ML090090172
| ML090090172 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 09/25/2008 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML090090172 (4) | |
Text
1 PrairieIslandNPEm Resource From:
Richard Plasse Sent:
Thursday, September 25, 2008 6:10 AM To:
Eckholt, Gene F.
Subject:
Please review 'Prairie Island Scoping and Screening RAI BC Approved' Attachments:
Prairie Island Scoping and Screening RAI BC Approved.doc PleasereviewtheattacheddraftRAIs.
Hearing Identifier:
Prairie_Island_NonPublic Email Number:
282 Mail Envelope Properties (Richard.Plasse@nrc.gov20080925061000)
Subject:
Please review 'Prairie Island Scoping and Screening RAI BC Approved' Sent Date:
9/25/2008 6:10:22 AM Received Date:
9/25/2008 6:10:00 AM From:
Richard Plasse Created By:
Richard.Plasse@nrc.gov Recipients:
"Eckholt, Gene F." <Gene.Eckholt@xenuclear.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 45 9/25/2008 6:10:00 AM Prairie Island Scoping and Screening RAI BC Approved.doc 25594 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
Review
Prairie Island Nuclear Generating Plant Scoping and Screening Methodology Audit August 4-7, 2008 Request for Additional Information (RAI)
RAI 2.1-1 10 CFR 54.4(a)(1) requires that safety-related systems, structures, and components required to be within the scope of license renewal are those which are relied upon to remain functional during and following design basis events to ensure (i) the integrity of the reactor coolant pressure boundary; (ii) the capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10 CFR 50.34(a)(1), 50.67(b)(2), or 100.11. During the NRC scoping and screening methodology audit, performed August 4-7, 2008, the applicant stated that there were plant defined safety-related components which were not included within the scope for license renewal in accordance with 10 CFR 54.4(a)(1).
(A)
During the audit, the applicant stated that although the waste gas decay tanks were defined as safety related per the plants definition of safety related, they were not in scope for license renewal because they did not meet the above criteria (i), (ii), or (iii). Specifically for criteria (iii), the applicant stated that the plants criteria for safety-related was more conservative than the license renewal criteria because the Prairie Island Nuclear Generating Plant has committed to the more conservative 1% of the 10 CFR 100.11 exposure guidelines following a design basis accident. The applicant also documented that the term comparable in criteria (iii) has been defined by the nuclear industry as greater than or equal to 10% and the value is consistent with NRC guidance in Regulatory Guide 1.70, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants.
The staff requests that the applicant provide: (1) specific documentation, references, and citations that define the term comparable, as used in 10 CFR 54.4(a)(1)(iii), to be greater than or equal to 10% and (2) a description of the methods used and the basis for conclusions, in determining that the safety-related waste gas decay tanks would not be included within the scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(1).
(B)
During the audit, the applicant stated that the boric acid storage tanks were defined as safety-related per the plants definition, but were not within the scope of license renewal for 10 CFR 54.4(a)(1). The staff requests the applicant provide a description of the methods used and the basis for conclusions, in determining that the safety-related boric acid storage tanks would not be included within the scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(1).
RAI 2.1-2 10 CFR 54.4(a)(2) requires that all nonsafety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in 10 CFR 54.4(a)(1)(i-iii) be included within the scope off license renewal. During the NRC scoping and screening methodology audit, performed August 4-7, 2008, the applicant stated that there were certain nonsafety-related abandoned equipment which were not included within the scope for license renewal in accordance with 10 CFR 54.4(a)(2).
(A)
LRA Section 2.1.2.5.5 states, Abandoned equipment that is removed from the plant or disconnected and drained does not have a potential for spatial interaction (i.e. no fluids
contained in the SSC), and is not within the scope of License Renewal. Abandoned equipment that is installed and connected to plant process pipes needs to be evaluated for non-safety attached to safety and non-safety affecting safety spatial interaction scoping criteria.
During the scoping and screening methodology audit, the applicant stated that not all abandoned equipment had been verified as disconnected and drained. However, this abandoned equipment had not been included within the scope of license renewal. The staff requests the applicant provide a description of the methods used and the basis for conclusions, in determining that nonsafety-related abandoned systems and attached piping, which had not been verified as disconnected and drained, were not included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).