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Category:Letter type:L
MONTHYEARL-MT-23-054, Subsequent License Renewal Application Supplement 82024-01-11011 January 2024 Subsequent License Renewal Application Supplement 8 L-MT-23-047, License Amendment Request: Revision to the MNGP Pressure Temperature Limits Report to Change the Neutron Fluence Methodology and Incorporate New Surveillance Capsule Data2023-12-29029 December 2023 License Amendment Request: Revision to the MNGP Pressure Temperature Limits Report to Change the Neutron Fluence Methodology and Incorporate New Surveillance Capsule Data L-MT-23-056, Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 Part 22023-12-18018 December 2023 Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 Part 2 L-MT-23-042, 2023 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.462023-12-11011 December 2023 2023 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.46 L-MT-23-052, Subsequent License Renewal Application Supplement 72023-11-30030 November 2023 Subsequent License Renewal Application Supplement 7 L-MT-23-051, Update to the Technical Specification Bases2023-11-28028 November 2023 Update to the Technical Specification Bases L-MT-23-049, Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 12023-11-21021 November 2023 Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 L-MT-23-043, 10 CFR 50.55a(z)(1) Request Regarding OMN-17, Revision 1. VR-092023-11-13013 November 2023 10 CFR 50.55a(z)(1) Request Regarding OMN-17, Revision 1. VR-09 L-MT-23-038, License Amendment Request to Revise Monticello Technical Specification Surveillance Requirement 3.8.6.62023-11-10010 November 2023 License Amendment Request to Revise Monticello Technical Specification Surveillance Requirement 3.8.6.6 L-MT-23-046, Subsequent License Renewal Application Response to Request for Additional Information Round 2 - Set 12023-11-0909 November 2023 Subsequent License Renewal Application Response to Request for Additional Information Round 2 - Set 1 L-MT-23-041, Subsequent License Renewal Application Response to Request for Confirmation of Information Set 22023-10-0303 October 2023 Subsequent License Renewal Application Response to Request for Confirmation of Information Set 2 L-MT-23-037, Subsequent License Renewal Application Response to Request for Additional Information Set 32023-09-22022 September 2023 Subsequent License Renewal Application Response to Request for Additional Information Set 3 L-MT-23-036, Subsequent License Renewal Application Response to Request for Additional Information Set 2 and Supplement 62023-09-0505 September 2023 Subsequent License Renewal Application Response to Request for Additional Information Set 2 and Supplement 6 L-MT-23-035, Subsequent License Renewal Application Supplement 52023-08-28028 August 2023 Subsequent License Renewal Application Supplement 5 L-MT-23-034, Subsequent License Renewal Application Response to Request for Additional Information Set 12023-08-15015 August 2023 Subsequent License Renewal Application Response to Request for Additional Information Set 1 L-MT-23-028, 2023 Refueling Outage 90-Day Inservice Inspection (ISI) Summary Report2023-07-31031 July 2023 2023 Refueling Outage 90-Day Inservice Inspection (ISI) Summary Report L-MT-23-032, 10 CFR 50.55a(z)(2) Request Regarding MO-2397, VR-112023-07-31031 July 2023 10 CFR 50.55a(z)(2) Request Regarding MO-2397, VR-11 L-MT-23-031, Subsequent License Renewal Application Supplement 4 and Responses to Request for Confirmation of Information - Set 12023-07-18018 July 2023 Subsequent License Renewal Application Supplement 4 and Responses to Request for Confirmation of Information - Set 1 L-MT-23-030, Subsequent License Renewal Application Supplement 32023-07-0404 July 2023 Subsequent License Renewal Application Supplement 3 L-MT-23-025, Subsequent License Renewal Application Supplement 22023-06-26026 June 2023 Subsequent License Renewal Application Supplement 2 L-MT-23-019, Submittal of 2022 Annual Radiological Environmental Operating Report2023-05-10010 May 2023 Submittal of 2022 Annual Radiological Environmental Operating Report L-MT-23-020, Submittal of 2022 Annual Radioactive Effluent Release Report2023-05-10010 May 2023 Submittal of 2022 Annual Radioactive Effluent Release Report L-MT-23-021, Core Operating Limits Report (COLR) for the Monticello Nuclear Generating Plant for Cycle 322023-05-0202 May 2023 Core Operating Limits Report (COLR) for the Monticello Nuclear Generating Plant for Cycle 32 L-MT-23-017, 2022 Annual Report of Individual Monitoring for the Monticello Nuclear Generating Plant (MNGP)2023-04-18018 April 2023 2022 Annual Report of Individual Monitoring for the Monticello Nuclear Generating Plant (MNGP) L-MT-23-010, Subsequent License Renewal Application Supplement 12023-04-0303 April 2023 Subsequent License Renewal Application Supplement 1 L-MT-23-013, Core Operating Limits Report (COLR) for Cycle 31, Revision 32023-03-28028 March 2023 Core Operating Limits Report (COLR) for Cycle 31, Revision 3 L-MT-23-012, Core Operating Limits Report (COLR) for Monticello Nuclear Generating Plant Cycle 31, Revision 22023-03-17017 March 2023 Core Operating Limits Report (COLR) for Monticello Nuclear Generating Plant Cycle 31, Revision 2 L-MT-23-008, 10CFR50.55a Request to Use Later Edition of ASME Section XI for ISI Code of Record (RR-003)2023-02-0707 February 2023 10CFR50.55a Request to Use Later Edition of ASME Section XI for ISI Code of Record (RR-003) L-MT-23-004, CFR 50.55a Request RR-001, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI for the Monticello Third Interval Containment Inservice Inspection Program2023-01-23023 January 2023 CFR 50.55a Request RR-001, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI for the Monticello Third Interval Containment Inservice Inspection Program L-MT-23-005, Response to the NRC Request for Additional Information Regarding the 50.55a Request Pr 08, HPCI Pump Quarterly Testing (EPID Number L-2022-LLR-0088)2023-01-0606 January 2023 Response to the NRC Request for Additional Information Regarding the 50.55a Request Pr 08, HPCI Pump Quarterly Testing (EPID Number L-2022-LLR-0088) L-MT-22-049, Industry Groundwater Protection Initiative Special Report2022-12-15015 December 2022 Industry Groundwater Protection Initiative Special Report L-MT-22-052, L-MT-22-052 Monticello Nuclear Generating Plant 10 CFR 50.55a Request No. Pr 08, Request for HPCI Pump Quarterly Alternative2022-12-15015 December 2022 L-MT-22-052 Monticello Nuclear Generating Plant 10 CFR 50.55a Request No. Pr 08, Request for HPCI Pump Quarterly Alternative L-MT-22-046, 2022 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.462022-12-13013 December 2022 2022 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.46 L-MT-22-048, Update to the Monticello Technical Specification Bases2022-11-28028 November 2022 Update to the Monticello Technical Specification Bases L-MT-22-047, Withdrawal of Request for Relief from ASME OM Code for the Sixth Inservice Testing Interval2022-11-10010 November 2022 Withdrawal of Request for Relief from ASME OM Code for the Sixth Inservice Testing Interval L-MT-22-045, Letter Submitting Post-Exam Package2022-11-0404 November 2022 Letter Submitting Post-Exam Package L-MT-22-030, Sixth Interval Inservice Testing (1ST) Plan2022-09-0606 September 2022 Sixth Interval Inservice Testing (1ST) Plan L-MT-22-037, Supplement to 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval, Alternative VR-10, Excess Flow Check Valve Testing Frequency2022-08-29029 August 2022 Supplement to 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval, Alternative VR-10, Excess Flow Check Valve Testing Frequency L-MT-22-007, Response to Request for Additional Information for the Monticello Nuclear Generating Plant Alternative Request VR-08 (EPID: L-MT-22-007)2022-07-22022 July 2022 Response to Request for Additional Information for the Monticello Nuclear Generating Plant Alternative Request VR-08 (EPID: L-MT-22-007) L-MT-22-026, Changes to the Emergency Plan2022-07-19019 July 2022 Changes to the Emergency Plan L-MT-22-024, Response to a Request for Additional Information for the Monticello Nuclear Generating Plant Related to the Amendment to Adopt Advanced Framatome Methodologies2022-06-0606 June 2022 Response to a Request for Additional Information for the Monticello Nuclear Generating Plant Related to the Amendment to Adopt Advanced Framatome Methodologies L-MT-22-022, Response to a Request for Additional Information: Monticello Alternative VR-10, Excess Flow Check Valve Testing Frequency2022-05-25025 May 2022 Response to a Request for Additional Information: Monticello Alternative VR-10, Excess Flow Check Valve Testing Frequency L-MT-22-017, 2021 Annual Radiological Environmental Operating Report2022-05-11011 May 2022 2021 Annual Radiological Environmental Operating Report L-MT-22-018, 2021 Annual Radioactive Effluent Release Report2022-05-11011 May 2022 2021 Annual Radioactive Effluent Release Report L-MT-22-016, 2021 Annual Report of Individual Monitoring2022-04-28028 April 2022 2021 Annual Report of Individual Monitoring L-MT-22-019, Withdrawal of Requests for Relief from ASME OM Code for the Sixth Inservice Testing Interval2022-04-18018 April 2022 Withdrawal of Requests for Relief from ASME OM Code for the Sixth Inservice Testing Interval L-MT-22-010, License Amendment Request to Revise Technical Specification 3.6.1.8 Residual Heat Removal (RHR) Drywell Spray Header and Nozzle Surveillance Frequency2022-03-18018 March 2022 License Amendment Request to Revise Technical Specification 3.6.1.8 Residual Heat Removal (RHR) Drywell Spray Header and Nozzle Surveillance Frequency L-MT-22-012, Special Report for the Bypass of the Offgas Treatment Storage System2022-03-15015 March 2022 Special Report for the Bypass of the Offgas Treatment Storage System L-MT-22-008, 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval Alternative Related to Excess Flow Check Valve Testing Frequency (L-MT-22-008)2022-03-0707 March 2022 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval Alternative Related to Excess Flow Check Valve Testing Frequency (L-MT-22-008) L-MT-22-006, 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval OMN-26 (L-MT-22-006)2022-02-18018 February 2022 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval OMN-26 (L-MT-22-006) 2024-01-11
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'n VA Monticello Nuclear Generating Plant NMC Committed to Nuclear Excel[e Operated by Nuclear Management Company, LLC August 11, 2005 L-MT-05-087 10 CFR 50.55a(a)(3)(i)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 License No. DPR-22 10 CFR 50.55a Request No. 12: Proposed Alternative for Visual Examination Illumination Levels in Accordance With 10 CFR 50.55a(a)(3)(i)
Pursuant to 10 CFR 50.55a(a)(3)(i), the Nuclear Management Company, LLC (NMC) requests U.S. Nuclear Regulatory Commission (NRC) authorization for application of the enclosed 10 CFR 50.55a request to the Fourth Ten-Year Interval Inservice Inspection (ISI) Program at the Monticello Nuclear Generating Plant (MNGP).
NMC identified five VT-2 examinations (done in conjunction with post-repair/replacement pressure tests) where illumination levels were not verified in accordance with Section Xl, IWA-2210, "Visual Examinations," of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. Authorization is requested on a one-time basis, for the use of an alternative method that was applied to verify illumination levels for these five VT-2 examinations (performed in 2003 and 2004), in lieu of the Section Xl, IWA-2210 requirements, as described within the 10 CFR 50.55a request provided in Enclosure 1.
This letter contains no new commitments and makes no revisions to existing commitments.
Johr/Conway Site V e President, Monticello Nuclear Generating Plant Nuc ar Management Company, LLC Enclosure cc: Administrator, Region l1l, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce (Attn: L. Brandon) g 2807 West County Road 75 . Monticello, Minnesota 55362-9637 Telephone: 763.295.5151
ENCLOSURE 1 10 CFR 50.55a REQUEST NO. 12 PROPOSED ALTERNATIVE FOR VISUAL EXAMINATION ILLUMINATION LEVELS IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)
- 1. ASME Code Component(s) Affected Component and System ASME Code Class Control Rod Drive (CRD) System Hydraulic Control Unit 2 (HCU) 26-27 Residual Heat Removal-Service Water (RHRSW) System 3 Pump 12 RHRSW System Pump 14 3 Emergency Diesel Generator-Emergency Service Water 3 (EDG-ESW) System Pump 11 EDG-ESW System Pump 12 3
- 2. Applicable ASME Section Xi Code Edition and Addenda The applicable Code for Repair/Replacement and related activities is the 2001 Edition, No Addenda as authorized in the Monticello Nuclear Generating Plant (MNGP) Fourth Ten-Year Interval Inservice Inspection (ISI) Program IOCFR50.55a Request No. 7, October 3, 2003 (TAC No. MB6897).
- 3. Applicable Code Requirement The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, IWA-2210, "Visual Examinations," provides the following requirements (meeting either of which would be sufficient to demonstrate adequate illumination) for conducting visual examinations.
IWA-221 0(e) specifies the following requirements for illumination levels:
"It is not necessary to measure illumination levels on each examination surface when the same portable light source or similar installed lighting equipment is demonstrated to provide the illumination specified in Table IWA-2500-1 at the maximum examination distance."
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ENCLOSURE 1 10 CFR 50.55a REQUEST NO. 12 PROPOSED ALTERNATIVE FOR VISUAL EXAMINATION ILLUMINATION LEVELS IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)
IWA-221 0(f) states:
"The adequacy of the illumination levels from battery powered portable lights shall be checked before and after each examination or series of examinations, not to exceed 4 hr between checks. In lieu of using a light meter, these checks may be made by verifying that the illumination is adequate (i.e., no discernable degradation in the visual examination resolution of the procedure demonstration test chart characters)."
- 4. Reason for Request:
NMC identified five VT-2 examinations, performed in conjunction with post-repair/replacement pressure tests (during the first period of the current 10-year ISI interval), which were not performed in accordance with the illumination requirements of IWA-2210 and could not be re-performed.' The illumination levels were not verified as required. Authorization is requested to utilize an alternative method that was used to verify the illumination levels, as described in Section 5.
The five VT-2 examinations were performed using portable battery-powered lights (a standard practice to ensure adequate lighting). However, due to a procedural inadequacy, the illumination levels were not verified before and after each VT-2 examination as specified in IWA-221 0(f), nor were the illumination levels demonstrated pursuant to IWA-2210(e). (This procedural inadequacy is tracked and is being corrected under the MNGP Corrective Action Program.)
Consequently, without verifying the illumination levels of the portable battery-powered lights or ambient light conditions, only the knowledge and skill of the certified VT-2 examiner was available to attest that the lighting conditions were adequate for the five VT-2 examinations. Because it could not initially be verified that the lighting levels were acceptable, it was conservatively assumed that the requirements of IWA-221 0 were not met for these five VT-2 examinations.
Listed below are the five pressure tests, which could not be re-performed,* where the VT-2 examination illumination levels could not initially be determined as acceptable:
The replaced components were restored to operable status prior to the identification of this illumination concern with the VT-2 examinations. The pre-service pressure testing required by IWA-4540 (and associated VT-2 examinations) cannot be re-performed because the associated systems were restored to service.
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ENCLOSURE I 10 CFR 50.55a REQUEST NO. 12 PROPOSED ALTERNATIVE FOR VISUAL EXAMINATION ILLUMINATION LEVELS IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)
RJR Plan Work Description Examination Number WokDsrpinDate 2003-22-0011 Replace accumulator on 10/26/03 HCU 26-27 2003-22-0012 Replace EDG-ESW Pump 12 with 12/4/03 2003-22-0014 rebuilt spare from stock. 12/4/03 2003-22-0014 Replace RHRSW Pump 14 with 11/7/03 rebuilt spare from stock.
2003-22-0021 Replace RHRSW Pump 12 with 11/21/03 rebuilt spare from stock.
2004-22-0062 Replace EDG-ESW Pump 11 with 11/15/04 1rebuilt spare from stock.
- 5. Proposed Alternative and Basis for Use The proposed illumination alternative for the five VT-2 examinations is based upon the following three factors. First, the possession of the knowledge and skill by the certified VT-2 examiners, and their attestation that there was sufficient lighting for them to properly perform the examinations. Second, the use of battery-powered portable lights by the VT-2 examiners, which provided additional illumination (beyond ambient) during the examinations. Third, a walk-down of the areas where the VT-2 examinations were conducted was performed by the site Nondestructive Examination (NDE) Level IlIl, to verify the ambient illumination level provided by the permanent plant lighting was adequate to meet the requirements of IWA-2210, as described below.
Upon discovery of the five post-repair/replacement pressure tests, for which the VT-2 examination illumination levels could not be initially be determined as acceptable, the site NDE Level IlIl walked-down each location and performed illumination checks where the VT-2 examinations had been conducted.
Illumination checks were performed using a light meter and/or a character card.
The illumination checks were done to establish whether the existing permanently installed plant (ambient) lighting provided reasonable assurance of sufficient illumination at each location to comply with IWA-221 0(e) illumination requirements during the performance of the VT-2 examinations.
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ENCLOSURE I 10 CFR 50.55a REQUEST NO. 12 PROPOSED ALTERNATIVE FOR VISUAL EXAMINATION ILLUMINATION LEVELS IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)
The results of these illumination checks provided reasonable assurance that the ambient illumination levels at the components, using the existing permanently installed plant lighting, were sufficient to meet IWA-2210 requirements. Also, during performance of these illumination checks, the NDE Level IlIl examiner did not identify any indications of leakage from the pressure-tested components.
Based on the following factors, NMC considers the proposed alternative to be acceptable:
- Walk-downs following the VT-2 examinations indicate that the ambient illumination provided by the permanent plant lighting was sufficient,
- The skill and knowledge of the certified VT-2 examiners attesting to a light level sufficient for them to perform their examinations, and
- The VT-2 examiners used battery-powered portable lights (which provided additional illumination above ambient) during the VT-2 examinations.
Therefore, NMC considers the proposed method, consisting of the three factors listed above, to be an acceptable alternative to the lighting verification required by IWA-2210 during the performance of the five VT-2 examinations. NMC believes that the proposed alternative provided an acceptable level of quality and safety.
NMC requests a one-time approval for the use of the alternative method previously described, that was applied for verifying the illumination levels for the five VT-2 examinations associated with the post-repair/replacement pressure tests identified in this 10 CFR 50.55a request.
- 6. Duration of Proposed Alternative NMC requests a one-time approval of the alternative method that was applied for determining the illumination levels for the five VT-2 examinations (for the subject components specified in Section 1) for the first period of the current fourth ten-year ISI interval for the MNGP.
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