L-MT-13-079, Monticello'S First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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Monticello'S First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
ML13241A200
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 08/28/2013
From: Schimmel M
Northern States Power Co, Xcel Energy
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
L-MT-13-079, EA-12-049
Download: ML13241A200 (7)


Text

Xcel Energy Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 August28,2013 L-MT-13-079 10 CFR 2.202 10 CFR 50.4 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 Monticello's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. NRC Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ADAMS Accession No. ML12054A736).
2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174).
3. Nuclear Energy Institute (NEI) Guide, NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012.
4. NSPM Letter to NRC, "Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated October 29, 2012 (ADAMS Accession No. ML12305A420).

Document Control Desk Page 2

5. NSPM Letter to NRC, "Monticello Nuclear Generating Plant's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"

dated February 27, 2013 (ADAMS Accession No. ML13066A066).

6. 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).
7. 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).

On March 12, 2012, the NRC staff issued Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," (Reference 1), to all NRC power reactor licensees and holders of construction permits in active or deferred status. Reference 1 was immediately effective and directs Northern States Power Company (NSPM), a Minnesota corporation, doing business as Xcel Energy, to develop, implement and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event for the Monticello Nuclear Generating Plant (MNGP). Specific requirements are outlined in of Reference 1.

Pursuant to Condition C of Section IV, Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (ISG), an overall integrated plan, and status reports at six-month intervals following the submittal of the overall integrated plan. The ISG (Reference 2) endorses, with exceptions and clarifications, the industry guidance document, NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0 (Reference 3). Reference 4 provided the NSPM initial 60 day status report for MNGP regarding mitigation strategies. Reference 5 provided the overall integrated plan for MNGP.

The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2 of Reference 1, which delineates the progress made in implementing the requirements of the Reference 1 Order. The enclosed report provides an update of milestone accomplishments since the overall integrated plan was submitted, including changes to the compliance method, schedule, or the need and basis for relief, if any.

NRC Order EA-12-049 (Reference 1) requires implementation of Mitigation Strategies to address an extended loss of alternating current (AC) power (ELAP) and loss of normal access to ultimate heat sink (LUHS). The endorsed ISG for compliance with NRC Order

Document Control Desk Page 3 EA-12-049, ISG-JLD-2012-01 (Reference 2), used the containment vent required by NRC Order EA-12-050 (Reference 6) for the heat removal function for boiling water reactors (BWRs). Reference 5 provided the NSPM response for MNGP to the NRC Order EA-12-049 using the endorsed guidance from Reference 2. On June 6, 2013, the NRC rescinded NRC Order EA-12-050 with the issuance of NRC Order EA-13-109 (Reference 7). Thus, NSPM will not be installing an NRC Order EA-12-050 containment vent for MNGP as stated in Reference 5.

NSPM will be revising strategies to comply with the NRC Order EA-12-049 during 2013 with information from the industry, NEI, and NRC relative to the new requirements and schedule associated with NRC Order EA-13-109. This new strategy will follow NRC issuance of an ISG in October 2013. It is anticipated that the revised criteria and implementation schedule associated with the NRC Order EA-13-109 may impact containment venting procedures, training, and demonstrations related to the compliance date for NRC Order EA-12-049. NSPM will be in compliance with the aspects of the Reference 5 Mitigation Strategies that do not rely upon a Hardened Containment* Vent System (HCVS) unless otherwise described. Any request for relief will be provided in a separate letter to the NRC and referenced in a future six-month status report. It is anticipated this will occur prior to the February 2014 six-month status report.

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

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

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

Executed on August 28, 2013.

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

L-MT-13-079 NSPM Enclosure Monticello Nuclear Generating Plant First Six-Month Status Report for Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1.0 Introduction The Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," on March 12, 2012 (Reference 1). The Order required licensees to develop, implement and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event. The Order required licensees to submit an overall integrated plan, including a description of how the requirements in of the Order would be achieved. Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, submitted the overall integrated plan (Reference 2) for the Monticello Nuclear Generating Plant (MNGP) on February 28, 2013.

This Enclosure provides the first six-month status report. This status report includes an update of milestone accomplishments since submittal of the overall integrated plan including changes to the compliance method, schedule, or the need and basis for relief, if any.

2.0 Milestone Accomplishments The original milestone schedule with target dates was provided in Attachment 2 of the Reference 2 Enclosure. No original milestones were scheduled for completion prior to this six-month status report. Therefore, NSPM has no milestone accomplishments to discuss.

3.0 Milestone Schedule Status The following provides an update of the milestone schedule for the overall integrated plan. This includes a brief milestone status and a revised target date if the target date has changed. The target dates are planning dates subject to change as design and implementation details are developed.

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L-MT-13-079 NSPM Enclosure

  • Validation Walk-throughs or Demonstrations:

A target completion date has been added to the milestone listing for completion of validation walk-throughs. The validation walk-throughs will be completed during the FLEX implementation outage.

Milestone Target Activity Status Revised Completion Target Date Completion Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Plan February 2013 Complete Submit First Six-Month Status August 2013 Complete with Update this submittal Commence Engineering January 2014 Not Started Modification Design- Phase 2 & 3 Submit Second Six-Month Status February 2014 Not Started Update Regional Response Center (TBD) Started Operational Procure Equipment June 2014 Started Submit Third Six-Month Status August 2014 Not Started Update Complete Installation for Online August 2014 Not Started Modifications - Phase 2 and 3 Implement Storage December 2014 Not Started Issue Maintenance Procedures December 2014 Started Implement Training February 2015 Not Started Submit Fourth Six-Month Status February 2015 Not Started Update Submit Staffing Assessment Four months Not Started prior to R27 Complete Communication Four months Not Started Recommendations prior to R27 Issue Procedures updated for April2015 Not Started FLEX strategies Implementation Outage April 2015 Not Started (End of R27)

Validation Walk-throughs April 2015 Not Started Submit Completion Report August 2015 Not Started Page 2 of 4

L-MT-13-079 NSPM Enclosure 4.0 Proposed Changes to Compliance Method There are no changes to the compliance method as documented in the overall integrated plan.

NRC Order EA-12-049 (Reference 1) requires implementation of Mitigation Strategies to address an extended loss of alternating current (AC) power (ELAP) and loss of normal access to ultimate heat sink (LUHS). The endorsed ISG for compliance with NRC Order EA-12-049, ISG-JLD-2012-01 (Reference 5), used the containment vent required by NRC Order EA-12-050 (Reference 6) for the heat removal function for boiling water reactors (BWRs). Reference 2 provided the NSPM response to the NRC Order EA-12-049 using the endorsed guidance from Reference 5. On June 6, 2013, the NRC rescinded NRC Order EA-12-050 with the issuance of NRC Order EA-13-109 (Reference 4). Thus, NSPM will not be installing an NRC Order EA-12-050 containment vent for MNGP as stated in Reference 2.

NSPM will be revising strategies to comply with the NRC Order EA-12-049 during 2013 with information from the industry, the Nuclear Energy Institute (NEI), and NRC relative to the new requirements and schedule associated with NRC Order EA-13-109. This new strategy will follow NRC issuance of an ISG in October 2013. It is anticipated that the revised criteria and implementation schedule associated with the NRC Order EA-13-1 09 may impact containment venting procedures, training, and demonstrations related to the compliance date for NRC Order EA-12-049. NSPM will be in compliance with the aspects of the Reference 2 Mitigation Strategies that do not rely upon a Hardened Containment Vent System (HCVS) unless otherwise described. Any request for relief will be provided in a separate letter to the NRC and referenced in a future six-month status report. It is anticipated this will occur prior to the February 2014 six-month status report.

5.0 Need and Basis for Relief from the Requirements of the Order NSPM expects to comply with the Order implementation date and requirements and no relief is required at this time.

6.0 Open Items from Overall Integrated Plan and Draft Safety Evaluation NSPM did not identify any open items in the MNGP mitigating strategies overall integrated plan. The overall integrated plan did contain future actions to ensure compliance with the Order. The future actions were identified internally and are being tracked through NSPM's corrective action program (CAP).

No draft Safety Evaluation (SE) has been issued as of July 31, 2013. Closure of the draft SE open items, when issued, will be tracked to closure in future status reports.

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L-MT-13-079 NSPM Enclosure 7.0 Potential Draft Safety Evaluation Impacts There are no potential impacts to the draft Safety Evaluation identified at this time.

8.0 References

1. NRC Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ADAMS Accession No. ML12054A736).
2. NSPM Letter to NRC, "Monticello Nuclear Generating Plant's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"

dated February 27, 2013 (ADAMS Accession No. ML13066A066).

3. 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).
4. 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).
5. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174).

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