ML16113A346

Evaluations or Changes, Tests, and Experiments and Permanent Plant Modifications Baseline Inspection Report 05000263/2016008

ML16113A346
Person / Time
Site:	Monticello
Issue date:	04/19/2016
From:	Robert Daley Engineering Branch 3
To:	Gardner P Northern States Power Company, Minnesota
References
IR 2016008
Download: ML16113A346 (12)

See also: IR 05000263/2016008

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 April 19, 2016 Mr. Peter A. Gardner Site Vice President Monticello Nuclear Generating Plant Northern States Power Company, Minnesota 2807 West County Road 75 Monticello, MN 553629637 SUBJECT: MONTICELLO NUCLEAR GENERATING PLANT - EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000263/2016008 Dear Mr. Gardner: On March 24, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications inspection at your Monticello Nuclear Generating Plant. The enclosed inspection report documents the inspection results which were discussed on March 24, 2016, with Mr. M. Lingenfelter and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. No findings were identified during this inspection. In accordance with Title 10 of the Code of Federal Regulations of this letter, its enclosure, and your response (if any) will be available electronically for public component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /RA/ Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50263 License No. DPR22 Enclosure: IR 05000263/2016008 cc: Distribution via LISTSERV

Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-263 License No: DPR-22 Report No: 05000263/2016008 Licensee: Northern States Power Company, Minnesota Facility: Monticello Nuclear Generating Plant Location: Monticello, MN Dates: February 29 thru March 24, 2016 Inspectors: Alan Dahbur, Senior Reactor Inspector (Lead) Jorge J. Corujo-Sandín, Reactor Inspector Michael A. Jones, Reactor Inspector Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety

2 SUMMARY Inspection Report 05000263/2016008; 02/29/2016 03/24/2016; Monticello Nuclear Generating Plant; Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications. This report covers a 2-week announced baseline inspection on evaluations of changes, tests, and experiments and permanent plant modifications. The inspection was conducted by Region III based engineering inspectors. program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-, dated February 2014. NRC-Identified and Self-Revealed Findings No findings were identified. Licensee-Identified Violations No violations were identified.

3 REPORT DETAILS 1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R17 Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications (71111.17T) .1 Evaluation of Changes, Tests, and Experiments a. Inspection Scope The inspectors reviewed 7 safety evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR), Part 50, Section 59, to determine if the evaluations were adequate, and that prior U.S. Nuclear Regulatory Commission (NRC) approval was obtained as appropriate. The inspectors also reviewed 16 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if: the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required; the safety issue requiring the change, tests or experiment was resolved; the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and the design and licensing basis documentation was updated to reflect the change. The inspectors used, in part, Nuclear Energy Institute Document 96-10 CFR e acceptability of the completed evaluations, and screenings. The Nuclear Energy Institute document was endorsed by CFR 50.59, e inspectors also consulted Part CFR Guidance for 10 CFR This inspection constituted 4 samples of evaluations and 13 samples of screenings and/or applicability determinations as defined in Inspection Procedure 71111.17-04. b. Findings (Open) Unresolved Item 05000263/2016008-01, Failure to provide acceptable Alternate Methods of Decay Heat Removal Introduction: The inspectors identified an Unresolved Item associated with Technical Shutdown Cooling System Cold alternate methods of decay heat removal described in Operations Manual C.4-B.03.04.A, Loss of Normal Shutdown Cooling,ing resulting from the loss of one or two RHR subsystems while in MODE 4 with high decay heat load.

4 Description: The Limiting Condition for Operation (LCO) 3.4.8 of TS ual Heat Removal Shutdown Cooling System Cold Shutdown, required in Mode 4, two RHR shutdown cooling subsystems shall be operable, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation. The TS Bases Section 3.4.8, indicated that an operable RHR shutdown cooling subsystem consisted of one operable RHR pump, one heat exchanger, the associated piping and valves, and the necessary portions of the RHR Service Water System System capable of providing c The TS Bases Section 3.4.8 further indicated that the two subsystems have a common suction source and were allowed to have a common heat exchanger and common discharge piping. Thus, to meet the LCO, both pumps in one loop or one pump in each of the two loops must be operable. Since the piping and heat exchangers were passive components that were assumed not to fail, they were When TS 3.4.8, LCO could not be met, Condition A,one or two RHR shutdown cooling subsystems inoperable, method of decay heat removal was available for each inoperable RHR shutdown cooling hour, and once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter. The TS Bases 3.4.8 for Condition A indicated that with one of the two required RHR shutdown cooling subsystems inoperable, the remaining subsystem was capable of providing the required decay heat removal. However, the overall reliability was reduced, therefore, an alternate method of decay heat removal must be provided. With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability. This was to ensure the re-establishment of backup decay heat removal capabilities, similar to the requirements of the LCO. The bases further stated that the required cooling capacity of the alternate method should be ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature. Alternate methods that can be used included (but not limited to) the Reactor Water Cleanup System by itself or using feed and bleed in combination with Control Rod Drive System or Condensate/Feed Systems. Abnormal Procedure, Operations Manual C.4-removal. The inspectors noticed that except for the alternate method as described below in the G-EK-1-45, the licensee was not able to show by calculation or demonstration that the systems and methods credited in this procedure would be capable of providing sufficient heat removal capability or appropriate levels of redundancy as required by TS 3.4.8. The G-EK-1-45 was a General Electric Letter to Northern States Power, Subject: Cold Shutdown Capability Report, dated April 22, 1981. This letter provided a report which described the capability of the Monticello Nuclear Generating Plant to achieve cold shutdown using only safety class systems and assuming the worst single failure. The alternate shutdown decay heat removal method used in the report credited combinations of the RHR pumps and heat exchangers in the suppression pool cooling mode of RHR to ensure suppression pool water temperatures were below the design limit. This method utilized the core spray system and safety relief valves to circulate reactor inventory to remove decay heat from the reactor.

5 The inspectors noted that calculations supporting the above alternate strategy utilized an RHR subsystem that could be inoperable and/or unavailable and therefore may not be credited to comply with TS 3.4.8. Specifically, the inspectors were concerned that while the plant was in mode 4, with a credited one subsystem inoperable, the licensees credited alternate decay heat removal method that relied on an RHR subsystem, to perform the required suppression pool cooling function. The inspectors were concerned that relying on the only operable RHR subsystem for the alternate method did not meet the intent of the TS requirement as described in the TS Bases. Furthermore, the inspectors noticed for Mode 4 with two RHR subsystems inoperable, the licensee failed to verify by calculation or demonstrations that two additional redundant alternate decay heat removal methods existed with sufficient capacity to maintain the average reactor coolant temperature below 212 degrees Fahrenheit. During the inspection, the licensee indicated that the Boiling Reactor Owners Group was in the process of developing a draft TS Task Force Traveler to address the requirement of TS 3.4.8 and its Bases. Based on the information above, the inspectors were concerned that the plant Operations Manual was inadequate and failed to include alternate decay heat removal methods that would enable the licensee to comply with the requirement of TS 3.4.8. The Othat written procedures shall be established, implemented, and maintained covering the emergency operating procedures. The inspectors determined that this issue was unresolved pending the actions by the licensee and the Boiling Reactor Owners Group and the NRC review of these actions. The licensee entered to their Corrective Action Program as AR 01516098. (URI 05000263/2016008-01, Failure to provide acceptable Alternate Methods of Decay Heat Removal) .2 Permanent Plant Modifications a. Inspection Scope The inspectors reviewed seven permanent plant modifications that had been installed in the plant during the last 3 years. This review included in-plant walkdowns portions of the high-pressure coolant injection steam drain line system, the Emergency Diesel Generator Fuel Oil Transfer System, including the Diesel Fuel Oil pump house, the new diesel fuel oil pumps installed in the day tank room, and portions of the fuel oil storage tank tornado missile protection modifications. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if: the supporting design and licensing basis documentation was updated; the changes were in accordance with the specified design requirements; the procedures and training plans affected by the modification have been adequately updated; the test documentation as required by the applicable test programs has been updated; and post-modification testing adequately verified system operability and/or functionality.

6 The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an Attachment to this report. This inspection constituted eight permanent plant modification samples as defined in Inspection Procedure 71111.17-04. 4. OTHER ACTIVITIES 4OA2 Problem Identification and Resolution .1 Routine Review of Condition Reports a. Inspection Scope The inspectors reviewed several corrective action process documents that identified or were related to Title 10 of the Code of Federal Regulations, Part 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent plant modifications and evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report. b. Findings No findings were identified. 4OA6 Management Meetings .1 Exit Meeting Summary On March 24, 2016, the inspectors presented the inspection results to Mr. M. Lingenfelter, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material provided to the inspection team was identified and will be dispositioned in accordance with applicable processes. ATTACHMENT: SUPPLEMENTAL INFORMATION

Attachment SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee M. Lingenfelter, Director of Engineering A. Gonnering, Design Engineering M. Kelly, Performance Assurance Manager J. Gausman, Engineering A. Ward, Regulatory Affairs Manager T. Hurrle, Design Engineering Manager B. Halvorson, Engineering A. Kouba, Regulatory Affairs D. Alstad, Design Engineer E. Watzel, Electrical Design Engineering Supervisor U.S. Nuclear Regulatory Commission P. Zurawski, Senior Resident Inspector P. LaFlamme, Acting Senior Resident Inspector D. Krause, Resident Inspector LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Opened 05000263/2016008-01 URI Failure to provide acceptable Alternate Methods of Decay Heat Removal (Section 1R17.1b) Closed and Discussed None LIST OF ACRONYMS USED ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations LCO Limiting Condition for Operation NRC U.S. Nuclear Regulatory Commission PARS Publicly Available Records System RHR Residual Heat Removal TS Technical Specifications

2 LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report. 10 CFR 50.59 EVALUATIONS Number Description or Title Revision SCR-12-0559 HPCI Logic Change to Provide Margin to MO-2035 and #16 Battery 1 SCR-13-0554 External Flooding Protection Strategy Change 0 SCR-15-0202 Evaluation of EPG/SAG, Revision 3 0 SCR-16-0024 Disconnect Faulty 46-19 PIP Over-Travel Input 0 10 CFR 50.59 SCREENINGS Number Description or Title Revision SCR-13-0696 Revise EDG Base Tank Fuel Oil Level Calculation 90-023 0 SCR-14-0074 Time Delay Relay 97-29 and 97-31 Setpoint Change 0 SCR-14-0413 Temp Rev to C.6-006-A-01and C.6-006-A-02 SCR-14-0415 USAR-06.06 Revision 0 SCR-14-0421 EC 23981 EDG Fuel Oil Tank Vent Lines Missile Protection 0 SCR-14-0512 Safety and Seismic Classification of the DG/RF and DG/RV Relays 0 SCR-14-0542 RHRSW and Emergency Service Water TS Bases Changes SCR-14-0591 Fuel Oil Separation 4 SCR-14-0593 Revise Calculation 94-086 on SRV Accumulation Allowable Leakage Rates 0 SCR-15-0093 EDG ESW Basket Strainer Modification SCR-15-0115 C.4-B.09.02.A Revision to Resolve CAP AR 01465720 1 SCR-15-0193 Room Heat Up Calculation Revisions for SBO SCR-15-0291 Revise Maximum Volume of EDG Base Tank in 90-023 0 SCR-15-0292 Diesel Pump House Heat Up Calculation 0 CALCULATIONS Number Description or Title Revision 03-089 Inservice Testing Acceptance Criteria 3 09-106 CSP Motor-Oil and Bearing Operating Temperatures without Cooling Water 1 09-176 Evaluation for Debris Disposition in Supply Pipe and Motor Cooler Tube 0 09-178 Time to reach the RHRSW Pump Motor Cooling Line Strainer Limiting Pressure Differential 0 14-025 Instrument Setpoint Calculation Time Delay for Transfer to EDG on Loss of Voltage 0 90-023 EC 23085 EDG Fuel Oil Train Separation 3 92-224 Emergency Diesel Generator Loading 6A 94-086 Max Allowed Leakage Rates and Test Acceptance Criteria for SRV 5

3 CORRECTIVE ACTION PROGRAM DOCUMENTS INITIATED DURING INSPECTION Number Description or Title Date 1510936 Incomplete EC Record Copy 02/03/2016 1514133 Clarification for USAR Section 8.4.1.3 03/01/2016 1514202 Page missing from WO 00491265 Record 03/02/2016 1514369 Screening SCR 14-0421 Answered Question Incorrectly 03/03/2016 1514464 EDG Building Roof FOI 91-0265 03/03/2016 1515054 Bases for Procedure A.6 Contain Incorrect Statements 03/09/2016 1515688 Signs of Leakage around FO-11-3 03/15/2016 1515716 NRC not Provided with Latest Copy of EC23085 03/15/2016 1515907 Formal Evaluation for HPCI Drain Line Bypass Flow 03/16/2016 1515939 Question Raised on CRD 46-19 03/16/2016 1516098 Actions for when LCO 3.4.8, RA A.1 not met Unclear 03/17/2016 1516101 Core Spray Motor Cooling Design Basis Question 03/17/2016 1516105 HPCI SR Test Inconsistent with TS Bases 03/17/2016 1516106 RCIC Surveillance Required Test Inconsistent with TS Bases 03/17/2016 CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date 952310 M91064A Quarterly Backflushing of Residual Heat Removal system and Core Spray Pump Motors 07/27/1991 01196451 CDBI EDG Base Tank Volume Calculation CA 90-023 09/03/2003 01355853 Update UFSAR for External Flooding Description Discrepancy 10/22/2012 01414416 Diesel Fuel Oil Temperature in Fuel Oil Transfer House is not Known 12/17/2013 01420875-03 Condition Evaluation on EDG Base Tank Level Issues 04/04/2014 01424477 Appendix R Fire Strategy for Fire Area XII incorrect 03/27/2014 1478798 EG Transfer Relay not Classified as Safety Related 05/13/2015 1484554 RHRSW-29-2 Handwheel/Stem Sheared off 06/29/2015 1502700 Catastrophic fail of MO-1900 11/19/2015 DRAWINGS Number Description or Title Revision NF-36175 Single Line Diagram Station Connections 85 104B2506 Connection Diagram Control Rod Drive Position Indicator Probe NH-46250 P&ID High Pressure Coolant Injection System 83 NE-36399-9 Essential Bus Transfer Circuit Division I 77 NE-36399-9B Essential Bus Transfer Circuits Division II 78 NF-36061 Equipment Location - 76 NF-36750 Standby Diesel Generator Building 8 NH-36241-1 Reactor Pressure Relief P&ID 78 NH-36051 P&ID Diesel Oil System 85 NH-178639-1 Levee Alignment and Bin Wall Plan 4 NF-119034-1 #11/#12 DG Fuel Oil System Isometric 78 NH-36253 P&ID Standby Liquid Control System 80 NH-36249 P&ID (Steam Side) High Pressure Coolant Injection System 82 NX-13142-42 Primary Steam & HPCI System 78

4 MODIFICATIONS Number Description or Title Revision EC-14065 RHRSW Motor Cooler Strainers 1 EC-20887 LT-5200 River Level Setpoint Change for Upper Value EC-21934 Evaluation of Corrosion Found in the 11 EDG Coolant Expansion Tank 0 EC-21999 Equivalency Evaluation: RHRSW-17 is the emergency injection check valve for the RHR to RSW crosstie 0 EC-22008 Monticello 125V #12 Battery Modified Performance Test Profile 0 EC-22414 SQUG Evaluation of Diesel Oil Service Pump P-77 0 EC-23085 EDG Fuel Oil Train Separation 0 EC-23272 Revise EDG Base Tank Fuel Oil Level Calc 90-023 EC-23616 Revise Setpoints for Relays 97-29 and 97-31 0 EC-23857 Recirc Pump Seal Water Piping 0 EC-25889 Operating with HPCI CV-2043 (Steam Trap Bypass) Open 0 EC-25266 EDG Fuel Oil Separation 0 OTHER DOCUMENTS Number Description or Title Date or Revision 10040-A-020 Technical Specification for Steel Roof Deck 2 FOI 91-0265 Qualification of the EDG Building Roof for Accumulated Snow Load 04/18/1994 FG-E-SE-03 50.59 Resource Manual 5 WO 00505386-30 EC23085 Pre-Op Testing Division I 05/06/2015 WO 00505386-29 EC23085 Pre-Op Testing Division II 04/26/2015 257HA354 Technical Specification for High Pressure Coolant Injection System 2 G-EK-1-45 Cold Shutdown Capability Report 04/22/1981 SRI 95-002 Core Spray Pump Motor Without Water Cooling 09/28/1995 EE 25506 RFO27 Decay Heat Evaluation PROCEDURES Number Description or Title Revision 0075 Control Rod Drive Coupling Test 19 C.06-006-C-01 Diesel Oil Storage Tank T-44 Hi Low Level 6 C.06-006-C-02 Diesel Oil Storage Tank T-44 Low-Low Level 6 C.06-006-C-03 Division 1 EDG P-160A & P-160C Not Running 6 C.06-006-C-06 Diesel Gen Tank T-160A Level/Flow Low 4 2014-02 Turbine Building Outside 27 A.6 Acts of Nature 53 0255-17-ID-1 Master Alternate Nitrogen System Tests 25 0255-17-ID-15 SRV RV-71D and RV-2-71G Pneumatic Supply Leakage Test 13 Ops Man C.4-B.03.04.A Loss of Normal Shutdown Cooling 15 1339 ECCS Pump Motor Cooler Flush 35 9111-01 Shutdown Cooling Division I Protected System Ticket Checklist 6 2270 Critical Safety System Checklist 11 OWI-02.03 Operator Rounds, Turbine Building West 64 Ops Man B. 03.01-05 Core Spray Cooling System 42 0255-05-1A-1-2 B RHR SW Quarterly Pump and Valve Test 82

April 19, 2016 Mr. Peter A. Gardner Site Vice President Monticello Nuclear Generating Plant Northern States Power Company, Minnesota 2807 West County Road 75 Monticello, MN 553629637 SUBJECT: MONTICELLO NUCLEAR GENERATING PLANT - EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000263/2016008 Dear Mr. Gardner: On March 24, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications inspection at your Monticello Nuclear Generating Plant. The enclosed inspection report documents the inspection results which were discussed on March 24, 2016, with Mr. M. Lingenfelter and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. No findings were identified during this inspection. In accordance with Title 10 of the Code of Federal Regulations this letter, its enclosure, and your response (if any) will be available electronically for public inspecPublic Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /RA/ Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50263 License No. DPR22 Enclosure: IR 05000263/2016008 cc: Distribution via LISTSERV DISTRIBUTION: Jeremy Bowen RidsNrrPMPalisades Resource RidsNrrDorlLpl3-1 Resource RidsNrrDirsIrib Resource Cynthia Pederson Darrell Roberts Richard Skokowski Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Jim Clay Carmen Olteanu ROPreports.Resource@nrc.gov ADAMS Accession Number ML16113A346 Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII RIII NAME ADahbur:cl RDaley DATE 04/19/16 04/19/16 OFFICIAL RECORD COPY