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MONTHYEARML14212A0712014-07-30030 July 2014 10 CFR 50.55a Request No. Vr 05: Proposed Alternative to Lnservice Testing Requirements Pursuant to 10 CFR 50.55a(a)(3)(ii) Project stage: Request ML14220A1352014-08-0606 August 2014 NRR E-mail Capture - Monticello Nuclear Generating Plant Acceptance Review Relief Request RR VR05 Project stage: Acceptance Review ML14223A5812014-08-27027 August 2014 Alternative Request Vr 05 to the Testing Requirements of the ASME OM Code for the Fifth 10-Year Inservice Inspection Program Interval Project stage: Acceptance Review 2014-08-27
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Category:Inservice/Preservice Inspection and Test Report
MONTHYEARL-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-23-024, 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Inspection (ISI) Interval, RR-002 (L-MT-23-024)2023-07-11011 July 2023 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Inspection (ISI) Interval, RR-002 (L-MT-23-024) L-MT-22-030, Sixth Interval Inservice Testing (1ST) Plan2022-09-0606 September 2022 Sixth Interval Inservice Testing (1ST) Plan ML22067A0842022-03-0707 March 2022 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval OMN-28 (LMT-22-007) L-MT-22-006, 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval OMN-26 (L-MT-22-006)2022-02-18018 February 2022 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval OMN-26 (L-MT-22-006) L-MT-21-051, 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval OMN-22 (L-MT-21-051)2021-12-23023 December 2021 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval OMN-22 (L-MT-21-051) ML21305A0672021-11-0101 November 2021 Clone of 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing (IST) Ten-Year Interval PR-02 (L-MT-21-054) ML21278A1852021-10-0505 October 2021 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval VR-02 (LMT-21-049) L-MT-21-041, 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval VR-05 (L-MT-21-041)2021-08-31031 August 2021 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval VR-05 (L-MT-21-041) L-MT-21-038, 2021 Refueling Outage 90-Day Inservice Inspection (ISI) Summary Report2021-08-17017 August 2021 2021 Refueling Outage 90-Day Inservice Inspection (ISI) Summary Report L-MT-20-004, 10 CFR 50.55a Request: Request RR-016 Associated with the Fifth Ten-Year Inservice Inspection (ISI) Interval2020-02-14014 February 2020 10 CFR 50.55a Request: Request RR-016 Associated with the Fifth Ten-Year Inservice Inspection (ISI) Interval L-MT-20-001, 10 CFR 50.55a(z)(1) Request Vr 05: Request for Approval of an Alternative for Pressure Isolation Valve Testing2020-01-16016 January 2020 10 CFR 50.55a(z)(1) Request Vr 05: Request for Approval of an Alternative for Pressure Isolation Valve Testing L-MT-19-028, 2019 Refueling Outage 90-Day Lnservice Inspection (ISI) Summary Report; Second Steam Dryer Inspection Summary2019-08-0909 August 2019 2019 Refueling Outage 90-Day Lnservice Inspection (ISI) Summary Report; Second Steam Dryer Inspection Summary L-MT-17-059, 2017 Refueling Outage 90-Day Lnservice Inspection (ISI) Summary Report2017-08-0909 August 2017 2017 Refueling Outage 90-Day Lnservice Inspection (ISI) Summary Report L-MT-15-064, Cycle 27 Inservice Inspection Summary Report2015-08-26026 August 2015 Cycle 27 Inservice Inspection Summary Report ML14212A0712014-07-30030 July 2014 10 CFR 50.55a Request No. Vr 05: Proposed Alternative to Lnservice Testing Requirements Pursuant to 10 CFR 50.55a(a)(3)(ii) L-MT-14-037, CFR 50.55a Request No. 009: Relief from Impractical Examination Coverage Requirements Pursuant to 10 CFR 50.55a(g)(5)(iii) for the Fifth Ten-Year Lnservice Inspection Interval2014-06-0606 June 2014 CFR 50.55a Request No. 009: Relief from Impractical Examination Coverage Requirements Pursuant to 10 CFR 50.55a(g)(5)(iii) for the Fifth Ten-Year Lnservice Inspection Interval L-MT-14-021, Proposed Alternative in Accordance with 10 CFR 50.55a Request RR-008 Associated with the Fifth Ten-Year Inservice Inspection (ISI) Interval2014-02-28028 February 2014 Proposed Alternative in Accordance with 10 CFR 50.55a Request RR-008 Associated with the Fifth Ten-Year Inservice Inspection (ISI) Interval ML13308B2192013-10-11011 October 2013 Enclosure 3 - MNGP Evaluation EC-22537 - 2013 H8-H9 Shroud Support Structure Indications Update ML13308B2182013-10-0808 October 2013 Enclosure 2- BWRVIP Inspection Summary Report ML13308B2172013-10-0808 October 2013 Enclosure 1 - Cycle No. 26 and 1R26 2013 Refueling Outage Inservice Inspection: Interval 4, Period 3 and Interval 5, Period 1, Owner'S Activity Report (OAR-1) L-MT-13-060, Response to Request for Additional Information Regarding Fifth 10-Year Inservice Inspection Program Plan Review2013-07-17017 July 2013 Response to Request for Additional Information Regarding Fifth 10-Year Inservice Inspection Program Plan Review L-MT-12-094, In-service Testing (IST) Program Plan for Safety Related Seismic Restraints (Snubbers) for the Fifth 10-Year Interval2012-11-30030 November 2012 In-service Testing (IST) Program Plan for Safety Related Seismic Restraints (Snubbers) for the Fifth 10-Year Interval L-MT-12-019, CFR 50.55a Requests Associated with the Fifth Ten-Year Inservice Testing Interval2012-02-28028 February 2012 CFR 50.55a Requests Associated with the Fifth Ten-Year Inservice Testing Interval L-MT-12-017, CFR 50.55a Requests Associated with the Fifth Ten-Year Inservice Inspection Interval2012-02-28028 February 2012 CFR 50.55a Requests Associated with the Fifth Ten-Year Inservice Inspection Interval L-MT-12-020, Fifth Ten-Year Lnservice Testing Plan2012-02-28028 February 2012 Fifth Ten-Year Lnservice Testing Plan L-MT-12-018, Fifth Ten-Year Lnservice Inspection Plan2012-02-28028 February 2012 Fifth Ten-Year Lnservice Inspection Plan L-MT-12-011, Supplement to 10CFR50.55a Requests Associated with the Fourth and Fifth Lnservice Lnspection Ten-Year Intervals2012-02-15015 February 2012 Supplement to 10CFR50.55a Requests Associated with the Fourth and Fifth Lnservice Lnspection Ten-Year Intervals L-MT-11-046, Cycle 25 Inservice Inspection Summary Report2011-08-23023 August 2011 Cycle 25 Inservice Inspection Summary Report L-MT-09-078, Submittal of Cycle No. 24 Inservice Inspection Summary Report for Inservice Inspection and ASME Section Xl Repairs and Replacements2009-08-0707 August 2009 Submittal of Cycle No. 24 Inservice Inspection Summary Report for Inservice Inspection and ASME Section Xl Repairs and Replacements L-MT-07-058, Cycle No. 23 Lnservice Inspection Summary Report for Lnservice Inspection and ASME Section XI Repairs and Replacements2007-07-27027 July 2007 Cycle No. 23 Lnservice Inspection Summary Report for Lnservice Inspection and ASME Section XI Repairs and Replacements L-MT-05-088, 10 CFR 50.55a Request No. 13: Relief from Impractical Examination Coverage Requirements Pursuant to 10 CFR 50.55a(g)(5)(iii) for the Fourth Ten-Year Inservice Inspection Interval2005-09-27027 September 2005 10 CFR 50.55a Request No. 13: Relief from Impractical Examination Coverage Requirements Pursuant to 10 CFR 50.55a(g)(5)(iii) for the Fourth Ten-Year Inservice Inspection Interval L-MT-05-078, Summary Report for Inservice Inspections and ASME Section XI Repairs and Replacements2005-07-12012 July 2005 Summary Report for Inservice Inspections and ASME Section XI Repairs and Replacements L-MT-05-039, Fourth Interval Inservice Inspection Examination Plan. Revision 32005-04-26026 April 2005 Fourth Interval Inservice Inspection Examination Plan. Revision 3 L-MT-04-050, Fourth Interval Inservice Inspection Examination Plan, Revision 22004-09-16016 September 2004 Fourth Interval Inservice Inspection Examination Plan, Revision 2 L-MT-03-056, Summary Report for Inservice Inspections and ASME Section XI Repairs and Replacements2003-08-25025 August 2003 Summary Report for Inservice Inspections and ASME Section XI Repairs and Replacements L-MT-03-023, Response to Request for Additional Information Regarding Fourth 10-Year Interval Inservice Testing Program Relief Request Number No.VR-012003-04-29029 April 2003 Response to Request for Additional Information Regarding Fourth 10-Year Interval Inservice Testing Program Relief Request Number No.VR-01 ML0235205912002-12-0606 December 2002 to Engineering Work Instruction EWI-09.04.01, Inservice Testing Program. ML0233806832002-11-22022 November 2002 Part 2 of 2, Monticello, Request for Review and Approval of Relief Request Associated with Fourth 10-Year Interval Inservice Testing Program Plan Submittal ML0233701072002-11-22022 November 2002 Part 1 of 2, Monticello, Request for Review and Approval of Relief Request Associated with Fourth 10-Year Interval Inservice Testing Program Plan Submittal ML0217102272002-06-0606 June 2002 Inservice Testing Program for Engineering Work Instruction, Revision 8 ML0211905312002-04-0101 April 2002 Revision 7 to EWI-09.04.01, Inservice Testing Program. ML0208603482002-03-12012 March 2002 Part 1 of 4, Monticello Nuclear Generating Plant, Summary Report for Inservice Inspections & ASME Section XI Repairs & Replacements ML0208605512002-03-12012 March 2002 Part 2 of 4, Monticello Nuclear Generating Plant, Summary Report for Inservice Inspections & ASME Section XI Repairs & Replacements, Owner'S Report for Repairs or Replacements - Form NIS-2, Revision 4 to 3613 ML0208606762002-03-12012 March 2002 Part 3 of 4, Monticello Nuclear Generating Plant, Summary Report for Inservice Inspections & ASME Section XI Repairs & Replacements, Owner'S Report for Repairs or Replacements - Form NIS-2, Revision 4 to 3613 ML0208606932002-03-12012 March 2002 Part 4 of 4, Monticello Nuclear Generating Plant, Summary Report for Inservice Inspections & ASME Section XI Repairs & Replacements, Owner'S Report for Repairs or Replacements - Form NIS-2, Revision 4 to 3613 ML0203203662002-01-11011 January 2002 Inservice Inspection Plan Submittal of Relief Request Number 14 for the Third Ten Year Interval 2023-07-31
[Table view] Category:Letter
MONTHYEARIR 05000263/20240022024-08-14014 August 2024 Integrated Inspection Report 05000263/2024002 ML24218A2282024-08-0505 August 2024 Request for Confirmation of Information for Relief Request RR-017, Inservice Inspection Impracticality During the Fifth Ten-Year Interval ML24208A1502024-07-26026 July 2024 Independent Spent Fuel Storage Installation - Submittal of Quality Assurance Topical Report (NSPM-1) ML24215A2992024-07-23023 July 2024 Minnesota State Historic Preservation Office Comments on Monticello SLR Draft EIS ML24198A2372024-07-18018 July 2024 Information Request to Support Upcoming Biennial Problem Identification and Resolution (Pi&R) Inspection at Monticello Nuclear Generating Plant L-MT-24-022, – Preparation and Scheduling of Operator Licensing Examinations2024-07-0909 July 2024 – Preparation and Scheduling of Operator Licensing Examinations ML24164A2402024-06-10010 June 2024 Minnesota State Historic Preservation Office- Comments on Draft Monticello SLR Draft EIS 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 ML24137A2792024-06-0303 June 2024 Audit Summary for License Amendment Request to Revise Technical Specification 3.8.6, Battery Parameters, Surveillance Requirement 3.8.6.6 IR 05000263/20244012024-05-30030 May 2024 Public - Monticello Nuclear Generating Plant - Cyber Security Inspection Report 05000263/2024401 ML24141A1292024-05-22022 May 2024 Northern States Power Company - Use of Encryption Software for Electronic Transmission of Safeguards Information ML24141A1782024-05-20020 May 2024 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection 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 ML24135A1902024-05-14014 May 2024 Submittal of 2023 Annual Radioactive Effluent Release Report L-MT-24-013, 2023 Annual Radiological Environmental Operating Report2024-05-14014 May 2024 2023 Annual Radiological Environmental Operating Report IR 05000263/20240102024-05-13013 May 2024 Age-Related Degrading Inspection Report 05000263/2024010 ML24128A0042024-05-0909 May 2024 Letter to Minnesota State Historic Preservation Office- Section 106 Consultation Regarding the Monticello Nuclear Generating Plant Subsequent License Renewal Application ML24127A1472024-05-0909 May 2024 Letter to Mille Lacs Band- Section 106 Consultation Regarding the Monticello Nuclear Generating Plant Subsequent License Renew. Application 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) IR 05000263/20240012024-04-29029 April 2024 Plan - Integrated Inspection Report 05000263/2024001 ML24115A2952024-04-25025 April 2024 Sec106 Tribal, Kakkak, Gena-Menominee Indian Tribe of Wisconsin ML24115A3022024-04-25025 April 2024 Sec106 Tribal, Stiffarm, Jeffrey-Fort Belknap Indian Community ML24115A2992024-04-25025 April 2024 Sec106 Tribal, Renville, J. Garret-Sisseton Wahpeton Oyate of the Lake Travers Reservation ML24115A3032024-04-25025 April 2024 Sec106 Tribal, Taylor, Louis-Lac Courte Oreilles Band of Lake Superior Chippewa Indians ML24115A2962024-04-25025 April 2024 Sec106 Tribal, Larsen, Robert-Lower Sioux Indian Community ML24115A3002024-04-25025 April 2024 Sec106 Tribal, Rhodd, Timothy-Iowa Tribe of Kansas and Nebraska ML24115A2892024-04-25025 April 2024 Sec106 Tribal, Fowler, Thomas-St. Croix Chippewa of Wisconsin ML24115A2922024-04-25025 April 2024 Sec106 Tribal, Jensvold, Kevin-Upper Sioux Community ML24115A2902024-04-25025 April 2024 Sec106 Tribal, Jackson-Street, Lonna-Spirit Lake Nation ML24115A2882024-04-25025 April 2024 Sec106 Tribal, Fairbanks, Michael-White Earth Nation.Docx ML24115A2972024-04-25025 April 2024 Sec106 Tribal, Miller, Cole-Shakopee Mdewakanton Sioux Community ML24115A2982024-04-25025 April 2024 Sec106 Tribal, Reider, Anthony-Flandreau Santee Sioux Tribe ML24115A2932024-04-25025 April 2024 Sec106 Tribal, Johnson, Grant-Prairie Island Indian Community ML24115A2912024-04-25025 April 2024 Sec106 Tribal, Jacskon, Sr., Faron-Leech Lake Band of Ojibwe ML24115A3072024-04-25025 April 2024 Sec106 Tribal, Williams, Jr., James-Lac Vieux Desert Band of Lake Superior Chippewa Indians ML24115A3052024-04-25025 April 2024 Sec106 Tribal, Vanzile, Jr., Robert-Sokaogon Chippewa Community ML24115A2872024-04-25025 April 2024 Sec106 Tribal, Dupuis, Kevin-Fond Du Lac Band of Lake Superior Chippewa ML24115A3062024-04-25025 April 2024 Sec106 Tribal, Wassana, Reggie-Cheyenne and Arapaho Tribes ML24115A3012024-04-25025 April 2024 Sec106 Tribal, Seki, Darrell-Red Lake Nation ML24115A2942024-04-25025 April 2024 Sec106 Tribal, Johnson, John-Lac Du Flambeau Band of Lake Superior Chippewa Indians ML24115A2792024-04-24024 April 2024 Sec106 Tribal, Blaker, Doreen-Keweenaw Bay Indian Community ML24115A2862024-04-24024 April 2024 Sec106 Tribal, Deschampe, Robert-Grand Portage Band of Lake Superior Chippewa ML24115A2812024-04-24024 April 2024 Sec106 Tribal, Boyd, NIcole-Red Cliff Band of Lake Superior Chippewa ML24115A2782024-04-24024 April 2024 Sec106 Tribal, Azure, Jamie-Turtle Mountain Band of Chippewa Indians ML24115A2842024-04-24024 April 2024 Sec106 Tribal, Chavers, Catherine-Boise Forte Band of Chippewa ML24115A2822024-04-24024 April 2024 Sec106 Tribal, Chavers, Catherine J-Minnesota Chippewa Tribe ML24115A2852024-04-24024 April 2024 Sec106 Tribal, Denney, Alonzo-Santee Sioux Nation ML24115A2802024-04-24024 April 2024 Sec106 Tribal, Blanchard, Robert-Bad River Band of Lake Superior 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) 2024-08-05
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Xcel Energy Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 July 30, 2014 L-MT-14-064 10 CFR 50.55a ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed Facility Operating License No. DPR-22
Subject:
10 CFR 50.55a Request No. VR 05: Proposed Alternative to lnservice Testing Requirements Pursuant to 10 CFR 50.55a(a)(3)(ii)
Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(ii), Northern States Power Company, a Minnesota corporation (NSPM), d/b/a Xcel Energy requests authorization of an alternative to the testing requirements of American Society of Mechanical Engineers (ASME) Code for Operations and Maintenance of Nuclear Power Plants (ASME OM Code) 2004 Edition, with Addenda through OMb Code-2006, for the Monticello Nuclear Generating Plant.
An upward trend in unidentified drywellleakage was suspected to be the result of a packing leak on an inboard main steam line drain valve. The inboard main steam line drain valve was back seated to isolate the packing leak, which reduced the unidentified leakage in the drywell. With the inboard main steam line drain valve back seated the outboard main steam line drain valve was closed and de-energized to prevent opening for 10 CFR 50, Appendix R concerns.
This 10 CFR 50.55a request is to defer quarterly valve exercise testing on the inboard and outboard main steam line drain valves (M0-2373 and M0-2374) to the refueling outage in spring 2015 because of the hardship without a compensating increase in the level of quality and safety presented by the temporary configuration of the main steam line drain valves. Quarterly testing will resume following the spring 2015 refueling outage. The details of the 10 CFR 50.55a request are provided herein.
NSPM submits this request for the Fifth Ten-Year lnservice Testing Interval and requests expedited approval by October 1, 2014, prior to the next quarterly surveillance scheduled for October 10, 2014.
If you have any questions or require additional information, please contact Mr. Randy Rippy at 612-330-6911.
Document Control Desk L-MT-14-064 Page 2 of 2
~ aL Summary of Commitments commitments and no revisions to existing commitments.
Karen D. Fili Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company- Minnesota Enclosure cc: Administrator, Region Ill, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce
ENCLOSURE 10 CFR 50.55a REQUEST VR 05 IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(ii)
INSERVICE TESTING HARDSHIP Main Steam Line Drain Valve Exercising Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(ii)
On the basis that compliance with the American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
- 1. ASME OM Code Component(s) Affected M0-2373, Main Steam Line Drain Valve - Inboard (Class 1) (Category A)
M0-2374, Main Steam Line Drain Valve- Outboard (Class 1) (Category A)
Component/System Function These valves are normally closed during power operations. These valves must close to prevent inventory loss following main steam line pipe breaks outside containment and to provide containment isolation.
These valves receive a Group 1 Isolation Signal to close upon: 1) Reactor low low water level; 2) Main steam line high flow; 3) Main steam line tunnel high temperature; 4) Main steam line low pressure (RUN mode only).
M0-2373 is the inboard containment isolation valve for penetration X-8 and M0-2374 is the outboard containment isolation valve for penetration X-8.
The main steam line drain valves may be opened to facilitate draining condensate and providing warm up steam during plant startup. These valves are also opened during reset of a Group I isolation to minimize differential pressure across the main steam isolation valves prior to their reopening. These open functions are not required for safe shutdown or accident mitigation.
- 2. Applicable Code Edition and Addenda The Monticello Nuclear Generating Plant (MNGP) is currently in the fifth 10-year lnservice Test (1ST) Program interval and is committed to the American Society of Mechanical Engineers (ASME) Code for Operations and Maintenance of Nuclear Power Plants (ASME OM Code) 2004 Edition, with Addenda through OMb Code-2006.
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- 3. Applicable Code Reguirement(s)
ISTC-351 0, "Exercising Test Frequency," states in part: "Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months ... "
- 4. Reason for Request In May 2014, an upward trend in unidentified drywellleakage was identified in conjunction with a change in the Drywell continuous air monitor which occurred coincidentally with the exercise (stroke time) testing of inboard main steam line drain valve M0-2373. The cause of the increased leakage was suspected to be the result of a packing leak on the inboard main steam line drain valve. Back seating this valve would likely reduce leakage into the Drywell.
A back seating testing methodology was developed which would maintain the functional performance parameters of both the inboard and outboard valves within acceptable limits. On July 10, 2014, M0-2373 was back seated and testing was performed which demonstrated the operability of the valves. After completion of the testing the inboard main steam line drain valve was back seated in the open position to isolate the packing leak. This reduced the unidentified leakage in the Drywell to levels that had existed prior to exercising M0-2373. With the inboard main steam line drain valve back seated, the outboard valve (M0-2374) was then closed and de-energized to prevent opening due to 10 CFR 50, Appendix R concerns.
Quarterly exercise testing of these valves is next required on October 10, 2014.
It is requested to defer this testing until the 2015 refueling outage, scheduled for the spring of 2015. To perform the quarterly exercise testing and returning M0-2373 to a back seated configuration between quarterly tests, would require multiple opening and closing evolutions of the two valves, including the need to re-energize and de-energize the breaker for M0-2374. These multiple evolutions have the potential to exacerbate drywellleakage, which the back seating operation had previously restored to normal levels.
Quarterly Exercise Testing Quarterly exercise testing of M0-2373 and M0-2374 with M0-2373 on its back seat requires multiple breaker manipulations. The quarterly test starts with M0-2373 being stroke timed closed. Next, the breaker for M0-2374 would have to be closed to restore power to M0-2374. M0-2374 would be stroke timed open and closed, and then the breaker for M0-2374 would be reopened. M0-2373 would then be stroke timed open. M0-2373 would then have to be back seated to reduce unidentified Drywellleakage resulting from packing leakage on M0-2373. This evolution would be required to be performed each quarter (two more quarterly tests) until the refueling outage in the spring of 2015 when the valve will be repaired.
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Risks Associated With The Back Seating Evolution Repeated back seating increases the risk of causing damage to the back seat or stem as described in US Nuclear Regulatory Commission (NRC) Information Notice 87-40, "Backseating Valves Routinely to Prevent Packing Leakage."
Placing the valve on its back seat multiple times requires opening the circuit breaker and connecting a reduced voltage source to the motor operated valve (MOV) bypassing the open circuit until the motor is stalled. The reduced voltage source is then removed and the circuit breaker is closed. Repeatedly performing this evolution increases the potential for human errors to occur. Motor damage could occur if the locked rotor current is in excess of 15 seconds. If reduced voltage is not properly controlled the valve back seat or stem may be damaged during the back seat evolution. In the open direction the calculated weakest link is the back seat on M0-2373. An increase in unidentified drywell leakage, such as might occur from repeated cycling of M0-2373, could ultimately result in a Technical Specification (TS) required shutdown.
Basis for Relief Based on Hardship NUREG 1482, Revision 2, section 3.1.1, states "A licensee may request relief from quarterly testing where such testing would impose a hardship (e.g., entering a limiting condition for operations of 3 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in duration, repositioning a breaker from "off" to "on" ... )." Other acceptable reasons for relief include: the need to keep personnel radiation exposure as low as reasonably achievable (ALARA), and personnel safety.
Repair of the valve packing would require entry into the Drywell. Entry into the Drywell would require the plant to either enter Mode 3 (Hot Shutdown) or drop below 10% power due to radiation levels. Entry into the Drywell with the plant operating is not ALARA and increases the personnel risk due to radiation levels.
Also, a Drywell entry presents personnel safety concerns due to high ambient temperatures, and inaccessibility- the Drywell is inerted with nitrogen gas during power operation.
Additionally, maneuvering the reactor to below 10% power or to Mode 3 involves inherent risk and increases the nuclear safety risks due to cycling plant equipment. Maintaining the packing leak isolated with the inboard main steam line drain valve (M0-2373) back seated in the open position and the outboard valve closed is the lower risk option.
For all of these reasons, quarterly exercising of main steam line drain valves (M0-2373 and M0-2374) involves a hardship. There is not a sufficient corresponding increase in level of safety versus the potential to increase Drywell unidentified leakage or cause further damage to the inboard main steam line drain isolation valve.
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- 5. Proposed Alternative and Basis for Use The main steam line drain valves are exercise tested quarterly. The present configuration of back seating the inboard main steam line drain valve in the open position to decrease Drywellleakage, and closing and de-energizing the outboard valve to isolate the penetration, is a temporary configuration. Quarterly exercise testing of the inboard main steam line drain valve from the back seated position increases the potential for unacceptable Drywellleakage, for which the back seating operation was previously performed to reduce Drywell leakage to acceptable levels.
Northern States Power Company- Minnesota (NSPM) proposes to stroke the inboard and outboard main steam line drain valves (M0-2373/M0-2374) on a refueling outage basis in lieu of the current quarterly exercise testing. The valves have successfully passed each quarterly exercise test since startup from the 2013 refueling outage. Historical exercise trending results for both of these main steam line drain valves for performances prior to the 2013 refueling outage are consistent with current cycle results.
The inboard and outboard main steam line drain valves are normally closed during power operation. The valves safety function is to close to prevent inventory loss following main steam line pipe breaks outside containment and to provide containment isolation. The proposed operating configuration for the remainder of the cycle, i.e., operating with the outboard valve closed and de-energized and the inboard valve back seated in the open position (to reduce leakage into the Drywell), maintains the required safety function of containment isolation. Multiple back seats of the inboard main steam line drain valve could result in back seat or stem damage. Requiring performance of quarterly exercise testing unnecessarily challenges the function. Also, since the inboard and outboard main steam line drain valves normal state is closed during power operation, there are no operational reasons to require stroking of these valves during this period.
It is desired by NSPM to extend the exercise testing to the refueling outage due to the hardship without a compensating increase in the level of quality and safety presented by the temporary configuration of the main steam line drain valves.
There is reasonable assurance that these valves will perform their safety function to close to prevent inventory loss following main steam line pipe breaks outside containment and to provide containment isolation.
- 6. Duration of Proposed Alternative The proposed alternative identified in this relief request shall be utilized until the next refueling outage in spring of 2015.
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