L-MT-15-031, Second 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 EA-13-109), Phase 1

Second 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 EA-13-109), Phase 1

ML15173A176
Person / Time
Site:	Monticello
Issue date:	06/22/2015
From:	Gardner P Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, L-MT-15-031
Download: ML15173A176 (9)

Text

Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 June 22, 2015 L-MT-15-031 10 CFR 2.202 EA-13-109 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: Second 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 EA-13-109), Phase 1

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-13-109, 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-13-109) 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. (ADAMS Accession No. ML13316A853)

Document Control Desk Page 2

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

MNGPs 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)

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

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 109), L-MT-14-092, dated December 16, 2014. (ADAMS Accession No. ML14353A215)

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 effective immediately 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. Reference 6 provided the first six-month status report for Phase 1 of the order.

The purpose of this letter is to provide the second 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.

Document Control Desk Page 3 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 Junell, 2015.

~~

Peter A. Gardner 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-15-031 ENCLOSURE MONTICELLO NUCLEAR GENERATING PLANT SECOND 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 (OIP) (Reference 1) in response to Phase 1 of NRC Order EA-13-109 (Reference 2). The OIP documents a plan to install 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). This enclosure provides an update of milestone accomplishments since submittal of the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2.0 Milestone Accomplishments None.

3.0 Milestone Schedule Status The following table provides an update to Part 5 of the MNGP HCVS Phase 1 OIP as modified by the first status report (Reference 6). The table 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).

There are no revised milestone target completion dates proposed in this status report.

Therefore, the Order Implementation date has not been impacted.

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L-MT-15-031 Target Activity Milestone Comments Completion Date Status Phase 1 HCVS Milestone Table Submit Overall Integrated June 2014 Complete Plan Submit 6 Month Updates:

Update 1 December 2014 Complete Complete with Update 2 June 2015 this submittal 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 Started On-site/Complete Implementation Outage May 2017 Not Started Walk Through Demonstration/Functional May 2017 Not Started Test Procedure Changes Active:

Operations Procedure September 2016 Not Started Changes Developed Site Specific Maintenance September 2016 Not Started Procedure Developed Procedure Changes Active May 2017 Not Started Training:

Training Complete May 2017 Not Started Page 2 of 6

L-MT-15-031 Target Activity Milestone Comments Completion Date Status Phase 1 HCVS Milestone Table Completion:

HCVS Implementation May 2017 Not Started Submit Completion Report July 2017 Not Started 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 expects to comply with the Order implementation date and 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 OIP (Reference 1) and the Interim Staff Evaluation (ISE) (Reference 7) 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.

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L-MT-15-031

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

1. Make available for NRC staff audit the final sizing evaluation for HCVS batteries/battery charger including incorporation into Open FLEX DG loading calculation.

2. Make available for NRC staff audit documentation of the HCVS Open nitrogen pneumatic system design including sizing and location.

3. Make available for NRC staff audit an evaluation of temperature and radiological conditions to ensure that operating personnel Open can safely access and operate controls and support equipment.

4. Make available for NRC staff audit analyses demonstrating that HCVS has the capacity to vent the steam/energy equivalent of one percent of licensed/rated thermal power (unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that Open following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

5. Make available for NRC staff audit the seismic and tornado Open missile final design criteria for the HCVS stack.

6. Make available for NRC staff audit the descriptions of local conditions (temperature, radiation and humidity) anticipated during ELAP [Extended Loss of AC Power] and severe accident for the components (valves, instrumentation, sensors, Open transmitters, indicators, electronics, control devices, etc.)

required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

7. Make available for NRC staff audit documentation that demonstrates adequate communication between the remote Open HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

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8. Provide a description of the final design of the HCVS to address Open hydrogen detonation and deflagration.

9. Provide a description of the strategies for hydrogen control that minimizes the potential for hydrogen gas migration and ingress Open into the reactor building or other buildings.

10. Make available for NRC staff audit descriptions of all instrumentation and controls (existing and planned) necessary to Open implement this order including qualification methods.

11. Make available for NRC staff audit documentation of an evaluation verifying the existing containment isolation valves, relied upon for the HCVS, will open under the maximum Open expected differential pressure during BDBEE and severe accident wetwell venting.

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

8.0 References

1. Letter from K. Fili (NSPM) to Document Control Desk (NRC), MNGPs 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. (ADAMS Accession No. ML13316A583)

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)

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5. Letter from D. Skeen (NRC) to J. Pollock (NEI), Endorsement of Hardened Containment Venting System (HCVS) Phase 1 Overall Integrated Plan Template (EA-13-109) Rev 0, dated May 14, 2014. (ADAMS Accession No. ML14128A219)

6. Letter from K. Fili (NSPM) to Document Control Desk (NRC), 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), L-MT-14-092, dated December 16, 2014. (ADAMS Accession No. ML14353A215)

7. Letter from M. Halter (NRC) to P. Gardner (NSPM), Monticello Nuclear Generating Plant - Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Phase One Of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC No. MF4376), dated April 2, 2015. (ADAMS Accession No. ML15082A167)

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