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Text

Day Response to NRC Bulletin 2011-01, Mitigating Strategies
	ML111890202
Person / Time
Site:	Monticello
Issue date:	07/07/2011
From:	O'Connor T; Northern States Power Co, Xcel Energy
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	BL-11-001, L-MT-11-041
	Download: ML111890202 (14)
	v • d • e

@ Xcel EnergyB July 7, 201 1 L-MT-11-041 10 CFR 50.54(f) U S Nuclear Regulatory Commission ATTN: Document Control Desk 1 1555 Rockville Pike Rockville, MD 20852 Monticello Nuclear Generating Plant Docket 50-263 Renewed Facility Operating License No. DPR-22 60-Dav Response to NRC Bulletin 201 1-01, "Mitigating Strategies"

Reference:

NRC Bulletin 201 1-01: "Mitigating Strategies," dated May 11, 201 1 On May 11, 201 1, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 201 1-01, "Mitigating Strategies" (Reference).

The NRC issued this Bulletin to achieve the following objectives:

1. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.54(hh)(2), 2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima-Daiichi facility in order to determine if

1) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and

3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).

The Bulletin requested each licensee to submit a written response within 30 days of the date of the Bulletin. This 30-day response letter was provided by Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, on June 10, 201

1. The Bulletin also requested that within 60 days of the date of this Bulletin that NSPM provide the following information on their mitigating strategies programs: How essential resources are maintained, tested and controlled to ensure availability; How strategies are re-evaluated if plant conditions or configurations change; and How arrangements are reached and maintained with local emergency response organizations.

2807 W County Road 75 Monticello, Minnesota 55362 Telephone: 763.295.5151 Document Control Desk L-MT-11-041 Page 2 of 2 The enclosure to this letter contains the 60-day response to the requested information pursuant to the provisions of 10 CFR 50.54(f) for the Monticello Nuclear Generating Plant (MNGP).

Summarv of Commitments This letter contains no new commitments and no changes to existing commitments.

y that the foregoing is true and correct. Executed on July 7, uclear Generating Plant Enclosure 1 - Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 cc: Administrator, Region Ill, USNRC NRR Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC Department of Commerce, State of Minnesota Enclosure 1 Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 On May 11, 201 1, the NRC issued Bulletin 201 1-01, Mitigating Strategies.

The Bulletin requested that within 60 days of the date of this Bulletin, licensees provide information on their NRC mitigating strategies programs.

The NRC questions related to the 60-day response are restated below followed by the Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, response for the Monticello Nuclear Generating Plant (MNGP). Many of the items described below represent current station practices. Individual items may be revised or adjusted in the future based on new or revised vendor recommendations, industry experience, etc., in accordance with established processes. Any changes involving commitments will be executed in accordance with NEI 99-04, Revision 0, Commitment Management Guidelines. Page 1 of 12 Enclosure 1 Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 Request: 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed. Examples of the types of information to include when providing your response to Question (1) are: a. Measures implemented to maintain the equipment, including periodicity.

b. Basis for establishing each maintenance item (e.g., manufacturer's recommendation, code or standard applicable to the craft). This should include consideration of storage environment impact on the maintenance necessary.

These examples are not meant to limit your response if you use other methods to address the issues described above. NSPM Response:

The maintenance activities listed below have been established to ensure that the procured B.5.b equipment can perform its intended function.

Equipment Portable Diesel Fire Pump Preventive Maintenance Check battery charger voltage, check battery fluid levels and add fluid if necessary, check and clean battery terminals, check battery voltage, and check and clean battery compartment as necessary. Change the mechanical seal oil Replace fuel system primary filterlwater separator, replace fuel, change oil and filter, replace fuel filter, and inspect belts and hoses. Check belt tension and replace air filter Grease motor adaptors if needed. lnspect volute for obstructions, check impeller wear plate clearances, inspect air compressor and ejector nozzle, and grease motor adaptors.

Inspect alternator, inspect, clean, and tighten the cylinder head grounding stud, clean engine crankcase breather, and lubricate fan drive bearing. Replace battery. Change the oil. Periodicity*

Triennially Biennially Basis Based on plant experience.

Vendor Recommendation.

Based on in-plant diesel fire pump battery history.

Based on plant experience.

Page 2 of 12 Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 1 Equipment Trucks Fire Equipment Trailers 125 VDC Battery Cart 2-112 Inch Stationary Monitor Oscillating Monitor Preventive Maintenance Empty fuel tank and refill with fresh fuel, check oil level, check coolant level, check battery, check tire pressure, visual tire inspection, check hydraulic levels if applicable, clean bedlbox or floor, check brake fluid level, clean vehicle interior, record current mileage, and start the vehicle. Check tire pressure, visual tire inspection, and clean bedlbox or floor. Replace batteries. Lubricate horizontal swivel joint, examine ground spikes, check inlet clappers, check the horizontal and vertical brakes, check wheel mechanisms function freely, check that wheel mechanisms function freely, check that the latch of the safety chain hook engages properly, and check to ensure both stop pins that limit vertical and horizontal movement are in place. Lightly grease each end of the piston and inspect ground spikes and safety straps for Annually Triennially Periodicity" Annually Annually Quarterly Basis Based on the maintenance check that is done on all site vehicles. Based on plant experience.

Vendor Specifications.

Vendor Recommendation.

wear. Grease the threaded portion of the elevation brake knob. Every Six Months

NOTE: The Preventative Maintenance program is condition based and frequencies are adjusted based on conditions found during maintenance and equipment performance.

The periodicity shown is the present frequency.

- NOTE: The periodicity had been adjusted for lowtinfrequent usage. For example, the pump vendor recommended maintenance frequency is 250 hours0.00289 days 0.0694 hours 4.133598e-4 weeks 9.5125e-5 months , which is not an appropriate frequency for a lowlinfrequently used pump. For the 250 hour0.00289 days 0.0694 hours 4.133598e-4 weeks 9.5125e-5 months recommended maintenance, most items will be performed every 10 years and some will be performed more frequently. All the above frequencies for the pump were reviewed and endorsed by the vendor.

Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 Request: 2. Describe in detail the testing of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed. Examples of the types of information to include when providing your response to Question (2) are: a. A description of any testing accomplished to ensure the strategies were initially feasible.

b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement

c. A description of the corrective action process used when the equipment fails to adequately perform its test.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

During the initial B.5.b program development, informal testing and time validations were performed to ensure the strategies were initially feasible: Spent Fuel Pool Water Delivery Time Validation (2008) A walk throughltable-top time validation was performed and concluded that water could be added to the spent fuel pool within 11 0 minutes, meeting the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months expectation. Spent Fuel Pool Water Fire Truck Delivery Demonstration (2007) The B.5.b portable fire pump was used to supply a City of Monticello Fire Department truck equipped with a ladder and hose capable of spraying water on the reactor building. Safety Relief Valve (SRV) Portable Power Supply (2007)

The B.5.b portable battery supply was tested under continuous load for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This test showed the portable battery supply will be capable of continuously supplying three SRV solenoids with a voltage greater than 125 VDC for at least 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . More recently, formal testinglevaluations were performed: Safety Relief Valve (SRV) Portable Power Supply (201

1) An engineering evaluation was performed to show that the SRV solenoids will be able to perform their function with 117 VDC. Therefore, with a supply voltage greater than 125 VDC and a minimum required voltage of 117 VDC, the B.5.b portable battery supply will be capable of supplying the voltage necessary to operate three SRVs for at least 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Spent Fuel Pool Water Delivery Demonstration (June 201

1) The B.5.b portable fire pump was used to pressure fire hoses to the reactor building. Hoses were also run, but not pressurized, in the Reactor Building, up to the spent fuel pool. These actions were completed in 92 minutes. Following this portion of the demonstration, a flow test was performed. Additional hose was added to compensate for elevation head loss to the spent fuel pool and a flow rate of 550 gpm was delivered Page 4 of 12 Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 from the B.5.b portable fire pump through hoses entirely outside the plant. Together, these demonstrations verified that 500 gpm could be delivered to the spent fuel pool within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . B.5.b Portable Fire Pump One Time Endurance Run (June 201

1) The B.5.b portable fire pump was successfully run at full load for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The following table describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.

Page 5 of 12 Equipment Godwin HL6M Portable Diesel Fire Pump 8 Inch Floating Suction Strainer Fire Hoses 125 VDC Battery Cart and Wall- Mounted 125 VDC Battery Charger Periodicity Quarterly Quarterly Annually Annually Triennially Annually Quarterly Surveillances Check proper operation of the pressure relief valve on the air compressor.

Every quarter the pump is run for 10 minutes to check functionality and the following maintenance is performed:

check hoses and connections for leaks, check fan belts for wear, check fuel level, check mechanical seal oil level, check engine speed, oil pressure, check coolant, check oil, coolant temperature, wiring and connections, check tire pressure on the trailer, and check trailer connection.

Also inspect water separator for water accumulation and drain as necessary. Same as quarterly surveillance plus the hoses are attached to the suction and discharge of the pump and run for 30 minutes. Check pump discharge pressure and calculate flow rate. Functionality is observed by acceptable operation of the Godwin HL6M Portable Diesel Fire Pump (OSP-FIR-0582). Fire hoses are hydrostatically tested at 200 to 225 psig every three years.

Re-rack and inspect fire hoses and gaskets. Check wiring and terminal connections, recording of input and output voltages as a check of acceptable operation. Additional checks include ripple voltage, float voltage, equalizing voltage, alarms, and current limits, checking the physical condition and cleaning of the charger and battery cabinet. Basis Based on plant experience.

Vendor Recommended.

Vendor Recommended. Based on plant observation.

10CFR50 Appendix R Based on plant experience.

Based on plant experience.

Vendor Recommendation. Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 The 10 CFR 50 Appendix B Corrective Action Program (CAP) is used to document failures, establish priorities for corrective actions and perform trending.

When an issue is identified a condition report is initiated, a management review team determines level of review required, and corrective actions are determined and implemented in accordance with the significance.

Equipment Self-contained Breathing Apparatus Nitrogen Bottles and Regulators Radios 150 Watt 12VDC to 110V AC Power Inverters Turnout gear (coats, Pants, Helmets, gloves, boots) Portable Lights (Flashlights, Quartz Lights, etc.) Tools (Includes 1-112" Double Hose Nozzles)

Dosimetry Page 6 of 12 Surveillances Inspect regulators, hoses, harness, face mask, and tank pressure for wear, deterioration, damage and cleanliness. Check cylinder pressure gauges greater than 2000 psig. Open and close valves, check alarms, functionally check the masks and regulators. Regulator certification by vendor. Bottles shall be certified.

Dispose of carbon fiber wrapped cylinders. Perform visual inspection and pressure check. Verify radios operational, then rotate in chargers. Check inverters for operability. lnspect for defects, wear, damage and deterioration Verify that lights are fully operational and are in good working condition.

Verify that handlight chargers are operational. Rotate handlights in chargers. Replace flashlight batteries if the light appears dim. Inspect for excessive wear, missing or damaged parts, cracks, deformities, and other signs that may indicate a drop in performance. Electronic Dosimeters: Change batteries if dead. Thermoluminescent dosimeters: Order new TLDs and replace old TLDs.

Periodicity Monthly (and after each use)

Quarterly (and after each use)

Annually Every 5 years Every 15 years Quarterly Quarterly Annually Annually Quarterly Quarterly Quarterly Annually Basis NRC Commitments M79006AI M79101AI M79007A and M85016A. Based on plant experience.

Based on plant experience.

Based on plant experience. Based on plant experience.

Based on plant experience.

Based on plant experience. Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 Request: 3. Describe in detail the controls for assuring that the equipment is available when needed.

Examples of the types of information to include when providing your response to Question (3) are: a. A description of any inventory requirements established for the equipment.

b. A listing of deficiencies noted in inventories for the equipment and corrective actions taken to prevent loss. These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

In addition to the controls described in responses 1 and 2, procured non -permanently installed B.5.b equipment is inventoried at least annually in accordance with station processes or procedures. This inventory assures the items are stored in the proper quantities and location.

Access to equipment storage locations is controlled by requiring personnel to obtain operations management permission prior to entering areas where equipment is stored. Inventory deficiencies are entered into the CAP. As of the date of this response, there are no outstanding inventory deficiencies that would render the strategies not viable. Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 Actions Performed Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities and check calibration dates Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Equipment Trucks and trailers for staging equipment Portable Diesel Fire Pump and battery charger Floating Suction Strainer and suction hose Fire Hose (5", 2 1/2" and 1-112 inch) nozzles, valves, splitters, monitors, manifolds, connectors, etc Portable Ventilation 125 VDC Battery Cart for SRV operation Battery Charger - Wall-Mounted 125 VDC Turnout gear ( coats, Pants, Helmets, gloves, boots) Self-contained Breathing Apparatus/Masks/Tanks Nitrogen Bottles and Regulators Radios and Chargers l nverters (1 2VDC to 1 10V AC) Instruments (including: Tachometer, Pyrometer, Multimeter) Portable Lights (Flashlights, Quartz Lights, etc.)

Dosimetry Tools (extension cords, hand tools, specialty tools, etc)

Rescue Equipmentlmedical supplies Fire extinguishers, foam etc.

Inventory Frequency Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly

Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Special Storage Controls Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 Request: 4. Describe in detail how configuration and guidance management is assured so that strategies remain feasible.

Examples of the types of information to include when providing your response to Question (4) are: a. Measures taken to evaluate any plant configuration changes for their effect on feasibility of the mitigating strategies.

b. , Measures taken to validate that the procedures or guidelines developed to support the strategies can be executed. These measures could include drills, exercises, or walk through of the procedures by personnel that would be expected to accomplish the strategies.

c. Measures taken to ensure procedures remain up-to-date and consistent with the current configuration of the plant.

d. A description of the training program implemented in support of the mitigating strategies and the manner in which you evaluate its effectiveness. These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response: Plant configuration changes are procedurally evaluated against the licensing basis, including the license conditions and their associated safety evaluation. Initially, mitigating strategies were validated by walkdowns, engineering evaluations andlor table top reviews. Subsequent procedure changes are validated to ensure that the guideline remains viable.

In 201 1, B.5.b mitigating strategies were revalidated by similar techniques. The training discussed below also validates that the associated mitigating strategies can be deployed.

The design change process requires a review of affected procedures and any necessary changes to be made. The mitigating strategy guidelines are controlled consistent with procedural controls under established administrative processes.

The following table describes the training program implemented in support of the mitigating strategies and the manner in which effectiveness is evaluated.

Page 9 of 12 Enclosure 1 Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 Page 10 of 12 Evaluation Testing Testing Drill and exercises Class participation Testing Periodicity NIA 2 years 2 years 2 years 2 years Station Personnel Operations ERO - Key decision makers Fire Brigade Security Training Training on the Extensive Damage Mitigation Guidelines is part of the Initial License Operator Training Program.

Licensed Operators are retrained per the License Operator Requalification Training Program Description per the biennial training plan described in the requalification program.

Emergency Directors (ED), Emergency Managers (EM), and Engineer Group Leaders (EGL) are initially trained in EDMG's per the MT-Training Program Description. Fire Brigade members are initially trained in Extensive Damage Mitigation Strategies in course and re-qualified per the Fire Brigade Training Program Description. Training on mitigating strategies was done as part of the implementation of B.5.b. Security EDMG actions are incorporated into Security Implementing Procedures, Contingency Plan Implementing Procedure and site procedures that are trained in initial training and are re-qualified per the Security Training Program Description. Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 Request: 5. Describe in detail how you assure availability of off-site support. Examples of the types of information to include when providing your response to Question (5) are: a. A listing of off-site organizations you rely on for emergency response.

b. Measures taken to ensure the continuity of memoranda of agreement or understanding or other applicable contractual arrangements. This should include a listing of periods of lapsed contractual arrangements.

c. A listing of any training or site familiarization provided to off-site responders.

This should include any measures taken to ensure continued familiarity of personnel of the off-site responders in light of turnover and the passage of time.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

The following off-site organizations are relied on for emergency response:

Page 11 of 12 Off-site Organization State of Minnesota City of Monticello (includes Monticello Fire Department)

Sherburne County Wright County General Electric Hitachi Nuclear Energy New River Medical Center Regions Hospital Implementing Document Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Date of Agreement 1211 712008 51231201 1 4/18/2011 1/26/2011 1/26/2011 7/6/2011 6/7/20 1 1 TraininglPeriodicity Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan. Annual familiarization training for the Monticello Fire Department is provided by the site. Annual training is provided to the City of Monticello via the MN Emergency Operations Plan, Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan. Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan.

NIA Annual familiarization training is provided by the Site. Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan.

Enclosure 1 Monticello Nuclear Generating Plant 60-Day Response to Bulletin 201 1-01 I Agreement Environmental, Inc. Midwest I Letter of 1 10/5/2010 1 NIA INPO TraininglPeriodicity Annual training provided by the State of Minnesota as stated in Minnesota Off-site Organization North Memorial Medical Center All Letters of Agreement are reviewed annually by procedure to ensure they are current and are renewed periodically.

Letter of Laboratory Pooled Inventory Management Department of Energy - Radiation Emergency Assistance CenterlTraining Site MNGP reviewed the corrective action program for issues involving lapsed Letters of Agreement related to B.5.b and found no examples of lapsed contractual agreements. All of the Letters of Agreement identified above meet the procedural requirements for renewal. However, the site identified during its review that the annual training for the New River Medical Center was offered but not provided in 201 0 at the discretion of the medical center. This item is being addressed though the site's CAP process. Implementing Document Letter of Agreement Page 12 of 12 Date of Agreement 1012512010 9/30/2010 Agreement Letter of Agreement Letter of Agreement Emergency Operations Plan.

NIA 1211 51201 0 91291201 0 NIA NIA