ML071700568

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Correction Letter - Extension of Technical Specifications 3.8.1 AC Source-Operating, Emergency Diesel Generators (DG) Completion Time
ML071700568
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 07/05/2007
From: Mahesh Chawla
NRC/NRR/ADRO/DORL/LPLIII-1
To: Wodley M
Nuclear Management Co
Chawla M, NRR/DORL, 415-8371
References
TAC MC9001, TAC MC9002
Download: ML071700568 (7)


Text

July 5, 2007 Mr. Michael D. Wodley Site Vice President Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC 1717 Wakonade Drive East Welch, MN 55089

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 -

CORRECTION OF SAFETY EVALUATION SUPPORTING AMENDMENT NOS.

178 AND 168 (TAC NOS. MC9001 AND MC9002)

Dear Mr. Wodley:

On May 30, 2007, the Nuclear Regulatory Commission (NRC) issued Amendment No.178 to Facility Operating License No. DPR-42 and Amendment No.168 to Facility Operating License No. DPR-60 for Prairie Island Nuclear Generating Plant, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated November 21, 2005, supplemented by letters dated June 16, August 31, September 29, and October 30, 2006, March 15, and May 10, 2007.

Subsequent to issuance of the amendment, Mr. Dale Vincent of your staff pointed out that the safety evaluation (SE) supporting the amendments did not correctly reflect some of the commitments made by your submittals. Also, a reference section was missing from the SE.

These errors are corrected by the attached pages 19 thru 22; please use these pages to replace corresponding pages in the SE.

These corrections do not change the conclusion reached in the SE. We regret any inconvenience these errors may have caused.

Sincerely,

/RA by P. Tam for/

Mahesh L. Chawla, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306

Enclosures:

Safety Evaluation cc w/encls: See next page

July 5, 2007 Mr. Michael D. Wodley Site Vice President Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC 1717 Wakonade Drive East Welch, MN 55089

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 -

CORRECTION OF SAFETY EVALUATION SUPPORTING AMENDMENT NOS.

178 AND 168 (TAC NOS. MC9001 AND MC9002)

Dear Mr. Wodley:

On May 30, 2007, the Nuclear Regulatory Commission (NRC) issued Amendment No.178 to Facility Operating License No. DPR-42 and Amendment No.168 to Facility Operating License No. DPR-60 for Prairie Island Nuclear Generating Plant, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated November 21, 2005, supplemented by letters dated June 16, August 31, September 29, and October 30, 2006, March 15, and May 10, 2007.

Subsequent to issuance of the amendment, Mr. Dale Vincent of your staff pointed out that the safety evaluation (SE) supporting the amendments did not correctly reflect some of the commitments made by your submittals. Also, a reference section was missing from the SE.

These errors are corrected by the attached pages 19 thru 22; please use these pages to replace corresponding pages in the SE.

These corrections do not change the conclusion reached in the SE. We regret any inconvenience these errors may have caused.

Sincerely,

/RA by P. Tam for/

Mahesh L. Chawla, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306

Enclosures:

Safety Evaluation cc w/encls: See next page DISTRIBUTION PUBLIC LPL3-1 r/f RidsNrrDorlLple RidsNrrPMMChawla RidsNrrLATHarris RidsOGCRp RidsAcrsAcnwMailCenter RidsNrrDirsltsb G. Hill, OIS RidsRgn3MailCenter GWilson RidsNrrDorlDpr OChopra OHopkins SLaur MRubin TKobetz RClark Adams Accession: ML071700568 OFFICE LPL3-1/PM LPL3-1/LA EEEB/BC OGC LPL3-1/(A)BC NAME PTam for MChawla THarris GWilson JRund TTate PM for DATE 7/3/07 6/25/07 6/27/07 6/28/07 7/5/07 OFFICIAL RECORD COPY

Prairie Island Nuclear Generating Plant, Units 1 and 2 cc:

Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Manager, Regulatory Affairs Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC 1717 Wakonade Drive East Welch, MN 55089 Manager - Environmental Protection Division Minnesota Attorney Generals Office 445 Minnesota St., Suite 900 St. Paul, MN 55101-2127 U.S. Nuclear Regulatory Commission Resident Inspector's Office 1719 Wakonade Drive East Welch, MN 55089-9642 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Administrator Goodhue County Courthouse Box 408 Red Wing, MN 55066-0408 Commissioner Minnesota Department of Commerce 85 7th Place East, Suite 500 St. Paul, MN 55101-2198 Tribal Council Prairie Island Indian Community ATTN: Environmental Department 5636 Sturgeon Lake Road Welch, MN 55089 Nuclear Asset Manager Xcel Energy, Inc.

414 Nicollet Mall, R.S. 8 Minneapolis, MN 55401 Michael B. Sellman President and Chief Executive Officer Nuclear Management Company, LLC 700 First Street Hudson, MI 54016 Douglas E. Cooper Senior Vice President and Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 July 2006 Maintenance is not scheduled that is highly likely to exceed a TS or Technical Requirements Manual CT requiring a plant shutdown. For activities that are expected to exceed 50 percent of a TS CT, a voluntary LCO plan is developed to minimize SSC unavailability, maximize SSC reliability, and ensure contingency and compensatory actions are in place.

For Maintenance Rule risk-significant SSCs, the impact of the planned activity on the unavailability performance criteria is evaluated.

As a final check, a quantitative risk assessment is performed to ensure that the activity does not pose any unacceptable risk. This evaluation is performed using the current Level 1 PRA model. The results of the risk assessment are classified by a color code based on the increased risk of the activity. Increasing levels of risk require increasing management approval.

Plant operation's management during non-business hours reviews emergent work to ensure that it does not invalidate risk analyses made during the work management process, and if it does, they are capable of updating the risk analyses.

If the risk of losing offsite power increases as a result of severe weather or as a result of unavailability or degradation of an offsite source, the CRMP is able to reflect this in the risk analysis.

In response to a staff question, the licensee confirmed that the CRMP in use at PINGP does not credit recovery of the OOS equipment.

Based on the licensees description of their CRMP, the staff finds that the licensees third tier risk evaluation is acceptable.

4.5 Staff Findings In summary, the staff finds that the licensee's proposed change to extend the CT associated with TS 3.8.1 Required Action B.4 from 7 days to 14 days is acceptable because the five key principles of risk-informed decision-making identified in RG 1.174 and RG 1.177 have been satisfied. Thus, the staff has concluded that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in this manner; (2) 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.

5.0 REGULATORY COMMITMENTS The licensee made the following commitments in References 1 and 2, to be put into effect upon implementation of the requested license amendment. In its May 10, 2007 letter (Reference 9), the l

licensee resubmitted the list to include new commitments and revision to some of the earlier l

commitments.

l Procedures shall be established to assure that the following provisions are invoked when an EDG is inoperable for an extended CT in TS 3.8.1 Condition B.

1.

The condition of the offsite power supply and switchyard will be evaluated prior to entering the extended EDG CT for elective maintenance. NMC will develop a procedure to Revised by letter of 7/5/07 l

determine acceptable grid conditions for entering an extended EDG CT to perform electivemaintenance. An extended EDG CT will not be entered to perform elective maintenance when grid stress conditions are high such as during extreme summer -

temperatures or high demand.

2.

No elective maintenance will be scheduled in the switchyard that would challenge offsite power availability and no elective maintenance will be scheduled on the main, auxiliary, or startup transformers associated with the unit during the proposed extended EDG CT.

3.

The system dispatcher will be contacted once per day to ensure no significant grid perturbations are expected during the extended EDG CT. The system dispatcher will be informed of the EDG status, the power needs of the facility and requested to inform PlNGP if conditions change such that unacceptable voltage would occur following a unit trip.

4.

The LCO statement requirements of TS 3.8.1 and TS 3.8.9, for safeguards ac buses will be met on the opposite unit (regardless of mode) during the extended EDG CT (required emergent corrective maintenance or TS required surveillance testing on EDGs, offsite paths or safeguards ac buses may be performed).

5.

The turbine-driven AFW pump on the associated unit will not be removed from service for planned maintenance activities during the extended EDG CT.

6.

Assure operating crews are briefed on the EDG work plan and procedural actions regarding:

o LOOP and SBO o 4 kV safeguards bus cross-tie o Reactor Coolant System bleed and feed 7.

Weather conditions will be evaluated prior to entering the extended EDG CT for elective maintenance. An extended EDG CT will not be entered for elective maintenance purposes if official weather forecasts are predicting severe conditions (tornado or thunderstorm warnings).

8.

12 and 22 cooling water (CL) pumps will be operable and 121 CL pumps will be available and aligned to the operable Unit 2 EDG when a Unit 2 EDG is in an extended CT, except required emergent corrective maintenance or TS-required surveillance testing on these CL pumps or Unit 2 EDGs may be performed if required.

9.

Assess the overall impact of maintenance on plant risk using a Configuration Risk Management Program before entering TS 3.8.1 Condition B for planned EDG maintenance activities.

10.

Verify that the safeguards bus cross-tie between the Unit 1 and Unit 2 safeguards buses are available before entering the TS 3.8.1 Condition B for extended EDG maintenance activities.

11.

By August 31, 2007, NMC shall submit a License Amendment Request which proposes l

changes to the Technical Specifications in Appendix A, similar to current plant procedural practices, which will require the Unit 1 monthly Emergency Diesel Generators load test (SR 3.8.1.3) to be performed at or above 90% of the diesel generators continuous power rating.

Revised by letter of 7/5/07 l

l 12.

By October 31, 2007, NMC shall submit a License Amendment Request which proposes l

changes to the Technical Specifications in Appendix A which will require the 24-hour Emergency Diesel Generators load test (SR 3.8.1.9) to be performed at or below a specified power factor. These changes shall be consistent with the guidance in NUREG-1431, Improved Technical Specifications, Westinghouse Plants, Revision 3.1, SR 3.8.1.14.

The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitment(s) are best provided by the licensee's administrative processes, including its commitment management program. The above regulatory commitments do not warrant the creation of regulatory requirements (i.e., items requiring prior NRC approval of subsequent changes).

6.0 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.

7.0 ENVIRONMENTAL CONSIDERATION

The amendment changes the requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The 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 (71 FR 151). 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.

8.0 REFERENCES

l l

(1)

Letter from Thomas J. Palmisano, Nuclear Management Company, LLC to U.S. Nuclear l

Regulatory Commission, License Amendment Request (LAR) For Extension Of Technical l

Specification (TS) 3.8.1, AC Sources-Operating, Emergency Diesel Generator l

Completion Time L-PI-05-036, November 21, 2005 (ADAMS Accession number l

ML053260088).

l l

(2)

Letter from Thomas J. Palmisano, Nuclear Management Company, LLC to U.S. Nuclear l

Regulatory Commission, Supplement to License Amendment Request (LAR) For Extension l

Of Technical Specification (TS) 3.8.1, AC Sources-Operating, Emergency Diesel l

Generator Completion Time (TAC Nos. MC9001 and MC9002) L-PI-06-031, June 16, 2006 l

(ADAMS Accession number ML062050567).

l l

(3)

Letter from Thomas J. Palmisano, Nuclear Management Company, LLC to U.S. Nuclear l

Regulatory Commission, Supplement to License Amendment Request (LAR) For Extension l

Of Technical Specification (TS) 3.8.1, AC Sources-Operating, Emergency Diesel l

Generator Completion Time (TAC Nos. MC9001 and MC9002), L-PI-06-069, August 31, l

2006 (ADAMS Accession number ML062430624).

l l

l Revised by letter of 7/5/07 l

l l

(4)

Letter from Thomas J. Palmisano, Nuclear Management Company, LLC to U.S. Nuclear l

Regulatory Commission, Supplement to License Amendment Request (LAR) For l

Extension Of Technical Specification (TS) 3.8.1, AC Sources-Operating, Emergency l

Diesel Generator Completion Time (TAC Nos. MC9001 and MC9002), L-PI-06-069, Sept.

l 29, 2006 (ADAMS Accession number ML062750470).

l l

(5)

Letter from U.S. Nuclear Regulatory Commission to Roger O. Anderson, Northern States l

Power Company, Staff evaluation of the Prairie Island Nuclear Generating Plant Individual l

Plant Examination (IPE) Submittal, May 16, 1997 (ADAMS Accession number l

ML9705290036).

l l

(6)

Letter from U.S. Nuclear Regulatory Commission to Joel Sorenson, Nuclear Management l

Company, LLC, Prairie Island Nuclear Generating Plant, Units 1 and 2 - Review of l

Individual Plant Examination of External Events (IPEEE) Submittal, May 29, 2001 (ADAMS l

Accession number ML011490017).

l l

(7)

Letter from Thomas J. Palmisano, Nuclear Management Company, LLC to U.S. Nuclear l

Regulatory Commission, Supplement to License Amendment Request (LAR) For Extension l

Of Technical Specification (TS) 3.8.1, AC Sources-Operating, Emergency Diesel l

Generator Completion Time (TAC Nos. MC9001 and MC9002), L-PI-06-077, Oct. 30, 2006 l

(ADAMS Accession number ML063040574) l l

(8)

Letter from Edward J. Weinkam, Nuclear Management Company, LLC to U.S. Nuclear l

Regulatory Commission, Supplement to License Amendment Request (LAR) For Extension l

Of Technical Specification (TS) 3.8.1, AC Sources-Operating, Emergency Diesel l

Generator Completion Time (TAC Nos. MC9001 and MC9002), L-HU-07-009, March 15, l

2007 (ADAMS Accession number ML070750177) l l

(9)

Letter from Michael D. Wadley, Nuclear Management Company, LLC to U.S. Nuclear l

Regulatory Commission, Supplement to License Amendment Request (LAR) For Extension l

Of Technical Specification (TS) 3.8.1, AC Sources-Operating, Emergency Diesel l

Generator Completion Time (TAC Nos. MC9001 and MC9002), L-PI-07-039, May 10, 2007 l

(ADAMS Accession number ML071310108) l l

9.0 CONCLUSION

l 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) 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.

Principal Contributors: Ogbana Hopkins Stephen Laur Om Chopra Date: July 5, 2007 Revised by letter of 7/5/07 l