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| | issue date = 10/28/2009 | | | issue date = 10/28/2009 |
| | title = Xcel Energy Request for NRC Concurrent Review of Monticello Nuclear Generating Plant Maximum Extended Load Line Limit Analysis Plus (Mellla+) License Amendment Request (LAR) with MNGP Extended Power Uprate (EPU) LAR Review Delay | | | title = Xcel Energy Request for NRC Concurrent Review of Monticello Nuclear Generating Plant Maximum Extended Load Line Limit Analysis Plus (Mellla+) License Amendment Request (LAR) with MNGP Extended Power Uprate (EPU) LAR Review Delay |
| | author name = O'Connor T J | | | author name = O'Connor T |
| | author affiliation = Northern States Power Co, Xcel Energy | | | author affiliation = Northern States Power Co, Xcel Energy |
| | addressee name = | | | addressee name = |
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| ==References:== | | ==References:== |
| : 1) NSPM letter to NRC, "License Amendment Request: Extended Power Uprate (L-MT-08-052)," dated November 5, 2008 2) Letter from NRR to MNGP, "Monticello Nuclear Generating Plant - Revised Schedule for Review of Extended power Uprate Amendment Application (TAC No. MD9990)", dated October 1, 2009 | | : 1) NSPM letter to NRC, "License Amendment Request: Extended Power Uprate (L-MT-08-052)," dated November 5, 2008 2) Letter from NRR to MNGP, "Monticello Nuclear Generating Plant - Revised Schedule for Review of Extended power Uprate Amendment Application (TAC No. MD9990)", dated October 1, 2009 |
| : 3) Letter from MNGP to Document Control Desk, "Monticello Extended Power Uprate: Acknowledgement of NRC Review Delay (TAC No. MD9990), dated October 13, 2009 The purpose of this letter is to request concurrent review of the Maximum Extended Load Line Limit Analysis Plus (MELLLA+) license amendment request (LAR) while the Extended Power Uprate (EPU) LAR is still under NRC review. Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota corporation (NSPM), requested in Reference 1 an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications to increase the maximum authorized power level from 1775 megawatts thermal (MWt) to 2004 MWt. In Reference 2, NSPM was informed of the US Nuclear Regulatory Commission (NRC) staff's decision to delay the review of the MNGP EPU LAR. This delay is based on the Commission's direction for the Office of Nuclear Reactor Regulation (NRR) staff to continue to work towards resolving Advisory Committee on Reactor safeguards (ACRS) concerns regarding the application of containment accident pressure (CAP) credit. Reference 3 contains NSPM1s acknowledgement of the EPU application review delay. | | : 3) Letter from MNGP to Document Control Desk, "Monticello Extended Power Uprate: Acknowledgement of NRC Review Delay (TAC No. MD9990), dated October 13, 2009 The purpose of this letter is to request concurrent review of the Maximum Extended Load Line Limit Analysis Plus (MELLLA+) license amendment request (LAR) while the Extended Power Uprate (EPU) LAR is still under NRC review. Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota corporation (NSPM), requested in Reference 1 an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications to increase the maximum authorized power level from 1775 megawatts thermal (MWt) to 2004 MWt. In Reference 2, NSPM was informed of the US Nuclear Regulatory Commission (NRC) staff's decision to delay the review of the MNGP EPU LAR. This delay is based on the Commission's direction for the Office of Nuclear Reactor Regulation (NRR) staff to continue to work towards resolving Advisory Committee on Reactor safeguards (ACRS) concerns regarding the application of containment accident pressure (CAP) credit. Reference 3 contains NSPM1s acknowledgement of the EPU application review delay. |
| Document Control Desk Page 2 As discussed with NRC staff previously, NSPM planned to submit the MELLLA+ LAR immediately following the approval of the EPU LAR, which was scheduled for the first quarter, 201 0. NSPM has continued development of the MELLLA+ LAR on the schedule previously communicated to the NRC. With the delay in the EPU LAR review, submittal of the MELLLA+ LAR (on the original schedule) would result in the MELLLA+ LAR and the EPU LAR being considered by the staff as "linked" licensing actions. | | Document Control Desk Page 2 As discussed with NRC staff previously, NSPM planned to submit the MELLLA+ LAR immediately following the approval of the EPU LAR, which was scheduled for the first quarter, 201 0. NSPM has continued development of the MELLLA+ LAR on the schedule previously communicated to the NRC. With the delay in the EPU LAR review, submittal of the MELLLA+ LAR (on the original schedule) would result in the MELLLA+ LAR and the EPU LAR being considered by the staff as "linked" licensing actions. |
| NSPM requests the concurrent review in order to minimize any scheduling gaps between the EPU implementation and MELLLA+ implementation at MNGP. MELLLA+, and the included transition to the Detect and Suppress Solution - Confirmation Density (DSS-CD) for stability protection, is an important operational change for MNGP that supports operation at EPU power levels. NSPM desires to minimize the schedule gap between implementation of the MNGP EPU and MELLLA+ in order to operate at the EPU power level in the most safe, effective, and efficient manner. NSPM's initial evaluation of plant operation under EPU conditions (licensed to 2004 MWt) indicates that MNGP would likely voluntarily de-rate the plant to approximately 1880 MWt pending the approval and implementation of MELLLA+. This voluntary de-rate would be applied to ensure an appropriately conservative "full power" flow window is established. The voluntary de-rate and related conservative flow window would provide margin to the boundaries of allowed operation on the MNGP power-to- flow map for normal plant operation and control rod pattern adjustments. Even with the voluntary de-rate, NSPM estimates the need to perform control rod pattern adjustments about two (2) to three (3) times more frequently. | | NSPM requests the concurrent review in order to minimize any scheduling gaps between the EPU implementation and MELLLA+ implementation at MNGP. MELLLA+, and the included transition to the Detect and Suppress Solution - Confirmation Density (DSS-CD) for stability protection, is an important operational change for MNGP that supports operation at EPU power levels. NSPM desires to minimize the schedule gap between implementation of the MNGP EPU and MELLLA+ in order to operate at the EPU power level in the most safe, effective, and efficient manner. NSPM's initial evaluation of plant operation under EPU conditions (licensed to 2004 MWt) indicates that MNGP would likely voluntarily de-rate the plant to approximately 1880 MWt pending the approval and implementation of MELLLA+. This voluntary de-rate would be applied to ensure an appropriately conservative "full power" flow window is established. The voluntary de-rate and related conservative flow window would provide margin to the boundaries of allowed operation on the MNGP power-to- flow map for normal plant operation and control rod pattern adjustments. Even with the voluntary de-rate, NSPM estimates the need to perform control rod pattern adjustments about two (2) to three (3) times more frequently. |
| In the Safety Evaluation for Licensing Topical Report NEDC-33006P, "General Electric Boiling Water Reactor Maximum Extended Load Line Limit Analysis Plus," October 2008, the NRC recognizes that EPU plants operating in the MELLLA+ range will require a significantly lower number of control rod movements and considered that element a "significant improvement on operating flexibility." The NRC also recognized that MELLLA+ operation "provides safer operation" because reducing the number of control rod manipulations minimizes the likelihood of fuel failures and reduces the likelihood of accidents initiated by reactor maneuvers required to achieve an operating condition where control rods can be extracted. NSPM understands concurrent review of the MELLLA+ LAR would be considered linked because the analysis assumes EPU has been approved and is the current licensing basis for Monticello. NSPM also acknowledges that the MELLLA+ amendment contains a CAP evaluation section. This circumstance also does not meet LIC-109, Acceptance Review Procedures," in regard to "promised information" and "completeness of scope." However, NSPM will commit in the MELLLA+ LAR to resolve the CAP section in the same manner as the issue is resolved for the delayed EPU amendment. | | In the Safety Evaluation for Licensing Topical Report NEDC-33006P, "General Electric Boiling Water Reactor Maximum Extended Load Line Limit Analysis Plus," October 2008, the NRC recognizes that EPU plants operating in the MELLLA+ range will require a significantly lower number of control rod movements and considered that element a "significant improvement on operating flexibility." The NRC also recognized that MELLLA+ operation "provides safer operation" because reducing the number of control rod manipulations minimizes the likelihood of fuel failures and reduces the likelihood of accidents initiated by reactor maneuvers required to achieve an operating condition where control rods can be extracted. NSPM understands concurrent review of the MELLLA+ LAR would be considered linked because the analysis assumes EPU has been approved and is the current licensing basis for Monticello. NSPM also acknowledges that the MELLLA+ amendment contains a CAP evaluation section. This circumstance also does not meet LIC-109, Acceptance Review Procedures," in regard to "promised information" and "completeness of scope." However, NSPM will commit in the MELLLA+ LAR to resolve the CAP section in the same manner as the issue is resolved for the delayed EPU amendment. |
| NRR staff expects resolution of the CAP review criteria in spring of 201 | | NRR staff expects resolution of the CAP review criteria in spring of 201 |
| : 0. | | : 0. |
| Document Control Desk Page 3 The current status of the NRR reviews for the MNGP EPU LAR is mostly complete. | | Document Control Desk Page 3 The current status of the NRR reviews for the MNGP EPU LAR is mostly complete. |
Letter Sequence Request |
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TAC:MD9990, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
Administration
- Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance
- Meeting, Meeting, Meeting, Meeting, Meeting, Meeting
Results
Other: L-MT-08-091, Calculation 0801040.301, Steam Dryer Outer Hood Submodel Analysis., L-MT-09-002, Response to NRC Probabilistic Risk Assessment (PRA) Branch Requests for Additional Information (Rais) Dated December 5, 2008, L-MT-09-003, Response to NRC Environmental Branch Requests for Additional Information (Rais) Dated December 18, 2008, L-MT-09-004, Enclosure 1 (Continued) to L-MT-09-004, NSPM Response to Containment & Ventilation Branch RAI Number 2, Copy of MNGP Appr T0406 Data Transmittal Pages 1 of 538 Through Pages 538 of 538, L-MT-09-026, Calculation 0000-0081-6958 MNGP-PRNMS-APRM Calc-2008-NP, Rev. 1, Average Power Range Monitor Selected Prnm Licensing Setpoints - EPU Operation (Numac), L-MT-09-027, Extended Power Uprate: Response to Instrumentation and Controls Branch RAI No. 3 Dated April 6, 2009, L-MT-09-044, Extended Power Uprate: Response to NRC Mechanical and Civil Engineering Review Branch (Emcb) Requests for Additional Information (Rais) Dated March 28, 2009, L-MT-09-049, Drawing C.5-2007, Revision 15, Failure to Scram, L-MT-09-073, Extended Power Uprate: Response to NRC Containment and Ventilation Review Branch (Scvb) Requests for Additional Information (Rais) Dated July 2, 2009 and July 14, 2009, L-MT-09-083, Extended Power Uprate: Limit Curves Requested by the Mechanical and Civil Review Branch (Emcb) Associated with Requests for Additional Information (Rais) Dated March 20, 2009, L-MT-09-088, Extended Power Uprate: Revision to Clarify Text in Enclosures 5 and 7 of L-MT-08-052, L-MT-09-097, Extended Power Uprate: Acknowledgement of NRC Review Delay, L-MT-10-025, Extended Power Uprate (Epu): Response to NRC-NSPM February 25, 2010 Conference Call, L-MT-10-072, Extended Power Uprate: Updates to Docketed Information, L-MT-11-044, Uprate (Epu): Update on EPU Commitments, L-MT-12-056, WCAP-17549-NP, Rev. 0, Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE, L-MT-12-090, Westinghouse, LTR-A&SA-12-8, Rev. 1, Attachment B, Recommendations for Inspections of the Monticello Replacement Steam Dryer., L-MT-12-114, Drawing C.5-2007, Rev. 17, Failure to Scram, L-MT-13-020, Enclosure 1 - Responses to the Gap Analysis, L-MT-13-029, Enclosure 14 to L-MT-13-029 - WCAP-17716-NP, Revision 0, Benchmarking of the Acoustic Circuit Enhanced Revision 2.0 for the Monticello Steam Dryer Replacement Project., L-MT-13-091, WCAP-17716-NP, Revision 1 - Benchmarking of the Acoustic Circuit Enhanced Revision 2.0 for the Monticello Steam Dryer Replacement Project, Enclosure 14, L-MT-13-092, Extended Power Uprate (Epu): Completion of EPU Commitments, Proposed License Conditions and Revised Power Ascension Test Plan, L-MT-13-096, GE-MNGP-AEP-3304R1, Enclosure 4, NEDC-33435 Corrected Pages, L-MT-13-126, Enclosure 3, GE-MNGP-AEP-3306, Enclosure 2 GEH Response to Mella+ Eicb RAI and Affidavit, L-MT-14-023, Maximum Extended Load Line Limit Analysis Plus: Technical Specification Clarifications, L-MT-15-074, Enclosure 7, WCAP-18604-NP, Revision 0, Monticello EPU Main Steam Line Strain Data Evaluation Report., L-MT-16-017, Revised Commitment to Reconcile Analysis of Bypass Voiding for Transition to Areva Analysis Methodology, L-MT-16-071, Submittal of 2016 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.46, ML083230111, ML083400402, ML083500575, ML083570610, ML083590127, ML090710680, ML090710683, ML090710684, ML091120578, ML091140470, ML091410121, ML091410122, ML091410123, ML091410124, ML091760769, ML092290250, ML092810554, ML093160816, ML093220925, ML093220964, ML093620024, ML100280558... further results
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MONTHYEARML0907106832008-02-17017 February 2008 Enclosure 1 (Continued) to L-MT-09-004, NSPM Response to Containment & Ventilation Branch RAI Number 2, Attachment 1-1g Through End of Encl. 1 Project stage: Other ML13064A4352008-03-20020 March 2008 CA-95-075, Main Steam Line High Flow Setpoint, Attachment 4 Project stage: Other ML0914101242008-08-11011 August 2008 Monticello - Calculation CA-08-050, Rev. 0, Instrument Setpoint Calculation - Average Power Range Monitor (APRM) Non-Flow Eiased Prnm Setpoints for Cl Tp and EPU Project stage: Other L-MT-08-091, Calculation 0801040.301, Steam Dryer Outer Hood Submodel Analysis.2008-10-31031 October 2008 Calculation 0801040.301, Steam Dryer Outer Hood Submodel Analysis. Project stage: Other ML0832301122008-10-31031 October 2008 NEDC-33322-NP, Revision 3, Monticello Nuclear Generating Plant, Safety Analysis Report, Constant Pressure Power Uprate. Project stage: Request ML0832301112008-11-0505 November 2008 Monticello Nuclear Generating Plant, License Amendment Request: Extended Power Uprate Project stage: Other ML0832301142008-11-0505 November 2008 Monticello Nuclear Generating Plant, Steam Dryer Dynamic Stress Evaluation. Project stage: Request ML0834003662008-12-0202 December 2008 Extended Power Uprate Acceptance Review Questions on Probabilistic Risk Assessment Issues Project stage: Acceptance Review ML0834004022008-12-0505 December 2008 Extended Power Uprate - Monticello - Request to Supplement the Application in the Probabilistic Risk Assessment Area Project stage: Other ML0835000992008-12-11011 December 2008 Monticello Extended Power Uprate (Usnrc TAC MD9990): Acceptance Review Supplement Regarding Steam Dryer Outer Hood Submodel Analysis Project stage: Supplement ML0835303022008-12-16016 December 2008 Draft Request for Additional Information, Environmental Issues of EPU Application Project stage: Draft RAI ML0936200242008-12-18018 December 2008 Report 0800760.401, Rev. 1, Flaw Evaluation and Vibration Assessment of Existing Monticello Steam Dryer Flaws for Extended Power Uprate. Project stage: Other ML0835005752008-12-18018 December 2008 Letter Finding 11/5/08 Application for Amendment Acceptable for Review Project stage: Other ML0835309982008-12-18018 December 2008 EPU Application - Additional RAI Question Regarding an Environmental Issue Project stage: RAI ML0835310022008-12-18018 December 2008 Proposed Eou Amendment - Revised RAI Re. Containment Analysis Project stage: RAI ML0914101222008-12-18018 December 2008 Monticello - Calculation CA-95-075, Revision 1, Main Steam Line High Flow Setpoint Project stage: Other ML0914101212008-12-19019 December 2008 Monticello - Calculation CA-95-073, Revision 4, Reactor Low Water Level SCRAM Setpoint Project stage: Other ML0835901272009-01-14014 January 2009 Letter Conveying Determination That Enclosure 5 of 11/5/08 Application for EPU Amendment Contains Proprietary Information and Withheld from Public Disclosure Project stage: Other ML0835706102009-01-26026 January 2009 Letter Conveying Determination That Enclosure 11 of 11/5/08 Application for EPU Amendment Contains Proprietary Information and Is Withheld from Public Disclosure Project stage: Other L-MT-09-003, Response to NRC Environmental Branch Requests for Additional Information (Rais) Dated December 18, 20082009-01-29029 January 2009 Response to NRC Environmental Branch Requests for Additional Information (Rais) Dated December 18, 2008 Project stage: Other L-MT-09-005, Revision to Attachment 1 of Enclosure 17 of MNGP License Amendment Request for Extended Power Uprate2009-02-0404 February 2009 Revision to Attachment 1 of Enclosure 17 of MNGP License Amendment Request for Extended Power Uprate Project stage: Request L-MT-09-002, Response to NRC Probabilistic Risk Assessment (PRA) Branch Requests for Additional Information (Rais) Dated December 5, 20082009-02-0404 February 2009 Response to NRC Probabilistic Risk Assessment (PRA) Branch Requests for Additional Information (Rais) Dated December 5, 2008 Project stage: Other ML0904204852009-02-11011 February 2009 Draft RAI from Materials Engineering Re. Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0907106792009-02-17017 February 2009 Monticello, Response to NRC Containment & Ventilation Branch Request for Additional Information (Rals) Dated December 18, 2008 Project stage: Request ML0907106802009-02-17017 February 2009 Monticello, Enclosure 1 to L-MT-09-004, NSPM Response to Containment & Ventilation Branch RAI Number 1 Dated December 18, 2008, Cover Through Copy of MNGP Appr T0406 Data Transmittal Page 424 of 424 Project stage: Other L-MT-09-004, Enclosure 1 (Continued) to L-MT-09-004, NSPM Response to Containment & Ventilation Branch RAI Number 2, Copy of MNGP Appr T0406 Data Transmittal Pages 1 of 538 Through Pages 538 of 5382009-02-17017 February 2009 Enclosure 1 (Continued) to L-MT-09-004, NSPM Response to Containment & Ventilation Branch RAI Number 2, Copy of MNGP Appr T0406 Data Transmittal Pages 1 of 538 Through Pages 538 of 538 Project stage: Other ML0907106842009-02-17017 February 2009 Enclosures 2 - 4: NSPM Response to Containment & Ventilation Branch RAI Numbers 2, 3 and 4 Dated December 18, 2008 Project stage: Other L-MT-09-018, Response to NRC Steam Generator Tube Integrity & Chemical Engineering Branch Request for Additional Information (RAI) Dated February 11, 20092009-02-24024 February 2009 Response to NRC Steam Generator Tube Integrity & Chemical Engineering Branch Request for Additional Information (RAI) Dated February 11, 2009 Project stage: Request ML0907100912009-03-11011 March 2009 Conveying Draft RAI Questions from the Instrumentation and Controls Branch Regarding the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0907200572009-03-12012 March 2009 Conveys Draft RAI Regarding Fire Protection for the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0907800062009-03-18018 March 2009 Draft RAI from Probabilistic Risk Assessment Licensing Branch on the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0907800042009-03-18018 March 2009 Conveys Draft RAI by the PRA Licensing Branch on the Proposed EPU Amendment Project stage: Draft RAI ML0907809032009-03-19019 March 2009 Conveys Draft RAI Provided by the Containment and Ventilation Branch on the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0907809092009-03-19019 March 2009 RAI from the Containment and Ventilation Branch the Proposed Extended Power Uprate Amendment Project stage: RAI L-MT-09-017, Extended Power Uprate: Response to NRC Reactor Systems Branch & Nuclear Performance & Code Review Branch Request for Additional Information (RAI) Dated January 16, 20092009-03-19019 March 2009 Extended Power Uprate: Response to NRC Reactor Systems Branch & Nuclear Performance & Code Review Branch Request for Additional Information (RAI) Dated January 16, 2009 Project stage: Request ML0908200312009-03-20020 March 2009 Draft RAI Re. Health Physics Issues for the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0908200992009-03-23023 March 2009 Draft RAI from the Balance of Plant Branch Re the Proposed Amendment on Extended Power Uprate Project stage: Draft RAI ML0908800022009-03-28028 March 2009 Second Portion of Draft RAI from the Mechanical and Civil Engineering Branch Regarding the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0908800032009-03-28028 March 2009 Draft RAI from the Electrical Engineering Branch Re. the Proposed Extended Power Uprate Amendment for Monticello Project stage: Draft RAI ML0908800012009-03-29029 March 2009 Additional Draft RAI Questions from the Containment and Ventilation Branch Proposed EPU Amendment for Monticello Project stage: Draft RAI ML0910300172009-04-0606 April 2009 Conveys an Additional EPU Draft RAI Question from Instrumentation and Controls Branch Project stage: Draft RAI ML0910300212009-04-0606 April 2009 Draft RAI Question from Instrumentation and Controls Branch Re. Proposed EPU Amendment Project stage: Draft RAI ML0911205782009-04-22022 April 2009 Request for Audit of Implementation of Long-Term Stability Solution Project stage: Other L-MT-09-025, Extended Power Uprate: Response to NRC Reactor Systems Branch and Nuclear Performance & Code Review Branch Request for Additional Information (RAI) Dated February 23, 20092009-04-22022 April 2009 Extended Power Uprate: Response to NRC Reactor Systems Branch and Nuclear Performance & Code Review Branch Request for Additional Information (RAI) Dated February 23, 2009 Project stage: Request ML0911902092009-04-29029 April 2009 Transmit Revised Draft RAI from the Probabilistic Risk Assessment Licensing Branch on the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0914101232009-05-0606 May 2009 Monticello - Calculation 96-054, Rev 5, Turbine Stop Valve Closure/Generator Load Reject Scram Bypass Project stage: Other ML0911404702009-05-0707 May 2009 Determination That Submitted Information Can Be Withheld from Public Disclosure Project stage: Other ML0914101202009-05-13013 May 2009 Monticello - Extended Power Uprate: Response to NRC Instrumentation & Controls Branch Request for Additional Information Dated March 11, 2009, and April 6, 2009, and Fire Protection Branch RAIs Dated March 12, 2009 Project stage: Request L-MT-09-045, Extended Power Uprate: Response to NRC Electrical Engineering Review Branch (Eeeb) Request for Additional Information (RAI) Dated March 28, 20092009-05-26026 May 2009 Extended Power Uprate: Response to NRC Electrical Engineering Review Branch (Eeeb) Request for Additional Information (RAI) Dated March 28, 2009 Project stage: Request L-MT-09-029, Extended Power Uprate: Response to NRC Probabilistic Risk Assessment (PRA) Licensing Branch Request for Additional Information (RAI) Dated April 29, 20092009-05-29029 May 2009 Extended Power Uprate: Response to NRC Probabilistic Risk Assessment (PRA) Licensing Branch Request for Additional Information (RAI) Dated April 29, 2009 Project stage: Request 2009-02-24
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Category:Letter type:L
MONTHYEARL-MT-24-028, Response to RCI for RR-017 ISI Impracticality2024-08-28028 August 2024 Response to RCI for RR-017 ISI Impracticality L-MT-24-022, – Preparation and Scheduling of Operator Licensing Examinations2024-07-0909 July 2024 – Preparation and Scheduling of Operator Licensing Examinations L-MT-24-019, Submittal of ASME Section XI, Section IWB-3720 Analytical Evaluation in Accordance with 10 CFR 50.55a(b)(2)(xliii)2024-06-10010 June 2024 Submittal of ASME Section XI, Section IWB-3720 Analytical Evaluation in Accordance with 10 CFR 50.55a(b)(2)(xliii) L-MT-24-017, Response to Request for Additional Information Regarding License Amendment Request to Revise Monticello Technical Specification Surveillance Requirement 3.8.6.6 (EPID-L-2023-LLA-01602024-06-0404 June 2024 Response to Request for Additional Information Regarding License Amendment Request to Revise Monticello Technical Specification Surveillance Requirement 3.8.6.6 (EPID-L-2023-LLA-0160 L-MT-24-015, Response to Request for Additional Information - Alternative Request VR-09 for OMN-172024-05-16016 May 2024 Response to Request for Additional Information - Alternative Request VR-09 for OMN-17 L-MT-24-013, 2023 Annual Radiological Environmental Operating Report2024-05-14014 May 2024 2023 Annual Radiological Environmental Operating Report L-MT-24-016, 2023 Annual Report of Individual Monitoring for the Monticello Nuclear Generating Plant (MNGP)2024-05-0808 May 2024 2023 Annual Report of Individual Monitoring for the Monticello Nuclear Generating Plant (MNGP) L-MT-24-002, Submittal of Revision 41 to the Updated Safety Analysis Report2024-04-17017 April 2024 Submittal of Revision 41 to the Updated Safety Analysis Report L-MT-24-004, Submittal of 10 CFR 72.48 Report for Monticello Nuclear Generating Plant (MNGP)2024-04-17017 April 2024 Submittal of 10 CFR 72.48 Report for Monticello Nuclear Generating Plant (MNGP) L-MT-24-006, Subsequent License Renewal Application Annual Update 1 and Supplement 92024-02-29029 February 2024 Subsequent License Renewal Application Annual Update 1 and Supplement 9 L-MT-24-007, Response to NRC Request for Additional Information on Proposed Inservice Inspection Alternative RR-002 for the Sixth Ten-Year ISI Interval2024-02-15015 February 2024 Response to NRC Request for Additional Information on Proposed Inservice Inspection Alternative RR-002 for the Sixth Ten-Year ISI Interval L-MT-24-001, 10 CFR 50.55a Request RR-017 - Inservice Inspection (ISI) Impracticality in Accordance with 10 CFR 50.55a(g)(5)(iii) During the Fifth Ten-Year Interval2024-01-30030 January 2024 10 CFR 50.55a Request RR-017 - Inservice Inspection (ISI) Impracticality in Accordance with 10 CFR 50.55a(g)(5)(iii) During the Fifth Ten-Year Interval L-MT-23-054, Subsequent License Renewal Application Supplement 82024-01-11011 January 2024 Subsequent License Renewal Application Supplement 8 L-MT-23-047, License Amendment Request: Revision to the MNGP Pressure Temperature Limits Report to Change the Neutron Fluence Methodology and Incorporate New Surveillance Capsule Data2023-12-29029 December 2023 License Amendment Request: Revision to the MNGP Pressure Temperature Limits Report to Change the Neutron Fluence Methodology and Incorporate New Surveillance Capsule Data L-MT-23-056, Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 Part 22023-12-18018 December 2023 Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 Part 2 L-MT-23-042, 2023 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.462023-12-11011 December 2023 2023 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.46 L-MT-23-052, Subsequent License Renewal Application Supplement 72023-11-30030 November 2023 Subsequent License Renewal Application Supplement 7 L-MT-23-051, Update to the Technical Specification Bases2023-11-28028 November 2023 Update to the Technical Specification Bases L-MT-23-049, Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 12023-11-21021 November 2023 Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 L-MT-23-043, 10 CFR 50.55a(z)(1) Request Regarding OMN-17, Revision 1. VR-092023-11-13013 November 2023 10 CFR 50.55a(z)(1) Request Regarding OMN-17, Revision 1. VR-09 L-MT-23-038, License Amendment Request to Revise Monticello Technical Specification Surveillance Requirement 3.8.6.62023-11-10010 November 2023 License Amendment Request to Revise Monticello Technical Specification Surveillance Requirement 3.8.6.6 L-MT-23-046, Subsequent License Renewal Application Response to Request for Additional Information Round 2 - Set 12023-11-0909 November 2023 Subsequent License Renewal Application Response to Request for Additional Information Round 2 - Set 1 L-MT-23-041, Subsequent License Renewal Application Response to Request for Confirmation of Information Set 22023-10-0303 October 2023 Subsequent License Renewal Application Response to Request for Confirmation of Information Set 2 L-MT-23-037, Subsequent License Renewal Application Response to Request for Additional Information Set 32023-09-22022 September 2023 Subsequent License Renewal Application Response to Request for Additional Information Set 3 L-MT-23-036, Subsequent License Renewal Application Response to Request for Additional Information Set 2 and Supplement 62023-09-0505 September 2023 Subsequent License Renewal Application Response to Request for Additional Information Set 2 and Supplement 6 L-MT-23-035, Subsequent License Renewal Application Supplement 52023-08-28028 August 2023 Subsequent License Renewal Application Supplement 5 L-MT-23-034, Subsequent License Renewal Application Response to Request for Additional Information Set 12023-08-15015 August 2023 Subsequent License Renewal Application Response to Request for Additional Information Set 1 L-MT-23-032, 10 CFR 50.55a(z)(2) Request Regarding MO-2397, VR-112023-07-31031 July 2023 10 CFR 50.55a(z)(2) Request Regarding MO-2397, VR-11 L-MT-23-028, 2023 Refueling Outage 90-Day Inservice Inspection (ISI) Summary Report2023-07-31031 July 2023 2023 Refueling Outage 90-Day Inservice Inspection (ISI) Summary Report L-MT-23-031, Subsequent License Renewal Application Supplement 4 and Responses to Request for Confirmation of Information - Set 12023-07-18018 July 2023 Subsequent License Renewal Application Supplement 4 and Responses to Request for Confirmation of Information - Set 1 L-MT-23-030, Subsequent License Renewal Application Supplement 32023-07-0404 July 2023 Subsequent License Renewal Application Supplement 3 L-MT-23-025, Subsequent License Renewal Application Supplement 22023-06-26026 June 2023 Subsequent License Renewal Application Supplement 2 L-MT-23-019, Submittal of 2022 Annual Radiological Environmental Operating Report2023-05-10010 May 2023 Submittal of 2022 Annual Radiological Environmental Operating Report L-MT-23-020, Submittal of 2022 Annual Radioactive Effluent Release Report2023-05-10010 May 2023 Submittal of 2022 Annual Radioactive Effluent Release Report L-MT-23-021, Core Operating Limits Report (COLR) for the Monticello Nuclear Generating Plant for Cycle 322023-05-0202 May 2023 Core Operating Limits Report (COLR) for the Monticello Nuclear Generating Plant for Cycle 32 L-MT-23-017, 2022 Annual Report of Individual Monitoring for the Monticello Nuclear Generating Plant (MNGP)2023-04-18018 April 2023 2022 Annual Report of Individual Monitoring for the Monticello Nuclear Generating Plant (MNGP) L-MT-23-010, Subsequent License Renewal Application Supplement 12023-04-0303 April 2023 Subsequent License Renewal Application Supplement 1 L-MT-23-013, Core Operating Limits Report (COLR) for Cycle 31, Revision 32023-03-28028 March 2023 Core Operating Limits Report (COLR) for Cycle 31, Revision 3 L-MT-23-012, Core Operating Limits Report (COLR) for Monticello Nuclear Generating Plant Cycle 31, Revision 22023-03-17017 March 2023 Core Operating Limits Report (COLR) for Monticello Nuclear Generating Plant Cycle 31, Revision 2 L-MT-23-008, 10CFR50.55a Request to Use Later Edition of ASME Section XI for ISI Code of Record (RR-003)2023-02-0707 February 2023 10CFR50.55a Request to Use Later Edition of ASME Section XI for ISI Code of Record (RR-003) L-MT-23-004, CFR 50.55a Request RR-001, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI for the Monticello Third Interval Containment Inservice Inspection Program2023-01-23023 January 2023 CFR 50.55a Request RR-001, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI for the Monticello Third Interval Containment Inservice Inspection Program L-MT-23-005, Response to the NRC Request for Additional Information Regarding the 50.55a Request Pr 08, HPCI Pump Quarterly Testing (EPID Number L-2022-LLR-0088)2023-01-0606 January 2023 Response to the NRC Request for Additional Information Regarding the 50.55a Request Pr 08, HPCI Pump Quarterly Testing (EPID Number L-2022-LLR-0088) L-MT-22-049, Industry Groundwater Protection Initiative Special Report2022-12-15015 December 2022 Industry Groundwater Protection Initiative Special Report L-MT-22-052, L-MT-22-052 Monticello Nuclear Generating Plant 10 CFR 50.55a Request No. Pr 08, Request for HPCI Pump Quarterly Alternative2022-12-15015 December 2022 L-MT-22-052 Monticello Nuclear Generating Plant 10 CFR 50.55a Request No. Pr 08, Request for HPCI Pump Quarterly Alternative L-MT-22-046, 2022 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.462022-12-13013 December 2022 2022 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.46 L-MT-22-048, Update to the Monticello Technical Specification Bases2022-11-28028 November 2022 Update to the Monticello Technical Specification Bases L-MT-22-047, Withdrawal of Request for Relief from ASME OM Code for the Sixth Inservice Testing Interval2022-11-10010 November 2022 Withdrawal of Request for Relief from ASME OM Code for the Sixth Inservice Testing Interval L-MT-22-045, Letter Submitting Post-Exam Package2022-11-0404 November 2022 Letter Submitting Post-Exam Package L-MT-22-030, Sixth Interval Inservice Testing (1ST) Plan2022-09-0606 September 2022 Sixth Interval Inservice Testing (1ST) Plan L-MT-22-037, Supplement to 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval, Alternative VR-10, Excess Flow Check Valve Testing Frequency2022-08-29029 August 2022 Supplement to 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval, Alternative VR-10, Excess Flow Check Valve Testing Frequency 2024-08-28
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October 28,2009 L-MT-09-100 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 Facility Operating License License No. DPR-22 Xcel Energv Request for NRC Concurrent Review of Monticello Nuclear Generating Plant Maximum Extended Load Line Limit Analvsis Plus (MELLLA+)
License Amendment Request (LAR) with MNGP Extended Power Uprate (EPU) LAR Review Delay
References:
- 1) NSPM letter to NRC, "License Amendment Request: Extended Power Uprate (L-MT-08-052)," dated November 5, 2008 2) Letter from NRR to MNGP, "Monticello Nuclear Generating Plant - Revised Schedule for Review of Extended power Uprate Amendment Application (TAC No. MD9990)", dated October 1, 2009
- 3) Letter from MNGP to Document Control Desk, "Monticello Extended Power Uprate: Acknowledgement of NRC Review Delay (TAC No. MD9990), dated October 13, 2009 The purpose of this letter is to request concurrent review of the Maximum Extended Load Line Limit Analysis Plus (MELLLA+) license amendment request (LAR) while the Extended Power Uprate (EPU) LAR is still under NRC review. Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota corporation (NSPM), requested in Reference 1 an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications to increase the maximum authorized power level from 1775 megawatts thermal (MWt) to 2004 MWt. In Reference 2, NSPM was informed of the US Nuclear Regulatory Commission (NRC) staff's decision to delay the review of the MNGP EPU LAR. This delay is based on the Commission's direction for the Office of Nuclear Reactor Regulation (NRR) staff to continue to work towards resolving Advisory Committee on Reactor safeguards (ACRS) concerns regarding the application of containment accident pressure (CAP) credit. Reference 3 contains NSPM1s acknowledgement of the EPU application review delay.
Document Control Desk Page 2 As discussed with NRC staff previously, NSPM planned to submit the MELLLA+ LAR immediately following the approval of the EPU LAR, which was scheduled for the first quarter, 201 0. NSPM has continued development of the MELLLA+ LAR on the schedule previously communicated to the NRC. With the delay in the EPU LAR review, submittal of the MELLLA+ LAR (on the original schedule) would result in the MELLLA+ LAR and the EPU LAR being considered by the staff as "linked" licensing actions.
NSPM requests the concurrent review in order to minimize any scheduling gaps between the EPU implementation and MELLLA+ implementation at MNGP. MELLLA+, and the included transition to the Detect and Suppress Solution - Confirmation Density (DSS-CD) for stability protection, is an important operational change for MNGP that supports operation at EPU power levels. NSPM desires to minimize the schedule gap between implementation of the MNGP EPU and MELLLA+ in order to operate at the EPU power level in the most safe, effective, and efficient manner. NSPM's initial evaluation of plant operation under EPU conditions (licensed to 2004 MWt) indicates that MNGP would likely voluntarily de-rate the plant to approximately 1880 MWt pending the approval and implementation of MELLLA+. This voluntary de-rate would be applied to ensure an appropriately conservative "full power" flow window is established. The voluntary de-rate and related conservative flow window would provide margin to the boundaries of allowed operation on the MNGP power-to- flow map for normal plant operation and control rod pattern adjustments. Even with the voluntary de-rate, NSPM estimates the need to perform control rod pattern adjustments about two (2) to three (3) times more frequently.
In the Safety Evaluation for Licensing Topical Report NEDC-33006P, "General Electric Boiling Water Reactor Maximum Extended Load Line Limit Analysis Plus," October 2008, the NRC recognizes that EPU plants operating in the MELLLA+ range will require a significantly lower number of control rod movements and considered that element a "significant improvement on operating flexibility." The NRC also recognized that MELLLA+ operation "provides safer operation" because reducing the number of control rod manipulations minimizes the likelihood of fuel failures and reduces the likelihood of accidents initiated by reactor maneuvers required to achieve an operating condition where control rods can be extracted. NSPM understands concurrent review of the MELLLA+ LAR would be considered linked because the analysis assumes EPU has been approved and is the current licensing basis for Monticello. NSPM also acknowledges that the MELLLA+ amendment contains a CAP evaluation section. This circumstance also does not meet LIC-109, Acceptance Review Procedures," in regard to "promised information" and "completeness of scope." However, NSPM will commit in the MELLLA+ LAR to resolve the CAP section in the same manner as the issue is resolved for the delayed EPU amendment.
NRR staff expects resolution of the CAP review criteria in spring of 201
- 0.
Document Control Desk Page 3 The current status of the NRR reviews for the MNGP EPU LAR is mostly complete.
NSPM's understanding is that two review areas remain outstanding, with one of those areas being dependent on resolution of the application of CAP credit.
The MELLLA+ amendment technical areas are an extension of the work done for EPU; therefore, the review of the majority of the MELLLA+ LAR technical areas could begin. As demonstrated above, there are strong economic and operational safety reasons for minimizing the schedule gap between approval of the MNGP EPU LAR and the MNGP MELLLA+ LAR. Based on that information, the EPU schedule delay, the LIC-I09 guidance, and the EPU review status (mostly complete), NSPM proposes NRR accept for review the MELLLA+ LAR as a situation with "rare circumstances" (LIC-109, Appendix B, 3.1.3). The rare circumstance is the delay in the EPU LAR review due to the resolution of the containment accident pressure credit issue. Please direct any questions regarding this matter to Lynne Gunderson, Projects Licensing Manager, 61 2-330-6588. In accordance with 10 CFR 50.91, a copy of this letter is being provided to the designated Minnesota Official without the proprietary version. Commitment Summary If NRR agrees to review the MELLLA+ LAR concurrent with the EPU LAR, NSPM will commit in the MELLLA+ LAR to resolve the CAP section in the same manner as the issue is resolved for the delayed EPU amendment.
I declare u der penalty of perjury that the foregoing is true and correct.
2 / President o Nuclear Generating Plant States Power Company - Minnesota cc: Administrator, Region Ill, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce