L-MT-14-015, Plant'S Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Plant'S Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML14069A463
Person / Time
Site:	Monticello
Issue date:	02/28/2014
From:	Fili K Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, L-MT-14-015, TAC MF0924
Download: ML14069A463 (15)

Text

Monticello Nuclear Generating Plant Monticello, MN 55362 February 28, 2014 L-MT-14-015 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 Nuclear Generatinq Plant's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)(TAC No.

MF0924)

References:

1. NRC Order EA-1 2-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (ADAMS Accession No. ML12054A679).

2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12221A339).

3. NEI 12-02, "Industry Guidance for Compliance with NRC Order EA 051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"' Revision 1, dated August 2012 (ADAMS Accession No. ML12240A307).

4. NSPM Letter to NRC, "Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),"

dated October 29, 2012 (ADAMS Accession No. ML12305A383).

Document Control Desk Page 2

5. NSPM Letter to NRC, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),"

dated February 28, 2013 (ADAMS Accession No. ML13060A447).

6. NSPM Letter to NRC, "Responses to Requests for Additional Information Regarding Monticello Nuclear Generating Plant's Overall Integrated Plan Submitted in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC No. MF0924)," dated July 12, 2013 (ADAMS Accession No. ML13193A324).

7. NSPM Letter to NRC, "Monticello's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated August 28, 2013 (ADAMS Accession No. ML13241A197).

8. NRC Letter to NSPM, "Monticello Nuclear Generating Plant - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0924)," dated October 28, 2013 (ADAMS Accession No. ML13275A187).

On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," (Reference 1) to all NRC power reactor licensees and holders of construction permits in active or deferred status. Reference 1 was effective immediately and directed Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, to have a reliable indication of the water level in the spent fuel storage pool for Monticello Nuclear Generating Plant (MNGP). Specific requirements were outlined in Attachment 2 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) endorsed, with exceptions and clarifications, the methodologies described in a guidance document from the Nuclear Energy Institute (NEI), NEI 12-02, "Industry Guidance for Compliance with Order EA 051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,'

Revision 1 (Reference 3). Reference 4 provided the MNGP initial 60-day status report regarding reliable spent fuel pool instrumentation. Reference 5 provided the overall integrated plan for MNGP. Reference 6 provided the NSPM responses to NRC Requests for Additional Information (RAIs) regarding the overall integrated plan for

Document Control Desk Page 3 MNGP. Reference 7 provided the first six-month status report for the overall integrated plan, per Condition C.2 of Section IV of Reference 1.

On October 28, 2013, the NRC issued an Interim Staff Evaluation (ISE) for MNGP's SFPI overall integrated plan (Reference 8). The ISE documents the NRC Staff's review and provides feedback on NSPM's overall integrated plan. The ISE also includes Requests for Additional Information (RAI), response to which the NRC Staff needs to complete their review.

The purpose of this letter is to provide the second 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 Reference 7 first status report was submitted, including changes to the compliance method, schedule, or the need and basis for relief, if any. This status report also provides an update on NSPM's closure of the RAIs identified in the NRC's ISE.

Please contact Jennie Wike, Licensing Engineer, at 612-330-5788, 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 February 28, 2014.

Karen D. Fili Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region III, USNRC Director of Nuclear Reactor Regulation (NRR), USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC

L-MT-14-015 NSPM Enclosure ENCLOSURE Monticello Nuclear Generating Plant Second Six-Month Status Report for Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation 1.0 Introduction The U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," on March 12, 2012 (Reference 1). The Order requires licensees to have reliable indication of the water level in associated spent fuel pools capable of supporting identification of the following spent fuel pool water level conditions by trained personnel: (1) level that is adequate to support operation of the normal fuel pool cooling system, (2) level that is adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck, and (3) level where fuel remains covered and actions to implement make-up water addition should no longer be deferred. The Order required licensees to submit an overall integrated plan, including a description of how the requirements in Attachment 2 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. Reference 4 provided the first six-month status report for the overall integrated plan, per Condition C.2 of Section IV of Reference 1.

On June 7, 2013, the NRC Staff provided requests for additional information (RAI) in Reference 5 regarding the Spent Fuel Pool Instrumentation (SFPI) overall integrated plan. Reference 3 provided the NSPM responses to NRC Requests for Additional Information (RAIs) regarding the overall integrated plan for MNGP.

On October 28, 2013, the NRC issued an Interim Staff Evaluation (ISE) for MNGP's SFPI overall integrated plan (Reference 6). The ISE documents the NRC Staff's review and provides feedback on NSPM's overall integrated plan. The ISE also includes RAIs, response to which the NRC Staff needs to complete their review.

This Enclosure provides the MNGP second six-month status report. This status report includes an update of milestone accomplishments since the previous status report was submitted, including any changes to the compliance method, schedule, or the need and basis for relief, if any. This status report also provides an update on NSPM's closure of the RAts identified in the NRC's ISE.

Page 1 of 12

L-MT-14-015 NSPM Enclosure 2.0 Milestone Accomplishments The original milestone schedule, with target dates, was provided in Section 1.2 of Reference 2. The following milestone has been completed since the previous status report was submitted and is current as of January 31, 2014.

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

Table 1 includes the following revised target completion date:

• Reliable Spent Fuel Pool Instrumentation Operational The target completion date for the implementation outage was changed from April 2015 to May 2015, due to changes in the refueling outage schedule.

Table 1 - Overall Integrated Plan Milestone Schedule Target Revised Milestone Completion Activity Status Target Date Completion Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Plan February 2013 Complete Select Instrument Vendor March 2013 Complete Submit First Six-Month Status August 2013 Complete Report Commence Engineering Design January 2014 Complete Submit Second Six-Month Status February 2014 Complete with Report this submittal Submit Third Six-Month Status August 2014 Not Started Report (includes responses to ISE RAIs)*

Commence Installation September 2014 Not Started Submit Fourth Six-Month Status February 2015 Not Started Report Page 2 of 12

L-MT-14-015 NSPM Enclosure Table I - Overall Integrated Plan Milestone Schedule Target Revised Milestone Completion Activity Status Target Date Completion Date Reliable Spent Fuel Pool April 2015 Not Started May 2015 Instrumentation Operational (End of R27) (End of R27)

Submit Report that Full June 2015 Not Started Compliance is Achieved

• Note: In Reference 3, NSPM originally stated it would provide the response to the Reference 5 RAIs in the August 2014 or February 2015 six-month status reports.

However, the NRC Staff requested in the ISE that licensees respond to the updated RAI list from the ISE by September 30, 2014, to ensure that any issues are resolved prior to the date by which NSPM must complete full implementation of Order EA-1 2-051. Responses to the ISE RAIs will be provided in the third six-month status report scheduled for August 2014, as noted above in Table 1.

4.0 Proposed Changes to Compliance Method There are no changes proposed to the compliance method described in the overall integrated plan (Reference 2).

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 Interim Staff Evaluation NSPM did not identify any open items in the 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).

On October 28, 2013, the NRC issued the ISE for MNGP's SFPI overall integrated plan (Reference 6). The ISE identified RAIs that were necessary for the NRC to complete its evaluation of NSPM's plans for implementing the requirements of Order EA-12-051.

These RAIs are listed as open items in Table 2. NSPM will track the closure of the ISE open items in future status reports.

Page 3 of 12

L-MT-14-015 NSPM Enclosure The RAIs issued by the NRC in the ISE, and listed in the following table, replace the open items reported in the Reference 4 first six-month status report.

Table 2 - Interim Staff Evaluation Open Items Open Open Item Description Status Item Number RAI-1 Given the potential for varied dose rates from hardware Scheduled stored in the [Spent Fuel Pool] SFP, please provide a (note that information description of how the elevation identified as Level 2 might will be submitted in the be affected. August 2014 six-month status report, as noted in Table 1)

RAI-2 Please provide a clearly labeled sketch or marked-up plant Scheduled drawing of the plan view of the SFP area, depicting the (note that information SFP inside dimensions, the planned locations/placement of will be submitted in the the primary and back-up SFP level sensor, and the August 2014 six-month proposed routing of the cables that will extend from these status report, as noted in sensors toward the location of the read-out/display device. Table 1)

Page 4 of 12

L-MT-14-015 NSPM Enclosure Table 2 - Interim Staff Evaluation Open Items Open Open Item Description Status Item Number RAI-3 Please provide the following: Scheduled (note that information a) The design criteria that will be used to estimate the will be submitted in the total loading on the mounting device(s), including August 2014 six-month static weight loads and dynamic loads. Describe status report, as noted in the methodology that will be used to estimate the Table 1) total loading, inclusive of design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

d) Address how other hardware stored in the SFP will not create adverse interaction with the fixed instrument location(s).

RAI-4 For RAI-3(a) above, please provide the analyses used to Scheduled verify the design criteria and methodology for seismic (note that information testing of the SFP instrumentation and the electronics will be submitted in the units, including, design basis maximum seismic loads and August 2014 six-month the hydrodynamic loads that could result from pool status report, as noted in sloshing or other effects that could accompany such Table 1) seismic forces.

RAI-5 For each of the mounting attachments required to attach Scheduled SFP level equipment to plant structures, please describe (note that information the design inputs, and the methodology that was used to will be submitted in the qualify the structural integrity of the affected August 2014 six-month structures/equipment. status report, as noted in Table 1)

Page 5 of 12

L-MT-14-015 NSPM Enclosure Table 2 - Interim Staff Evaluation Open Items Open Open Item Description Status Item Number RAI-6 Please provide the following: Scheduled (note that information a) A description of the specific method or combination will be submitted in the of methods you intend to apply to demonstrate the August 2014 six-month reliability of the permanently installed equipment status report, as noted in under beyond-design-basis [(BDB)] ambient Table 1) temperature, humidity, shock, vibration, and radiation conditions.

b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to a) the level sensor mounted in the SFP area, and b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.

For RAI-6 above, please provide the results for the Scheduled selected methods, tests and analyses used to demonstrate (note that information the qualification and reliability of the installed equipment in will be submitted in the accordance with the Order requirements. August 2014 six-month status report, as noted in Table 1)

Page 6 of 12

L-MT-14-015 NSPM Enclosure Table 2 - Interim Staff Evaluation Open Items Open Open Item Description Status Item Number RAI-8 Please provide the following: Scheduled (note that information a) A description of how the two channels of the will be submitted in the proposed level measurement system meet this August 2014 six-month requirement so that the potential for a common status report, as noted in cause event to adversely affect both channels is Table 1) minimized to the extent practicable.

b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, and readout devices will be designed and installed to address independence through the application and selection of independent power sources, the use of physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.

RAI-9 Please provide the following: Scheduled (note that information a) A description of the electrical ac power sources and will be submitted inthe capabilities for the primary and backup channels. August 2014 six-month b) Please provide the results of the calculation status report, as noted in depicting the battery backup duty cycle Table 1) requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.

Page 7 of 12

L-MT-14-015 NSPM Enclosure Table 2 - Interim Staff Evaluation Open Items Open Open Item Description Status Item Number RAI-10 Please provide the following: Scheduled (note that information a) An estimate of the expected instrument channel will be submitted in the accuracy performance under both (a) normal SFP August 2014 six-month level conditions (approximately Level 1 or higher) status report, as noted in and (b) at the beyond-design-basis conditions (i.e., Table 1) radiation, temperature, humidity, post-seismic and post- shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.

Page 8 of 12

L-MT-14-015 NSPM Enclosure Table 2 - Interim Staff Evaluation Open Items Open Open Item Description Status Item Number RAI-1 1 Please provide the following: Scheduled (note that information a) A description of the capability and provisions the will be submitted in the proposed level sensing equipment will have to August 2014 six-month enable periodic testing and calibration, including status report, as noted in how this capability enables the equipment to be Table 1) tested in-situ.

b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.

c) A description of how functional checks will be performed, and the frequency at which they will be conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted. Provide a discussion as to how these surveillances will be incorporated into the plant surveillance program.

d) A description of what preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

Page 9 of 12

L-MT-14-015 NSPM Enclosure Table 2 - Interim Staff Evaluation Open Items Open Open Item Description Status Item Number RAI-12 Please provide the following: Scheduled (note that information a) The specific location for the backup instrument will be submitted in the channel display. August 2014 six-month b) Please describe the evaluation used to validate that status report, as noted in the display location can be accessed without Table 1) unreasonable delay following a BDB event. Include the time available for personnel to access the display as credited in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display.

Additionally, please include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BDB event. Describe whether personnel are continuously stationed at the display or monitor the display periodically.

RAI-13 Please provide a list of the procedures addressing Scheduled operation (both normal and abnormal response), (note that information calibration, test, maintenance, and inspection procedures will be submitted inthe that will be developed for use of the spent SFP August 2014 six-month instrumentation. Please provide a brief description of the status report, as noted in specific technical objectives to be achieved within each Table 1) procedure.

Page 10 of 12

L-MT-14-015 NSPM Enclosure Table 2 - Interim Staff Evaluation Open Items Open Open Item Description Status Item Number RAI-14 Please provide the following: Scheduled (note that information a) Further information describing the maintenance and will be submitted in the testing program the licensee will establish and August 2014 six-month implement to ensure that regular-testing and status report, as noted in calibration is performed and verified by inspection Table 1) and audit to demonstrate conformance with design and system readiness requirements. Please include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

b) A description of how the guidance in NEI 12-02 Section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.

c) A description of what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.

7.0 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

8.0 References The following references support the updates to the overall integrated plan described in this enclosure.

1. NRC Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (ADAMS Accession No. ML12054A679).

Page 11 of 12

L-MT-14-015 NSPM Enclosure

2. NSPM Letter to NRC, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),"

dated February 28, 2013 (ADAMS Accession No. ML13060A447).

3. NSPM Letter to NRC, "Responses to Requests for Additional Information Regarding Monticello Nuclear Generating Plant's Overall Integrated Plan Submitted in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC No. MF0924)," dated July 12, 2013 (ADAMS Accession No. ML13193A324).

4. NSPM Letter to NRC, "Monticello's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated August 28, 2013 (ADAMS Accession No. ML13241A197).

5. NRC Email to NSPM, "Monticello Nuclear Generating Plant - Requests for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (TAC No. MF0924)," dated June 7, 2013 (ADAMS Accession No. ML13176A331).

6. NRC Letter to NSPM, "Monticello Nuclear Generating Plant - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0924)," dated October 28, 2013 (ADAMS Accession No. ML13275A187).

Page 12 of 12