ML023640042

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Part 1 of 4 - Revision 0 to Inservice Inspection Examination Plan, Fourth Interval March 9, 2003 Through May 31, 2012
ML023640042
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 12/06/2002
From: Whitcomb D
Nuclear Management Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML023640042 (103)


Text

{{#Wiki_filter:NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN NM~6 NUCLEAR MANAGEMENT COMPANY 700 1st Street HUDSON, WISCONSIN 54106 MONTICELLO NUCLEAR GENERATING PLANT 2807 WEST HIGHWAY 75 MONTICELLO, MINNESOTA 55362 INSERVICE INSPECTION EXAMINATION PLAN REVISION 0 FOURTH INTERVAL MARCH 9, 2003 THROUGH MAY 31, 2012 Prepared By: Daniel Whitcomb ISI Program Engineer, MMRN Reviewed By:, Richard Deopere Section XIl I JCoordinator, Monticello Approved By: Secti dintor Gary Park Supv, Material Inspection and Repair Approved By:Z/Z* 4 ,f'.*.J.--- - .

                            - 6nica Vik Supt, Metals and Materials Resources AN II Review:

Kurt Suleski, ANII Hartford Steam Boiler - CT Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN RECORD OF REVISIONS Paqe Rev. Review and Approval ................................................................................ 0 i ..... ..................... ........................ .......................0 1.1-1 .......................................................................................................... 0 1.2-1 through 1.2-3 .................................................................................. 0 1.3-1 and 1.3-2 ......................................................................................... 0 1.4-1 through 1.4-6 .................................................................................... 0 1.5-1 through 1.5-55 .................................................................................. 0 1.6-1 through 1.6-4 ................................................................................... 0 1.7-1 through 1.7-3 .................................................................................... 0 Inspection Schedule (Page 1 to 326) ......................................................... 0 i Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN TABLE OF CONTENTS Page Record of Revisions ................................................................................... i Table of Contents ....................................................................................... 1.1-1 Introduction ................................................................................................ 1.2-1 Source Documents ..................................................................................... 1.3-1 Section Xl Code Cases .............................................................................. 1.4-1 Requests for Relief .................................................................................... 1.5-1 ISI Boundary/Isometric Drawings .............................................................. 1.6-1 Inspection Plan and Schedule Tables (Pages 1 to 326) ............................ 1.7-1 1.1-1 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN INTRODUCTION

Background:

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code (hereafter referred to as ASME Section Xl, Section XI, or the Code), Section Xl Inservice Inspection (ISI) Program is prepared and maintained by the Nuclear Management Company (NMC). The Inservice Testing Program (IST) is maintained separately from this program and is submitted under separate cover. The Repair/Replacement Program and Containment Inspection Program (as allowed by 10CFR55a(g)(6)(ii)(B)(5)) are maintained separately from this program and, although they are not submitted, they are available at the plant site for audit and review. 4th Ten-Year Interval: The Monticello 4th Ten-Year Inservice Inspection Interval is slightly less than 120 months due to an extension of the 3rd Interval (Letter to NRC dated May 30, 2002 providing notification of 3rd Interval extension through March 8, 2003) (M2002057). The 4th Interval begins March 9, 2003 and ends May 31, 2012. Six refueling and maintenance outages are currently scheduled in this time frame. Component Selection: With the exception of Class 1 and 2 piping welds, components within the examination plan were selected and scheduled using criteria in the 1995 Edition of ASME Section XI with thel 996 Addenda (Inspection Program B) and 10CFR50.55a(g)(6)(ii)(A), except where relief has been requested. Per 10CFR50.55a(b)(2)(xi), the requirements of IWB-1220 in the 1989 Edition of ASME Section Xl, "Components Exempt from Examination," shall be used for Class 1 piping instead of the 1995 Edition of ASME Section XI with 1996 Addenda. Selection of Class 1 and Class 2 piping welds in ASME Categories B-F, B-J, C-F-1 and C-F-2 are based on EPRI Topical Report 112657 Rev. B-A. "Revised Risk Informed Inservice Inspection Evaluation Procedure." The Risk Informed Class 1 and Class 2 application was also conducted in a manner consistent with ASME Code Case N-578 "Risk Informed Requirements for Class 1, 2, and 3 Piping, Method B." The use of the RI-ISI program was approved for use on July 27, 2002. (reference TAC MB3819 and Relief Request #1 for 4th ISI Interval) 1.2-1 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN INTRODUCTION (cont'd) Code Edition Summary: The code editions implemented in the ISI Program can be summarized as follows: Class I (Quality Group A) 1995 Edition with 1996 Addenda Risk-Informed Program (Relief #1) 1989 Edition IWB-1220 (10CFR50.55a) Class 1 CRD Bolting (B7.80) Augmented program GE SIL. No. 483R2 Class 2 (Quality Group B) 1995 Edition with 1996 Addenda Risk-Informed Program (Relief #1) Class 3 (Quality Group C) 1995 Edition with 1996 Addenda NF (Supports) 1995 Edition with 1996 Addenda MC (Metal Containment) 1992 Edition with 1992 Addenda, Subsection IWE Appendix VIII -- Supplements 1995 Edition with 1996 Addenda per 10CFR50.55a(g)(6)(ii)(C) effective Nov.22, 1999 Supplements 1, 2, 3, 8 Implemented May 22, 2000 Supplements 4 and 6 Implemented Nov. 22, 2000 Supplements 11 Implemented Nov. 22, 2001 Supplements 5, 7,10,12,13 Implemented Nov. 22, 2002 Background for PlanlSchedule Development: The examination plan and schedule was developed from ASME Code requirements, Risk-Informed Methodology, individual component examination history and plant scheduling needs such as optimizing insulation removal and scaffolding needs. During the 2nd Interval, a substantial number of component replacements and alterations were made (e.g. the recirculation piping replacement). The intent of the 4th Interval scheduling was to be consistent with the 2nd and 3rd Interval, subject to allowing meaningful accumulation of service time for new components. For Class I (category B-F and B-J) and Class 2 Category C-F-1 and C-F-2) Piping Welds examined per the RI-ISI Plan, there may be little schedule correlation with previous ISI Intervals. 1.2-2 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN INTRODUCTION (cont'd) Examination Personnel I Procedures: Inservice Inspection examinations are performed by personnel qualified and certified by written practice to the 1995 Edition of ASME Section XI with the 1996 Addenda, CP-1 89, and PDI (Performance Demonstration Initiative) to perform Appendix VIII - Supplements, referenced in ASME Section Xl, 1995 Edition with 1996 addenda. Additional training for UT examination personnel shall also include the requirements of 10CFR50.55a(b)(2)(xiv). Reportinq of Associated Section Xl Programs: The Section Xl Repair and Replacement Program, System Pressure Tests and Snubber Functional Tests are administered under separate program documents. Although these programs are administered separately, the activities required by the Repair and Replacement Program, System Pressure Tests and Snubber Functional Tests are reported in the "Inservice Inspection Summary Report" following each refueling outage. ISI Plan Overall

Description:

The ASME Section XI Inservice Inspection Program is comprised of six parts: Introduction, Source Documents, Requests for Relief, ISI Boundary Drawings, ISI Isometric Drawings, and a table containing the Inservice Inspection Examination Plan and Schedule. The ISI Boundary Drawings outline Quality Group Classifications, (A, B and C). The ISI Isometric Drawings delineate ASME Section Xl components or items that are included in the examination program. The Inservice Inspection Examination Plan and Schedule lists the ASME Section XI components by Isometric Drawing Number, System, Code Category, Code Item, Component Description and Required Examination. The Examination Plan and Schedule identify the ASME Section XI Item Number listed in Tables IWB-2500-1, IWC-2500-1, IWD-2500-1 and Subsection IWF, and item number for Risk Informed Tables as identified in EPRI TR-1 12657, thus identifying the examination method. The examination schedule lists the anticipated period and outage for the examination of a given component. The examination schedule is intended to be flexible to allow for deviations in outage length and outage work scope. Therefore, the schedule may be changed, as allowed by the Code, without further notification. Examination distribution was developed in accordance with IWA-2432, Inspection Program B. 1.2-3 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN INTRODUCTION (cont'd) The examination plan and schedule also contains certain non-code items to be examined, or examinations beyond Section XI Code requirements. These augmented items include licensee-initiated examinations on NC-7879-6ITank and NC-ISI-37/W-1, W-2, W-3, W-4, W-12, W-12A shown in the plan and schedule. These items will be examined to the extent practical in accordance with the Section Xl Code, 1995 Edition with 1996 Addenda, not the RI-ISI Program. Relief requests will not be submitted for these non-code exams if Section Xl Code requirements cannot be met. Non-code exams are also subject to change without prior notification to the NRC. The Monticello Plant was built prior to the implementation of Section Xl Access Requirements. As a result, some components that require examination may not be completely accessible. Welds selected for examination under the Risk Informed Program were selected base on risk ranking, radiation area, and weld accessibility as allowed by EPRI TR-1 12657. 1.2-4 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Source Documents: The following referenced source documents described and listed below are basis documents used and applicable to the Monticello 4th Interval ISI Plan. ASME BPV Code Section XI, 1992 Edition with 1992 Addenda, Subsection IWE ASME BPV Code Section XI, 1995 Edition with 1996 Addenda 10CFR50.55a (66FR16391) 10CFR-50.55a(g)(6)(ii)(A)(64FR51370) ASME Section XI, 1995 Edition with 1996 Addenda, Appendix VIII Supplements IOCFR-50.55a(g)(6)(ii)(A)(66FR1 6391) ASME Section XI, 1995 Edition with 1996 Addenda, Appendix VIII Supplement 4 Length Sizing Correction Regulatory Guide 1.150, Rev. 1 & Generic Letter 83-15 Regulatory Guide 1.147, Rev. 12, May 1999 Regulatory Guide 1.147, Rev. 13 (unpublished) (DG-1091 "Inservice Inspection Code Case Acceptability," ASME Section XI, Division 1 December 2001) and (DG-1 112 "ASME Code Cases Not Approved for Use" December 2001) Monticello Inservice Inspection Licensee Control Program, 4 AWI-09.04.00 GE Nuclear Services Information Letter, SIL. No. 483R2 "CRD Cap Screw Crack Indications," September 5, 1992 Generic Letter 88-01 & NUREG 0313, Rev 2 (IGSCC (M88080A, M88082A)

       **Note: All Monticello welds meet NUREG-0313, Rev. 2. Category A NRC Letter, "Monticello Nuclear Generating Plant-Approval of Relief Request Number 8 of the Third 10 Year Inservice Inspection Program,"

(TAC No. M96255), November 19,1997 NRC Letter, "MNGP-Evaluation of Relief Request No. 12 (for the 3rd 10-Year ISI Program Plan," (TAC No. MB0261), July 27, 2001 NRC Letter, "MNGP-Evaluation of Relief Request No. 13 (for the 3rd 10-Year ISI Program Plan," (TAC No. MB1 833), August 22, 2001 1.3-1 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Source Documents: (cont'd) Monticello Notification Letter to NRC, uNotification of Extension of 3rd Ten-Year Inservice Testing and Inservice Inspection Intervals," May 30, 2002 NRC Letter, "MNGP-Third 10-Year Interval ISI Program Request for Relief from ASME Code, Section XI Requirements (TAC No. MB3904). (Relief Request #14 for 3rd ISI Interval), April 22, 2002 NRC Letter, "Monticello Nuclear Generating Plant - Risk-Informed Inservice Inspection Program (TAC MB3819)" (Relief Request #1 for 4th ISI Interval) EPRI Report TR-1 12657, Rev B-A, "Revised Risk-Informed Inservice Inspection Evaluation Procedure," December 1999 1.3-2 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Section XI Code Cases: The following listed Code Cases are permissible for use at Monticello during the 4th Interval per Draft Regulatory Guide DG-1091. The Draft Reg. Guide will become Reg. Guide 1.147, Rev. 13. The examination schedule will reflect Code Case implementation on an item or category basis, as applicable. Code Case N-307-2 Revised Ultrasonic Examination Volume for Class I Bolting, Table IWB-2500-1, Examination Category B-G-I, When the Examinations are Conducted from the End of the Bolt or Stud, or from the Center-Drilled Hole. (Applicable, see Schedule Section of Plan) Code Case N-460 Alternative Examination Coverage for Class 1 and Class 2 Welds, Section XI, Division I (Applied as necessary on an item/exam basis, will be referred to in Schedule Section of Plan when/if applied) Code Case N-498-1 Alternative Rules for 10 Year System Hydrostatic Testing for Class 1, 2, and 3 Systems. (Applicable to Class 3, Category D-B only, see Schedule Section of Plan) Code Case N-504-2 Alternative Rules for Repair of Class 1, 2, and 3 Austenitic Stainless Steel Piping. (Applied as necessary on an item/exam basis, will be referred to in Schedule Section of Plan when/if applied) 1.4-1 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Section XI Code Cases: (cont'd) Code Case N-517-1 Quality Assurance Program Requirements for Owners. (Applicable) Condition of Use for The owners quality assurance program that Code Case N-517-1 is approved under Appendix B to 10 CFR 50 must address the use of this Code Case and any unique QA requirements identified by the Code Case that are not contained in the owner's QA Program description. This would include the activities performed in accordance with this Code Case that are subject to monitoring by the Authorized Nuclear Inspector. (Condition of Use noted) Code Case N-522 Pressure Testing of Containment Penetration Piping. (Applicable) Condition of Use for The test should be conducted at peak Code Case N-522 calculated containment pressure and the test procedure must permit the detection and location of through wall leakage in containment isolation (CIV) and pipe segment between the CIVs. (Condition of Use noted) Code Case N-526 Alternative Requirements for Successive Inspections of Class 1 and 2 Vessels. (Applied as necessary on an item/exam basis, will be referred to in Schedule Section of Plan when/if applied). Code Case N-528-1 Purchase, Exchange, or Transfer of Material Between Nuclear plant Sites. (Applicable) Condition of Use for The requirements of 10 CFR Part 21 are to be Code Case N-528-1 applied to the nuclear plant site supplying the material as well as to the nuclear plant site receiving the material that has been purchased, exchanged, or transferred between sites. (Condition of Use noted) 1.4-2 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Section XI Code Cases: (cont'd) Code Case N-532 Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA 6000. (Applicable) Condition of Use for An Owner's Activity Report OAR-1 is required Code Case N-532 to be prepared and certified upon completion of each refueling outage. The Code Case does not designate a time frame for submission to the regulatory authority. Thus the OAR-1 must be submitted within 90 days. (Condition of Use noted) Code Case N-533-1 Alternative requirements for VT-2 Visual Examination of Class 1, 2, and 3 Insulated Pressure Retaining Bolted Connections. (Applied as necessary on an item/exam basis, when/if applied). Condition of Use for A four hour hold time must be maintained Code Case N-533-1 prior to the VT-2 visual examination. (Condition of Use noted) Code Case N-537 Location of Ultrasonic Depth Sizing Flaws. Code Case N-545 Alternative Requirements for Conduct of Performance Demonstration Detection Test of Reactor Vessel. 1.4-3 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Section XI Code Cases: (cont'd) Code Case N-546 Alternative Requirements for Qualification of VT-2 Examination Personnel. (Applicable) Condition of Use for (1) Qualify examination personnel by test Code Case N-546 to demonstrate knowledge of Section XI and plant specific procedures for VT-2 visual examination. (2) Re-qualify examination personnel by examination every three years. (3) This Code Case is applicable only to the performance of VT-2 examinations. (Condition of Use noted) Code Case N-552 Alternative Methods-Qualification for Nozzle Inside Radius Section from the Outside Surface. Condition of Use for To achieve consistency with the 10CFR50.55a Code Case N-552 rule change published September 22, 1999, incorporating Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems," to Section XI; add the following to the Specimen requirements:

                               "At least 50 percent of the flaws in the demonstration test set must be cracks and the maximum misorientation must be demonstrated with cracks. Flaws in nozzles with bore diameters equal to or less than 4 inches may be notches.

Add to detection criteria, "The number of false calls must not exceed three." Code Case N-566-1 Corrective action for leakage Identified at Bolted Connections. (Applied as necessary on an item/exam basis, will be referred to in Schedule Section of Plan when/if applied) 1.4-4 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Section XI Code Cases: (cont'd) Code Case N-578* Risk-Informed Requirements for Class 1, 2, and 3 Piping, Method B, Section Xl, Division I (* Not approved by DG-1 091, but approved by Relief Request #1 on page 1.5-2. Applied to Class 1 and 2 piping welds, Category B-F, B-J, C-F-I, and C-F-2) Code Case N-592 ASNT Central Certification Program. Code Case N-598 Alternative Requirements to Required Percentages of examinations. Code Case N-606-1 Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW Temper Bead Technique for BWR CRD Housing/Stub tube repairs. Condition of Use for A VT-1 surface examination, in accordance Code Case N-606-1 with IWA-221 0 must be performed prior to welding to ensure that the surface is free from contaminants, and that the surface is properly contoured so that an acceptable weld can be produced. Code Case N-617 Alternative Examination Distribution Requirements for Table IWC-2500-1 Examination Category C-G, Pressure Retaining Welds in Pumps and Valves. (Applicable, will be referenced in Schedule Section of Plan when/if applied) Code Case N-623 Deferral of Inspections of Shell to Flange and Head-to-Flange Welds of a Reactor Vessel. (Applicable, see Schedule Section of Plan) Code Case N-624 Successive Inspections 1.4-5 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Section Xl Code Cases: (cont'd) Code Case N-638 Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW Temper Bead Technique Code Case N-639 Alternative Calibration Block Material Condition of Use for The chemical analysis must be within the Code Case N-639 material specification, and the microstructure (phase and grain shape) must be the same as the material being examined. Code Case N-652 Alternative Requirements to Category B-G-1, B-G-2, and C-D bolting examination Methods and Selection Criteria. (Applicable, see Schedule Section of Plan) <-I 1.4-6 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Requests for Relief Relief Request No. Description Rev. 1* Risk Informed Inservice Inspection Plan 0 (Approved July 24, 2002 for 4th Interval) 2** Reactor Vessel Circumferential Welds 1 (Approved July 27, 2001 for remainder of current 40-Year Operating License) 3 Appendix VIII Supplement 4 0 4 Reactor Vessel Stabilizer Brackets 0 5 Leakage at Bolted Control Rod Drive 0 (CRD) Housing Connections 6 Appendix VII Annual Training 0

  • Relief No. 1 is approved for use during the 4th ISI Interval and is not being submitted for further NRC Review or approval.

Relief No. 2 is approved for use during the remaining time in the current operating license, including the 4th ISI Interval, and is not being submitted for further NRC Approval. It has been revised slightly to correct a weldname nomenclature error and update commitment statements made in Rev. 0. 1.5-1 Revision 0 9/26/2002

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NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Monticello Unit I - ISI Relief Request No. 1 (Rev. 0) Risk Informed Inservice Inspection Plan System: Various Class: l and2 Category: B-F Item: ALL B-J ALL C-F-1 ALL C-F-2 ALL Alternative Examination Requirements: Monticello has implemented Risk Informed Inservice Inspection program for Class 1 and Class 2 piping welds in accordance with EPRI Topical Report TR- 12657 Rev. B-A, Final Report, December 1999. Basis for Relief: See attached Risk Informed Program Plan Submittal Rev. 0. Status: Approved July 24, 2002. NRC Letter, "Monticello Nuclear Generating Plant Risk-Informed Inservice Inspection Program (TAC MB3819)" 1.5-2 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN RISK-INFORMED INSERVICE INSPECTION PROGRAM PLAN MONTICELLO NUCLEAR GENERATING PLANT - REVISION 0 Table of Contents

1. Introduction 1.1 Relation to NRC Regulatory Guides 1.174 and 1.178 1.2 PSA Quality
2. Proposed Alternative to Current Inservice Inspection Programs 2.1 ASME Section Xl 2.2 Augmented Programs
3. Risk-Informed ISI Process 3.1 Scope of Program 3.2 Consequence Evaluation 3.3 Failure Potential Assessment 3.4 Risk Characterization 3.5 Element and NDE Selection 3.5.1 Additional Examinations 3.5.2 Program Relief Requests 3.6 Risk Impact Assessment 3.6.1 Quantitative Analysis 3.6.2 Defense-in-Depth
4. Implementation and Monitoring Program
5. Proposed ISI Program Plan Change
6. References/Documentation 1.5-3 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN

1. INTRODUCTION The Monticello Nuclear Generating Plant (MNGP) is nearing the end of its 3rd Inservice Inspection (ISI) Interval as defined by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Section Xl Code for Inspection Program B. MNGP plans to implement a Risk-Informed Inservice Inspection (RI-ISI) Program concurrent with the start of the 4th ISI interval, which will begin on June 1, 2002. Pursuant to 10 CFR 50.55a(g)(4)(ii), the applicable ASME Section XI Code for the 4th ISI interval will be the 1995 Edition through 1996 Addenda.

The objective of this submittal is to request the use of a risk-informed process for the inservice inspection of Class 1 and 2 piping. The risk-informed inservice inspection (RI-ISI) process used in this submittal is described in Electric Power Research Institute (EPRI) Topical Report (TR) 112657 Rev. B-A "Revised Risk Informed Inservice Inspection Evaluation Procedure." The RI-ISI application was also conducted in a manner consistent with ASME Code Case N-578 "Risk Informed Requirements for Class 1, 2, and 3 Piping, Method B." 1.1 Relation to NRC Regulatory Guides 1.174 and 1.178 As a risk-informed application, this submittal meets the intent and principles of Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions On Plant Specific Changes to the Licensing Basis" and Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-Informed Decisionmaking Inservice Inspection of Piping." Further information is provided in Section 3.6.2 relative to defense-in-depth. 1.2 PSA Quality The Monticello Level 1 and Level 2 Probabilistic Safety Assessment (PSA) results that are based on the January 1999 update were used to evaluate the consequences of pipe ruptures for the RI-ISI assessment during power operation. The base PSA Core Damage Frequency (CDF) is 1.5E-5 events per year and the base PSA Large Early Release Frequency (LERF) is 5.5E-7 events per year for the 1999 update. The original IPE result was a CDF of 2.6E-5, which was reported to the NRC in 1992. The PSA model update history is discussed below. 1.5-4 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN The NRC review of the Monticello Individual Plant Examination (IPE) was issued in May 1994. The Staff Evaluation Report (SER) concluded the following regarding the Monticello IPE:

    "* The IPE is complete with respect to the information requested in Generic Letter 88-20 and associated Supplement 1;
    "* The IPE analytical approach is technically sound and capable of identifying plant-specific vulnerabilities;
     "   Monticello employed a viable means to verify that the IPE models reflect the current plant design and operation at the time of submittal to the NRC;
     "* The IPE had been peer-reviewed;
     "* Monticello participated in the IPE process;
     "* The IPE specifically evaluated the Monticello decay heat removal functions for vulnerabilities;
     "* Monticello had responded appropriately to the Containment Performance Improvement program recommendations.

There were no areas of improvement to the PSA model that were identified by the NRC in their review of the plant's IPE submittal. The internal events PSA used for the RI-ISI evaluation is based on a more current version of the PSA than the version used for the IPE. The PSA model was updated in 1994, 1995 and 1999. The major differences in the PSA model between the original IPE and the PSA updates through the 1995 update are that the updated model includes the following:

     "* Addition of a non-safety 480kv diesel generator that can backfeed through emergency bus 15 to supply battery charges;
      "* Installation of a hard piped vent that provides an additional means for containment heat removal; 1.5-5                        Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN

    "* Improvements to safety relief valve pneumatics (including power supplies);
    "* Addition of a crosstie for alignment of the diesel fire pump as an additional source of low pressure makeup water;
    "* Replacement of an instrument air compressor with one that is not dependent on service water;
    "* More realistic success criteria for service water by changing from 2 of 3 pumps required for success to 1 of 3 pumps required for success;
    "* Internal floods initiating event frequency and effects were updated.

The 1999 PSA update was performed to incorporate the effects of power uprate conditions. In 1997, a BWROG PSA Peer Certification Review was performed on the 1995 update PSA model. The overall conclusion was positive and said that the Monticello PSA can be effectively used to support applications involving relative risk significance. The "Facts and Observations" for Monticello have been evaluated, and are being addressed by the Monticello PSA Program. No substantial changes to the RI-ISI consequence conclusions are anticipated due to planned PSA model revisions to address these "Facts and Observations."

2. PROPOSED ALTERNATIVE TO CURRENT ISI PROGRAM REQUIREMENTS 2.1 ASME Section XI ASME Section Xl Examination Categories B-F, B-J, C-F-1 and C-F-2 currently contain the requirements for the nondestructive examination (NDE) of Class 1 and 2 piping components. The alternative RI-ISI program for piping is described in EPRI TR-112657. The RI-ISI program will be substituted for the current program for Class 1 and 2 piping (Examination Categories B-F, B-J, C-F-1 and C-F-2) in accordance with 10 CFR 50.55a(a)(3)(i) by alternatively providing an acceptable level of quality and safety. Other non-related portions of the ASME Section X1 Code will be unaffected. EPRI TR- 12657 provides the requirements for 1.5-6 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN defining the relationship between the RI-ISI program and the remaining unaffected portions of ASME Section XI. 2.2 Augmented Programs The following augmented inspection programs were considered during the RI-ISI application:

    "   The augmented inspection program for flow accelerated corrosion (FAC) per Generic Letter 89-08 is relied upon to manage this damage mechanism but is not otherwise affected or changed by the RI-ISI program.
    "   The augmented inspection program for intergranular stress corrosion cracking (IGSCC) as addressed in NRC Generic Letter 88-01 and NUREG-0313, Rev. 2, have been resolved by Monticello's pipe replacement program wherein all susceptible material was replaced with resistant material. All welds are therefore classified as IGSCC Category "A". In accordance with EPRI TR-1 12657, piping welds identified as Category "A" are considered resistant to IGSCC, and as such are assigned a low failure potential provided no other damage mechanisms are present. Examination criteria for these welds will be in accordance with the RI-ISI process.
     "  The augmented inspection program for High Energy Line Break (HELB) piping includes 36 Class 1 welds that are classified as ASME Section XI, Examination Category B-J. Although MNGP is not committed to using the NUREG-0800 Standard Review Plan (SRP),

Sections 3.6.1 and 3.6.2 of the SRP are used as guidance in determining appropriate design and examination requirements for specified high energy piping. The 36 Class 1 welds that require examination in accordance with the HELB augmented inspection program are between the containment penetration and the outboard isolation valve in the main steam, high pressure coolant injection, reactor core isolation cooling, reactor water clean-up, residual heat removal and core spray systems. Independent of the HELB program, the RI-ISI application selected 8 of these 36 HELB welds for examination. The remaining 28 HELB welds will continue to be examined in accordance with the HELB augmented inspection program. 1.5-7 Revision 0 9126/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN

3. RISK-INFORMED ISI PROCESS The process used to develop the RI-ISI program conformed to the methodology described in EPRI TR-112657 and consisted of the following steps:
  • Scope Definition
  • Consequence Evaluation
  • Failure Potential Assessment
  • Risk Characterization
  • Element and NDE Selection
  • Risk Impact Assessment
  • Implementation Program
  • Feedback Loop A deviation to the EPRI RI-ISI methodology has been implemented in the failure potential assessment for MNGP. Table 3-16 of EPRI TR-1 12657 contains criteria for assessing the potential for thermal stratification, cycling and striping (TASCS). Key attributes for horizontal or slightly sloped piping greater than 1" nominal pipe size (NPS) include:
1. Potential exists for low flow in a pipe section connected to a component allowing mixing of hot and cold fluids, or
2. Potential exists for leakage flow past a valve, including in-leakage, out leakage and cross-leakage allowing mixing of hot and cold fluids, or
3. Potential exists for convective heating in dead-ended pipe sections connected to a source of hot fluid, or
4. Potential exists for two phase (steam/water) flow, or
5. Potential exists for turbulent penetration into a relatively colder branch pipe connected to header piping containing hot fluid with turbulent flow, AND AT > 50'F, AND Richardson Number > 4 (this value predicts the potential buoyancy of a stratified flow) 1.5-8 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN These criteria, based on meeting a high cycle fatigue endurance limit with the actual AT assumed equal to the greatest potential AT for the transient, will identify all locations where stratification is likely to occur, but allows for no assessment of severity. As such, many locations will be identified as subject to TASCS where no significant potential for thermal fatigue exists. The critical attribute missing from the existing methodology that would allow consideration of fatigue severity is a criterion that addresses the potential for fluid cycling. The impact of this additional consideration on the existing TASCS susceptibility criteria is presented below. Turbulent penetration TASCS Turbulent penetration typically occurs in lines connected to piping containing hot flowing fluid. In the case of downward sloping lines that then turn horizontal, significant top-to-bottom cyclic ATs can develop in the horizontal sections if the horizontal section is less than about 25 pipe diameters from the reactor coolant piping. Therefore, TASCS is considered for this configuration. For upward sloping branch lines connected to the hot fluid source that turn horizontal or in horizontal branch lines, natural convective effects combined with effects of turbulence penetration will keep the line filled with hot water. Ifthere is no potential for in-leakage towards the hot fluid source from the outboard end of the line, this will result in a well-mixed fluid condition where significant top-to-bottom ATs will not occur. Therefore TASCS is not considered for these configurations. Even in fairly long lines, where some heat loss from the outside of the piping will tend to occur and some fluid stratification may be present, there is no significant potential for cycling as has been observed for the in-leakage case. The effect of TASCS will not be significant under these conditions and can be neglected.

>       Low flow TASCS In some situations, the transient startup of a system (e.g., RHR suction piping) creates the potential for fluid stratification as flow is established.

In cases where no cold fluid source exists, the hot flowing fluid will fairly rapidly displace the cold fluid in stagnant lines, while fluid mixing will occur in the piping further removed from the hot source and stratified conditions will exist only briefly as the line fills with hot fluid. As such, since the situation is transient in nature, it can be assumed that the criteria for thermal transients (TT) will govern. 1.5-9 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN > Valve leakage TASCS Sometimes a very small leakage flow of hot water can occur outward past a valve into a line that is relatively colder, creating a significant temperature difference. However, since this is a generally a "steady state" phenomenon with no potential for cyclic temperature changes, the effect of TASCS is not significant and can be neglected. >* Convection heating TASCS Similarly, there sometimes exists the potential for heat transfer across a valve to an isolated section beyond the valve, resulting in fluid stratification due to natural convection. However, since there is no potential for cyclic temperature changes in this case, the effect of TASCS is not significant and can be neglected. In summary, these additional considerations for determining the potential for thermal fatigue as a result of the effects of TASCS provide an allowance for the consideration of cycle severity in assessing the potential for TASCS effects. The above criteria has previously been submitted by EPRI for generic approval (Letter dated February 28, 2001, P.J. O'Regan (EPRI) to Dr. B. Sheron (USNRC), "Extension of Risk-informed Inservice Inspection Methodology"). 3.1 Scope of Program The systems included in the RI-ISI program are provided in Table 3.1. The piping and instrumentation diagrams and additional plant information including the existing plant ISI program, were used to define the Class 1 and 2 piping system boundaries. 3.2 Consequence Evaluation The consequence(s) of pressure boundary failures were evaluated and ranked based on their impact on core damage and containment performance (i.e., isolation, bypass and large early release). The impact on these measures due to both direct and indirect effects was considered using the guidance provided in EPRI TR-1 12657. 3.3 Failure Potential Assessment Failure potential estimates were generated utilizing industry failure history, plant specific failure history, and other relevant information. 1.5-10 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN These failure estimates were determined using the guidance provided in EPRI TR-1 12657, with the exception of the previously stated deviation. Table 3.3 summarizes the failure potential assessment by system for each degradation mechanism that was identified as potentially operative. 3.4 Risk Characterization In the preceding steps, each run of piping within the scope of the program was evaluated to determine its impact on core damage and containment performance (i.e., isolation, bypass and large, early release) as well as its potential for failure. Given the results of these steps, piping segments are then defined as continuous runs of piping potentially susceptible to the same type(s) of degradation and whose failure will result in similar consequence(s). Segments are then ranked based upon their risk significance as defined in EPRI TR-1 12657. The results of these calculations are presented in Table 3.4. 3.5 Element and NDE Selection In general, EPRI TR-1 12657 requires that 25% of the locations in the high risk region and 10% of the locations in the medium risk region be selected for inspection using appropriate NDE methods tailored to the applicable degradation mechanism. In addition, per Section 3.6.4.2 of EPRI TR 112657, if the percentage of Class 1 piping locations selected for examination falls substantially below 10%, then the basis for selection needs to be investigated. For MNGP, the percentage of Class 1 welds selected per the RI-ISI process is 9.3% (76 of 817 welds), which is not a significant departure from 10%. One additional factor that was considered during the evaluation was that the overall percentage of Class 1 selections included both socket and non-socket welds. Therefore, the percentage of Class 1 selections was 9.3% when both socket and non-socket piping welds were considered. This percentage increases to 13.2% (75 of 567 welds) when considering only those piping welds that are non-socket welded. It should be noted that non-socket welds are subject to volumetric examination, so this percentage does not rely upon welds that are solely subject to a VT-2 visual examination. As stated in TR-1 12657, the existing FAC augmented inspection program provides the means to effectively manage this mechanism. No additional 1.5-11 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN credit was taken for any FAC augmented inspection program locations beyond those selected by the RI-ISI process to meet the sampling percentage requirements. A brief summary is provided below, and the results of the selection are presented in Table 3.5. Section 4 of EPRI TR-1 12657 was used as guidance in determining the examination requirements for these locations. Class I Piping Welds( ) 1 Class 2 Piping Welds(2) All Piping Welds(3) Unit I Total Selected Total Selected Total Selected 1 817 76 901 12 1718 88 Notes

1. Includes all Category B-F and B-J locations 2 Includes all Category C-F-1 and C-F-2 locations 3 All in-scope piping components, regardless of risk classification, will continue to receive Code required pressure testing, as part of the current ASME Section XI program. VT-2 visual examinations are scheduled in accordance with the station's pressure test program that remains unaffected by the RI-ISI program.

3.5.1 Additional Examinations The RI-ISI program in all cases will determine through an engineering evaluation the root cause of any unacceptable flaw or relevant condition found during examination. The evaluation will include the applicable service conditions and degradation mechanisms to establish that the element(s) will still perform their intended safety function during subsequent operation. Elements not meeting this requirement will be repaired or replaced. The evaluation will include whether other elements in the segment or additional segments are subject to the same root cause conditions. Additional examinations will be performed on those elements with the same root cause conditions or degradation mechanisms. The additional examinations will include high risk significant elements and medium risk significant elements, if needed, up to a number equivalent to the number of elements required to be inspected on the segment or segments during the current outage. If unacceptable flaws or relevant conditions are again found similar to the initial problem, the remaining elements identified as susceptible will be examined. No additional 1.5-12 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN examinations will be performed if there are no additional elements identified as being susceptible to the same root cause conditions. 3.5.2 Program Relief Requests An attempt has been made to select RI-ISI locations for examination such that a minimum of >90% coverage (i.e., Code Case N-460 criteria) is attainable. However, some limitations will not be known until the examination is performed, since some locations may be examined for the first time by the specified techniques. In instances where locations are found at the time of the examination that do not meet the >90% coverage requirement, the process outlined in EPRI TR-112657 will be followed. None of the existing MNGP relief requests are being withdrawn due to the RI-ISI application. 3.6 Risk Impact Assessment The RI-ISI program has been conducted in accordance with Regulatory Guide 1.174 and the requirements of EPRI TR-112657, and the risk from implementation of this program is expected to remain neutral or decrease when compared to that estimated from current requirements. This evaluation identified the allocation of segments into High, Medium, and Low risk regions of the EPRI TR-1 12657 and ASME Code Case N 578 risk ranking matrix, and then determined for each of these risk classes what inspection changes are proposed for each of the locations in each segment. The changes include changing the number and location of inspections within the segment and in many cases improving the effectiveness of the inspection to account for the findings of the RI-ISI degradation mechanism assessment. For example, for locations subject to thermal fatigue, examinations will be conducted on an expanded volume and will be focused to enhance the probability of detection (POD) during the inspection process. 3.6.1 Quantitative Analysis Limits are imposed by the EPRI methodology to ensure that the change in risk of implementing the RI-ISI program meets the 1.5-13 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN requirements of Regulatory Guides 1.174 and 1.178. The EPRI criterion requires that the cumulative change in core damage frequency (CDF) and large early release frequency (LERF) be less than 1E-07 and 1 E-08 per year per system, respectively. Monticello conducted a risk impact analysis per the requirements of Section 3.7 of EPRI TR-1 12657. The analysis estimates the net change in risk due to the positive and negative influence of adding and removing locations from the inspection program. A risk quantification was performed using the "Simplified Risk Quantification Method" described in Section 3.7 of EPRI TR 112657. The conditional core damage probability (CCDP) and conditional large early release probability (CLERP) used for high consequence category segments was based on the highest evaluated CCDP (9E-03) and CLERP (9E-03), whereas, for medium consequence category segments, bounding estimates of CCDP (1 E-04) and CLERP (1 E-05) were used. The likelihood of pressure boundary failure (PBF) is determined by the presence of different degradation mechanisms and the rank is based on the relative failure probability. The basic likelihood of PBF for a piping location with no degradation mechanism present is given as x0 and is expected to have a value less than 1 E-08. Piping locations identified as medium failure potential have a likelihood of 20x0 . In addition, the analysis was performed both with and without taking credit for enhanced inspection effectiveness due to an increased POD from application of the RI-ISI approach. The PBF likelihoods and POD values used in the analysis are consistent with those used in the approved RI-ISI pilot applications at Arkansas Nuclear One, Unit 2, and Vermont Yankee, as documented in References 9 and 14 of EPRI TR-1 12657. Table 3.6-1 presents a summary of the RI-ISI program versus ASME Section Xl Code requirements and identifies on a per system basis each applicable risk category. The presence of FAC was adjusted for in the performance of the quantitative analysis by excluding its impact on the risk ranking. However, in an effort to be as informative as possible, for those systems where FAC is present, Table 3.6-1 presents the information in such a manner as to depict what the resultant risk categorization is both with and without consideration of FAC. This is accomplished by enclosing the FAC damage mechanism, as well as all other resultant corresponding changes (failure potential rank, risk category and risk rank), in parenthesis. Again, this has only been done for information purposes, and has no impact on the assessment itself. 1.5-14 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN The use of this approach to depict the impact of degradation mechanisms managed by augmented inspection programs on the risk categorization is consistent with that used in the delta risk assessment for the Arkansas Nuclear One, Unit 2 pilot application. An example is provided below. System Risk Consequence Failure Potential Category j RankW) Rank DMs Rank In this example if FAC is not considered, the failure potential rank is "medium" instead of "high" based on the TASCS and TT damage mechanisms When a "medium" failure potential rank is combined with a "medium" consequence rank, it results in risk category 5 ("medium" risk) being assigned instead of risk cateqorv 3 ("hiqh" risk) t.... TASCSTT FW Medium (High) Medium (FAC) T(3) Medium (High) In this example if FAC were considered, the failure potential rank would be "high' instead of "medium". If a "high" failure potential rank were combined with a "medium" consequence . rank, it would result in risk category 3 ("high" risk) being assigned instead of risk category 5 ("medium" risk). Note

1. The risk rank is not included in Table 3 6-1 but it is included in Table 5-2 1.5-15 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN As indicated in the table below, this evaluation has demonstrated that unacceptable risk impacts will not occur from implementation of the RI-ISI program, and satisfies the acceptance criteria of Regulatory Guide 1.174 and EPRI TR-112657. Risk Impact Results ARiskLERF SystemW ARiSkCDF w/ POD w/o POD w/ POD wlo POD RPV 9 OOE-1 1 9.OOE-1 1 9 OOE-1 1 9.00E-1 1 RWCU 4 50E-11 4 50E-11 4 50E-11 4.50E-11 MS 9.90E-10 9 90E-10 9.90E-10 9 90E-10 SLC -4.50E-11 -4.50E-1I -4.50E-11 -4.50E-11 RCR 6.98E-09 6 98E-09 6 98E-09 6.98E-09 RCIC -1.38E-10 -1.10E-10 -9 48E-11 -9.20E-11 RHR -9 71E-09 -2.13E-09 -9 72E-09 -2 16E-09 CS 1.22E-09 1.22E-09 1 22E-09 1.22E-09 HPCI -6.15E-10 2.69E-09 -5.88E-10 2.66E-09 FW -6 20E-09 3 90E-09 -6.17E-09 3 91E-09 CCW negligible negligible negligible negligible CRD negligible negligible negligible negligible FPEC no change no change no change no change PCAC negligible negligible negligible negligible Torus negligible negligible negligible negligible Total -7.40E-09 1.36E-08 -7.30E-09 1.36E-08 Note

1. Systems are described in Table 3 1.

1.5-16 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN 3.6.2 Defense-in-Depth The intent of the inspections mandated by ASME Section XI for piping welds is to identify conditions such as flaws or indications that may be precursors to leaks or ruptures in a system's pressure boundary. Currently, the process for picking inspection locations is based upon structural discontinuity and stress analysis results. As depicted in ASME White Paper 92-01-01 Rev. 1, "Evaluation of Inservice Inspection Requirements for Class 1, Category B-J Pressure Retaining Welds," this method has been ineffective in identifying leaks or failures. EPRI TR-1 12657 and Code Case N 578 provide a more robust selection process founded on actual service experience with nuclear plant piping failure data. This process has two key independent ingredients, that is, a determination of each location's susceptibility to degradation and secondly, an independent assessment of the consequence of the piping failure. These two ingredients assure defense in depth is maintained. First, by evaluating a location's susceptibility to degradation, the likelihood of finding flaws or indications that may be precursors to leak or ruptures is increased. Secondly, the consequence assessment effort has a single failure criterion. As such, no matter how unlikely a failure scenario is, it is ranked High in the consequence assessment, and at worst Medium in the risk assessment (i.e., Risk Category 4), if as a result of the failure there is no mitigative equipment available to respond to the event. In addition, the consequence assessment takes into account equipment reliability, and less credit is given to less reliable equipment. All locations within the Class 1 and 2 pressure boundaries will continue to receive a system pressure test and visual VT-2 examination as currently required by the Code regardless of its risk classification.

4. IMPLEMENTATION AND MONITORING PROGRAM Upon approval of the RI-ISI program, procedures that comply with the guidelines described in EPRI TR-1 12657 will be prepared to implement and monitor the program. The new program will be integrated into the 4th Inservice Inspection Interval. No changes to the Technical Specifications or Updated Final Safety Analysis Report are necessary for program implementation.

1.5-17 Revision 0 9/2612002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN The applicable aspects of the ASME Code not affected by this change will be retained, such as inspection methods, acceptance guidelines, pressure testing, corrective measures, documentation requirements, and quality control requirements. Existing ASME Section Xl program implementing procedures will be retained and modified to address the RI-ISI process, as appropriate. The monitoring and corrective action program will contain the following elements: A. Identify B. Characterize C. (1) Evaluate, determine the cause and extent of the condition identified (2) Evaluate, develop a corrective action plan or plans D. Decide E. Implement F. Monitor G. Trend The RI-ISI program is a living program requiring feedback of new relevant information to ensure the appropriate identification of high safety significant piping locations. As a minimum, risk ranking of piping segments will be reviewed and adjusted on an ASME period basis. In addition, significant changes may require more frequent adjustment as directed by NRC Bulletin or Generic Letter requirements, or by industry and plant specific feedback.

5. PROPOSED ISI PROGRAM PLAN CHANGE A comparison between the RI-ISI program and ASME Section XI Code 1986 Edition program requirements for in-scope piping is provided in Tables 5-1 and 5-2. (Since no examination selections had been made for the 4th interval ISI Program prior to the development on the RI-ISI Program, the 3rd Interval selections were used for comparison purposes. The Code of record for the 3rd Interval was the 1986 Edition of ASME Section XI.) Table 5-1 provides a summary comparison by risk region. Table 5-2 provides the same comparison information, but in a more detailed manner by risk category, similar to the format used in Table 3.6-1.

MNGP is implementing the RI-ISI program at the start of the 1st period of its 4th Inspection Interval. As such, 100% of the required RI-ISI program inspections will be completed in the 4th interval. Examinations shall be performed during the 1.5-18 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN interval such that the period examination percentage requirements of ASME Section XI, paragraphs IWB-2412 and IWC-2412 are met.

6. REFERENCES/DOCUMENTATION EPRI TR-1 12657, "Revised Risk-Informed Inservice Inspection Evaluation Procedure," Rev. B-A ASME Code Case N-578, "Risk-Informed Requirements for Class 1, 2, and 3 Piping, Method B, Section Xl, Division 1" Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions On Plant-Specific Changes to the Licensing Basis" Regulatory Guide 1.178, "An Approach for Plant-Specific Risk Informed Decisionmaking Inservice Inspection of Piping" Supporting Onsite Documentation Structural Integrity Calculation/File No. NMC-01-301, "Degradation Mechanism Evaluation for Class 1 and 2 Piping Welds at Monticello Nuclear Generating Plant," Revision 1 Structural Integrity Calculation/File No. NMC-01 -302, "Risk-Informed Inservice Inspection Consequence Evaluation of Class 1 and 2 Piping for Monticello Nuclear Power Plant," Revision 1 Structural Integrity Calculation/File No. NMC-01-303, "Risk Ranking Summary, Matrix and Report for the Monticello Nuclear Generating Plant," Revision 0 Structural Integrity Calculation/File No. NMC-01 -304, "Risk Impact Analysis for the Monticello Nuclear Generating Plant," Revision 1 Structural Integrity File No. NMC-01 -103-4, Record of Conversation No. ROC 002, "Minutes of the Element Selection Meeting for the Risk-Informed ISI Project at the Monticello Nuclear Generating Plant," Revision 1, June 21, 2001 MNGP Calculation/File No. CA-01-216, "Monticello Nuclear Generating Plant, Risk-Informed Service History Report for Class I and IIPiping Welds, ASME Categories B-F, B-J, C-F-1 and C-F-2," Revision 0 1.5-19 Revision 0 9/26/2002

(. C, C INSERVICE INSPECTION NUCLEAR MANAGEMENT COMPANY EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 3.1 System Selection and Segment I Element Definition System Description Number of Segments Number of Elements RPV - Reactor Pressure Vessel 19 112 RWCU - Reactor Water Clean-Up 10 85 MS - Main Steam 22 204 SLC - Standby Liquid Control 3 35 RCR - Reactor Coolant Recirculation 22 135 RCIC - Reator Core Isolation Cooling 13 65 RHR - Residual Heat Removal 97 476 CS - Core Spray 36 191 HPCI - High Pressure Coolant Injection 20 158 FW - Feedwater 37 78 CCW - Component Cooling Water 2 18 CRD - Control Rod Drive 7 41 FPEC- Fuel Pool Emergency Cooling 10 54 PCAC - Primary Containment and Atmospheric Control 8 47 Torus - Torus Hard Vent 1 19 Totals 307 1718 NOTE: TABLE 3.2 was not part of the Risk-Informed ISI Program submittal and is intentionally excluded from this document. 1.5-20 Revision 0 9/26/2002

( ( NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 3.3 Failure Potential Assessment Summary Thermal Fatigue Stress Corrosion Cracking Localized Corrosion Flow Sensitive TASCS TT IGSCC TGSCC ECSCC PWSCC MIC PIT CCC E-C FAC RPV RWCU MS X SLC RCR X RCIC X X RHR X X CS x x HPCI X FW X X X X CCW CRD FPEC PCAC Torus Note

1. Systems are described in Table 3.1.

1.5-21 Revision 0 9/26/2002

( NUCLEAR MANAGEMENT COMPANY Tale3. INSERVICE INSPECTION EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 3.4 Number of Segments by Risk Category With and Without Impact of FAC High Risk Region Medium Risk Region Low Risk Region System( 1

           "        Category I               Category 2         Category 3           Category 4             Category 5             Category 6          Category 7 With     Without        With      Without With       Without     With     Without      With      Without      With       Without    With    Without RPV                                                                           6           6                                10           10        3         3 RWCU                                                                            9           9                                                       1         1 MS           2(2)       0                                                     5           7                                14           14        1         1 SLC                                                                           1           1                                  2          2 RCR                                  10          10                           10         10                                                       2         2 RCIC                                                     3(3)        0         2           2          3          6            3          3         2         2 RHR                                   3           3    15(4)        0         13         13         5(5)        2          44          59        17        20 CS                                    2           2     1(6)        0         4           4         47)         0            6          7        19        23 HPCI                                   2           2                           4           4          3          3          11           11 FW           14(8)      0            14          21     2(9)        0         6          13           1         3 Ccw                                                                                                                                                2         2 CRD                                                                                                                           2          2         5         5 FPEC                                                                                                                         10           10 PCAC                                                                                                                           8          8 Torus                                                                                                                           1         1 Total          16        0            31-- -      38     21-         0         60         69          16         14         111         127       52        59 Notes
1. Systems are described in Table 3 1.
2. These two segments become Category 4 after FAC is removed from consideration due to no other damage mechanisms being present.
3. These three segments become Category 5 after FAC is removed from consideration due to the presence of other 'medium' failure potential damage mechanisms.
4. These fifteen segments become Category 6 after FAC is removed from consideration due to no other damage mechanisms being present.

1.5-22 Revision 0 9/26/2002

C ( NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Notes for Table 3.4 (cont'd)

5. Of these five segments, three segments become Category 7 after FAC is removed due to no other damage mechanisms being present.

6 This one segment becomes Category 6 after FAC is removed due to no other damage mechanisms being present

7. These four segments become Category 7 after FAC is removed due to no other damage mechanisms being present.
8. Of these fourteen segments, seven segments become Category 2 after FAC is removed due to the presence of other'medium" failure potential damage mechanisms, and seven segments become Category 4 after FAC is removed due to no other damage mechanisms being present.
9. These two segments become Category 5 after FAC is removed due to no other damage mechanisms being present.

1.5-23 Revision 0 9/26/2002

( NUCLEAR MANAGEMENT COMPANY TalC. INSERVICE INSPECTION EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 3.5 Number of Elements Selected for Inspection by Risk Category Excluding Impact of FAC High Risk Region Medium Risk Region Low Risk Region System(l) Category I Category 2 Category 3 Category 4 Category 5 Category 6 Category 7 Total Selected Total Selected Total Selected Total Selected Total Selected Total Selected Total Selected RPV 21 3 83 0 8 0 RWCU 84 9 1 0 MS 105 i1(2) 95 0 4 0 SLC 8 1 27 0 RCR 10 3 113 12 12 0 RCIC 12 2 28 3 12 0 13 0 RHR 31 8 67 7 10 1 269 0 99 0 CS 2 1 20 2 35 0 134 0 HPCI 8 2 27 3 33 4 90 0 FW 36 10 38 4(3) 4 2 CcW 18 0 CRD 10 0 31 0 FPEC 54 0 PCAC 47 0 Torus 19 0 Total 87 24 495 54 75 10 741 0 320 0 Notes

1. Systems are described in Table 3 1.
2. One of these eleven welds was selected for examination by both the FAC and RI-ISI Programs. Since FAC was the only damage mechanism identified for this weld, the FAC examination will be credited toward both programs.
3. Two of these four welds were selected for examination by both the FAC and RI-ISI Programs. Since FAC was the only damage mechanism identified for these welds, the FAC examinations will be credited toward both programs.

1.5-24 Revision 0 9/26/2002

(7 C C NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Table 3.6-1 Risk Impact Analysis Results Inspections CDF Impact(4) LERF lmpact(4) Sstem Consequence Failure Potential CategoryI CaCogu Rank DMs Rank jSection XI(2)J Rl-lSI()I Delta w/ POD w/o POD wl POD w/o POD RPV 4 High None Low 5 3 -2 9.002-11 9,00E-11 9.00E-11 9.00E-11 RPV 6 Medium None Low 4 0 -4 negligible negligible negligible negligible RPV 7 Low None Low 2 0 -2 negligible negligible negligible negligible RPV Total 9.00E-11 9.OOE-11 9.00E-11 9.OOE-11 RWCU 4 High None Low 10 9 -1 4.50E-11 4 50E-11 4.50E-11 4.502-11 RWCU 7 Low None Low 0 0 0 no change no change no change no change RWCU Total 4.50E-11 4.50E-11 4.50E-11 4.502-11 MS 4(1) High None(FAC) Low (High) 2 0 -2 9.00E-11 9.00E-11 9.00E-11 9.OOE-11 MS 4 High None Low 30 10 -20 9 OOE-10 9.002-10 9.00E-10 9.00E-10 MS 6 Medium None Low 21 0 -21 negligible negligible negligible negligible MS 7 Low None Low 0 0 0 no change no change no change no change MS Total 9.90E-10 9.90E-10 9.90E-10 9.90E-10 SLC 4 High None Low 0 1 1 -4.50E-1 1 -4.502 -4.50E-11 -4.50E-11 SLC 6 Medium None Low 0 0 0 no change no change no change no change SLC Total _ -4.50E-11 -4.50E-11 -4.50E-11 -4.50E-11 RCR 2 High CC Medium 10 3 -7 6 30E-09 6.30E-09 6,30E-09 6.30E-09 RCR 4 High None Low 27 12 -15 6.75E-10 6.75E-10 6.75E-10 6.75E-10 RCR 7 Low None Low 0 0 0 no change no change no change no change RCR Total III_6.98E-09 6.98E-09 6.98E-09 6.98E-09 1.5-25 Revision 0 9/26/2002

C C C INSERVICE INSPECTION NUCLEAR MANAGEMENT COMPANY EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 3.6-1 Risk Impact Analysis Results 41 LERF lmpact(4) Consequence Failure Potential Inspections CDF Impact ) System(l) Category Rank DMs Rank Section XI(2) RI-ISI(3) Delta w/ POD wlo POD w/ POD wlo POD High None Low 0 2 2 -9 00E-11 -9.00E-11 -9.00E-11 -9.00E-11 RCIC 4 Medium TT, (FAC) Medium (High) 1 1 0 -1.20E-11 no change -1.20E-12 no change RCIC 5 (3) TT Medium 0 2 2 -3.60E-11 -2.00E-11 -3.60E-12 -2.002-12 RCIC 5 Medium Medium None Low 1 0 -1 negligible negligible negligible negligible RCIC 6 Low None Low 0 0 0 no change no change no change no change RCIC 7

                                                               ....                                 -1.38E-10   -1.10E-10   -9.48E-11     -9.20E-11 RCIC Total TT                Medium               5             8        3  -1.03E-08   -2.70E-09   -1.03E-08     -2.70E-09 RHR         2        High Low               19             7      -12   5 40E-10    5.401-10    5.40E-10      5.40E-10 RHR         4        High       None TT                Medium               4             1       -3   6.00E-12    3.00E-11    6.00E-13      3 OOE-12 RHR         5      Medium None (FAC)          Low (High)             5             0       -5   negligible  negligible  negligible    negligible RHR       6 (3)    Medium Low               20             0      -20   negligible  negligible  negligible  . negligible RHR         6      Medium       None Low     None (FAC)          Low (High)             1             0       -1   negligible  negligible  negligible    negligible RHR       7 (5)

None Low 8 0 -8 negligible negligible negligible negligible RHR 7 Low

                                                                                                    -9.71E-09   -2.13E-09   -9.72E-09      -2.16E-09 RHR Total High        CC                Medium               2             1       -1   9 00E-10    9.00E-10    9 0OE-10      9.00E-10 CS         2 High       None                  Low               9             2       -7   3.15E-10    3.15E-10    3.15E-10      3.15E-10 CS         4 None (FAC)          Low (High)             0             0        0  no change   no change   no change     no change CS       6 (3)    Medium None                  Low               6             0       -6   negligible  negligible  negligible    negligible CS         6      Medium Low     None (FAC)          Low (High)             0             0        0  no change   no change   no change     no change CS       7 (5)

None Low 18 0 -18 negligible negligible negligible negligible CS 7 Low 1.22E-09 1.22E-09 1.22E-09 1.22E-09 CS Total 1.5-26 Revision 0 9/26/2002

INSERVICE INSPECTION NUCLEAR MANAGEMENT COMPANY EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 3.6-1 Risk Impact Analysis Results Inspections CDF lmpactý4 ) LERF Impact(4 l SystemW Category Consequence Failure Potential wlo POD Rank DMs Rank Section XI(2) Rl-ISl(3) Delta wI POD wlo POD w/ POD High TT Medium 5 2 -3 -5 40E-10 2.70E-09 -5.40E-10 2.70E-09 HPCI 2 High None Low 2 3 1 -4.50E-11 -4.50E-11 -4.50E-11 -4.50E-11 HPCI 4 TT Medium 7 4 -3 -3.OOE-11 3.00E-11 -3 00E-12 3.00E-12 HPCI 5 Medium Medium None Low 7 0 -7 negligible negligible negligible negligible HPCI 6 Low TT Medium 1 0 -1 negligible negligible negligible negligible HPCI 6

                                                                                                         -6.15E-10   2.69E-09    -5.88E-10     2.66E-09 HPCI Total High    TASCS, TT, (FAC)     Medium (High)       0               1        1    -1.62E-09   -9.00E-10   -1.62E-09    -9.00E-10 FW       2 (1)

High TASCS, (FAC) Medium (High) 4 1 -3 5.40E-10 2.70E-09 5.40E-10 2 70E-09 FW 2 (1) High TT, (FAC) Medium (High) 2 1 -1 -5.40E-10 9 00E-10 -5.40E-10 9.00E-10 FW 2 (1) TASCS, TT Medium 0 1 1 -1.62E-09 -9 002-10 -1 62E-09 -9.00E-10 FW 2 High High TASCS Medium 6 4 -2 -3.24E-09 1.80E-09 -3 24E-09 1.80E-09 FW 2 High TT Medium 0 0 0 no change no change no change no change FW 2 High CC Medium 2 2 0 no change no change no change no change FW 2 None (FAC) Low (High) 6 0 -6 2.70E-10 2.70E-10 2.70E-10 2.70E-10 FW 4 (1) High None Low 3 2 -1 4.50E-11 4.50E-11 4.502-11 4.50E-11 FW 4 High Medium TASCS, TT, (FAC) Medium (High) 0" 1 1 -1.80E-11 -1.00E-11 -1.80E-12 -1.00E-12 FW 5(3) Medium TASCS, (FAC) Medium (High) 0 0 0 no change no change no change no change FW 5 (3) Medium TASCS Medium 0 1 1 -1.80E-11 -1.00E-11 -1.80E-12 -1.00E-12 FW 5

                                                                                                         -6.20E-09    3.90E-09   -6.17E-09     3.91E-09 FW Total Low          None                  Low            1              0       -1     negligible  negligible  negligible   negligible CCW          7 negligible  negligible  negligible   negligible CCW Total None                  Low           10              0      -10     negligible  negligible  negligible   negligible CRD         6        Medium None                   Low          21              0      -21     negligible  negligible  negligible   negligible CRD         7          Low I negligible  negligible  negligible   negligible CRD Total           I 1.5-27                                                              Revision 0 9/26/2002

( ( NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 3.6-1 Risk Impact Analysis Results 4 CDF LERF Impact(4) System(W) Category Consequence Rank DMs Failure Potential Rank Section XI(2) Inspections RI-ISI(3 J Delta w/ POD lmpact( ) wlo POD w/ POD [ w/o POD FPEC 6 Medium None Low 0 0 0 no change no change no change no change FPEC Total no change no change no change no change PCAC 6 Medium None Low 4 0 -4 negligible negligible negligible negligible negligible negligible negligible negligible PCAC Total Torus 6 Medium None Low 1 0 -1 negligible negligible negligible negligible

                                                                                                                        ..... negligible    negligible  negligible   negligible Torus Total Grand Total                                                                                                                   -7.40E-09      1.36E-08   -7.30E-09     1.36E-08 Notes
1. Systems are described in Table 3.1.
2. Only those ASME Section Xl Code inspection locations that received a volumetric examination in addition to a surface examination were included in the count Inspection locations previously subjected to a surface examination only were not considered in accordance with Section 3.7.1 of EPRI TR-1 12657.

3 Risk Category 4 (1) inspection locations selected for examination by both the FAC and RI-ISI Programs are not included in the count since they do not represent additional examinations

4. Per Section 3.7.1 of EPRI TR-112657, the contribution of low risk categories 6 and 7 need not be considered in assessing the change in risk Hence, the word "negligible" is given in these cases in lieu of values for CDF and LERF Impact. In those cases where no inspections were being performed previously via Section XA, and none are planned for RI-ISI purposes, "no change" is listed instead of "negligible" NOTE: TABLE 4 was not part of the Risk-Informed ISI Program submittal and is intentionally excluded from this document.

1.5-28 Revision 0 9/26/2002

C C C NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 5-1 Inspection Location Selection Comparison Between 1986 ASME Section Xl Code and EPRI TR-112657 by Risk Region High Risk Region Medium Risk Region Low Risk Region Systm~l) Code2X12X2 Xl)2) EPRI TR-112657 Weld 1986 Section ) EPRI TR-112657 SYstem Category2) Weld 1986 Section Xl(2) EPRITR-112657 Weld 1986 Section Only RI-ISI IOther(3) Count Vol/Sur SurOnly RI-ISI JOther(3') Count VollSur Sur Only RI-ISI Other(3) Count Vol/Sur Sur 3 2 1 3 1 2 0 5 RPV B-F 3 2 88 5 24 0 13B-J 16 2 B-F 1 1 0 1 B-J 83 9 15 8 1 0 0 0 MS B-J 105 32 1 11(i) 99 21 21 0 B-F 1 0 1 0 13B-J 8 0 3 1 26 0 6 0 B-F 10 10 0 3 2 2 0 0 RCR B-J 111 25 5 12 12 0 3 0 B-J 14 0 5 0 C-F-2 40 1 0 5 11 1 0 0 B-F 1 1 0 0 2 2 0 0 RHR B-J 30 4 0 8 75 21 0 8 7 4 0 0 C-F-2 361 30 2 0 B-F 2 2 0 1 CS B-J 20 9 0 2 8 2 0 0 C-F-2 161 22 0 0 B-F 2 2 0 0 HPCI B-J 6 3 0 2 9 1 0 0 C-F-2 60 9 0 7 81 7 0 0 B-J 29 9 0 10 41 8 0 6(5) C-F-2 7 5 0 0 1 1 0 0 1.5-29 Revision 0 9/26/2002

C C NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 5-1 (cont'd) Inspection Location Selection Comparison Between 1986 ASME Section Xl Code and EPRI TR-112657 by Risk Region High Risk Regi!on Medium Risk Region Low Risk Region 12 2 Systm~l) Code CategoryV2) Weld 1986 Section X(XI ) EPRI TR-112657 Weld 1986 Section Xl(12X(

                                                                                                              ) EPRI TR-112657      Weld    1986 Section XI(2) EPRI TR-112657 Count    Vol/Sur Sur Only      RI-ISI   Other(3 ) Count    Vol/Sur Sur Only      RI-ISI  JOther()   Count   Vol/Sur Sur Only      RI-ISI jOther(3)

CCW C-F-2 18 1 0 0 C-F-1 31 28 0 0 C-F-2 10 3 0 0 FPEC C-F-2 54 0 0 0 PCAC C-F-2 47 4 0 0 Torus C-F-2 19 1 0 0 B-F 15 15 0 4 10 8 2 2 4 1 3 0 B-J 65 16 0 20 459 106 27 50 264 33 59 0 Total C-F-1 1 31 28 0 0 C-F-2 7 5 0 0 101 11 0 12 762 69 2 0 Notes

1. Systems are described in Table 3.1.
2. Since no examination selections had been made for the 4th interval ISI Program prior to the development of the RI-ISI Program, the 3rd Interval selections were used for comparison purposes. The Code of record for the 3rd Interval was the 1986 Edition of ASME Section Xl. The Code Categories listed in the table are therefore in accordance with the 1986 Edition of ASME Section Xl.
3. The column labeled "Other' is generally used to Identify augmented inspection program locations credited per Section 3.6.5 of EPRI TR-112657. The EPRI methodology allows augmented inspection program locations to be credited if the inspection locations selected strictly for RI-ISI purposes produce substantially less than a 10% sampling of the overall Class 1 weld population. As stated in Section 3.5 of this template, MNGP achieved a 9 2% sampling without relying on augmented inspection program locations beyond those selected by the RI-ISI process. The 'Other" column has been retained in this table solely for uniformity purposes with the other RI-ISI application template submittals.
4. One of these eleven welds was selected for examination by both the FAC and RI-ISI Programs. Since FAC was the only damage mechanism identified for this weld, the FAC examination will be credited toward both programs
5. Two of these six welds were selected for examination by both the FAC and RI-ISI Programs. Since FAC was the only damage mechanism identified for these welds, the FAC examinations will be credited toward both programs.

1.5-30 Revision 0 9/26/2002

C ( INSERVICE INSPECTION NUCLEAR MANAGEMENT COMPANY EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 5-2 Inspection Location Selection Comparison Between 1986 ASME Section XI Code and EPRI TR-112657 by Risk Category Failure Potential Code Weld 1986 Section XI(2) EPRI TR-112657 System() Risk Consequence Category Rank Rank DMs Rank Category(2) Count Vol/Sur ISur Only RI-ISI Other 3') B-F 5 3 2 1 High None Low RPV 4 Medium B-J 16 2 3 2 B-F 3 1 2 0 Medium None Low RPV 6 Low B-J 80 3 22 0 RPV 7 Low Low None Low B-J 8 2 2 0 B-F 1 1 0 1 Medium High None Low RWCU 4 9 15 8 B-J 83 RWCU 7 Low Low None Low B-J 1 0 0 0 None (FAC) Low (High) B-J 6 2 0 1(4) MS 4(1) Medium (High) High MS 4 Medium High None Low B-J 99 30 1 10 MS 6 Low Medium None Low B-J 95 21 18 0 MS 7 Low Low None Low B-J 4 0 3 0 SLC 4 Medium High None Low B-J 8 0 3 1 B-F 1 0 1 0 SLC 6 Low Medium None Low B-J 26 0 6 0 RCR 2 High High CC Medium B-F 10 10 0 3 B-F 2 2 0 0 RCR 4 Medium High None Low B-J 111 25 5 12 7 Low Low None Low B-J 12 0 3 0 RCR 1.5-31 Revision 0 9/26/2002

(I C C NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 5-2 (cont'd) Inspection Location Selection Comparison Between 1986 ASME Section XI Code and EPRI TR-112657 by Risk Category Failure Potential Code Weld 1986 Section X112) EPRI TR-112657 System(" Category J Risk Rank Consequence Rank DMs Rank Category2) Count Vol/Sur Sur Only RI-ISI Other(3 ) 4 Medium High None Low C-F-2 12 0 0 2 RCIC 5 (3) Medium (High) Medium TT, (FAC) Medium (High) C-F-2 8 1 0 1 RCIC 5 Medium Medium TT Medium C-F-2 20 0 0 2 RCIC B-J 5 0 2 0 RCIC 6 Low Medium None Low C-F-2 7 1 0 0 ___ B-J 9 0 3 0 RCIC 7 Low Low None Low C-F-2 4 0 0 0 ___ B-F 1 1 0 0 RHR 2 High High TT Medium B-J 30 4 0 8 ___ B-F 2 2 0 0 RHR 4 Medium High None Low B-J 65 17 0 7 ___ RHR 5 Medium Medium TT Medium B-J 10 4 0 1 RHR 6 (3) Low (High) Medium None (FAC) Low (High) C-F-2 42 5 0 0 RHR 6 Low Medium None Low C-F-2 227 20 0 0 7 (5) Low (Medium) Low None (FAC) Low (High) C-F-2 10 1 0 0 RHR B-J 7 4 0 0 RHR 7 Low Low None Low C-F-2 82 4 2 0 CS 2 High High CC Medium B-F 2 2 0 1 CS 4 Medium High None Low B-J 20 9 0 2 6 (3) Low (High) Medium None (FAC) Low (High) C-F-2 4 0 0 0 CS B-J 8 2 0 0 CS 6 Low Medium None Low C-F-2 23 4 0 0 7(5) Low (Medium) Low None(FAC) Low (High) C-F-2 13 0 0 0 CS CS 7 Low Low None Low C-F-2 121 18 0 0 1.5-32 Revision 0 9/26/2002

(7 ( ( NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 5-2 (cont'd) Inspection Location Selection Comparison Between 1986 ASME Section XI Code and EPRI TR-112657 by Risk Category Risk Consequence Failure Potential Code Weld 1986 Section XI(2) EPRI TR-112657 Category Rank Rank DMs Rank Categoryi2 ) Count Vol/Sur Sur Only RI-ISI Otheri3 ) B-F 2 2 0 0 HPCI 2 High High TT Medium B-J 6 3 0 2 HPCI 4 Medium High None Low C-F-2 27 2 0 3 HPCI 5 Medium Medium "T Medium C-F-2 33 7 0 4 HPCI 6 Low Medium None Low C-F-2 81 7 0 0 HPCI 6 Low Low TT Medium B-J 9 1 0 0 FW 2 (1) High (High) High TASCS, TT, (FAC) Medium (High) B-J 1 0 0 1 B-J 1 1 0 1 FW 2 (1) High (High) High TASCS, (FAC) Medium (High) C-F-2 4 3 0 0 B-J 4 1 0 1 FW 2 (1) High (High) High TT, (FAC) Medium (High) CF2 1 0 B-J 2 0 0 1 FW 2 High High TASCS, TT Medium C-F-2 1 0 0 0 B-J 12 5 0 4 High TASCS Medium FW 2 High C-F-2 1 1 0 0 FW 2 High High TT Medium B-J 1 0 0 0 FW 2 High High CC Medium B-J 8 2 0 2 B-J 18 5 0 2(5) FW 4 (1) Medium (High) High None (FAC) Low (High) CF2 1 1 0 0 FW 4 Medium High None Low B-J 19 3 0 2 FW 5 (3) Medium (High) Medium TASCS, TT, (FAC) Medium (High) B-J 1 0 0 1 FW 5 (3) Medium (High) Medium TASCS, (FAC) Medium (High) B-J 1 0 0 0 FW 5 Medium Medium TASCS Medium B-J 2 0 0 1 1.5-33 Revision 0 9/26/2002

C ( ( NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION EXAMINATION PLAN MONTICELLO 4th INTERVAL Table 5-2 (cont'd) Inspection Location Selection Comparison Between 1986 ASME Section XI Code and EPRI TR-112657 by Risk Category Risk Consequence Failure Potential Code Weld 1986 Section XI(2) EPRI TR-112657 SystemCategory Rank Rank DMs Rank Category(2) Count Vol/Sur Sur Only RI-ISI Otheri') CCW 7 Low Low None Low C-F-2 18 1 0 0 CRD 6 Low Medium None Low C-F-1 10 10 0 0 C-F-1 21 18 0 0 Low None Low CRD 7 Low C-F-2 10 3 0 0 FPEC 6 Low Medium None Low C-F-2 54 0 0 0 PCAC 6 Low Medium None Low C-F-2 47 4 0 0 Torus 6 Low Medium None Low C-F-2 19 1 0 0 Notes

1. Systems are described in Table 3.1.
2. Since no examination selections had been made for the 4th interval ISI Program prior to the development of the RI-ISI Program, the 3rd Interval selections were used for comparison purposes. The Code of record for the 3rd Interval was the 1986 Edition of ASME Section XI. The Code Categories listed in the table are therefore in accordance with the 1986 Edition of ASME Section XI.
3. The column labeled 'Other' is generally used to identify augmented inspection program locations credited per Section 3 6.5 of EPRI TR-112657. The EPRI methodology allows augmented inspection program locations to be credited if the inspection locations selected strictly for RI-ISI purposes produce substantially less than a 10% sampling of the overall Class 1 weld population. As stated in Section 3.5 of this template, MNGP achieved a 9.2% sampling without relying on augmented inspection program locations beyond those selected by the RI-ISI process. The 'Other" column has been retained in this table solely for uniformity purposes with the other RI-ISI application template submittals
4. This one weld was selected for examination by both the FAC and RI-ISI Programs. Since FAC was the only damage mechanism identified for this weld, the FAC examination will be credited toward both programs.
5. These two welds were selected for examination by both the FAC and RI-ISI Programs. Since FAC was the only damage mechanism identified for these welds, the FAC examinations will be credited toward both programs.

1.5-34 Revision 0 9/26/2002

                               -4 (Intentionally Blank Page)
                          *l 4

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Monticello Unit 1 - ISI Relief Request No. 2 (Rev. 1) Reactor Vessel Circumferential Shell Welds (note - revised text is italicized) System: Reactor Vessel Class: 1 Category: B-A Item: B1.11 Reactor Vessel Circumferential Welds: VCBB-4, VCBB-3 and VCBA-2 (errantlynamed VCBB-2 on Rev.O) Examination Requirements: A September 8, 1992 revision to 10 CFR 50.55a(g)(6)(ii)(A) contains an augmented examination requirement to perform a one time volumetric examination of essentially 100% (>90%) of all circumferential and axial reactor pressure vessel (RPV) shell assembly welds. This rule revokes previously granted relief requests regarding the extent of volumetric examination on circumferential (B1.11) and longitudinal (B1.12) reactor pressure shell vessel welds. 10 CFR 50.55a(g)(6)(ii)(A) requires the augmented examinations to be performed as specified in the ASME Code Section Xl (1989 Edition). Monticello requests relief from the inspection of Reactor Vessel Circumferential (B-A) Welds Item B13.11 for the remaining term of the current license for Monticello (during the 4th ISI Interval). Basis For Relief: Monticello reactor vessel circumferential welds were not inspected to the essentially 100% volumetric requirements during the 1st and 2nd ISI inspection intervals. A relief request (RR-01) was granted on the basis of inadequate accessibility and unnecessary radiation exposure during the first two 10 year inspection intervals. Upon submittal of the 3rd Interval ISI Inspection Plan, Rev. 1 (July 29, 1993), continuance for the 1st and 2nd interval relief request (RR-01) was requested. That relief request (RR-01) was denied on the basis of 10 CFR 50.55a(g)(6)(ii)(A), effective September 8, 1992, requiring augmented examination for reactor vessel shell assembly welds. On November 10, 1998, the NRC issued Generic Letter 98-05 "BOILING WATER REACTOR LICENSEES USE OF BWRVIP-05 REPORT TO REQUEST RELIEF FROM AUGMENTED EXAMINATION REQUIREMENTS ON REACTOR PRESSURE VESSEL CIRCUMFERENTIAL WELDS." This generic letter permits licensees to request permanent relief from the inservice inspection requirements of 10 CFR 50.55a(g)(6) for the volumetric examination of 1.5-35 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN circumferential reactor pressure vessel welds if it can be demonstrated that: (1) at the expiration of the license, the circumferential welds will continue to satisfy the limiting conditional failure probability for circumferential welds in the staffs July 28, 1998, safety evaluation, and (2) operator training and procedures limit the frequency of cold over-pressure events to the amount specified in the staffs July 28, 1998, safety evaluation (Reference 1). The following is our evaluation of these two criteria. (1) Limiting Conditional Failure Probability The values established in Attachment 1 were calculated in accordance with the guidelines of Regulatory Guide 1.99, Revision 2. The chemistry factor for the limiting circumferential weld recorded in Attachment 1 is Monticello (manufactured by Chicago Bridge & Iron (CB&I)) plant specific (Reference 3). This value is slightly higher than the USNRC's value which utilizes Table 1 of Regulatory Guide 1.99, Revision 2. As a result, the Monticello mean RTNDT value of 46.90 F is slightly higher than the USNRC's limiting plant specific analysis mean RTNDT value of 44.50 F listed in Reference 5 for the CB&I reference case. A recent safety evaluation (Reference 6) identified a Brunswick Unit 1 (manufactured by CB&I) mean RTNDT value of 46.50 F which also exceeded the corresponding CB&I mean RTNDT value specified in Reference 5. To validate the acceptability of the failure probability in this case, the staff performed calculations using the Brunswick Unit 1 value of 46.50 F. The calculations showed only a small increase in failure probability (6 x 10"'/yr for Brunswick vs. 2 x 10"7 /yr for the reference case). Since the Monticello mean RTNDT is only slightly higher than the Brunswick Unit 1 mean RTNDT (46.90 F vs. 46.50 F), it is expected that only a small increase in failure probability will result for Monticello. The overall limiting conditional failure probability for circumferential welds across the BWR fleet listed in Reference 5 is 8.17 x 105/yr (calculated by the staff for the Babcock & Wilcox (B&W) reference case). This limiting conditional failure probability is based on reactor vessel data that produced a calculated mean RTNDT of 99.80 F (Reference 5). Since the Monticello mean RTNDT (46.90 F) is less than 99.80 F, it follows that the Monticello conditional failure probability will also be less than the limiting failure probability listed in Reference 5. provides a plot of mean RTNDT against failure probability using results documented in References 5 and 6. Based on this trend, the conditional failure probability for Monticello is estimated to be less than 1 x I 0 4 /yr. In conclusion, the above discussion demonstrates that the circumferential welds of the Monticello RPV will continue to satisfy the limiting conditional failure probability listed in Reference 5. 1.5-36 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN (2) Traininq and Procedures The cold pressurization events considered in Reference 1 (i.e., inadvertent injections, condensate injection, CRD injection, loss of RWCU, actual event) were reviewed to identify the critical operator actions that were assumed to occur to mitigate these events. Procedures and training were reviewed to ensure that those critical operator actions would occur with a high degree of certainty so that the low temperature over pressurization (LTOP) event frequency is maintained less than the amount specified in Reference 1 (i.e., 1 x 10 3 /yr). System design was also considered in this review to assure that the associated systems function as described in Reference 1. Results of our review indicate that in general, procedures, training and system design ensure that the evaluations contained in Reference 1 are valid for Monticello. Following are the detailed results of our review:

1. Inadvertent Injections.

The evaluation provided in Reference 1 (paragraph 2.6.1.1) is applicable to Monticello with one exception. The evaluation considered the availability of automatic trips of high pressure injection systems on high water level. Review of Monticello procedures identified that during performance of reactor feedwater pump (RFP) testing during cold shutdown, the high reactor water level trip is bypassed. Measures are taken procedurally to close valves that prevent water from getting to the vessel. Monticello enhanced OperationsProcedureB.06.05-05 to further assure the isolation of flow to the vessel.

2. Condensate Injection.

The evaluation provided in Reference 1, (paragraph 2.6.1.2) is applicable to Monticello. Operating procedures provide precautions which indicate that reactor water level is to be closely monitored when starting a condensate pump. This aids in assuring that an overfill event which could lead to an LTOP event does not occur. In order to assure that operations personnel understand that an overfill event has the potential to lead to an LTOP event, Monticello enhanced OperationsProcedureB.06.05-05 to identify an LTOP event as a potentialconsequence of an overfill event. Monticello also has high reactor water level and high reactor pressure alarms in the control room that warn operators when high level/pressure limitations are being exceeded which provides further assurance that an LTOP event will not occur due to condensate injection. 1.5-37 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN

3. CRD Injection.

The evaluation provided in Reference 1, (paragraph 2.6.1.3), is applicable to Monticello. The evaluation notes that the risk of cold over pressurization due to CRD injection may be higher if a loss of station power were to occur during reactor vessel pressure testing. Monticello revised vessel pressure testing procedures 0255-20-11A-1 and 0255-20-IIC-1 to provide precautionsthat ensure properresponse to a loss of station power (i.e., RWCU and Recirculationpumps are restored along with restorationof CRD).

4. Loss of Reactor Water Cleanup (RWCU)

The evaluation provided in Reference 1, (paragraph 2.6.1.4), is applicable to Monticello. Monticello has procedures in place to provide guidance for recovery measures following a scram. In the event that a scram occurs that results in a RWCU isolation, procedural guidance is provided which consists of restoring the RWCU system as soon as the cause of the isolation is identified and resetting the reactor scram as soon as possible in order to limit cold water injection into the vessel. Also, procedural guidance is provided for dealing with recirculation loop or vessel stratification so that an excessive amount of cold water is not distributed throughout the reactor vessel during the restart of a tripped recirculation pump(s). Monticello added a precautionin the OperationsProcedure C.4-A for RWCU restorationin orderto further inform the operations personnel of the potentialof an LTOP event occurring during SCRAM recovery.

5. Actual Event.

General Electric issued RICSIL No. 049, Inadvertent Vessel Pressurization, in response to the actual event discussed in Reference 1, (paragraph 2.6.1.5). Our assessment of the RICSIL indicated that the likelihood of a similar event occurring at Monticello is very low. Procedures require that the reactor vessel remain vented at all times during cold shutdown except as permitted by approved procedures. The reactor vessel pressure test procedure allows the vent valves to be closed during cold shutdown. During the pressure test, strict procedural guidance is provided for administratively monitoring vessel pressure and temperature while controlling CRD injection and RWCU reject in order to assure a smooth, controlled method of increasing or decreasing pressure while vessel temperature is being maintained above the required P-T limits. If reactor pressure exceeds the specified limits, during the test, the 1.5-38 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN CRD pump is immediately tripped. In addition to the above mentioned procedural guidance, a requirement is included to perform an "Infrequent Test or Evolution Briefing" with all essential personnel. This briefing details the anticipated testing evolution with special emphasis on conservative decision making, plant safety awareness, lessons learned from similar in-house or industry operating experiences, the importance of open communications, and the process in which the test would be aborted if plant systems responded in an adverse manner. The above evaluations show that system design and procedures, including the proposed enhancements, minimize the probability of LTOP events at Monticello. Our review of training indicated that licensed operator training addresses LTOP events. Initial licensed operator simulator training, for example, includes performance of surveillance tests which ensure pressure-temperature curve compliance during plant heatup and cooldown. Additionally Monticello created Request for Training (RFT) 20012810 to provide trainingto operationspersonnel on the specific scenariosand events evaluatedin Reference 1, (paragraph 2.6.1.1-5), including the features of system design and proceduralcontrols that prevent such events at Monticello.

== Conclusion:==

The Monticello mean RTNDT value of 46.90 F is less than the mean RTNDT value of 99.80 F corresponding to the B&W limiting reference case. Since the Monticello RTNDT is much less than the limiting RTNDT, the Monticello conditional failure probability will be well below the limiting conditional failure probability of 8.17 x 10 5/yr calculated by the Staff for the corresponding B&W reference case. A thorough review of existing procedures, operator training and system design identified improvement opportunities that Monticello has committed to implement. With the recommended enhancements to existing procedures and operator training and with the current design capabilities of the associated systems, the LTOP event frequency is limited to the amount specified in Reference 1, (1 x 10 3/yr). Based on these evaluations the conditions for requesting relief from the inservice inspection requirements of 10 CFR 50.55a(g)(6)(ii)(A), for the volumetric examination of circumferential reactor pressure vessel welds in accordance with ASME Code Section Xl (1995 Edition with 1996 Addenda), Table IWB-2500-1, Examination Category B-A, Item B1.11, Circumferential Welds, are satisfied. Relief is hereby requested in accordance with 10 CFR 50.55a(a)(3)(I). The proposed alternative examinations provide an adequate level of quality and safety. 1.5-39 Revision 0 9/2612002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Alternate Examination: As an alternative to the inspection requirements of ASME Code Section XI (1995 Edition with the 1996 Addenda) Category B-A, Item B 1.11,100% volume requirement, we propose that the following examination methodology be used. The alternative examination requested maintains essentially 100% (>90%) examination of reactor vessel longitudinal (axial) shell welds, Code Category B A, Item B.1.12. Two to three percent of the circumferential RPV shell welds Code Category B-A, Item B1.11, Code Category B-A, Item B1.11 will be inspected at the intersections of the axial and circumferential welds. This is consistent with the alternate inspection requirements as specified in GL 98-05. This alternative is capable of detecting weld degradation sufficient to insure the integrity of the reactor pressure vessel boundary, and is the same as that described in the NRC SER (Reference 1). Time Period Relief is Requested For: Relief is presently approved by the NRC for the remaining term of the current Monticello license during the 4th 10 year interval. (Reference 7)

References:

1. NRC Safety Evaluation Report of Topical Report by the Boiling Water Reactor Vessel and Internals Project: "BWR Reactor Pressure Vessel Shell Weld Inspection Recommendations, BWRVIP-5," (TAC No. M93925), July 28, 1998.
2. General Electric Report SASR 87-61, DRF137-0010, "Revision of Pressure Temperature Curves to Reflect Improved Beltline Weld Toughness Estimate for the Monticello Nuclear Generating Plant - Rev. 1," December 1987.
3. NSP Letter to NRC, Submittal of Report on Reactor Pressure Vessel Specimen Test, December 21, 1998.
4. General Electric Report GENE-B13-01796-1, "Reactor Vessel Fracture Toughness Engineering Evaluation - Task 5.4," March 13, 1996 1.5-40 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN

5. NRC Safety Evaluation Report of Topical Report by the Boiling Water Reactor Vessel and Internals Project: "Supplement to Final Safety Evaluation of the BWR Vessel and Internals Project BWRVIP-5 Report (TAC No.

MA3395)," March 7, 2000.

6. Brunswick Steam Electric Plant, Unit No's 1 and 2 - Safety Evaluation for Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i) for Reactor Vessel Circumferential Shell Weld Examinations (TAC No's MA9299 and MA9300).
7. NRC Letter, "Monticello Nuclear Generating Plant - Approval of Relief Request Number 12 of the Third 10 Year Inservice Inspection Program,"

(TAC No. MB0261), July 27, 2001. Status: Approved July 27, 2001 for continued use in 4th Interval (...'remainderof current 40-year operatinglicense for the unit), (See Reference #7 above). 1.5-41 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN ATTACHMENT I Comparison of Monticello RPV Parameters to NRC Limited Plant Specific Parameters Parameter Monticello Parameters USNRC Limiting Plant Description for the Bounding Specific Analyses Circumferential Weld Parameters SER Table 2.6-4 (Reference 5) CB&I B&W Cu, wt% 0.10 (Reference 2) 0.10 0.31 Ni, wt% 0.99 (Reference 2) 0.99 0.59 CF (Chemistry factor) "138.5 (Reference 3) 134.9 196.7 EOL ID 0.51 (Reference 4) 0.51 0.095 Fluence, x 10' 9 n/cm2 ARTNDT, °F 112.5 109.5 79.8 RTNDT (u) °F -65.6 (Reference 2) -65 20 Mean RTNDT, OF 46.9 44.5 99.8 Conditional Failure <1x105 2x10-7 8.17x10-5 Probability P(FIE) Attachment 2 1.5-42 Revision 0 9/26/2002

( ( ( oc OC) 4, 0> 1-mJ ATTACHMENT - 2 0>*Z Circ. Weld Failure Probability vs Mean RTNDT Trend Using Limiting CE, CB&I, B&W and Brunswick Data 1.00E+00 _) zm mm 1.00E-01 Legend: uz I = CB&l Limiting Analysis (Ref. 5) 0 W 2 = Brunswick Limiting Analysis (Ref. 6) 0 1.OOE-02 3 = CE ( Im hnAnaLyss4lef-5) 4 = CE (CEOG) Limiting Analysis (Ref. 5) 5 = B&W Limiting Analysis (Ref. 5) z ai. 2 1.00E-03

  .cn    I.1 C4 U.

U. _= 1.00E-04 4 0. 0I U

        *0 0m U

1.00E-05 S~NOTE: Data based on results of NRC

                                                                             --TedLne                                Staff analysis.

1.O0E-06

2. C',

0-d" Monticello Failure Probability vs Mean RTNoT Projected Intersection Zz CD 1.00E-07  : ": ', :  : I { I I I I 1 I t I I  ! I I  ! I l I l I I I !  ! I I ""0 CD 40 46.9 50 60 70 80 90 100 11

0) Fn*

0 o3 Mean RTNDT (F) 0 0 z

4 (Intentionally Blank Page) Jj 9 1

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Monticello Unit I - Relief Request No. 3 (Rev. 0) Appendix VIII Supplement 4 SystemlComponent(s) For Which Relief Request Will Be Used Code Class: Class I

Reference:

ASME, Section Xl, Tables IWB-2500-1 (1995 Edition, 1996 Addenda) Examination Category: B-A Item Number: B1.10, B1.20

Description:

Alternative Requirement to Appendix VIII, Supplement 4 "Qualification Requirements for the Clad/Base Metal Interface of Reactor Vessel" Component Numbers: All Code and 10 CFR 50.55a Requirements: 10 CFR 50.55a(b)(2) was amended on September 22, 1999 to reference Section XI of the ASME Code through the 1995 Edition with the 1996 Addenda (64 FR 51370). This amendment provides an implementation schedule for the supplements to Appendix VIII of Section XI to the 1995 Edition with the 1996 Addenda. Supplement 4 to Appendix VIII, Subparagraph 3.2(c) imposes three statistical parameters for depth sizing. The first parameter, 3.2(c)(1), pertains to the slope of a linear regression line. The linear regression line is the difference between measured versus true value plotted along a through-wall thickness. The second parameter, 3.2(c)(2), pertains to the mean deviation of flaw depth. The third parameter, 3.2(c)(3), pertains to a correlation coefficient. The Final Rule was amended by Federal Register Notice (66FR16391) dated March 26, 2001. This amendment specified the use of a flaw length sizing tolerance criterion of 0.75 inch Root Mean Square (RMS) for reactor vessel qualification to be used in conjunction with the 0.15 inch RMS for depth sizing specified in the Rule in lieu of paragraphs 3.2(a) and 3.2(b). In the Notice, there was no reference to the elimination of the statistical parameters of Paragraph 3.2(c), which were intended for use with paragraphs 3.2(a) and 3.2(b) of Appendix VIII, Supplement 4. There was no amendment statement included to reflect the use of the RMS error calculations for depth and length sizing in lieu of Paragraph 3.2(c). 1.5-44 Revision 0 9/26/2002 a

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Basis for Altemative Examination: This relief request was developed using the Electric Power Research Institute (EPRI) Performance Demonstration Initiative (PDI) ASME Section Xl, Appendix VIII Implementation Guideline. It is modeled after the sample request for relief associated with the Supplement 4 published discrepancies: Appendix D, "Sample Request for Relief - Alternative Length Sizing Criteria (Revised)." (Reference 5) The U.S. nuclear utilities created PDI to implement demonstration requirements contained in Appendix VIII. PDI developed a performance demonstration program for qualifying UT techniques. PDI does not use paragraph 3.2(c) for sizing qualifications. The solution for resolving the differences between the PDI program and the Code was for PDI to participate in the development of a Code case that reflected PDI's program. The Code case was presented to ASME for discussion and consensus building. NRC representatives participated in this process. ASME approved the Code Case and published it as Code Case N-622, "Ultrasonic Examination of RPV and Piping, Bolts and Studs, Section XI, Division 1." (Reference 6) The NRC first approved the use of Code Case N-622 for Florida Power and Light Company's St. Lucie Plant Unit 2 (TAC No. MA5041). (Reference 7) Operating in parallel with the actions of PDI, the Staff incorporated most of Code Case N-622 criteria in the Rule published in the Federal Register, 64 FR 51370 dated September 22, 1999. This amendment requires the implementation of the ASME Code Section Xl, Appendix VIII, Supplement 4, 1995 Edition with the 1996 Addenda. The required implementation date for Supplement 4 was November 22, 2000. Appendix IVto Code Case N-622 contains the proposed alternative sizing criteria which has been authorized by the Staff. However, the sizing parameters printed in the published Rule differed from the sizing parameters implemented by the PDI Program and Code Case N-622. On January 12, 2000, NRC Staff, representatives from the EPRI Nondestructive Examination Center, and representatives from PDI participated in a conference call. The discussion during the conference call included the differences between Supplement 4, "Qualification Requirements for the Clad/Base Metal Interface of Reactor Vessel," to Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems," Paragraph 10 CFR 50.55a(b)(2)(xv)(C)(1) in the rule (Federal Register, 64 FR 51370), and the implementation of Supplement 4 by the PDI Program. (Reference 8) 1.5-45 Revision 0 9126/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN In a public meeting on October 11, 2000 at NRC offices in White Flint, MD, the PDI identified the discrepancy between the PDI Program and statistical parameters required by Subparagraph 3.2(c). The Staff agreed that the inclusion of the statistical parameters of Paragraph 3.2(c) of Supplement 4 to Appendix VIII was an oversight. The NRC agreed that Paragraph 10 CFR 50.55a(b)(2)(xv)(C)(1) should have excluded Subparagraph 3.2(c) as a requirement. (Reference 9) In Subparagraph 3.2(c), the linear regression line is the difference between measured versus true value plotted along a through-wall thickness. For Supplement 4 performance demonstrations, a linear regression line of the data is not applicable because the performance demonstrations are performed on test specimens with flaws located in the inner 15% through-wall. The difference between measured versus true value produce a tight grouping of results that resemble a shotgun pattern. The slope of a regression line from such data is extremely sensitive to small variations, thus making the parameter of Subparagraph 3.2(c)(1) a poor and inappropriate acceptance criterion. The value used in the 3.2(c)(2) is too lax with respect to evaluating flaw depths within the inner 15% of wall thickness. Therefore, Monticello proposes to use the more appropriate criterion of 0.15 inch RMS of 10 CFR 50.55a(b)(2)(xv)(C)(1), that modifies Subparagraph 3.2(a) as the acceptance criteria. Subparagraph 3.2(c)(3) pertains to a correlation coefficient. This value of correlation coefficient is inappropriate for this application since it is based on the linear regression from Subparagraph 3.2(c)(1). The NRC Staff previously approved MNGP use of this Alternative to the Code and 10 CFR 50.55a on August 22, 2001 (TAC No. MB1833) for use during the 3rd ISI Interval. (Reference 10) Alternative Examination: Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested to use the RMS Error calculations in lieu of the statistical parameters of Subparagraph 3.2(c) in Supplement 4 of the 1995 Edition 1996 Addenda of ASME Section XI Appendix VIII. As discussed above and demonstrated by the PDI, this will provide an acceptable level of quality and safety. 1.5-46 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Implementation Schedule: This alternative is requested for continued use for the 4th Ten-Year Interval of the Inservice Inspection Program for Monticello.

References:

1. ASME Boiler and Pressure Vessel Code, Section XI, 1995 Edition with 1996 Addenda
2. Federal Register, Rules and Regulations, September 22, 1999 (64 FR 51370)
3. Federal Register Notice, Industry Codes and Standards, Amended Requirements, March 26, 2001 (66 FR 16391)
4. Federal Register, Rules and Regulations, September 26, 2002 (67 FR 60520)
5. Performance Demonstration Initiative (PDI), "Guideline for Implementation of Appendix VIII and 10CFR50.55a," Volume One, Programmatic Implementation, Rev. 2, Appendix D, October 14, 2000
6. ASME Section Xl Nuclear Code Case N-622, "Ultrasonic Examination of RPV and Piping, Bolts, and Studs"
7. NRC Staff letter to Mr. T. F. Plunkett, Florida Power and Light Company, September 23,1999.
8. Meeting Summary, Teleconference between NRC and representatives from PDI, D.G. Naujock, Metallurgist, NDE & Metallurgy Section, to Edmund J. Sullivan, Chief NDE & Metallurgy Section, Chemical Engineering Branch, Division of Engineering, U.S. NRC, March 6, 2000.
9. NRC Memo, "Summary of Public Meeting Held on October 11, 2000, with PDI Representatives," November 13, 2000
10. NRC Letter to Nuclear Management Company, "MNGP - Evaluation of Relief Request No. 13 for the Third 10-Year Interval Inservice Inspection Program," (TAC No. MB1833), August 22, 2001 Status:

Previously approved for 3rd Interval, (See Reference #10 above). Not yet approved for 4th Interval. Requested for continued use during 4th Interval. 1.5-47 Revision 0 9/26/2002

4 v, (Intentionally Blank Page) 14

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Monticello Unit I - IS! Relief Request No. 4 (Rev. 0) Reactor Vessel Stabilizer Brackets System: Reactor Vessel Class: 1 Category: B-K Item: B10.10 Code Examination Requirements (ASME Section XI, 1995 Edition with 1996 Addenda): Perform surface examination on 100% of the vessel stabilizer bracket to vessel integral attachment welds. Basis for Relief: The vessel stabilizer brackets are surrounded by mirror insulation secured with cable hangers and buckles, ventilation ductwork and electrical installations. The stabilizer brackets do not provide support during normal operation. The brackets stabilize the vessel against local and seismic loads. Alternative Examination: Pursuant to 10 CFR 50.55a(a)(3)(i), Monticello proposes to perform a surface examination on the stabilizer brackets if local (jet reaction forces) or seismic loads are experienced. This proposed alternative to the requirements of Table IWB-2500-1, Category B-K, Item B10.10 will provide an acceptable level of quality and safety. Status: This Alternative to the Code was previously approved for 2nd and 3rd Intervals:

   "* NRC Letter, "Monticello - Second Ten-Year Inservice Inspection (ISI)

Program," (TAC No. 46510), November 29, 1990, Relief Request No. 51

   "* NRC Letter, "Evaluation of the Third 10-Year Interval Inservice Inspection Program Plan and Associated Requests for Relief for Monticello,"

(TAC No. M82545), October 18, 1994, Relief Request No. 2 Not yet approved for 4th interval. Requested for continued use during 4th interval. 1.5-48 Revision 0 9/26/2002

7Z

       *At W e.

(Intentionally Blank Page) q

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Monticello Unit I - ISI Relief Request No. 5 (Rev. 0) Leakage at Bolted Control Rod Drive (CRD) Housing Connections SYSTEM: Bolted CRD Housing Joint Class: 1 Category: B-P Item: B15.10 Code Examination Requirements: IWA-5250(a)(2): If leakage occurs at a bolted connection on other than a gaseous system, one of the bolts shall be removed, VT-3 examined, and evaluated in accordance with IWA-31 00. Basis for Relief: 10 CFR Part 50, Section 50.55a(a)(3), which states, (in part):

      "Proposedalternativesto the requirements of paragraphs (c), (d), (e), (f, (g), and (h) of this section or portions thereof may be used when...

(ii) Compliance with the specified requirementsof this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety." The CRD (Control Rod Drive) housings are flanged connections beneath the reactor vessel that are used to secure the 121 CRD mechanisms in position below the vessel. Each of the 121 CRD to CRD housing bolted joints utilizes eight bolts, washers, and nuts to hold the CRD mechanism in position. The joint also utilizes three hollow metal O-rings to provide a watertight seal capable of withstanding full reactor pressure at normal operating temperatures. The CRD housing joints are VT-2 examined as part of the periodic Reactor Pressure Vessel Leakage and Hydrostatic pressure tests. These tests are conducted with the vessel temperature much less than the design operating temperature. For a typical test, the vessel temperature would be <2120 F, as compared to a normal operating temperature of about 5400 F. It is not unusual for these bolted joints to leak slightly during periodic reactor vessel pressure tests conducted at test temperatures below normal operating temperature. 1.5-49 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN This is a condition identified in the original design of the connection by the Architect/Engineer, General Electric (GE). GE developed guidance to permit evaluation of a leaking CRD housing bolted connection over a period of time, while at test pressure, to determine whether the leak will stop once the vessel heats up to normal operating pressure. This leakage evaluation criteria is incorporated into the VT-2 tests for these joints. Compliance with Code Requirement IWA-5250(a)(2) represents a hardship (burden) in the case of the CRD housing bolted joints because:

1) Examining the bolting would involve the accumulation of considerable personnel radiation exposure, since the work must be performed in a relatively high dose rate area inside the drywell, immediately below the reactor vessel. Typical shutdown dose rates in the vicinity of the bolting flanges would be on the order of 50 to 100 mr/hr.
2) Since the reactor pressure vessel test is critical path item, the additional time needed to depressurize the vessel, remove the bolting, perform the exam, and then re-pressurize the vessel to retest the joint would delay plant startup from an outage by an equivalent amount of time. The cost of such delays is significant, since it is estimated that the cost of extending the duration of an outage is $379,000 per day (including replacement power costs)(this is estimated cost submitted in 1993 (see TAC No M82545 referenced in "Status" section)

Compliance with Code requirement IWA-5250(a)(2) would not result in a compensating increase in quality or safety because:

1) CRD Housing joint leakage during (relatively) low temperature testing is not unexpected due to the design of the bolted joint. This
             -joint is unusual in that it has hollow metal o-rings that require the CRD housing bolts to be tightened within a specific torque range in order to function properly at normal operating temperature. Thus, the bolts cannot simply be tightened to stop leakage as might be done for a conventional gasketed joint. As noted previously, GE developed guidance to evaluate any CRD housing leakage to determine if the leakage will persist at normal operating temperature/pressure and should therefore be corrected.

1.5-50 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN

2) Leakage that is found to be acceptable per the guidance is not considered adverse to quality or safety and need not be corrected prior to startup. This type of analysis is consistent with Section XI.
3) Code paragraph IWB-3142 allows analysis of the leakage for acceptability. Performance of the VT-3 bolting examination does not represent a corrective action for the joint leakage and will not reduce the likelihood of joint leakage upon retest. Therefore, the VT-3 bolting examination does not contribute to increased quality or safety.
4) The bolts in the CRD housing connection are periodically examined when the joint is disassembled, per Table IWB-2500-1, Item B7.80 (1995 Edition with no Addenda per 10CFR50.55A Paragraph (b)(2)(xxi)(B)) and Procedure 9309, "Changeout Selected CRD's - Maintenance" and Commitment No. M92076A.

Four of the eight bolts on each housing joint were replaced with new bolts in 1991 under Work Control Record (WCR) 91-01909. It was also reported in General Electric SIL 483 that only three uniformly distributed housing bolts are required to support the CRD mechanism. These factors provide a high degree of confidence in the long term safety and integrity of the CRD housing joints. Earlier Section Xl code editions invoked by Monticello's 1st and 2nd Ten-Year Inspection Interval Programs did not include the subject examination requirement. During the 3rd Inspection Interval, Relief Request 7 was granted by the NRC in an SER dated October 18, 1994. Alternate Examination: Pursuant to 10 CFR 50.55a(a)(3)(ii), the following alternative is proposed. Any leakage found at a CRD housing bolted joint during a periodic pressure test performed at a temperature much less than operating temperature will be evaluated to determine whether it will stop leaking at operating temperature. If this evaluation shows the leak will stop as temperature increases to normal operating temperature, no further action will be taken. The acceptance criteria is based on guidance provided by General Electric and is included in the VT-2 tests for the joint (Note: This criteria was submitted for NRC review during the Request for Relief process previously approved on October 18, 1994, therefore it is not included in this submittal). If the leakage is determined to be unacceptable according to the General Electric guidelines and the joint is disassembled to correct the leak, any CRD bolting that is reused will be examined by the VT-1 examination method (10 CFR 50.55a(b)(2)(xxi)(B) dated September 26, 2002). 1.5-51 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Upon approval of this Relief Request, MNGP commits to revise the applicable pressure test procedure to perform a VT-1 exam in lieu of a VT-3 exam specified by IWA-5250(a)(2) on all CRD bolting that will be reused when the GE acceptance criteria has been exceeded and disassembly is required to correct the leak. Status: An alternative to the Code was previously approved for the 3rd ISI Interval:

  • NRC Letter, "Evaluation of Third 10 Year Interval ISI Plan,"

(TAC No. M82545), October 18, 1994, Relief Request #7. Not yet approved for 4th Interval. Requested for continued use during 4th Interval. 1.5-52 Revision 0 9/26/2002

   - a I

te 4-4 (Intentionally Blank Page) ii a 4.'

                            -. 4

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Monticello Unit I - ISI Relief Request No. 6 (Rev. 0) Appendix VII Annual Training System/Component(s) For Which Relief Will Be Used: Code Class: All

Reference:

ASME, Section Xl 1995 Edition 1996 Addenda, Appendix VII, VII-4240 Examination Category: All Item Number: All

== Description:== All NDE Examiners performing ultrasonic volumetric examination in accordance with ASME Section Xl, 1995 Edition 1996 Addenda and Appendix VII, Annual Training. Component Numbers: All Code and 10 CFR 50.55a Requirement: ASME Section Xl, 1995 Edition, 1996 Addenda, Mandatory Appendix VII, Paragraph VII-4240: Supplemental training is required on an annual basis to impart knowledge of new developments, material failure modes, and any pertinent technical topics as determined by the Employer. The extent of this training shall be a minimum of 10 hours per year. A record of attendance and the topics covered during the training shall be maintained; however no examination is required. 10 CFR 50.55a, paragraph (b)(2)(xiv): All personnel qualified for performing ultrasonic examinations in accordance with Appendix VIII shall receive 8 hours of annual hands-on training on specimens that contain cracks. This training must be completed no earlier than 6 months prior to performing ultrasonic examinations at a licensee's facility. Basis For Relief Request: 10 CFR 50.55a was amended in the Federal Register (Volume 64, No. 183 dated September 22, 1999) to require Appendix VIII - Supplements for accelerated implementation in accordance with ASME Section Xl 1995 Edition, 1996 Addenda. 1.5-53 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Basis For Relief Request (continued): Paragraph 2.4.1.1.1 in the Federal Register (Volume 64, No. 183 dated September 22, 1999) during rule making contained the following statement: "The NRC had determined that this requirement (10 hours of training on an annual basis) was inadequate for two reasons. The first reason was that the training does not require laboratory work and examination of flawed specimens. Signals can be difficult to interpret and as detailed in the regulatory analysis for this rulemaking, experience and studies indicate that the examiner must practice on a frequent basis to maintain the capability for proper interpretation. The second reason is related to the length of training and its frequency. Studies have shown that an examiner's capability begins to diminish within approximately 6 months if skills are not maintained." Thus, the NRC has determined that 10 hours of annual training is not sufficient practice to maintain skills and that annual Ultrasonic training shall be conducted in accordance with 10 CFR 50.55a(b)(2)(xiv) as amended in the Federal Register (Volume 64, No. 183 dated September 22, 1999) in lieu of ASME Section XI, 1995 Edition, 1996 Addenda, Appendix VII, Subparagraph VII-4240." The latest amendment to 10 CFR 50.55a (Volume 67, No. 187 dated September 26, 2002), paragraph (b)(2)(xiv) further recognizes, and permits use of, analyzing prerecorded data from material or welds that contain cracks for meeting annual training requirements. However, these provisions apply to those sites implementing use of the 1999 Addenda through the latest Edition and Addenda referenced in paragraph (b)(2) of the Rule; Monticello is using the 1995 Edition with the 1996 Addenda as the Code of Record for the 4th ISI Interval. Alternative Requirement: Pursuant to 10 CFR 50.55a(a)(3)(i), Monticello proposes to use the more rigorous and detailed annual training requirements of 10 CFR 50.55a(b)(2)(xiv) in lieu of annual training requirements Appendix VII, paragraph VII-4240. Therefore, all personnel qualified for performing Ultrasonic examinations in accordance with Appendix VIII - Supplements ASME Section XI, 1995 Edition, 1996 Addenda shall receive 8 hours of annual hands-on training on specimens that contain cracks or by analyzing prerecorded data from material or welds that contain cracks. This training will be completed no earlier than 6 months prior to performing ultrasonic examinations at the Monticello Nuclear Generating Unit. 1.5-54 Revision 0 9/26/2002

NUCLEAR MANAGEMENT COMPANY INSERVICE INSPECTION MONTICELLO 4th INTERVAL EXAMINATION PLAN Justification for Granting Relief: This relief improves the performance of Appendix VIII - Supplement examinations by requiring NDE examiner performing Appendix VIII examinations to demonstrate proficiency by analyzing specimens that contain cracks or prerecorded ultrasonic data from material or welds that contain cracks prior to performing actual examinations. The proposed alternative will simplify record keeping, satisfy the needs of maintaining Ultrasonic examiner skills, and also provides an acceptable level of quality and safety. Implementation Schedule: The proposed alternative is requested for the 4th Ten-Year Interval of the Inservice Inspection Program for Monticello Nuclear Generating Unit.

References:

1. ASME Boiler and Pressure Vessel Code, Section XI, 1995 Edition with 1996 Addenda
2. Federal Register, Rules and Regulations, September 22, 1999 (64 FR 51370)
3. Federal Register, Rules and Regulations, September 26, 2002 (67 FR 60520)

Status: Not Yet Approved. 1.5-55 Revision 0 9/26/2002

C* (7 C ISI INDEX KEY

  ---------- INDICATES NDE REQUIRED I OR ANASME  CODE CLASS 1 INDICATES NO NDE REQUIRED ASME CODE CLASS 2 ASME CODE CLASS 3 ko l ASME SAFETY RELATED COMPONENT BUT CANNOT BE CLASSIFIED UNDER REG. GUIDE 1.26 CRITERIA.

ASME NON SAFETY RELATED REF: IFILE NO: RS (M&SP)- ISI INDEX KEY ISI DWN: TJH CHKD: IV APPD: 0h,/ SYSTEM: LINE: DWG: 1.5-1 REV: 0

c ( c XDV.3 XDV-2 REACTOR H1EADVENT CV-2372 CV-2371 TO-CRW N-141 -&13 TO'CRW 1 REACTOR RV-2-71B RV-2-71G VESSEL RV-2-7111 RV-2-71C 0-2-86B AO-2-808 oAO-2-8OC AO28 TO TURBINE +j~1l_ N-3C TTUBN STOP VALVE -- IN-3B + STOP VALVE FE-2-114B FE-2-114C PEN X-7C PEN X-71 TO RCIC TO HPCISUPPLY SIEAM STEAM SUPPLY - I f RV-2-71E RV-2-71A 7+-'- RV-2-71D RV-2-71F AO-2-80D TO TURBINE STOP VALVE ZL-N rA-2-86A 1-PEN X-7A N-3A N-3D TO TURBINE STOP VALVE PEN X-7D rmo2374 O 7 TO -- - -- - - - A CONDENSER *- .... . PEN X-8 REF: NH-36241 FILE NO: IS (M&SP)- MONTICELLO DWN: TJH CHKD:/1/2y.;i:-" SYSTEM: MAIN STEAM SYSTEM

C (C C t----1 I I I I I REACTOR I I VESSEL I I I I I I N-4C I I ~I FW 91-2 FW 94-2 FW 97-2 FW 98-2 I 1 1 FW 98-1 F/y97.-l FW,94-1 BY 91-1 FEEDWATER B' -- -"- _ N-40I_ 1 - -. - _ L FW- <-

                                             ~ -~[N-PEN
                                                               -       ~       1-4A       '1' IN     _7- 1 7i        -1    .-              FEEDWATER 'A' I          I                                PEN       --    I X-9A                                                                         X-g REACTOR WATER CLEAN-UP RETURN  -

FI L ------ --- FROM

                                                                                                                                                                        ?.RCIC HPCI---

THiERMAL lEE I ...... REACTOR WATER CLEAN-tIP RETURN REF: NH-36241 IFILE NO: IP (M&SP)- MONTICELLO ISI DWN: TJH CHKD: i<IU APPD:/4?,Fj SYSTEM: FEEDWATER SYSTEM LINE: DWG: 1.5-3 REV: 02

      ,C                                                                                          C                                                                                             C REACTOR VESSEL C                                                                                        N-2E RHR                                                   .L_*>I*                  FN-2D SYSTEM CV-42 91    PNC PEN    -2790          XR-17                                  -N

[N2 --- -2D N-2G X-41 I I L3N-2C 7 I N-2H N-2J

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  • MO-2035  :-<--

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                                                                      "-Is ýljPC,-60                                                         IiI PCI- 4
                                                                                  ~6 OH~ 1 P I -                                  PCI - 73 PSD-2038     -        HPI-5                                                   HPI7 ITPCI-82      HPCI-10    ItPCf-9                 HPI5/V26 I-'                       RV-2056                                                   TO MAIN PC    -80 HPCI-66        9(20"0l6')                                            AFLHPCI-12
                                                                                            .I CONDENSER 4I~~I~a-aoCONDENSER X- 2                                              PCV-3492 HNPCI-675'11:7 PENE                                                      1o                     IPCI COOLING WATER (WATER       SIDE)

REF: NH-36249 IFILE NO: P(M&SP)- MONTICELLO (S1 DWN: TJH CHKD: "VJSA14L APPD:,,9 ,,.v.c SYSTEM: HP COOLANT INJECTION SYS. (STEAM SIDE) LINE: 1.5-8 [REV: 02 D WO: DWG: 1.5-8 1REV: 02

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                                                  -   ----------        N--      -----     ------               j X-225 REF: NH-36250                         IFILE NO:

16? (M&sP)- MONTICELLO ISI DWN: TJH CHKD: Jýi\A-) APPID: 2.- SYSTEM: HPD COOLANT INJECTION SYS._ (WATER SIDE) LINE: __ ____ _ __ __ __ __ _ __ __ __ __ _ DWG: 1.5-9 REV: 02

C C C

           ---.                                         PEN X-10 olf-                                            (SLEEVED) 1          ~MO-2075           1\       MO- 2076 IREACTOR 1         I ------     -  -    >-    --                 >

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                                                             -P-207~RCIC      I       PUMP DRIV  TURBINEj
                                                                                -RCI                                        RCIC-3 C6RCIC-64 TO REACTOR                                                ST-2081 CV-2079I
                                                       -r    T                                                 *RCIC-4 "aI                                                          T              CV-2082A RCIC-10    RCIC-9           r Tr TO MAIN RCIC-70                                                                                                                    CONDENSER RCIC-61                                                                                               RCIC-12 PCV-2092 RRCI-C49 RCI-59RCIC-14                                                 RCIC-26 RO-2094                                                        -49 Ah04*4*                                                        -       TO BAROMETRIC MO-2096                                            RCIC-23         CONDENSER MTS                  RCIC-17 LUVUE                     RCIC-20 YS-4262 R0-4263 PUMP FUMP                             RV-2097         OILno                                                 C0.14DE1,__4SE B ROE, TO BAROM--RI FROM                   COOLER                                                   CONDENSER CONDENSATE PUMP                            TO BAROMETRIC CONDENSER REF: NH-36251                        IFILE NO:

NS (M&SP)- MONTICELLO ISI DWN: TJH CHKD: ]qN ) APPD:/., SYSTEM: RX CORE ISOLATION COOLING (STEAM SIDE) LINE: 1.5-10 IREV: 02 DWG: 1.5-10 1REV: 02

( (

     /'        N I REACTOR VESSEL I    I L _-I',l REF: NH-36252               IFILE NO:

IGSP (M&sP)- MONTICELLO ISI DWN: TJH CHKD: PAL) PDrij-ý SYSTEM: REACTOR CORE ISOLATION COOLING (WATER SIDE) LINE: __ ____ __ __ __ _ __ __ __ __ __ __ _DWG: 1.5-11 REV: 02

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                                  ~~FROM                                   TEST TANKZ XP-11-14B         it                                         XP-17 R   -  3-"

ACCUMULATOR XPE XP-11-14AIlr2--1 (SLEEVED) TI~l* l P-203A P- (Positive DIspI Pmp) XP-8/ XP-SSL XP-4-12 XP-3-1 XP-2-1 L- - - - _ ACCUMULATOR T-204B UL T-204B RV-11--398 REF: NH-36253 IFILE N: Pap (M&SP)- MONTICELLO ISI DWN: TJH CHKD: ,IW APPD:-r. SYSTEM: STANDBY LIQUID CONTROL SYSTEM LINE: DWG: 1.5-12 REV: 02

( C Q FROM NITROGEN AO-7423A AO-7423B TO STANDBY GAS TREATMENT AND REACTOR BUILDING PLENUM AO-7422B AIR PURGE I" SUPPLY FROM AO-2381 REACTOR BUILDING TO STANDBY GAS AND REACTOR BUlL I ,J D WV--2 VACUUM REUEF SAO-' SECONDARY F*O*MOM IAO-237ý9 CONTAINMENT S_ DWV-8-1 VACUUM RELIEF 18 1_______ / " FROM SECONDARY f AO-4539 7--[]AO-7424A CV-2384 NH-36258 NH-46162 ' CGCS DlVI NIU QAA0n FROM CC I NH-94897 REF: NH-1 16629 IFILE NO: Rupture DIsk KJ ISP (M&SP)- MONTICELLO ISI HARD PIPE DWN: TJH CHKD: iOP 1P APPD: ,*)Ji; VENT SYSTEM SYSTEM: PRI. CONTAIN. ATMOS. CONT. SYS. LINE: DWG: 1.5-13 REV: 02

SESW-6-1 dD ESW-61-1 ESW-60-1

                                                                       ><I- 4        ~       -"              I I-     -      TO STORM SEWER STANDBY DIESEL GENERATORS             K ESW-7 E W-5-1         w-ESW-5-2 FROM SERVICE                             FROM SERVICE        RVC             ESW-61-2 WATER PUMPS                              WATER PUMPS IFESW-3-1                                  ESW-3-2            AEW1 0                               BS-24140                                          WS-1980 ESW-3-3                                  ESW-3-4 ESW-7 j7  EW2-1   -1ESW-2-2 REMOVABLE 7ESW-1 -1         SPOOL                   7ESW-1-2 A -155316REF:

NH-36665 IFILE NO: EMERGENC SERVICE A EMERGNWSERVICE NS? (M&sP)- MONTICELLO ISI WATER PUMP WATER PUMP DWN: TJH CHKD: iAW) APPD:,i?. P-111A P-11iD SYSTEM: EMVERG. DIESEL GEN. EMER. SERV. WATER LINE: DWG: 1.5-14 IREV: 02

ESW-34 ESW-34 VEAC-14A ESW-32 ESW-62-1 ESW-4-I EVSW-48 ESW-48 Lý ESW-62-2 ESW-4-2 W SW- FR34-1 F 7W-1 FE428E S SERVICE WATERVA -- W2-58-1' E W1E-4 SW 2.58.ESW-36 ESW-35 ES-33VA-

                                                -31F                            SW-235-2   SW,                                                             SW- OF 25 SW-106-2   SW-108      SW-11O-4    SW-11O-2 XSW-112-2                         SW-iW2-1
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                                                                                                                                   -1m2 A UNITS        CR-SPRAY         )      V A-       ECCS PUMP VE TU4S UNNTS SZEESW-5 FL11-SW113       SW-113-1X        sw- iistN ESW-38        AV-4024                                                       NH-36664 REF: NH-36665                              IFILE NO:

I A (M&SP)- MONTICELLO ISI EMERGENCY SERVICE EMERGENCY SERVICE DWN: TJH CHKD: li' APPD: 4 -9,-r' WATER PUMP WATER PUMP SYSTEM: EMERG. DIESEL GEN. EMER. SERV. WATER P-11C P- 1iD LINE: DWG: 1.5-15 1REV: 02

RHRSW-12 IRW1 RHRSW-4-2 RHRSW-4-1 2-TO RHR

                                                                                                                                ,c--   --  IHEAT EXCIIANGER RHRSW-3-2                                IRHRSW-3-1        FE 10-96A     ,'I'v                         E-200A              F10-96A BS-19520                                  BS-19510 DEMINERAUZED                                     DEMINERAUZED SWATER                                                                WATER RIIRSW-2-4          RHRSW-2-2           RIIRSW-2-3            RIIRSW                  --            HR    -W S

RV-3202 07, RV-3203 RHRSW-1-4 AV-3148 RHRSW-1-2 V AV-.315 RHRSW-1-3 RIIRSW-1-1 V AV-3149 AV-3147 1-316-1 B- 1-316-2 RHRSW-52-4 RHRSW-5 / 'II RHRSW-52-3 RIIRSW-52-1 RHR fix 200~ E-200B P-109D P-109B P-109C P-I19A A CV1728 A _TDCVW1729 TO CIRC WATER TO CIRC WATER RHR SERVICE WATER PUMPS DISCHARGE DISCHARGE NH-36664 REF: NH-36665 IFILE NO: I~w (M&SP)- MONTICELLO ISI DWN: TJH CHKD: iAC APPD:,")go*"io SYSTEM: RHR SERVICE WATER LINE: _DWG: 1.5-16 REV: 02

C C, ( TO EXIHAUST FROM DRIV WATER HEADER WATER HEADER SV-121 SV-120 PEN X-38A-D L_ - REF: NH-36245 FII N0: N Pap (M&SP)- MONTICELLO ISI DWN: TJH CHKD: I ',A(-) APPD:,,,. SYSTEM: HYDRAULIC CONTROL UNIT LINE: DWG: 1.5-17 IREV: 03

( C C

                                 -ROMCU          TF           TT FROM H-CU SCRAM RISERS'                 SCRAM RISERS     ýli CV-3-32C CV-3-32A                  FR2MOMlicI    IFROM                    HCU CV-3-32B CV-3-32D SCRAM RISERS ISCRAM                 RISERSC Tz          ~'                                           i FROM IICU                        FROM HIctU SCRAM RISERS I               SCRAM RISERS
                                                                   -         N F--I F--I SCRAM DISCHARGE VOLUME-,-I       I L1 I-'--SCRAM DISCHARGE VOLUME I    I II 1I DCV-3-33A Al~-)CV-3-33B 7L c-*_*

I REF: NH-36245 IFILE NO: 18 (M&SP)- MONTICELLO isi DWN: TJH CHKD: I.:Al-b APPD:,,Is;.. SYSTEM: CONT. ROD DRIVE SYS. (SCRAM DISCH. PIPING) LINE: DWG: 1.5-18

  • I ... .. .

DW:1.5-18 I REV: 02

C C C, PEN CV-1478 X-22 CV-7956 PEN X-229 N AL-574 S

                           ~zI  TAD-571 INSTRUMENT AIR                   Z-iý                                           INSTRUMENT AIR TO TORUS TO DRYWELL AI-631 Al-630 PEN X-21 AS-78      AS-79  AS-39    _

iSERVICE AIR Lg;;- ~ ,~. T RW PEN X-1OS-B-G PEN AI-599 AI-584 X-34A AI-700 AI-708 AI-598 Al-577

                           -   N2 SUPPLY                            -1                                   -     N2 SUPPLY S1                           TO RV-2-719                                                                     TO RV-2-71F ACCUMULATOR                                                                     ACCUMULATOR NH-36049-4 NH-36049-10 NH-36049-12 REF: NH-36049-14                       WFILE NO:            19 hsP         (M&SP)- MONTICELLO                              IsI DWN: CADWorks CHKD:                ""         APPD:,i-v-<

SYSTEM: COMPRESSED AIR SYSTEM LINE: DWG: 1.5-19 REV: 01

C C C PEN DM-152 DM-58 X-20 DM-151 DI*(4 DEMIN. WATER TO DRYVVELL DEMIN. WATER SYSTEM TO COOLING FROM REACTOR BUILDING WATER PUMP HEAT EXCHANGERS FROM DRYWELL TO DRYWELL COOLERS COOLERS NH-36039 REF: NH-36042-2 IlP (M&SP)- MONTICELLO ISI REACTOR BUILDING COOLING WATER SYSTEM DWN: TJH CHKID: .l I'b APPD: ,N-. SYSTEM: DEMIN. WATER S§i'STEM & RX BLDG CW LINE: DWG: 1.5-20 REV: 02

TO ttPDI .... . - * -- FROM CLEANUP HEAT EXCHANGERS TO RCICO RC-1 RC-104 MO-2397 k MO-2398 FROM REACTORZ- -- > -- -< - -II'l -- - ... ..-- - TO CLEANUP RECIRC. LOOP 'B PEN RECIRC. PUMPS X-14 FROM REACTORl --- ---- J VESSEL DRAIN REACTOR WATER CLEAN-UP SYSTEM PEN AO- 541AA-51 X-1 8 1 A - 1 kt, DRW-93 FROM DRYWELLL--f >< -TO FLOOR DRAIN FLOOR DRAIN SUMP COLLECTOR TANK PEN AO-2561A AO- 561B X-19 FROM DRYWELL-'4I----T- -ZTO WASTE EQUIPMENT DRAIN 1577 .. ] COLLECTOR TANK NH-36043 NH-36044 LIQUID RADWASTE REF:NH-36254 IFILE NO: liS (M&SP)- MONTICELLO IS! DWN: TJH CHKD: ll~) APPD:,;e., SYSTEM: RX WTR CLEAN-UP & LIQUID RADWASTE LINE: DWG: 1.5-21 REV: 02

IREACTOR I BALL SHEAR VESSEL I VALVES VALVES INDEX P MECHANISM TIP-1-2 TIP- 2-1

                     *P       [9,O                 RI RV MECHANISM T         T1P-3-2 lAI2261   A625 NITROGEN PURGE SUPPLY REF:                        IFILE NO:      22 I         (M&SP)- MONTICELLO                 ISI DWN: CADWorks CHKD: ,*/'          APPD: *,-'"

SYSTEM: TRAVERSING IN-CORE PROBE SYSTEM LINE: DWG: 1.5-22 REV: 01

( C MANUAL EXCESS-FLOW CHECK VALVE

              " L*UN**EE     VAL' VTO FROM?ýQET PRIMARY                                             INSTRUMENT SYSTEM                                             RACK TYPICAL FOR EXCESS-FLOW CHECK VALVES EXCEPT EXCESS-FLOW CHECK VALVE FOR PENETRATION X-28F VESSEL HEAD FLANGEG IISEALS S          MANUAL      EXCESS-FLOW VALVE      CHECK VALVE PEN                   XFV-          ItSTRUMENT X-28F    L.  "                         RACK EXCESS-FLOW CHECK VALVE FOR PENETRATION X-28F NH-36241 REF: NH-36242                IFILE NO:       23 NS         (M&SP)- MONTICELLO                 ISI DWN: CADWorks CHKD:,,),5        -,-- APPD:      ,

SYSTEM: EXCESS-FLOW CHECK VALVES LINE: DWG: 1.5-23 REV: 01

                                                                                           ""QMBINERA ILT ..Zp FE-4052A TO II         AO-7422A                      AO-7423A D- 11 I   Mo-4043A CGC-9-1     MO-4044A                  r TO CAM SAMPLE TO CAM CGC-1-1                                MO-4047A AO-7424A       TO    PRIMARYY AO-7425A CONTOLOL CONTAINMENT-7 ATMOSPHERIC                               RV-4032A IPVC-4037A CONTROL RYELCGC-13-1                                   CGC-PIA SV-4034A CC -1S--C4054A SV-43A        G-I?*                               CGC-3-1 CGC-1-1 TO RHR LOOP A REF: NH-94896                    IFILE NO:

hS (M&SP)- MONTICELLO ISI DWN: TJH CHKD: RJi. APPD: ,rC SYSTEM: COMBUSTIBLE GAS CONTROL, DIVISION 1 LINE: DWG: 1.5-24 REV: 02

R.fCOMABR U T .2,_1 SFE-40528 FE401 AO-7423B AO-7422 MDIV I A CGC-9-2 TO CAM SSAMPLE TO CAM SPRAY SAMPLE __Co _MO-4047 oc-1o-2 AO-74259 AO-7424B PEN X-47 "CGC-2-2 TO PRIMARY PVC-4037B *RV-4032B CONTAINMENT ATMOSPHERIC CONTROL R CGC-PIB CGC-13-2 SV-40 SV-4033 (MC) CGC-3-f2 CC -? - SV-403413

                                                                                  -                 CCC- 1-2 C          TO RIIR "LOOP B REF: NH-94897                     FFILE NO:

I%57 (M&SP)- MONTICELLO ISI DWN: TJH CHKD: I',M APPD:/ SYSTEM: COMBUSTIBLE GAS CONTROL, DIVISION 11 LINE: DWG: 1.5-25 REV: 02

TO POST ACCIDENT TO OXYGEN TO HYDROGEN SAMP ING ANALYZER OXYGEN ANALYZE S T-SV-4082 SV-3307 SV-4001A SV-4001 SV-4081 SV-3308 SV-4020A SV-40200 DWVV5

                                            *.*  DWV-6                      e      DWV-5     DYV93     CV-3312    CV-3 X-27EZ-~1---?TOOYE                                                     AAYE 4B OXYGEN      CV-3313 CV-3314                   TORUS-215 ANALYZER                                                                                                      I P SV-4005A   SV-4004A         DWV-55-1                         DWV-55-3              SV-4002B  SV-40030 FROM HYDROGEN-                                                                                                          iTO           HYDROGEN OXYGEN       SV-4005B   SV-4004B         DWV-55-2                           DWV-50              SV-4002A  SV-4OO3A        OXYGEN ANALYZERS                     0l4                                                                                        1   ANALYZERS NH-46162 NH-91197 REF: NH-96042-1                      FILE NO:           26 I         (M&SP)- MONTICELLO                             ISi DWN: CADWorks CHKD:                       - APPD:     ,    .&

SYSTEM: PRIMARY CONTAINMENT SAMPLING SYSTEMS LINE: DING: 1.5-26 1.5-26 IREV: 01 IREV: 01 DWG:

C C C N-- - - -- =-i-- RI VESSE IN

               "-CI------           N-11A         N-11B                T"--
                      -J            N-12A         N-12B3
                              -{    N-BA           N-8      I:

ALL BOUNDRIES ARE SHOWN QUAUTY GROUP A

                                                         /

ISI REF: NH-36242 IFILE NO: MONTICELLO S(M&SP)- 27 01 d.)5.*,.J f;Y'c.t.,"- INSTRUMENTATION CHKD: ISP (M&sP)- MONTICELLO DWN: APPD: VESSELlREV:ISI CADWorks REACTOR DWN: CADWorks CHKD: 6)jrfV5r SYSTEM:APPID: 1.5-27 SYSTEM: REACTOR VESSEL INSTRUMENTATION LINE: LINE: DWG: __ __ __ _ __ __ __ _ __ __ __ _ DWG: 1.5-27 REV: 01}}