ML12096A461

Draft Request for Additional Information for Monticello TIA 2012-03

ML12096A461
Person / Time
Site:	Monticello
Issue date:	04/05/2012
From:	Tam P Plant Licensing Branch III
To:	Patricia Anderson, Loeffler R Northern States Power Co
Tam P
References
TAC ME7933, TIA 2012-03
Download: ML12096A461 (2)

Text

Accession NO. ML12096A461 From: Tam, Peter Sent: Thursday, April 05, 2012 6:19 PM To: Loeffler, Richard A.; 'Anderson, Paula K.'

Cc: Cruz, Holly; Armstrong, Garry; Beltz, Terry; Frankl, Istvan; Dunlop, Andrew

Subject:

Monticello - Draft RAI regarding TIA 2012-03 (TAC ME7933)

Paula:

NRC Headquarters is responding to Task Interface Agreement (TIA) 2011-03 from the Region III staff, asking to provide the staffs technical position on the issue. The review at Headquarters is ongoing. Our reviewer developed an information need, identified by the following two draft RAI questions. We would like to discuss these draft questions with you in a conference call, preferably when I return to the office after 4/19/2012: Should you desire to hold the discussion before my return, please contact Terry Beltz to make the arrangement.

(1) Monticello Improved Technical Specifications (ITS) 3.8.1, AC Sources - Operating, requires two Emergency Diesel Generators (EDGs) to be operable during Modes 1, 2 and 3.

ITS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, require that the subsystems shall be within limits for each EDG. Furthermore, Condition G for ITS 3.8.3 requires for the licensee to declare the affected EDG inoperable immediately if the above subsystems are not within limits for reasons other than Condition A, B, C, D, E, or F.

The two EDGs and their associated day tanks share a common pipeline, which is serviced by both the fuel oil transfer pump (safety-related) and the fuel oil service pump (nonsafety-related),

and is connected to a common storage tank. The fuel oil service pump provides fuel oil to both day tanks in order to satisfy ITS 3.8.3 during normal conditions. In the event of loss of offsite power (LOOP), the power to the fuel oil service pump is lost and must be manually re-energized by the operators by procedure. Furthermore, if the fuel oil transfer pump fails to start to provide the fuel oil transfer to either day tanks, the licensee will have to declare the affected EDG inoperable per Condition G of ITS 3.8.3.

Please describes how the determination is made to declare which EDG is inoperable based on the above scenario.

(2) 10 CFR 50.59(c)(1) states that A licensee may make changes in the facility as described in the final safety analysis report (as updated), make changes in the procedures as described in the final safety analysis report (as updated), and conduct tests or experiments not described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to Sec. 50.90 only if:

(i) A change to the technical specifications incorporated in the license is not required, and (ii) The change, test, or experiment does not meet any of the criteria in paragraph (c)(2) of this section.

Furthermore, 10 CFR 50.59(c)(2)(iv) states that a license amendment should be obtained if the change [r]esult in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated)

Revision 27 of Monticellos Updated Safety Analysis Report (USAR) Section 8.4.1, Safeguards Emergency Diesel Generator (EDG) Systems, states that Operator action may be required within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to establish fuel oil transfer capability from the storage tank to the day tanks so that EDG operation may continue as long as needed. This appears to be in the event of the fuel oil transfer pump failing to start during a LOOP event to provide fuel oil to either one of the two EDG day tanks. However, considering that the fuel oil transfer function is a safety-related function, the NRC staff could not identify any references that discuss the inclusion of the manual action to re-establish the fuel oil transfer function. The NRC staff considers performing a manual action for a safety-related function, such as re-establishing the fuel oil transfer, to meet the criteria 10 CFR 50.59(c)(2)(iv), in which the manual action could potentially impact the EDGs if not performed in a timely manner or incorrectly.

Please provide the USAR revision reference and justification for including the operator action in the USAR without the NRC staffs review.

Peter S. Tam, Senior Project Manager (for D.C. Cook and Monticello)

Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Tel. 301-415-1451