IR 05000263/2009006

IR 05000263-09-006, on 03/23/2009 - 05/08/0009, Monticello Nuclear Generating Plant, Post-Approval Site Inspection for License Renewal IP 71003

ML091540669
Person / Time
Site:	Monticello
Issue date:	06/02/2009
From:	Ann Marie Stone NRC/RGN-III/DRS/EB2
To:	O'Connor T Northern States Power Co
References
IR-09-006 IR-09-006
Download: ML091540669 (14)

Text

UNITED STATES une 2, 2009

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT NRC POST APPROVAL SITE INSPECTION FOR LICENSE RENEWAL INSPECTION REPORT 05000263/2009006

Dear Mr. OConnor:

On May 8, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed a post-approval site inspection for license renewal at your Monticello Nuclear Generating Plant. The enclosed report documents the inspection findings, which were discussed on May 8, 2009, with Mr. John Grubb and other members of your staff.

This inspection was an examination of activities conducted under your renewed license as they relate to the completion of commitments made during the renewed license application process and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The NRC staff did not identify any instances of incomplete commitments with respect to timeliness or adequacy.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-263 License No. DPR-22 Enclosure: Inspection Report 05000263/2009006 w/Attachment: Supplemental Information cc w/encl: D. Koehl, Chief Nuclear Officer Manager, Nuclear Safety Assessment P. Glass, Assistant General Counsel Nuclear Asset Manager, Xcel Energy, Inc.

J. Stine, State Liaison Officer, Minnesota Department of Health Commissioner, Minnesota Pollution Control Agency R. Hiivala, Auditor/Treasurer, Wright County Government Center Commissioner, Minnesota Department of Commerce Manager - Environmental Protection Division Minnesota Attorney Generals Office

SUMMARY OF FINDINGS

IR 05000263/2009006; 03/23/09 - 05/08/09; Monticello Nuclear Generating Plant; Post-

Approval Site Inspection for License Renewal IP 71003.

The inspection was conducted by two regional based inspectors and the resident inspector. No instances were noted of incomplete license renewal commitments with respect to timeliness or adequacy. The significance of most findings is indicated by their color (Green, White, Yellow,

Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

Summary of Plant Status

Monticello Nuclear Generating Plant was in a refueling outage during the period of this inspection.

4OA5 License Renewal Commitment Implementation and Completion (Phase 1) - IP 71003

.1 Commitment Sample Selection Process

The inspectors reviewed supporting documents including completed surveillance, conducted interviews, performed visual inspection of structures and components including those not accessible during power operation, and observed selected activities described below to verify the licensee completed the necessary actions to comply with the license conditions that are a part of the renewed operating license. The inspectors reviewed the licensee implementation of the aging management programs included in the staffs license renewal safety evaluation report (SER) in accordance with Title 10 of the Code of Federal Regulations (CFR) Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants.

The commitments selected were those with activities that could only be completed during an outage. The selected commitments are discussed below.

.2.1 Electrical Cables & Connections Not Subject To 10 CFR 50.49 Environmental

Qualification Requirements

a. Inspection Scope

The inspectors reviewed the licensees activities to implement commitment item number 26, of the Monticello NRC license renewal SER. This commitment documents that the licensee agreed to develop an aging management program consistent with NUREG-1801, Generic Aging Lessons Learned,Section XI.E1.

The inspectors interviewed the program owner and reviewed the implementing procedure and records of completed inspections. Specific documents are listed in the attachment. This program specifies that a representative sample of accessible electrical cables and connections installed in adverse localized environments are visually inspected at least once every 10 years. The first inspection for license renewal is to be completed before the period of extended operation. The inspectors observed visual cable inspections in the condenser bay.

b. Findings and Observations

The inspectors concluded that this commitment has not been completed to date.

.2.2 Inaccessible Medium Voltage (2kV to 34.5kV) Cables Not Subject to 10 CFR 50.49 EQ

Requirements

a. Inspection Scope

The inspectors reviewed the licensees activities to implement commitment item number 36, of the Monticello NRC license renewal SER. This commitment documents that the licensee agreed to develop an aging management program consistent with NUREG-1801, Generic Aging Lessons Learned,Section XI.E3.

The inspectors interviewed the program owner and reviewed the implementing procedure and records of completed inspections. Specific documents are listed in the attachment. This program includes requirements for testing in scope cables prior to the period of extended operation. The inspectors reviewed records of cable testing associated with the 2R transformer. This testing included Time Domain Reflectometry, Tan Delta/Dissipation Factor Testing, Very Low Frequency 30 Minute Withstand, and Partial Discharge Testing. Inspectors observed feedwater pump cable testing which was representative of the aging management program testing. Testing of other cables in scope for LR had been scheduled for this outage but was deferred to a future planned outage.

This program includes requirements for inspecting manholes containing in-scope cables for the presence of water. The inspectors reviewed records of manhole inspections including one manhole that was found full of water in September 2008. (Refer to NRC IR 05000263/2008009) This particular manhole, NMH-313, had not been recognized previously, but has since been captured within the monitoring program. Other manholes have been dry when inspected.

b. Findings and Observations

The inspectors concluded that this commitment has not been completed to date.

.2.3 One-Time Inspection Program

a. Inspection Scope

The inspectors reviewed the licensees activities to implement commitment item number 38, of the Monticello NRC license renewal SER. This commitment documents that the licensee agreed to develop an aging management program consistent with NUREG-1801, Generic Aging Lessons Learned,Section XI.M32.

The inspectors interviewed the program owner, reviewed implementing procedures and records of completed inspections, and performed direct observation of nondestructive examinations (NDE) in the field. Specific documents reviewed are listed in the

.

b. Findings and Observations

(1) One Time Inspection Program Implementation

Introduction:

An unresolved item was identified by the inspectors involving conducting one-time inspections with personnel and procedures that did not appear consistent with licensee commitments.

Description:

The inspectors were concerned that the One-Time Inspection Program implementation to date had not been entirely consistent with the licensees commitment.

The Monticello NRC license renewal SER documents that the licensee agreed to develop an aging management program consistent with NUREG-1801 Rev 0, Generic Aging Lessons Learned,Section XI.M32. This section describes a program where inspections are performed by qualified personnel following procedures consistent with the ASME Code and 10 CFR 50, Appendix B. The licensee implemented this as a requirement in Monticello procedures including License Renewal One Time Inspection Methods and 4 AWI-07.03.01, Nondestructive Examination Techniques, which required that personnel conducting NDE in support of license renewal to be certified in accordance with FP-PE-NDE-03.

The inspectors were concerned that procedures used in work order (WO) 0157972 and WO 284608 were not the procedures specified in the One Time Inspection Methods program document. The licensee also documented instances where inspections were conducted by personnel who were not certified in accordance with station procedures.

The licensee entered this issue into the corrective action program as CAP 01175477.

This issue is being opened as an unresolved item (URI) to be reviewed in context during the Inspection Procedure (IP) 71003 team inspection. (URI 05000263/2009006-01)

(2) Potential Failure to Follow Procedures

Introduction:

An unresolved item was identified by the inspectors involving a potential failure to follow procedures during an NDE exam for the one-time inspection program.

Description:

The inspectors were concerned that an NDE examiner did not follow procedures during WO 346293. The licensee captured this concern in AR 1175537.

This issue is being opened as a URI pending further investigation into the issue.

(URI 05000263/2009006-02)

(3) Adequacy of the One-Time Inspection Program

Introduction:

An unresolved item was identified by the inspectors involving potential inadequacies in the One-Time Inspection Program.

Description:

The inspectors were concerned that indication of degradation had not been evaluated in context of the on-time inspection program. The inspectors identified WO 267268 and WO 293396, where measured wall thickness was below the evaluation threshold. The equipment was evaluated to be acceptable, based upon minimum wall thickness, but the indicated degradation was not further evaluated in the context of demonstrating the extent of aging effects. The licensee captured these concerns in AR 1175752 and AR 1175545 respectively for these two work orders.

The inspectors were also concerned about the adequacy of procedures used to identify pitting corrosion. WO 346293-01 dealt with the one-time ultrasonic thickness (UT)examination of the Reactor Core Isolation Cooling system barometric condenser using UT procedure FP-PE-NDE-425 (Revision 1).

This examination was to measure thickness of the material to detect the aging effect of loss of material due to corrosion, including pitting corrosion. The examination performed consisted of linear, circumferential checks, every six inches along the length of the condenser with a 0 degree transducer. The diameter of the transducer used, and therefore the approximate width of each scan, was roughly 0.30. The inspectors were also concerned that this examination was not likely to detect pitting due to the small area examined and type of transducer used.

This examination adequacy issue is considered a URI pending review of the entire one time inspection program in context during the IP 71003 team inspection. (URI 05000263/2009006-03).

The licensee indicated that this commitment is not complete as not all sample selections had been made. The inspectors agreed that this commitment has not been completed to date.

.2.4 Protective Coating Monitoring and Maintenance Program

a. Inspection Scope

The inspectors reviewed the licensees activities to implement Commitment Items 39, 40, 41, and 54 of the Monticello NRC License Renewal Safety Evaluation Report. These commitments document licensee agreement to revise procedures implementing the Protective Coating Monitoring and Maintenance Program. This program, which applies to Service Level 1 protective coatings inside containment, addresses NRC GL 98-04, Potential for Degradation of the Emergency Core Cooling System and the Containment Spray System after a Loss-of-Coolant Accident because of Construction and Protective Coating Deficiencies and Foreign Material in Containment. The procedure changes included inspection of all accessible painted surfaces inside containment; pre-inspection review of the previous two inspection reports to identify trends; provisions for analysis of suspected reasons for coating failure; and, requirements for coating inspectors to meet the requirements of ANSI N45.2.6, Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants.

The inspectors reviewed the applicable inspection procedures that contained the revisions:

0135, Pressure-Suppression Chamber Painted Surface Internal Inspection; 0140, Drywell Interior Surface Inspection; and 1367, Pressure-Suppression Chamber Below Water Line Painted Surface Inspection. The inspectors also accompanied the licensee during the performance of the 0135 and 0140 inspections inside the drywell and torus.

b. Findings and Observations

The inspectors determined that the licensee has completed commitment Items 39, 40, 41, and 54 of the Monticello NRC License Renewal Safety Evaluation Report, associated with the Protective Coating Monitoring and Maintenance Program.

The licensee initiated CAP 01175535 following questions from the inspectors regarding inspection of all accessible areas of the drywell. Specifically, the 0140 procedure did not include a separate inspection area for coated surfaces below the reactor vessel. The licensee revised 0140 to include the under-vessel area and appropriate inspections were conducted prior to evaluating all identified degraded coatings.

4OA6 Management Meetings

.1 Exit Meeting Summary

On May 8, 2009, the inspectors presented the inspection results to Mr. John Grubb and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Grubb Engineering Director

S. Porter Manager, Engineering Programs

P. Young Regulatory Programs Supervisor

J. Rootes License Renewal Coordinator

B. Dixon EQ Coordinator

D. Potter Fleet ISI and NDE Supervisor

R. Siepel Design Engineering, Electrical

J. Bridgeman Program Engineering, Inspection and Materials

LIST OF ITEMS

Opened

05000263/2009006-01 URI One Time Inspection Program Implementation (Section 4OA5.2.3(1))

05000263/2009006-02 URI Potential Failure to Follow Procedures (Section 4OA5.2.3(3))

05000263/2009006-03 URI Adequacy of the One-Time Inspection program (Section 4OA5.2.3(3))

Closed and

Discussed

None Attachment