Text

Day Response to NRC Bulletin 2011-01, Mitigating Strategies.
	ML111930159
Person / Time
Site:	Prairie Island
Issue date:	07/11/2011
From:	Schimmel M; Northern States Power Co, Xcel Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BL-11-001, L-PI-11-069
	Download: ML111930159 (15)
	v • d • e

July 11, 201 1 L-PI-11-069 10 CFR 50.54(f)

U S Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Prairie Island Nuclear Generating Plant, Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 60-Dav Response to NRC Bulletin 201 1-01, "Mitigating Strategies"

Reference:

NRC Bulletin 201 1-01, "Mitigating Strategies," dated May 11, 201 1 (MLI 11250360).

On May 1I , 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 (10 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

. I ) 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, doing business as Xcel Energy (hereafter "NSPM"), on June 9,201 1.

1717 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1121

Document Control Desk Page 2 The Bulletin also requested that within 60 days of the date of the Bulletin that NSPM provide the following information on their mitigating strategies:

' 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.

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 Prairie Island Nuclear Generating Plant (PINGP).

Summaw of Commitments This letter contains one new commitment and no changes to existing commitments. In response to Question 4 in the Enclosure, NSPM makes the following commitment:

NSPM will include a requirement for continuing training on Extensive Damage Mitigation Guidelines (EDMG) in the PINGP training program for the Emergency Response Organization (ERO) qualified decision makers by January 13,2012.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 11, 201 1.

L Mark A. Schimmel Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC

Prairie Island Nuclear Generating Plant Enclosure I 60-Day Response for NRC 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 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, doing business as Xcel Energy (hereafter "NSPM"), response for the Prairie Island Nuclear Generating Plant'(PINGP).

The items described below represent current plant 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, "Guidelines for Managing NRC Commitment Changes."

Page 1 of 13

Prairie Island Nuclear Generating Plant 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 in Table Ihave been established to ensure that the equipment procured to support the B.5.b mitigation strategies is functional when needed.

Table 1 Preventative Maintenance Equipment Preventive Maintenance periodicity* Basis 125 VDC Replace batteries. 30 months Vendor Battery Cart Specifications.

Portable Diesel Change engine oil and filter. Annually Based on plant Fire Pump experience.

Replace fuel filter. Annually Based on plant experience.

Check battery condition. Annually Based on plant experience.

Inspect and clean (if necessary) Annually Based on plant radiator coils. experience.

Inspect all hoses and belts for Annually Based on plant wear and tension. experience.

Replaceladjust as necessary.

Inspect engine air cleaner for Annually Based on plant excessive dirt. Replace filter as experience.

required.

Check gauges and hour meter Annually Based on plant for damage. Repairlreplace as experience.

necessary.

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Prairie Island Nuclear Generating Plant 1 Equipment I Preventive Maintenance I periodicity' I Basis I Verify lug nuts tight on wheels. Annually Based on plant experience.

Verify proper air pressure in Annually Based on plant tires. Adjust as necessary. experience.

Verify jack stands operational Annually Based on plant and in good condition. Lubricate experience.

with grease.

Remove compressor guards and Annually Based on plant inspect the compressor belt, oil experience.

lines and air lines, checking for wear. Replace as necessary.

Change the mechanical seal oil. Annually Based on plant experience.

Replace display panel battery. 8 years Based on plant experience.

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.

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Prairie Island Nuclear Generating Plant Request:

2. Describe in detail the testing of equipment procured to support the strategies arid 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 development of the B.5.b mitigating strategies, NSPM validated strategies by performing engineering evaluations, time validations and/or tabletop reviews. The following Table 2.a describes the testing and evaluations accomplished to verify the initial feasibility of the mitigating strategies.

Table 2.a - Mitigating Strategies Validation Strategy Description External Spent Fuel Pool Time validation performed to demonstrate water could Makeup be delivered within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Portable diesel fire pump and I 0 0 foot aerial fire truck tested. A plant walkdown and an engineering evaluation completed to analyze the B.5.b flow path scenarios.

Internal Spent Fuel Pool A plant walkdown and an engineering evaluation Makeup completed to analyze the B.5.b flow path scenarios.

Spent Fuel Pool Spray Engineering evaluation completed to analyze the B.5.b flow path scenarios.

Steam Generator Injection Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.

Containment Flooding Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.

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Prairie Island Nuclear Generating Plant Strategy Description Refueling Water Storage Tank Engineering evaluation completed to analyze the Makeup B.5.b flow path scenarios.

Condensate Storage Tank Engineering evaluation completed to analyze the Makeup B.5.b flow path scenarios.

Remote Battery Operation of Engineering evaluation completed to ensure battery the PORV capable of supplying power to the solenoids.

The following Table 2.b describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.

Table 2.b - Surveillances Equipment Surveillances Periodicity Basis Portable General unit inspection is performed prior Quarterly Vendor Diesel Fire to performing the test. The oil, coolant, Recommended.

Pump fuel, and mechanical seal level is checked.

The trailer is attached to the truck and Quarterly Vendor transported to test location. Pump is run Recommended.

for 5-10 minutes at 1500-2000 rpm and then reduced to 900 rpm for an additional 3 minutes. The engine operating data (coolant temperature, oil pressure, etc.) is recorded.

Perform general visual inspection of Quarterly Vendor diesel and pump (i.e., engine hoses, Recommended.

clamps, connections, etc.)

Similar to quarterly surveillance, plus Annual Vendor hoses are attached to the suction and Recommended.

discharge of the pump and run for 30 minutes. The pump is also run at elevated rpm to obtain flow vs, pressure data.

Pagers Tested weekly to verify that pagers used Weekly Based on plant for Emergency Response are functional. experience.

Cell Phone Ensure the functionality of the Emergency Every other Based on plant Operations Facility cellular telephone. month experience.

Radios Check the functionality of the radios every Quarterly Based on plant quarter. experience.

Prairie Island Nuclear Generating Plant

~ ~ u i b e n t Surveillances Periodicity Basis Fire Hoses Fire hoses are hydrostatically tested Biennially 10 CFR 50 and every two years, except the hose on the Appendix R and Adapters turbine building roof which is tested plant annually. experience.

Inspect fire hoses and gaskets. Biennially Based on plant experience.

In regards to question 2.c1The 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 CAP Action Request (AR) is initiated, a management review team determines level of review required, and corrective actions are determined and implemented in accordance with the significance.

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Prairie Island Nuclear Generating Plant 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 quarterly in accordance with plant processes or procedures. This inventory assures the items are stored in the proper quantities and location. Access to equipment storage locations is controlled by postings on lockers and trailers where they are stored, citing the equipment is designated for use only for B.5.b scenarios.

lnventory 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.

Table 3 Inventories Equipment Inventory Special Actions Performed Frequency Storage Controls Carts, trucks and trailers for Quarterly Indoors, Verify proper staging equipment Heated quantities Portable Diesel Fire Pump and Quarterly Indoors, Verify proper battery charger Heated quantities Set(s) of wheel chocks Quarterly Indoors, Verify proper Heated quantities Floating suction strainer and Quarterly Indoors, Verify proper suction hose Heated quantities steak Generator fill connector Quarterly Indoors, Verify proper Heated quantities Reverse Osmosis connector for Quarterly Indoors, Verify proper Refueling Water Storage Tank fill Heated quantities Page 7 of 13

Prairie Island Nuclear Generating Plant Equipment Inventory Special Actions Performed Frequency Storage Controls Fire Hose (6, 5, 4, 2 % and 1-112 - Quarterly Indoors, Verify proper inch) nozzles, valves, adapters, Heated quantities splitters, monitors, manifolds, strainer, connectors, wrenches, etc.

DllD2 connector (replaces spool Quarterly Indoors, Verify proper pieces) Heated quantities Deepwell supply connector for Quarterly Indoors, Verify proper D l ID2 cooling Heated quantities 5-inch discharge flow indicator Quarterly Indoors, Verify proper Heated quantities 125 VDC Battery Cart Quarterly Indoors, Verify proper Heated quantities Turnout gear ( coats, pants, Quarterly Indoors, Verify proper helmets, gloves, boots) Heated quantities Self-contained Breathing Quarterly Indoors, Verify proper Apparatuslmasksltanks Heated quantities Radios and chargers Quarterly Indoors, Verify proper Heated quantities Portable lights (flashlights, quartz Quarterly Indoors, Verify proper lights, halogen lights, etc.) Heated quantities Dosimetry Quarterly Indoors, Verify proper Heated quantities Tools (extension cords, hand tools, Quarterly Indoors, Verify proper specialty tools, etc) Heated quantities Rescue equipmentlmedical Quarterly Indoors, Verify proper supplies Heated quantities Fuel oil for Portable Diesel Fire Quarterly Indoors, Verify proper Pump Heated quantities Page 8 of 13

Prairie Island Nuclear Generating Plant 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 and/or 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 13

Prairie Island Nuclear Generating Plant Table 4 - Training Plant Training Periodicity Evaluation Personnel Non-Licensed Training on the Non-Licensed Operator 3 years Testing I Operators role in implementing Extensive Damage Qualification Mitigation Guidelines (EDMG) is part of the Initial Non-Licensed Operator Training programs and retrained per the NLO continuing training plan.

Licensed Licensed Operators are initially trained 2 years Testing and Operators on EDMGs per the Initial Licensed DrillsIExercises Operator training program. Licensed Operators are retrained per the biennial training plan as described in the Licensed Operator Requalification Training Program Description.

Fire Brigade Fire Brigade members are Non-Licensed 3 Years Testing Operators and are initially trained in EDMGs. Refresher training on B.5.b events is offered every 3 years.

Emergency The Emergency Response Organization None Qualification Reponse (ERO) qualified decision makers receive Organzation - initial training on EDMGs. However, Key Decision NSPM currently has no procedural Makers requirements to provide continuing training. NSPM recognizes the need for ongoing training for its qualified decision makers. Therefore, NSPM makes the following commitment for the PINGP:

NSPM will include a requirement for continuing training on EDMGs in the PINGP training program for the ERO qualified decision makers by January 13, 2012.

Security Training on mitigating strategies was 2 Years Testing 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.

Page 10 of 13

Prairie Island Nuclear Generating Plant 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 in Table 5 are relied on for emergency response.

Table 5 - Offsite Organizations Off-site Organization Implementing Date of Training1 Periodicity Document Agreement State of Minnesota Letter of 1211712008 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

State of Wisconsin Letter of 101612010 Annual training provided by Agreement the State of Wisconsin as stated in Wisconsin Emergency Operations Plan.

City of Red Wing Letter of 21241201 1 Annual training for the Red (includes Red Wing Agreement Wing Fire Department is Fire Department) provided by the site and the State of Minnesota. Annual training is provided to the City of Red Wing via the Minnesota Emergency Operations Plan.

Dakota County Letter of 41281201 1 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

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Prairie Island Nuclear Generating Plant Off-site Organization Implementing Date of Training1 Periodicity Document Agreement Goodhue County Letter of 1111112010 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

Pier~e County Letter of 1/4/2011 Initial and annual training is Agreement provided by Pierce County as stated in the Pierce County Emergency Operations Plan.

Fairview Red Wing Letter of 3/18/2010 Annual training is provided by Hospital Agreement the site.

Sacred Heart Hospital Letter of 311812010 Annual training provided by Agreement the Wisconsin Department of Health Services.

Prairie Island Indian Letter of 1/31/2011 NSPM supports emergency Community Agreement response services provided by the Prairie Island Indian Community, including providing training.

Regions Hospital Letter of 6/7/2011 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

North Memorial Letter of 10/2512010 Annual training provided by Medical Center Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

Westinghouse Letter of 10/12/2010 N/A Agreement Canadian Pacific Letter of 312512010 NIA Railway Agreement Institute of Nuclear Letter of 9/30/2010 N/A Power Operations Agreement (INPO)

Environmental, Inc. Letter of 10/5/2010 N/A Midwest Laboratory Agreement Pooled Inventory Letter of 1211512010 N/A Management Agreement Department of Energy- Letter of 9/29/2010 N/A Radiation Emergency Agreement Assistance CenteriTraining Site Page 12 of 13

Prairie Island Nuclear Generating Plant All Letters of Agreement are reviewed annually by procedure to ensure they are current and are renewed periodically.

NSPM 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.

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