L-MT-16-038, Seventh Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049)

Seventh Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049)

ML16235A005
Person / Time
Site:	Monticello
Issue date:	08/19/2016
From:	Gardner P Northern States Power Company, Minnesota, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-MT-16-038, TAC MF0923
Download: ML16235A005 (10)

Text

2807 West County Road 75 Monticello, MN 55362 800.895.4999 xcelenergy.com August 19, 2016 L-MT-16-038 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 Plants Seventh Six-Month Status Report 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) (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. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174).

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378).

4. NSPM Letter to NRC, Initial Status Report 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-12-088, dated October 29, 2012 (ADAMS Accession No. ML12305A420).

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5. 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).

6. NSPM Letter to NRC, Monticellos First Six-Month Status Report 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-13-079, dated August 28, 2013 (ADAMS Accession No. ML13241A200).

7. NSPM Letter to NRC, Monticello Nuclear Generating Plants Second Six-Month Status Report 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) (TAC No. MF0923), L-MT-14-014, dated February 28, 2014 (ADAMS Accession No. ML14065A037).

8. NSPM Letter to NRC, Monticello Nuclear Generating Plants Third Six-Month Status Report 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) (TAC No. MF0923), L-MT-14-073, dated August 28, 2014 (ADAMS Accession No. ML14241A260).

9. NSPM Letter to NRC, Monticello Nuclear Generating Plants Fourth Six-Month Status Report 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) (TAC No. MF0923), L-MT-15-004, dated February 24, 2015 (ADAMS Accession No. ML15055A599).

10. NSPM Letter to NRC, Monticello Nuclear Generating Plants Fifth Six-Month Status Report 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) (TAC No. MF0923), L-MT-15-059, dated August 19, 2015 (ADAMS Accession No. ML15232A553).

11. NSPM Letter to NRC, Monticello Nuclear Generating Plants Sixth Six-Month Status Report 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) (TAC No. MF0923), L-MT-16-009, dated February 22, 2016 (ADAMS Accession No. ML16053A454).

Document Control Desk Page 3 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 are outlined in Attachment 2 of Reference 1.

Pursuant to Condition C of Section IV, Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (ISG), an overall integrated plan, and status reports at six-month intervals following the submittal of the overall integrated plan. The ISG (Reference 2) endorses, with clarifications, an industry guidance document from the Nuclear Energy Institute (NEI), NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0 (Reference 3). Reference 4 provided the MNGP initial 60-day status report regarding mitigation strategies. Reference 5 provided the overall integrated plan for MNGP. The six-month status reports have been provided in References 6 through 11.

The purpose of this letter is to provide the seventh six-month status report pursuant to Section IV, Condition C.2 of Reference 1, which delineates the progress made in implementing the requirements of the Reference 1 Order. The enclosed report provides an update of milestone accomplishments since the Reference 11 status report was submitted, including changes to the compliance method, schedule, or the need and basis for relief, if any.

Please contact John Fields, at 763-271-6707, if additional information or clarification is required.

Document Control Desk Page 4 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 August ---l.f_, 2016.

Peter A.

Site Vice resident, 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-16-038 NSPM Enclosure Monticello Nuclear Generating Plant Seventh Six-Month Status Report for Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1.0 Introduction The Nuclear Regulatory Commission (NRC) issued Order EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, on March 12, 2012 (Reference 1). The Order required licensees 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. The Order required licensees to submit an Overall Integrated Plan (OIP), including a description of how the requirements in of the Order would be achieved. Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, submitted the OIP (Reference 2) for the Monticello Nuclear Generating Plant (MNGP) on February 28, 2013. In accordance with Section IV, Condition C.2 of Reference 1, NSPM submitted the first six-month status report on August 28, 2013 (Reference 3), the second six-month report on February 28, 2014 (Reference 4), the third six-month report on August 28, 2014 (Reference 6), the fourth six-month report on February 24, 2015 (Reference 9), the fifth six-month report on August 19, 2015 (Reference 10) and the sixth six-month report on February 22, 2016 (Reference 11).

On November 25, 2013, the NRC issued an Interim Staff Evaluation (ISE) for MNGPs Mitigating Strategies OIP (Reference 5). The ISE documents the NRCs conclusion that NSPM has provided sufficient information to determine that there is reasonable assurance that the OIP, when properly implemented, will meet the requirements of Order EA-12-049 at MNGP. The ISE also documents the confirmatory and open items identified by the NRC as a result of their review and audit of MNGPs OIP.

This Enclosure provides the seventh six-month status report. This status report includes an update of milestone accomplishments since submittal of the sixth six-month status report, including changes to the compliance method, schedule, or the need and basis for relief, if any. This status report also provides an update on NSPMs closure of the open and confirmatory items identified in the NRCs ISE, if any. This information is current as of July 31, 2016.

2.0 Milestone Accomplishments The original milestone schedule with target dates was provided in Attachment 2 of the Reference 2 Enclosure. No milestones were completed since the last six-month status report and prior to July 31, 2016.

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L-MT-16-038 NSPM Enclosure 3.0 Milestone Schedule Status The following Table 1 provides an update of the milestone schedule for the OIP. This table includes a brief milestone status and a revised target date, if the target date has changed. The target dates are planning dates subject to change as design and implementation details are developed. This schedule is current as of July 31, 2016.

No activity statuses or target dates have changed for this status report.

Table 1 - Overall Integrated Plan Milestone Schedule Revised Target Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report October 2012* Complete Submit Overall Integrated Plan February 2013* Complete Submit First Six-Month Status August 2013* Complete Report Commence Engineering January 2014 Complete Modification Design - Phase 2 &

3 Submit Second Six-Month Status February 2014* Complete Report National SAFER Response March 2015 Complete Center Operational (MNGP)

Procure Equipment April 2015 Complete Submit Third Six-Month Status August 2014* Complete Update Commence Installation for October 2014 Complete Online Modifications - Phase 2 and 3 Implement Storage April 2015 Complete Issue Maintenance Procedures March 2015 Complete Implement Training April 2015 Complete Submit Fourth Six-Month Status February 2015* Complete Report Submit Fifth Six-Month Status August 2015* Complete Report Submit Sixth Six-Month Status February 2016* Complete Report Submit Seventh Six-Month August 2016* Complete with Status Report this submittal Page 2 of 6

L-MT-16-038 NSPM Enclosure Table 1 - Overall Integrated Plan Milestone Schedule Revised Target Target Milestone Completion Activity Status Completion Date Date Submit Staffing Assessment Four months Complete prior to R27*

Complete Communication Four months Complete Recommendations prior to R27*

Issue Procedures Updated for May 2015 Complete FLEX strategies Implementation Outage May 2015 Complete (End of R27)*

Validation Walk-throughs April 2015 Complete Submit Completion Report July 2017 Not Started

• Required dates 4.0 Proposed Changes to Compliance Method There are no additional changes to the compliance methods in the Reference 2 OIP.

No updates to information in the OIP are included in this report.

5.0 Need and Basis for Relief from the Requirements of the Order NSPM expects to comply with the Order implementation date (as described below) and requirements. No relief from the requirements of the Order is required at this time.

On October 1, 2014, NSPM submitted a relaxation request to the NRC for Order EA-12-049 (Reference 7). The relaxation request was proposed because the installation of a containment wetwell vent that meets the requirements of Order EA-13-109, Phase I, will take additional time to complete, as compared to the compliance dates associated with Order EA-12-049. On November 21, 2014, the NRC approved the requested relaxation (Reference 8).

NSPM plans to provide the NRC with a report that full compliance with the EA-12-049 order has been achieved within 60 days after completion of the 2017 refueling outage.

The Submit Completion Report milestone is consistent with the current projected completion of the 2017 refueling outage, plus 60 days.

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L-MT-16-038 NSPM Enclosure 6.0 Open Items from Overall Integrated Plan and Interim Staff Evaluation NSPM did not identify any open items in the MNGP Mitigating Strategies OIP. The OIP contained future actions to ensure compliance with the Order. The future actions were identified internally and are being tracked through NSPMs corrective action program (CAP).

On November 25, 2013, the NRC issued the ISE for MNGPs Mitigating Strategies OIP (Reference 5). As a result of the review and audit of MNGPs OIP, the NRC identified a list of confirmatory and open items that required additional follow-up or resolution.

Subsequently, during the week of November 17, 2014, the NRC held an onsite audit to assess MNGPs readiness for compliance with Order EA-12-049.

NSPM provided a full update to ISE open items and audit questions in a separate letter to the NRC dated October 12, 2015 (Reference 12). Subsequent to the Reference 12 letter, the NRC opened an additional item identified as SE 11. NRC sent SE 11 to NSPM in an email dated November 13, 2015 (Reference 13). NSPM will continue to provide information to the NRC via the online reference portal as necessary.

7.0 Potential Interim Staff Evaluation Impacts No potential impacts of ISE updates are proposed in this report.

8.0 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. 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).

3. NSPM Letter to NRC, Monticellos First Six-Month Status Report 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-13-079, dated August 28, 2013 (ADAMS Accession No. ML13241A200).

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L-MT-16-038 NSPM Enclosure

4. NSPM Letter to NRC, Monticello Nuclear Generating Plants Second Six-Month Status Report 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) (TAC No. MF0923), L-MT-14-014, dated February 28, 2014 (ADAMS Accession No. ML14065A037).

5. NRC Letter to NSPM, Monticello Nuclear Generating Plant - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF0923), dated November 25, 2013 (ADAMS Accession No. ML13220A139).

6. NSPM Letter to NRC, Monticello Nuclear Generating Plants Third Six-Month Status Report 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) (TAC No. MF0923), L-MT-14-073, dated August 28, 2014 (ADAMS Accession No. ML14241A260).

7. NSPM Letter to NRC, Request for Relaxation from NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events - Monticello Nuclear Generating Plant, L-MT-14-083, dated October 1, 2014 (ADAMS Accession No. ML14289A512).

8. NRC letter to NSPM, Monticello Nuclear Generating Plant- Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events (TAC No. MF0923), dated November 21, 2014 (ADAMS Accession No. ML14294A061).

9. NSPM Letter to NRC, Monticello Nuclear Generating Plants Fourth Six-Month Status Report 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) (TAC No. MF0923), L-MT-15-004, dated February 24, 2015 (ADAMS Accession No. ML15055A599).

10. NSPM Letter to NRC, Monticello Nuclear Generating Plants Fifth Six-Month Status Report 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) (TAC No. MF0923), L-MT-15-059, dated August 19, 2015 (ADAMS Accession No. ML15232A553).

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L-MT-16-038 NSPM Enclosure

11. NSPM Letter to NRC, Monticello Nuclear Generating Plants Sixth Six-Month Status Report 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) (TAC No. MF0923), L-MT-16-009, dated February 22, 2016 (ADAMS Accession No. ML16053A454).

12. NSPM Letter to NRC, Monticello Nuclear Generating Plant: Update of Information Related to NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events (TAC No. MF0923), L-MT-15-047, dated October 12, 2015, (ADAMS Accession No. ML15288A132).

13. Email from P. Bamford (NRC) to J. Fields (NSPM), New SE Tracker Question for Monticello Mitigating Strategies Audit, dated November 13, 2015.

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