ML20083G903
| ML20083G903 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 03/20/2020 |
| From: | O'Brien K NRC/RGN-III |
| To: | Church C Northern States Power Company, Minnesota |
| References | |
| EA-15-206 | |
| Download: ML20083G903 (8) | |
See also: IR 05000263/2015007
Text
March 20, 2020
Mr. Christopher Church
Site Vice President
Monticello Nuclear Generating Plant
Northern States Power Company, Minnesota
2807 West County Road 75
Monticello, MN 55362-9637
SUBJECT: REVISED NON-CITED VIOLATIONMONTICELLO NUCLEAR
GENERATING PLANT NRC COMPONENT DESIGN BASES INSPECTION
REPORT 05000263/2015007 (NCV 05000263/2015007-02; FAILURE TO
REVIEW FOR SUITABILITY OF APPLICATION OF SAFETY-RELATED
RELAYS INSTALLED BEYOND THEIR SERVICE LIFE)
Dear Mr. Church:
On October 2, 2015, Monticello Nuclear Generating Plant (MNGP) provided a written
response to U.S. Nuclear Regulatory Commission (NRC) Inspection Report 05000263/2015007,
which was issued on September 2, 2015. Specifically, the letter contested Non-Cited Violation 05000263/2015007-02 associated with the failure to justify continued service of safety-related
relays and motor starter contactors installed beyond their service life. The letter explained
MNGP agreed a performance deficiency occurred but disagreed the deficiency was associated
with a violation of Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix B,
Criterion III, Design Control, as stated in the inspection report. The letter further stated MNGP
believed the performance deficiency was associated with 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings.
The NRC carefully reviewed MNGPs reply and determined the Non-Cited Violation should
be changed to a violation of Technical Specifications 5.4.1, Procedures, as shown in the
enclosed assessment. Technical Specification 5.4.1, requires, in part, the establishment,
implementation, and maintenance of written procedures recommended in Regulatory
Guide 1.33, Revision 2, Appendix A, February 1978. Section 9 of the Regulatory Guide
requires the development of preventive maintenance schedules and associated procedures
for the inspection or replacement of parts that have a specific lifetime. The bases for the
staffs conclusion are detailed in the enclosed report.
C. Church
-2-
This letter, its enclosure, MNGPs October 2, 2015, response, and your response (if any) will be
made available for public inspection and copying at http://www.nrc.gov/reading- rm/adams.html
and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections,
Exemptions, Requests for Withholding.
Sincerely,
/RA/
Kenneth G. OBrien, Director
Division of Reactor Safety
Docket No. 50-263
License No. DPR-22
Enclosure:
NRC Staff Assessment of Disputed
cc: Distribution via LISTSERV
C. Church
-3-
Letter to Christopher Church from Kenneth G. OBrien dated March 20, 2020.
SUBJECT: REVISED NON-CITED VIOLATIONMONTICELLO NUCLEAR
GENERATING PLANT NRC COMPONENT DESIGN BASES INSPECTION
REPORT 05000263/2015007 (NCV 05000263/2015007-02; FAILURE TO
REVIEW FOR SUITABILITY OF APPLICATION OF SAFETY-RELATED
RELAYS INSTALLED BEYOND THEIR SERVICE LIFE)
DISTRIBUTION:
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RidsNrrPMMonticello
RidsNrrDroIrib Resource
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ADAMS Accession Number: ML20083G903
OFFICE
RIII
N RIII
RIII
NAME
KStoedter:jw
JCameron
SLewman
JPeralta
DATE
02/25/20
02/25/20
03/18/20 via Email
02/26/20 via Email
OFFICE
RIII
NAME
KOBrien
DATE
03/20/20 via Email
OFFICIAL RECORD COPY
NRC STAFF ASSESSMENT OF DISPUTED NCV 05000263/2015007-02
Enclosure
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed information provided in
the Monticello Nuclear Generating Plant (MNGP) letter dated October 2, 2015. This review
was performed by staff members having relevant technical and regulatory knowledge.
Documents referenced are listed in the Reference Section of this Enclosure.
1. BACKGROUND
During the 2012 Problem Identification and Resolution inspection, Unresolved
Item (URI)05000263/2012008-01 was opened related to the qualification basis for
safety-related relays and motor starter contactors. The URI identified concerns regarding
the acceptability of keeping specific safety-related relays and motor starter contactors
installed in the plant for a period which exceeded the vendor recommended service life
without an appropriate justification.
The inspectors, in consultation with Nuclear Reactor Regulation staff, issued Task Interface
Agreement (TIA) 2014-01, Final Task Interface Agreement - Regulatory Position on Design
Life of Safety-Related Structures, Systems, and Components Related to Unresolved Items
at Donald C. Cook Nuclear Power Plant, Monticello Nuclear Generating Plant and Palisades
Nuclear Plant, on May 7, 2015. This TIA concluded when a licensee becomes aware that
a safety-related structure, system or components (SSCs) service life has been exceeded or
information challenges the presumption that a safety-related SSC can perform its specified
function, the licensee must promptly address and document this non-conforming condition in
accordance with the licensees NRC approved Quality Assurance Program, the licensees
operability/functionality program and the corrective action program. This includes
completing appropriate corrective actions in a timely manner and documenting evaluations
justifying the service life extensions.
On September 2, 2015, the NRC issued Component Design Bases Inspection
Report 05000263/2015007 that assessed, in part, the unresolved item discussed above.
The NRC documented the closure of the URI as a finding of very-low safety significance
(Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal
Regulations (CFR), Part 50, Appendix B, Criterion III, for the failure to review for suitability
of application of safety-related relays and motor starter contactors, which were installed
beyond their service life. This inspection report dispositioned this issue as NCV 05000263/2015007-02. Immediate corrective actions included instituting a Relay Monitoring
Program, performing generic service life evaluations on specific types of safety-related
relays, and identifying and replacing relays that had exceeded the vendor recommended
service life. The licensee continued to identify safety-related relays exceeding the vendor
recommended service life and had plans to conduct extent of condition reviews. A separate
corrective action item was initiated to evaluate motor starter contactors installed beyond the
recommended service life.
On October 2, 2015, MNGP provided a written response to the NRC contesting the
enforcement decision associated with NCV 05000263/2015007-02. Specifically, the letter
explained MNGP agreed a performance deficiency occurred but disagreed it was associated
with a violation of 10 CFR Part 50, Appendix B, Criterion III, as stated in the inspection
report. Rather, MNGP stated the performance deficiency was associated with a violation of
10 CFR Part 50, Appendix B, Criterion V.
NRC STAFF ASSESSMENT OF DISPUTED NCV 05000263/2015007-02
2
2. ORIGINAL ENFORCEMENT DECISION
The original enforcement decision as stated in Inspection Report 05000263/2015007 was:
Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that
measures shall be established for the selection and review for suitability of application of
materials, parts, equipment, and processes that are essential to the safety-related functions
of structures, systems, and components.
Contrary to the above, as of July 24, 2015, the licensee failed to establish measures to
ensure the selection and review for suitability of application of materials, parts, equipment,
and processes that were essential to the safety-related functions of structures, systems or
components. Specifically, the licensee did not review for suitability of application of
safety-related Agastat and General Electric relays and motor starter contactors that
exceeded their service life, a condition nonconforming to their design basis, to justify their
continued service considering in-service deterioration.
3. LICENSEE POSITION
In a letter dated October 2, 2015, the licensee stated MNGP agreed a performance
deficiency occurred but disagreed it was associated with a violation of 10 CFR Part 50,
Appendix B, Criterion III, as stated in the inspection report. The letter further stated MNGP
believed the performance deficiency was associated with 10 CFR Part 50, Appendix B,
Criterion V. The basis for the licensees position was, in part, that regulatory requirements
(including Criterion V) required the establishment of maintenance schedules as opposed to
strictly adhering to vendor recommendations or formally evaluating deviations from those
recommendations under a quality assurance program established to meet 10 CFR Part 50,
Appendix B. The licensee agreed it had not established a preventive maintenance schedule
for replacing specific Agastat and General Electric relays or motor starter contactors. In
addition, the licensee asserted that issuance of NCV 05000263/2015007-02 was premature
because the underlying NRC staff position may be changed due to the ongoing
development of a Regulatory Issue Summary (RIS) by the NRC.
4. NRC STAFF REVIEW
The NRC staff considered MNGPs assertion that regulatory requirements and NRC
endorsed quality assurance program standards do not require licensees to strictly adhere
to vendor recommendations or formally evaluate deviations from those recommendations
under the Appendix B quality assurance program. The NRC staff agreed that a licensee
may not have requirements involving strict adherence to vendor recommendations, unless
specified in other design and licensing basis documents. However, the NRC staff
determined that current regulations required licensees to establish quality assurance
programs and supporting procedures that, among other things, set preventive maintenance
schedules for the inspection or replacement of parts that have a specific lifetime.
In this case, the licensees preventive maintenance template used for scheduling preventive
maintenance activities established a specific lifetime for safety-related relays and contactors
classified as critical components. However, no preventive maintenance schedule or
associated procedures were developed for safety-related relays and motor starter
contactors classified as non-critical components.
NRC STAFF ASSESSMENT OF DISPUTED NCV 05000263/2015007-02
3
As discussed in the licensees letter, the failure to develop procedures to ensure continued
quality of the safety-related relays and motor starter contactors during the equipment
operational phase could be dispositioned as a violation of 10 CFR Part 50, Appendix B,
Criterion V, which requires, in part, activities affecting quality to be prescribed by
documented procedures of a type appropriate to the circumstances. Similarly, the issue
could be dispositioned as a violation of Technical Specification Section 5.4.1, Procedures,
which requires, in part, the establishment, implementation, and maintenance of written
procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February
1978. Section 9 of the Regulatory Guide requires the development of preventive
maintenance schedules and associated procedures for the inspection or replacement
of parts that have a specific lifetime.
Finally, the staff considered the licensees position that any inspection finding in this matter
should await the development of a RIS. Since the licensees letter, the NRC decided to not
issue a RIS as explained in the Statements of Considerations published by the NRC in
83 FR 46199 (September 12, 2018). Instead of issuing a RIS, the NRC provided training to
inspectors in 2018 to, in part, assist them in identifying and dispositioning issues related to
how long safety-related structures, systems, and components remain in service and clarify
the applicability of various regulations and industry standards.
5. CONCLUSION
The NRC staff carefully considered the information provided by MNGP in its letter
dated October 2, 2015, and determined the original enforcement decision of
NCV 05000263/2015007-02 should be modified as follows:
Technical Specification 5.4.1, Procedures, states, in part, that written procedures shall
be established, implemented, and maintained covering the applicable procedures
recommended in Regulatory Guide 1.33, Quality Assurance Program Requirements,
Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A,
Section 9, Procedures for Performing Maintenance, requires, in part, that preventive
maintenance schedules shall be developed for the inspection or replacement of parts that
have a specific lifetime.
Contrary to the above, as of July 24, 2015, the licensee failed to establish, implement
and maintain applicable procedures recommended in Section 9 of Regulatory Guide 1.33,
Revision 2, Appendix A, February 1978. Specifically, the licensee did not develop a
preventive maintenance schedule for inspecting or replacing various safety-related relays
and motor starter contactors classified as non-critical, which had a specific lifetime.
6. REFERENCES
1. Letter from Mohammed A. Shuaibi to Aby S. Mohseni; Final Task Interface
AgreementRegulatory Position on Design Life of Safety-Related Structures, Systems,
and Components Related to Unresolved Items at Donald C. Cook Nuclear Power Plant,
Monticello Nuclear Generating Plant, and Palisades Nuclear Plant (TIA 2014-01);
May 7, 2015.
NRC STAFF ASSESSMENT OF DISPUTED NCV 05000263/2015007-02
4
2. Letter from Christine A. Lipa to Mr. Peter A. Gardner; Monticello Nuclear Generating
Plant NRC Component Design Bases Inspection Report 05000263/2015007;
September 2, 2015.
3. Letter from Peter A. Gardner to the NRC Document Control Desk; Response to
Non-Cited Violation Dated September 2, 2015; October 2, 2015.
4. Letter from Edwin M. Hackett to Victor M. McCree; Committee to Review Generic
Requirements: Minutes of Meeting Numbers 446 and 447; October 17, 2017.
5. Definitions; 10 CFR 50.2; 2015-2017.
6. Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants;
10 CFR Part 50, Appendix B; 2015-2017.
7. Requirements for monitoring the effectiveness of maintenance at nuclear power plants;
10 CFR 50.65; 2015-2017.
8. Regulatory Guide 1.33; February 1978; Quality Assurance Program Requirements;
U.S. Nuclear Regulatory Commission; Washington, DC.
9. Regulatory Guide 1.186; December 2000; Guidance and Examples for Identifying
10 CFR 50.2 Design Bases; U.S. Nuclear Regulatory Commission; Washington, DC.
10. 34 FR 6599; Quality Assurance Criteria for Nuclear Power Plants; Federal Register;
Volume 34; p. 6599; Washington, DC; April 17, 1969.
11. 35 FR 10498; Quality Assurance Criteria for Nuclear Power Plants; Federal Register;
Volume 35; p. 10498; Washington, DC; June 27, 1970.
12. 48 FR 2729; Environmental Qualification of Electric Equipment Important to Safety
for Nuclear Power Plants; Federal Register; Volume 48; p. 2729; Washington, DC;
January 21, 1983.
13. 60 FR 22478; Nuclear Power Plant License Renewal; Federal Register; Volume 60;
p. 22478; Washington, DC; May 8, 1995.
14. 81 FR 30571; Disposition of Information Related to the Time Period That Safety-
Related Structures, Systems, or Components Are Installed; Federal Register;
Volume 81; p. 30571; Washington, DC; May 17, 2016.
15. 83 FR 46199; Disposition of Information Related to the Time Period That Safety-
Related Structures, Systems, or Components Are Installed; Federal Register;
Volume 83; p. 46199; Washington, DC; September 12, 2018.
16. NRC Enforcement Manual; Revisions 9 and 10.
17. NRC Enforcement Policy; February 4, 2015, and November 1, 2016.
18. Revised Appendix B to NEI 97-04; Guidance and Examples for Identifying 10 CFR 50.2
Design Bases; November 2000.
NRC STAFF ASSESSMENT OF DISPUTED NCV 05000263/2015007-02
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19. Inspector Guidance (Training) on Service Life Issues; June 2018; ML18219A470.
20. SL-009555; Preventive Maintenance Optimization for Agastat Relays using Refine
Maintenance Optimization, Revision 0.
21. SL-009558; Preventive Maintenance Optimization for G.E. Relays using Refine
Maintenance Optimization, Revision 0.
22. Issue ID 500001446684; MNGP Relay Program Issues; September 15, 2014.
23. Work Order 700029534-0010; One-Time Relay Replacement-23A-K9; June 13, 2018.