IR 05000263/2020012

Inspection of the Implementation of EA-13-09: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Report 05000263/2020012

ML20147A637
Person / Time
Site:	Monticello
Issue date:	05/26/2020
From:	Aaron Mccraw NRC/RGN-III/DRP/TSS
To:	Conboy T Northern States Power Co
References
EA-13-109 IR 2020012
Download: ML20147A637 (9)

Text

May 26, 2020

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT - INSPECTION OF THE IMPLEMENTATION OF EA-13-109: ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS REPORT 05000263/2020012

Dear Mr. Conboy:

On May 7, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Monticello Nuclear Generating Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Aaron T. McCraw, Team Leader

Technical Support Staff

Division of Reactor Projects

Docket No. 05000263 License No. DPR-22

Enclosure:

As stated

Inspection Report

Docket Number:

05000263

License Number:

DPR-22

Report Number:

05000263/2020012

Licensee:

Northern States Power Company, Minnesota

Facility:

Monticello Nuclear Generating Plant

Location:

Monticello, MN

Inspection Dates:

May 04, 2020 to May 07, 2020

Inspectors:

D. Krause, Resident Inspector

S. Sheldon, Project Engineer

Approved By:

Aaron T. McCraw, Team Leader Technical Support Staff

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an Inspection of The Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions at Monticello Nuclear Generating Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/readingrm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. From January 1 - March 19, 2020, the inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to postpone and reschedule the inspection to a later date.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

2515/193 - Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions

Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (1 Sample)

(1) Inspectors reviewed documentation, conducted walkdowns, and held discussions with licensee staff to verify implementation of a reliable hardened containment vent as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML19255F582) to determined compliance with NRC Order EA-13-109 Phase 1, Reliable, Severe Accident Capable Wetwell Venting System (ADAMS Accession No. ML13143A321).

The inspectors verified that the licensee satisfactorily:

• Installed the Hardened Containment Vent System (HCVS) to meet the performance objectives outlined in Section A.1.1 of Attachment 2 to the Order EA-13-109;

• Installed the HCVS system with the design features specified in Section A.1.2 of Attachment 2 to the Order EA-13-109;

• Designed the HCVS to meet the quality standards described in Section A.2 of 2 to the Order EA-13-109;

• Developed and implemented adequate maintenance and testing of HCVS equipment to ensure their availability and capability;

• Developed and issued procedures to safely operate the HCVS using normal power supplies, during Extended Loss of AC Power (ELAP), and a postulated severe accident scenario, and integrated the procedures into existing plant procedures; and

• Trained their staff to ensure personnel can proficiently operate the HCVS.

Inspectors reviewed documentation, conducted walkdowns, and held discussions with licensee staff to verify implementation of a reliable hardened containment vent as described in the plant specific submittal and the associated safety evaluation (ADAMS Accession No. ML19255F582) to determine compliance with NRC Order EA-13-109 Phase 2, Reliable, Severe Accident Capable Drywell (or alternative strategy) Venting System (ADAMS Accession No. ML13143A321).

The inspectors verified that the licensee satisfactorily developed a strategy making it unlikely that the licensee would need to vent from the containment drywell, that includes the following:

• Implemented the Severe Accident Water Addition (SAWA)/Severe Accident Water Management (SAWM) systems as defined and fulfilled functional requirements for installed and portable equipment;

• Installed and/or identified the previously-installed instrumentation necessary to implement SAWM;

• Developed and implemented adequate maintenance and testing of SAWA/SAWM equipment to ensure availability and capability;

• Developed and issued procedures to safely operate the SAWA/SAWM during an ELAP and during postulated severe accident scenario, and integrated their procedures into their existing plant procedures such that entry into and exiting from the procedures are clear when using existing plant procedures; and

• Trained their staff to ensure personnel can proficiently operate the HCVS during an ELAP and accident scenario.

The inspectors verified that any noncompliance with requirements, and standards identified during the inspection was entered into the licensee's corrective action program.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On May 7, 2020, the inspectors presented the Inspection of The Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions results to Mr. T. Conboy, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2515/193

Calculations

PRA-CALC-14-

003

Monticello MAAP Thermal Hydraulic Calculations to Support

Extended Loss of AC Power (ELAP) Mitigating Strategies

Corrective Action

Documents

501000002224

Hard Pipe Vent Rad Monitor Failure

501000008583

RM-4544 Signal Failure During Rounds

501000021681

B.5.B Vehicle Needs New Oil Pan

501000023266

Flex/Alternate Emergency Access Point

501000026426

RFO29 Flex Lead Bolt Issue

501000026766

Fuel Leak from FLEX Pump P-506

501000028840

Hole Developed on 5" 50ft Discharge Hose

501000030038

Potential FLEX Generator PM Enhancement

501000032050

HPV Rad Monitor Failed Off Scale Low

501000034669

FLEX Fire Hose Connection Icing Issue

501000035387

Snow Removal for FLEX Not Followed

501000035574

HCVS FSA SAWA Valve Testing

501000036074

RM-4544 Spiking/ Losing Power

501000036090

Hard Pipe Vent Rad Monitor Found Failed

501000038161

Hard Pipe Rad Monitor Power Loss

501000038252

RM-4544, HPV Rad Monitor failed

501000039165

Adverse Trend of HPV Rad Monitor

501000039448

SAWA Maint Plan Issue Not Addressed

Corrective Action

Documents

Resulting from

Inspection

501000040276

HCVS 2020 - Procedure Enhancement

05/05/2020

501000040360

HCVS 2020 - NRC Question on Procedures

05/06/2020

Drawings

NH-116629

Hard Pipe Vent System

P&ID

Miscellaneous

Monticello Nuclear Generating Plant FLEX Validation and

Staffing Addendum

2/01/2018

MT-OPS-CYCLE

18B RO

Training Attendance: Licensed Operator Requal for Cycle

18B

2515/193

Miscellaneous

FLEX

Diverse and Flexible Coping Strategies (FLEX) Program

Document

LOR-17B-005L

Training Lesson Plan

M-8107L-041

Initial Licensed Training Plan

M8119S-007

Training Simulator Scenario

MT-ILT-FLX-001L

Training Lesson Plan

MT-LOR-18B-

004L

Training Lesson Plan

MT-LOR-20B-

001S

Training Simulator Scenario

MT-NL0-18B-

001L

Training Lesson Plan

MT-NLO-FLX-

001-L

Training Lesson Plan

MT-OPS-CYCLE

17B LOR

Training Attendance: Licensed Operator Requal for

Cycle 17B

03/29/2017

MT-OPS-CYCLE

18B NLO

Training Attendance: Non-Licensed Operator Requal for

Cycle 18B

MT-OPS-CYCLE

18B SRO

Training Attendance: Licensed SRO Requal for Cycle 18B

QF 1040-16 - MT-

ILT-FLX-001L

Training Attendance Sheet

06/12/2018

Procedures

1415

Primary Containment Hard Pipe Vent Valve Exercise

AWI-04.05.01

General Work Controls

AWI-08.16.01

Monticello Emergency Operating Procedure and Beyond-

Design-Basis Guideline Maintenance Program

C.5-1200

Primary Containment Control

C.5-3203

Use of Alternate Injection Systems for RPV Makeup

C.5-3505

Venting Primary Containment

C.5-4050

SBO without High Pressure Injection

C.5-4051

Energize LPCI Swing Bus During SBO

C.5-4201

FLEX Portable Diesel Pump Staging and Hose Connection

C.5-4202

Portable Diesel Pump (PDP) Operation

C.5-4301

Spent Fuel Pool Makeup with FLEX Portable Diesel Pump

C.5-4453

Energize Hard Pipe Vent During SBO

FP-BDB-EQP-01

Equipment Important to BDB Compliance

FP-G-DOC-03

Procedure and Work Instruction use and Adherence

FP-OP-COO-27

Work Management

FP-PA-ARP-01

CAP Process

Work Orders

00491481

Hard Pipe Vent LLRT

05/12/2017

00533714 01

1415 PCT Hard Pipe Vent Valve Exercise

05/08/2017

00540339 07

HPV N2 Supply and Alternate Operating Station For

EC 26083

05/09/2017

00540342 19

EC26083 - Permanent Power Installation All Post Installation

Testing

05/03/2017

00540342 24

EC26083 - Initial Charge and Capacitance Testing

03/09/2017

700014154 0010

Primary Containment Hard Pipe Vent Valve Exercise

04/21/2019

700026369 0070

ECR6MOD0002692I - PDG Phase Rotation Check

03/26/2018

700026369 0080

ECR6MOD00026921 - B4353 Phase Rotation Check

03/15/2018

700040377 0010

P.507 Portable Diesel Pump Testing

06/12/2019

700040561 0010

1. 11 Portable Diesel Water Pump Testing

06/21/2019

700046725 0010

P-506 Diesel Fire Pump 12M PM

01/07/2020

700069919 0010

Periodic Cycle of Flex Valves

04/27/2020