ML23017A222

Verbal Authorization of Proposed Alternative PR-08 Regarding Inservice Testing Requirements of Certain High Pressure Coolant Injection System Components (EPID L-2022-LLR-0088) (Email)

ML23017A222
Person / Time
Site:	Monticello
Issue date:	01/13/2023
From:	Ballard B Plant Licensing Branch III
To:	Jacobson R Northern States Power Company, Minnesota, Xcel Energy
Ballard, B
References
EPID L-2022-LLR-0088
Download: ML23017A222 (1)

Text

From: Brent Ballard To: ronald.g.jacobson@xcelenergy.com Cc: Nancy Salgado; Stewart Bailey; Chakrapani Basavaraju; Thomas Scarbrough

Subject:

Monticello Nuclear Generating Plant - Verbal Authorization of Proposed Alternative PR-08 Regarding Inservice Testing Requirements of Certain High Pressure Coolant Injection System Components (EPID L-2022-LLR-0088)

Date: Friday, January 13, 2023 1:57:00 PM Attachments: Monticello Verbal Authorization for PR-08 Jan 12, 2023.pdf Good afternoon, By web-based submission dated December 15, 2022 (Agencywide Documents Access and Management System (ADAMS) accession number ML22350A726), as supplemented by letter dated January 6, 2023 (ML23006A277), Northern States Power Company (NSPM, the licensee), requested alternative PR-08 to certain inservice testing requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance (OM Code) at Monticello Nuclear Generating Plant. The alternative request PR-08 was submitted in accordance with 10 CFR 50.55a(z)

(2) on the basis that performance of inservice testing required by the ASME OM Code for specific components in the High Pressure Coolant Injection (HPCI) system prior to the spring 2023 refueling outage at Monticello would cause a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

By telephone conversation on January 12, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff provided a verbal authorization to NSPM for the proposed alternative PR-08. The NRC staffs evaluation and verbal authorization is attached to this e-mail. The following NRC and licensee personnel participated in the conference call:

NRC Nancy Salgado - Chief, Plant Licensing Branch 3 Stewart Bailey - Chief, Mechanical Engineering and Inservice Testing Branch Chakrapani Basavaraju - Mechanical Engineer, Mechanical Engineering and Inservice Testing Branch Brent Ballard - Project Manager, Plant Licensing Branch 3 Daniel Brockman - Project Manager, Plant Licensing Branch 3 NSPM Sara Scott - Director, Nuclear Licensing and Regulation Ronald Jacobson - Senior Nuclear Regulatory Engineer Michael Miller - Regulatory Affairs Manager Rick Loeffler - Senior Nuclear Regulatory Engineer Bobbi Jo Halvorson - Engineering Director Please contact me if you have any questions.

Thank you, Brent Ballard Project Manager Plant Licensing Branch III

Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-0680

VERBAL AUTHORIZATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR ALTERNATIVE REQUEST PR-08 HIGH PRESSURE COOLANT INJECTION PUMP QUARTERLY TESTING MONTICELLO NUCLEAR GENERATING PLANT NORTHERN STATES POWER COMPANY DOCKET NO. 50-263 EPID L-2022-LLR-0088 JANUARY 12, 2023 Technical Evaluation read by Stewart Bailey, Chief, Mechanical Engineering and Inservice Testing Branch, Division of Engineering and External Hazards, NRC Office of Nuclear Reactor Regulation This call is for the NRC to verbally authorize a request by Northern States Power Company (the licensee) for an alternative to certain inservice testing requirements of the ASME OM Code at Monticello Nuclear Generating Plant. In particular, the licensee submitted Alternative Request PR-08 electronically on December 15, 2022 and supplemented it by a letter dated January 6, 2023. The licensee proposes to defer the quarterly testing of certain components in the High Pressure Coolant Injection system at Monticello until the 2023 spring refueling outage, when repairs to Safety Relief Valve RV-2-71G will be conducted.

Title 10 of the Code of Federal Regulations, Section 50.55a, permits the NRC staff to verbally authorize alternatives to inservice testing requirements in circumstances where the licensee has docketed all pertinent information, the NRC staff has completed its review, and there is not enough time for the NRC to issue its written safety evaluation before the alternative is needed. That is the case here.

The licensee submitted Alternative Request PR-08 in accordance with 10 CFR 50.55a(z)(2) on the basis that performance of inservice testing required by the ASME OM Code 1

for specific components in the HPCI system prior to the spring 2023 refueling outage at Monticello would cause a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

As background, The NRC regulations in 10 CFR 50.55a(f) require licensees to implement inservice testing programs for pumps, valves, and dynamic restraints that meet the requirements of the ASME OM Code as incorporated by reference in 10 CFR 50.55a. The current ASME OM Code of Record for Monticello is the 2017 Edition. The ASME OM Code requirements applicable to Alternative Request PR-08 include ASME OM Code, Subsection ISTB, paragraph ISTB-3400, Frequency of Inservice Testing, Subsection ISTC, paragraph ISTC-3510, Exercising Test Frequency, and Mandatory Appendix III, paragraph III-3721, high safety significant component motor-operated valves.

In Alternative Request PR-08, the licensee specifies that Safety Relief Valve RV-2-71G has an elevated tailpipe temperature, which might be indicative of pilot or second stage leakage.

The licensee stated that there is a potential for a spurious lift of the SRV during inservice testing of certain components. A spurious lift might result in a plant transient and require a rapid power reduction or reactor scram. Therefore, the licensee requests deferral of the following quarterly inservice tests: the quarterly pump test for HPCI pump P-209, the quarterly exercising of the HPCI check valves numbered 9, 10, 18, 20, and 23 [32]1, and quarterly exercising of HPCI Turbine Steam Supply Isolation MOV [motor-operated valve] MO-2036. These tests would be deferred until repairs are made to Safety Relief Valve RV-2-71G during the spring refueling outage, and normal inservice testing of the HPCI system thereafter. The spring 2023 refueling outage is scheduled to start on April 15, 2023.

1 The NRC staff misread HPCI valve 32 as 23 when granting verbal relief to the licensee.

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The licensee stated that it had reviewed the maintenance history and inservice testing results for the specified components and determined that the components would retain their operational readiness with the deferral of the specified inservice tests. The NRC staff requested specific information regarding the performance and testing history of the HPCI components within the scope of the request, and other clarifying information. In its letter dated January 6, 2023, the licensee provided the results of several recent quarterly and biennial tests of the HPCI check valves indicating their satisfactory performance, and their recent preventive maintenance and leak tightness history. The licensee also described its estimate of the capability margin for the actuator to open HPCI Turbine Steam Supply Isolation MOV [motor-operated valve] the MO-2036 based on diagnostic testing. The licensee also provided the results of the last three quarterly tests of HPCI pump P-209 wherein the flow, differential pressure, and vibration demonstrated stable performance, as well as satisfactory results of recent oil sample evaluations. The licensee also clarified that the deferral for HPCI pump P-209 included the fourth quarter 2022 test, which has a grace period that expires January 15, 2023.

In its review of Alternative Request PR-08, the NRC staff evaluated the licensees description of the specific inservice tests proposed to be deferred, the performance and testing history of the applicable HPCI components, the licensees plans to conduct repairs to the Safety Relief Valve RV-2-71G during the spring 2023 refueling outage, and the re-initiation of the inservice tests required by the ASME OM Code following the spring 2023 refueling outage at Monticello.

Based on the information provided by the licensee, the NRC staff finds that a hardship exists without a compensating increase in the level of quality and safety, in accordance with 10 CFR 50.55a(z)(2), for the performance of the inservice testing requirements specified in Alternative Request PR-08. Therefore, the NRC staff finds that the licensees proposed alternative to defer the inservice tests for the applicable HPCI components until the spring refueling outage will not 3

adversely impact the reasonable assurance that those components will be operationally ready to perform their safety functions. Therefore, the NRC staff authorizes Alternative Request PR-08 to defer the specified inservice tests until the spring 2023 refueling outage at Monticello. The NRC staff does not authorize Alternative Request PR-08 beyond the spring 2023 refueling outage.

All other ASME OM Code requirements for which relief or an alternative was not specifically requested and granted or authorized as part of this alternative request remain applicable. If the licensee identifies a performance issue with any of the HPCI components, the licensee will be expected to take action to implement the requirements of its Technical Specifications. The NRC staffs review of Alternative Request PR-08 for Monticello will be described in detail in a separate safety evaluation.

NRC Staff Conclusion read by Nancy Salgado Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation As Chief of Plant Licensing Branch 3, I concur with the conclusions of the NRR Mechanical Engineering and Inservice Testing Branch.

The NRC staff concludes that Alternative Request PR-08 addresses the identified hardship or unusual difficulty without a compensating increase in the level of quality and safety for the performance of certain inservice testing required by the ASME OM Code for the specified HPCI components until the spring 2023 refueling outage at the Monticello Nuclear Generating Plant.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2) to justify the requested alternative to defer the ASME OM Code inservice testing requirements for the specified HPCI components until the spring 2023 refueling outage.

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Therefore, on January 12, 2023, the NRC authorizes Alternative Request PR-08 (as supplemented) until the spring 2023 refueling outage at Monticello. All other requirements of the ASME OM Code, for which relief or an alternative was not specifically requested and authorized by the NRC staff, remain applicable.

This verbal authorization does not preclude the NRC staff from asking additional questions and clarifications regarding the licensees proposed alternative while preparing the subsequent written safety evaluation.

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