L-MT-17-066, Supplemental Information for the Notification of Full Compliance of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events

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Supplemental Information for the Notification of Full Compliance of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events
ML17272A035
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 09/28/2017
From: Church C
Northern States Power Company, Minnesota, Xcel Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-MT-17-066, TAC MF0923
Download: ML17272A035 (8)


Text

2807 West County Road 75 Monticello, MN 55362 800.895.4999 xcelenergy.com September 28, 2017 L-MT-17-066 10 CFR 2.202 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket No. 50-263 Renewed Facility Operating License No. DPR-22 Monticello Nuclear Generating Plant: Supplemental Information for the Notification of Full Compliance of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events (TAC No. MF0923)

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. ML12054A735)
2) NEI 12-06, Revision 2, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, December 2015. (ADAMS Accession No. ML16005A625)

3) Letter from P. Gardner (NSPM) to Document Control Desk (NRC), Monticello Nuclear Generating Plant: Notification of Full Compliance of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events (TAC No. MF0923), L-MT-17-047, dated July 6, 2017. (ADAMS Accession No. ML17187A153)

On March 12, 2012, the Nuclear Regulatory Commission (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 effective immediately and directed Northern States Power Company, a Minnesota corporation (NSPM),

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 were outlined in Attachment 2 of Reference 1. NSPM notified the Commission of full compliance with the Reference 1 Order in Reference 3.

Document Control Desk L-MT-17-066 Page 2 The purpose of this letter is to provide clarifications and supplemental information to support the Reference 3 compliance letter and Final Integrated Plan (FIP). NSPM is providing a clarification to the text and a figure regarding the Spent Fuel Pool (SFP) Cooling/Inventory strategy. Additionally, the NRC contacted NSPM by electronic mail requesting clarification of the FLEX strategy for reactor pressure vessel (RPV) makeup. The Enclosure of this letter provides clarification of both the SFP Cooling/Inventory strategy and the RPV makeup options.

For the RPV makeup options, the Enclosure includes justification supporting an alternative to the NEI 12-06, Revision 2 (Reference 2) guidance.

Please contact Lynne Gunderson at 651-267-7421, 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 September Zi, 2017.

Christoper R. Church Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region Ill, USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC

L-MT-17-066 NSPM ENCLOSURE Monticello Nuclear Generating Plant Supplemental Information for the Notification of Full Compliance of Required Action for NRC Order EA 12-049 Mitigation Strategies for Beyond-Design-Basis External Events (TAC No. MF0923) 1.0 Background On March 12, 2012, the Nuclear Regulatory Commission (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 effective immediately and directed Northern States Power Company, a Minnesota corporation (NSPM),

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 (BDBEE) for the Monticello Nuclear Generating Plant (MNGP). Specific requirements were outlined in Attachment 2 of Reference 1. NSPM notified the Commission of full compliance with the Reference 1 Order in Reference 3.

Section 2.0 below provides clarification to the text and a figure in Reference 3, Enclosure 2, Final Integrated Plan. The clarification is specifically for Section 3.2.4, Structures, Systems and Components, Section 3.2.4.2, Alternate Connection, Figure 3.2.3-1, Monticello FLEX SFP Water Delivery Strategy, and Section 5.3.2, SFP Injection Makeup Strategy, all regarding the Spent Fuel Pool (SFP) Cooling/Inventory strategy.

Section 3.0 below provides supplemental information to support the Reference 3 compliance letter and Final Integrated Plan (FIP). The NRC requested clarification of the Diverse and Flexible Coping Strategies (FLEX) strategy for reactor pressure vessel (RPV) makeup, which uses a common section of piping for all RPV makeup options. NSPM has determined this is an alternative to the NEI 12-06, Revision 2 (Reference 2), guidance. The NRC requested clarification is provided in bold italics in Section 2.0 followed by the NSPM response and alternative justification.

2.0 Clarification of Final Integrated Plan - SFP Cooling/Inventory FIP Section 3.2.4 Clarification The introductory information in Section 3.2.4 discusses the three specific paths that have been assessed for providing makeup to the SFP. When developing the paths for procedures, NSPM wanted to provide as many options as possible for SFP inventory makeup. Although Path 1 is an option in response procedures for providing SFP for inventory makeup, Path 1 is not a credited option because it requires the fire system piping to be intact and uses local fire hose stations. The bases section of procedure C.5-4301, Spent Fuel Pool Makeup with FLEX Portable Diesel Pump, notes this is not a credited option. The Paths 2 and 3 are credited strategies for meeting the FLEX Order. NSPM revises the Section 3.2.4 bullets as follows to clarify the credited paths (changed text is italicized and underlined):

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L-MT-17-066 NSPM Enclosure

  • Path 1 routes a fire hose from a FLEX portable diesel driven pump to the FLEX connection (see Figure 3.2.3-1) at RHRSW-68 to the refueling floor fire hose station located near the SFP. From the local fire hose stations, water can be supplied to the SFP. Path 1 route does not conform to NEI 12-06 and is not a credited path because it requires the fire system piping to be intact and uses local fire hose stations.
  • Path 2 routes a fire hose directly from a FLEX portable diesel driven pump up the equipment hatch to the refueling floor. From there, the hose can be supplied to the SFP.

This path conforms to NEI 12-06, Table 3-2, by providing makeup via hoses directly to the SFP.

  • Path 3 routes a fire hose directly from a FLEX portable diesel driven pump supplies water through RHRSW-68 to RHRSW-14 to fill the SFP directly using the RHR to SFP emergency return line. This path conforms to NEI 12-06, Table D-3, by providing SFP makeup without accessing the SFP area.

FIP Section 3.2.4.2, Figure 3.2.3-1 and Section 5.3.2 Clarifications:

Originally, MNGPs SFP Cooling/Inventory strategies included the use of spray capability through spray nozzles on the refueling floor using a portable FLEX pump. The MNGP Overall Integrated Plan (Reference 4) included SFP spray as a means of compliance with Order EA-12-049. This required the use of two 2 1/2 hoses for the strategies. However, as discussed in Reference 3, Enclosure 2, Section 3.2.4.4, Spray Option, the requirement for this capability was removed consistent with the endorsed guidance in NRC NEI guidance contained in NEI 12-06, Revision 2 (Reference 2). Based on the strategy change, only one 2 1/2 hose is required to implement the strategies.

Reference 3, Enclosure 2, currently makes the following references to two 2 1/2 hoses for the SFP Cooling/Inventory strategies:

  • Section 3.2.4.2, Alternate Connection, refers to two, 2 1/2 hoses being routed
  • Figure 3.2.3-1, Monticello FLEX SFP Water Delivery Strategy, depicts two 2 1/2 hoses from the Portable Diesel Driven Pump
  • Section 5.3.2, SFP Injection Makeup Strategy, discusses the hose path that includes reference to two 2 1/2 outlets from flow splitters These above bullets are in conflict with the strategy change discussed above. Therefore, NSPM is correcting Section 3.2.4.2, Figure 3.2.3-1, and Section 5.3.2, as provided below.

These replace the referenced sections and the figure in Reference 3, Enclosure 2, in their entirety.

Section 3.2.4.2, Alternate Connection (changed text is italicized and underlined):

Path 2 - The alternate connection for SFP refilling is to route a hose from the FLEX pump into the reactor building railway and up the equipment hatch directly to the refuel floor. One, 2 1/2 hose is routed from the 5 hose manifold located outside the Reactor Building (RB). This path utilizes no permanently installed plant equipment. The FLEX SFP makeup connection is sufficiently sized to restore SFP level long-term after the loss of SFP cooling at a makeup rate of 200 gpm of makeup water for SFP boil off.

The revised Figure 3.2.3-1 is provided on the next page with only one 2-1/2 hose depicted for Path 2.

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L-MT-17-066 NSPM Enclosure Final Integrated Plan for Mitigating Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Instrumentation for Monticello Nuclear Generating Plant Figure 3.2.3-1 Page 3 of 6

L-MT-17-066 NSPM Enclosure Section 5.3.2, SFP Injection Makeup Strategy, second bullet (changed text is italicized and underlined):

o One of the two 21/2 outlets from the flow splitters described in Section 5.3.1 is used to route 21/2 fire hose through the reactor building railroad doors, up to 1027 elevation of the reactor building.

3.0 Supplemental Information NRC requested Clarification: The three RPV makeup options listed in FIP Section 3.1.5 appear to connect and flow through a single train (A train RHR/RHRSW). This conflicts with the provisions of NEI 12-06, Rev. 2, Table C-1 Performance Attribute bullet #1 for Depressurizing RPV for FLEX Injection (Page 80) (i.e. connections should not be in the same train/division). This results in a common section of piping for all portable FLEX pump RPV makeup options. The NRC staff views this as an alternative to NEI 12-06, Rev. 2. Please provide an alternative justification or show the ability to provide an additional flow path to the RPV that does not use this common piping NSPM Response:

As noted by the NRC in the above question, the three RPV makeup options listed in the MNGP FIP are routed to a single section of residual heat removal (RHR) piping (i.e., a single train).

Therefore, the single section of pipe is shared by the three FLEX injection flow paths and does not fully meet the intent of NEI 12-06, Revision 2 (Reference 2), regarding provisions for injection through separate trains. NEI 12-06, Revision 2, Table C-1, states in part Diverse injection points are required to establish capability to inject through separate divisions/trains, i.e., should not have both connections in one division/train. The MNGP configuration does not meet this provision in Reference 2. Therefore, NSPM proposes the following justification for the alternative to Reference 2.

The single piping section shared by the three FLEX injection flow paths is part of the RHR system, which is a Class I system per USAR Section 12.2.1.2. The RHR system is designed to withstand the design basis earthquake and is considered seismically robust. The common section of piping is welded steel piping designed to meet ASME Code requirements and withstand a design basis earthquake. The single section of piping is also protected from BDBEEs as it is installed within the Reactor Building. The Reactor Building is a Class I Structure, which is a seismically qualified and high winds and tornado missile-protected building as noted in USAR Section 12.2.1. The common piping begins in the train A RHR corner room (below ground level), transits the torus room (also below ground level), rises to approximately eight feet above ground level within a concrete block room on the ground floor of the reactor building, and enters the containment at that elevation. Two motor-operated valves are located within the concrete block room. This routing provides additional protection from tornado-generated missiles. Therefore, the single section of piping is reasonably protected from applicable external hazards.

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L-MT-17-066 NSPM Enclosure Seismic Category I piping systems have been confirmed to meet the licensing bases through several generic NRC programs, such as IE Bulletin 79-14. Periodic walkdowns by plant system engineers and ASME Section XI In-Service Inspections ensure that Seismic Category I piping systems are maintained in accordance with the licensing bases. Due to the inherent ruggedness Seismic Category I piping systems, the piping systems were not included on the equipment list for the Recommendation 2.3 seismic walkdowns. Additionally, examinations of power plant and industrial piping systems that have experienced strong motion earthquakes and shake-table tests well beyond the expected SSE acceleration have demonstrated inherent seismic ruggedness in piping systems.

There are two motor-operated control valves in the common piping shared by the three FLEX injection flow paths. Monticellos Flex Support Guidelines (FSGs) call for manual operation of one or both of these motor-operated valves to establish a flow path to the reactor. Since the valves are manually positioned in the FSGs, the valves were treated as inherently rugged in the Expedited Seismic Evaluation Process (ESEP). An earlier review under the Seismic Qualification Utility Group (SQUG) program covered both of these motor-operated valves and determined they have adequate seismic capacity. In addition, the valves are designed to Seismic Category I and are mounted close to ground level, which minimizes building amplification of seismic motion. If for some reason a valve cannot be opened, FSG C.5-3203 contains instructions to inject via a crosstie to the B loop of Low Pressure Coolant Injection (LPCI). None of the valves in either flow path is of the type covered by a 2013 10 CFR Part 21 notification of a defect or noncompliance for Anchor Darling Double Disk Gate Valves.

In the NRCs seismic prioritization letter (Reference 5), Monticello was classified as a low seismic hazard (Group 3) plant, meaning it has a reevaluated ground motion response spectrum greater than the design basis SSE. However, the exceedance in the 1-10 Hz range is relatively small and the maximum ground motion in the 1-10 Hz range is also not high. Given Monticellos low seismic hazard and the inherent ruggedness of nuclear Seismic Category 1 piping, it can be concluded that the actual seismic capacity of the common section of RHR piping substantially exceeds the seismic demand that would be placed on it by either a design basis safe shutdown earthquake or by the reevaluated ground motion response spectrum.

Other external hazards applicable to Monticello - snow, cold, ice, heat, and flooding - do not pose a material risk to piping systems or manually-operated valves. Based on the installation of the Class I piping in a seismically robust manner within a seismically qualified and missile-protected structure that reasonably protects the piping and connection points, NSPM concludes that the single RHR piping will be available to support the RPV makeup FLEX mitigation strategies for a BDBEE and that the proposed alternative to NEI 12-06 is acceptable for compliance with NRC Order EA-12-049.

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L-MT-17-066 NSPM Enclosure 4.0 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. ML12054A735)

2) NEI 12-06, Revision 2, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, December 2015. (ADAMS Accession No. ML16005A625)

3) Letter from P. Gardner (NSPM) to Document Control Desk (NRC), Monticello Nuclear Generating Plant: Notification of Full Compliance of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events (TAC No. MF0923), L-MT-17-047, dated July 6, 2017. (ADAMS Accession No. ML17187A153)
4) NSPM Letter to NRC, Monticello Nuclear Generating Plants 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), L-MT-13-017, dated February 28, 2013 (ADAMS Accession No. ML13066A066)
5) NRC Letter to all Power Reactor Licensees, Screening and Prioritization Results Regarding Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Seismic Hazard Re-Evaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, dated May 9, 2014 (ADAMS Accession No. ML14111A147)

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