ML040050075

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Corrected Page for Fourth 10-Year Interval Inservice Inspection Program Plan Relief Request No. 7
ML040050075
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 12/31/2003
From: Padovan L
Division of Nuclear Materials Safety III
To: Thomas J. Palmisano
Nuclear Management Co
References
TAC MB6897
Download: ML040050075 (3)


Text

December 31, 2003 Mr. Thomas J. Palmisano Site Vice President Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT ISSUANCE OF CORRECTED PAGE FOR FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN RELIEF REQUEST NO. 7 (TAC NO. MB6897)

Dear Mr. Palmisano:

Our letter of October 3, 2003 (ADAMS Accession No. ML032040157), authorized an alternative pursuant to Title 10 of the Code of Federal Regulations, Section 50.55a(a)(3)(ii),

allowing the Nuclear Management Company, LLC, to use the 2001 edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, for repair/replacement activities and procedures. Your Monticello licensing staff noted a minor editorial error in our safety evaluation. Section 3.4 (page 5, line 4) of the safety evaluation should have referred to paragraph IWA-4540(c) of the 1998 edition of the ASME Code instead of paragraph IWA-4540. This letter forwards a corrected page 5.

Sincerely,

/RA/

L. Mark Padovan, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-263

Enclosure:

Corrected Safety Evaluation page 5 cc w/encl: See next page

ML032040157), authorized an alternative pursuant to Title 10 of the Code of Federal Regulations, Section 50.55a(a)(3)(ii),

allowing the Nuclear Management Company, LLC, to use the 2001 edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, for repair/replacement activities and procedures. Your Monticello licensing staff noted a minor editorial error in our safety evaluation. Section 3.4 (page 5, line 4) of the safety evaluation should have referred to paragraph IWA-4540(c) of the 1998 edition of the ASME Code instead of paragraph IWA-4540. This letter forwards a corrected page 5.

Sincerely,

/RA/

L. Mark Padovan, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-263

Enclosure:

Corrected Safety Evaluation page 5 cc w/encl: See next page DISTRIBUTION:

PUBLIC OGC GHill(2)

PDIII-1 Reading ACRS RBouling LRaghavan EReichelt BBurgess, RGN-III LPadovan TChan ADAMS Accession No. ML040050075 OFFICE PDIII-1/PM PDIII-1/LA PDIII-1/SC NAME LPadovan RBouling LRaghavan DATE 12/31/03 12/31/03 12/31/03 Monticello Nuclear Generating Plant cc:

Jonathan Rogoff, Esquire Commissioner Vice President, Counsel & Secretary Minnesota Department of Commerce Nuclear Management Company, LLC 121 Seventh Place East 700 First Street Suite 200 Hudson, WI 54016 St. Paul, MN 55101-2145 U.S. Nuclear Regulatory Commission Manager - Environmental Protection Division Resident Inspectors Office Minnesota Attorney Generals Office 2807 W. County Road 75 445 Minnesota St., Suite 900 Monticello, MN 55362 St. Paul, MN 55101-2127 Manager, Regulatory Affairs John Paul Cowan Monticello Nuclear Generating Plant Executive Vice President & Chief Nuclear Nuclear Management Company, LLC Officer 2807 West County Road 75 Nuclear Management Company, LLC Monticello, MN 55362-9637 700 First Street Hudson, WI 54016 Robert Nelson, President Minnesota Environmental Control Nuclear Asset Manager Citizens Association (MECCA) Xcel Energy, Inc.

1051 South McKnight Road 414 Nicollet Mall, R.S. 8 St. Paul, MN 55119 Minneapolis, MN 55401 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 October 2003

testing requirements on a plant-specific basis. This potentially allows different utility organizations to implement inadequate or inconsistent pressure-testing practices and requirements for the same types of repair and replacement activities. Therefore, the NRC staff requires implementation of paragraph IWA-4540(c) of the 1998 edition in lieu of that of the 2001 l edition when implementing the 2001 edition of ASME Code,Section XI, Article IWX-4000 for repair and replacement activities. The NRC staff recognizes that the 1999 addenda through the 2000 addenda of the ASME Code has been incorporated by reference in 10 CFR 50.55a without referencing a limitation paragraph IWA-4540(c). The NRC staff will address this in an upcoming rulemaking regarding the incorporation by reference of the 2001 edition through the 2002 addenda of the ASME Code into 10 CFR 50.55a.

NMC has committed to implement the limitations and modifications to the 1998 edition through 2000 addenda of the ASME Code,Section XI, as stated in 10 CFR 50.55a(b)(2) when implementing the 2001 edition. NMC has further committed to implement any limitations and modifications to the 2001 edition of the ASME Code for its repair and replacement program when the NRC incorporates, by reference, this edition into the regulations. As a result, updating the two separate repair/replacement programs to meet the 2001 edition of the ASME Code,Section XI, including all the related requirements, as NMC proposed, and including paragraph IWA-4540(c) of the 1998 edition of the ASME Code as discussed above, provides an acceptable alternative. When the 2001 edition of the ASME Code is incorporated by reference in 10 CFR 50.55a, NMC must comply with all limitations and modifications stated in the regulations, if any, regarding the implementation of the 2001 edition of the ASME Code, as applied to Relief Request No. 7.

4.0 CONCLUSION

Based on the above, the NRC staff concludes that updating two separate repair/replacement programs at Monticello to meet the 2001 edition of the ASME Code Section XI, including all related requirements, as NMC proposes and as modified by the staff, provides an acceptable alternative pursuant to 10 CFR 50.55a(a)(3)(ii). Maintaining two separate repair/replacement programs will result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the NRC staff authorizes NMCs proposed alternative, and as modified by the NRC staff, pursuant to 10 CFR 50.55a(a)(3)(ii) for the fourth 10-year ISI interval at Monticello. When the 2001 edition of the ASME Code is incorporated by reference in 10 CFR 50.55a, NMC must comply with all limitations and modifications, if any, regarding the implementation of the 2001 edition of the ASME Code, as applied to RR-7. All other ASME Code,Section XI, requirements for which relief was not specifically requested and authorized herein by the NRC staff remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: E. Reichelt Date: October 3, 2003 Corrected by NRC letter dated December 31, 2003 l