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VA Monticello Nuclear Generating Plant
NMC
Committed to Nuclear Excel[e
Operated by Nuclear Management Company, LLC
August 11, 2005 L-MT-05-087
10 CFR 50.55a(a)(3)(i)
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, DC 20555
Monticello Nuclear Generating Plant
Docket 50-263
License No. DPR-22
10 CFR 50.55a Request No. 12: Proposed Alternative for Visual Examination
Illumination Levels in Accordance With 10 CFR 50.55a(a)(3)(i)
Pursuant to 10 CFR 50.55a(a)(3)(i), the Nuclear Management Company, LLC (NMC)
requests U.S. Nuclear Regulatory Commission (NRC) authorization for application of
the enclosed 10 CFR 50.55a request to the Fourth Ten-Year Interval Inservice
Inspection (ISI) Program at the Monticello Nuclear Generating Plant (MNGP).
NMC identified five VT-2 examinations (done in conjunction with post-repair/replacement
pressure tests) where illumination levels were not verified in accordance with Section Xl,
IWA-2210, "Visual Examinations," of the American Society of Mechanical Engineers
(ASME) Boiler and Pressure Vessel Code. Authorization is requested on a one-time
basis, for the use of an alternative method that was applied to verify illumination levels for
these five VT-2 examinations (performed in 2003 and 2004), in lieu of the Section Xl,
IWA-2210 requirements, as described within the 10 CFR 50.55a request provided in
Enclosure 1.
This letter contains no new commitments and makes no revisions to existing
commitments.
Johr/Conway
Site V e President, Monticello Nuclear Generating Plant
Nuc ar Management Company, LLC
Enclosure
cc: Administrator, Region l1l, USNRC
Project Manager, Monticello, USNRC
Resident Inspector, Monticello, USNRC
Minnesota Department of Commerce (Attn: L. Brandon) g
2807 West County Road 75 . Monticello, Minnesota 55362-9637
Telephone: 763.295.5151 * Fax: 763.295.1454
ENCLOSURE 1
10 CFR 50.55a REQUEST NO. 12
PROPOSED ALTERNATIVE FOR VISUAL EXAMINATION ILLUMINATION LEVELS
IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)
1. ASME Code Component(s) Affected
Component and System ASME
Code Class
Control Rod Drive (CRD) System Hydraulic Control Unit 2
(HCU) 26-27
Residual Heat Removal-Service Water (RHRSW) System 3
Pump 12
RHRSW System Pump 14 3
Emergency Diesel Generator-Emergency Service Water 3
(EDG-ESW) System Pump 11
EDG-ESW System Pump 12 3
2. Applicable ASME Section Xi Code Edition and Addenda
The applicable Code for Repair/Replacement and related activities is the 2001
Edition, No Addenda as authorized in the Monticello Nuclear Generating Plant
(MNGP) Fourth Ten-Year Interval Inservice Inspection (ISI) Program
IOCFR50.55a Request No. 7, October 3, 2003 (TAC No. MB6897).
3. Applicable Code Requirement
The American Society of Mechanical Engineers (ASME) Boiler and Pressure
Vessel Code, Section Xl, IWA-2210, "Visual Examinations," provides the
following requirements (meeting either of which would be sufficient to
demonstrate adequate illumination) for conducting visual examinations.
IWA-221 0(e) specifies the following requirements for illumination levels:
"It is not necessary to measure illumination levels on each examination
surface when the same portable light source or similar installed lighting
equipment is demonstrated to provide the illumination specified in Table
IWA-2500-1 at the maximum examination distance."
Page 1 of 4
ENCLOSURE 1
10 CFR 50.55a REQUEST NO. 12
PROPOSED ALTERNATIVE FOR VISUAL EXAMINATION ILLUMINATION LEVELS
IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)
IWA-221 0(f) states:
"The adequacy of the illumination levels from battery powered portable
lights shall be checked before and after each examination or series of
examinations, not to exceed 4 hr between checks. In lieu of using a light
meter, these checks may be made by verifying that the illumination is
adequate (i.e., no discernable degradation in the visual examination
resolution of the procedure demonstration test chart characters)."
4. Reason for Request:
NMC identified five VT-2 examinations, performed in conjunction with
post-repair/replacement pressure tests (during the first period of the current
10-year ISI interval), which were not performed in accordance with the
illumination requirements of IWA-2210 and could not be re-performed.' The
illumination levels were not verified as required. Authorization is requested to
utilize an alternative method that was used to verify the illumination levels, as
described in Section 5.
The five VT-2 examinations were performed using portable battery-powered
lights (a standard practice to ensure adequate lighting). However, due to a
procedural inadequacy, the illumination levels were not verified before and after
each VT-2 examination as specified in IWA-221 0(f), nor were the illumination
levels demonstrated pursuant to IWA-2210(e). (This procedural inadequacy is
tracked and is being corrected under the MNGP Corrective Action Program.)
Consequently, without verifying the illumination levels of the portable
battery-powered lights or ambient light conditions, only the knowledge and skill of
the certified VT-2 examiner was available to attest that the lighting conditions
were adequate for the five VT-2 examinations. Because it could not initially be
verified that the lighting levels were acceptable, it was conservatively assumed
that the requirements of IWA-221 0 were not met for these five VT-2
examinations.
Listed below are the five pressure tests, which could not be re-performed,* where
the VT-2 examination illumination levels could not initially be determined as
acceptable:
The replaced components were restored to operable status prior to the
identification of this illumination concern with the VT-2 examinations. The
pre-service pressure testing required by IWA-4540 (and associated VT-2
examinations) cannot be re-performed because the associated systems were
restored to service.
Page 2 of 4
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ENCLOSURE I
10 CFR 50.55a REQUEST NO. 12
PROPOSED ALTERNATIVE FOR VISUAL EXAMINATION ILLUMINATION LEVELS
IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)
RJR Plan Work Description Examination
Number WokDsrpinDate
2003-22-0011 Replace accumulator on 10/26/03
HCU 26-27
2003-22-0012 Replace EDG-ESW Pump 12 with 12/4/03
2003-22-0014 rebuilt spare from stock. 12/4/03
2003-22-0014 Replace RHRSW Pump 14 with 11/7/03
rebuilt spare from stock.
2003-22-0021 Replace RHRSW Pump 12 with 11/21/03
rebuilt spare from stock.
2004-22-0062 Replace EDG-ESW Pump 11 with 11/15/04
1rebuilt spare from stock.
5. Proposed Alternative and Basis for Use
The proposed illumination alternative for the five VT-2 examinations is based
upon the following three factors. First, the possession of the knowledge and skill
by the certified VT-2 examiners, and their attestation that there was sufficient
lighting for them to properly perform the examinations. Second, the use of
battery-powered portable lights by the VT-2 examiners, which provided additional
illumination (beyond ambient) during the examinations. Third, a walk-down of the
areas where the VT-2 examinations were conducted was performed by the site
Nondestructive Examination (NDE) Level IlIl, to verify the ambient illumination
level provided by the permanent plant lighting was adequate to meet the
requirements of IWA-2210, as described below.
Upon discovery of the five post-repair/replacement pressure tests, for which the
VT-2 examination illumination levels could not be initially be determined as
acceptable, the site NDE Level IlIl walked-down each location and performed
illumination checks where the VT-2 examinations had been conducted.
Illumination checks were performed using a light meter and/or a character card.
The illumination checks were done to establish whether the existing permanently
installed plant (ambient) lighting provided reasonable assurance of sufficient
illumination at each location to comply with IWA-221 0(e) illumination
requirements during the performance of the VT-2 examinations.
Page 3 of 4
ENCLOSURE I
10 CFR 50.55a REQUEST NO. 12
PROPOSED ALTERNATIVE FOR VISUAL EXAMINATION ILLUMINATION LEVELS
IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)
The results of these illumination checks provided reasonable assurance that the
ambient illumination levels at the components, using the existing permanently
installed plant lighting, were sufficient to meet IWA-2210 requirements. Also,
during performance of these illumination checks, the NDE Level IlIl examiner did
not identify any indications of leakage from the pressure-tested components.
Based on the following factors, NMC considers the proposed alternative to be
acceptable:
* Walk-downs following the VT-2 examinations indicate that the ambient
illumination provided by the permanent plant lighting was sufficient,
* The skill and knowledge of the certified VT-2 examiners attesting to a light
level sufficient for them to perform their examinations, and
* The VT-2 examiners used battery-powered portable lights (which provided
additional illumination above ambient) during the VT-2 examinations.
Therefore, NMC considers the proposed method, consisting of the three factors
listed above, to be an acceptable alternative to the lighting verification required
by IWA-2210 during the performance of the five VT-2 examinations. NMC
believes that the proposed alternative provided an acceptable level of quality and
safety.
NMC requests a one-time approval for the use of the alternative method
previously described, that was applied for verifying the illumination levels for the
five VT-2 examinations associated with the post-repair/replacement pressure
tests identified in this 10 CFR 50.55a request.
6. Duration of Proposed Alternative
NMC requests a one-time approval of the alternative method that was applied for
determining the illumination levels for the five VT-2 examinations (for the subject
components specified in Section 1) for the first period of the current fourth
ten-year ISI interval for the MNGP.
Page 4 of 4
