L-MT-13-056, Answer to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

Answer to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

ML13170A243
Person / Time
Site:	Monticello
Issue date:	06/19/2013
From:	Schimmel M Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, L-MT-13-056
Download: ML13170A243 (3)

Text

Xcel Energy Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 June 19, 2013 L-MT-13-056 10 CFR 2.202 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket No. 50-263 Renewed Facility Operating License No. DPR-22 Answer to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-1 09)

References:

1. NRC Order EA-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6,2013 (ADAMS Accession No. ML13130A067).

2. NRC Order EA-12-050, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents," dated March 12,2012 (ADAMS Accession No. ML12054A694).

3. NSPM Letter to NRC, "MNGP's Overall Integrated Plan in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Requirement for Reliable Hardened Containment Vents (Order Number EA-12-050)," dated February 28,2013 (ADAMS Accession No. ML13060A411).

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued an immediately effective Order (Order EA-13-1 09) to all licensees that operate boiling-water reactors (8WRs) with Mark I and Mark II containment designs, including Northern States Power Company, a Minnesota corporation, d/b/a Xcel Energy (hereafter "NSPM"), entitled "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," (Reference 1).

Document Control Desk Page 2 Reference 1 rescinds Order EA-12-050 (Reference 2) issued by the NRC on March 12, 2012, that required all BWRs with Mark I and Mark" containments to take certain actions to ensure the capability of reliable hardened vent systems to remove decay heat and maintain control of containment pressure following events that result in loss of active containment heat removal capability or prolonged loss of alternating current (AC) power.

Reference 1 requires NSPM, the owner and operator of the Monticello Nuclear Generating Plant (MNGP), to install hardened containment venting systems that can be maintained functional during severe accident conditions, i.e., following significant core damage. The substantive requirements of the Order are contained in Attachment 2 of Reference 1.

The Reference 1 Order includes two separate implementation phases. Phase 1 includes modifications to wetwell venting systems, while Phase 2 includes modifications to drywell venting systems or implementation of a reliable containment strategy that meets regulatory approval. NSPM is required by June 30, 2014, to submit to the NRC an overall integrated plan including a description of how compliance with the Phase 1 requirements will be achieved. NSPM is required to complete full implementation of the Phase 1 requirements no later than startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever is sooner. NSPM is also required by December 31,2015, to submit to the NRC an overall integrated plan including a description of how compliance with the Phase 2 requirements will be achieved. NSPM is required to complete full implementation of the Phase 2 requirements no later than startup from the first refueling outage that begins after June 30,2017, or June 30,2019, whichever is sooner.

The NRC states in Reference 1 that it anticipates issuing implementation guidance for Phase 1 by October 31, 2013, and for Phase 2 by April 30, 2015. Upon issuance of each Phase's implementation guidance, NSPM understands that it will have twenty days to assess the impact of the guidance and notify the NRC of any challenges with implementation of the Order in accordance with Paragraph IV.C of Reference 1.

Pursuant to 10 CFR § 2.202(a)(2), NSPM hereby submits its answer to the Reference 1 Order. NSPM consents to Order EA-13-109 and does not request a hearing. However, because implementing guidance is not expected to be available until October 31, 2013, for Phase 1 and April 30, 2015, for Phase 2, there remain significant uncertainties about the scope of the work that will be required by Order EA-13-109. As a result, NSPM is unable to state with certainty that it will be able to meet all of the specified compliance deadlines in the Order. As such, NSPM's future responses may include requests for schedule relief as warranted by subsequent NRC requirements or implementing guidance or the results of engineering analyses not yet performed. Any such request would be submitted in accordance with the relaxation provision in Section IV of the Reference 1.

Document Control Desk Page 3 The requirements in Section IV and Attachment 2 of the Reference 2 Order are rescinded by the Reference 1 Order. Therefore, NSPM understands that all implementation deadlines and submittal requirements for Reference 2 are no longer in force. As such, NSPM considers the overall integrated plan that was submitted to the NRC on February 28, 2013 (Reference 3) to be withdrawn, and no further action is required by NSPM with respect to that submittal or any other requirement specific to Reference 2.

Please contact Lynne Gunderson, Licensing Engineer, at 612-396-0173, if additional information or clarification is required.

Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June 19, 2013.

Mark A. Schimmel Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company - Minnesota cc: Administrator, Region III, USNRC Director of Nuclear Reactor Regulation (NRR), USNRC NRR Project Manager, MNGP, USNRC Senior Resident Inspector, MNGP, USNRC