in a departure from a
Section IV of the NRC Enforcement Policy. However, the results of the violation, that is,
        method of evaluation, were assessed using the Significance Determination Process.
the failure to demonstrate that the proposed change did not result in a departure from a
        The finding was determined to be greater than minor because the change had the
method of evaluation, were assessed using the Significance Determination Process.  
        potential for impacting the NRCs ability to perform its regulatory function as the
The finding was determined to be greater than minor because the change had the
        inspectors determined the change would have required prior NRC approval. The
potential for impacting the NRCs ability to perform its regulatory function as the
        finding was of very low safety significance based on the completed analysis for the
inspectors determined the change would have required prior NRC approval. The
        emergency diesel generator exhausts. This was determined to be a Severity Level IV
finding was of very low safety significance based on the completed analysis for the
        NCV of 10 CFR 50.59. (Section 1R02)
emergency diesel generator exhausts. This was determined to be a Severity Level IV
B.     Licensee-Identified Violations
NCV of 10 CFR 50.59. (Section 1R02)
        No findings of significance were identified.
B.
                                                    1                                    Enclosure
Licensee-Identified Violations
No findings of significance were identified.


                                    REPORT DETAILS
Enclosure
1.   REACTOR SAFETY
2
    Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
REPORT DETAILS
1R02 Evaluations of Changes, Tests, or Experiments (71111.02)
1.
.1   Review of 10 CFR 50.59 Evaluations and Screenings
REACTOR SAFETY
   a. Inspection Scope
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
    From February 12, 2007, through March 1, 2007, the inspectors reviewed two
1R02
    evaluations performed pursuant to 10 CFR 50.59. The inspectors reviewed the
Evaluations of Changes, Tests, or Experiments (71111.02)
    evaluations to confirm that they were thorough and that prior NRC approval was
.1
    obtained as appropriate. The inspector could not review the minimum sample size of
Review of 10 CFR 50.59 Evaluations and Screenings
    five evaluations because the licensee only performed one evaluation during the biennial
   a.
    sample period. One additional safety evaluation was reviewed that was performed in
Inspection Scope
    the previous sample period for a total of two samples. The inspectors also reviewed
From February 12, 2007, through March 1, 2007, the inspectors reviewed two
    18 screenings where licensee personnel had determined that a 10 CFR 50.59
evaluations performed pursuant to 10 CFR 50.59. The inspectors reviewed the
    evaluation was not necessary. In addition, seven applicability determinations were
evaluations to confirm that they were thorough and that prior NRC approval was
    reviewed to verify they did not meet the applicability requirements for a screening. The
obtained as appropriate. The inspector could not review the minimum sample size of
    evaluations and screenings were chosen based on risk significance, safety significance,
five evaluations because the licensee only performed one evaluation during the biennial
    and complexity. The list of documents reviewed by the inspectors are included as an
sample period. One additional safety evaluation was reviewed that was performed in
    attachment to this report.
the previous sample period for a total of two samples. The inspectors also reviewed
    The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for
18 screenings where licensee personnel had determined that a 10 CFR 50.59
    10 CFR 50.59 Implementation, and Revision 1, to determine acceptability of the
evaluation was not necessary. In addition, seven applicability determinations were
    completed evaluations, and screenings. The NEI document was endorsed by the
reviewed to verify they did not meet the applicability requirements for a screening. The
    NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59,
evaluations and screenings were chosen based on risk significance, safety significance,
    Changes, Tests, and Experiments, dated November 2000. The inspectors also
and complexity. The list of documents reviewed by the inspectors are included as an
    consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR
attachment to this report.
    50.59, Changes, Tests, and Experiments.
The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for  
   b. Findings
10 CFR 50.59 Implementation, and Revision 1, to determine acceptability of the
    Inadequate 10 CFR 50.59 Evaluation for Diesel Generator Exhaust Missile Protection
completed evaluations, and screenings. The NEI document was endorsed by the
    Introduction: The inspectors identified an inadequate evaluation performed pursuant to
NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59,
    10 CFR 50.59 associated with the vulnerability of the emergency diesel generator (EDG)
Changes, Tests, and Experiments, dated November 2000. The inspectors also
    exhaust stacks to tornado generated missiles. Specifically, the licensee did not provide
consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR
    an adequate response to the question posed in 10 CFR 50.59(c)(2)(viii) and did not
50.59, Changes, Tests, and Experiments.
    demonstrate that the proposed change did not result in a departure from a method of
   b.
    evaluation described in the USAR used in establishing the design bases or in the safety
Findings
    analyses. This issue was considered to be of very low safety significance (Green) and
Inadequate 10 CFR 50.59 Evaluation for Diesel Generator Exhaust Missile Protection  
    was dispositioned as a Severity Level IV Non-Cited Violation (NCV).
Introduction: The inspectors identified an inadequate evaluation performed pursuant to
                                              2                                      Enclosure
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).


Description: The inspectors reviewed 10 CFR 50.59 safety evaluation (SE) 03-004,
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)
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 the
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
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 NRCs 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 licensees 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).
(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
The NRCs safety evaluation concluded that the PRA methodology as contained in the
EPRI report was an acceptable probabilistic approach for demonstrating compliance
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 NRCs 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
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evaluation on the EPRI methodology was incorrect and that the licensees No answer
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
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.
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
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
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
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
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
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.
                                          3                                        Enclosure


In response to the finding, the licensee initiated Action Request (AR) 01079705. The
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
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 licensees 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 NRCs 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.
specific features.  
Analysis: This issue was determined to involve a performance deficiency because the
Analysis: This issue was determined to involve a performance deficiency because the
licensee incorrectly concluded that the TORMIS methodology had been approved for
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 NRCs 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.
inspectors determined the change would have required prior NRC approval.  
The inspectors evaluated the finding using IMC 0609, Appendix A, Significance
The inspectors evaluated the finding using IMC 0609, Appendix A, Significance
Determination of Reactor Inspection Findings for At-Power Situations, Phase 1
Determination of Reactor Inspection Findings for At-Power Situations, Phase 1
Line 295: Line 336:
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
licensees 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 NRCs 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.
with this finding.
Enforcement: Title 10 CFR 50.59(c)(2)(viii) states, in part, that a licensee shall obtain a
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,
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
Line 309: Line 350:
evaluation (SE-03-004) incorporating a change to the tornado missile protection
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,
                                          4                                      Enclosure


    because this violation was of very low safety significance and it was entered into the
Enclosure
    licensees corrective action program, this Severity Level IV violation is being treated as
5
    an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy
because this violation was of very low safety significance and it was entered into the
    (NCV 05000263/2007006-01(DRS)). The licensee entered the finding into their
licensees corrective action program, this Severity Level IV violation is being treated as
    corrective action program as AR01079705.
an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy
1R17 Permanent Plant Modifications (71111.17B)
(NCV 05000263/2007006-01(DRS)). The licensee entered the finding into their
.1   Review of Permanent Plant Modifications
corrective action program as AR01079705.
   a. Inspection Scope
1R17
    From February 12, 2007, through March 1, 2007, the inspectors reviewed ten
Permanent Plant Modifications (71111.17B)
    permanent plant modifications that had been installed in the plant during the last two
.1
    years. This included two engineering changes, three equivalency evaluations, and five
Review of Permanent Plant Modifications
    setpoint changes. The modifications were chosen based upon risk significance, safety
   a.
    significance, and complexity. As per inspection procedure 71111.17B, two modifications
Inspection Scope
    were chosen that affected the barrier integrity cornerstone. The inspectors reviewed the
From February 12, 2007, through March 1, 2007, the inspectors reviewed ten
    modifications to verify that the completed design changes were in accordance with the
permanent plant modifications that had been installed in the plant during the last two
    specified design requirements, and the licensing bases, and to confirm that the changes
years. This included two engineering changes, three equivalency evaluations, and five
    did not adversely affect any systems' safety function. Design and post-modification
setpoint changes. The modifications were chosen based upon risk significance, safety
    testing aspects were verified to ensure the functionality of the modification, its
significance, and complexity. As per inspection procedure 71111.17B, two modifications
    associated system, and any support systems. The inspectors also verified that the
were chosen that affected the barrier integrity cornerstone. The inspectors reviewed the
    modifications performed did not place the plant in an increased risk configuration.
modifications to verify that the completed design changes were in accordance with the
    The inspectors also used applicable industry standards to evaluate acceptability of the
specified design requirements, and the licensing bases, and to confirm that the changes
    modifications. The list of modifications and other documents reviewed by the inspectors
did not adversely affect any systems' safety function. Design and post-modification
    is included as an attachment to this report.
testing aspects were verified to ensure the functionality of the modification, its
   b. Findings
associated system, and any support systems. The inspectors also verified that the
    No findings of significance were identified.
modifications performed did not place the plant in an increased risk configuration.
4.   OTHER ACTIVITIES (OA)
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
4OA2 Identification and Resolution of Problems
.1   Routine Review of Condition Reports
.1
   a. Inspection Scope
Routine Review of Condition Reports
    From February 12, 2007, through March 1, 2007, the inspectors reviewed 18 Corrective
   a.
    Action Process documents that identified or were related to 10 CFR 50.59 evaluations
Inspection Scope
    and permanent plant modifications. The inspectors reviewed these documents to
From February 12, 2007, through March 1, 2007, the inspectors reviewed 18 Corrective
    evaluate the effectiveness of corrective actions related to permanent plant modifications
Action Process documents that identified or were related to 10 CFR 50.59 evaluations
    and evaluations for changes, tests, or experiments issues. In addition, corrective action
and permanent plant modifications. The inspectors reviewed these documents to
    documents written on issues identified during the inspection were reviewed to verify
evaluate the effectiveness of corrective actions related to permanent plant modifications
    adequate problem identification and incorporation of the problems into the corrective
and evaluations for changes, tests, or experiments issues. In addition, corrective action
                                              5                                        Enclosure
documents written on issues identified during the inspection were reviewed to verify
adequate problem identification and incorporation of the problems into the corrective


    action system. The specific corrective action documents that were sampled and
Enclosure
    reviewed by the inspectors are listed in the attachment to this report.
6
   b. Findings
action system. The specific corrective action documents that were sampled and
    No findings of significance were identified.
reviewed by the inspectors are listed in the attachment to this report.
   b.
Findings
No findings of significance were identified.
4OA6 Meetings
4OA6 Meetings
.1   Exit Meeting
.1
    The inspectors presented the inspection results to Mr. J. Grubb and others of the
Exit Meeting
    licensees staff, on March 1, 2007. Licensee personnel acknowledged the inspection
The inspectors presented the inspection results to Mr. J. Grubb and others of the
    results presented. Licensee personnel were asked to identify any documents, materials,
licensees staff, on March 1, 2007. Licensee personnel acknowledged the inspection
    or information provided during the inspection that were considered proprietary. No
results presented. Licensee personnel were asked to identify any documents, materials,
    proprietary information was identified.
or information provided during the inspection that were considered proprietary. No
ATTACHMENT: SUPPLEMENTAL INFORMATION
proprietary information was identified.
                                              6                                    Enclosure
ATTACHMENT: SUPPLEMENTAL INFORMATION


                              SUPPLEMENTAL INFORMATION
Attachment
                                  KEY POINTS OF CONTACT
1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
Licensee
R. Baumer, Licensing
R. Baumer, Licensing
Line 381: Line 434:
S. Thomas, Senior Resident Inspector
S. Thomas, Senior Resident Inspector
L. Haeg, Resident Inspector
L. Haeg, Resident Inspector
                        ITEMS OPENED, CLOSED, AND DISCUSSED
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened/Closed
Opened/Closed
05000263/2007006-01         NCV   Inadequate 10 CFR 50.59 Evaluation for Diesel Generator
05000263/2007006-01
                                    Exhaust Missile Protection (Section 1R21.3.b)
NCV
                                                1                                Attachment
Inadequate 10 CFR 50.59 Evaluation for Diesel Generator
Exhaust Missile Protection (Section 1R21.3.b)


                                LIST OF DOCUMENTS REVIEWED
Attachment
2
LIST OF DOCUMENTS REVIEWED
The following is a list of licensee documents reviewed during the inspection, including
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
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 stated
document in this list does not imply NRC acceptance of the document, unless specifically stated
in the inspection report.
in the inspection report.
IR02     Evaluation of Changes, Tests, or Experiments 71111.02
IR02
        10 CFR 50.59 Evaluations
Evaluation of Changes, Tests, or Experiments 71111.02
        SE-03-004; Diesel Exhaust Missile Protection Design Consideration; dated
10 CFR 50.59 Evaluations
        July 28, 2003
SE-03-004; Diesel Exhaust Missile Protection Design Consideration; dated
        SE-06-003; SBO Operator Actions Associated with the HPCI System; dated
July 28, 2003
        September 19, 2006
SE-06-003; SBO Operator Actions Associated with the HPCI System; dated  
        10 CFR 50.59 Screenings
September 19, 2006
        SCR-04-0283; SRV Air Actuator Model Change; dated November 23, 2005
10 CFR 50.59 Screenings
        SCR-04-0859; HPCI Turbine Steam Supply Low Pressure Isolation; dated
SCR-04-0283; SRV Air Actuator Model Change; dated November 23, 2005
        September 11, 2006
SCR-04-0859; HPCI Turbine Steam Supply Low Pressure Isolation; dated
        SCR-05-0161; Set Point for RHR Minimum Flow Switches FS-10-2-121, A, B, C and D;
September 11, 2006
        dated August 23, 2006
SCR-05-0161; Set Point for RHR Minimum Flow Switches FS-10-2-121, A, B, C and D;
        SCR-05-0242; Instrument Setpoint Calculation 4.16KV Degraded Voltage; dated
dated August 23, 2006
        March 28, 2006
SCR-05-0242; Instrument Setpoint Calculation 4.16KV Degraded Voltage; dated
        SCR-05-0266; ITS Setpoint Change - HPCI Steam Line Area Temperature - High;
March 28, 2006
        dated August 26, 2006
SCR-05-0266; ITS Setpoint Change - HPCI Steam Line Area Temperature - High;
        SCR-05-0689; Calc CA-05-146, Evaluation of Wall Thinning on FW2B-10-ED; dated
dated August 26, 2006
        October 11, 2005
SCR-05-0689; Calc CA-05-146, Evaluation of Wall Thinning on FW2B-10-ED; dated
        SCR-05-0738; Calc CA-05-028, Evaluation of HPCI Condensate Drain Line D13-2"-HE
October 11, 2005
        in the HPCI Room; dated November 9, 2005
SCR-05-0738; Calc CA-05-028, Evaluation of HPCI Condensate Drain Line D13-2"-HE
        SCR-05-0739; Calc 05-147, Evaluation of HPCI Module E.2; dated November 9, 2005
in the HPCI Room; dated November 9, 2005
        SCR-05-0757; Chilled Water Expansion Tank V-CT-1 Replacement; dated
SCR-05-0739; Calc 05-147, Evaluation of HPCI Module E.2; dated November 9, 2005
        November 15, 2005
SCR-05-0757; Chilled Water Expansion Tank V-CT-1 Replacement; dated
        SCR-05-0822; CA-05-155, Evaluation of Offgas Stack for SSE Seismic Loads; dated
November 15, 2005
        December 22, 2005
SCR-05-0822; CA-05-155, Evaluation of Offgas Stack for SSE Seismic Loads; dated
                                                2                                    Attachment
December 22, 2005


    SCR-06-0062; Less than Full Thread Engagement on RWCU AO Valve Actuator Bonnet
Attachment
    Nuts; dated February 15, 2006
3
    SCR-06-0103; HPCI Steam Void Elimination; dated April 6, 2006
SCR-06-0062; Less than Full Thread Engagement on RWCU AO Valve Actuator Bonnet
    SCR-06-0106; Service Water Pump Replacement; October 30, 2006
Nuts; dated February 15, 2006
    SCR-06-0165; Replace AO-1575(6) and Check Valves with Normally Closed Valve
SCR-06-0103; HPCI Steam Void Elimination; dated April 6, 2006
    SW-228(9); dated October 31, 2006
SCR-06-0106; Service Water Pump Replacement; October 30, 2006
    SCR-06-0166; Replace Rotork Actuators on Five MOVs with Limitorque Actuators;
SCR-06-0165; Replace AO-1575(6) and Check Valves with Normally Closed Valve
    dated April 26, 2006
SW-228(9); dated October 31, 2006
    SCR-06-0310; Technical Requirements Manual - Appendix B - Secondary Containment
SCR-06-0166; Replace Rotork Actuators on Five MOVs with Limitorque Actuators;
    Isolation Valves; dated September 12, 2006
dated April 26, 2006
    SCR-06-0557; Suppression Chamber Inspection; dated December 4, 2006
SCR-06-0310; Technical Requirements Manual - Appendix B - Secondary Containment
    SCR-07-0043; Fuel Storage and Handling Systems, Design Basis; dated
Isolation Valves; dated September 12, 2006
    January 22, 2007
SCR-06-0557; Suppression Chamber Inspection; dated December 4, 2006
    10 CFR 50.59 Applicability Determinations
SCR-07-0043; Fuel Storage and Handling Systems, Design Basis; dated
    SCR-05-0645; Drawing Classification Level Change to 3'; dated September 19, 2005
January 22, 2007
    SCR-05-0657; Combustible Loading Calculation; dated September 22, 2005
10 CFR 50.59 Applicability Determinations
    SCR-05-0663; Replace Fusible Link on V-DF-SBGT-2 with One of a Higher
SCR-05-0645; Drawing Classification Level Change to 3'; dated September 19, 2005
    Temperature Rating; dated September 28, 2005
SCR-05-0657; Combustible Loading Calculation; dated September 22, 2005
    SCR-05-0791; Evaluation of Fire Detector Locations in the Reactor Building; dated
SCR-05-0663; Replace Fusible Link on V-DF-SBGT-2 with One of a Higher
    December 5, 2005
Temperature Rating; dated September 28, 2005
    SCR-05-0819; Setpoint Change Request for the Safety/Relief Valve Low-Low Set Logic
SCR-05-0791; Evaluation of Fire Detector Locations in the Reactor Building; dated
    to Incorporate the New Trip Settings; dated December 21, 2005
December 5, 2005
    SCR-05-0830; Setpoint Change Request for the 4KV Bus-15 and Bus 16 Undervoltage
SCR-05-0819; Setpoint Change Request for the Safety/Relief Valve Low-Low Set Logic
    Relays to Incorporate the New Trip Setting; dated January 3, 2006
to Incorporate the New Trip Settings; dated December 21, 2005
    SCR-06-0308; Update USAR for Improved Technical Specification Project; dated
SCR-05-0830; Setpoint Change Request for the 4KV Bus-15 and Bus 16 Undervoltage
    July, 29, 2006
Relays to Incorporate the New Trip Setting; dated January 3, 2006
IR17 Permanent Plant Modifications 71111.17B
SCR-06-0308; Update USAR for Improved Technical Specification Project; dated
    Modifications
July, 29, 2006
    EC8819; HPCI Steam Line Area Temperature - High; dated October 27, 2006
IR17
    EC7583; Degraded Voltage Relays for Safety-Related 4KV Busses ; dated
Permanent Plant Modifications 71111.17B
    August 7, 2006
Modifications
                                            3                                  Attachment
EC8819; HPCI Steam Line Area Temperature - High; dated October 27, 2006
EC7583; Degraded Voltage Relays for Safety-Related 4KV Busses ; dated
August 7, 2006


      Equivalency Evaluations
Attachment
      EC910; Replacement Blower Wheel; Revision 1
4
      EC933 (05A099); HPCI Auxiliary Lube Oil Pump; Revision 0
Equivalency Evaluations
      EC7828; Engine Driven Fuel Pump Suction Line; Revision 0
EC910; Replacement Blower Wheel; Revision 1
      Setpoint Changes
EC933 (05A099); HPCI Auxiliary Lube Oil Pump; Revision 0
      EC8818; HPCI Turbine Steam Line Pressure - Low; dated October 27, 2006
EC7828; Engine Driven Fuel Pump Suction Line; Revision 0
      EC8792; LPCI Pump Discharge Flow - Low; dated October 27, 2006
Setpoint Changes
      SCR 05-022; 4KV Bus-15 and Bus-16 Undervoltage Relays; dated December 1, 2005
EC8818; HPCI Turbine Steam Line Pressure - Low; dated October 27, 2006
      SCR 05-023; Main Steam Line Steam Chase High Temp Group 1 Isolation; dated
EC8792; LPCI Pump Discharge Flow - Low; dated October 27, 2006
      December 1, 2005
SCR 05-022; 4KV Bus-15 and Bus-16 Undervoltage Relays; dated December 1, 2005
      SCR 05-028; SRV Low Low Set Pressure Interlock; 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
Other Documents Reviewed During Inspection
      Corrective Action Program Documents Generated As a Result of 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;
AR01076896; List to NRC Screened out All 50.59 Screening using the 3283 Form;
      AR01077202; SCR-05-0830 Description Contains Incorrect Value; dated
AR01077202; SCR-05-0830 Description Contains Incorrect Value; dated
      February 14, 2007
February 14, 2007
      AR01077855; Action to Correct Drawing Error was Cancelled; dated February 19, 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
AR01078665; Error in Calculation CA-05-146, Evaluation of Wall Thinning in
      FW2B-10"-ED; dated February 22, 2007
FW2B-10"-ED; dated February 22, 2007
      AR01079705; LAR Required for Use of TORMIS Code Methodology; dated
AR01079705; LAR Required for Use of TORMIS Code Methodology; dated
      February 28, 2007
February 28, 2007
      AR01080049; SCR-05-0161 Activity Incorrectly Categorized; dated March 1, 2007
AR01080049; SCR-05-0161 Activity Incorrectly Categorized; dated March 1, 2007
      Corrective Action Program Documents Reviewed During the Inspection
Corrective Action Program Documents Reviewed During the Inspection  
      AR00824446; NDE Thickness < 87.5 percent TNOM on FW2B-10"-ED, B Feedwater
AR00824446; NDE Thickness < 87.5 percent TNOM on FW2B-10"-ED, B Feedwater
      to Reactor Line; March 25, 2005
to Reactor Line; March 25, 2005
      AR00891838; Evidence of Water Leakage on 11 and 12 EDG Exhaust Pipe Insulation;
AR00891838; Evidence of Water Leakage on 11 and 12 EDG Exhaust Pipe Insulation;
      dated September 28, 2005
dated September 28, 2005
      AR01000610; Replacement Part does not Match the Part Removed; dated
AR01000610; Replacement Part does not Match the Part Removed; dated
      October 10, 2005
October 10, 2005
                                            4                                    Attachment


Attachment
5
AR01000746; Inconsistency Between Line Design Table and Plant; dated
AR01000746; Inconsistency Between Line Design Table and Plant; dated
October 11, 2005
October 11, 2005
Line 498: Line 559:
December 21, 2005
December 21, 2005
AR01022687; SW 1-18"-JF Does Not Meet Class 1 Design Criteria ; dated April 6, 2006
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
AR01026395; Potential Exists for Failure to Manually Start ECCS Room Coolers; dated
April 26, 2006
April 26, 2006
Line 517: Line 579:
System Pressure; Revision 0
System Pressure; Revision 0
CA-04-110; Determination of HPCI Area High Temperature Setpoints; Revision 1
CA-04-110; Determination of HPCI Area High Temperature Setpoints; Revision 1
                                      5                                  Attachment


Attachment
6
CA-05-108; Evaluation of Wall Thinning on FW2B-10-ED Piping; Revision 0
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
CA-05-146; Evaluation of Wall Thinning on FW2B-10"-ED Piping; Revision 0
Line 526: Line 589:
NH-36250; Monticello Nuclear Generating Plant P&ID (Water Side) High Pressure
NH-36250; Monticello Nuclear Generating Plant P&ID (Water Side) High Pressure
Coolant Injection System; Revision AF
Coolant Injection System; Revision AF
                                      6                                    Attachment


                        LIST OF ACRONYMS USED
Attachment
ADAMS Agency-Wide Document Access and Management System
7
AR   Action Request
LIST OF ACRONYMS USED
CFR   Code of Federal Regulations
ADAMS
DRP   Division of Reactor Projects
Agency-Wide Document Access and Management System
DRS   Division of Reactor Safety
AR
EDG   Emergency Diesel Generator
Action Request
EC   Engineering Change
CFR
EPRI Electric Power Research Institute
Code of Federal Regulations  
IMC   Inspection Manual Chapter
DRP
IR   Inspection Report
Division of Reactor Projects
NCV   Non-Cited Violation
DRS
NEI   Nuclear Energy Institute
Division of Reactor Safety
NRC   Nuclear Regulatory Commission
EDG
NRR   Office of Nuclear Reactor Regulation
Emergency Diesel Generator
PARS Publicly Available Records
EC
PRA   Probabilistic Risk Assessment
Engineering Change
SCR   Screening (50.59)
EPRI
SCR   Setpoint Change Request
Electric Power Research Institute  
SDP   Significance Determination Process
IMC
SE   Safety Evaluation (50.59)
Inspection Manual Chapter
TS   Technical Specifications
IR
USAR Updated Safety Analysis Report
Inspection Report
                                      7                Attachment
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:

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GLS

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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