ML23006A133

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Submittal of Revision 40 to Updated Safety Analysis Report
ML23006A133
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 12/19/2022
From: Hafen S
Xcel Energy, Northern States Power Company, Minnesota
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML23006A159 List:
References
L-MT-22-021
Download: ML23006A133 (1)


Text

ENCLOSURE 4 CONTAINS SECURITY-RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390 WHEN SEPARATE FROM ENCLOSURE 4 THIS DOCUMENT IS DECONTROLLED (l, Xcel Energy* 2807 West County Road 75 Monticello, MN 55362 December 19, 2022 L-MT-22-021 10 CFR 50.71(e) 10 CFR 50.59(d)(2)

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 Submittal of Revision 40 to the Updated Safety Analysis Report Pursuant to 10 CFR 50.71 (e) , Revision 40 to the Monticello Nuclear Generating Plant (MNGP)

Updated Safety Analysis Report (USAR) is provided . This revision completes an update of the information in the USAR for the period from December 17, 2021. to October 28, 2022.

The changes in this revision reflect the incorporation of modifications, license amendments, and editorial corrections and clarifications. These changes are made in accordance with the guidance provided in Nuclear Energy Institute (NEI) Report NEI 98-03, "Guidelines for Updating Final Safety Analysis Reports", Revision 1. dated June 1999 and Regulatory Guide 1.181, "Content of the Updated Final Safety Analysis Report in accordance with 10 CFR 50.71(e)", dated September 1999. , "Report of Changes, Tests and Experiments", states that there were no 10 CFR 50.59 evaluations performed . This report is provided as required by 10 CFR 50.59(d)(2) . , "Report of Changes to Licensee Docketed Commitments", indicates that in accordance with the guidance provided in NEI 99-04 , "Guidelines for Managing NRC Commitment Changes", dated July 1999, for this period, there were three (3) commitment retirements and two (2) changes to commitments . , "Summary of Information Removed from the USAR", provides the information removed from the USAR for this revision cycle . This information is provided in accordance with Revision 1 of NEI 98-03 and Regulatory Guide 1.181 . contains Revision 40 of the MNGP USAR . The USAR is being submitted electronically, in its entirety, on CD-ROM according to the instructions in Regulatory Issue RECEI VED DEC 2 7 2022

ENCLOSURE 4 CONTAINS $ECURITY-RELATED INFORMATION WITHHOLD UNDl;R 10 CFR 2.390 WHEN SEPARATE FROM ENCLOSURE 4 THIS DOCUMENT IS DECONTROLLED L-MT-22-021 Page 2 of 2 Summary (RIS) RIS 2001-005, "Guidance on Submitting Documen~ to the NRC by Electronic lnfonnation Exchange or on CD-ROM". , "Report of Changes to the Monticello Fire Protection Program", provides a summary of changes to the program. Changes to the Fire Protection Program are provided in accordance with the guidance contained in Generic Letter 86-10, "Implementation of Fire Protection Requirements", dated April 24, 1986. consistent with the guidance in RIS *2007-16, "Implementation of Requirements of 10 CFR 54.37(b) for Holders of Renewed Licenses*, contains a review of engineering changes, equipment list changes, USAR changes, changes to SSC's credited to 10 CFR 54.4(a)(3) regulated events, and changes to time limited agin*g analyses (TLAA's) was conduged for the review period of ~mber 16, 2021 to October 28, 2022. These changes were reviewed to identify componemts installed that had not previously been screened or screened incorrectly for being in scope of License Renewal Aging Management.

Summary of Commitments This letter contains three (3) commitment retirements and two (2) changes to a commitment (Enclosure 2).

In accordance with 10 CFR 50.71 (e)(2), I certify that the information presented herein, accurately presents changes made since the previous submittal prepared pursuant to Commission requirement and identifies changes made under the provisions of 10 CFR 50.59 not previously s mitted to the Commission.

Sha~

Plant Mana r onticello Nuclear Generating Plant Northern s Power Company - Minnesota Enclosures (6) cc: Administrator, Region Ill, USNRC Resident Inspector, Monticello, USNRC (without enclosure 4)

State of Minnesota, Department of Commerce (letter with enclosure 1)

ENCLOSURE 1 MONTICELLO NUCLEAR GENERATING PLANT REPORT OF CHANGES, TESTS AND EXPERIMENTS The following includes a brief description and summary of the 10 CFR 50.59 for those changes, tests and experiments that were carried out without prior U.S. Nuclear Regulatory Commission (NRG) approval, pursuant to the requirements of 10 CFR 50.59(d)(2).

  • For the period December 17, 2021 fo October 28, 2022 there were no 50.59 evaluations perfonned.

Page 1 of 1

ENCLOSURE 2 MONTICELLO NUCLEAR GENERATING PLANT REPORT OF CHANGES TO LICENSEE DOCKETED COMMITMENTS Commitments are Identified and reported to the Commi~slon in accordance with guidance provided In NEI Technical Report 99-04 Revision 0, "Guidelines for Managing NRC Commitment Changes."

This enclosure provides a brief description and a summary of changes to commitments established with the NRC by the Montlcello Nuclear Generating Plant (MNGP) per NEI 99-04 guidelines.

For Revision 40:

Three (3) commitments are being retired from the MNGP commitment tracking program and two (2) commitment is being changed.

1. Commitment Tracking Number:

M79167A (Commitment Change)

Commitment source document:

A letter dated December 31 1979, titled gMonticello Nuclear Generating Plant Lessons Learned Short Term Requirements Methods of Implementation for items required by January 1, 1980, Letter from L.O. Mayer to Director of Nuclear Reactor Regulation [ML112990354].

Orlginal Commitment Wording:

A permanent process to conduct independent verifications of system alignments on a periodic basis will be established with qualified personnel from the Plant Quality Group.

It is expected that verifications by these personnel will commence prior to restart following the February-March 1980 refueling outage.

Justification:

The intent of this commitment is to ensure that status control is being maintained through the effective use of turnover procedures. The verification of system alignments by operations personnel will validate that status control is being maintained using turnover procedures. -

Operations personnel are responsible for maintain plant configuration and understanding plant status. Relocating the commitment associated with maintaining status control to the Operations-responsible procedure is prudent to ensure the individuals most familiar with plant status are accountable for maintaining the verification that the plant systems are in the expected alignment. The effectiveness of this procedure is maintained through programmatic assessments and independent reviews of the performance.

2. Commitment Tracking Number:

M79178A (Commitment Retirement)

Commitment source document:

Technical Evaluation Report from C. Bomberger (Franklin Research Center) to NRC, TER-C55506-370, acontrol of Heavy Loads: Monticello Nuclear Generating Station/

dated January 30, 1984 (ADAMS Accession No. ML113330320)

Page 1 of 3 Orlglnal Commitment Wording:

Training in radioactive material shipping Is now Included in the plant Radiation Protection Specialist Training and Retraining Program. The training program foroperations and

  • maintenance personnel will be upgraded by October 1, 1980, to include appropriate training in radioactive material shipping.

Justification:

The response to an NRC IE Bulletin was a one-time commitment in that it implemented the training requirements for personnel ir:,volved in radioactive material shipping. In addition to the Bulletin, this same training is required by DOT regulations in 49 CFR 172, Subpart H, and will be maintained going forward.

3. Commitment Tracking Number:

M05043A (Commitment Change)

Commitment source document:

Letter MT-05-014 the following commitment was made:

Original Commitment Wording:

MNGP intends to use the Integrated Surveillance Program during the period of extended operation by implementing the requirements of BWRVIP-116, which is currently being reviewed by the NRC.

Justification:

The commitment is being changed because BWRVI P-116 has been retired and superseded by BWRVIP-86 Revision 1-A. Currently the BWRVIP ISP program guidance is provided in BWRVIP-86, Revision 1-A which states in Section 1,, "This report combines BWRVIP-86-A and BWRVIP-116 to provide a comprehensive ISP Implementation Plan for both the original and renewed license periods." BWRVIP-86 Revision 1-A has been approved by the NRC in a letter dated October 20, 2011 (ML112780503).

4. Commitment Tracking Number:

M92094A (Commitment Retirement)

Commitment source document:

August 8, 1992 NRC Supplemental Safety Evaluation for Station Blackout Original Commitment Wording:

The licensee states that it will utilize alternative replacement criteria that ensures that batteries never reach the point of requiring accelerated testing. The criteria are (a) 85%

of life has been reached, (b) battery capacity drops more than 10% of rated capacity as determined by previous performance test, and (c) test data and calculations indicate that capacity will drop below 90% during the subsequent operating cycle. In order to do this, the licensee will perform a performance test each cycle, rather than at the five-year intervals specified in IEEE-450.

Page 2 of 3 Justification:

This requirement for a test each cycle existed in Custom-Tech Specs (CTS) at the time of the 1992 SE which this commitment is capturing. Subsequently, this condition was carried over Into TS SR 3.8.6.6 / SR 3.8.4.3 during ITS conversion; it is presently maintained in TS with both TS SRs adjusted via NRG-approved license amendment for implementing the Surveillance Frequency Control Program.

5. Commitment Tracking Number:

M91186A (Commitment Retirement)

Commitment source document:

November 22, 1991 NSP letter to NRC, "Response to NRC Recommendations Contained in 'Monticello Station Blackout Evaluation, dated august 22, 1991 ",

ML113110790.

Original Commitment Wording:

(M91186A) Resolution of Recommendation No. 2.c: An aging factor of 1.11 has been used in our 250 volt battery capacity calculations. We believe that use of this factor is Justified because it is Monticello practice to replace batteries when:

1) 85% expected service life is reached, or;
2) Battery capacity drops more than 10% of rated capacity from its capacity on the previous test.or;
3) Battery capacity tests at or below 90% of the manufacturer's rating.

These replacement criteria, which will be Incorporated Into plant procedures, are used in lieu of the less conservative IEEE Std 450 recommended practice of battery replacement when a capacity test of the battery shows its capacity had dropped to below 80% of the manufacturer's rating.

Justification:

This commitment has been Incorporated into TS SR 3.8.6.6 / SR 3.8.4.3 during ITS conversion and is currently maintained in TS with an adjustment since for implementing the Surveillance Frequency Control Program. The obligation as worded In the TS is not being changed; only the retirement of these two commitments which preceded the current TS obligation.

Page 3 of 3

ENCLOSURE 3 MONTICELLO NUCLEAR GENERATING PLANT

SUMMARY

OF INFORMATION REMOVED FROM THE USAR Consistent with the guidance in Nuclear Energy Institute (NEI) Report NEI 98-03, "Guidelines for Updated Final Safety Analysis Reports," Revision 1 and Regulatory Guide 1.181, "Content of the Updated Final Safety Analysis Report in Accordance With 10 CFR 50.71(e)," Information removed from the Monticello Nuclear Generating Plant Updated Safety Analysis Report (USAR) for the period December 17, 2021 to October 28, 2022 is summarized below.

  • USAR Change 604000000753 Affectec;I section:

Section USAR-03, Reactor Table 3.1-2, Design Basis Limits for Fission Product Barriers Editorial change, explicit list .of Design Basis Limits for Fission Product Barriers was removed to eliminate redundant information.

All information contained in this table is ineluded in the USAR, in a report this incorporated by reference into the USAR or is from a CFR for which compliance is noted in the USAR.

  • USAR Change 604000000761 Affected sections:

Section USAR-J.5, Updated Fire Hazards Analysis Attachment A, Fire Hazards Analysis Matrices Fire Hazard Analysis Matrix for Fire Zone 2C removed duplication of 21 D/1 ceiling in Fire Area Barrier table.

Fire Hazard Analysis Matrix for Fire Zone 12A removed V-DF-516 from Fire Dampers in Required Barrier table.

Fire Hazard Analysis Matrix for Fire Zone 14A removed V-DF-516 from Fire Dampers in Required Barrier table.

Fire Hazard Analysis Matrix for Fire Zone 198 removed V-DF-136 and V-DF-113 from Fire Dampers in Required Barrier table.

Fire Hazard Analysis Matrix for Fire Zone 23A removed 41/IX as a Fire Area Barrier.

Fire Hazard Analysis Matrix for Fire Zone 31 B removed V-DF-113, V-DF-120 and V-DF-137 from Fire Dampers in Required Barrier table.

Page 1 of 2

Fire Hazard Analysis Matrix for Fire Zone 32A removed Fire Zone 318/XXII from Fire Dampers in Required Barrier table.

Fire Hazard Analysis Matrix for Fire Zone 328 removed Fire Zone 198/XII from Fire Dampers in Required Barrier table.

Attachment C, Fire Dampers Fire Dampers V-DF-516 and V-DF-113 removed based on fire damper changes.

Page 2 of 2

ENCLOSURE 4 CONTAINS SECURITY-RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390 ENCLOSURE 4 MONTICELLO NUCLEAR GENERATING PLANT USAR REVISION 40 SEE ENCLOSED CD-ROM ENCLOSURE 4 CONTAINS SECURITY-RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390

ENCLOSURE 4 - DISC 1 MONTICELLO NUCLEAR GENERATING PLANT USAR REVISION 40 ENCLOSED CD-ROM File Name Rev. 40 File Size (KB) 001 - USAR LOEP 168 002 - USAR TOC 120 003 - USAR Section 1 910 004 - USAR Section 2 2,297 005 - USAR Section 3 1,771 006 - USAR Section 4 1,968 007 - USAR Section 5 4,645 008 - USAR Section 6 1,722 009 - USAR Section 7 2,306 010 - USAR Section 8 1,190 011 - USAR Section 9 350 012 - USAR Section 10 767 013 - USAR Section 11 1,030 014 - USAR Section 12 727 015 - USAR Section 13 215 016- USAR Section 14 3,731 017 - USAR Section 15-1, Part 1 of 2 136 017 - USAR Section 15-2 DRAWING SET, Part 2 of 2 29,871 018 - USAR Appendix A 9,824 019 - USAR Appendix C 59 020 - USAR Appendix D 350 021 - USAR Appendix E 492 022 - USAR Appendix F 6,419 023 - USAR Appendix- G 1,800 024 - USAR Appendix H 31,643 7 025 - USAR Appendix I 448 026 - USAR Appendix J 5,525 027 - USAR Appendix K 626 ----

j -

ENCLOSURE 4 - DISC 2 - Security Related Information MONTICELLO NUCLEAR GENERATING PLANT USAR REVISION 40 ENCLOSED CD-ROM File Name Rev. 40 File Size (KB) 006 - USAR Section 4 160 007 - USAR Section 5 116 Q16- USAR Section 14.1 134 016 - USAR Section 14.2 139 016 - USAR Section 14.3 139 017 - USAR Section 15-2 Drawing Set 15,476 018 - USAR Appendix A 152 025 - USAR Appendix I 3,536 026 - USAR Appendix J 645

ENCLOSURE 5 MONTICELLO NUCLEAR GENERATING PLANT REPORT OF CHANGES TO THE MONTICELLO FIRE PROTECTION PROGRAM This enclosure contains a report of changes to the Monticello Fire Protection Program (FPP) in accordance with the provisions of Generic Letter (GL) 86-10.

In conformance with GL 86-10, the Updated Fire Hazards Analysis (UFHA) and the Safe Shutdown Analysis (SSDA) are incorporated directly into the Updated Safety Analysis Report (USAR) as Appendix J.5 and J.4 respectively. The following summarizes fire protection program document changes since the previous submittal.

1. USAR J.04, SAFE SHUTDOWN ANALYSIS None
2. USAR J.05, FIRE HAZARDS ANALYSIS Revision 40 Licensing Document Change 604000000761 Rev. 1 o Pgs. 515- 516 4 AWl-08.01.00 was replaced with

.FIREPROTECT because 4 AWl-08.01 .00 was superseded by FIREPROTECT.

o Pg 516 4 AWl-08.01 .01 was replaced with FIREPREVENT because 4 AWl-08.01 .01 was superseded by FIREPREVENT.

o Table 2 - Fire Zone Summary was revised to correct the square footage of Fire Zones 7A, 78, and 7C.

o Fire Hazard Analysis Matrix for Fire Zone 1F changed 8NIII to 1D/11 in Fire Area Sarrier table.

o Fire Hazard Analysis Matrix for Fire Zone 2C removed duplication of 21 D/1 ceiling in Fire Area Barrier table.

o Fire Hazard Analysis Matrix for Fire Zone 3C editorial change Fire Dampers in Required Barrier table for consistency to (1 - Comment 2) N/A .

o Fire Hazard Analysis Matrix for Fire Zone 8 editorial change to Fire Area from VI to VII I o Fire Hazard Analysis Matrix for Fire Zone 10 editorial change to square footage from 42,791 to 40,115 o Fire Hazard Analysis Matrix for Fire Zone 12A removed V-DF-516 from Fire Dampers in Required Barrier table o Fire Hazard Analysis Matrix for Fire Zone 12C editorial change Fire Dampers in Required Barrier table for consistency to (1 - Comment 2) N/A and changed "None" to "NIA" Page 1 of 3

o Fire Hazard Analysis Matrix for Fire Zone 12C Section IX updated the Portable Extinguishers wording o Fire Hazard Analysis Matrix for Fire Zon*e 12E editorial change Fire Dampers in Required Barrier table for consistency to (1 - Comment 2), N/A o Fire Hazard Analysis Matrix for Fire Zone 14A removed V-DF516 from Fire Dampers in Required Barrier table o Fire Hazard Analysis Matrix for Fire Zone 14B change made to Fire Area Barrier table to change 14A/XI 11 to 14A/XI I o Fire Hazard Analysis Matrix for Fire Zone 19B removed V-DF-136 and V-DF-113 from Fire Dampers in Required Barrier table o Fire Hazard Analysis Matrix for Fire Zone 23A removed 41 /IX as a Fire Area Barrier o Fire Hazard Analysis Matrix for Fire Zone 31 B editorial chan*ges made to Fire Area Barrier table changing 20/XII to 20/XXIV and 19/XII to 198/XI I o Fire Hazard Analysis Matrix for Fire Zone 31 B removed V-DF-113, V-DF-120 and V-DF-137 from Fire Dampers in Required Barrier table o Fire Hazard Analysis Matrix for Fire Zone 32A editorial changes made to Fire Area Barrier table changing* 20/XII to 20/XXIV o Fire Hazard Analysis Matrix for Fire Zone 32A removed Fire Zone 318/XXII row and added V-DF-120, V-DF-136, and V-DF-137 to Fire Zone 328/XXII row in the Fire Dampers in Required Barrier table o Fire Hazard Analysis Matrix for Fire Zone 328 removed Fire Zone 198/XII row and added V-DF-120, V-DF-136, and V-DF-137 to Fire Zone 32A/XXI row in the Fire Dampers in Required Barrier table o Attachment B changed fire door number/ID from 18A to 18.

o Attachment C Removed V-DF-516 Removed V-DF-113 Revised V-DF-136 from 198-32A to 32A-328 and East to South Revised V-DF-120 from 31 B-32A to 32B-32A Revised V-DF-137 from 318-32A to 32B-32A

3. FIREPROTECT, FIRE PROTECTION PROGRAM PLAN (was 4 AWl-08.01 .00)

Revision 02 PCR 602000020861 o Revised to include Supply Chain and Supply Chain responsibilities to 4.4 - Organization, 4.10 - Quality Assurance.

o Procedure Numbers and Titles were updated throughout.

Page 2 of 3

4. B.08.05-05, FIRE PROTECTION - SYSTEM OPERATION, TABLES A.2-1, A.2-2, A.2-3 AND A.2-4 Revision 82 PCR 602000023498 o Table A.2 LPCI Swing Bus Undeivoltage Relaying was added to functionality requirements (Specification J) and bases section.

o Table A.2 Bases section revised to include that the fire pumps can be started automatically as well as manually to meet NRC and NFPA code, and are required to be automatically started to meet NEIL requirements.

o Table A.2 None o Table A.2 None Page 3 of 3

Enclosure 6 Report Consistent with 10 CFR 54.37(b)

This summary report is in lieu of adding a level of detail to the Monticello Nuclear Generating Plant (MNGP) Updated Safety Evaluation Report (USAR) that is greater in the remainder of the USAR, including the License Renewal Supplement in Appendix K The contents of this report are consistent with the requirements of 10 CFR 54.37(b) and the guidance of Regulatory Issue Summary (RIS) 2007-16, "Implementation of the Requirements of 10 CFR 54.37(b) for Holders of Renewed Licenses" (ADAMS Accession Number ML100250279).

Three corrective actions were initiated that identified structures, systems, and components (SSCs) that should have been subject to aging management review had they been identified at the time of the initial license renewal application. One corrective action identified that the Condensate Storage Tanks (CSTs) and associ_ated piping are credited for Station Black Out (SBO). Two corrective actions identified systems and components *credited for Alternate Source Term (AST). The following discussion describes how the effects of aging will be managed for these SSCs to ensure the applicable License Renewal intended functions are effectively maintained throughout the period of extended operation.

Condensate Storage Tank Summary During review of the licensing basis for SBO in support of the Subsequent License Renewal (SLR) project, it was discovered that T-1A and T-1 B, Condensate Storage Tanks, should have been considered for inclusion within scope of first license renewal.

The CSTs were excluded from scope of first license renewal as they were not originally credited for SBO. However, subsequent to the first license renewal the SBO analysis was changed to credit CST inventory as part of Extended Power Update (EPU). Therefore, the CSTs and associated piping are incorporated into the scope of License Renewal per 10 CFR 54.37(b). Specifically, this USAR update incorporates the following components:

  • T-1A and T-1 B, Condensate Storage Tanks
  • The associated line segments exiting the CSTs to the first isolation valve as shown on drawing NH-36039
  • CST-1-1 and CST-1-2 piping downstream of CSTs to where this line intersects with existing License Renewal boundary as shown on LR-36039.
  • CST-2-1 and CST-2-2 piping downstream of CSTs to where this line intersects with existing License Renewal boundary as shown on LR-36039.
  • CST-6-1 and CST-6-2 piping downstream of CSTs to where this line intersects with

.existing License Renewal boundary as shown on LR-36039, including CST-160-1 and CST-160-2.

A new aging management program, Outdoor and Large Atmospheric Metallic Storage Tanks (OLAMST), will manage the aging effects of the CSTs. Additionally, portions of the newly identified CSTs and associated piping will be managed by the following existing AMPs:

  • EWl-11.01 .07, Structures Monitoring Program lof 13
  • EWl-11.01 .13, System Condition Monitoring Program
  • EWl-11.01 .14, Buried Piping and Tanks Inspection
  • EWl-11.01 .33, Bolting Integrity
  • 11.16, Plant Chemistry Program Table 1 describes the how the effects of aging will be managed such that the intended function will be effectively maintained during the period of extended operation for newly scoped in components listed above. In addition, had this been identified at the time the when the SBO analysis was updated, the CSTs would have been included in the One Time Inspection program to verify that unacceptable degradation was not occurring. The One Time Inspection Program related to this issue can be consider satisfied based on internal inspection of the CSTs in 2017. This included both above and belqw the waterline visual inspections, UT of the tank floor (bottom), cleaning of the tanks, and coating repairs as needed.

2 of 13

Table f Aging Management Review Condensate Storage System Component Material Environment 3.x.2 Table Aging Effect Aging Management Type Ref. or Requiring Program Internal External Aging Effect Management (AMPs)

Evaluation (AERMs)

(AEE)

Condensate Carbon Treated NUREG-1801, Rev 0 Loss of Material - II. 16, Plant Chemistry storage Tank steel water (April 2001) General, pitting, and Program (XI.M2).

Table V/1I.E.5-a crevice corrosion Table V/11.E.5.1 Monticello One .Time Inspection Program (XI.M32)

Condensate Carbon Treated Outside Air NUREG-1801, Rev 0 Loss of Material - New AMP for Outdoor storage Tank Steel Water (described in (April 2001) General corrosion and Large Atmospheric (aboveground, NUREG-1801 as Table V/11.E.5-c Metallic Storage Tanks external Air "Sun, weather, Table V/1I.E.5.1 (OLAMS7J (XI.M29) surfaces) humidity, and moisture")

Condensate Carbon Buried NUREG-1801, Rev 0 Loss of Material - EWl-11.01.14, Buried storage Tank steel (described in (April 2001) General, pitting, Piping & Tanks Inspection (buried, NUREG-1801 as Table V/1I.E.5-d crevice, and (XI.M34) external "Soil and ground Table VI/I.E.5.1 microbiological/y surfaces) water'? influenced corrosion 3 of 13

Fasteners/ Carbon Outside Air NUREG-1801, Rev 0 Loss of Material - EW/-11.01.33, Bolting Bolting steel (described in (April 2001) General Integrity (XI.Mt 8)

NUREG-1801 as Table VIII.H.1-b (Environmental)

Stainless "Sun, weather, Table VII/.H.1.1 Corrosion, Galvanic steel humidity, and Corrosion, and Pitting moisture") Corrosion Expansion Rubber Treater Outside Air LRA Table 3.4.2-2 Thenna/ exposure New AMP for Outdoor Joints Water (described in and Large Atmospheric NUREG-1801 as Metallic storage Tanks "Sun, weather, (OLAMST) (X/.M29) humidfty, and moisture")

Valves, piping, Carbon Treated Outside Air NUREG-1801, Rev 0 Loss of Material - New AMP for Outdoor

& fittings Steel Water (described in (April 2001) General, pitting, and Large Atmospheric NUREG-1801 as Table VIII.E.1-b cracking, and crevice Metallic storage Tanks Stainless "Sun, weather, Table VIII.E.1.1 corrosion (OLAMST) (X/.M29)

Steel humidfty, and Table VIII.E.2-b moisture'? Table VII/.E.2. 1 EW/-11.01.13, System Condition Monftoring Program (LRA Section 82.1.32) 4 of 13

Alternate Source Term Summary During review of the licensing basis for AST in support of the Subsequent License Renewal (SLR) project, it was discovered that various non-safety related Main Steam system piping and drains, as well as other balance of plant systems, were only identified for their pressure boundary intended function and not their plate out and holdup function. Additionally, the E-4 Steam Packing Exhauster was not identified as being in scope of first license renewal, when it should have been included due to the plate out and holdup functions for AST.

It was also discovered that an Aging Management Review was not performed on the Off-Gas System during the first License Renewal project. This resulted in omission of SSCs within the Off-Gas System credited for AST from scope of first License Renewal.

Therefore, applicable SSCs credited for AST are part of the scope of first License Renewal per 10 CFR 54.37(b).

The following existing AMPs were revised to indicate that Alternate Source Term (AST) is in scope, including changes to the Material/Environment/Aging Effects Figures within these AMPs:

  • EWl-11.01 .07, Structures Monitoring Program
  • EWl-11.01 .12, Open-Cycle Cooling Water System
  • EWl-11.01 .13, System Condition Monitoring System
  • EWl-11.01 .14, Buried Piping & Tanks Inspection
  • EWl-11.01 .15, Flow-Accelerated Corrosion
  • EWl-11.01 .33, Bolting Integrity
  • EWl-11.01 .35, Selective Leaching
  • 11.16, Plant Chemistry Program In addition, had this been identified at the time the License Renewal Application was submitted, the SSCs impacted by AST would have been included in the One Time Inspection program to verify that unacceptable degradation was not occurring. The One Time Inspection Program was reviewed to ensure original sample scope remains valid with the newly identified SSCs.

Table 2 describes how the effects of aging will be managed such that the intended function will be effectively maintained during the period of extended operation for the SSCs credited for AST.

5 of13

Table 2: Aging Management Review of Systems credited by Alternate Source Term Component Material Environment 3.x.2 Table Ref. Aging Effect Aging Management Type Internal External or Requiring Program (AMPs)

Aging Effect Evaluation Management (AEE) (AERMs)

Piping and Carbon steam NUREG-1801, Rev 0 Loss of Material - II. 16, Plant frttings Steel (April 2001) General, pitting and Chemisuy Program Table V/11.A.1-b crevice Corrosion (XI.M2)

Table Vlll.82.1-a Table V/11.C.1-b Monticello One Time Inspection Program (XI.M32)

Valves Carbon Steam NUREG-1801, Rev 0 Loss of Material - II. 16, Plant steel (April 2001) General, pitting and Chemistry Program Table V/11.A.2-b crevice Corrosion (XI.M2)

Table V/11.82.2-b Table VIII. C.2-b Monticello One Time Inspection Program (XI.M32)

Piping and Carbon steam NUREG-1801, Rev 0 Wall thinning - EWl-11.01.15, Flow-fittings steel (April 2001) Flow-accelerated Accelerated Table V/11.A.1-a corrosion Corrosion (XI. M17)

Table Vl/1.82.1-b Table VIII.C.1-a Valves Carbon Steam NUREG-1801, Rev 0 Wall thinning - EWl-11.01.15, Flow-steel (April 2001) Flow-accelerated Accelerated Table VIII.A.2-a corrosion Corrosion (XI.M17)

Table V/11.82.2-a Table VIII.C.2-a Piping and Carbon Treated water NUREG-1801, Rev 0 Wall thinning - EWl-11.01.15, Flow-frttings steel (April 2001) Flow-accelerated Accelerated Table V/11.O2.1-a corrosion Corrosion (XI.M17)

Table V/11.E.1-a 6 of 13

Valves Carbon Treated water NUREG-1801, Rev 0 Wall thinning - EWl-11.01.15, Flow-Steel (April 2001) Flow-accelerated Accelerated Table V/1I.D2.2-a corrosion Corrosion (XI.M17)

Table VIII.E.2-a Pumps Carbon Treated water NUREG-1801, Rev 0 Wall thinning - EWl-11.01.15, Flow-Steel (April 2001) Flow-accelerated Accelerated Table VIII.D2.3-a corrosion Corrosion (XI. M17)

Piping and Carbon Treated water NUREG-1801, Rev 0 Loss of Material - 11.*16, Plant fittings Steel (April 2001) General, pitting and Chemistry Program Table VIII.D2.1-b crevice Corrosion (XI.M2)

Table VIII.E.1-b Monticello One Time Inspection Program (XI.M32)

Valves Carbon Treated water NUREG-1801, Rev 0 Loss of Material - II. 16, Plant Steel (April 2001) General, pitting and Chemistry Program Table Vlll.02.2-b crevice Corrosion (XI.M2)

Table VIII.E.2-b Monticello One Time Inspection Program (XI.M32)

Piping and Carbon Air GALL-SLR Loss of Material - EWl-11.01.13, fittings Steel (described in General, pitting and System Condftion NUREG- crevice Corrosion Monitoring System 1801 as "Air, (LRA Section moisture, 82.1.32) humidity, and leaking fluid")

Valves Carbon Air GALL-SLR Loss of Material - EWl-11.01.13, Steel (described in General, pitting and System Condftion NUREG- crevice Corrosion Monitoring System 1801 as "Air, (LRA Section moisture, 82.1.32) humidity, and leakina fluid")

7 of 13

Piping and Carbon Buried NUREG-1801, Rev 0 Loss of Material - EWl-11.01.14, frttings Steel (described in (April 2001) General, pitting, Buried Piping &

NUREG- Table VIII.E.5-d crevice, and Tanks Inspection 1801 as "Soil Table VII/.E.5.1 microbiologlcally (XI.M34) and ground influenced corrosion water')

Piping and Copper Gas Air GALL-SLR None None fittings Allow (described in with 15% NUREG-Zinc or 1801 as "Air, Jess moisture, humidity, and leakina fluid")

Valves Copper Gas Air GALL-SLR None None Allow (described in with 15% NUREG-Zinc or 1801 as aAir, Jess moisture, humidity, and

/eakina fluidn)

Piping and Copper Gas Air GALL-SLR Loss of Material - .EW/-11.01.13, fittings Allow (described in Pitting, Crevice, System Condition with NUREG- Cracking Corrosion Monitoring System Greater 1801 as aAir, (LRA Section than 15% moisture, B2.1.32)

Zinc humidity, and

/eakina fluidn)

Valves Copper Gas Air GALL-SLR Loss of Material - EWl-11.01.13, Allow (described in Pitting, Crevice, System Condition with NUREG- Cracking Corrosion -Monitoring System Greater 1801 as aAir, (LRA Section than 15% moisture, B2.1.32)

Zinc humidity, and leakina fluidn) 8 of 13

Pumps Carbon Air GALL-SLR Loss of Material - EWl-11.01.13, Steel (described in General, pitting and System Condition NUREG- crevice Co!TOsion Monitoring System 1801 as "Air, (LRA Section moisture, 82.1.32) humidity, and leaking fluid")

Piping and Stainless Steam Air GALL-SLR Loss of Material - EWl-11.01.13, fittings Steel (described in Pitting, Crevice, System Condition Treated NUREG- Cracking Co!TOslon Monitoring System Water 1801 as "Air, (LRA Section moisture, 82.1.32) humidity, and leaking fluid") 11.16, Plant Chemistry Program (XI.M2)

Monticello One Time Inspection Program (XI.M32)

Piping and Stainless Treated GALL-SLR Wall thinning - EWl-11.01.15, Flow-frttings Steel Water Flow-accelerated Accelerated corrosion Co!TOsion (XI. M17) 9 of 13

Valves Stainless Steam Air GALL-SLR Loss of Material - EWl-11.01.13, Steel (described in Pitting, Crevice, System Condition Treated NUREG- Cracking Corrosion Monitoring System Water 1801 as "Air, (LRA Section moisture, 82.1.32) humidity, and leaking fluid") 11.16, Plant Chemistry Program (XI.M2)

Monticello One Time Inspection Program O<I.M32)

Valves Stainless Treated GALL-SLR Wall thinning - EWl-11.01.15, Flow-Steel Water Flow-accelerated Accelerated corrosion Corrosion (XI. M17)

Pumps Garbon Treated water NUREG-1801, Rev 0 Loss of Material - 11.16, Plant Steel (April 2001) General, pitting and Chemistry Program Table VI/I.D2.3-b crevice Corrosion (XI.M2)

Table VIII.E.3-a Monticello One Time Inspection Program

{X/.M32)

Bolting Carbon Air (described Air NUREG-1801, Rev 0 Loss of Material - EWl-11.01.33, Steel in NUREG- (described in (April 2001) General, crack Bolting Integrity 1801 as "Air, NUREG- Table VIII.H.2-a Corrosion (XI.M18)

Stainless moisture, 1801 as "Air, Steel humidity, and moisture, Cyclic loading leaking fluid') humidity, and Copper leaking fluid")

alloy with 15% Zinc or less 10 of 13

Bolting Copper Air (described Air NUREG-1801, Rev 0 Cyclic loading EWl-11.01.33, alloy with in NUREG- (described in (April 2001) Bolting Integrity 15% Zinc 1801 as "Air, NUREG- Table VIII.H.2-a (XI.M18) or less moisture, 1801 as aAir, humidity, and moisture, leaking fluid") humidity, and leakina fluid1 Heat exchanger stainless Air (described Treated GALL-SLR Loss of Material - Monticello One Time (Condenser, Steel in NUREG- Water Pitting, Crevice, Inspection Program Tubes, 1801 as "Air, Cracking Corrosion (XI.M32) tubesheet, moisture, channel head, humidfty, and II. 16, Plant and shell) leaking fluid") Chemistry Program (XI.M2)

Treated Water Heat exchanger Carbon Air (described Treated GALL-SLR Loss of Material - Monticello One Time (Pre-Heater, steel in NUREG- Water General, pitting, Inspection Program Tubes, 1801 as aAir, crevice and cracking (XI.M32) tubesheet, stainless moisture, Corrosion channel head, Steel humidfty, and II. 16, Plant and shelO leaking fluid") Chemistry Program (XI.M2)

EWl-11.01.13, System Condition Monitoring System (LRA Section B2.1.32) 11 of 13

Heat exchanger Carbon Air (described Treated GALL-SLR Cracking Monticello One Time (Drain Cooler, Steel in NUREG- water Inspection Program Tubes, 1801 as "Air, (XI.M32) tubesheet, moisture, channel head, humidity, and II. 16, Plant and shell) leaking fluid'; Chemistry Program (XI.M2)

EWl-11.01.13, System Condition Monitoring System (LRA Section 82.1.32)

Heat exchanger Stainless Closed Cycle steam GALL-SLR Loss of Material - Monticello One Time (H2O2 Sample Steel Cooling Water Pitting, Crevice, Inspection Program Coolers, Tubes, Cracking Corrosion (XI.M32) tubesheet, channel head, and shem Heat exchanger Carbon Air (described Treated GALL-SLR Loss of Material - Monticello One Time (Inter- steel in NUREG- Water General, Pitting and Inspection Program condenser, 1801 as "Air, Crevice, Corrosion (XI.M32)

Tubes, moisture, tubesheet, humidity, and II. 16, Plant channel head, leaking fluid") Chemistry Program and shell) (XI.M2)

Treated Water Tanks Stainless Treated Air GALL-SLR Loss of Material - Monticello One Time (Recombiner) steel Water (described in Pitting, Crevice, Inspection Program NUREG- Cracking Corrosion (XI.M32) 1801 as "Air, moisture, II. 16, Plant humidfty, and Chemistry Program leaking fluid") (XI.M2) 12 of 13

Tanks Carbon Steam Air GALL-SLR Loss of Material - Monticello One Time (Condensate Steel (described in General, Pitting and Inspection Program Flash Tank) Treated NUREG- Crevice, Corrosion (XI.M32)

Water 1801 as "Air, moisture, II. 16, Plant humidity, and Chemistry Program leaking fluid") (XI.M2)

EWl-11.01.13, System Condition.

Monitoring System (LRA Section 82.1.32) 13 of 13