L-PI-11-096, Response to NRC Bulletin 2011-01, Mitigating Strategies, Request for Additional Information (RAI) (TAC Nos. ME6471 and ME64720)

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Response to NRC Bulletin 2011-01, Mitigating Strategies, Request for Additional Information (RAI) (TAC Nos. ME6471 and ME64720)
ML113570165
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 12/21/2011
From: Schimmel M
Northern States Power Co, Xcel Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-11-001, L-PI-11-096, TAC ME6471, TAC ME6472
Download: ML113570165 (4)
v • d • e


Text

Xeel Energy DEC 2.1 *2011 L-PI-11-096 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 Response to NRC Bulletin 2011-01, "Mitigating Strategies", Request for Additional Information (RAil (TAG Nos. ME6471 and ME6472)

On May 11,2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating strategies", .(Agencywide Docu.ments Access and Management System (ADAMS) ML111250360). 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 ofthe Code of Federal Regulations (10 CFR) Section 50.54(hh)(2),
2. To notify addressees about the NRC staff's need for information associatect.with

. licensee mitigating strategies under 10 CFR 50.54(hh)(2) il! 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 and 60 days of the date of the Bulletin. The 3~-day and 60 day response letters were prC?vided by Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), on June 9, 2011, (ADAMS Accession No. ML111610510) and July 11, 2011, (ADAMS Accession No. ML111930159) respectively.

By letter dated November 28, 2011, ADAMS Accession No. ML 1"13220222) NRC Staff 1717 Wakonade Drive East

  • Welch, Minnesota 55089*9642 Telephone: 651.388.1121

Document Control Desk Page 2 requested additional information to support their review of th~ July 11, 2011, (ADAMS Accession No. ML111930159) submittal.

The enclosure to this letter provides the response to the NRC Staff RAI for the Prairie Island Nuclear Generating Plant (PINGP) .. NSPM submits this supplement in accordance with the provisions of 10 CFR 50.54(f).

If there are any questions or if additional information is needed, please contact Mr. Dale Vincent, P.E., at 651-388-1121.

Summary of Commitments This letter contains no new commitmen~s and no revisions to existing commitments I declare under penalty of perjury that the foregoing is true and correct.

h Mark A. Schimmel Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (1) cc
Administrator, Region III, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC

ENCLOSURE Response to Request for Additional Information (RAt) on NRC Bulletin 2011 ~01, IIMitigating Strategies", An'swers This enClosure provides the response from the Northern Stat~s Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), to a Nuclear Regulatory 90mmission (NRC) RAl'provided by letter dated November 28, 2011, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113220222) regarding the NSPM answers to NRC Bulletin 2011~01 for the Prairie Island Nuclear Gener~ting Plant (PINGP).

The N~C RAI stated:

Background

, Bulletin 2011 ~01, "Mitigating Strategies," requested that each licensee describe ,in detail the maintenance and testing on equipment procured to support the mitigating strategies to ensure that it will be functional when needed. In the' context of the mitigating strategies, these devices are commonly used for '

firefighting, spent fuel pool spray strategies, and as a means to reduce the magnitude of fission product rel~ases. The NRC staff could not determine if you performed activities to ensure that these devices will be functional when needed.

Request for Additional Information Describe in detail the maintenElnce or testing of monitor nozzles, spray nozzles, or similar devices to ensure that they will be functional when needed.

NSPM response:

A review of the surveillance and test procedures (SPs and TPs) associat~d with the Extensive Damage Mitigating Guidelines (EDMG) determined that the monitor and spray nozzles a'ra inventoried quarterly in accordance with the EDMG equipment Inventory procedur~. Currently the procedure does not r~quire a functional check or inspection to be performed on this equipment.

The industry standard applicable to this equipment, National Fire Protection Association Standard 1962 (NFPA 1962), "Standard for the Inspection, Care, and Use,of Fire Hose, Couplings, and Nozzles and the Service Testing of Fire Hose", 2008 Edition, Section 6.1 uNoz?:les", requires this equipment to be fnspected after each use and at lea~t annually. Specific inspection acceptance criteria are provided in NFPA 1962 Section 6.1. A functional cheqk (performance in~use test) is not required for nozzles.

Page 1 of2

Response to BL 11 01 RAI w

Since current plant procedural requirements do not meet th.e applicable industry standard, an action request was documented and a procedure change initiated in the NSPM Corrective Action Program. The existing quarterly EDMG equipment inventory procedure will be revised to require documentation of inspection results on the Inventory sheet for each nozzle.

The following inspection acceptance criteria, which are provided in NFPA 1962, Section

.6.1, will be listed in the procedure:

1. The waterway is clear of obstructions.
2. There is no damage to the tip.
3. All controls and adjustments operate as designed.
4. The shutoff valve, ifso equipped, 'operates as designed and closes off the flow completely. .
5. There are no missing or broken parts.
6. The thread gasket is in good condition in accordance with Section 6.3 (which requires gaskets to be inspected for presence, fit, and deterioration, and shall not protrude into waterway).

When these proposed changes are completed, the NSPM quarterly EDMG equipment inventory for PINGP will meet orexceed the inspection requirements of NFPA 1962, the applicable ilidustry standard.

Page 2 of 2

Text

Xeel Energy DEC 2.1 *2011 L-PI-11-096 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 Response to NRC Bulletin 2011-01, "Mitigating Strategies", Request for Additional Information (RAil (TAG Nos. ME6471 and ME6472)

On May 11,2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating strategies", .(Agencywide Docu.ments Access and Management System (ADAMS) ML111250360). 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 ofthe Code of Federal Regulations (10 CFR) Section 50.54(hh)(2),
2. To notify addressees about the NRC staff's need for information associatect.with

. licensee mitigating strategies under 10 CFR 50.54(hh)(2) il! 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 and 60 days of the date of the Bulletin. The 3~-day and 60 day response letters were prC?vided by Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), on June 9, 2011, (ADAMS Accession No. ML111610510) and July 11, 2011, (ADAMS Accession No. ML111930159) respectively.

By letter dated November 28, 2011, ADAMS Accession No. ML 1"13220222) NRC Staff 1717 Wakonade Drive East

  • Welch, Minnesota 55089*9642 Telephone: 651.388.1121

Document Control Desk Page 2 requested additional information to support their review of th~ July 11, 2011, (ADAMS Accession No. ML111930159) submittal.

The enclosure to this letter provides the response to the NRC Staff RAI for the Prairie Island Nuclear Generating Plant (PINGP) .. NSPM submits this supplement in accordance with the provisions of 10 CFR 50.54(f).

If there are any questions or if additional information is needed, please contact Mr. Dale Vincent, P.E., at 651-388-1121.

Summary of Commitments This letter contains no new commitmen~s and no revisions to existing commitments I declare under penalty of perjury that the foregoing is true and correct.

h Mark A. Schimmel Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (1) cc
Administrator, Region III, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC

ENCLOSURE Response to Request for Additional Information (RAt) on NRC Bulletin 2011 ~01, IIMitigating Strategies", An'swers This enClosure provides the response from the Northern Stat~s Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), to a Nuclear Regulatory 90mmission (NRC) RAl'provided by letter dated November 28, 2011, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113220222) regarding the NSPM answers to NRC Bulletin 2011~01 for the Prairie Island Nuclear Gener~ting Plant (PINGP).

The N~C RAI stated:

Background

, Bulletin 2011 ~01, "Mitigating Strategies," requested that each licensee describe ,in detail the maintenance and testing on equipment procured to support the mitigating strategies to ensure that it will be functional when needed. In the' context of the mitigating strategies, these devices are commonly used for '

firefighting, spent fuel pool spray strategies, and as a means to reduce the magnitude of fission product rel~ases. The NRC staff could not determine if you performed activities to ensure that these devices will be functional when needed.

Request for Additional Information Describe in detail the maintenElnce or testing of monitor nozzles, spray nozzles, or similar devices to ensure that they will be functional when needed.

NSPM response:

A review of the surveillance and test procedures (SPs and TPs) associat~d with the Extensive Damage Mitigating Guidelines (EDMG) determined that the monitor and spray nozzles a'ra inventoried quarterly in accordance with the EDMG equipment Inventory procedur~. Currently the procedure does not r~quire a functional check or inspection to be performed on this equipment.

The industry standard applicable to this equipment, National Fire Protection Association Standard 1962 (NFPA 1962), "Standard for the Inspection, Care, and Use,of Fire Hose, Couplings, and Nozzles and the Service Testing of Fire Hose", 2008 Edition, Section 6.1 uNoz?:les", requires this equipment to be fnspected after each use and at lea~t annually. Specific inspection acceptance criteria are provided in NFPA 1962 Section 6.1. A functional cheqk (performance in~use test) is not required for nozzles.

Page 1 of2

Response to BL 11 01 RAI w

Since current plant procedural requirements do not meet th.e applicable industry standard, an action request was documented and a procedure change initiated in the NSPM Corrective Action Program. The existing quarterly EDMG equipment inventory procedure will be revised to require documentation of inspection results on the Inventory sheet for each nozzle.

The following inspection acceptance criteria, which are provided in NFPA 1962, Section

.6.1, will be listed in the procedure:

1. The waterway is clear of obstructions.
2. There is no damage to the tip.
3. All controls and adjustments operate as designed.
4. The shutoff valve, ifso equipped, 'operates as designed and closes off the flow completely. .
5. There are no missing or broken parts.
6. The thread gasket is in good condition in accordance with Section 6.3 (which requires gaskets to be inspected for presence, fit, and deterioration, and shall not protrude into waterway).

When these proposed changes are completed, the NSPM quarterly EDMG equipment inventory for PINGP will meet orexceed the inspection requirements of NFPA 1962, the applicable ilidustry standard.

Page 2 of 2

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