L-MT-14-092, First Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

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First Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
ML14353A215
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 12/16/2014
From: Fili K
Northern States Power Co, Xcel Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, L-MT-14-092
Download: ML14353A215 (8)


Text

Monticello Nuclear Generating Plant Monticello, MN 55362 December 16, 2014 L-MT-1 4-092 10 CFR 2.202 EA-1 3-109 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 Generating Plant: First Six-Month Status Report in Response 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)

References:

1) NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013. (ADAMS Accession No. ML13143A334)
2) NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-1 3-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," Revision 0, dated November 14, 2013.

(ADAMS Accession No. ML13304B836)

3) Letter from D. Skeen (NRC) to J. Pollock (NEI), Endorsement of "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-1 3-109) Rev 0," dated May 14, 2014.

(ADAMS Accession No. ML14128A219)

4) NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109,"

Revision 0, dated November 2013.

5) Letter from K.D. Fili (NSPM) to Document Control Desk (NRC),

"MNGP's Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe

Document Control Desk Page 2 Accident Conditions (Order Number EA-13-109)," L-MT-14-052, dated June 30, 2014. (ADAMS Accession No. ML14183A412)

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-109 (Reference 1) to Northern States Power Company, a Minnesota corporation (NSPM),

doing business as Xcel Energy. Reference 1 was immediately effective and directs NSPM to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris for Monticello Nuclear Generating Plant (MNGP). Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of a Phase 1 Overall Integrated Plan (OIP) pursuant to Section IV, Condition D. Reference 3 endorses industry guidance document, NEI 13-02, Revision 0 (Reference 4) with clarifications and exceptions identified in Reference 3. Reference 5 provided the MNGP Phase 1 OIP.

Reference 1 requires submission of a status report at six-month intervals following submittal of the Phase 1 OIP. References 2 and 4 provide direction regarding the content of the status reports.

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

Please contact John Fields, Fukushima Response Licensing, at 763-271-6707, if additional information or clarification is required.

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

Document Control Desk Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on December/_C, 2014.

Karen D. Fili Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company - Minnesota 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-14-092 ENCLOSURE MONTICELLO NUCLEAR GENERATING PLANT FIRST SIX MONTH STATUS REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109, "ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS" 1.0 Introduction Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy developed a Phase 1 Overall Integrated Plan (Reference 1), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable wetwell hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris for the Monticello Nuclear Generating Plant (MNGP), in response to Reference 2.

This enclosure provides an update of milestone accomplishments since submittal of the Phase 1 Overall Integrated Plan (OIP), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2.0 Milestone Accomplishments No milestones have been completed since the development of the OIP (Reference 1),

and are current as of November 30, 2014.

3.0 Milestone Schedule Status The following table provides an update to Part 5 of the MNGP HCVS Phase 1 GIP. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed (i.e., not considered formal regulatory commitments).

The revised target completion dates impact the Order Implementation date. Revised dates are provided in the Comments section of the table. An explanation of the impact of these changes is provided in Section 5 of this enclosure.

Page 1 of 5

L-MT-14-092 Milestone Target Activity Comments Completion Date Status Phase I HCVS Milestone Table Submit Overall Integrated June 2014 Complete Plan Submit 6 Month Updates:

Complete Update 1 December 2014 with this submittal Update 2 June 2015 Not Started Update 3 December 2015 Not Started Update 4 June 2016 Not Started Update 5 December 2016 Not Started Modifications:

Hold preliminary/conceptual June 2014 Complete design meeting Design Engineering March 2016 Not Started On-site/Complete Implementation Outage April 2017 Not Started May 2017 Walk Through Demonstration/Functional April 2017 Not Started May 2017 Test Procedure Changes Active:

Operations Procedure September 2016 Not Started Changes Developed Site Specific Maintenance September 2016 Not Started Procedure Developed Procedure Changes Active April 2017 Not Started May 2017 Page 2 of 5

L-MT-14-092 Milestone Target Activity Comments Completion Date Status Phase 1 HCVS Milestone Table Training:

Training Complete April 2017 Not Started May 2017 Completion:

HCVS Implementation April 2017 Not Started May 2017 Submit Completion Report June 2017 Not Started July 2017 4.0 Proposed Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 OIP (Reference 1).

5.0 Need and Basis for Relief from the Requirements of the Order NSPM has changed the Order Implementation dates as reported in the MNGP HCVS Phase 1 OIP, Part 5 from April 2017 to May 2017 for the following items (see Section 3.0):

  • Implementation Outage
  • Walk Through Demonstration/Functional Test

" Procedure Changes Active

  • Training Complete
  • HCVS Implementation The change to the above listed Order Implementation dates was made to align each item's completion date with the current projected completion of the 2017 refueling outage (the second refueling outage for MNGP after June 30, 2014).

In addition, NSPM has changed the Order Implementation date as reported in the MNGP HCVS Phase 1 OIP, Part 5 from June 2017 to July 2017 for the "Submit Completion Report" item. This change was made in order to maintain the Completion Report submittal 60 days after completion of the Order Implementation date, which is tied to the completion of the 2017 refueling outage, and changed as described above.

Page 3 of 5

L-MT-14-092 These changes do not result in the need for relief from the requirements of NRC Order EA-1 3-109 as the revised implementation dates meet the Order requirements. Namely, that Phase 1 of NRC Order EA-1 3-109 must be completed no later than startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first. Therefore, NSPM continues to comply with the Order Implementation date; no relief/relaxation is required at this time.

6.0 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the Phase 1 Overall Integrated Plan and the Interim Staff Evaluation (ISE) and the status of each item.

Overall Integrated Plan Phase 1 Open Item Status

1. Follow industry guidance on missile protection for HCVS. Open
2. Identify the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> power supply for the HCVS. Open
3. Determine radiological conditions for the FLEX portable Open equipment staging areas.
4. Evaluate the Alternate Shutdown System Panel and Backup HCVS Operation Station locations for accessibility, habitability, Open staffing sufficiency, associated pathways from the control room and communication capability with vent-use decision makers.
5. Determine approach or combination of approaches to control Open hydrogen.
6. Determine the Qualification Method for HCVS instrumentation. Open
7. Evaluate the effects of radiological and temperature constraints Open on the deployment of nitrogen bottles after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
8. Evaluate HCVS battery charger location for accessibility, habitability, staffing sufficiency, associated pathways from Open control room and communication capability with vent-use decision makers.

Interim Staff Evaluation Open Item Status None - NSPM has not received an Interim Staff Evaluation for NtAlibl MNGP. oppicae Page 4 of 5

L-MT-1 4-092 7.0 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time as NSPM has not received an Interim Staff Evaluation for MNGP.

8.0 References The following references support the updates to the OIP described in this enclosure.

1. Letter from K.D. Fili (NSPM) to Document Control Desk (NRC), "MNGP's Phase 1 Overall Integrated Plan in Response 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)," L-MT-14-052, dated June 30, 2014. (ADAMS Accession No. ML14183A412)
2. NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," dated June 6, 2013. (ADAMS Accession No. ML13143A334)
3. NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109," Revision 0, dated November 2013.
4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA 109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 14, 2013. (ADAMS Accession No. ML13304B836)
5. Letter from D. Skeen (NRC) to J. Pollock (NEI), Endorsement of "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-1 3-109) Rev 0." (ADAMS Accession No. ML14128A219)

Page 5 of 5

Monticello Nuclear Generating Plant Monticello, MN 55362 December 16, 2014 L-MT-1 4-092 10 CFR 2.202 EA-1 3-109 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 Generating Plant: First Six-Month Status Report in Response 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)

References:

1) NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013. (ADAMS Accession No. ML13143A334)
2) NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-1 3-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," Revision 0, dated November 14, 2013.

(ADAMS Accession No. ML13304B836)

3) Letter from D. Skeen (NRC) to J. Pollock (NEI), Endorsement of "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-1 3-109) Rev 0," dated May 14, 2014.

(ADAMS Accession No. ML14128A219)

4) NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109,"

Revision 0, dated November 2013.

5) Letter from K.D. Fili (NSPM) to Document Control Desk (NRC),

"MNGP's Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe

Document Control Desk Page 2 Accident Conditions (Order Number EA-13-109)," L-MT-14-052, dated June 30, 2014. (ADAMS Accession No. ML14183A412)

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-109 (Reference 1) to Northern States Power Company, a Minnesota corporation (NSPM),

doing business as Xcel Energy. Reference 1 was immediately effective and directs NSPM to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris for Monticello Nuclear Generating Plant (MNGP). Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of a Phase 1 Overall Integrated Plan (OIP) pursuant to Section IV, Condition D. Reference 3 endorses industry guidance document, NEI 13-02, Revision 0 (Reference 4) with clarifications and exceptions identified in Reference 3. Reference 5 provided the MNGP Phase 1 OIP.

Reference 1 requires submission of a status report at six-month intervals following submittal of the Phase 1 OIP. References 2 and 4 provide direction regarding the content of the status reports.

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

Please contact John Fields, Fukushima Response Licensing, at 763-271-6707, if additional information or clarification is required.

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

Document Control Desk Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on December/_C, 2014.

Karen D. Fili Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company - Minnesota 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-14-092 ENCLOSURE MONTICELLO NUCLEAR GENERATING PLANT FIRST SIX MONTH STATUS REPORT FOR THE IMPLEMENTATION OF NRC ORDER EA-13-109, "ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS" 1.0 Introduction Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy developed a Phase 1 Overall Integrated Plan (Reference 1), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable wetwell hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris for the Monticello Nuclear Generating Plant (MNGP), in response to Reference 2.

This enclosure provides an update of milestone accomplishments since submittal of the Phase 1 Overall Integrated Plan (OIP), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2.0 Milestone Accomplishments No milestones have been completed since the development of the OIP (Reference 1),

and are current as of November 30, 2014.

3.0 Milestone Schedule Status The following table provides an update to Part 5 of the MNGP HCVS Phase 1 GIP. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed (i.e., not considered formal regulatory commitments).

The revised target completion dates impact the Order Implementation date. Revised dates are provided in the Comments section of the table. An explanation of the impact of these changes is provided in Section 5 of this enclosure.

Page 1 of 5

L-MT-14-092 Milestone Target Activity Comments Completion Date Status Phase I HCVS Milestone Table Submit Overall Integrated June 2014 Complete Plan Submit 6 Month Updates:

Complete Update 1 December 2014 with this submittal Update 2 June 2015 Not Started Update 3 December 2015 Not Started Update 4 June 2016 Not Started Update 5 December 2016 Not Started Modifications:

Hold preliminary/conceptual June 2014 Complete design meeting Design Engineering March 2016 Not Started On-site/Complete Implementation Outage April 2017 Not Started May 2017 Walk Through Demonstration/Functional April 2017 Not Started May 2017 Test Procedure Changes Active:

Operations Procedure September 2016 Not Started Changes Developed Site Specific Maintenance September 2016 Not Started Procedure Developed Procedure Changes Active April 2017 Not Started May 2017 Page 2 of 5

L-MT-14-092 Milestone Target Activity Comments Completion Date Status Phase 1 HCVS Milestone Table Training:

Training Complete April 2017 Not Started May 2017 Completion:

HCVS Implementation April 2017 Not Started May 2017 Submit Completion Report June 2017 Not Started July 2017 4.0 Proposed Changes to Compliance Method There are no changes to the compliance method as documented in the Phase 1 OIP (Reference 1).

5.0 Need and Basis for Relief from the Requirements of the Order NSPM has changed the Order Implementation dates as reported in the MNGP HCVS Phase 1 OIP, Part 5 from April 2017 to May 2017 for the following items (see Section 3.0):

  • Implementation Outage
  • Walk Through Demonstration/Functional Test

" Procedure Changes Active

  • Training Complete
  • HCVS Implementation The change to the above listed Order Implementation dates was made to align each item's completion date with the current projected completion of the 2017 refueling outage (the second refueling outage for MNGP after June 30, 2014).

In addition, NSPM has changed the Order Implementation date as reported in the MNGP HCVS Phase 1 OIP, Part 5 from June 2017 to July 2017 for the "Submit Completion Report" item. This change was made in order to maintain the Completion Report submittal 60 days after completion of the Order Implementation date, which is tied to the completion of the 2017 refueling outage, and changed as described above.

Page 3 of 5

L-MT-14-092 These changes do not result in the need for relief from the requirements of NRC Order EA-1 3-109 as the revised implementation dates meet the Order requirements. Namely, that Phase 1 of NRC Order EA-1 3-109 must be completed no later than startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first. Therefore, NSPM continues to comply with the Order Implementation date; no relief/relaxation is required at this time.

6.0 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the Phase 1 Overall Integrated Plan and the Interim Staff Evaluation (ISE) and the status of each item.

Overall Integrated Plan Phase 1 Open Item Status

1. Follow industry guidance on missile protection for HCVS. Open
2. Identify the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> power supply for the HCVS. Open
3. Determine radiological conditions for the FLEX portable Open equipment staging areas.
4. Evaluate the Alternate Shutdown System Panel and Backup HCVS Operation Station locations for accessibility, habitability, Open staffing sufficiency, associated pathways from the control room and communication capability with vent-use decision makers.
5. Determine approach or combination of approaches to control Open hydrogen.
6. Determine the Qualification Method for HCVS instrumentation. Open
7. Evaluate the effects of radiological and temperature constraints Open on the deployment of nitrogen bottles after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
8. Evaluate HCVS battery charger location for accessibility, habitability, staffing sufficiency, associated pathways from Open control room and communication capability with vent-use decision makers.

Interim Staff Evaluation Open Item Status None - NSPM has not received an Interim Staff Evaluation for NtAlibl MNGP. oppicae Page 4 of 5

L-MT-1 4-092 7.0 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time as NSPM has not received an Interim Staff Evaluation for MNGP.

8.0 References The following references support the updates to the OIP described in this enclosure.

1. Letter from K.D. Fili (NSPM) to Document Control Desk (NRC), "MNGP's Phase 1 Overall Integrated Plan in Response 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)," L-MT-14-052, dated June 30, 2014. (ADAMS Accession No. ML14183A412)
2. NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions," dated June 6, 2013. (ADAMS Accession No. ML13143A334)
3. NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109," Revision 0, dated November 2013.
4. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA 109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 14, 2013. (ADAMS Accession No. ML13304B836)
5. Letter from D. Skeen (NRC) to J. Pollock (NEI), Endorsement of "Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-1 3-109) Rev 0." (ADAMS Accession No. ML14128A219)

Page 5 of 5