UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

May 13, 2011

Mr. Timothy J. O’Connor

Site Vice President

Monticello Nuclear Generating Plant

Northern States Power Company, Minnesota

2807 West County Road 75

Monticello, MN 55362-9637

SUBJECT: MONTICELLO NUCLEAR GENERATING PLANT – NRC TEMPORARY 

INSTRUCTION 2515/183 INSPECTION REPORT 05000263/2011009

Dear Mr. O’Connor: 

On April 29, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at 

your Monticello Nuclear Generating Plant, using Temporary Instruction 2515/183, “Followup to 

the Fukushima Daiichi Nuclear Station Fuel Damage Event.” The enclosed inspection report 

documents the inspection results which were discussed on April 26, 2011, with Mr. John Grubb

and other members of your staff. 

The objective of this inspection was to promptly assess the capabilities of Monticello Nuclear 

Generating Plant to respond to extraordinary consequences similar to those that have recently 

occurred at the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, 

along with the results from this inspection performed at other operating commercial nuclear 

plants in the United States, will be used to evaluate the U.S. nuclear industry’s readiness to

safely respond to similar events. These results will also help the NRC to determine if additional 

regulatory actions are warranted.

All of the potential issues and observations identified by this inspection are contained in this 

report. The NRC’s Reactor Oversight Process will further evaluate any issues to determine if 

they are regulatory findings or violations. Any resulting findings or violations will be documented 

by the NRC in the next quarterly report. You are not required to respond to this letter. 
T. O'Connor -2-

In accordance with 10 CFR 2.390 of the NRC’s “Rules of Practice,” a copy of this letter 

and its enclosure will be made available electronically for public inspection in the NRC 

Public Document Room or from the Publicly Available Records (PARS) component of 

NRC’s document system (ADAMS), accessible from the NRC Web site at 

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Kenneth Riemer, Chief

Branch 2

Division of Reactor Projects

Docket No. 50-263

License No. DPR-22

Enclosure: Inspection Report 05000263/2011009

cc w/encl: Distribution via ListServe
Enclosure

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-263

License No: DRP-22

Report No: 05000263/2011009

Licensee: Northern States Power Company, Minnesota

Facility: Monticello Nuclear Generating Plant

Location: Monticello, Minnesota

Dates: March 23 through April 29, 2011

Inspector: S. Thomas, Senior Resident Inspector

Approved by: Kenneth Riemer

Branch 2

Division of Reactor Projects
1 Enclosure

SUMMARY OF FINDINGS

IR 05000263/2011009, 03/23/2011 – 04/29/2011; Monticello Nuclear Generating Plant 

Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel 

Damage Event. 

This report covers an announced Temporary Instruction (TI) inspection. The inspection was 

conducted by Resident and Region III inspectors. The NRC’s program for overseeing the 

safe operation of commercial nuclear power reactors is described in NUREG-1649, 

“Reactor Oversight Process,” Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the TI is to provide a broad overview of the industry’s preparedness for events 

that may exceed the current design basis for a plant. The focus of the TI was on 

(1) assessing the licensee’s capability to mitigate consequences from large fires or explosions 

on site, (2) assessing the licensee’s capability to mitigate station blackout (SBO) conditions, 

(3) assessing the licensee’s capability to mitigate internal and external flooding events 

accounted for by the station’s design, and (4) assessing the thoroughness of the licensee’s 

walk downs and inspections of important equipment needed to mitigate fire and flood events to 

identify the potential that the equipment’s function could be lost during seismic events possible 

for the site. If necessary, a more specific follow-up inspection will be performed at a later date.

INSPECTION RESULTS

All of the potential issues and observations identified by this inspection are contained in this 

report. The NRC’s Reactor Oversight Process will further evaluate any issues to determine if 

they are regulatory findings or violations. Any resulting findings or violations will be documented 

by the NRC in the next quarterly report. 
2 Enclosure

03.01 Assess the licensee’s capability to mitigate conditions that result from beyond design basis events, typically bounded by 

security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident 

management guidelines as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54 (hh). Use Inspection Procedure 

(IP) 71111.05T, “Fire Protection (Triennial),” Section 02.03 and 03.03 as a guideline. If IP 71111.05T was recently performed at 

the facility, the inspector should review the inspection results and findings to identify any other potential areas of inspection. 

Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited 

to, an assessment of any licensee actions to:

Licensee Action Describe what the licensee did to test or inspect equipment.

a. Verify through test or inspection 

that equipment is available and 

functional. Active equipment 

shall be tested and passive 

equipment shall be walked down 

and inspected. It is not 

expected that permanently 

installed equipment that is 

tested under an existing 

regulatory testing program be 

retested. 

This review should be done for a 

reasonable sample of mitigating 

strategies/equipment.

The licensee performed walkdowns with qualified operators and discussions took place 

regarding the use of the procedures and the desired result, as well as the required 

equipment. Equipment inventories were completed using approved site procedures with 

all gaps noted in the corrective action process. Monticello has the capability to mitigate 

conditions that result from beyond basis events, typically bounded by security threats, 

committed to as part of B.5.b licensing process and using severe accident management 

guidelines. The flooding events require materials not currently onsite, but the procedure is 

written assuming the flooding can be predicted allowing for the material to be obtained and 

barriers constructed. 

The following procedures were performed to verify equipment was available and functional:

• 1488; Emergency Operating Procedures (EOP)/Abnormal Operating Procedures 

(AOP) Equipment Inventory;

• 1224; Fire Brigade Equipment Inventory;

• OSP-FIR-0582; Portable Diesel Fire Pump Testing Procedure;

• ESP-125-0583; 125V DC Portable Battery Cart Testing Procedure; and

• IMP-1023; Fluke Model 87V EX Digital Multimeter Performance Test.

Procedure 1224 requires that the operator perform a condition inspection using criteria 

outlined in the procedure. Active equipment, such as the portable diesel fire pump and 

125 VDC battery cart, were tested using approved site procedures. The 1488 procedure 

does not specifically require that an inspection be performed during the equipment 

inventory. Nonetheless, the inventory done for this activity did assess the condition and 

readiness of the equipment. All Emergency Operating Procedure (EOP) equipment was 

validated to be stored in the proper location.
3 Enclosure

Describe inspector actions taken to confirm equipment readiness (e.g., observed a 

test, reviewed test results, discussed actions, reviewed records, etc.).

The inspectors assessed the licensee’s capabilities by conducting a review of the licensee’s 

walkdown activities. In addition, the inspectors independently walked down and inspected a 

sampling of the major B.5.b contingency equipment staged throughout the plant.

Discuss general results including corrective actions by licensee.

During the EOP inventory, equipment was found to be stored in areas that could potentially 

be susceptible to damage during a seismic event. While performing the fire brigade 

inventory (1224), some equipment was not in the proper storage location, and some 

equipment called out in the B.5.b procedures was not on the inventory as expected. 

Corrective actions were documented to correct these issues. The missing equipment from 

the B.5.b procedures is readily available at numerous locations onsite; however, a 

dedicated supply was not in the dedicated B.5.b storage location. Specific corrective action 

program (CAP) documents applicable to this section are listed in Section 3.01(e).

No issues of significance were identified by the inspectors.

Licensee Action Describe the licensee’s actions to verify that procedures are in place and can be 

executed (e.g., walkdowns, demonstrations, tests, etc.).

b. Verify through walkdowns or 

demonstration that procedures 

to implement the strategies 

associated with B.5.b and 

10 CFR 50.54 (hh) are in-place 

and are executable. Licensees 

may choose not to connect or 

operate permanently installed 

equipment during this 

verification. 

This review should be done for a 

reasonable sample of mitigating 

strategies/equipment.

The A.7 – Severe Accident Mitigation Guidelines (SAMG) procedures are in-place and 

executable. This was demonstrated by a tabletop exercise using an Accident Management 

Team (AMT) stationed in the Technical Support Center (TSC) with an operator in the control 

room simulator to demonstrate the communication link. The tabletop exercise challenged 

all legs of the SAMGs. Activities to be performed in the plant were done by operations 

personnel in a walk-through format with an evaluator observing their performance. 

The AMT was able to complete priority actions that would have ensured event mitigation. 

The SAMGs refer to multiple EOP Support Procedures (C.5-3XXX) that are part of the 

regular training cycle for the Operations crews. All actions performed by Operations 

during SAMG situations are in the EOP Support Procedures. Several of the A.8 

(Extensive Damage Mitigation Strategy (EDMG) Overview) procedures that implement the 

B.5.b program requirements are in-place and validated as executable via walkdowns.
4 Enclosure

Describe inspector actions and the sample strategies reviewed. Assess whether 

procedures were in place and could be used as intended.

The inspectors assessed the licensee’s capabilities by conducting a review of the licensee’s 

walkdown activities. In addition, the inspectors selected several sections of a sample of the 

procedures walked down by the licensee and walked them down to independently verify the 

licensee’s conclusions. The inspectors did not observe the performance of the tabletop 

exercise, but did review the exercise materials.

Discuss general results including corrective actions by licensee.

No gaps were identified that would impair the station’s ability to utilize these mitigation 

strategies. Several enhancement opportunities were documented and entered in the 

licensee’s corrective action process. Specific CAP documents applicable to this section are 

listed in Section 3.01(e).

No issues of significance were identified by the inspectors.

Licensee Action Describe the licensee’s actions and conclusions regarding training and qualifications 

of operators and support staff.

c. Verify the training and 

qualifications of operators and 

the support staff needed to 

implement the procedures and 

work instructions are current for 

activities related to Security 

Order Section B.5.b and severe 

accident management 

guidelines as required by 

10 CFR 50.54 (hh). 

The licensee conducted a review of their Emergency Plan (EP) Training Program, as well as 

a qualification search for the number of individuals qualified in each position, via the 

Learning Management System (LMS) tool. The Training Department verified that all 

positions in the six ERO duty teams were staffed by individuals qualified in their associated 

jobs.

Describe inspector actions and the sample strategies reviewed to assess training and 

qualifications of operators and support staff

The inspectors assessed the licensee’s training and qualification activities by conducting a 

review of training and qualification materials and records related to the current Emergency 

Response Organization (ERO) qualifications of the assigned site staff.
5 Enclosure

Discuss general results including corrective actions by licensee.

The training requirements, qualifications, and associated records needed to verify that the 

site’s ERO could be staffed and function during an event, were reviewed by the licensee. 

This recommendation is being met in accordance with site procedures and regulatory 

commitments. No deficiencies were noted when applicable training and qualification 

documents were reviewed. Specific CAP documents applicable to this section are listed in 

Section 3.01(e).

No issues of significance were identified by the inspectors.

Licensee Action Describe the licensee’s actions and conclusions regarding applicable agreements 

and contracts are in place.

d. Verify that any applicable 

agreements and contracts are in 

place and are capable of 

meeting the conditions needed 

to mitigate the consequences of 

these events. 

This review should be done for a 

reasonable sample of mitigating 

strategies/equipment.

The licensee performed a review of B.5.b and SAMG procedures to determine what 

equipment is required from offsite venders to successfully implement their procedures. 

The review was also expanded to include flooding and SBO concerns to consolidate the 

scope and content of the agreements/contracts. The licensee conducted interviews of site 

program owners to determine what contracts were in place and what services, equipment, 

or materials offsite entities had agreed to provide.

For a sample of mitigating strategies involving contracts or agreements with offsite 

entities, describe inspector actions to confirm agreements and contracts are in place 

and current (e.g., confirm that offsite fire assistance agreement is in place and 

current).

The inspectors assessed the licensee’s capabilities by conducting an independent review of 

the licensee’s letters of agreement, memorandums of understanding, and contracts for 

goods and services counted on to successfully implement their SAMGs and EDMGs. 

The inspectors verified that each was current and whether or not each was adequate for 

meeting the licensee’s mitigation strategy.
6 Enclosure

Discuss general results including corrective actions by licensee.

Gaps were identified during the licensee’s review of offsite equipment that might be 

necessary to effectively implement their mitigating strategies. Corrective action documents 

have been initiated for the site to determine what equipment should be available onsite and 

what agreements are adequate for equipment that comes from offsite sources. At this time, 

the site has not made formal agreements to provide all equipment required from offsite 

entities. The licensee has determined that the agreements that are currently in place are 

sufficient to provide resources that the site might request in the event to allow for effective 

utilization of their mitigation strategies. Further review is required to determine what 

equipment should be purchased for onsite storage and what formal agreements should be 

made with offsite suppliers. Specific CAP documents applicable to this section are listed in 

Section 3.01(e).

No issues of significance were identified by the inspectors.
7 Enclosure

Licensee Action

Document the corrective action report number and briefly summarize problems noted 

by the licensee that have significant potential to prevent the success of any existing 

mitigating strategy.

e. Review any open corrective 

action documents to assess 

problems with mitigating 

strategy implementation 

identified by the licensee. 

Assess the impact of the 

problem on the mitigating 

capability and the remaining 

capability that is not impacted.

The following entries into the licensee’s CAP were made to address issues identified during 

the evaluation of IER 11-1; Recommendation 1:

• CAP 1276717; IER 11-1 – Emergency Planning Enhancements

• CAP 1276710; IER 11-1 – SAMG/EOP Procedure Enhancements

• CAP 1276567; IER 11-1 – SAMG/EDMG Training Improvements

• CAP 1280884; IER 11-1 – Improve Training for SAMGs

• CAP 1276416; IER 11-1 – During the 1224 Fire Equipment Inventory, Numerous 

Deficiencies were Found

• CAP 1276377; Abnormal Charger Indication during ESP-125-0583

• CAP 1276324; IER 11-1 - Vulnerabilities (Several Seismic Type Vulnerabilities have 

been Identified)

• CAP 1276101; O2 Storage Rack not Anchored to the Wall

• CAP 1276098; IER 11-1 – Shelves in Alt Fire Brigade Room not Anchored to the 

Wall

• CAP 1276096; IER 11-1 – RCIC Tachometer Found Out of Calibration

• CAP 1276088; Materials Staged Limiting Access to EOP Equipment

• CAP 1276087; IER 11-1 – Training Improvement on Use of SAMG/EDMG in 

Emergency Plan

• CAP 1276692; Not All Equipment Called for Use in A.8 Procedures (EDMGs) was 

Listed on the Fire Brigade Inventory

• CAP 1276414; N2 Tank Used to Support C.5-1301 (Alternate Rod Insertion) could 

be Damaged in a Seismic Event

• CAP 1278817; EOP Equipment Inventory does not Require Inspection of the 

Equipment

• CAP 1276707; Offsite Support Equipment for A.8 not Assured Available

• CAP 1276715; Offsite Support Equipment for A.6 Procedure Not Assured Available

• CAP 1280539; Equipment Needed to Perform EDMGs not in Specified Location

• CAP 1280633; IER 11-1 – Can B.5.b/SAMG Equipment do Simultaneous Tasks?

The inspectors reviewed each condition report for potential impact to the licensee’s 

mitigation strategies. No significant impacts were identified.
8 Enclosure

03.02 Assess the licensee’s capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, “Loss of All 

Alternating Current Power,” and station design is functional and valid. Refer to TI 2515/120, “Inspection of Implementation of 

Station Blackout Rule Multi-Plant Action Item A-22,” as a guideline. It is not intended that TI 2515/120 be completely reinspected. 

The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe the licensee’s actions to verify the adequacy of equipment needed to 

mitigate an SBO event.

a. Verify through walkdowns and 

inspection that all required 

materials are adequate and 

properly staged, tested, and 

maintained.

Abnormal Operating Procedure C.4-B.09.02A (Station Blackout) is the governing procedure 

for the plant response to a SBO. This procedure implements the few specific requirements 

for mitigating the design basis SBO. This procedure also has steps which are not required 

for design basis mitigation, but serve to increase the coping duration beyond the required 

four hour period. The MNGP staff performed C.4-B.09.02A using the control room simulator 

combined with a plant walkdown to assure that all required materials and procedures are 

adequate, properly staged, and executable to support the design basis SBO mitigation.

Describe inspector actions to verify equipment is available and useable. 

The inspectors assessed the licensee’s capability to mitigate SBO conditions by conducting 

a review of the licensee’s walkdown activities. In addition, the inspectors selected a sample 

of equipment utilized/required for mitigation of a SBO and conducted independent 

walkdowns of that equipment to verify that the equipment was properly aligned and staged.

Discuss general results including corrective actions by licensee.

Operators verified that the steps in this procedure that are required to meet the four hour 

coping duration are executable.

No issues of significance were identified by the inspectors.
9 Enclosure

Licensee Action Describe the licensee’s actions to verify the capability to mitigate an SBO event.

b. Demonstrate through 

walkdowns that procedures for 

response to an SBO are 

executable.

Abnormal Operating Procedure C.4-B.09.02A (Station Blackout) is the governing procedure 

for the plant response to a SBO. This procedure implements the few specific requirements 

for mitigating the design basis SBO. This procedure also has steps which are not required 

for design basis mitigation, but serve to increase the coping duration beyond the required 

four hour period. The MNGP staff performed C.4-B.09.02A using the control room simulator 

combined with a plant walkdown to assure that all required materials and procedures are 

adequate, properly staged, and executable to support the design basis SBO mitigation. 

Describe inspector actions to assess whether procedures were in place and could be 

used as intended.

The inspectors assessed the licensee’s capabilities by conducting a review of the licensee’s 

walkdown activities. In addition, the inspectors selected several sections of a sample of the 

procedures walked down by the licensee and walked those down to independently verify the 

licensee’s conclusions.

Discuss general results including corrective actions by licensee.

Operation staff verified that the steps in this procedure that are required to meet the four 

hour coping duration are executable. Items that were identified by the licensee and entered 

into their CAP to address issues identified during the evaluation of IER 11-1, 

Recommendation 2, are listed in the List of Documents Reviewed at the end of this report.

No issues of significance were identified by the inspectors.
10 Enclosure

03.03 Assess the licensee’s capability to mitigate internal and external flooding events required by station design. Refer to 

IP 71111.01, “Adverse Weather Protection,” Section 02.04, “Evaluate Readiness to Cope with External Flooding,” as a guideline. 

The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and 

inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall 

include verification that accessible doors, barriers, and penetration seals are functional.

Licensee Action Describe the licensee’s actions to verify the capability to mitigate existing design 

basis flooding events.

a. Verify through walkdowns and 

inspection that all required 

materials are adequate and 

properly staged, tested, and 

maintained.

The structures, systems, and components (SSCs) credited in MNGP’s External Flooding, 

Internal Flooding, and High Energy Line Break (HELB) programs were cataloged. 

This catalogue list included all SSCs which control the movement of water between 

adjacent volumes and the boundary penetrations between these adjacent volumes. 

Only the penetrations at or below maximum probable water levels based on station 

flooding calculations were evaluated.

Utilizing this list, field walkdowns were conducted to assess the condition of the flood control 

SSCs. For external flooding, a walkdown was performed to ensure pathways were clear 

and capable of performing their function (i.e., passage of water along the path assumed in 

the applicable calculation). The acceptability of the flood barriers and relief paths was 

documented on the list of the flood control SSCs.

Describe inspector actions to verify equipment is available and useable. Assess 

whether procedures were in place and could be used as intended.

The inspectors assessed the licensee’s capabilities to mitigate flooding by conducting a 

review of the licensee’s walkdown activities. Flood mitigation procedures were reviewed to 

verify usability. In addition, the inspectors conducted independent walkdowns of selected 

flood mitigation equipment to independently assess the licensee’s flood mitigation 

capabilities.
11 Enclosure

Discuss general results including corrective actions by licensee.

Of the 377 components to be inspected, 39 were not accessible. Monticello Nuclear 

Generating Plant is currently in a Refueling Outage (RFO). Currently during the refueling 

outage, work at the plant has required partial disassembly of credited barriers, created 

temporary openings through boundaries, restricted access to protected equipment, and 

obstructed viewing of some equipment by scaffold or other non-permanent tools and 

equipment staged for work. These items will be tracked as follow-on actions, with 

walkdowns to be conducted when station conditions permit. A walkdown was performed of 

the accessible plant areas having flood barriers and required relief paths. Walkdown notes 

documented the acceptability of every SSC and the cases where SSCs were inaccessible 

and could not be inspected. Items that were identified by the licensee and entered into their 

CAP to address issues identified during the evaluation of IER 11-1, Recommendation 3, are 

listed in the List of Documents Reviewed at the end of this report.

No issues of significance were identified by the inspectors.
12 Enclosure

03.04 Assess the thoroughness of the licensee’s walkdowns and inspections of important equipment needed to mitigate fire and 

flood events to identify the potential that the equipment’s function could be lost during seismic events possible for the site. 

Assess the licensee’s development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective 

action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections 

of important equipment (permanent and temporary), such as storage tanks, plant water intake structures, and fire and flood response 

equipment, and developed mitigating strategies to cope with the loss of that important function. Use IP 71111.21, “Component 

Design Basis Inspection,” Appendix 3, “Component Walkdown Considerations,” as a guideline to assess the thoroughness of the 

licensee’s walkdowns and inspections.

Licensee Action Describe the licensee’s actions to assess the potential impact of seismic events on 

the availability of equipment used in fire and flooding mitigation strategies. 

a. Verify through walkdowns that 

all required materials are 

adequate and properly staged, 

tested, and maintained.

Important SSCs for fire protection were determined as equipment that can mitigate post

safe-shutdown earthquake (SSE) fires in the following four categories:

• permanently installed fire protection systems;

• permanently installed, seismically-qualified non-fire protection systems that could be 

used to fight fires;

• portable equipment that could be used to fight fires after an SSE; and

• offsite responders.

These categories of equipment, individually or in aggregate, must be capable of fighting 

fires in the critical portions of the station. Examples of critical portions of the station could 

include:

• control room and support structures;

• electrical switchgear rooms;

• turbine building;

• reactor building;

• diesel generator buildings;

• main and auxiliary transformers; and 

• intake structures.

Piping and instrumentation diagrams were used to define the boundaries of the fire 

protection system within the scope of this recommendation, and the flood protection SSCs 

for this recommendation are the same as those used for Recommendation 3.
13 Enclosure

The licensee enlisted a contractor, who specializes in the evaluation of the impacts of 

seismic activity on structures, to perform walkdowns of specific areas onsite. Working from 

the lists of fire protection and flood protection SSCs provided by the licensee, this contractor 

performed a walkdown and examined all of the flood and fire mitigation SSCs which were 

identified, and assessed the seismic vulnerability of these SSCs as high, medium, or low. 

A low vulnerability meant that the SSC would clearly withstand the SSE for the Monticello 

site. A medium vulnerability meant it was highly likely that the component would be shown 

through analysis to be able to survive the SSE for Monticello. A high vulnerability meant

that it was quite possible that an SSE would disable the component.

Describe inspector actions to verify equipment is available and useable. 

Assess whether procedures were in place and could be used as intended.

The inspectors conducted multiple walkdowns of important equipment needed to mitigate 

fire and flood events to identify the potential that the equipment’s function could be lost 

during or subsequent to a seismic event. Specific equipment reviewed as part of this 

assessment included a sampling of the major B.5.b contingency response equipment,

installed fire protection and suppression equipment, installed diesel and electric fire pumps,

and watertight hatches and floor plugs. In addition to the walkdowns, the inspectors 

reviewed a report prepared by the contractor which documented the results of how site flood 

and fire mitigation equipment would be impacted by an SSE.

Discuss general results including corrective actions by licensee. Briefly summarize 

any new mitigating strategies identified by the licensee as a result of their reviews.

For fire protection, the overall conclusion was that the system would likely suffer key failures 

in an SSE and could not be relied upon to be available after an earthquake. The mitigation 

strategy is to use B.5.b equipment to fight any fires that would occur following an 

earthquake. The B.5.b equipment is stored in a warehouse that is not designed as a 

Seismic Class I structure, but was examined by seismic experts and was it was concluded 

that it would remain intact following an SSE. Items that were identified by the licensee and 

entered into their CAP to address issues identified during the evaluation of IER 11-1, 

Recommendation 4, are listed in the List of Documents Reviewed at the end of this report.

No issues of significance were identified by the inspectors.
14 Enclosure

Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. Grubb, and other members of 

licensee management, at the conclusion of the inspection on April 26, 2011. 

The inspectors asked the licensee whether any materials examined during the 

inspection should be considered proprietary. No proprietary information was identified. 
15 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. O’Connor, Site Vice President

J. Grubb, Plant Manager

W. Paulhardt, Assistant Plant Manager

N. Haskell, Site Engineering Director

K. Jepson, Business Support Manager

S. Radebaugh, Maintenance Manager

M. Holmes, Radiation Protection/Chemistry Manager

S. Leonard, Regulatory Affairs Manager

J. Earl, Emergency Preparedness Manager

Nuclear Regulatory Commission

K. Riemer, Chief, Reactor Projects Branch 2
16 Enclosure

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does 

not imply that the NRC inspectors reviewed the documents in their entirety but rather that 

selected sections of portions of the documents were evaluated as part of the overall inspection 

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or 

any part of it, unless this is stated in the body of the inspection report. 

03.01 Assess the licensee’s capability to mitigate conditions that result from beyond design 

basis events

Number Description or Title Date or

Revision

1488 Cycle Inventory of Equipment for EOP C.5-3XXX and 

AOP C.4 Series Procedures

Revision 1*

1244 Fire Brigade Equipment Inventory Revision 27

OSP-FIR-0582 Portable Diesel Fire Pump Testing Procedure Revision 2

ESP-125-0583 125V DC Portable Battery Cart Testing Procedure Revision 2

IMP-1023 Fluke Model 87V EX Digital Multimeter Performance Test Revision 3

A.8 Procedure 

Series

Extensive Damage Mitigation Strategies (various)

A.7-SAMG-01 Primary Containment Flooding Revision 5

A.7-SAMG-02 RPV, Containment, and Radioactivity Release Control Revision 3

A.7-SAMG-03 Combustible Gas Control Revision 1

XE Nuclear LMS Qualification Status Verification for 

Turbine Building Operator; Reactor Building Operator; 

Reactor Operator; Senior Reactor Operator; Operations 

Shift Manager; Emergency Director; Support Group 

Leader; Security Group Leader/Emergency Operation 

Facility (EOF) Security Coordinator; Engineering Group 

Leader; Engineering Group; Core Thermal Hydraulics; 

Nuclear Engineer; Maintenance Group Leader; 

SM/CRS/Operations Group Leader; Radiological 

Emergency Coordinator; Monitoring Section Leader; 

Shift Emergency Communicator; Midas Dose Projection; 

Emergency Manager/Recovery Manager; Radiation 

Protection Support Supervisor; EOF Coordinator; 

Technical Support Supervisor; Field Team Coordinator; 

OSC Coordinator; Chemists; Electrical; I&C; Mechanical; 

SAMG Decision Makers; and SAMG Evaluators.

04/03/2011

03.02 Assess the licensee’s capability to mitigate station blackout (SBO) conditions

Number Description or Title Date or

Revision

C.4-B.0902.A Station Blackout Revision 36

C.4-B.0902.B Loss of Normal Offsite Power Revision 12

E.4-01 Backfeed Bus 13 from 13 DG Revision 3

8153 Powering Division II 250 VDC Battery Chargers from 

No. 13 Diesel, Security Diesel or Portable Generator

Revision 3

CAP 1276138-01 Initiate PCR for 8153 Procedure Enhancements
17 Enclosure

CAP 1276138-03 Verify Incorporation of the CAPX 2020 Subyard 

Modifications into E.5 Procedure

CAP 1276138-04 Enhancement to Attach Relay Boots to the C.4 

Station Blackout Procedure

CAP 1279730 Actions to Enhance Extended SBO Coping Abilities

8900 Operation of RCIC without Electric Power Revision 2

E.5 System Electrical Blackout Revision 12

CA-05-136 SBO Coping Revision 15

03.03 Assess the licensee’s capability to mitigate internal and external flooding events required 

by station design

Number Description or Title Date or

Revision

A.6 Acts of Nature Revision 37

CA-07-021 Internal Flooding – Reactor Building, Turbine Building and

Intake Structure Water Height

Revision 0

CA-07-029 RX and Turbine Building and Intake Structure Water 

Height for Internal Flooding

Revision 0

Form 3336 HELB Barrier Start-Up Checklist Revision 24

CAP 1277413 Strategies for External Flood might be Inadequate

CAP 1276767 A.6; Rev 37 – TSC not Included in Earth Ring Levee

CAP 1277785 A.6; Ext Flooding Procedure Lacks In-Place Barrier 

Walkdowns

CAP 1276143 IER 1-11-1; Flood Plan does not ID Impact on Radioactive 

Material

CAP 1279439 Security Training Facilities not Included in Trigger Actions 

of A.6

CAP 1279440 New Security Building not Inside Earth Ring Levee

CAP 1279342 Four SSCs not Modeled in Flood Analysis

CAP 1279347 SSC Inconsistently Labeled in Plant

CAP 1279342 SSC Needs Verification with Flood Analysis Model, 

PAB-923 Battery Room

CAP 1276715 21 SSCs require Procurement per A.6, with 

Availability/Quantity not Assured

CAP 1279348 SSC Removed for RFO25 Work

CAP 1279350 Four Penetrations with Inadequate Seals

CAP 1279352 Two SSCs could be Compromised by DBE

CAP 1279356 SSC Located Onsite has Accessibility/Warehousing 

Concern

CAP 1279358 Twenty-Two Doors Lack Flooding Labels

CAP 1279361 Forty SSC/Areas could not be Surveyed due to 

Inaccessibility/Safety/Contaminated Area Concerns
18 Enclosure

03.04 Assess the thoroughness of the licensee’s walkdowns and inspections of important 

equipment needed to mitigate fire and flood events to identify the potential that the 

equipment’s function could be lost during seismic events

Number Description or Title Date or

Revision

B.08.05-05 Fire Protection – System Operation Revision 49

Contractor Report 

011C3956-RPT001

Assessment of the Seismic Vulnerability of Fire Protection 

and Flood Mitigation Systems at the Monticello Nuclear 

Power Plant

Revision A

CAP 1278169 IER 1-11-1; Fire System Seismic Vulnerabilities

CAP 1278243 Fire System Seismic Vulnerabilities, Hydrants

CAP 1276324 Several Seismic Type Vulnerabilities have been Identified 

(B.5.b Equipment, Trucks, Pump, Fuel, Hoses Stored in 

Non-Seismic Building)

CAP 1278594 Fires System Seismic Vulnerabilities,Transformers

CAP 1280332 Receiving Warehouse Possible Seismic Damage (Inhibits 

Ability to get to Sandbags and Other Equipment)

CAP 1280335 Perform Seismic Walkdown of Equipment that could not 

be Accessed during Initial Walkdown for IER 11-1

CAP 1280337 Door 18 could be Compromised by Seismic Event

CAP 1277358 IER 1-11; Vulnerability, Diesel Fire Pump
19 Enclosure

LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System

AOP Abnormal Operating Procedure

AMT Accident Management Team

CAP Corrective Action Program

CFR Code of Federal Regulations

EDMG Extensive Damage Mitigating Strategies

EOF Emergency Operating Facility

EOP Emergency Operating Procedure

ERO Emergency Response Organization

HELB High Energy Line Break

IP Inspection Procedure

LMS Learning Management System

MNGP Monticello Nuclear Generating Plant

NRC U.S. Nuclear Regulatory Commission

PARS Publicly Available Records System

RFO Refueling Outage

SAMG Severe Accident Management Guideline

SBO Station Blackout

SSC Structure, System, and Component

SSE Safe-Shutdown Earthquake

TSC Technical Support Center
T. O'Connor -2-

In accordance with 10 CFR 2.390 of the NRC’s “Rules of Practice,” a copy of this letter and 

its enclosure will be made available electronically for public inspection in the NRC Public 

Document Room or from the Publicly Available Records (PARS) component of NRC’s 

document system (ADAMS), accessible from the NRC Website at http://www.nrc.gov/readingrm/adams.html (the Public Electronic Reading Room). 

Sincerely,

/RA/

Kenneth Riemer, Chief

Branch 2

Division of Reactor Projects

Docket No. 50-263

License No. DPR-22

Enclosure: Inspection Report 05000263/2011009

cc w/encl: Distribution via ListServe

DISTRIBUTION:

See next page

DOCUMENT NAME: G:\DRPIII\1-Secy\1-Work In Progress\TI Reports\MON 2011 009.docx

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl

"E" = Copy with attach/encl "N" = No copy

OFFICE RIII N RIII E RIII RIII

NAME KRiemer for AScarbeary KRiemer

DATE 05/10 /11 05/10/11

OFFICIAL RECORD COPY
Letter to T. O'Connor from K. Riemer dated May 13, 2011

SUBJECT: MONTICELLO NUCLEAR GENERATING PLANT – NRC TEMPORARY 

INSTRUCTION 2515/183 INSPECTION REPORT 05000263/2011009

DISTRIBUTION:

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