ML053120003
| ML053120003 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 11/07/2005 |
| From: | Daniel Merzke NRC/NRR/ADRO/DLR/RLRA |
| To: | Conway J Nuclear Management Co |
| Merzke, D., NRR/DRIP/RLEP, 415-3777 | |
| References | |
| TAC MC6440 | |
| Download: ML053120003 (6) | |
Text
November 7, 2005 Mr. John T. Conway Site Vice President Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE MONTICELLO NUCLEAR GENERATING PLANT LICENSE RENEWAL APPLICATION (TAC NO. MC6440)
Dear Mr. Conway:
By letter dated March 16, 2005, Nuclear Management Company, LLC, (NMC or the applicant) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) to renew the operating license for Monticello Nuclear Generating Plant (MNGP), for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified, in the enclosure, areas where additional information is needed to complete the review.
These questions were discussed with your staff, Mr. Patrick Burke, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me by telephone at 301-415-3777 or via e-mail DXM2@nrc.gov.
Sincerely,
/RA/
Daniel J. Merzke, Project Manager License Renewal Branch A Division of License Renewal Office of Nuclear Reactor Regulation Docket No.: 50-263
Enclosure:
As stated cc w/encl: See next page
November 7, 2005 Mr. John T. Conway Site Vice President Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE MONTICELLO NUCLEAR GENERATING PLANT LICENSE RENEWAL APPLICATION (TAC NO. MC6440)
Dear Mr. Conway:
By letter dated March 16, 2005, Nuclear Management Company, LLC, (NMC or the applicant) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) to renew the operating license for Monticello Nuclear Generating Plant (MNGP), for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified, in the enclosure, areas where additional information is needed to complete the review.
These questions were discussed with your staff, Mr. Patrick Burke, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me by telephone at 301-415-3777 or via e-mail DXM2@nrc.gov.
Sincerely,
/RA/
Daniel J. Merzke, Project Manager License Renewal Branch A Division of License Renewal Office of Nuclear Reactor Regulation Docket No.: 50-263
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION: See next page Adams accession no.: ML053120003 Document Name: G:\\DRIP\\RLEP\\License Renewal Section-A\\Merzke\\Monticello LRA\\RAIs\\Final RAIs - EEIB.wpd OFFICE PM:RLRA LA:DLR SC:RLRA NAME DMerzke YEdmonds LLund DATE 11/ 03 /05 11/ 03 /05 11/ 07 /05 OFFICIAL RECORD COPY
Monticello Nuclear Generating Plant cc:
Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 U.S. Nuclear Regulatory Commission Resident Inspector=s Office 2807 W. County Road 75 Monticello, MN 55362 Manager, Regulatory Affairs Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637 Robert Nelson, President Minnesota Environmental Control Citizens Association (MECCA) 1051 South McKnight Road St. Paul, MN 55119 Commissioner Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, MN 55155-4194 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Commissioner Minnesota Department of Health 717 Delaware Street, S.E.
Minneapolis, MN 55440 Douglas M. Gruber, Auditor/Treasurer Wright County Government Center 10 NW Second Street Buffalo, MN 55313 Commissioner Minnesota Department of Commerce 85 7th Place East, Suite 500 St. Paul, MN 55101-2198 Manager - Environmental Protection Division Minnesota Attorney General=s Office 445 Minnesota St., Suite 900 St. Paul, MN 55101-2127 John Paul Cowan Executive Vice President & Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Nuclear Asset Manager Xcel Energy, Inc.
414 Nicollet Mall, R.S. 8 Minneapolis, MN 55401 Mr. James Ross Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Patrick Burke License Renewal Project Manager Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637 Mr. Douglas F. Johnson Director, Plant Life Cycle Issues Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 David R. Lewis Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street, NW Washington, DC 20037-1122 Monticello Nuclear Generating Plant
cc:
Mr. George Crocker North American Water Office P.O. Box 174 Lake Elmo, MN 55042
DISTRIBUTION: Memo to J. Conway, re: RAI for review of Monticello LRA, Dated: November 7, 2005 Adams Accession No.: ML053120003 HARD COPY RLEP RF E-MAIL:
RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins J. Fair RidsNrrDssa RidsNrrDipm D. Thatcher R. Pettis G. Galletti K. Winsberg (RidsOgcMailCenter)
R. Weisman M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy Y. L. (Renee) Li RLEP Staff L. Raghavan L. Padovan A. Stone, RIII B. Burgess, RIII P. Lougheed, RIII R. Orlikowski, RIII A. Hodgdon M. Woods OPA
Enclosure MONTICELLO NUCLEAR GENERATING PLANT LICENSE RENEWAL APPLICATION (LRA)
REQUEST FOR ADDITIONAL INFORMATION (RAI)
RAI 2.5.2-2 LRA Section 2.5.2.4 states that the specific path for the 345 kV source is Athe 4.16 kV Non-segregated Phase Bus...the 34.5 kV direct buried cable to the Current Limiting Protector in parallel with...@ Also, the specific path for the 13.8 kV offsite source is, Athe buried cables from the...direct buried cable from the 1AR/10TR Disconnect Switch...@ Please identify the Aging Management Program (AMP) that will be used to manage the aging effects of these buried cables.
RAI 3.6-1 LRA Table 3.6.2-1, Electrical Penetrations Commodity Group, addresses the components of Non-EQ Electrical and Instrumentation and Controls (I&C) penetration assemblies subject to aging management review (AMR).
Please justify why the seal and other insulating material associated with these penetration assemblies do not require an AMP. In addition, identify the AMP that will be used to manage the aging effects of cables and connectors associated with penetrations that are within the scope of license renewal.
RAI 3.6-2 In LRA Table 3.6.2-4, the applicant identified AMR line items for cable connections and stated that no AMP is required for the cable connections. The staff notes that the applicant referenced SAND96-0344, AAging Management Guidelines For Electrical Cable and Terminations,@ in its justification for not having an AMP. However, this report indicates that several plants identified loosening of terminations and found that the major concern is that failures of a deteriorated cable system (cables, connections including fuse holders, and penetrations) might be induced during accident conditions. Since these connections are not subject to the requirements of 10 CFR 50.49, an AMP is required to manage the aging effects in cable connections.
In addition, operating experience has shown evidence of loosening of metallic parts of cable connections. Several licensees reported in Licensee Event Reports loose connections due to corrosion, vibration, thermal cycling, etc. Based on the above, justify why an AMP is not required for cable connections or provide an AMP.
RAI 3.6-3 In LRA Table 3.6.2-2, the applicant identified AMR line items for fuse holders and stated that no AMP is required for the fuse holders. The staff finds that the justification provided by the applicant is not adequate. For example, thermal cycling due to energizing and de-energizing of circuits is not addressed. Also, it is not clear to the staff how the fuse holders are protected
Enclosure from exposure to external sources of moisture and chemical contamination. Please justify in detail why the fuse holders at MNGP do not need an AMP by addressing each aging effect included in Generic Aging Lessons Learned Report (GALL) AMP XI.E5, Fuse Holders.
Additionally, identify those fuse holders that perform an intended function to meet the criteria of 10 CFR 54.4(a) (i.e., isolate safety loads from non-safety loads or are used as protective devices to ensure the integrity of containment electrical penetrations). Where are these fuse holders located?
RAI 4.7-1 The environmental qualification of electrical equipment results described in Section 4.7 indicate that the aging effects of the environmental qualification (EQ) of electrical equipment identified in the Time-Limited Aging Analysis (TLAA) will be managed during the extended period of operation under 10 CFR 54.21(c)(1)(iii). The important attributes of a re-analysis include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria and corrective actions. Please discuss how the important attributes for re-analysis of an aging evaluation of electrical equipment identified in the TLAA to extend the qualification under 10 CFR 50.49(e) will be implemented at MNGP (e.g., how the temperature data used in an aging evaluation is collected at MNGP).
RAI B2.1.6-1 The applicant states in AMP B2.1.6, for the ADetection of Aging Effects@ program element, that this program will visually inspect internal portions of bus ducts, the bus insulating system, and bus supports. In addition, a torque test or resistance test of a sample of accessible bolted connections will be performed. However, the staff notes that vendors do not typically recommend re-torquing of bolted connections unless the joint requires service or the bolted connections are clearly loose. The torque required to turn the fastener in the tightening direction (restart torque) is not a good indication of the pre-load once the fastener is in service. Due to relaxation of the parts of the joint, the final loads are likely to be lower than the installed loads.
Provide a technical justification detailing how re-torque of bolted connections is a good indicator of the pre-load once the fastener is in service. Please modify the acceptance criteria accordingly. Also, please clarify if there are any bolted connections covered with heat sink tape, sleeving, insulating boots, etc., that are accessible and are not covered by this activity.
RAI B2.1.6-2 With regard to the ACorrective Action@ element for the Bus Duct Inspection Program, it is stated that requirements of 10 CFR 50, Appendix B, AQuality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants,@ is applicable to MNGP. However, the staff notes that GALL AMP XI.E4, Metal Enclosed Bus, the ACorrective Actions@ element states that further investigation and evaluation are performed when the acceptance criteria are not met. Corrective actions may include but are not limited to cleaning, drying, increased inspection frequency, replacement, or repair of the affected metal enclosed bus components. If an unacceptable condition or situation is identified, a determination is made as to whether the same condition or situation is applicable to other accessible or inaccessible metal enclosed bus. Please revise corrective actions in B2.1.6 to add specific requirements or provide justification why these corrective actions are not necessary.
RAI B3.1-1 In Section B3.1 under the AScope of Program@ element, it is stated that an equipment master list is maintained at MNGP that has been developed to encompass the requirements of
10 CFR 50.49(b). This master list includes safety-related electrical equipment and non-safety-related equipment whose failure could prevent accomplishment of safety functions.
Please identify the non-safety-related electrical equipment that is needed to be qualified to meet the requirements of 10 CFR 50.49.
RAI B3.1-2 In Section B3.1 under the ADetection of Aging, Monitoring and Trending,@ and AParameters Monitored or Inspected@ elements, it is not clear how, without monitoring or inspection of certain environmental conditions or component parameters, the aging effects of electrical equipment can be managed, to assure that the component is within the bounds of its qualified life, or as a means to modify the qualification. Please justify why the EQ program at MNGP without the above attributes is acceptable for managing the effects of aging.
RAI B3.1-3 In Section B3.1, the ACorrective Actions@ element refers to 10 CFR Part 50, Appendix B. In GALL AMP X.E1, Environmental Qualification of Electrical Components, the ACorrective Actions@ element states that when unexpected adverse conditions are identified during operational or maintenance activities that affect the environment of a qualified component, the affected component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions. When an emerging industry aging issue that affects the qualification of an EQ component is identified, the affected component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions. Please revise corrective actions in B2.1.6 to add specific requirements or provide justification why these corrective actions are not necessary.
RAI B2.1.21-1 In AMP B2.1.21, Inaccessible Medium Voltage (2kV to 34.5 kV) Cables Not Subject to 10 CFR 50.49 EQ Requirements, the applicant described under the APreventive Action@ element that periodic actions are taken to prevent medium voltage cables from being subject to prolonged exposure to significant moisture, such as inspecting for water collection in cable manholes and conduit, and draining water, as needed. The staff requests the applicant to state the inspection frequency and its basis.
In addition, because it is the staff position that inaccessible medium voltage cables be tested and inspected, the staff requests the applicant remove the following line from the APreventive Action@ element, AMedium-voltage cables, for which such actions are taken, are not required to be tested since operating experience indicates that prolonged exposure to significant moisture and being energized for significant periods of time are required to induce this effect.@