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#REDIRECT [[L-MT-15-047, Update of Information Related to NRC Order Update of Information Related to NRC Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events]]
| number = ML15288A132
| issue date = 10/12/2015
| title = Monticello - Update of Information Related to NRC Order Update of Information Related to NRC Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events
| author name = Gardner P A
| author affiliation = Northern States Power Co, Xcel Energy
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000263
| license number = DPR-022
| contact person =
| case reference number = EA-12-049, L-MT-15-047, TAC MF0923
| document type = Letter
| page count = 92
| project = TAC:MF0923
}}
 
=Text=
{{#Wiki_filter:YX cel~~nergy"2807Monticello Nuclear Generating PlantwCutRod7~ X c I~ne g~'Monticello, MN 55362October 12, 2015 L-MT-l15-04710 CFR 2.202U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Monticello Nuclear Generating PlantDocket No. 50-263Renewed Facility Operating License No. DPR-22Monticello Nuclear Generatingq Plant: Update of Information Related to NRC OrderEA-12-049 Mitiqation Strategies for Beyond-Design-Basis External Events (TAC No.MF0923)References:1. NRC Order EA-12-049, "Issuance of Order to Modify Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012. (ADAMS Accession No.ML1 2054A735)2. Letter from K. Fili (NSPM) to Document Control Desk (NRC), "Request forRelaxation from NRC Order EA-12-049, "Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-BasisExternal Events" -Monticello Nuclear Generating Plant," L-MT-14-083, datedOctober 1, 2014. (ADAMS Accession No. ML14289A512)3. Letter from W. Dean (NRC) to K. Fili (NSPM), "Subject: Monticello NuclearGenerating Plant -Relaxation of Certain Schedule Requirements for OrderEA-1 2-049 'Issuance of Order to Modify Licenses With Regard toRequirements for Mitigation Strategies for Beyond Design Basis ExternalEvents' (TAC No. MF0923)," dated November 21, 2014. (ADAMS AccessionNo. ML14294A061)4. NRC Order EA-1 3-1 09, "Issuance of Order to Modify Licenses with Regard toReliable Hardened Containment Vents Capable of Operation under SevereAccident Conditions," dated June 6, 2013. (ADAMS Accession No.ML1 3143A334)A (51 Document Control DeskPage 2On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued OrderEA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events," (Reference 1), to allNRC power reactor licensees and holders of construction permits in active or deferredstatus. Reference 1 was effective immediately and directed Northern States PowerCompany, a Minnesota corporation (NSPM), doing business as Xcel Energy, todevelop, implement and maintain guidance and strategies to maintain or restore corecooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event for the Monticello Nuclear Generating Plant (MNGP).Specific requirements are outlined in Attachment 2 of Reference 1.In Reference 2, NSPM requested relaxation of order EA-12-049 for the MNGP. NSPMrequested relaxation of the completion of the Order from startup from the Spring 2015refueling outage (RFO) to startup from the Spring 2017 RFO. The reason for therelaxation was to permit NSPM to design and install the severe accident capablehardened containment wetwell vent in accordance with Order EA-1 3-109 (Reference 4),and integrate it into the mitigating strategies required for Order EA-12-049. Therelaxation request stipulated that the relaxation request only applied to the hardenedcontainment vent portion of Order EA-12-049, and further stipulated that otherrequirements of Order EA-12-049 would be completed prior to startup from the Spring2015 RFO.In Reference 3, the NRC approved NSPMs relaxation request and accepted both thejustification and the stipulations regarding completion of the balance of OrderEA-12-049 by the completion of the 2015 RFO.The purpose of this letter is to inform the NRC that the equipment and modificationsrequired to implement the mitigating strategies required by Order EA-12-049 have beencompleted and are available for use in accordance with the original implementationschedule requirements, except for installation of a severe accident capable hardenedcontainment wetwell vent as required by NRC Order EA-1 3-1 09, and integration of itsoperation into the mitigating strategies required for Order EA-12-049. This is supportedby the information provided in Enclosure 1. In Enclosure 2, NSPM is providing updatesto NRC information requests to demonstrate implementation of Order EA-12-049 to theextent described in Reference 3.Please contact John Fields at 763-271-6707, if additional information or clarification isrequired.
Document Control DeskPage 3Summary of CommitmentsThis letter makes no new commitments and no revisions to existing commitments.I declare under penalty of perjury that the foregoing is true and correct.Executed on October ___, 2015.Peter A. Site Vice President, Monticello Nuclear Generating PlantNorthern States'Power Company -MinnesotaEnclosures (2)cc: Administrator, Region Ill, USNRCProject Manager, Monticello Nuclear Generating Plant, USNRCResident Inspector, Monticello Nuclear Generating Plant, USNRC L-MT-1 5-047 NSPMEnclosure IENCLOSURE 1Monticello Nuclear Generating PlantImplementation of Required Action by NRC Order EA-12-049Mitigation Strategies for Beyond-Design-Basis External Events1.0 BackgroundOn March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued OrderEA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events," (Reference 1), to allNRC power reactor licensees and holders of construction permits in active or deferredstatus. Reference 1 was effective immediately and directed Northern States PowerCompany, a Minnesota corporation (NSPM), doing business as Xcel Energy, todevelop, implement and maintain guidance and strategies to maintain or restore corecooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event for the Monticello Nuclear Generating Plant (MNGP).Specific requirements are outlined in Attachment 2 of Reference 1.NSPM submitted the MNGP Overall Integrated Plan (OIP) for compliance of OrderEA-12-049 by letter dated February 28, 2013 (Reference 2). By letter dated,November 25, 2013 (Reference 3) the NRC provided its interim staff evaluation of theOIP and requested additional information necessary for completion of the review. Theinformation requested by the NRC is included in Enclosure 2.In Reference 4, NSPM requested relaxation of order EA-12-049 for the MNGP. NSPMrequested relaxation of the completion of the Order from startup from the Spring 2015refueling outage (RFO) to startup from the Spring 2017 RFO. The reason for therelaxation was to permit NSPM to design and install the severe accident capablehardened containment wetwell vent in accordance with Order EA-1 3-109, and integrateit into the mitigating strategies required for Order EA-12-0491.The relaxation requeststipulated that the relaxation request only applied to the hardened containment vent(HCV) portion of Order EA-12-049, and further stipulated that other requirements ofOrder EA-12-049 would be completed prior to startup from the Spring 2015 RFO.In Reference 5, the NRC approved NSPMs relaxation request and accepted both thejustification and the stipulations regarding completion of the balance of OrderEA-12-049 by the completion of the 2015 RFO.SMNGP has previously and continues to maintain the ability and procedural direction to perform wetwellventing during specified emergency conditions. The approved relaxation did not remove the ability orprocedural direction to perform wetwell venting during Extended Loss of AC Power (ELAP) events.Page 1 of 4 L-MT-1 5-047 NSPMEnclosure 12.0 ImplementationSTRATEGIES -IMPLEMENTEDMNGP strategies are in compliance with Order EA-12-049, except as permittedby the NRC approved Order relaxation. There are no strategy related OpenItems, Confirmatory Items, or Audit Questions/Audit Report Open Items, exceptinformation related to the HCV installation and strategies are incomplete at thistime.MODIFICATIONS -IMPLEMENTEDThe modifications required to support the FLEX strategies for MNGP have beenfully implemented in accordance with the station design control process, exceptas permitted by the NRC approved Order relaxation.EQUIPMENT -- PROCURED AND MAINTENANCE & TESTING -IMPLEMENTEDThe equipment required to implement the FLEX strategies for MNGP has beenprocured in accordance with NEI 12-06, Section 11.1 and 11.2, received atMNGP, initially tested/performance verified as identified in NEI 12-06, Section11.5, and is available for use, except as permitted by the NRC approved Orderrelaxation.Maintenance and testing will be conducted through the use of the MNGPPreventative Maintenance program such that equipment reliability is achievedand maintained.PROTECTED STORAGE -IMPLEMENTEDThe storage facilities required to implement the FLEX strategies for MNGP havebeen completed and provide protection from the applicable site hazards. Theequipment required to implement the FLEX strategies for MNGP is stored in itsprotected configuration.PROCEDURES -IMPLEMENTEDFLEX Support Guidelines (FSGs) for MNGP have been developed andintegrated with existing procedures, except as permitted by the NRC approvedOrder relaxation. The implemented FSGs and affected existing procedures havebeen verified and are available for use in accordance with the site procedurecontrol program.Page 2 of 4 L-MT-l15-047 NSPMEnclosure 1TRAINING -IMPLEMENTEDTraining for MNGP has been implemented in accordance with an acceptedtraining process as recommended in NEI 12-06, Section 11.6.STAFFING -IMPLEMENTEDThe staffing study for MNGP has been completed in accordance with10OCFR50.54(f), "Request for Information Pursuant to Title 10 of the Code ofFederal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Forcereview of Insights from the Fukushima Dai-ichi Accident," Recommendation 9.3,dated March 12, 2012 (Reference 6), as documented in a letter to the NRC datedApril 30, 2015 (Reference 7). The staffing study concluded that no additional.staff is required to mitigate the extended loss of alternating current (ac) power(FLAP) event.NATIONAL SAFER RESPONSE CENTERS -IMPLEMENTEDNSPM has established a contract with Pooled Equipment Inventory Company(PEICo) and has joined the Strategic Alliance for FLEX Emergency Response(SAFER) Team Equipment Committee for off-site facility coordination. It hasbeen confirmed that PEICo is ready to support MNGP with Phase 3 equipmentstored in the National SAFER Response Centers in accordance with the sitespecific SAFER Response Plan.VALIDATION -COMPLETENSPM has completed performance of validation in accordance with industrydeveloped guidance to assure required tasks, manual actions and decisions forFLEX strategies are feasible and may be executed within the constraintsidentified in the GIP and Request for Additional Information Responses (i.e. theOpen Items, Confirmatory Items, Audit Questions and Safety Evaluationquestions included in Enclosure 2 of this letter) for Order EA-12-049, except aspermitted by the NRC approved Order relaxation.FLEX PROGRAM DOCUMENT -ESTABLISHEDThe NSPM FLEX Program Document for MNGP has been developed inaccordance with the requirements of NEI 12-06.Page 3 of 4 L-MT-1 5-047 NSPMEnclosure 13.0 References1. NRC Order EA-12-049, "Issuance of Order to Modify Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents,"' dated March 12, 2012. (ADAMS Accession No. ML12054A735)2. Letter from M. Schimmel (NSPM) to Document Control Desk (NRC), "MonticelloNuclear Generating Plant's Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049)," L-MT-13-017, dated February 28, 2013. (ADAMSAccession No. ML13066A066)3. Letter from J. Bowen (NRC) to K. Fili (NSPM), "Monticello Nuclear GeneratingPlant -Interim Staff Evaluation Relating to Overall Integrated Plan in Responseto Order EA-12-049 (Mitigation Strategies) (TAC No. MF0923)," datedNovember 25, 2013. (ADAMS Accession No. ML1 3220A1 39)4. Letter from K. Fili (NSPM) to Document Control Desk (NRC), "Request forRelaxation from NRC Order EA-12-049, "Order Modifying Licenses with Regardto Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents" -Monticello Nuclear Generating Plant," L-MT-14-083, datedOctober 1, 2014. (ADAMS Accession No. ML14289A512)5. Letter from W. Dean (NRC) to K. Fili (NSPM), "Subject: Monticello NuclearGenerating Plant -Relaxation of Certain Schedule Requirements for OrderEA-12-049 'Issuance of Order to Modify Licenses With Regard to Requirementsfor Mitigation Strategies for Beyond Design Basis External Events' (TAC No.MF0923)," dated November 21, 2014. (ADAMS Accession No. ML14294A061)6. Letter from E. Leeds/M. Johnson (NRC), to Licensees, "Request for InformationPursuant to Title 10 of the Code of Federal Regulations 50.54(f), RegardingRecommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review ofInsights from the Fukushima Dai-ichi Accident," dated March 12, 2012. (ADAMSAccession No. ML12053A340)7. Letter from P. Gardner (NSPM) to Document Control Desk (NRC), "MonticelloNuclear Generating Plant Phase 2 Staffing Assessment Revised -Onsite andAugmented Staffing Assessment Considering Functions Related to Near-TermTask Force (NTTF) Recommendation 4.2," L-MT-15-027, dated April 30, 2015.(ADAMS Accession No. ML15128A264)Page 4 of 4 L-MT-1 5-047Enclosure 2ENCLOSURE 2Monticello Nuclear Generating PlantCompletion of Required Action by NRC Order EA-12-049Mitigation Strategies for Beyond-Design-Basis External EventsResponses to Requests for Additional InformationNorthern States Power Minnesota, a Minnesota corporation (NSPM), doing business asXcel Energy developed an Overall Integrated Plan (OIP) for (Reference 1), documentingthe diverse and flexible strategies (FLEX), in response to Order EA-12-049, "OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Desig n-Basis External Events," (Reference 2 ) for Monticello Nuclear Generating Plant(MNGP).In Reference 3, the NRC documented their review of the MNGP OIP and provided OpenItems (Ols) and Confirmatory Items (CIs) for NSPM to address. Subsequently, prior tothe on-site audit of the MNGP FLEX Order and the Spent Fuel Pool Instrumentation(SFPI) Order, the NRC also provided Audit Questions (AQs) and Safety EvaluationItems (SEs) for NSPM to address as well (Reference 4).All responses to the OIsClCslAQslSEs were previously provided to the NRC in the onlinereference portal or during the FLEX/SFPI audit performed in November 2014. Eachitem is complete pending NRC closure.This enclosure contains formal responses to the NRC's OlsClCslAQslSEs. The NRC'sOIICIIAQISE is provided in italics font and the NSPM response is in the normal font.The OIICIIAQISE responses were initially provided to the NRC via the online referenceportal during completion of the design and analyses associated with the FLEXstrategies. Most of the OIICIIAQ/SE responses are unchanged except for small editorialchanges and replacement of future tense statements with past tense statements asnecessary to reflect the completed status of the associated actions. However, thefollowing responses have been modified more significantly to provide updatedinformation. A brief synopsis of the changes is provided below:01 3.2.3.A -The original response to the NRC indicated that the ReactorPressure Vessel (RPV) would be maintained at a pressure of 200 -400 psig tosupport Reactor Core Isolation Cooling (RCIC) pump operation during phase 1and while transitioning to phase 2 of the extended loss of alternating current (ac)power (ELAP) event. The RPV pressure range was subsequently changed to befrom 150 -300 psig. This impacted heat load in the Torus (also calledPage 1 of 85 L-MT-1 5-047Enclosure 2suppression pool) and the time for Torus temperature to reach approximately250&deg;F. See the responses to AQ 62 and 0I 3.2.3.A for further details.OI0 3.2.4.3.A -The original response to the NRC indicated that the ELAPprocedure would contain a discussion about the effects of loss of heat tracing incold weather. This was later deemed not to be necessary for FLEX Ordercompliance.*AQ 62 -The original response indicated that RCIC pump operation wasassumed to cease when the suppression pool temperature reached 240&deg;F andthe portable diesel pump would be operating at that time. This has been revisedto cease RCIC pump operation and begin portable diesel pump operation atapproximately 250&deg;F. See the responses to AQ 62 and 0I 3.2.3.A for furtherdetails.*SE 5 -Added the FLEX strategies validation document as the basis fordemonstrating human factors considerations for FLEX strategies have beenadequately addressed.References:1. Letter from M. Schimmel (NSPM) to Document Control Desk (NRC), "MonticelloNuclear Generating Plant's Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049)," L-MT-13-017, dated February 28, 2013. (ADAMSAccession No. ML13066A066)2. NRC Order EA-12-049, "Issuance of Order to Modify Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents," dated March 12, 2012. (ADAMS Accession No. ML12054A735)3. Letter from J. Bowen (NRC) to K. Fili (NSPM), "Monticello Nuclear GeneratingPlant -Interim Staff Evaluation Relating to Overall Integrated Plan in Responseto Order EA-12-049 (Mitigation Strategies) (TAC No. MF0923)," datedNovember 25, 2013. (ADAMS Accession No. ML1 3220A1 39)4. Letter from P. Bamford (NRC) to K. Fili (NSPM), "Monticello Nuclear GeneratingPlant -Plan For the Onsite Audit Regarding Implementation of MitigatingStrategies and Reliable Spent Fuel Pool Instrumentation Related to OrdersEA-12-049 and EA-12-051 (TAC Nos. MF0923 and MF0924)," datedOctober 22, 2014. (ADAMS Accession No. ML14290A367)Page 2 of 85 L-MT-1 5-047Enclosure 2Responses toOpen Items (Ols). Confirmatory Items (CIs),Audit Questions (AQs), and Safety Evaluation (SEs)0I 3.1.1.3.AThe licensee's integrated plan did not address the potential imp acts from largeinternal flooding sources that are not seismically robust and do not require ac power,the potential loss of ac power to mitigate ground water in critical locations, or theimpact of potential failure of non-seismically robust downstream dams.NSPM ResponseNEI 12-06, Section 5.3.3, states:"Consideration should be given to the impacts from large internal floodingsources that are not seismically robust and do not require ac power (e.g., gravitydrainage from lake or cooling basins for non-safety-related cooling watersystems)."MNGP does not have any lakes or cooling basins capable of creating large internalflooding. The principal source of internal flooding at MNGP is a pipe break. Themajor pipe breaks include Condensate Storage Tank (CST) flooding from a largepipe break in the Turbine Building (TB), Condenser failure, and flooding from thediesel driven fire pump pumping into non-seismic fire piping. Procedural guidanceaddressing internal flooding is available for operational consideration. This floodingcould affect the FLEX alternate electrical connections for the Division I 125V batterychargers. However, the flooding would not affect the primary FLEX electricalconnections.NEI 12-06, Section 5.3.3, states:"For sites that use ac power to mitigate ground water in critical locations, astrategy to remove this water will be required."MNGP occasionally experiences minor amounts of ground water seepage into theplant. If groundwater in-leakage occurs, the flooding response procedures providepower and pumps to control in-leakage.NEI 12-06, Section 5.3.3, states:Page 3 of 85 L-MT-15-047Enclosure 2'Additional guidance may be required to address the deployment of FLEX forthose plants that could be impacted by failure of a not seismically robustdownstream dam."The nearest downstream dam is the Coon Rapids Dam, which is approximately 35river miles downstream from the plant. The impact of a Coon Rapids dam failure onthe river level at MNGP has not been evaluated. However, failure of a downstreamdam will not impact the MNGP discharge canal level, as there is a weir between thedischarge canal and the river. NEI 12-06, section 3.2.1.3, item 4, does not requirethat licensees assess for loss of the water inventory in the ultimate heat sink.Instead, only the normal access to the ultimate heat sink is assumed to be lost, butthe water inventory in the ultimate heat sink remains available. Even assuming aweir failure; a significant amount of water remains in the discharge canal andanother source of water is available in the intake basin.Following the ELAP initiating event, an assessment of the site is performed todetermine the availability and accessibility of the following sources of water:* Discharge Canal* Intake* Condensate Storage Tanks / Condensate Storage Tank Pit.Based on the above assessment, the Control Room Supervisor will select theappropriate staging location for the portable diesel pump.01 3.1 .2.2.AThe licensee's integrated plan did not address flooding deployment issues forrestocking supplies during flooding conditions, protection for fuel supplies assuringconnection points are protected, the need to provide water extraction pumps, andthe need for temporary flood barriers.NSPM ResponseThe MNGP flood response procedures provide for alternate access to the site byinstalling an additional gravel roadway, thereby allowing for access and delivery ofnecessary provisions including consumables, fuel, etc. The MNGP flood plan buildsa horseshoe levee to connect with the currently installed bin walls thereby encirclingthe fuel tanks and pump house that support the emergency diesels (needed toobtain fuel oil for FLEX equipment). The hose and electrical connection points arealso fully contained within the levee and protected from flooding. Pumps, generatorsPage 4 of 85 L-MT-1 5-047Enclosure 2and other equipment necessary for the flood mitigation are identified in proceduresand stored onsite or are readily available through existing contracts.Supplies and Restocking PlansSite procedures define the items that need to be obtained at the time of an externalflooding event.The procedure for flood protection implementation directs the acquisition ofPolyurethane Joint Sealant for general use for sealing gaps. This is a commonmaterial that is easily obtainable by supply chain. The procedure also directs theacquisition of 9200 cubic yards of clay for substation levee construction. This isthrough a standing contract with our levee constructor from a local clay pit that wehave tested clay characteristics on file. Finally, the procedure also directs theacquisition of diesel generators that would be used for powering pumps and othercomponents during a flood. These would be obtained through standing contractswith multiple vendors.Site procedures also direct the levee constructor to bring materials and equipment tosite to build the flood barrier. This is established equipment that can be mobilizedand delivered in time to build the barrier and stay ahead of the rising river water.Specific timing is contained in a site calculation and in the Technical Execution Plan(TEP).Site procedures direct the acquisition of facilities needed to support personnel thatwill be working to protect the plant during a flood. These items include portablerestrooms, food, water, etc. In addition, the following items are stored for use asnecessary for a Beyond Design Basis event or an event that would require FLEXmitigation strategies. These items include forty 5 gallon bottles of drinking water,twenty cases of Meals Ready to Eat (MREs) (~1 pallet), work lights, flashlights,gloves, hoses and fittings, hand tools, satellite phones, life jackets, radios, ladders,etc.The acquisition of diesel fuel oil and gasoline, as needed to support pumps andgenerators during the event, is also described in procedures.All of these items would be procured under the direction of the duty station managerby supply chain, operations, and construction leadership.If a flood was underway, the emergency response organization (ERG) would bemobilized. In such a case, the NRC, Institute of Nuclear Power Operations (INPO),Federal Emergency Management Agency (FEMA), and county and stategovernments would be contacted to support the site as needed.Page 5 of 85 L-MT-1 5-047Enclosure 2All other items that the site needs to respond to a flood are already on site andstored primarily in Parking Lot H and the receiving warehouse.Prior to river levels reaching the point of hampering site access, materials would beprovided via normal means. As water levels rise and cover the access road,procedures require that a temporary access road be built from County Road 75through a wooded area west of the Independent Spent Fuel Storage Installation(ISFSI) and connect to the existing road that runs from the ISESI to the plantdomestic water wells. This is also a pre-established plan to be executed by ourlevee constructor and the specific timing is determined by a site calculation andcommunicated in the TEP. This procedure ensures the road is built so as to notinterrupt the ability to access the site. There is ample real estate to the west of theplant where elevations are above the Probable Maximum Flood (PMF) height forstaging of materials and equipment. This also allows access into the area protectedby the levee which includes the power block.Watercraft and helicopters can also be utilized for material delivery.Fuel Supplies and Connections PointsTechnical Specification Bases B.3.8.3 (Diesel Fuel Oil, Lube Oil and Starting Air)identifies that the onsite fuel oil supply capacity is sufficient to operate oneEmergency Diesel Generator (EDG) for a period of 7 days under full load (2500 kW).The onsite fuel oil capacity is sufficient to operate the portable diesel generators fora time period longer than the time to replenish the onsite supply from outsidesources. In order to get the fuel to the site per this requirement, a contract with asupplier has been established as well as a route to get to the site during a floodingevent. MNGP has a standing contract with Flint Hills Resources, LP to deliver fuel tothe site when called upon.During a flooding event, not all normal roads to the site will be navigable; therefore atemporary road will be constructed as described previously. Although all ofMinnesota (MN) will not be at the same flood conditions, it is reasonable to assumethat some roads will not be available. If this is the case, there are recommendedroutes established in plant documentation with alternatives. Two recommendedalternative routes are described from the Flint Hills Rosemount, MN resource facilityto MNGP during a flood. The direct route from the Flint Hills facility to MNGP isapproximately 1 hour. The two alternative routes provided that are recommendedduring flooding conditions take approximately 2 hours and 2.5 hours respectively.This is a negligible increase in the time required for delivery and well within the 7 dayrequirement.Instructions are provided in plant documents to order fuel at the time of flood. Thesework orders (WOs) direct topping off of T-44, Diesel Oil Storage Tank as well asT-83, Diesel Oil Receiving Tank upon onset of flooding conditions. Additionally,Page 6 of 85 L-MT-1 5-047Enclosure 2tanker(s) will be ordered with the intent to remain at the site during the event to usetheir inventory as needed, additional tankers will be ordered prior to emptying onsitetankers, and as a contingency measure, helicopters (per SAFER plan) andwatercraft will be utilized if all other methods of fuel delivery fail.Additionally, multiple connection points are provided to fill the diesel fuel storagetanks. These connection points are protected by the horseshoe levee.Finally, site documents also direct the acquisition of gasoline to power pumps andgenerators as needed.0I 3.1 .2.3.AThe licensee did not discuss the need for temporary flood barriers and dewateringpumps during flooding events.NSPM ResponseMNGP flooding procedures specifically describe the actions needed including theconstruction of a horseshoe levee around the site, sealing of penetrations and otheractivities to mitigate flooding up to and including the PMF. MNGP implements theuse of flooding barriers and dewatering pumps through these procedures.0I 3.2.1.2.AThe licensee did not Identify or provide justification for the assumptions maderegarding primary system leakage from the recirculation pump seals and othersources.NSPM ResponseNSPM completed the Modular Accident Analysis Program (MAAP) analysis of anELAP event for MNGP. The primary system leakage used in the MAAP analysisranged from 30 gpm to 165 gpm, assuming an initial RPV pressure of 1000 psig(nominal operating pressure). The primary system leakage was assumed to occurat the transient initiation. As the RPV was depressurized, leakage decreased. Themaximum leakage from the failure of both seals for each reactor recirculation pumpis 70 gpm. The maximum leakage for both reactor recirculation pumps plus thePage 7 of 85 L-MT-1 5-047Enclosure 2Technical Specification (TS) primary system boundary leakage of 25 gpm, equals atotal primary system leakage of up to 165 gpm.Sulzer/Bingham has reported that the Seal Model # is RV-600. Further, Sulzerstates the pump and seal geometry is per the original design and the designevaluated by GE in NEDO-24083, dated November 1978. NEDO-24083 determinedthe equivalent makeup requirement for the seals is 65.27 gpm. The 65.27 gpmsupports use of a maximum leakage of 70 gpm in the MAAP analysis as aconservative number.01 3.2.3.AAdditional plant-specific Extended Loss of AC Power (ELAP) analysis informationcommensurate with the level of detail contained in NEDC-33771P, including analysisassumptions and results in their tabulated and plotted formats is needed to concludethat containment functions will be maintained.NSPM ResponseNSPM completed a plant-specific ELAP analysis, called a MAAP analysis. Thereference case analysis assumptions used in the MAAP analysis are the following:* 90&deg;F per hour cool down was initiated at 30 minutes, after which pressure wasmaintained between 150 and 300 psig.* Leakage from the RPV was assumed to be 165 gpm.* Reactor water level was maintained near +39.5" by the RCIC system.* RCIC was assumed to be available until the suppression pool temperaturereaches 2400&deg;F. This was revised by a later evaluation. See information below.* Above 240&deg;F, it was assumed that RPV level was maintained by a portablepump. This was revised by later evaluation. See information below.* The hardened containment vent (HCV) (also called hard pipe vent (HPV)) wasopened when the containment pressure reaches 10 psig and the suppressionpool temperature was greater than 212&deg;F. HCV was closed if drywell pressuredropped to 5 psig.Additional cases were run to evaluate sensitivities to:* Depressurization time (2 hrs vs 30 min)* HCV opening pressure (30 psig vs 10 psig)* Containment vent coefficientPage 8 of 85 L-MT-1 5-047Enclosure 2* RPV leakage (30 and 61 gpm vs 165 gpm)* Reactor water level range (RCIC operating in batch mode with a water levelrange of -100" to +48" and -47" to +48")* RCIC suction from the CSTs vs the suppression pool and the transfer time* High Pressure Coolant Injection (HPCI) system being used instead of the RCICsystem* Initial suppression pool temperature* Initial suppression pool water level* RPV insulationA summary of the results of the reference case analysis is provided as follows:* Reactor depressurization started at 30 minutes.* Hard pipe vent opened at 7.1 hours.* The suppression pool reached 240&deg;F at 10.5 hours (Subsequently changed to250&deg;F and 11.5 hours as described below).* Adequate core cooling was achieved for Phases 1 and 2 using RCIC for 10.5hours and then a portable pump after 10.5 hours (Subsequently changed to 11.5hours as described below).* Drywell temperature did not exceed 300&deg;F.* Suppression pool temperature stabilized at approximately 250&deg;F. Peaksuppression pool temperature by the analysis is approximately 250.7&deg;F andoccurs at 11.7 hours into the FLAP event.NSPM subsequently evaluated use of the RCIC pump at higher temperatures anddetermined that there was adequate margin to run the RCIC pump with suppressionpool temperature at the peak temperature from the analysis (approximately250.7&deg;F). Use of this temperature extends the run time of RCIC from 10.5 hours togreater than 11.5 hours2 and should not impact the functionality of the RCIC pump.2 The peak suppression pool temperature through the first 11.5 hours of the ELAP event is approximately 250.4&deg;F.Page 9 of 85 L-MT-1 5-047Enclosure 201 3.2.3.BThe licensee needs to resolve the issue of the potential for the BWROG revisedventing strategy to increase (relative to currently accepted venting strategies) thelikelihood of detrimental effects on containment response for events in which theventing strategy is invoked. In particular it has not been shown that the potential fornegative pressure transients, hydrogen combustion, or loss of containmentoverpressure (as needed for pump net positive suction head) is not significantlydifferent when implementing Revision 3 of the Emergency PlanningGuidelines/Severe Accident Guidelines (ERG/SAG) vs. Revision 2 of the ERG/SAG.NSPM ResponseOn January 9, 2014, the NRC endorsed the NEI/BWROG paper titled "BWRContainment Venting" that addresses the NRC staff's concerns with the revisedventing strategy in Revision 3 of the EPG/SAG (ADAMS Accession No.ML1 3358A206). The NRC's endorsement letter noted that plant specificimplementation of the EPG/SAG relied on such items as the capabilities of theinstalled vent path, the Net Positive Suction Head (NPSH) for RCIC, and guidance toprevent negative containment pressures. NSPM addresses each of these plant-specific implementation items in the paragraphs below.Installed Vent PathThe MNGP HCV consists of an 8-inch diameter line starting at a dedicatedpenetration at the top of the torus, connected to two containment isolation valves.The 8-inch line expands to a 10-inch diameter pipe to a rupture disc and exits to arelease point above the Reactor Building roof near the Reactor Building exhaust onthe north side of the Reactor Building. The HCV piping travels up the north side ofthe reactor building. The vent was designed to a temperature of 309&deg;F and apressure of 62 psig. The completed MAAP analysis verified that venting with theHCV will prevent the containment pressure from exceeding its design pressure.NPSH for RCICThe discussion of the NPSH for RCIC operation is provided in response toConfirmatory Item 3.2.1.8.A.Hard Pipe Vent StrateqyThe HPV strategy was designed with the following goals in mind:* Develop a strategy that is as simple as possible, recognizing that theoperators are functioning in the most challenging of times, and* Ensuring sufficient NPSH exists for RCIC pump operation, and* Address the potential to develop a negative pressure in containment.Page 10 of 85 L-MT-1 5-047Enclosure 2Based on these criteria NSPM has developed the following strategy for ventingMNGP containment:* Open the HPV when containment pressure is >10 psig AND the torus watertemperature is > 2120F* Close the HPV before containment pressure decreases to 5 psig.* Repeat venting as needed to maintain containment pressure between5 -10 psig.Strategy JustificationIf the HPV is opened at 10 psig during an ELAP event (without consideration of toruswater temperature), containment pressure will drop to near atmospheric for the nextseveral hours while the torus water heats up for the several hours reaching boiling inapproximately 7 hours. At 7 hours, the containment pressure again starts toincrease.The following figures show this graphically. Figure 0I 3.2.3.B -1 assumes a largeprimary coolant leak (165 gpm) and this drives the containment pressure to increaserapidly. This yields an opening of the vent at approximately 1.7 hours.Figure 01 3.2.3.B -1 -Early Venting -Large Primary System LeakMonticello ELAP EvaluationCase: mo flex casel40 -5 --Vent Opened]:.2520-~15 -_ _ _-Jd 5O 0 4 8 12 1620 24TIME, HOURSPage 11 of 85 L-MT-1 5-047Enclosure 2Figure 01 3.2.3.B -2 assumes a 30 gpm primary coolant leak and shows a similarbut shorter time with containment pressure near atmospheric pressure. Still thisshows a vent opening occurring at approximately 4 hours.Figure 0I 3.2.3.B -2- Early Venting -Small Primary System LeakMonticello ELAP EvaluationCase: mo_flex_case504040w25-J10-Jo 0 4 8 12 16 20 2TIME, HOURS24In these figures, venting removes the nitrogen overpressure and steam leaking fromthe primary system; no significant amount of energy is lost from the torus. Thenitrogen loss reduces RCIC NPSH so that its flow is limited. There is not muchdecay heat removed from the containment during this period as shown in Figure01 3.2.3.B -3 below. Opening the vent this early is of marginal use and providessome challenges.Page 12 of 85 L-MT-1 5-047Enclosure 2Figure 01 3.2.3.B -3- Torus Water Temperature with Early VentingCase: mo..flex_casel300z 250.T7..200 _ _boiling intetorus unNo inhia. approximately 7 hours1 00,.z 2 1QsTIEHOR20 24What is clear from figures 01 3.2.3.B -3 and 01 3.2.3.B -4 is that once the torus isheated up to boiling (Case 1 -around 7 to 8 hours) the containment pressure will befairly constant (-30 -38 psia, (15 -23 psig)) for the next day or more.However, when the venting strategy criterion is changed to 10 psig and torustemperature greater than 212&deg;F, the containment pressure remains positive withmargin. The modified MAAP run is shown below in Figure 01 3.2.3.B -4. Note, thiscase was run out to 48 hours instead of 24 hours.Page 13 of 85 L-MT-1 5-047Enclosure 2Figure 0I 3.2.3.B -4- Torus Pressure with Later VentingMonticello ELAP EvaluationCase: mojflex...caselz435w2Oo10~o 0 4 8 12 1620 242832 3640 4448 52TIME, HOURSIn order to address the NRC concern of preventing a negative pressure in thecontainment and admitting oxygen into the containment (a concern if core damageoccurred producing hydrogen in the containment), a venting criterion was added toclose the vent if containment pressure drops below 5 psig.With this venting strategy, operators will need to do minimal cycling of the HPVvalve. Cycling will not be needed until several days after the event when decay heatreduces.Guidance to Prevent Neqative Pressure In ContainmentAs described above, guidance is provided in the containment venting procedure toensure that the HCV is closed before a negative pressure is created in thecontainment.Page 14 of 85 L-MT-1 5-047Enclosure 20I 3.2.4.3.AThe licensee needs to provide a discussion of the effects of loss of power to heattracing.NSPM ResponseHeat tracing will be lost due to the loss of power. Heat traced components thatcould be used in an ELAP, but are not credited in the FLEX strategies, are sectionsof piping in the condensate storage system, diesel fuel oil system, and the fireprotection system.Piping associated with the CSTs is equipped with heat tracing to protect the pipesfrom freezing. The CSTs are insulated and heated with a typical temperature of1000F. The CSTs and associated piping are insulated, which will slow cooling anddelay freezing of the piping. The normal suction supply for both RCIC and HPCI arethe non-seismically qualified CSTs and are the preferred source of makeup water, ifavailable.If the CSTs are available to supply RCIC, the already heated water would be flowingthrough the lines and would not be subject to freezing.Heat tracing is also provided to a diesel fuel oil line and two fire hose stations in theTB Addition. These components are not credited in MNGP's FLEX strategies.0I 3.2.4.5.AThe licensee needs to provide information regarding local access to the protectedareas under ELAP.NSPM ResponseKeys are available to Operations personnel and allow Operators local access tointernal locked areas in the plant (protected areas) during an ELAP.Page 15 of 85 L-MT-1 5-047Enclosure 20I 3.2.4.8.AThe licensee did not provide any information regarding loading/sizing calculations ofportable diesel generator(s) and strategy for electrical isolation for FLEX electricalgenerators from installed plant equipment.NSPM ResponseThe 480 Vac FLEX Diesel Generators (DGs) were sized based on supplying StationBlackout (SBO) loads to battery chargers (D10, D20, D52, D54, D70, and D90). Thechargers provide 125/250 Vdc power to the #11 (125 Vdc Division 1), #12 (125 VdcDivision 2), #13 (250 Vdc Division 1) and #16 (250 Vdc Division 2) batteries.The 480 Vac Flex DGs are isolated from the normal plant battery charger powersupply by safety related (SR) circuit breakers. Each battery charger (D10, D20,D52, D54, D70, and D90) was modified to include a new SR circuit breaker to beused to connect the 480 Vac FLEX DGs. The new SR circuit breakers aremechanically interlocked with the existing incoming circuit breakers, such that onlyone circuit breaker on a battery charger can be closed at any one time, therebyproviding isolation from the normal plant equipment.The Strategic Alliance for FLEX Emergency Response (SAFER) 4160 Vac DGs aresized to be 1MW units, which will operate in parallel, to provide 2 MW. The SAFER4160 Vac DGs are equipped with an integrated distribution panel (with 1200 amperebreaker) which provides isolation from plant equipment.The SAFER 4160 Vac DGs are sized to permit operation of a Residual HeatRemoval (RHR) pump, an RHR Service Water (RH RSW) pump and additional smallloads. NSPM confirmed from the loading calculations for Busses 15 and 16 thatoperation of an RHR pump and a RHRSW pump from either bus could beaccomplished with sufficient margin when these loads are connected to two SAFER4160 Vac DGs.The cable being supplied by SAFER to connect from the 4160 Vac DG to either Bus15 or Bus 16 has been determined to be adequate for supplying the required power.Investigation of the cable used to connect the 480 Vac Portable Generator to thebattery chargers has demonstrated that for a maximum of 365 feet of 4/c #4 AWGwith a full load current at 80% power factor, the voltage drop is 1.68% (less than the2.5% acceptance criteria). Both 4160 Vac and the 480 Vac generators may beadjusted to raise the voltage if either is determined to have a voltage drop issue.Page 16 of 85 L-MT-1 5-047Enclosure 20I 3.2.4.8.BThe licensee needs to provide a description of the instrumentation that will be usedto monitor portable/FLEX electrical power equipment including their associatedmeasurement tolerances/accuracy to ensure that the electrical equipment remainsprotected and that operators are provided with accurate information.NSPM ResponseSite Portable FLEX EquipmentNSPM will rely on the instrumentation on the portable pumps and portable 480 Vacdiesel generators. In addition, NSPM will use flow instrumentation to verify adequatepump flow and instrumentation on the battery chargers to verify adequate chargingof the batteries.The FLEX portable pump engine controls are shown in Figure 0I 3.2.4.8.B -1below:Figure 0I 3.2.4.8.B -1 -Portable FLEX Pump ControlsIII .........................................................40 W$AL.CO DISPLAYKEYPADCIRCUITBREAKERADJUSTMENTKEY SWITCHBecklit LCD displI'.in defaulRPM. voltae).manevrin ttoghmenus and editing8 end 20 amp cclToggle swic to manuallincrease and decreaseSelc Manual orAomer cpe.maMN AUTOUI EIR$/Page 17 of 85 L-MT-1 5-047Enclosure 2The FLEX portable 480 Vac generator controls are shown in Figures 0I 3.2.4.8.B -2and 0I 3.4.8.B -3 below:Figure 0I 3.2.4.8.B -2 -Portable FLEX 480 Vac Generator ControlsAlarm Acknowledge -Press to:Silence HornClear Red or Yellow Alarm if condition has clearedRed or Yellow Alarm steady if condition has NOTclearedosla S, eeAC OverviewPushbutton -Press toVlew GeneratorElectrical ParametersEngine OvervlewPushbutton -Press toView Engine ParametersMain Menu Pushbutton -Press to View Menu ofParametersReset PushbuttonRun Pushbutton (green)Stop Pushbutton (red)Menu navigation arrows:-used to movethrough menus-used to changesetpolntsEscape Pushbutton.- usedto move through menus(Back or Up)Ok (Enter) Pushbutton -used tomove through menus(Forward or Down)Page 18 of 85 L-MT-1 5-047Enclosure 2Figure 0I 3.2.4.8.B -3 -Portable FLEX 480 Vac Generator ControlsBattery ChargeAmmeterFuel Level GaugeFuel Level GaugePushbuttonFuel Prime PushbuttonVoltage AdjustSwItchEngine ECM SwitchMaint. Use OnlySpeed SwitchUP -Idle Speed*. Green light ONF- IReady for Start IStop(Red Pushbutton)I ..Particulate Filter lSAFER EquipmentThe SAFER Response Center will provide 480 Vac and 4160 Vac DGs for additionalcapability and redundancy from off-site equipment until power, water, and coolantinjection systems are restored. The SAFER DGs provide displays that will alertoperators to off-normal conditions. These displays will be monitored during dieselgenerator operation. Specific conditions monitored during SAFER DG operationinclude Racepak and Woodward EasyGen 3000 displays, oil reservoir level, and oiland fuel lines for leakage. The level in the external fuel tank will also be monitored.Page 19 of 85 L-MT-1 5-047Enclosure 2Cl 3.1 .1 .2.AThe licensee is still developing storage locations and associated deploymentpathways for Phase 2 equipment. The availability of the potential need for ac powerto deploy equipment could not be evaluated.NSPM ResponseTwo FLEX storage buildings have been completed. The FLEX storage buildings usemanual roll up doors. The loss of AC power will not adversely impact thedeployment of FLEX equipment. Flashlights, portable lights and portable generatorswill be used to support the deployment of equipment from the storage locations.AC electrical power is not required to deploy equipment. All outside doors and gatesrequired to be opened can be done so manually. Airlock doors (e.g. DOOR-73 andDOOR-78 between the Reactor Building and the Motor Generator (MG) Set Room)have a battery backup that prevents opening both doors simultaneously.Procedures include guidance for defeating airlock battery backups to allowsimultaneous opening of both doors to an airlock to setup portable lighting andportable fans.CI 3.1 .1 .4.AThe licensee's integrated plan did not identify Regional Response Center resources,the off-site staging areas, and delivery methods sufficiently in order to evaluate themeans to obtain the resources from off site.NSPM ResponseMNGP is participating in the industry SAFER Program through a contractualagreement with the Pooled Equipment Inventory Co. (PEICo). PEICo and itssubcontractor AREVA (together called the SAFER Team) will provide engineeringand management services for selecting and procuring emergency responseequipment. The SAFER Team will also provide ongoing monthly management,maintenance, and testing of the National SAFER Response Center (NSRC)equipment.ResourcesThe NSRC (i.e. Regional Response Center) resources include both "Generic" and"Non-Generic" equipment for MNGP. As a member of SAFER, MNGP has access toPage 20 of 85 L-MT-1 5-047Enclosure 2all of the Generic equipment as well as specific Non-Generic equipment asspecified.Generic NSRC current capabilities include:* 4kV Turbine Generators with non-integral fuel tanks* 4kV Distribution Panel* 480 Vac Turbine Generator with non-integral fuel tanks* High Pressure Pump (2000 psi /60 gpm)* Low Pressure -Medium Flow Pump (300 psi / 2500 gpm)* SGIRPV Makeup Pump (500 psi I 500 gpm)* Low Pressure -High Flow Pump (150 psi/I5000 gpm)* Diesel Fuel Transfer (fuel storage, pump and hoses)* Standard Hoses and Connections (suction, discharge, strainers)* Standard Generator Connection Cables* Portable Lighting* SAFER Team Equipment (Communications, Material Handling, and Habitability)* Limited spare partsMNGP is also a participant for selected Non-Generic Equipment from the NSRC.The Non-Generic equipment list for MNGP is:* Water Treatment Systems* Water Treatment Generators* Water Storage* Suction Booster PumpPage 21 of 85 L-MT-1 5-047Enclosure 2Off-site Staqing Area (Stagqingq Area C)The off-site staging area for MNGP is the Xcel Energy Maple Grove Service Center.This Staging Area is located 26 miles direct path from the site; and, therefore, isinside the recommended 35-mile radius for helicopter operation. The facility hasseveral buildings and parking lots that provide multiple options for personnel logisticsand equipment maneuvering. A memorandum of understanding (MOU) with MapleGrove Service Center has been implemented for use of Staging Area C. See Figure4-2 from the SAFER plan below for Staging Area C overview.Figure 4-2: Staging Area "C" (Maple Grove Service Center)Page 22 of 85 L-MT-1 5-047Enclosure 2Delivery MethodsThe SAFER team will deliver equipment to either the Maple Grove Service Center(Staging Area C) or directly to the MNGP site (Staging Area B -shown below)depending on conditions. Primary and Secondary land routes from Staging Area Cto the site have been identified. There is a tiered approach to helicopter availabilityand operations if the site cannot be reached by ground transportation, as describedin the SAFER Capabilities White Paper. See Figure 4-1 below for Staging Area Boverview.Figure 4-1: Staging Area "B" (Onsite)Page 23 of 85 L-MT-1 5-047Enclosure 2If a flooding condition prohibits use of Staging Area B, MNGP procedures include analternate Staging Area B for offloading of SAFER equipment. MNGP proceduresdirect a temporary road to be constructed during external flooding events if the mainplant road is projected to flood. Figure 2 below shows the general location of thetemporary road and the alternate Staging Area B.FIJe2GENERAL LOCATION OF TEPOARY ROAD(Refer to PARTIP, Bul Temporay Access Road to Site)General loation of' a ldomestic well. Botlrds erein the are-,a however withbrush arnd grassbuluover years it may be slightymasked especialy n theand rain.NSRC Alternate Staging Area B(During Flood)I. .IThe equipment delivered by the NSRC will be delivered off Country Hwy 75 (see redarrow above) and equipment will be moved through the temporary access road andonto the site. The MNGP SAFER Response Plan also includes directions to thealternate Staging Area B.Page 24 of 85 L-MT-1 5-047Enclosure 2CI 3.1 .5.3.AThe licensee did not provide measures for operating FLEX equipment at possibleexcessively high temperatures that may exist inside plant structures and buildings.NSPM ResponseNSPM has completed elevated temperature analyses for the ELAP scenario. Theanalyses were performed for the main control room (MCR), battery rooms, RCICroom, the reactor building and in the Emergency Filtration Train (EFT) Building.During Phase 2 supplemental ventilation is provided for the operators in the MCR,Battery Rooms, RCIC ROom, and EFT Building using portable ducting and fans forair circulation as necessary. Portable fans will need to be powered by a portableDG. 250V and 125V battery charger rooms require cooling when the battery chargeris energized. Ventilation is provided by staging portable fans to circulate air throughthe rooms for cooling and to mitigate the potential for hydrogen buildup.Procedures require that within 1 hour the decision is made to declare an ELAP.Ventilation is required for battery and charger operation and for Operator habitability.After 10.5 hours portable FLEX fans will be staged and powered by the 120 Vacgenerators to provide cooling.The analyses conclude that adequate ventilation is available to support operatingFLEX equipment if high temperatures occur inside plant buildings. Therefore, theseanalyses confirm the FLEX strategy documented in the MNGP procedures.Cl 3.2.1.1.AFrom the June position paper, identify and discuss the benchmarks which are reliedupon to demonstrate that MAAP4 is an appropriate code for simulation the of ELAPevent.NSPM ResponseA generic benchmark is provided by Electric Power Research Institute (EPRI) BoilingWater Reactor (BWR) Roadmap "Technical Basis for Establishing SuccessTimelines in Extended Loss of AC Power Scenarios in Boiling Water Reactors UsingMAAP4," (EPRI Product ID 3002002749). The MNGP calculation was performedusing MAAP 4.0.6.Page 25 of 85 L-MT-1 5-047Enclosure 2The benchmark ensures that MAAP4 has sufficient fidelity to perform the mass andenergy balances required for the ELAP calculations. Table Cl 3.2.1.1 .A -1, below,provides the BWR specific calculations that support all of the code calculationsneeded to model the ELAP scenarios.Table Cl 3.2.1 .1.A- ISequence Initiating TyeNumber and Overall SequenceEvent Typeof Benchmark Types of Areet Tm rmEvent ~~~~~Sequences Areet Tm rmPlant event: Oyster 1LF eygo 0mCreek (PE3)1LFWVrgod3miIntegral code comparison 2 LOOPs withGod8mtoGod8riBWR transients TRACG02 (IC3) LO~(including SBOs, Integral code comparison Good agreement 15mn2hLOFW, and turbine to SAFE 4 LOFW with MAAP3B 15mn2htrips) Total with (IC11)-MAAP3BMAAP4" Integral experiment Good agreement3 + 4 minor support comparison to FIST 2 LOFW with MAAP3B 15-50 minTotal with (IE11)-MAAP3BMAAP3B: Good: only a6 minorIntegral code comparison 1 SBO and 3 supporting40hto MELCOR (1&#xa2;10) transients benchmark for 40hLevel 1_____________________applicationsIntegral code comparison 2 LOOPs withGod8mto TRACG02 (IC3) LLOCABWR LLOCAs Integral code comparison 1 LLOCA Good 4 hr(excluding MSLBs) to SR5 and MELCOR (IC5)Total withMAAP4: Good: only a3 + mior sppot Inegrl coe cmparsonminor supportingmnrspotItega od MEcomprison 1 LLOCA benchmark for 40 hrto MECOR (C10)Level 1applicationsBWR MIOCAs and Integral code comparison 1 SLOCA Good agreement 1hSLOCAs None with to SAFE (ICli) -MAAP3B with MAAP3B 1hMAAP4Total with Integral experiment Good agreementMAAP3B: comparison to FIST (IEll) 1 MLOCA with MAAP3B 8 min2 -MAAP3BPage 26 of 85 L-MT-1 5-047Enclosure 2SqecIntaigNumber and Overall SequenceEntType of Benchmark Types ofEetSequences Agreement Time FrameBWR MSLBsNone withMAAP4Total with Integral code comparison 1 MSLB Good agreement 7 minMAAP3B: to SAFE (ICll) -MAAP3B with MAAP3B1Can be considereda subset of LLOCAsBWR interfacingsystem LOCAs No supporting benchmarks, but essentially covered by LLOCA and(discharge outside S/MLOCA benchmarks.of containment)No supporting benchmarks with stuck-open SRVs as an initiator, but similar toBWR stuck- open SLOCAs if discharge is to the gas space (versus to theSRVs suppression pool). Sequences are also supported by benchmarks in which stuck-open or manually opened SRVs are subsequent conditions.BWR Feedwater No supporting benchmarks, but essentially covered by S/MLOCAline breaks benchmarksBWR ATWS No supporting benchmarksCl 3.2.1.1.BConfirm that the collapsed level remains above Top of Active Fuel (TAF) and thatthe cool down rate was within the technical specification limits.NSPM ResponseNSPM completed the MAAP analysis for MNGP. The MAAP analysis confirmed thatthe collapsed level remains above the TAF. The MAAP analysis assumed a 90&deg;Fper hour cool down rate, which is within the TS limit.Page 27 of 85 L-MT-1 5-047Enclosure 2Cl 3.2.1.1.CConfirm that MAAP was used in accordance with Sections 4.1, 4.2, 4.3, 4. 4, and 4.5of the June position paper.NSPM ResponseThe MAAP analysis performed for MNGP was carried out in accordance withSections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper, EPRI TechnicalReport 3002001785, "Use of Modular Accident Analysis Program (MAAP) in Supportof Post-Fukushima Applications."Cl 3.2.1.1.DIdentify and justify the subset of key modeling parameters taken from Tables 4-1through 4-6 of the MAAP4 Applications Guidance (EPRI 1020236). This shouldinclude response at a plant-specific level regarding specific modeling options andparameter choices for key models that would be expected to substantially affect theELAP analysis performed for that licensee's plant. Although some suggested keyphenomena are identified below, other parameters considered important in thesimulation of the ELAP event by the vendor/licensee should also be included.a. Nodalizationb. General two-phase flow modelingc. Modeling of heat transfer and lossesd. Choked flowe. Vent line pressure lossesf. Decay heat (fission products/lactinides /etc.)NSPM ResponseEach of the specific modeling options requested are discussed below:a) Nodalization: The reactor vessel nodalization is fixed by the MAAP code andcannot be altered by the user, with the exception of the detailed corenodalization. The MNGP MAAP 4.0.6 parameter file divides the core region into5 equal volume radial regions and 27 axial regions. The axial nodalizationrepresents 24 equal-sized fueled nodes, 1 unfueled node at the top, and 2unfueled nodes at the bottom. Figure Cl 3.2.1.1.D -1 below, taken from theMAAP User's Manual, illustrates the vessel nodalization scheme.Page 28 of 85 L-MT-1 5-047Enclosure 2Figure Cl 3.2.1.1.D -1 -MAAP MNGP Vessel Nodalization SchemeContainment nodalization is defined by the user. The standard nodalization schemeis used in the MNGP MAAP 4.0.6 parameter file and represents the followingindividual compartments:* Pedestal -Drywell Opening (Nodes 1-2)* Drywell -Vent Line/Downcomer (Nodes 2-3)* VentlDowncomer -Torus (Nodes 3-4)* Drywell Vent; Drywell -Half of 962' Elev. (Nodes 2-13)* Vacuum Breakers -Torus -Vent Header (Nodes 4-3)* Wetwell Vent; Wetwell -Torus Room (Nodes 4-5)* Leakage; Drywell To Half of 962' (Nodes 2-13)* Containment Failure -Vent Pipes To Torus Room (Nodes 3-5)Page 29 of 85 L-MT-1 5-047Enclosure 2Figure CI 3.2.1.1 .D -2 below illustrates the MNGP containment nodalizationalong with an identification of containment flow junctions.Figure CI 3.2.1.1.D -2- MAAP MNGP Containment Nodalization SchemeDrywellVent7*LeakageJvnc~Jo~i D.s~tIp$~1 Pedestal Door2 D~V~i.II ~e~ii~pIpe3 Downcomer4 ~W v~fl/f~I1ur~5 Vacuum BreakersG ~7 Drywell Leakage8 ~ryweI~ ~aiIure-->Shell FailureVIents4-SWetwellVent/failureb) General two-phase flow modeling: General two-phase flow from the reactorvessel is described in the EPRI Technical Basis for ELAP Success Timelinesreport (EPRI Product ID 3002002749). In the case of the scenario outlined in theintegrated plan, flow can exit the RPV via the open safety relief valve(s) (SRV(s))and from the assumed recirculation pump seal leakage. Flow from an SRV willbe single-phase steam, and flow from the recirculating pump seal will be single-phase liquid due to the location of the break low in the RPV with RPV levelcontinued to be maintained above TAF. Upon exiting the RPV, the seal leakagewill flash a portion of the flow to steam based on saturated conditions in thedrywell, creating a steam source and a liquid water source to the drywell. Asdescribed in the EPRI report there are two parameters that can influence the two-phase level on the RPV. Table Cl 3.2.1.1 .D -1 below confirms that theparameter values match the recommended values that are outlined in the EPRIreport.Page 30 of 85 L-MT-1 5-047Enclosure 2Table Cl 3.2.1.1.0 -1Modeling of heat transfer and losses: Modeling of heat transfer and losses fromthe RPV are described in the EPRI Technical Basis for ELAP Success Timelinesreport (EPRI Product ID 3002002749). The parameters that control theseprocesses, as defined in the report, are provided in Tables Cl 3.2.1.1.D -2 andCl 3.2.1 .I.D -3 below with the values selected to represent MNGP.Table Cl 3.2.1.1.D -2Value used in MNGPParameter Name MAAP analysis CommentQC0 -not-thru-insulation heat Plant specific value based on3.55E6 BTU/hr drywell heat removal to coolerstransfer from RPVI during (1.04 MW) during normal operation. Typicalnormal operation. values range between 1-2 MW.FINPLT -number of plates in 80Patseii aureflective insulation ____________________________XTNS- veag rflctve0.335 ft. Plant-specific valueinsulation thicknessAdditional Information relating to MAAP Analysis Parameter Values relating toheat transfer and losses is provided in Table Cl 3.2.1. .ID -3 below.Table CI 3.2.1.1.0 -3Parameter Value inParameter Definition Parameter Name in MIAAP MNGP MAAP AnalysisPower level, MWth QCR0 (BTU/hr) 6.84E9 BTU/hrInitial CST water volume, gal VCSTO (ft3) 35,187 ft3Initial CST water temperature, F HCST (enthalpy) 67.97 BTUInitial suppression pool water mass, Cacltdfoinu4,700IbIbmIniialsupresio pol wte leelftXWRBO(i), where i is node1.2fIniialsupresio pol wte leelftnumber for wetwell1.2fInitial suppression pool water TWRBO(i), where i is node 80temperature, F number for wetwellPage 31 of 85 L-MT-1 5-047Enclosure 2Parameter Value inParameter Definition Parameter Name in MAAP MNGP MAAP AnalysisDrywell free volume, ft3  VOLRB(i), where i is node 114,936.4 ft3number for drywellVOLRB(i) -volume ofWetwell free volume, ft3  suppression pooi water from 176,000 ft3initial pooi mass____ ________Containment vent pressure, psia Ree oScin41o h an24.7 psiareportRCIC max flow rate, gpm WVRCIC 400 gpmMa FEXpup lo rte gmRefer to Section A.1 (Parameter 2200 gpmMax LEXpum flw rtegpmWVHPSW(8))Lowest set SRV flow rate, lb/hr Derived from SRV area, ASRV 83,800 lb/hrLowest set SRV pressure, psia PSETRV 1066.7 psiaRecicultin pup sal eakgegpm Value that was used to define 70gmprupRecicultin pup sal eakgegpmLOCA area, ALOCA70gmerppTotal leakage used in the transient, Value that was used to define16gpgpm LOCA area, ALOCA 165_____gpm __c) Choked flow: Choked flow from the SRV and the recirculation pump seal leakageis discussed in the EPRI Technical Basis for ELAP Success Timelines report(EPRI Product ID 3002002749). The parameters identified that impact the flowcalculation are listed in Table Cl 3.2.1.1 .D -4 below with input values identified.Table CI 3.2.1.1.D -4Value used in MVNGPParameter Name MAAP analysis EPRI recommended valueASRV -effective flow area for relief 0.1105 ft2  Plant-specific valuevalveALOCA -seal leakage area 1.19E-3 ft2  Plant-specific valueFCDBRK -discharge coefficient for0.5.7seal leakage 0.75__________ __0.75_________d) Vent line pressure losses: Vent line pressure loss can be represented in twodifferent approaches. One approach is to input the actual piping flow area alongwith a discharge coefficient (FCDJ). An alternative approach would be tocalculate the effective flow given the estimated piping losses, and input a losscoefficient of 1.0. The MNGP MAAP analysis utilizes the discharge coefficientapproach. The MNGP MAAP analysis flow rate out of the hard pipe vent wascompared to the MNGP HPV flow curve which is displayed in FigureCl 3.2.1 .1.D -3 below. Figure Cl 3.2.1 .1.D -3 was used to develop a functionthat correlates the torus pressure to the vent flow rate using the dischargePage 32 of 85 L-MT-1 5-047Enclosure 2coefficient. The MAAP analysis was reviewed to verify that the flow rate was wellrepresented by this modeling approach.Figure CI 3.2.1.1.D -3 -MNGP Hard Pipe Vent Flow Curve*MONTICELLO WET WELL 'VENT*Mass Flow Rate v. WetwelI Pressire40.0C~ho.cJ<c62&0~1;~- -_ _ ."IL-!0 0 23 .0 5 0 nO l. t1 120TtORUS PRESSURE (PSIA)e) Decay heat (fission products/actinides/etc.): Decay heat representation in MAAPis discussed in the EPRI Technical Basis for ELAP Success Timelines report(EPRI Product ID 3002002749). Input parameters used to compute the decayheat are identified in the report and are listed in the Table CI 3.2.1.1 .D -5 alongwith the values used in the MNGP analysis.Table CI 3.2.1.1 .D -5Value used in MVNGP EPRI recommendedParameter Name MAAP analysis valueFENRCH -normal fuelenihet0.0384 Plant-specific valueEXPO -average exposure 33974.6 Plant-specific valueFCR -total capture rate of U-034Patseii au238 / total absorption rateFFAF -total absorption rate / .7Patseii autotal fission ratePage 33 of 85 L-MT-1 5-047Enclosure 2Value used in MNGP EPRI recommendedParameter Name MAAP analysis valueFO.FR1 -fraction of fissionpower due to U-235 and PU- 0.476 Plant-specific value241FQR2- ratonoffisin0.437 Plant-specific valuepower due to PU-239FQFR3 -fraction of fission 007Patseii aupower due to U-238TIRAD- aergeeffctve33,580 hrs. Plant-specific valueirradiation time for entire coreCl 3.2.1.1.EIdentify the specific MAAP analysis case that was used to validate the timing ofmitigating strategies in the integrated plan and state that it is available on a webportal for NRC staff to view. Alternately, a comparable level of information may beincluded in the response to the question./In either case, the analysis should includea plot of the collapsed vessel level to confirm that TAF is not reached (the elevationof the TAF should be provided) and a plot of the temperature cool down to confirmthat the cool down is within tech spec limits.NSPM ResponseThe MNGP MAAP Analysis modeled several scenarios representative of the OIPand performed a case that is defined as the representative case for the MonticelloELAP strategy. The analysis considers collapsed RPV water levels as indicated byinstrumentation (parameter XWSH) and boiled-up water levels in the core(parameter XWCOR). Figure CI 3.2.1.1.E -1, below illustrates the vessel waterlevel relative to instrument zero (-126") over the scenario duration (24 hours) ELAPcase. Note that neither the collapsed nor boiled-up water level parameters indicatethat fuel was uncovered.Page 34 of 85 L-MT-1 5-047Enclosure 2Figure CI 3.2.1.1.E -1 -MNGP Core Level during ELAP EventCore Water Level HeightComparisonformoflex caselz__150"- 125S100150~-75", -50O~-125CoreWate Lee Hegh -oprsnfrm~xcslI I I I I II I I I I IvII I II I I I I---- XWCOR -Boiled Up CoreWater Level----XWSH -Collapsed WaterLevel in the Shroud*.*..* TAFLJ I........ F .... .........."'" F ..........................0 2 4 6 8 10 12 14 16 18 20 22 24Time (hours)Page 35 of 85 L-MT-1 5-047Enclosure 2Figures Cl 3.2.1.1 .E -2 and CI 3.2.1.1 .E -3 illustrate primary system watertemperature and RPV pressure, respectively, during the RPV cooldown phase forthe ELAP case. These figures indicate that the cooldown rate was maintained<100&deg;F/hr, within the TS limits. Figure Cl 3.2.1.1 .E -2 indicates the RPV coolanttemperature drops from 550&deg;F to 400&deg;F over the period from 0.5 hours to 2.2 hours.This corresponds to approximately a 90&deg;F/hr cooldown rate.Figure CI 3.2.1.1.E -2- MNGP Primary System Water TemperatureDuring ELAP EventPrimary System Average Water Temperaturefor mo~fiex~caselz400S0~Time (hours)Page 36 of 85 L-MT-1 5-047Enclosure 2Figure Cl 3.2.1.1.E -3- MNGP Reactor Vessel Pressure during ELAP EventRPV Pressure for mo..lex_-.as.1lz12001000 _ I&deg;Z200 / A,00 0.5 1 1.5 2 2.5 3 3.5 4Time (hours)Note: Lo-Lo set controls RPV pressure for initial 30 min. or until RPV depressurization (cooldown) isinitiated.Cl 3.2.1.3.CThe licensee did not provide a completed analysis for repowering batteries using theportable FLEX 480 volt ac diesel generator and the associated time constraint forbattery life. Additional analysis is required to confirm timing.NSPM ResponseNSPM has completed DC Load Flow and Cell Sizing analyses for the ELAP scenariowith associated deep load shed. The analyses incorporate battery recharging usingthe portable FLEX 480 Vac DG and the associated time constraint for battery life.Page 37 of 85 L-MT-1 5-047Enclosure 2The shift manager must declare an ELAP event has occurred by procedure within Ihour of the event occurring. Once the declaration is made, load shedding will beperformed on the Division I and D~ivision II station batteries to extend the time stationbatteries can be used to operate equipment and instruments used to provide corecooling. The battery calculations have been performed using the remaining loads todemonstrate that the batteries life was extended to 12 hours.When an ELAP is declared, the DC load shed is completed within 2 hours from theonset of the event. Within 11 hours the batteries are re-powered using the FLEX480 Vac DGs.The analyses conclude that the batteries can support a 12 hour coping duration.Therefore, these analyses confirm the FLEX mitigation strategy as outlined in theplant procedures is acceptable with margin for repowering the batteries at MNGP.CI 3.2.1.3.0The licensee did not provide the basis for SQE Action Item 9 regarding the 8-hourtime the portable diesel driven FLEX pumps will be staged. Additional analysis isrequired to confirm timing.NSPM ResponseThe FLEX portable diesel driven pump can be credited as being staged for usewithin 10.5 hours. This time was chosen as the earliest reasonable time for pumpstaging, as additional staff can be credited as arriving on site at six hours and it isreasonable that debris can be cleared within the following two hours. Staging couldbe completed earlier depending on the amount of debris and the timing of personnelarriving on site. Pump deployment and hose layout have been demonstrated to beaccomplished within two hours in previous time studies.Staging of the FLEX portable pump is not identified as a time constraint as theMNGP strategy relies on RCIC to supply core cooling as long as possible. TheFLEX portable pump does not need to be utilized until RCIC failure. The MAAPanalysis shows that the suppression pool temperature will reach 240&deg;F atapproximately 10.5 hours and the RCIC pump could be stopped at that point as theFLEX portable pump would be available just after hour 10. An NSPM evaluationdetermined that RCIC pump operation would last at least 11.5 hours based onsuppression pool temperature and the ruggedness of the RCIC pump and turbine.Since the MAAP analysis shows that suppression pool temperature peaks atapproximately 250.7&deg;F, it is expected that RCIC will run well past 11.5 hours.Page 38 of 85 L-MT-1 5-047Enclosure 2Also, battery power for RCIC will be available continuously throughout the event.Battery capacity/Load shed calculations show 12 hours of power are available. Theportable diesel generator will be staged and available for use by hour 10.5.Cl 3.2.1.3.EThe licensee provided preliminary times for SOE Action Items 10, 11, and 12regarding ventilation needs for various areas of the plant. Additional analysis isrequired to confirm timing.NSPM ResponseNSPM has completed elevated temperature analyses for the ELAP scenario. Theanalyses were performed on the MCR, battery rooms, RCIC room and the reactorbuilding.During Phase 2 supplemental ventilation is provided for the operators in the MCR,Battery Rooms, RCIC Room, and EFT Building using portable ducting and fans forair circulation as necessary. Portable fans will need to be powered by a portableDG. 250V and 125V battery charger rooms require cooling when the battery chargeris energized. Ventilation is provided by staging portable fans to circulate air throughthe rooms for cooling and to mitigate the potential for hydrogen buildup.Procedures require that within one hour the decision is made to declare an ELAP.After 10.5 hours portable FLEX fans will be staged and powered by the 120 Vacgenerators to provide cooling.The analyses conclude that adequate ventilation is available to support operatingFLEX equipment if high temperatures occur inside plant buildings. Therefore, theseanalyses confirm the FLEX strategy documented in the MNGP procedures.Page 39 of 85 L-MT-1 5-047Enclosure 2Cl 3.2.1.4.AThe licensee did not provide complete updated information regarding FLEX portablepump flow analyses. This will be provided in the licensee's February 2014 statusupdate report.NSPM ResponseOf the possible combinations of portable diesel pump (PDP) suction sources andinjection locations, the longest run of hose will be required to transfer water from thedischarge canal to the RHR/RHRSW cross-tie (located on the 931' east elevation ofthe TB). From the pump discharge, two 5" hoses are routed south between thecooling towers. From there the hoses are routed over the security barricade,through the security fence at the east gate just south of the Plant EngineeringBuilding (PEB)), then west toward the Plant Administration Building (PAB). Othersources can be connected to the Division 1 (or A train) RHR -system, or the 12Cooling Tower Fire connection. If the intake is used as the suction source for thePDP, the 12 Cooling Tower Fire system connection is not used as an injectionlocation.At the hose run closest to the Reactor Building railroad doors, a splitter is attachedto each hose. The splitter has a 5" inlet, a 5" outlet, and at least one 21/2" outlet. The5"' outlet is used to continue to route the 5" hose on the east end of the PAB, aroundthe Compressed Air Building, and into the TB through the north door of the 13.8 kVroom.Near the entrance to the TB, the two 5'" hoses are connected to the double end of aY-fitting. The single 5" hose from the Outlet of the Y-fitting is then connected to aflow meter. The outlet of the flow meter is connected to a single 5" hose, which isthen connected to the RHR/RHRSW cross-tie through RHRSW-68. See Cl3.2.1.8.B for further information on this connection point.Adding water to the SFP can be accomplished via several means:1. Via hoses to the SFP:a. Pump through 5" hoses, to RHRSW-68, to RHRSW-46, through FireProtection piping, through 1W" hoses on the refuel floor, orb. Each of the two 21/2" outlets from the above mentioned splitters are usedto route 21/2" fire hoses through the reactor building railroad doors, up to1027' elevation of the reactor building.2. Via RHR:a. Pump through 5" hoses, to RHRSW-68, to RHRSW-14, to PC-18 to thespent fuel pool (SFP).Page 40 of 85 L-MT-1 5-047Enclosure 2Three hydraulic calculations have been performed to determine the acceptability ofthis hose deployment strategy:*The first calculation evaluated the use of the PDPs to provide flow to the SFPspray taking flow from the discharge canal. A number of different hose routesand spray configurations are presented. This calculation evaluated the flowpaths determined to require the highest pump discharge head and providesoptions for hose configurations which could reduce the required head to providemargin for pump operation, if required. The calculation determined that theportable pumps can provide sufficient flow and pressure for the spray at the SFPhandrail, SFP deck, and Reactor Building roof level from any of the three pumplocations.*The second calculation confirmed that a minimum of 300 gpm of cooling waterfrom the Mississippi River or discharge canal can be delivered to the RPV,through the Low Pressure Coolant Injection (LPCI) A loop, using a combinationof existing piping systems and interconnecting hoses in conjunction with aportable pump. The analysis is performed assuming an RPV pressure of100 psig and injection through the A LPCI flow path. The calculation assumesthe RPV water level is at the bottom of the main steam line (998'-3"). A summarytable of pump flow and pump head, at their operating point, for each pumpconfiguration is contained in the calculation. The calculation concluded that useof a portable diesel pump in any of the four hose configurations for waterinjection allows for an injection rate of over 300 gpm.*The final calculation confirmed that a minimum of 300 gpm of makeup water canbe delivered to the RPV simultaneously with makeup water (200 gpm) or spraywater (250 gpm) supplied to the SFP. Flow paths to both the RPV and SEP arethrough a combination of existing piping systems RHR, RHRSW, Fuel PoolCooling (FPC), and Fire Protection (FP) and interconnecting hoses in conjunctionwith a PDP.Page 41 of 85 L-MT-1 5-047Enclosure 2Cl 3.2.1.4.BThe licensee needs to provide further technical basis or a supporting analysis for theportable/Flex diesel generator capabilities considering the capacity of the equipment.A summary of the sizing calculation for the FLEX 480 V diesel generators to showthat they can supply the loads assumed in phases 2 is also needed.NSPM ResponseAn Engineering Evaluation was prepared to size the 480 Vac portable dieselgenerators. This evaluation was based on the FLEX Strategies for the ELAP event.MNGP uses the 480 Vac portable generator to supply power to six battery chargersto support the use of the DC control power for greater than 24 hours.MNGP is using a Caterpillar XQ200 portable diesel generator with a prime rating of182 kW. The engineering evaluation determined that a generator with a continuousrating in the range of 175 kW and 200 kW is recommended. Therefore, the MNGPportable diesel generator is sized appropriately for MNGP's mitigating strategy.CI 3.2.1.6.AThe licensee specified that the 24-hour time constraint for supplying alternatenitrogen is preliminary but provided no technical basis or analysis to support the24-hour requirement to supply alternate nitrogen. The licensee will provide updatedinformation in a six-month status report in February 2014.NSPM ResponseA calculation was performed which determined that the currently installed capacity ofthe Alternate Nitrogen system (four bottles) could adequately supply the systemneeds for up to 9.4 hours. A 24 hour supply would require an installed capacity ofsix bottles.This condition is acceptable as additional nitrogen bottles are staged in the Make-upDemineralizer Area, and compressed gas storage building. These bottles may beused to replace the bottles depleted by routine system usage. There are eightnitrogen bottles staged in the Make-up Demineralizer Area (931' TB NE). Fourbottles are staged to allow replacement of a bottle bank within four hours.Therefore, during an ELAP event, a greater than 24 hour supply of nitrogen wouldbe available in the TB to supply the Alternate Nitrogen system.Page 42 of 85 L-MT-1 5-047Enclosure 2In addition to the nitrogen stored in the TB, nitrogen bottles dedicated for use only inthe Alternate Nitrogen System, are available in the plant warehouse. 17 nitrogenbottles per train, for a total supply of 34 bottles are required by procedure to bestaged in the warehouse.Procedural guidance is provided to operators to monitor alternate nitrogen systembottle pressure every six hours and to replace bottles as necessary.Information in this response is subject to change when Order EA-13-109 isimplemented. Order EA-1 3-1 09 will likely change the quantities of nitrogen used inan ELAP event.CI 3.2.1.8.AThe licensee did not provide a discussion regarding the methodology used to assureadequate NPSH for the RCIC pump and justify that it is adequate in light of thepotential for limited margins and potentially significant transient phenomena.Additional information will be provided in a six-month update.NSPM ResponseNPSH has been evaluated for the RCIC pump. The evaluation did not assume anynitrogen gas was present in the suppression chamber atmosphere. The evaluationassumed saturated conditions in the suppression pool. With a suppression poollevel greater than 11 feet and RCIC flow less than 300 gpm, the evaluationconcluded that there is NPSH margin. The evaluation assumed that the suppressionpool liquid was a uniform temperature. This assumption is conservative because ofwater stagnation. With water stagnation, hotter water is on the surface; andtherefore, cooler water at the suppression pool ring header would be drawn into theRCIC pump suction.Page 43 of 85 L-MT-1 5-047Enclosure 2Cl 3.2.1.8.BThe integrated plan provides no details regarding; actual connection points, (e.g.,system valve numbers and actual location in plant piping) the length of hose runsand associated connecting fittings required to connect the portable pump at theprimar'y and alternate locations, and no details regarding portable pump capabilitiesto correlate with actual flow and pressure requirements. It is not possible todetermine based on the limited information that the strategies for phase 2 corecooling are viable.NSPM ResponseNSPM installed a new connection point to the RHRSW piping in the TB. The newconnection piping consists of a new valve (RHRSW-68) and a fire hose connection(see Figure Cl 3.2.1 .8.B -1 below). This is the primary location for connecting thedischarge of the portable diesel pump to allow injecting into the RPV.Figure Cl 3.2.1.8.B -1 -MNGP Primary PDP RPV Injection PointPage 44 of 85 L-MT-1 5-047Enclosure 2With the discharge from the PDP connected to RHRSW-68, water can be injectedinto the RPV by opening RHRSW-14 (Emergency Injection via A RHRSW Loop).RPV water level can be controlled by throttling RHRSW-14 as necessary.FLEX procedures provide instructions for connecting hoses from the portable dieselpump to RHRSW-68 and instructions for controlling RPV water level.The alternate portable diesel pump injection location is into the Division I RHRsystem through RHR-47, which is located in the Division I RHR room. See FigureCl 3.2.1.8.B -2 below.Figure CI 3.2.1.8.B -2- MNGP Primary PDP RPV Injection PointFLEX procedures provide instructions for connecting hoses from the PDP to RHR-47and instructions for controlling RPV water level.See the response to CI 3.2.1 .4.A for a summary of the calculations and analysesverifying the acceptability of the hose runs and associated connecting fittingsrequired to connect the portable pump at the primary and alternate locations. Inaddition, the response to CI 3.2.1.4.A provides details regarding portable pumpcapabilities to correlate with actual flow and pressure requirements.Page 45 of 85 L-MT-1 5-047Enclosure 2Cl 3.2.1.8.CThe licensee will provide additional information regarding final design andimplementation plans for use of impure water for core makeup.NSPM ResponseThe normal suction supply for RCIC and HPCI pumps are the two CSTs, which arenon-seismic, and the suppression pool. Since the CSTs may not be available for allscenarios, the credited makeup water source for the FLEX portable pumps is fromthe discharge canal, where river water is processed through the traveling screensprior to the loss of power. The hoses taking suction from the discharge canal willhave strainers with 3/8" holes to prevent large debris from entering the pump. TheMississippi River, at the intake structure, serves as a backup source of water to thedischarge canal.NSPM participated in the development of BWROG-TP-14-006, Revision 0, whichwas issued in March 2014. This document concludes BWR fuel is adequatelycooled when the inside shroud is flooded, thus allowing raw water to enter the fuelthrough the top of the fuel channel. The inside shroud is maintained flooded byeither injecting raw water inside the shroud or by maintaining the water level abovethe steam separator return elevation if injecting into the downcomer.During an ELAP condition, NSPM will inject raw water into the MNGP RPV usingLPCI injection piping, which injects into outer shroud region. Under this condition,RPV water level must be maintained above the steam separator return elevation(approximately +47.25 inches).By procedure RPV water level is controlled in a band from +55 inches to +100inches when injecting raw water into the RPV. This maintains water level above thesteam separator return elevation and below the main steam lines.Page 46 of 85 L-MT-1 5-047Enclosure 2Cl 3.2.1.8.0The licensee provided insufficient in formation to support a conclusion that theswitchover from CST to the torus function will be accomplished in a timely mannerso that RCIC injection to RPV will commence without delay and remainuninterrupted. Additional information to be provided in a six-month update.NSPM ResponseWhen the CST level drops to 2'-8", the RCIC torus suction valves (MO-2100 andMO-2101) will automatically open. Limit switches on these valves will cause theCST suction valve (MO-2102) to automatically close when both torus suction valvesare full open. These actions automatically transfer RClC suction from the CST tothe torus.MO-2100, MO-2101, and MO-2102 are DC powered valves that will be capable ofchanging state following an ELAP event.Cl 3.2.2.AThe licensee will provide additional information regarding providing alternatemakeup via RHR spent fuel cooling piping, e.g., the routing of hoses from the FLEXportable pump, location where the portable pump is connected to the RHR system,FLEX pump flow and pressure requirements using this flow path in a six-monthupdate.NSPM ResponseSee response to Cl 3.2.1 .4.A for details concerning use of the PDP to supply waterto the SFP via the RHR system or using hoses to the FP system or using hosesdirectly into the SFP. These flow path combinations have been evaluated anddetermined to meet flow and pressure requirements.Page 47 of 85 L-MT-1 5-047Enclosure 2Cl 3.2.2.BThe licensee did not provide complete information regarding the FLEX portablepump for the strategy for maintaining SFP level including routing of hoses, availableflow rates and flow rates required to the .SFP.NSPM ResponseCl 3.2.1 .4.A describes the hose deployment strategy for moving water into the SFP.Calculations to support the strategy demonstrated that adequate flow and pressurewould be available to supply sufficient water to the SFP. See Cl 3.2.1 .4.A for theresponse.Cl 3.2.4.1.AThe licensee did not provide additional formal analysis to determine the timing andscope of the supplemental cooling water, or systems and components need tosupport ELAP strategies. The results of this analysis will be provided in a six-monthstatus report.NSPM ResponseSupplemental Cooling water is not required for any FLEX Phase 1 components.Supplemental Cooling (in the form of opening doors and deploying fans) is requiredfor the RCIC room in Phase 1.Cl 3.2.4.2.A provides a response regarding the timing and scope of ventilationrequired to support the FLEX Phase 2 components.Page 48 of 85 L-MT-1 5-047Enclosure 2Cl 3.2.4.2.AThe licensee did not perform calculations or supporting analysis regarding theeffects of loss of ventilation in the RCIC room (that NEI 12-06 states may beaddressed by plant-specific thermal hydraulic calculations) nor other areas of theplant (main con trol room (MCR) and battery room) when normal ventilation will notbe available during the ELAP. This should include formal analysis for supplementalcooling of the RCIC room and battery room using portable fans, opening doors, andthe timing and scope of such actions.NSPM ResponseNSPM has completed elevated temperature analyses for the ELAP scenario. Theanalyses were performed on the MCR, battery charger rooms, RCIC pump room andthe entire Reactor Building.During Phase 2 of the ELAP event supplemental ventilation is provided for theoperators in the MCR, Battery Rooms, RCIC Room, and EFT Building using portableducting and fans for air circulation as necessary. Portable fans will need to bepowered by a portable diesel generator. Division I 250V battery room requirescooling as the battery charger is energized. Portable fans, as required, are placedoutside the PAB doors with ducting to rooms to circulate air through the rooms forcooling and to mitigate hydrogen buildup.Procedures require that within one hour the decision is made to declare an ELAP.After 10.5 hours portable FLEX fans will be staged and powered by the 120 Vacgenerators to provide cooling.The analyses conclude that adequate ventilation is available to support operatingFLEX equipment if high temperatures occur inside plant buildings. Therefore, theseanalyses confirm the FLEX strategy documented in the MNGP procedures.Page 49 of 85 L-MT-1 5-047Enclosure 2CI 3.2.4.2.BThe licensee needs to provide information to confirm that the habitability limits of theMCR will be maintained in all Phases of an ELAP considering MIL-STD-1472C,which is incorporated by reference in NEI 12-06 via NUMARC 87-00 and specifiesthat 1 10&deg;F is tolerable for light work for a 4 -hour period while dressed in conventionalclothing with a relative humidity of -30%.NSPM ResponseNSPM has not used MIL-STD-1472C in the determination of the MNGP MCRtemperature. In section 2.2.1, of the Supplemental Safety Evaluation -MonticelloNuclear Generating Plant Station Blackout Rule (10CFR50.63) (TAG M68569), theNRC states that the expected calculated peak temperature for the SBO event wouldbe below the temperature limit of 120&deg;F. Therefore, 120&deg;F remains the MNGPtemperature limit for the MCR.NSPM performed a calculation that determined the peak area temperature in oneMCR sub-volume for SBO at 120.4&deg;F. The significance of this temperature wasconsidered negligible since the initial MCR temperature used was 80&deg;F rather thanthe normal MCR temperature of 78&deg;F. If 78&deg;F would have been used all MCR sub-volumes would have remained below 120&deg;F. The ELAP maximum peak temperaturefor the same sub-volume space was calculated at 120.2&deg;F. The calculationconcludes that in both the SBO and the ELAP events the average maximumtemperature of 120&deg;F is not exceeded. The calculation does not open any doors normakes use of any forced ventilation.In addition, procedural guidance exists which would prop open the MCR door anduse portable fans to add ventilation into the MCR.Cl 3.2.4.4.AThe licensee needs to provide a discussion that includes a rationale for eliminatingpower to 125 volt dc emergency lighting. This action is inconsistent with othersections of the licensee's response regarding emergency lighting.NSPM ResponseThe DC emergency lighting powered from SR batteries will be load shed early in theevent to preserve batteries for other uses. Local battery powered emergencylighting (wall mounted units) will supply lighting for at least eight hours. These wallPage 50 of 85 L-MT-1 5-047Enclosure 2mounted units overlap the DC emergency lighting in the areas required to beaccessed.DC emergency lighting will be restored following:1) re-powering battery chargers from 480 Vac portable diesel generator, and2) restoration of DC loads.If there is a lighting gap between the lighting supplied by the local battery poweredemergency lighting (wall mounted units) and DC emergency lighting powered fromSR batteries, and flashlights will be used to facilitate safe movement in the plant.Therefore, DC emergency lighting is not needed.The GIP stated that the DC emergency lighting system was going to be modified touse light emitting diode (LED) bulbs. Based on the above information, themodification was determined not to be necessary.Cl 3.2.4.4.BReview of the licensee communications enhancements for confirmation thatupgrades to the site's communications systems have been completed if necessary.NSPM ResponseThe site's communication system upgrade has been completed. The upgradeinstalled the following equipment:* 24 new satellite phones and docking stations* 24 new satellite phone external antennas* coaxial cabling between the new external antennas and the satellite phonedocking stations* 24 new analog phones for each docking station* dedicated phone circuits between the 24 new analog phones and the satellitephone docking stations* three uninterruptible power supplies (UPS) that provide backup power for satellitephone systems in the PAB, PEB and Monticello Training Center (MTC)*integrated the 24 satellite phones into the MNGP phone system.Page 51 of 85 L-MT-1 5-047Enclosure 2Cl 3.2.4.9.AThe licensee did not address actions to maintain the quality of fuel stored in thetanks of the portable equipment for potentially long periods of time when theequipment (diesel driven pumps and generators) will not be operated.NSPM ResponseThe PDPs (P-506 & P-507) have established preventative maintenance plans whichchange out the fuel stored in the pumps once per year.The 200 kw 480 Vac portable DGs (G-506 & G-507) have established preventativemaintenance plans which change out the fuel stored in the portable DGs once peryear.The 12 kw FLEX portable DGs (0-101 & G-102) have established preventativemaintenance plans which change out the fuel stored in the portable DGs once peryear.The PM program for each component also includes additional PM activities alongwith a quarterly operation of each component.Cl 3.2.4.10.AThe licensee provided various examples of loads to be shed, and loads to remainpowered from both divisions of the 125V DC and 250V DC buses, and stated thatthe station batteries do not require portable supplemental charging before eight (8)hours. The licensee needs to provide a completed load shed analysis.NSPM ResponseNSPM has completed DC Load Flow and Cell Sizing analyses for the ELAP scenariowith associated deep load shed. The analyses incorporate battery recharging usingthe portable FLEX 480 Vac DG and the associated time constraint for battery life.The operator must declare an ELAP event has occurred by procedure within onehour of the event occurring. Once the declaration is made, load shedding will beperformed on the Division I and Division II station batteries to extend the time stationbatteries can be used to operate equipment and instruments used to provide corecooling. The battery calculations have been performed using the remaining loads todemonstrate that the batteries life was extended to 12 hours.Page 52 of 85 L-MT-1 5-047Enclosure 2When an ELAP is declared, then within two hours from the onset of the event the DCload shed is completed. Within 11 hours the batteries are re-powered using theFLEX 480 Vac Diesel Generators.The analyses conclude that the batteries can support a 12 hour coping duration.Therefore, these analyses confirm the FLEX mitigation strategy as outlined in theplant procedures is acceptable with margin for repowering the batteries at MNGP.Cl 3.3.2.AThe licensee needs to provide a description of the configuration control program itwill implement that includes a program document that will contain; a historical recordof previous strategies and the basis for changes, and a change control process toallow changes to the strategies only if they continue to meet the guidelines of NEI12-06.NSPM ResponseThe MNGP FLEX program configuration control requirements are contained withinthe MNGP FLEX program document and NSPM FLEX procedures. Below is adescription of those configuration control requirements.FLEX Program Document:The Diverse and Flexible Coping Strategies (FLEX) Program Document contains thefollowing requirements as required by NEI 12-06:* Maintains the FLEX strategies and associated basis.* Contains a historical record of previous strategies and the basis for changes.* Contains the basis for the ongoing maintenance and testing programs chosen forthe FLEX equipment.NSPM FLEX ProceduresNSPM FLEX procedures provide instructions for the tracking, preparation, andapproval of changes to the FLEX strategies in response to order EA-12-049.Changes to the FLEX strategies can be made without NRC approval provided:1. The revised FLEX strategy meets the requirements of NEI 12-06, and2. An engineering basis is documented that ensures that the change in FLEXstrategy continues to ensure the key safety functions (core and SFP cooling,containment integrity) are met.Page 53 of 85 L-MT-1 5-047Enclosure 2Any changes to FLEX Strategies are evaluated and documented.Modifications that Potentially Affect FLEX StrateqiiesPlant modifications are assessed for any impact on the FLEX mitigating strategies.The Design Input Checklist is the vehicle by which potential impacts are identified. Ifa potential change is identified, then the change will be evaluated per NSPM FLEXprocedures.CI 3.4.AThe licensee needs to provide additional information regarding the minimumcapabilities for offsite resources for which each licensee should establish availabilityas noted in considerations 2 through 10 of NEI 12-06, Section 12.2 lists the followingminimum capabilities.NSPM ResponseNEI 12-06, Revision 0, Section 12.2, "Minimum Capabilities of Off-Site Resources"states that:"Each site will establish a means to ensure the necessary resources will beavailable from off-site. Considerations that should be included in establishingthis capability include:2. Off-site equipment procurement, maintenance, testing, calibration,storage, and control.3. A provision to inspect and audit the contractual agreements toreasonably assure the capabilities to deploy the FLEX strategiesincluding unannounced random inspections by the Nuclear RegulatoryCommission.4. Provisions to ensure that no single external event will preclude thecapability to supply the needed resources to the plant site.5. Provisions to ensure that the off-site capability can be maintained for thelife of the plant.6. Provisions to revise the required supplied equipment due to changes inthe FLEX strategies or plant equipment or equipment obsolescence.7. The appropriate standard mechanical and electrical connections need tobe specified.8. Provisions to ensure that the periodic maintenance, periodicmaintenance schedule, testing, and calibration of off-site equipment arecomparable/consistent with that of similar on-site FLEX equipment.Page 54 of 85 L-MT-1 5-047Enclosure 29. Provisions to ensure that equipment determined to be unavailable/non-opera tional during maintenance or testing is either restored tooperational status or replaced with appropriate alternative equipmentwithin 90 days.10. Provision to ensure that reasonable supplies of spare parts for the off-site equipment are readily available if needed. The intent of thisprovision is to reduce the likelihood of extended equipment maintenance(requiring in excess of 90 days for returning the equipment to operationalstatus)."MNGP is participating in the industry Strategic Alliance for FLEX EmergencyResponse (SAFER) Program through a contractual agreement with the PooledEquipment Inventory Co. (PEICo). PEICo and its subcontractor AREVA (togethercalled the SAFER Team) will provide engineering and management services forselecting and procuring emergency response equipment. The SAFER Team alsoprovides ongoing monthly management, maintenance, and testing of the NationalSAFER Response Center (NSRC) equipment.There are two, redundant NSRCs established with five sets of generic equipmentstored in Memphis and Phoenix. There are also diverse delivery methods fortransporting this equipment to the site:* Air and ground transport to Staging Area C (Maple Grove Service Center -greater than 25 miles direct path from MNGP) from NSRC* Delivery to Staging Area B (on site staging area adjacent to Receiving Facility)from Staging C or directly from NSRC* Air or ground transport to Staging Area BThe SAFER capabilities are described in the White Paper -National SAFERResponse Centers document dated September 11, 2014. The white paper includesa table that identifies that the SAFER team meets the specific requirements of NEI12-06, Section 12.2.By letter Dated September 26, 2014 from NRC to NEI the NRC staff concluded that:"SAFER has procured equipment, implemented appropriate processes tomaintain the equipment, and developed plans to deliver the equipment needed tosupport site responses to BDBEEs, consistent with.NEI 12-06 guidance ....Therefore, the NRC staff concludes that ... licensees can reference the SAFERprogram and implement their SAFER Response Plans for plant-specificcompliance with the final phase requirements of Order EA-12-049. "Regarding guideline 5, a MOU with Maple Grove Service Center has beenimplemented for use of Staging Area C. Communication with State and CountyPage 55 of 85 L-MT-1 5-047Enclosure 2officials is covered by plant procedures that will be in place (or equivalent) for the lifeof the plant.Regarding guideline 7, mechanical and electrical connections for off-site equipmentare specified and controlled by AREVA document 51-9199717, "Regional ResponseCenter Equipment Technical Requirements."Based on the above, NSPM has determined that NEI12.06 Revision 0 Section 12.2considerations 2 through 10 have been adequately addressed.AQ 2NEl 12-06, Section 5.3.3, "Procedural Interfaces," Consideration 1 specifies criteriafor compiling a reference source for plant operators for obtaining necessaryinstrument readings to support the implementation of the coping strategies in theevent a beyond-design-basis seismic event affects seismically qualified electricalequipment.In its Overall Integrated plan (QIP), NSPM identified that it is possible to determinelocal readings for containment temperature using a portable handheld device. TheQIP did not provide the detail needed to determine whether a reference sourcecurrently exists for obtaining containment temperatures or other key reactorparameter local instrument readings (e.g., at control room panels or containmentpenetrations) in this same manner (handheld device) or some other method to bedeveloped.Provide a discussion regarding the ability to read key instrumentation locally in theevent Main Con trol Room and non-Main Contfrol Room instrumentation is notavailable.NSPM ResponseIn the event of loss of all AC or DC power (including an ELAP event) proceduralguidance is provided which directs personnel to obtain information regarding thefollowing parameters:* Reactor Water Level* Reactor Pressure* SRV Tailpipe Differential Pressure* Drywell Pressure* Suppression PoolIWater LevelPage 56 of 85 L-MT-1 5-047Enclosure 2* Drywell Temperature* Suppression Chamber Temperature* Reactor Metal TemperaturesWith this guidance, operators can use hand held meters to take measurements ofthe installed instruments locally in the plant or in the CR as directed. Each specificinstrument has detailed instructions of the necessary steps to measure theparameter and translate the instrument reading into the specified parameter, i.e.level, pressure, and temperature.Operators can also use local indicators to read parameters directly, if available.AQ 5NEI 12-06, Section 6.2.3.1, "Protection of FLEX Equipment," Option 1.c. permitsstorage of FLEX equipment below flood level if time is available and plantprocedures/guidance address the needed actions to relocate the equipment.Section 3.2.1.7, "Event Response Actions," Principle 6 discusses that strategies thathave a time constraint should be identified with a basis the time can reasonably bemet.NSPM is proposing to store the FLEX equipment at a location in buildings that arenot designed to withstand an external flood because the flood hazard has amplewarning time to allow deployment of FLEX equipment. NSPM noted that theplanned new storage building will be located at an elevation that prevents a floodfrom impacting access to FLEX equipment during the early stages of the flood.NSPM did not provide the actual elevations for the new storage location relative tothe maximum flood level, nor discussion regarding the time needed to move theequipment before either of the two storage buildings were flooded (except to say inthe early stages of the flood).Provide a discussion of the timing required for relocation of the FLEX equipment inorder to provide a basis to show that time constraints can reasonably be met.NSPM ResponseAmerican Engineering Testing, Inc. (AET) was contracted to perform subsurfaceexploration for the siting of the FLEX storage building. Included in their report is anelevation map of the FLEX building. This map shows the elevation around the FLEXbuilding to be approximately 919 feet mean sea level (MSL).Page 57 of 85 L-MT-1 5-047Enclosure 2The map also shows the elevation of a proposed building site near Warehouse 6that ultimately was not constructed. This map shows the elevation of the road nearWarehouse 6 to be at approximately 932 feet MSL. A portion of Warehouse 6 isbeing used as the second location for storing FLEX equipment.Based on projections for the Probable Maximum Flood, river height will reach 915.5feet MSL at the end of day 4 and will reach 931.0 feet MSL at the end of day 7.By procedural guidance, FLEX equipment stored in the FLEX building will be movedinside the berm if the projected river crest exceeds 919.0 feet MSL. FLEXequipment stored in Warehouse 6 will be moved inside the berm if the projectedriver crest exceeds 930.0 feet MSL. If the projected river crest exceeds 930.0 feetMSL, a portable diesel pump is staged to draw water from the CST to inject into theRPV and SFP.AQ 9NEI 12-06, Section 8.3.2, "Deployment of FLEX Equipment," Consideration 2discusses that provisions should be made for snow/ice removal to obtain andtransport FLEX equipment from storage to its deployment location.In its OIP, NSPM identified that the administrative program for deployment of thestrategies will include elements to ensure pathways are clear or require actions toclear pathways, but did not provide the detail needed regarding the program andcapabilities.Provide a discussion regarding the snow/ice removal program and relatedcapabilities.NSPM ResponseThe MNGP facilities group is responsible for the snow removal around the MNGP.Snow removal is performed with the front end loader stored in the FLEX storagebuilding. The snow removal is performed by a contracting company in conjunctionwith MNGP mechanical maintenance personnel. The mechanical maintenancepersonnel operate both the front end loader and the forklift to remove debris during aFLEX event.A MNGP procedure establishes the requirements and duties for snow removal andmaintaining accessibility in support of FLEX strategies deployment. In the event ofsnow accumulation of equal or greater than 6 inch depth, the procedure provides thePage 58 of 85 L-MT-1 5-047Enclosure 2following guidance for clearing snow from areas to support deployment of FLEXstrategies:* All Entrances and Exits to Warehouse 6* All Entrances and Exits to FLEX Equipment Storage Building* Area Adjacent to the Discharge CanalThis area is to be cleared to support deployment of equipment near the concretevehicle barrier wall, adjacent to the northeast corner of the Protected Area fence(area cleared is to be a minimum of 20 foot wide to provide a sufficient pathway forvehicles and FLEX equipment).* Alternate Protected Area Access PortThis area, on east of the protected area fence line near trash compactors, is to becleared to include the area between the inner and outer fences.* All cleared areas are to have adequate ice melt applied on a periodic basis tomaintain the pathways safe for travel to support the FLEX Strategy.* Clear paths approximately 12 feet wide (or as needed) to support FLEX PortableDiesel Pump Deployment Paths and Staging Areas.* Manhole cover by IntakePage 59 of 85 L-MT-1 5-047Enclosure 2AQ 23The integrated plan on pages 33 and 34 notes that the battery load shed analysis ispreliminary and provides a high level summary of potential loads that can be shedand loads that will remain for the 125V and 250V DC batteries. It also notes thatadditional analysis will be accomplished and if the analysis results require a changein strategy this will be communicated in a six-month status update. Identify the six-month status report in which this information is to be provided. When accomplishingthis further analysis, include a discussion of the following issues in the appropriatesix month status update:With regard to the load shedding of the dc bus in order to conserve battery capacity:a. Provide the dc load profile for the mitigation strategies to maintain corecooling, containment, and spent fuel pool cooling during all modes ofoperation. In your response, describe any load shedding that is assumed tooccur and the actions necessary to complete each load shed. Also provide adetailed discussion on the loads that will be shed from the dc bus, theequipment location (or location where the required action needs to be taken),and the required operator actions necessary and the time to complete eachaction. In your response, explain which functions are lost as a result ofshedding each load and discuss any impact on defense-in-depth strategiesand redundancy.b. Identify any plant components that will change state if vital ac or dc power islost or de-energized during the load shed. The NRC is particularly interestedin whether a safety hazard is introduced, such as de-energizing the do-powered seal oil pump for the main generator and allowing hydrogen toescape, which could contribute to risk of fire or explosion in the vicinity fromthe uncooled main turbine bearings.c. Identify dc breakers that must be opened as a part of the load shed evolution.d. Identify whether the dc breakers that must be opened will be physicallyidentified by special markings to assist operators in manipulating the correctbreakers.NSPM ResponseA response to each of the four elements of the NRC question is provided below.a) The load profile for the mitigating strategies to maintain core cooling,containment, and SFP cooling for the ELAP condition are in the cell sizing/loadprofiles from the calculations. The load shedding required is directed byprocedure. The loads are located in the Division I -125 Vdc Battery Room,Division 1 -250 Vdc Battery Room, Division 2 -125 Vdc Battery Room, whichare in the PAB Basement, and Division 2 -DI100, which is the first floor EFTPage 60 of 85 L-MT-1 5-047Enclosure 2Building. Inverter Y20 is located on the 2nd floor of the EFT Building andinverters Y80 and Y84 are located on the 3rd floor of the EFT Building.b) Plant procedures direct that 87 circuit breakers and fused disconnects areopened as part of the MNGP's deep load shed strategy; with these actions,hundreds of individual components are de-energized. NSPM assessed anddocumented the impact of the load shed concluded the credited systems areavailable and will operate acceptably following the deep DC Load Shed.c) The DC Breakers to be opened as part of the mitigating strategy are controlledvia a site procedure. The procedure directs that 87 circuit breakers and fuseddisconnect switches be opened as part of the load shed strategy.d) The individual circuits to be shed have been labeled with reflective labels foroperations to identify as FLEX support equipment.AQ 24NEl 12-06, Section 3.2.1, "General Criteria and Baseline Assumptions" discussesthe criteria and assumptions to be used in establishing the baseline copingcapability.On pages 33-34 of the OIP, NSPM states that "with this deep load sheddingstrategy, it is expected that the station batteries can be extended through Phase Iand do not require portable supplemental charging before eight hours for the mostlimiting battery. Additional formal analysis will be performed to support this. Ifanalysis results require a change in strategy, that change will be communicated in asix-month status report. This approach will reduce critical instrument diversity asonly Division II of essential ins trumentation will remain powered after load shedding."Identify the six-month OIP update for NSPM set to provide the formal load shed andbattery life extension analysis mentioned above and any resulting changes instrategy.NSPM ResponseSee response to AQ 23 for the load shed analysis. See Cl 3.2.4.10.A for the lengthof time instrumentation will remain powered after load shedding.Page 61 of 85 L-MT-1 5-047Enclosure 2AQ 27NEI 12-06 Section 3.2.1.7, principle 6, specifies that strategies that have a timeconstraint to be successful should be identified and a basis provided that the timecan reasonably be met. No technical basis or supporting analysis is provided for (1)why Action Item 5 (depressurization of the RCS to 100 psig) has no time constraint,(2) why depressurization is required prior to venting the Torus, (3) the rate ofdepressurization that would be implemented, or (4) that the resulting pressure ortemperature conditions in the containment have been determined to be acceptable,e.g., for RCIC NPSH.Provide additional information and analysis to address the gaps (1) through (4)identified above.NSPM ResponseEach of the four bases is provided below:1) RPV depressurization to 150 to 300 psig is performed in a controlled manner forthe following reasons:a. RPV depressurization removes energy from the RPVb. Reducing RPV pressure reduces the time required to depressurize whenlow pressure pumps are required for RPV injection.c. RPV depressurization into the range of 150 to 300 psig does not impactRCIC injection capabilityd. RPV depressurization reduces the reactor coolant temperature, whichultimately reduces the fuel temperature.RPV depressurization is begun after an ELAP is declared as required byprocedure. An ELAP is declared at or before one hour has elapsed following astation blackout. There is no time constraint, as the RPV depressurization in therange of 150 to 300 psig will take approximately two hours, and the earliest RPVinjection with low pressure pumps is needed is approximately 11 hours.2) The depressurization is required to reduce the energy within the RPV beforereaching plant conditions for which the pressure suppression system (Torus) maynot be able to safely accommodate Automatic Depressurization System (ADS)valves opening. If the pressure suppression pressure is exceededdepressurization is required.Page 62 of 85 L-MT-1 5-047Enclosure 23) The depressurization rate is procedurally restricted:Concurrent opening of all ADS valves is within analyzed plant design limits. Cooldown rate is controlled to less than 100&deg; F/hr unless a higher cool down rate(emergency depressurization) is required/allowed by the EOPs.4) The resulting pressure or temperature conditions in the containment have beendetermined to be acceptable for RCIC NPSH. The maximum containmenttemperature is less than 300&deg;F, ensuring SRV solenoid operability. Themaximum containment pressure is less than the design temperature. The NPSHfor RCIC is acceptable. The RCIC flow may need to be limited after the nitrogenoverpressure is removed (i.e. when containment venting occurs).AQ 38Battery Room Ventilation. With regard to ventilation, the licensee stated that "thereare two strategies for venting the battery rooms. The primary strategy will be torepower the existing exhaust fan which is connected to the emergency power bus.The alternate strategy is to prop open doors and set up portable fans."Provide a discussion of the hydrogen gas exhaust path for each strategy.NSPM ResponseThe primary strategy as described in AQ 38 has been abandoned. The strategy forBattery room ventilation is as follows.During Phase 2 supplemental ventilation is provided for the Battery Rooms usingportable ducting and fans for air circulation as necessary. Portable fans will need tobe powered by a portable DG. 250V and 125V battery charger rooms requirecooling when the battery charger is energized. Ventilation is provided by stagingportable fans to circulate air through the rooms for cooling and to mitigate thepotential for hydrogen buildup. By opening room doors and circulating air withportable fans, hydrogen is exhausted or sufficiently diluted to have no adverseeffects.Page 63 of 85 L-MT-1 5-047Enclosure 2AQ 4OElectrical Isolations and Interactions. NEI 12-06, Section 3.2.2, guideline (13)specifies that appropriate electrical isolation and interactions for portable equipmentdiesel generator should be addressed in procedures/guidance. In its integratedplan, NSPM provides no information on the electrical isolations of the portable dieselgenerators.Describe how the portable/FLEX diesel generators and installed generators andswitch gear are isolated to prevent simultaneously supplying power in order toconform to NEI 12-06, Section 3.2.2, guideline (13). Provide a discussion oranalysis regarding electrical isolations when complete.The following generic item questions represent information the NRC staff will need inorder to assess the adequacy of the response to Order EA-12-049. The NRC staff ispursuing resolution of these issues under a separate effort; however, the questionslisted below represent how these generic issues relate to the individual licenseeOrder EA-12-049 responses. Licensees are asked to review the generic items andconsider how they will provide the information requested to the NRC staff in thefuture in coordination with the separate effort.NSPM ResponseEach station battery charger required following an ELAP event was modified toinstall a 480 Vac receptacle and an input breaker for the receptacle. A mechanicalinterlock was added to each battery charger that allows either the normal AC inputbreaker to be closed or the input breaker from the 480 Vac receptacle to be closed,but not both. With only one input breaker closed, the 480 Vac receptacle is isolatedfrom the normal AC input to the battery charger.The MNGP FLEX procedures provide instructions for connecting the 480 VacPortable DGs to essential battery chargers. Prior to connecting the power cablefrom the portable DG to the battery charger, the input breaker from the 480 Vacreceptacle is verified to be in the OFF position, thus providing isolation between theportable DG and the normal supply to the battery charger.MNGP FLEX procedures also provide instructions for powering the required stationbattery chargers from the portable DGs. For each battery charger, the first step is toverify both the Motor Control Center (MCC) supply breaker and the receptaclesupply breaker are in the OFF position.If access to the battery chargers is not available, the portable DG is used to supplythe associated MCC. The procedures provide instructions for connecting theportable DG to the associated MCC. In each case, prior to connecting the portablePage 64 of 85 L-MT-1 5-047Enclosure 2DG to the MCC, the MCC feeder breaker at the Load Center is verified to be in theOPEN position.Maintaining either the battery charger supply breaker at the MCC in the OFF positionor the MCC feeder breaker at the Load Center in the OPEN position provideselectrical isolation between the FLEX portable DG and the normal switchgear, thuspreventing simultaneously supplying electrical power to the battery charger or MCCfrom both the FLEX portable DG and the normal power supply.Procedures are also provided to give guidance for installing the 4KV generatorbrought onsite by the National SAFER Response Center. Included in this guidanceare instructions to ensure electrical isolation exists between the portable andpermanently installed power supplies.AQ 41The response discusses use of the HCVS line from the torus that will be opened toremove heat from the torus to reduce containment temperature for both Phase 1 and2 strategies. On page 34, the discussion regarding nitrogen supplies, notes that,"HCVS usage includes breaking the rupture disc and operation of air operatedvalves."Provide a discussion of valve operations and actions required to break the rupturedisc to allow flow from the torus to the vent piping, number of operators required toaccomplish this activity, and any special equipment or tools required to access andbreak the rupture disc. Discuss any access limitations that may result from anyadverse environmental effects and how this will be mitigated.NSPM ResponseThe MNGP Emergency Operating Procedures (EOPs) for primary containmentcontrol are entered if drywell pressure exceeds 1.84 psig. The EOPs permit primarycontainment venting to maintain drywell pressure within the Drywell Pressure Limit.Primary containment venting is also permitted if primary containment pressurereduction is required to restore and maintain adequate core cooling or reduce thetotal offsite dose. The EOPs direct use of the HPV system to vent primarycontainment.Procedures provide instruction for venting primary containment through the HPV. Tosupply Nitrogen to the HPV valves, AI-651, located in the TB, must be opened. Ifdrywell pressure is below 50 psig, HS-4541 (at the Alternate Shutdown System(ASDS) panel) is used to open the rupture disc (PSD-4543). From the ASDS panel,Page 65 of 85 L-MT-1 5-047Enclosure 2AO-4540 and AO-4539 are opened to vent containment through the hard pipe vent.When venting is complete, AO-4540 and AO-4539 are closed from the ASDS panel.Opening AI-651 requires one operator and does not require any special tools.Operating HS-4541 and manipulating AO-4539 and AO-4540 at the ASDS panelrequires one operator. Keys for the hand switches on the ASDS panel aremaintained along with procedural guidance in the MNGP CR.Since manipulations occur in either the TB or the EFT Building, there are no adverseenvironmental effects associated with these tasks.Nitrogen calculations to support hard pipe vent operation are described in Cl3.2.1 .6.A. See Cl 3.2.1 .6.A for additional alternate nitrogen supply discussion.AQ 49The MNGP integrated plan for Phase 2 SFP makeup for the normal and emergencyheat load case contains insufficient information to determine the adequacy of SFPcooling strategies and did not provide any details regarding providing makeup viathe RHR spent fuel cooling piping to include the routing of hoses from the FLEXportable pump, location where the portable pump is connected to the system, andFLEX pump flow and pressure requirements and capabilities using this flow path.Provide a discussion and analysis regarding how this strategy will be implementedconsidering the above factors and an analysis to show that the required flow can bedelivered to the .SFP with the planned deployment strategy.NSPM ResponseThe SFP normal and emergency heat load values and basis are provided in theresponse to AQ 51. Hose deployment strategies and makeup paths are described inthe response to CI 3.2.1.4.A.The USAR, section 10.2.2.3 provides the following regarding evaporation and flowrates associates with maintaining the SFP cooling level under emergency heat loadconditions:If fuel pool cooling capability is lost, the minimum possible time to achieve bulkpool boiling is 8.3 hours (assuming a maximum initial fuel pool temperature of120&deg;0F). The maximum evaporation rate after bulk boiling commences is 53 gpm.8.3 hours would be sufficient time to establish 53 gpm makeup rate from theResidual Heat Removal Service Water System (emergency makeup source).Page 66 of 85 L-MT-1 5-047Enclosure 253 gpm is considered the maximum bounding makeup rate for the worst case loss ofcooling to the SEP.The decay heat at ~1 1.1 hours is 14.5 MW. Assuming all this energy goes into thelatent heat of evaporation requires 139 gpm of make-up to the reactor per thefollowing equation.139 gpm = 14.5 MW x 3,412,000 BTU/hr/MW x 0.0181 82 ft3/Ib (300 pskiq) x 7.48 .qall/ft3(60 mmn/hr x 804.9 BTU/hr (300 psig))This assumes all the decay heat goes into boiling and no heat raises the water temperature to boiling.Calculations described in Cl 3.2.1 .4.A show the FLEX PDPs (P-506, P-507) cansupply flow rates greater than the sum of the SEP emergency make-up requirementsand the boil off rate (139 + 53 = 192 gpm). The calculations also demonstrate thatadequate flow is achieved from a single FLEX PDP when supplying both the SEP(makeup water (200 gpm) or spray water (250 gpm)) and the reactor (300 gpm ofmakeup water) at the same time.Therefore, the FLEX PDPs can maintain SEP level and reactor level after 11.1 hoursfrom the beginning of an ELAP event.AQ 51The source of the information (reference) for the determination of emergency coreoff load heat load discussed above was not provided. The source of information forthe normal heat load was the USAR.Provide the appropriate reference.NSPM ResponseThe source for both the normal and emergency SEP heat load is the MNGP UpdatedSafety Analysis Report (USAR) Section 10.2.2.3. USAR section 10.2.2.3 states thefollowing regarding SEP normal and emergency heat load:"The normal spent fuel pool heat load is evaluated using conditions such thatwould be expected during routine refuel shuffles and includes the heat loadassociated with a fully loaded 64 cell contingencyv fuel storage rack .... TheNormal Heat Load for this condition is 5. 55 x 10U Btu/hr for a dischargecompleted 216 hours after shutdown. The Emergency Heat Load is nominally24.7 x 106 Btu/hr for conditions which are as defined as:Page 67 of 85 L-MT-1 5-047Enclosure 2Emergency Heat Load -assumes full core discharge required 30 days followinglast refueling discharge and fills last 484 spaces; full core discharge is completeapproximately 192 hours after shutdown."AQ 53In its integrated plan, NSPM relies on diesel fuel reserves from the diesel generatorday tanks, and installed fuel transfer pumps. Additional information is required todetermine if the areas of the plant containing fuel tanks and pumps are fullyprotected for probable maximum flood (PMF) events. This information is required inorder to form the basis for conclusions with respect to conformance to the guidanceof NE/ 12-06, Section 3.2.1.3, initial condition (5).Provide a discussion regarding protection of fuel supplies and pumping systemsduring PMF conditions.NSPM ResponseThe MNGP flood plan builds a horseshoe levee to connect with the currentlyinstalled bin walls thereby encircling and protecting the EDG buildings, fuel tanksand pump house that support the emergency diesels from flooding. Theseprocedures form the response for MNGP flooding mitigation up to and including thePMF.FLEX equipment stored in the FLEX building will be moved inside the berm if theprojected river crest exceeds 919.0 feet MSL. FLEX equipment stored inWarehouse 6 will be moved inside the berm if the projected river crest exceeds930.0 feet MSL. If the projected river crest exceeds 930.0 feet MSL, a PDP isstaged to draw water from the CST to inject into the RPV and SFP. The MNGPflood response procedures provide for alternate access to the site by installing anadditional gravel roadway, thereby allowing for access and delivery of necessaryprovisions including consumables, fuel, etc.Specific guidance is provided to the operators for refueling the FLEX dieselequipment using several methods. These methods include:*Refueling the portable FLEX equipment is performed using the installedemergency diesel generatOr day tanks (two tanks with a capacity of 1500gallons each). Both day tanks are located in a Class 1 seismic structure andwould be located inside the licensee constructed PMF levee and thusprotected from flood waters.Page 68 of 85 L-MT-1 5-047Enclosure 2Refueling the portable FLEX equipment is performed using the fuel transfercubes (FTCs) provided by the SAFER response. In the event of flooding theFTCs would be delivered to the site and stored inside the flooding berm.AQ 62Page 14 states that when RCIC operation is no longer possible, the reactor will befully depressurized using the SRVs.Clarify the criteria that are used to determine whether RC/C operation is possible(e.g., fluid temperature, NPSH) and justify their adequacy. Include clarification as towhether the assessment of RCIC pump NPSH margin considers the potential fortransient conditions associated with cyclical safety/relief valve discharge (potentiallyin the vicinity of the RCIC suction line) and containment venting while thesuppression pool is saturated or nearly saturated. Provide a discussion of themethodology used to assure adequate NPSH for the RC/C pump and justify that it isadequate in light of the potential for limited margins and potentially significanttransient phenomena.NSPM ResponseFrom an operational point of view, RCIC would be run as long as possible (i.e., itwould be run to failure). From an analysis point of view, NSPM assumed RCIC willrun until the suppression pool temperature reaches approximately 250&deg;F based onanalysis and data recorded for Fukushima Unit 2.An NPSH evaluation was performed for the conditions when no nitrogenoverpressure is present (per Figure AQ 62 -2 a minimum of approximately 20 psi isavailable in the suppression pooi after the HCV is opened). This analysis concludedthat margin existed for steady state conditions at all flow rates below 300 gpm for thesuppression pool levels expected when the RCIC suction is connected to thesuppression pool. The NPSH evaluation shows approximately 5 ft of NPSH marginat the flow rates necessary to make-up for boil off for the suppression pool levelexpected.At Fukushima Dai-ichi, RCIC provided water to the reactor with a suppression pooltemperature well above 2500F with no operator actions. This data suggests thattransients associated with SRV actuations did not prevent RCIC operation. NSPMprocedures will use multiple SRVs to remove decay heat from the reactor to thesuppression pool.Page 69 of 85 L-MT-1 5-047Enclosure 2The MAAP analysis shows that the opening vent reduces NPSH as the nitrogenoverpressure is vented off with steam releases. The suppression pool temperaturepeaks at approximately 250&deg;F following the initial venting. See Figures AQ 62 -1and AQ 62 -2 for Suppression Pool Temperature and Pressure, respectively, duringan ELAP event.Figure AQ 62 -1 -MNGP Suppression Pool Temperature during ELAP EventMotiello ELA EvaluationCase: mojfiex..ca-sel zp15oOIL0 1a.0,,,,-,/I_____________ ____________ ______I______-A -i -A -A -A -04812 1020 224TIME, HOURSPage 70 of 85 L-MT-1 5-047Enclosure 2Figure AQ 62 -2- MNGP Suppression Pool Pressure during ELAP EventMonticelo ELA EvaluationCase: mojflex~casel zG4O20 __ 8_ __2 16TIME, HOURS2024Based on the RClC operations at Fukushima Unit 2 and the NPSH margin present,NSPM expects that RCIC will not fail during the ELAP event as suppression pooltemperature peaks at approximately 250.70F. However, the strategy conservativelyplans for the FLEX portable pump to be available when suppression pooltemperature reaches 250&deg;F.Page 71 of 85 L-MT-1 5-047Enclosure 2AQ 63The in formation provided in the submittal suggests that a single FLEX pump may beused to provide cooling flow to multiple destinations (e.g., the reactor core, thesuppression pool, and the spent fuel pool). Confirm that the FLEX pump can supplyadequate flow and clarify whether the pumped flow will be split and simultaneouslysupplied to all destinations or whether the flow will be alternated between them. Ifsimultaneous flow will be used, then clarify how the flow splits will be measured andcontrolled (i.e., whether control exists for the total flow on a common line or on linesto individual destinations) to ensure that adequate flow (i.e., sufficient but notexcessive) reaches each destination.NSPM ResponseA calculation was performed that confirmed that a minimum of 300 gpm of makeupwater can be delivered to the RPV simultaneously with makeup water (200 gpm) orspray water (250 gpm) supplied to the SFP. Flow paths to both the RPV and SFPare through a combination of existing piping systems (RHR, RHRSW, FPC and FP)and interconnecting hoses in conjunction with a PDP.RPV injection and SFP makeup instructions are provided by procedure. In all of theconfigurations, specific valves are identified and throttled to maintain, restore andbalance the necessary makeup water flow for simultaneous flow to the RPV andSEP.See Cl 3.2.1 .4.A for a full description of the hose deployment paths and thecalculations supporting adequate flow to the RPV and SFP. Suppression poolcooling is not required as the suppression pool peak temperature peaks atapproximately 250.7&deg;F. See Figure 01 3.2.3.B -3 and Figure AQ 62 -1 for furtherdetails.Page 72 of 85 L-MT-1 5-047Enclosure 2AQ 65Provide a discussion on the effects of heightened temperatures (i.e., temperaturesabove those assumed in the sizing calculation for each battery) on each battery'scapability to perform its function for the duration of the ELAP event.NSPM ResponseThe vendor instruction manual for the 1 E batteries states that heat accelerateschemical activity. The vendor states that higher-than-normal temperature has thefollowing effects on a lead acid battery:* Increase performance* Increases internal discharge or local action losses* Lower cell voltage for a given charge voltage* Shortens life* Increases water usage* Increases maintenance requirementsTherefore, NSPM has concluded that the battery's capability to perform its functionuntil a charger is placed in service will not be adversely impacted.The effects of increased in cell electrolyte temperatures will have no appreciableeffect on the magnitude of short-circuit current delivered by the battery. An increasecell temperature during an ELAP will not result in a challenge to the interruptingrating of the distribution system protective devices.The maximum temperatures calculated in the battery rooms remained below theacceptance criterion of 120&deg;F with forced ventilation being used.Page 73 of 85 L-MT-1 5-047Enclosure 2SE 4Please address the following items regarding the use of raw water sources formitigating an ELAP event:a. Please discuss the quality of the water (e.g., suspended solids, dissolved salts)that will be used for primary makeup during ELAP events, accounting for thepotential for increased suspended or dissolved material in some raw watersources during events such as flooding or severe storms.b. Please discuss whether instrumentation available during the ELAP event iscapable of providing indication that inadequate core cooling exists for one ormore fuel assemblies due to blockage at fuel assembly inlets or bypass leakageflow paths.c. As applicable, please provide justification that the use of the intended raw watersources will not result in blockage of coolant flow across fuel assembly inlets andapplicable bypass leakage flow paths to an extent that would inhibit adequatecore cooling. Or, if deleterious blockage at the core inlet cannot be precludedunder ELAP conditions, then please discuss alternate means for assuring theadequacy of adequate core cooling in light of available indications. For example,will ELAP mitigation procedures be capable of ensuring top-down cooling of thereactor core?NSPM Responsea. The raw water source for the Monticello plant is the Mississippi river. PortableFLEX pumps will draw water from the intake (behind the traveling screens) or thedischarge canal after water has traversed though the travelling screens. TheFLEX pump suction line is equipped with a filter that stops debris larger then 3/8"(see response to SE 9).The typical quality of the Mississippi river as measured near the Monticello plant:Specific Conductivity minimum/maximum/average (uS/em) = 276/667/415Total suspended Solids minimum/maximum/average (mg/I) = 1.1/13.4/4.1Suspend-Sediment sieve dia < 0.0625 mm (%) upstream average = 90%Suspend-Sediment sieve dia < 0.0625 mm (%) downstream average = 83%During a flood, the FLEX equipment will be moved inside the berm. Should anELAP occur in this condition, the CSTs will be used as a source of water for theFLEX PDPs.b. Reactor fuel blockage is very unlikely when RCIC is supplying water to thereactor. Furthermore, currently installed Reactor level indication instrumentationPage 74 of 85 L-MT-1 5-047Enclosure 2is available which will ensure adequate core cooling. These instruments will beused for monitoring level in all cases. When raw water is used, the reactor waterlevel will be raised above the separator return elevation (spillover level) asdiscussed in the response below. This will ensure all fuel assemblies arecovered with water even if water blockage occurs at the bottom of one or morebundles. See Cl 3.2.1.8.0 for further information.c. When a portable pump is injecting water from the intake or the discharge canal,reactor fuel is adequately cooled if the reactor water level outside the shroud ismaintained above the steam separator return elevation of approx. +48 inches. Iffuel blockage occurs, the fuel can be cooled from water spilling over in the corethrough the steam separators. Procedures direct operators to maintain reactorwater level in the range +55" to + 100".The portable pump will inject thru LPCI injection, thru the jet pumps into lowerreactor head. Water will flow up into the fuel unless the flow is blocked by debris.In this condition, the fuel can still be adequately cooled with water spilling overthrough the separators. This is supported by BWROG-TP-14-006, Revision 0,"Raw Water Issue: Fuel inlet blockage from debris", March 2014. See CI3.2.1.8.C for further information.In order to monitor for adequate cooling, reactor water level instruments arerequired (vessel flood instrumentation). Station batteries are still available duringan ELAP and provide power to the reactor water level instruments. If power islost, procedural guidance is available to provide instructions for local levelmeasurement with hand held instruments.SE5Verify that appropriate human factors are applied for the implementation of the FLEXstrategies.NSPM ResponseNSPM personnel performed a validation of the FLEX strategies to define anddocument that personnel can perform the required tasks, manual actions, anddecisions necessary to implement the FLEX strategies. The results of the FLEXstrategies validation determined that the FLEX strategies are feasible and may beexecuted within the constraints of Order EA-12-049.Page 75 of 85 L-MT-1 5-047Enclosure 2The purpose of the review was to ensure that adequate resources (personnel,equipment, materials) are available to implement the individual strategies to achievethe intended results of the FLEX strategies.One of the Key Site Assumptions in the Monticello QIP is: "Deployment resourcesare assumed to begin arriving at hour six and fully staffed by 24 hours". These timeswere agreed to in discussions between with the NRC staff and are documented inNEI 12-01, "Guideline for Assessing Beyond Design Basis Accident ResponseStaffing and Communications Capabilities", Section 2.2: Assumptions Common toBoth Assessments.Use of FLEX equipment requires personnel to be available to perform the following:1) Select staging areas and deployment paths,2) Debris removal from the deployment paths, if necessary,a. Move debris by hand,b. Move larger debris with a truck and chains, slings and come-alongs,c. Move largest debris with a front-end loader or large forklift,3) Staging the FLEX equipment:a. The act of moving portable equipment from the FLEX buildings to thestaging location,b. Laying out, and connecting cables for the FLEX diesel generators andhoses for the FLEX pump,c. Breaker manipulation, if necessary,d. Starting the diesel engines, starting the battery chargers and preparing theequipment to deliver water and electricity.Note: Staging of hoses and cables could begin before debris removal begins.On-shift personnel can perform all the above tasks except for task 2)c. They are notqualified to operate the front-end loader or the large forklift (e.g. heavy equipment).FLEX equipment, which includes a FLEX PDP, a 120 Vac portable DG and a 480Vac portable DG, will not be needed before hour 11, based on MAAP analysis, loadshedding and preliminary battery calculations.Debris removal will begin as early as hour two by on-site personnel. The staffingstudy assumes that 3 members of the duty crew (operations, chemists and radiationprotection personnel) are available to begin staging cables and hoses as well asperforming debris removal. A truck, another piece of dedicated FLEX equipment,using chains and tow straps, can be used to begin moving debris prior to hour six.The staffing study identifies 10 person-hours available for staging/debris removalprior to hour six. These efforts will reduce the time required after hour six toPage 76 of 85 L-MT-1 5-047Enclosure 2complete staging and perform any additional debris removal required. See FigureSE 5-1 below.Figure SE 5-1 FLEX TimelineStagjr~g; a~idlO 2. 4. a 8& 1_0 12Staging the FLEX pump, a 120 Vac portable DG and a 480 Vac portable DG willrequire less than two hours. Hoses and cables can be staged by on-site personnelwithin the first six hours, reducing the post-six hour staging time by up to an hour.Between hour six and hour 11, there are five hours to remove any large debris andfinish staging the FLEX PDP, a 120 Vac portable DG and a 480 Vac portable DG.The equipment will be ready for use between hour 10 and hour 11.There are many mechanical maintenance employees that are qualified to operatethe front-end loader and the large forklift. The mechanical maintenance employeesare members of the emergency organization and carry pagers. The FLEX strategyassumes only one of these individuals arrives on-site at hour six and begins debrisremoval.The site has a variety of equipment on-site, e.g., skid-steer loaders, cranes, trucks,forklifts, etc. For example, the site typically maintains two skid-steer loaders on-sitefor everyday work. These require less training to operate and more people haveexperience operating these than a front-end loader. The skid-steer loaders andother heavy equipment will not be credited in the FLEX program for debris removal,but could be used by on-site personnel in the first six hours to remove debris. On-shift personnel will not be trained on skid-steer loader operation as an individual canbecome modestly proficient with a skid-steer loader in 15 to 30 minutes. When notin use, one skid-steer loader will generally be stored in each FLEX building. Aplacard with basic operating instructions is provided with each skid-steer loader.Page 77 of 85 L-MT-1 5-047Enclosure 2Based on the following:1) the staging/debris removal by on-site personnel prior to hour six,2) the large number of trained and qualified heavy-equipment operators,3) heavy-equipment operators are paged as part of the ERO activation, and4) the amount of time available after hour six for completion of debris removal,it is reasonable to assume that a qualified individual will be available at hour six, ifnecessary to remove larger debris, and that the FLEX equipment will be availablewhen it is needed.SEGProvide the basis for the minimum dc bus voltage that is required to ensure properoperation of all required electrical equipment.NSPM ResponseLoad flow and cell sizing analyses have been performed to assess the capability ofthe station batteries to support specific loads during ELAP event. For eachcalculation, a minimum battery terminal voltage was selected to assure the mostlimiting device minimum terminal voltage acceptance criteria was satisfied for thoseloads credited during the ELAP scenario.The circuits and load descriptions considered for each battery are summarizedbelow:Dl 125V Division I Station BatteryDll1-06, RCIC Indication and Drain Solenoid ValvesD1 1-07, Evacuation Siren Control PowerD11-12, RCIC LogicD1 1-17, Inboard Isolation Valve Relay Panel 0-4102 125V Division II Station BatteryD21-05, HPCI Logic and Indication021-12, SRV Logic and SolenoidsD21-15, HPCI LogicPage 78 of 85 L-MT-1 5-047Enclosure 203 250V Division I Station BatteryD31-06, Supply to N-3106 (Plant Evacuation Siren)D31-08, Supply to 033D31-10, MOO for ROIC MOVs031-12, Y71 Inverter033-01, RCIC MOV Contactor Circuits06 250V Division II Station BatteryD1 00-01, HPOI MOV Contactor Circuits0100-03, SRV Logic and Solenoids0100-04, Supply to C-292, ASDS0100-05, Supply to C-303B, EGOS Analog Trip Unit0100-11, MOO for HPCI MOVs0100-12, Y81 Inverter07 250V Non-IlE Station BatteryD71-01, Y91 UPS071-03, Emergency Seal Oil Pump MotorSE 7Provide electrical Single Line Diagrams showing the proposed connections of Phase2 and 3 electrical equipment to permanent plant equipment. Show protectioninformation (breaker, relay etc.) and rating of the equipment on the Single LineDiagrams.NSPM ResponseSee Figure SE 7 -I below.Page 79 of 85 L-MT-1 5-047Enclosure 2Figure SE 7 -1 -FLEX POG/SAFER Single Line DiagramSAFER 1SAFER 2Q 4160 VAC1000 ;cwSZ5 Q 4!60gVC1250 KVA1 0.8 PF4/0 A.NG TYPE SM 400 A4/0 AWS TYPE- SE 400 Afist Sys CU i[EI4.16 kV1200A250 EVAEus 13 1 120'87CB 52-1/C--4/0 .140 PEATYP9E 58 400 A0 A250 IrA1200 A250 EVTA152-404 120lZ0 A Ens 14250 EVA 4.16 IV152--408B 1200 A250 EVABus 164 .15 IcYPUG SAFER 480VCB1%>)0PUG Dist Panel0.48 IcV400 AC52 I CBS601) 6B3315 B343) II'010 11524/C-4 AWG 100 A (TYP.)Page 80 of 85 L-MT-1 5-047Enclosure 2SE 8In the August 2014 update, the licensee discussed changing the portable FLEXpump connections to RHRSW from the Reactor Building to the Turbine Building.Confirm this change provides reasonable assurance that accessibility to at least oneconnection point of FLEX equipment is limited to seismically robust structures. Thisaccess includes both the connection point and any areas that plant operators willhave to access to deploy or control the capability as required by NE1-12-06, Section5.3.2. Consideration 2. Provide additional information to demonstrate conformanceto NEI 12-06, Section 5.3.2, Consideration 2.NSPM ResponseNEI 12-06, Section 5.3.2, Consideration 2 states:"At least one connection point of FLEX equipment will only require accessthrough seismically robust structures. This includes both the connection pointand any areas that plant operators will have to access to deploy or control thecapability."All Class I structures are shown in Table SE 8 -1.The connection points for FLEX PDPs and portable DGs are located in Class Istructures (see Figure SE 8 -1). The portions of the MNGP TB that support electricalcontrols and instrumentation for Class I equipment were designed in accordancewith criteria for design of portions of Class I structures enclosing Class I equipmentfor seismic loads. This includes the portion of the TB below elevation 951'0".The portable FLEX pump connection to RHRSW is located below the TB 951'0"elevation.The Reactor Building railroad bay is part of the Radwaste Building (see TableSE 8 -1). The Rail Car Shelter (or railroad bay) portion of the building has beenevaluated for a Safe Shutdown Earthquake (SSE) event to assure that it will remainintact in an SSE. Thus, the Rail Car Shelter is considered seismically robust forFLEX, even though the Radwaste Building is a Class II structure.Electrical cables to the Division I battery chargers and the 125V Division II batterycharger will be run through the seismically robust control building. Both paths to theDivision II 250 V battery chargers must pass through the PAR (See Table SE 8 -1)to get to the EFT Building. The PAR has been evaluated for a SSE event to assurethat it will remain intact in an SSE. Thus, the PAB is considered seismically robustfor FLEX, even though the PAR is classified as a Class II structure.Page 81 of 85 L-MT-1 5-047Enclosure 2Table SE 8 -1 -MNGP Class I StructuresMNGP Class I StructuresPertinent structures only as discussed in the USAR Section 12.2Structure FLEX Strategqy SigqnificanceReactor Building (up to Operating Floor- Connection points for SEP and Reactor1027-foot 8-inch)Plant Control and Cable Spreading Connection points for Division I SRStructure (a portion of the PAB)
* batteries and Division I11125 V SR batteryParts of TB Housing Class I Equipment Connection points for SFP and ReactorEFT Building Connection points for Division II 250 V SRbatteryRailroad Bay (or Rail Car Shelter) A Deployment path for hoses to support______________________________FLEX strategy* The PAB is made up of two areas: a seismic I section -Plant Control and CableSpreading Structure and the old office building which is a Class II structure. Thestructure was analyzed to withstand design basis earthquake in accordance withClass I design criteria set forth in USAR Section 12.2.1.4 to prevent failure of the firemain and subsequent internal flooding of the battery rooms. The resulting forces anddisplacements from the dynamic analysis of the entire Office and Control Buildingwere used in the analysis of the old office building.A The Railroad Bay occupies a portion of the Radwaste Building. Per USAR Section12.2.1.3, the Radwaste Building is a Class II structure, and was not evaluated for theDesign Basis Earthquake (DBE). However, to ensure a spent fuel cask was notdamaged in the event of a DBE, the Rail Car Shelter was evaluated for a DBE. Theresults of the calculation determined that the Rail Car Shelter would stay intact and notcollapse on to a spent fuel cask due to a DBE. Thus, since it has been demonstratedthat the Rail Car Shelter will remain intact due to a DBE, and will provide a viablepathway for FLEX hoses into the Reactor Building.Page 82 of 85 L-MT-1 5-047Enclosure 2Figure SE 8 -1 -FLEX Hose and Cable Deployment Paths*Seismic EFT EntryLegendH Hose connection locationE Electrical connection location-.....Seismic I Hose and electrical Connection Path.....Seismic I ElectricalConnection PathlSeismic I BuildingPage 83 of 85 L-MT-1 5-047Enclosure 2SE 9A. Discuss the design of the suction strainers used with FLEX pumps taking suctionfrom raw water sources, including perforation dimension(s) and approximatesurface area.B. Provide reasonable assurance that the strainers will not be clogged with debris(accounting for conditions following, flooding, severe storms, earthquakes orother natural hazards), or else that the strainers can be cleaned of debris at afrequency that is sufficient to provide the required flow. In the response, considerthe following factors:i. The timing at which FLEX pumps would take suction on raw water relativeto the onset and duration of the natural hazard.ii. The timing at which FLEX pumps would take suction on raw water relativeto the timing at which augmented staffing would be available onsite.ifi. Whether multiple suction hoses exist for each FLEX pump taking suction onraw water, such that flow interruption would not be required to clean suctionstrainers.NSPM ResponseA. Suction Strainer design: (See Cl 3.2.1 .4.A for flow calculations. See Cl 3.2.1.8.0for strainer use.)The suction strainer is 13.75" long, 6" diameter, with 950 -3/8" holes. It is afloating strainer that is designed to float at a depth of 1ft. It is assumed that thesuction strainer is maintained relatively clear of debris. Significant margin existsin the strainer geometry (an open area of approximately 105 in2 vs. a 6 in pipecross section of 28 in2), such that small amounts of debris blockage can betolerated with negligible impact on the pressure drop across the strainer. Thepump suction strainer can be manually cleaned if clogged.B. See response to SE 4 for FLEX pump suction sources during flooding conditionsand typical Mississippi River water quality data. This data has been gathered atlocations near MNGP.The FLEX PDP is expected to be ready for use 10.5 hours after the ELAP eventoccurs and 4.5 hours after augmented staff will be available. One of the twoavailable pumps and respective strainers will be available as one is stored ineach storage building. The pump will not need to run continuously as the pumpcapacity exceeds the flow required in the reactor and the SFP and levelsmaintained will have considerable margin. Therefore, interruptions in flow will notadversely affect the fuel to be adequately cooled, allowing the pump to be shutdown and the strainer cleaned, as required.Page 84 of 85 L-MT-1 5-047Enclosure 2During a flood, the FLEX equipment will be moved inside the berm. Should anELAP occur in this condition, the CSTs will be used as a source of water for theFLEX pumps.Page 85 of 85
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