ML14246A449

Issuance of Amendment to Revise TS 3.5.1, ECCS - Operating

ML14246A449
Person / Time
Site:	Monticello
Issue date:	11/03/2014
From:	Beltz T A Plant Licensing Branch III
To:	Fili K D Northern States Power Co, Xcel Energy
Beltz T A
References
TAC MF3911
Download: ML14246A449 (14)

Text

REG(/( o.,..L ("l 0 ;;; 't/. **** .. Karen D. Fili Site Vice President UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 3, 2014 Monticello Nuclear Generating Plant Northern States Power Company -Minnesota 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT-ISSUANCE OF AMENDMENT TO REVISE TECHNICAL SPECIFICATION 3.5.1, "ECCS [EMERGENCY CORE COOLING SYSTEM]-OPERATING" (TAC NO. MF3911)

Dear Ms. Fili:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 184 to Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating Plant (MNGP). The amendment consists of a change to technical specification (TS) 3.5.1, Operating," in response to your application dated April4, 2014. The amendment removes MNGP TS 3.5.1, Condition F, which provides a 72-hour Completion Time to restore one core spray subsystem to an operable status when both core spray subsystems are inoperable.

Northern States Power Company determined that operation of at least one core spray subsystem is necessary post-accident to maintain adequate long-term core cooling and, therefore, requested approval for removing the option of having a limiting condition of operation with both core spray subsystems inoperable.

A copy of our related safety evaluation is also enclosed.

The Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket No. 50-263

Enclosures:

1. Amendment No. 184 to DPR-22 2. Safety Evaluation cc w/encls: Distribution via ListServ Sincerely, Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER COMPANY-MINNESOTA DOCKET NO. 50-263 MONTICELLO NUCLEAR GENERATING PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 184 License No. DPR-22 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Northern States Power Company -Minnesota (NSPM, the licensee), dated Apri14, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2 of Renewed Facility Operating License No. DPR-22 is hereby amended to read as follows: Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 184, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

Enclosure 1 3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.

Attachment:

Changes to Renewed Facility Operating License No. DPR-22 and Technical Specifications avid L. Pelton, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance:

November 3, 2014 ATTACHMENT TO LICENSE AMENDMENT NO. 184 RENEWED FACILITY OPERATING LICENSE NO. DPR-22 DOCKET NO. 50-263 Replace the following page of Renewed Facility Operating License No. DPR-22 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change. REMOVE INSERT 3 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. REMOVE 3.5.1-2 3.5.1-3 3.5.1-4 INSERT 3.5.1-2 3.5.1-3 3.5.1-4 2. Pursuant to the Act and 10 CFR Part 70, NSPM to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operations, as described in the Final Safety Analysis Report, as supplemented and amended, and the licensee's filings dated August 16, 197 4 (those portions dealing with handling of reactor fuel); 3. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;

4. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and 5. Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess, but not separate, such byproduct and special nuclear material as may be produced by operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: 1. Maximum Power Level NSPM is authorized to operate the facility at steady state reactor core power levels not in excess of 2004 megawatts (thermal).

2. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 184, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

3. Physical Protection NSPM shall implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Renewed License No. DPR-22 Amendment No. 4-tfi.R:i 184 ACTIONS (continued)

CONDITION C. One LPCI pump in both LPCI subsystems inoperable.

D. Two LPCI subsystems inoperable for reasons other than Condition C or G. E. One Core Spray subsystem inoperable.

AND One LPCI subsystem inoperable.

OR One or two LPCI pump(s) inoperable.

F. Required Action and associated Completion Time of Condition A, B, C, D, or E not met. G. Two LPCI subsystems inoperable due to open RHR intertie return line isolation valve(s).

Monticello C.1 D.1 E.1 OR E.2 OR E.3 F.1 AND F.2 G.1 REQUIRED ACTION Restore one LPCI pump to OPERABLE status. Restore one LPCI subsystem to OPERABLE status. Restore Core Spray subsystem to OPERABLE status. Restore LPCI subsystem to OPERABLE status. Restore LPCI pump(s) to OPERABLE status. Be in MODE 3. Be in MODE 4. Isolate the RHR intertie line. ECCS -Operating 3.5.1 COMPLETION TIME 7 days 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 72 hours 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 72 hours 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> 3.5.1-2 Amendment No. 146, 162, 184 ACTIONS (continued)

CONDITION H. Required Action and H.1 associated Completion Time of Condition G not met. I. HPCI System 1.1 inoperable.

AND 1.2 J. HPCI System J.1 inoperable.

AND OR Condition A, B, or C J.2 entered. K. One ADS valve K.1 inoperable.

Monticello REQUIRED ACTION Be in MODE 2. Verify by administrative means RCIC System is OPERABLE.

Restore HPCI System to OPERABLE status. Restore HPCI System to OPERABLE status. Restore low pressure ECCS injection/spray subsystem(s) to OPERABLE status. Restore ADS valve to OPERABLE status. ECCS -Operating 3.5.1 COMPLETION TIME 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Immediately 14 days 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 72 hours 14 days 3.5.1-3 Amendment No. 146, 162, 176, 184 ACTIONS (continued)

CONDITION L. Required Action and associated Completion Time of Condition I, J, or Knot met. OR One ADS valve inoperable and Condition A, 8, C, D, or G entered. OR Two or more ADS valves inoperable.

OR HPCI System inoperable and Condition D, E, or G entered. M. Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition C, D, E, or G. OR HPCI System and one or more ADS valves inoperable.

Monticello L.1 AND L.2 M.1 REQUIRED ACTION Be in MODE 3. Reduce reactor steam dome pressure to :::;; 150 psig. Enter LCO 3.0.3. ECCS -Operating 3.5.1 COMPLETION TIME 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours Immediately 3.5.1-4 Amendment No. 146, 162, 176, 184 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 RELATED TO AMENDMENT NO. 184 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-22 NORTHERN STATES POWER COMPANY-MINNESOTA MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263

1.0 INTRODUCTION

By letter dated April4, 2014 (Reference 1), Northern States Power Company-Minnesota (NSPM, the licensee), doing business as Xcel Energy, Inc., requested changes to the technical specifications (TSs) for the Monticello Nuclear Generating Plant (MNGP). Specifically, the licensee requested to delete its current Condition F, "Both Core Spray subsystems inoperable," from TS 3.5.1, "ECCS [Emergency Core Cooling System]-Operating." NSPM requested approval to remove the capability for having an allowed complete loss of core spray as currently provided in the MNGP TSs. The revised required actions to be taken with both core spray subsystems inoperable would be governed by TS Condition M (previously Condition N), and require immediate entry into limiting condition for operation (LCO) 3.0.3 (i.e., commence actions to place the reactor into a shutdown condition).

In MNGP Amendment No. 162, dated July 10, 2009 (Reference 2), the NRC staff approved the required action in TS 3.5.1, "ECCS-Operating," pertaining to the condition when both core spray subsystems are inoperable.

Condition F provided a 72-hour Completion Time to restore one core spray subsystem to Operable status when both core spray subsystems were inoperable.

This 72-hour Completion Time was predicated on an approved Completion Time for a similar Boiling Water Reactor under the same circumstances.

The licensee proposed in this license amendment request (LAR) to remove Condition F from the MNGP TSs for the reasons summarized below. While in a refueling outage in April 2013, the licensee questioned whether the 72-hour Completion Time duration forTS 3.5.1, Condition F, was appropriate for the situation in which both core spray subsystems are inoperable.

Operation of one core spray subsystem is necessary post-accident to maintain adequate long-term core cooling. While the acceptability of a 72-hour Completion Time for having both core spray subsystems inoperable during the term phase of an accident had been presented in the LAR, the impact on the long-term core cooling capability had not been presented to the NRC for consideration as part of the review for Amendment No. 162. Enclosure 2 In its April4, 2014, application, the licensee stated that it has been applying guidance specified in NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That are Insufficient to Assure Plant Safety," until this condition is resolved with approval of the proposed LAR. Corrective actions have been implemented for the interim period between identification and resolution of this condition to ensure conservative plant operation.

2.0 REGULATORY EVALUATION

The licensee's requested change is based upon the MNGP loss-of-coolant accident (LOCA) analysis and ECCS single-failure analysis.

MNGP was designed largely before publication of the 70 General Design Criteria (GDC) for nuclear power plant construction permits proposed by the Atomic Energy Commission (AEC) for public comment in July 1967, and constructed prior to 1971 publication of Appendix A, "General Design Criteria for Nuclear Power Plants," to Title 10 of the Code of Federal Regulations (1 0 CFR), Part 50. As such, MNGP was not licensed to the GDCs of Appendix A. The MNGP Updated Safety Analysis Report (USAR), Section 1.2, lists the principal design criteria for the design, construction, and operation of MNGP. Appendix E of the USAR provides a plant comparative evaluation to the 70 proposed AEC design criteria.

The licensee conforms to the intent of the 70 proposed GDCs. The NRC performed its regulatory evaluation of the proposed LAR based, in part, on a review of the following:

1. 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," insofar as it establishes standards for the calculation of ECCS performance and acceptance criteria for that calculated performance;

2. 10 CFR 50, Appendix K, "ECCS Evaluation Models," insofar as it establishes required and acceptable features of evaluation models for heat removal by the ECCS after the blowdown phase of a LOCA; 3. Draft GDC-40 and 42, insofar as they require that protection be provided for engineered safety features against the dynamic effects that might result from plant equipment failures, as well as the effects of a LOCA; and 4. Draft GDC-37, 41, and 44, insofar as they require that a system to provide abundant emergency core cooling be provided so that fuel and clad damage that would interfere with the emergency core cooling function will be prevented.

3.0 TECHNICAL EVALUATION 3.1 Background The ECCS provides makeup water for injection into the reactor pressure vessel during accident scenarios.

The ECCS at MNGP is comprised of the following systems: high pressure coolant injection (HPCI) system; the low pressure coolant injection (LPCI) mode of the residual heat removal (RHR) system; the core spray (CS) system; and the automatic depressurization system (ADS). Low pressure ECCS consists of the LPCI and CS systems, in addition to ADS, and provides injection of a high volume of makeup water when reactor pressure is low. The current MNGP TS 3.5.1, Condition B, allows for one CS subsystem to be inoperable for seven (7) days. NRC approval of this LARwill not change any of the current TS 3.5.1 requirements, except for the deletion of the present Condition F. As previously stated, this LAR proposes to delete Condition F, "Both Core Spray subsystems inoperable," in TS 3.5.1. The change would eliminate the current 72-hour Completion Time to restore one CS subsystem to an operable status. The licensee actions with two or more low pressure ECCS CS subsystems inoperable will be controlled by the TS 3.5.1, Condition M (current condition N), which would require a plant shutdown as required by TS LCO 3.0.3. In its LAR, the licensee identified those single-failure scenarios assumed in the USAR and evaluated the remaining ECCS equipment available for accident mitigation.

The licensee concluded that the proposed TS change and the resulting equipment out-of-service combinations are all bounded by the existing MNGP ECCS single-failure analysis.

The MNGP ECCS/LOCA analysis is based on the General Electric (GE) SAFER/GESTR methodology and associated NRC-approved code set (References 3, 4 and 5). The licensee analyzed the CS system impact on both short-and long-term core cooling for limiting recirculation line breaks, in addition to breaks other than a recirculation line break. The MNGP long-term core cooling performance is discussed in USAR Section 14.7.2.3.6.

The NRC acceptance criteria for ECCS performance is specified in 10 CFR 50.46(b).

Criterion (b)(5), "Long-term cooling," is satisfied generically and documented in NED0-20666-A (Reference 6). For MNGP, at least one core spray subsystem is required to provide adequate long-term core cooling and is bounded by the existing single-failure analysis.

3.2 NRC Staff's Evaluation The NRC staff finds that the licensee analyzed the limiting LOCA scenarios with the limiting single-failure, and that MGNP will remain in compliance with the regulatory requirements specified in 10 CFR 50.46 and 10 CFR 50.46, Appendix K. Therefore, the staff concludes that the proposed TS change is supported by the safety analysis.

According to the draft GDCs 37, 41 and 44, systems shall be provided to provide abundant emergency core cooling. The systems shall be capable of transferring heat from the reactor core following any loss of reactor coolant to prevent fuel and clad damage and clad metal-water reaction.

The systems are also required to be redundant and capable of accomplishing their task assuming a single failure. NSPM has shown through its analysis that the MNGP ECCS systems would still be able to meet these criteria in the event of a LOCA, assuming a single failure and inoperable ECCS subsystems.

The licensee states that the current 72-hour Completion Time allowance when both CS subsystems are inoperable is now being applied administratively.

Plant operators are directed to not enter TS 3.5.1, Condition F. This administrative control is expected to be withdrawn upon implementation of this license amendment.

Finally, the NRC staff finds that the MNGP EPU SER, Section 2.8.5.6.2, continues to remain applicable with regard to ECCS and LOCA (Reference 7). 3.3 Conclusion Based on the above, the NRC staff finds the proposed change to be acceptable.

The licensee has provided adequate justification for the proposed change, and the staff concludes that the MGNP ECCS/LOCA licensing basis provides reasonable assurance that the proposed change will not adversely affect the ability for continued compliance with regulatory requirements.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendment.

The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION The amendment changes requirements with respect to the use of facility components located within the restricted area as defined in 10 CFR Part 20 or changes surveillance requirements.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding as published in the Federal Register on August 19, 2014 (79 FR 49107). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Letter from K. D. Fili, Site Vice President, to the U.S. NRC Document Control Desk (DCD) L-MT-14-009, "License Amendment Request: Revision to Required Actions for Specification 3.5.1, Emergency Core Cooling System," dated April4, 2014 (ADAMS Accession No. ML 14097A106).

2. Letter from K. D. Feintuch (U.S. NRC) toT. J. O'Connor (NSPM), "Monticello Nuclear Generating Plant (MNGP) -Issuance of Amendment Regarding Completion Time to Restore a Low-Pressure Emergency Core Cooling Subsystem to Operable Status (TAC No. MD9170)," dated July 10, 2009 (ADAMS Accession No. ML091480782). 3. Letter from C. 0. Thomas (U.S. NRC) to J. F. Quirk (General Electric), "Acceptance for Referencing of Licensing Topical Report NEDE-23785P, Revision 1, Volume Ill (P), "The GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Flow Accident,"" dated June 1, 1984 (ADAMS Accession No. ML 102260240-proprietary).

4. GE Nuclear Energy, NEDC-32514P, Revision 1, "Monticello Nuclear Generating Plant SAFER/GESTR-LOCA Loss-of-Coolant Accident Analysis," dated October 1997. 5. GE Nuclear Energy, GE-NE-J1103878-09-02P, "Monticello ECCS-LOCA Evaluation for GE14," dated August 2001. 6. NED0-20566A, "General Electric Company Analytical Model for Loss-Of-Coolant Analysis in accordance with 10 CFR 50 Appendix K-Volume 2," dated September 1986. 7. Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 176 to Facility Operating License No. DPR-22, Northern States Power Minnesota (NSPM), Monticello Nuclear Generating Plant, Docket No. 50-263," dated December 9, 2013 (ADAMS Accession No. ML 13343A006-non-proprietary (redacted version) and ADAMS Accession No. ML 11311C644-proprietary).

Principal Contributors:

George Thomas, NRR Date of issuance:

November 3, 2014 November 3, 2014 Karen D. Fili Site Vice President Monticello Nuclear Generating Plant Northern States Power Company -Minnesota 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT-ISSUANCE OF AMENDMENT TO REVISE TECHNICAL SPECIFICATION 3.5.1, "ECCS [EMERGENCY CORE COOLING SYSTEM]-OPERATING" (TAC NO. MF3911)

Dear Ms. Fili:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 184 to Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating Plant (MNGP). The amendment consists of a change to technical specification (TS) 3.5.1, Operating," in response to your application dated April 4, 2014. The amendment removes MNGP TS 3.5.1, Condition F, which provides a 72-hour Completion Time to restore one core spray subsystem to an operable status when both core spray subsystems are inoperable.

Northern States Power Company determined that operation of at least one core spray subsystem is necessary post-accident to maintain adequate long-term core cooling and, therefore, requested approval for removing the option of having a limiting condition of operation with both core spray subsystems inoperable.

A copy of our related safety evaluation is also enclosed.

The Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket No. 50-263

Enclosures:

1. Amendment No. 184 to DPR-22 2. Safety Evaluation cc w/encls: Distribution via ListServ DISTRIBUTION:

PUBLIC LPL3-1 r/f Sincerely, /RAJ Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation GThomas, NRR RidsNrrPMMonticello Resource RidsNrrLAMHenderson Resource RidsNrrDssStsb Resource RidsRgn3MaiiCenter Resource RidsNrrDoriDpr Resource ResourceRidsNrrDssStsb Resource RidsNrrDorllpl3-1 Resource RidsNrrDssSrxb RidsAcrsAcnw_MaiiCTR Resource ADAM s Accession No.: ML 14246A449

• SE transmitted by memo dated August 7, 2014 OFFICE LPL3-1/PM LPL3-1/LA SRXB/BC STSB/BC OGC LPL3-1/BC LPL3-1/PM NAME TBeltz MHenderson US hoop REIIiott BGanco DPelton TBeltz DATE 09/08/2014 10/03/2014 08/07/2014 10/10/2014 10/20/2014 10/29/2014 11/03/2014 OFFICIAL RECORD COPY