L-MT-18-058, Response to Request for Additional Information: Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to ...

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Response to Request for Additional Information: Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to ...
ML18296A653
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 10/23/2018
From: Church C
Northern States Power Co, Xcel Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2017-LLA-0434, L-MT-18-058
Download: ML18296A653 (5)


Text

2807 West County Road 75 Monticello, MN 55362

(}, Xcel Energy*

RESPONSIBLE BY NATURE

  • 800.895.4999 xcelenergy.com October 23, 2018 L-MT-18-058 10 CFR 50.90 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 Response to Request for Additional Information: Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (EPID L-2017-LLA-0434)

References:

1) NSPM Letter (L-MT-17-083) to NRC Document Control Desk, License Amendment Request: Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program, dated December 19, 2017 (ADAMS Accession No. ML17353A189)
2) Nuclear Energy Institute (NEI) 04-10, Risk-Informed Technical Specification Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1, dated April 2007 (ADAMS Accession No. ML071360456)
3) NSPM Letter (L-MT-18-020), Supplement to License Amendment Request:

Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (EPID L-2017-LLA-0434), dated April 24, 2018 (ADAMS Accession No. ML18114A401)

4) Email from NRC, Request for Additional Information RE: Monticello license amendment request to adopt TSTF425, dated September 26, 2018 (ADAMS Accession No. ML18269A357)

In Reference 1, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), requested to amend Renewed Facility Operating License DPR-22 for the Monticello Nuclear Generating Plant (MNGP). The proposed amendment

Document Control Desk Page 2 would modify the MNGP Technical Specifications (TS) by relocating specific surveillance frequencies to a licensee-controlled program with implementation of NEI 04-10, "Risk-Informed Technical Specification Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies", (Reference 2) . Reference 1 was supplemented to correct errors in two facts and observations (F&O) (Reference 3). On September 26, 2018, the NRG issued a request for additional information (RAI) (Reference 4). The response to the Reference 4 request is provided in the enclosure to this letter.

The information provided in this letter does not alter the evaluations performed in accordance with 10 CFR 50.92 .

Please contact Sara Scott, Licensing Manager, at 612-330-6698, if additional information or clarification is required.

Summary of Commitments This letter makes one new commitment and no revisions to existing commitments:

  • The Fire PRA model update activities related to F&O 2-5 will be completed prior to implementation of TSTF-425.

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

Executed on October l!J_, 2018.

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

L-MT-18-058 NSPM Enclosure Response to Request for Additional Information:

Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program 1.0 Background In Reference 1, Northern States Power Company, a Minnesota corporation (hereafter NSPM),

doing business as Xcel Energy, requested to amend renewed Facility Operating License DPR-22 for the Monticello Nuclear Generating Plant (MNGP). The proposed amendment would modify the MNGP Technical Specifications (TS) by relocating specific surveillance frequencies to a licensee-controlled program with implementation of NEI 04-10, Risk-Informed Technical Specification Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies, (Reference 2). Reference 1 was supplemented to correct errors in two Facts &

Observations (Reference 3). On September 26, 2018, the NRC issued a request for additional information (RAI) (Reference 4). The NSPM responses to the NRC RAIs are provided below.

2.0 Responses to Requests for Additional Information NRC RAI 01 - LAR Attachment 2, MNGP Open Fire PRA Peer Review Findings:

The LAR Attachment 2, Table 2-1, MNGP Open Fire PRA Peer Review Findings, provides resolutions for the open facts and observations (F&Os) from the full-scope 2015 and focused-scope 2017 Fire PRA (FPRA) peer reviews that were not closed by the October 2017 Finding Closure Review.

For F&O 2-5, the peer review team stated the influencing factors assigned in the FPRA model were based on engineering judgement and a set of rules documented in Section 5.6.2 of the Ignition Frequency Notebook. The peer review team further stated that the influencing factors assigned resulted in comparatively low values (i.e., averaging much less than 3). The resolution of this F&O indicates, in part, that a better justification of application of a very low factor in two compartments needs to be provided. As related to F&O 2-5, Attachment 3 of the MNGP submittal, dated March 28, 2018, (ADAMS Accession No. ML18087A323) for the implementation of a program related to 10 CFR 50.69 further indicates that the compartments 8 and 33 were assigned very low influencing factors.

The update for treatment of influence factors for the two fire compartment areas, compartments 8 and 33, which were assigned very low influencing factors, could have an impact on this risk-informed application. Additionally, Frequently Asked Question (FAQ) 12-0064, Close-Out of National Fire Protection Association 805 Frequently Asked Question 12-0064 on Hot Work/Transient Fire Frequency Influence Factors (ADAMS Accession No. ML12346A488), provides related guidance for consideration in the use of influencing factors in an FPRA.

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L-MT-18-058 NSPM Enclosure EITHER:

a. Provide justification for why the treatment (use of the influencing factors) used in the MNGP FPRA for fire compartments 8 and 33 is appropriate for this application (e.g.,

explain how the influencing factors used for fire compartments 8 and 33 are consistent with or bound the guidance in FAQ 12-0064; discuss the results of a sensitivity analysis that confirms the F&O will have negligible impact on the surveillance test interval (STI) evaluations).

OR

b. If justification to confirm the influencing factors used for fire compartments 8 and 33 cannot be provided, propose a mechanism that ensures F&O 2-5 will be resolved for supporting requirement IGN-A7 at Capability Category (CC) II, consistent with the NEI 04-10 guidance. The proposed mechanism should ensure the activities and changes associated with F&O 2-5 will be completed, appropriately reviewed, and any issues resolved prior to any future STI evaluations. Additionally, this mechanism should specify how F&O 2-5 will be resolved in the PRA (e.g., provide an explicit description or a reference to the appropriate section of the LAR). An example would be a table of listed implementation items referenced in a license condition.

NSPM Response to RAI 01(b):

In the November 2017 Fire PRA Peer Review Findings Closure Report, F&O 2-5 was characterized as a documentation issue noting that better justification of the application of the very low factor (0.3) needed to be made or potentially the use of the typical low factor (1.0) should be considered.

A detailed review performed in May 2018 recognized that the Transient Fire Frequency Influence Factors were not justifiable at the very low factor. The suggested guidance within FAQ 12-0064, Close-Out of National Fire Protection Association 805 Frequently Asked Question 12-0064 on Hot Work/Transient Fire Frequency Influence Factors, (Reference 5), was considered during this review. Based on this, the Transient Storage Factor for both Fire Zone 8 and 33 will be classified as low (1.0). Therefore, RAI 01 Option (b) is selected as the appropriate response approach.

The Fire PRA is currently undergoing an update in accordance with FP-PE-PRA-02, PRA Guideline for Model Maintenance and Update, and this change is being incorporated. The Fire PRA model update activities related to F&O 2-5 will be completed prior to implementation of TSTF-425. Once the Fire PRA model update is complete, this revised model will be used to address the surveillance test interval changes.

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L-MT-18-058 NSPM Enclosure 3.0 References

1. NSPM Letter (L-MT-17-083) to NRC Document Control Desk, License Amendment Request: Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program, dated December 19, 2017 (ADAMS Accession No. ML17353A189)
2. Nuclear Energy Institute (NEI) 04-10, Risk-Informed Technical Specification Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1, dated April 2007 (ADAMS Accession No. ML071360456)
3. NSPM Letter (L-MT-18-020), Supplement to License Amendment Request: Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (EPID L-2017-LLA-0434), dated April 24, 2018 (ADAMS Accession No. ML18114A401)
4. Email from NRC, Request for Additional Information RE: Monticello license amendment request to adopt TSTF425, dated September 26, 2018 (ADAMS Accession No. ML18269A357)
5. Frequently Asked Question (FAQ) 12-0064, Close-Out of National Fire Protection Association 805 Frequently Asked Question 12-0064 on Hot Work/Transient Fire Frequency Influence Factors, dated January 17, 2013 (ADAMS Accession No. ML12346A488)

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