ML12192A104

Supplement to Maximum Extended Load Line Limit Analysis Plus License Amendment Request

ML12192A104
Person / Time
Site:	Monticello
Issue date:	06/27/2012
From:	Schimmel M A Xcel Energy, Northern States Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-12-054, TAC ME3145, TAC MD9990
Download: ML12192A104 (13)

Text

ENCLOSURE 4 CONTAINS PROPRIETARY INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 Xcel Energy Monticello Nuclear Generating Plant 2807 W County Rd 75 Monticello, MN 55362 June 27, 2012 L-MT-12-054 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22

Subject:

Supplement to Maximum Extended Load Line Limit Analysis Plus License Amendment Request (TAC ME3145)

References:

1) Letter from T J O'Connor (NSPM), to Document Control Desk (NRC),"License Amendment Request: Maximum Extended Load Line Limit Analysis Plus," L-MT-10-003, dated January 21, 2010. (ADAMS Accession No. ML100280558)

2) Letter from T J O'Connor (NSPM) to Document Control Desk (NRC),"

Subject:

Monticello Extended Power Uprate: Replacement Steam Dryer Supplement (TAC MD9990)," L-MT-10-046, dated June 30, 2010. (ADAMS Accession No. ML1 02010462)3) NEDC-33006P-A, Revision 3, "Licensing Topical Report, General Electric Boiling Water Reactor, Maximum Extended Load Line Limit Analysis Plus," dated June 2009. (ADAMS Accession No.ML091800512)

4) Letter from P S Tam (NRC) to T J O'Connor (NSPM), "

Subject:

Monticello Nuclear Generating Plant -Determination that Submitted Information is Proprietary and Will Be Withheld from Public Disclosure (TAC No. ME3145)," dated February 16, 2010. (ADAMS Accession No. ML100320229)

In Reference 1, Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, requested approval of an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Document Control Desk Page 2 Specifications (TS). The proposed change would allow operation in the expanded Maximum Extended Load Line Limit Analysis Plus (MELLLA+)

domain.In Reference 2, NSPM provided analyses for a Replacement Steam Dryer (RSD) for MNGP. A portion of these analyses concern the potential effect of moisture carryover (MCO) on plant operation in conjunction with the MNGP Extended Power Uprate (EPU)license amendment request (LAR). Enclosure 1 to this letter contains an evaluation of the effects of the installation of a RSD on the MELLLA+ LAR. The RSD supplement was provided to the NRC in Reference

2. The evaluation concludes that there are no effects on the MELLLA+ LAR.Enclosure 2 to this letter contains corrected pages for NEDC-33435P, Revision 1 and NEDO-33435, Revision 1, based on an error discovered on Table 1-1 of these documents.

NEDC-33435P, Revision 1 and NEDO-33435, Revision 1 were originally provided to the NRC in Reference 1.Enclosure 3 to this letter contains a MNGP cycle 26 supplemental reload licensing report (SRLR) that includes MELLLA+ conditions and evaluations.

The cycle 26 SRLR is being submitted to the NRC to fulfill the requirements of the MELLLA+ topical report (Reference 3), Limitation and Condition 12.4, which specifies that the SRLR for the initial MELLLA+ implementation cycle shall be submitted for NRC staff confirmation.

Enclosure 4 to this letter contains a clarification regarding application of administrative controls described in the original MELLLA+ LAR (Reference 1). This clarification forms the basis for a correction to NEDC-33435P, Revision 1.Information in Enclosure 4 is considered proprietary to General Electric -Hitachi. No new information is being provided; however, to fully describe the clarification required, it was necessary to include excerpts of proprietary information from NEDC-33435P, Revision 1, which was included in Reference 1, Attachment

3. Since this information has been previously accepted by the NRC as proprietary information withheld from public disclosure (Reference 4), no new request for withholding or affidavit has been provided as the original request for withholding and affidavit (provided in Reference 1, Attachment

4) is applicable to this information.

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: June Z7, 2012 Mark A. Schimmel Site Vice-President Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (4)cc: Regional Administrator, Region Ill, USNRC (w/o enclosures)

Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC (w/o enclosures)

Minnesota Department of Commerce (w/o enclosures)

L-MT-12-054 ENCLOSURE I EVALUATION OF REPLACEMENT STEAM DRYER ON MELLLA+ LICENSE AMENDMENT REQUEST 6 pages follow L-MT-12-054 Enclosure 1 Page 1 of 6 The purpose of this table is to demonstrate that installation of the replacement steam dryer (RSD) does not impact the analyses provided in the Maximum Extended Load Line Limit Analysis Plus (MELLLA+)

application for Monticello Nuclear Generating Plant (MNGP). Reference E1-1, Attachment 3 indicated that the MELLLA+ analysis determined that the moisture content of the steam leaving the vessel may increase up to 0.5 wt% at times while operating near the minimum core flow in the MELLLA+ operating domain. Operation at this point in the MELLLA+ domain would be experienced infrequently.

As the table below indicates, 0.5 wt% is the level of moisture carryover (MCO) that has been evaluated for MELLLA+.The first two columns in the table below list the MELLLA+ submittal and text location that describes the previously installed steam dryer (PISD) or analyses that used PISD parameters.

The third column describes the contents (text) that are under review. The final column dispositions the text under review and determines that no actions or resolutions are required.Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-10-003, M+ Attachment 3, The 4 th paragraph has the statement: "There is a The MOO assumed for Extended Power LAR NEDC-33435P, potential increase in the steam moisture content Uprate (EPU) and MELLLA+ is 0.5% by ML100280558 Executive.

at certain times while operating in the MELLLA+ weight, while the estimated MCO for the Summary pg xii operating domain. The effects of the potential RSD is < 0.14% by weight. Thus, the increase in moisture content on plant hardware MELLLA+ SAR basis and evaluation have been evaluated and determined to be results bound MELLLA+ operation with acceptable." the RSD. Therefore, no change is required.L-MT-10-003, M+ Attachment 3, The 3 rd paragraph has the statement: "There is a The MCO assumed for EPU and LAR NEDC-33435P, potential increase in the steam moisture content MELLLA+ is 0.5% by weight, while the ML100280558 S1.0 pg 1-1 at certain times while operating in the MELLLA+ estimated MCO for the RSD is <0.14%operating domain. The effects of the potential by weight. Thus, the MELLLA+ SAR increase in moisture content on plant hardware basis and evaluation results bound have been evaluated and determined to be MELLLA+ operation with the RSD.acceptable." Therefore, no change is required.

L-MT-12-054 Enclosure 1 Page 2 of 6 Letter No. Locations Applicable Contents/Issues Required Actions or Resolution ADAMS No. Evaluated L-MT-10-003, M+ Attachment 3, Section 1.1.4, when referring to Section 8.0 The MCO assumed for EPU and LAR NEDC-33435P, states: "However, slightly higher loading of the MELLLA+ is 0.5% by weight, while the ML100280558 S1.1.4 pg 1-4 condensate demineralizers is possible if the estimated MCO for the RSD is <0.14%moisture carryover (MCO) in the reactor steam by weight. Thus, the MELLLA+ SAR increases.

The radiological consequences are basis and evaluation results bound evaluated to show that applicable regulations are MELLLA+ operation with the RSD.met." Therefore, no change is required.L-MT-10-003, M+ Attachment 3, Section 3.3.6 addresses "Steam Separator and The MCO assumed for EPU and LAR NEDC-33435P, Dryer Performance" and states: MELLLA+ is 0.5% by weight, while the ML100280558 S3.3.6 pg 3-8 "The evaluation of steam separator and dryer estimated MCO for the RSD is < 0.14%performance at MELLLA+ conditions indicates an by weight. Thus, the MELLLA+ SAR increase in MCO will occur. The effect of basis and evaluation results bound increasing steam moisture content has been MELLLA+ operation with the RSD.analyzed and is discussed in the following Therefore, no change is required.sections of this report: a. 3.5.1 Reactor Coolant Pressure Boundary Piping b. 8. 1 Liquid and Solid Waste Management

c. 8.4.2 Fission and Activation Corrosion Products d. 8.5 Radiation Levels e. 10.4 Testing f 10. 7.2 Flow Accelerated Corrosion The effect of increased MCO on plant operation has been analyzed to verify acceptable steam separator-dryer performance under MELLLA +operating conditions.

MCO is monitored during operation to ensure adequate operating limitations are implemented as required to maintain MCO within analyzed conditions."

L-MT-12-054 Enclosure 1 Page 3 of 6 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-10-003, M+ Attachment 3, Section 3.4.2 addresses "FIV Influence on The conclusion that MELLLA+ does not LAR NEDC-33435P, Reactor Internals," and lists the steam dryer as increase the steam flow is not changed ML100280558 S3.4.2 pg 3-10 one of the reviewed components.

by the introduction of the RSD. Thus, the RSD does not affect the Flow Induced Vibration (FIV) evaluation for MELLLA+.L-MT-10-003, M+ Attachment 3, Section 3.5.1.1 addresses "Main Steam and The MCO assumed for EPU and LAR NEDC-33435P, Feedwater Piping Inside Containment." MELLLA+ is 0.5% by weight, while the ML100280558 S3.5.1.1 pgs 3- The 3 rd paragraph has the statement:

estimated MCO for the RSD is < 0.14%12, 3-13 "...as discussed in Section 3.3.6, the MCO may by weight. Thus, the MELLLA+ SAR basis and evaluation results bound increase for a period of time during the cycle Mas operation with thuRd when a plant is operating at or near the MELLLA+ operation with the RSD.MELLLA+ minimum core flow rate. The time that Therefore, no change is required.a plant spends in this flow condition is not excessive.

The generic disposition concludes that the change in erosion/corrosion rates as a result of increased carryover is adequately managed by the existing programs discussed in Section 10. 7." The 4 th paragraph has the statement:

"...the MCO for Monticello may increase to a maximum of 0. 5 wt% for a period of time during the cycle when Monticello is operating at or near the MELLLA+ minimum core flow rate.Monticello implements programs adequate to manage this change in the erosion/corrosion rate as described in Section 10. 7."

L-MT-12-054 Enclosure 1 Page 4 of 6 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-10-003, M+ Attachment 3, Section 8.1.2 addresses "Waste Volumes," and The MCO assumed for EPU and LAR NEDC-33435P, the effects of potentially higher MCO. The MELLLA+ is 0.5% by weight, while the ML100280558 S8.1.2 pg 8-1 MELLLA+ SAR's MCO related evaluations and estimated MCO for the RSD is 0.14%conclusions are based on a MCO of 0.5%. by weight. Thus, the MELLLA+ SAR basis and evaluation results bound MELLLA+ operation with the RSD.Therefore, no change is required.L-MT-10-003, M+ Attachment 3, Section 8.4.2 addresses "Fission and Activation The MCO assumed for EPU and LAR NEDC-33435P, Corrosion Products," which could increase with MELLLA+ is 0.5% by weight, while the ML100280558 S8.4.2 pg 8-4 increased MCO. The Section's evaluation and estimated MCO for the RSD is 0.14%conclusion are based on a MCO of 0.5%. by weight. Thus, the MELLLA+ SAR basis and evaluation results bound MELLLA+ operation with the RSD.Therefore, no change is required.L-MT-10-003, M+ Attachment 3, Section 8.5.1 addresses "Normal Operational The MCO assumed for EPU and LAR NEDC-33435P, Radiation Levels," and Section 8.5.2 addresses MELLLA+ is 0.5% by weight, while the ML100280558 S8.5.1, S8.5.2 "Post-Shutdown Radiation Levels" both of which estimated MCO for the RSD is 0.14%pgs 8-5, 8-6 could increase with increased MCO. These by weight. Thus, the MELLLA+ SAR evaluations and conclusions in these sections basis and evaluation results bound are based on a MCO of 0.5%. MELLLA+ operation with the RSD.Therefore, no change is required.L-MT-10-003, M+ Attachment 3, Section 10.4.1 addresses "Steam Separator-The information in Section 10.4.1 is LAR NEDC-33435P, Dryer Performance" testing. applicable to any steam dryer, and does ML100280558 S10.4.1 pg 10-4 not conflict with any information regarding the RSD. Therefore, this section does not require change.

L-MT-12-054 Enclosure 1 Page 5 of 6 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-10-003, M+ Attachment 3, Section 10.7.2 includes addressing the MCO The MCO assumed for EPU and LAR NEDC-33435P, effects on "Flow Accelerated Corrosion." MELLLA+ is 0.5% by weight, while the ML100280558 S10.7.2 pgs 10- estimated MCO for the RSD is < 0.14%8, 10-9 by weight. Thus, the MELLLA+ SAR basis and evaluation results bound MELLLA+ operation with the RSD.Therefore, no change is required.L-MT-10-003, M+ Attachment 5, Attachment 5 is a nonproprietary version of This document does not require reissue LAR NEDO-33435 Attachment

3. as no proprietary changes have been ML100280558 made. No changes are proposed for Attachment 3, therefore, no changes to Attachment 5 are required.L-MT-10-003, M+ Attachment 6, Item T0304 addresses "Reactor Internal MELLLA+ does not involve increased LAR Risk Pressure Differences

& Fuel Lift Evaluation." flows, and thus, the T0304 is not ML100280558 Assessment, affected.

The Reactor Internal Pressure Table 3-1, Differential (RIPD) methodology was T0304, pg 3-10 discussed in enclosure 8 of L-MT-10-046 and no change to the MELLLA+evaluation is required.L-MT-10-003, M+ Attachment 6, Item T0306 addresses "Steam Dryer/Separator The MCO assumed for EPU and LAR Risk Performance," and discusses the effects of MELLLA+ is 0.5% by weight, while the ML100280558 Assessment, MCO. estimated MCO for the RSD is < 0.14%Tab. 3-1, T0306, by weight. Thus, the MELLLA+ SAR pg 3-10 basis and evaluation results bound MELLLA+ operation with the RSD.Therefore, no change is required.

L-MT-12-054 Enclosure 1 Page 6 of 6 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-10-017, M+ Attachment 1, RAI 2 requests MCO information, which is based The MCO assumed for EPU and Supplement for NRC Acceptance on the PISD. MELLLA+ is 0.5% by weight, while the Acceptance Review RAI 2, estimated MCO for the RSD is < 0.14%Review pgs 2, 3 by weight. Thus, the MELLLA+ SAR ML100710445 basis and evaluation results bound MELLLA+ operation with the RSD.Therefore, no change is required.Conclusion Based on the reviews provided above, no changes to any MELLLA+ documentation are required based on the installation of a replacement steam dryer.References El-1 Letter from T J O'Connor (NSPM), to Document Control Desk (NRC), "License Amendment Request: Maximum Extended Load Line Limit Analysis Plus," L-MT-1 0-003, dated January 21, 2010. (ADAMS Accession No.ML100280558)

L-MT-12-054 ENCLOSURE 2 Corrected Pages for NEDC-33435P, Revision I and NEDO-33435, Revision 1 In a letter from General Electric-Hitachi (GEH) dated March 24, 2010, GEH described a typographical error discovered in Table 1-1 of NEDC-33435P, Revision 1 and its companion document NEDO-33435, Revision 1 (non-proprietary version of NEDC-33435P). NEDC-33435P, Revision 1 was provided to the NRC as attachment 3 of enclosure 1 of reference E2-1 and NEDO-33435, Revision 1 was provided to the NRC as attachment 5 of enclosure 1 of reference E2-1.Table 1-1 of NEDC-33435P, Revision 1 identifies computer codes that were used in the production of the Maximum Extended Load Line Limit Analysis Plus (MELLLA+)

Safety Analysis Report (SAR). The table incorrectly identified that the computer code ODYN version 09 was used in the production of the MELLLA+ SAR. Rather Table 1-1 should have identified that ODYN version 10 was used in the production of the MELLLA+ SAR.The corrected pages are attached.

The attached corrected pages do not contain GEH proprietary information.

References:

E2-1 Letter from T J O'Connor (NSPM), to Document Control Desk (NRC), "License Amendment Request: Maximum Extended Load Line Limit Analysis Plus," L-MT-10-003, dated January 21, 2010. (ADAMS Accession No. ML100280558) 2 pages follow NEDC-33435P REVISION 1- CORRECTED PAGE GEH PROPRIETARY INFORMATION Table 1-1 Computer Codes Used in the M+SAR Evaluations Task Computer Version or NRC Comments Code Revision Approved Reactor Heat Balance ISCOR 09 Y(1) NEDE-2401 1 P Rev. 0 SER Reactor Core and Fuel TGBLA 06 Y(2) NEDE-30130P-A Performance PANAC 11 Y(2) NEDE-30130P-A ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER Thermal Hydraulic Stability ODYSY 05 Y NEDC-33213P-A TRACG 02 Y(15) NEDC-33147P-A Rev. 2 TRACG 04 N(15)ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER PANACEA 11 Y(3) NEDE-30130P-A Reactor Internal Pressure LAMB 07 (4) NEDE-20566P-A Differences TRACG 02 Y(5) NEDE-32176P, Rev. 2, Dec. 1999 NEDC-32177P, Rev. 2, Jan. 2000 NRC TAC No. M90270, Sept. 1994 ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER Reactor Pressure Vessel TGBLA 06 Y(2) NEDE-30130P-A (RPV) Fluence DORTG 01 Y (12, 13) CCC-543 Annulus Pressurization ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER Loads Transient Analysis PANAC 11 Y NEDE-30130P-A (6)ODYN 10 Y NEDE-24154P-A NEDC-24154P-A, Vol 4, Sup 1 ISCOR 09 Y (1) NEDE-24011P Rev. 0 SER TASC 03 Y NEDC-32084P-A Rev. 2 Anticipated Transient ODYN 10 Y NEDC-24154P-A, Vol 4, Sup 1 Without Scram (ATWS) STEMP 04 (7)PANACEA 11 Y(6)TASC 03A Y NEDC-32084P-A Rev. 2 ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER TRACG 04 N(14)Containment System M3CPT 05 Y NEDO-10320, April 1971 Response LAMB 08 (4) NEDE-20566P-A, September 1986 Reactor Recirculation BILBO 04V (8) NEDE-23504, Feb. 1977 System ECCS-Loss of Coolant LAMB 08 Y NEDE-20566P-A Accident (LOCA) GESTR 08 Y NEDE-23785-1P-A, Rev. 1 SAFER 04 Y (9)(10) (11)ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER TASC 03 Y NEDC-32084P-A

• The application of these codes to the MELLLA+ analyses complies with the limitations, restrictions, and conditions specified in the approving NRC SER where applicable for each code. The application of the codes also complies with the SERs for the extended power uprate programs.1-10 NEDO-33435 REVISION 1 -CORRECTED PAGE NON-PROPRIETARY INFORMATION Table 1-1 Computer Codes Used in the M+SAR Evaluations Task Computer Version or NRC Comments Code Revision Approved Reactor Heat Balance ISCOR 09 Y(1) NEDE-2401 IP Rev. 0 SER Reactor Core and Fuel TGBLA 06 Y(2) NEDE-30130P-A Performance PANAC 11 Y(2) NEDE-30130P-A ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER Thermal Hydraulic Stability ODYSY 05 Y NEDC-33213P-A TRACG 02 Y(15) NEDC-33147P-A Rev. 2 TRACG 04 N(15)ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER PANACEA 11 Y(3) NEDE-30130P-A Reactor Internal Pressure LAMB 07 (4) NEDE-20566P-A Differences TRACG 02 Y(5) NEDE-32176P, Rev. 2, Dec. 1999 NEDC-32177P, Rev. 2, Jan. 2000 NRC TAC No. M90270, Sept. 1994 ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER Reactor Pressure Vessel TGBLA 06 Y(2) NEDE-30130P-A (RPV) Fluence DORTG 01 Y (12, 13) CCC-543 Annulus Pressurization ISCOR 09 Y(1) NEDE-2401 1 P Rev. 0 SER Loads Transient Analysis PANAC 11 Y NEDE-30130P-A (6)ODYN 10 Y NEDE-24154P-A NEDC-24154P-A, Vol 4, Sup 1 ISCOR 09 Y (1) NEDE-2401 1 P Rev. 0 SER TASC 03 Y NEDC-32084P-A Rev. 2 Anticipated Transient ODYN 10 Y NEDC-24154P-A, Vol 4, Sup 1 Without Scram (ATWS) STEMP 04 (7)PANACEA 11 Y(6)TASC 03A Y NEDC-32084P-A Rev. 2 ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER TRACG 04 N(14)Containment System M3CPT 05 Y NEDO-10320, April 1971 Response LAMB 08 (4) NEDE-20566P-A, September 1986 Reactor Recirculation BILBO 04V (8) NEDE-23504, Feb. 1977 System ECCS-Loss of Coolant LAMB 08 Y NEDE-20566P-A Accident (LOCA) GESTR 08 Y NEDE-23785-1P-A, Rev. 1 SAFER 04 Y (9)(10) (11)ISCOR 09 Y(1) NEDE-24011P Rev. 0 SER TASC 03 Y NEDC-32084P-A

• The application of these codes to the MELLLA+ analyses complies with the limitations, restrictions, and conditions specified in the approving NRC SER where applicable for each code. The application of the codes also complies with the SERs for the extended power uprate programs.1-10