L-PI-16-007, Sixth Six-Month Status Report in Response to March 12. 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Sixth Six-Month Status Report in Response to March 12. 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML16057A061
Person / Time
Site:	Prairie Island
Issue date:	02/24/2016
From:	Davison K Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-PI-16-007, TAC MF0834
Download: ML16057A061 (13)

Text

(l Xcel Energy Prairie Island Nuclear Generating Plant 1717 Wakonade Drive East Welch, MN 55089 L-PI-16-007 FEB 2 It 2016 10 CFR 2.202 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Unit 1 Docket Number 50-282 Renewed Facility Operating License No. DPR-42 Prairie Island Nuclear Generating Plant, Unit 1, Sixth Six-Month Status Report in Response to March 12. 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) (TAC No. MF0834)

References:

1. NRC Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ADAMS Accession No. ML12054A735).

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174).

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378).

4. NSPM Letter (L-PI-12-092) to NRC, "Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated October 29, 2012 (ADAMS Accession No. ML12305A287).

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5. NSPM Letter (L-PI-13-007) to NRC, "Prairie Island Nuclear Generating Plant's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 26, 2013 (ADAMS Accession No. ML13060A379).

6. NSPM Letter (L-PI-13-080) to NRC, "Prairie Island's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 26, 2013 (ADAMS Accession No. ML13239A094).

7. NSPM Letter (L-PI-14-018) to NRC, "Prairie Island Nuclear Generating Plant's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 26, 2014 (ADAMS Accession No. ML14057A771).

8. NSPM Letter (L-PI-14-1 04) to NRC, "Prairie Island Nuclear Generating Plant's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), CORRECTED" dated October 20, 2014 (ADAMS Accession No. ML14295A761).

9. NSPM Letter (L-PI-14-078) to NRC, "Prairie Island Nuclear Generating Plant's Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA 049) (TAG Nos. MF0834 and MF0835)," dated August 25, 2014 (ADAMS Accession No. ML14237A512).

10.NSPM Letter (L-PI-15-021) to NRC, "Prairie Island Nuclear Generating Plant's Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA 049) (TAG Nos. MF0834 and MF0835)," dated February 26, 2015 (ADAMS Accession No. ML15057A323).

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11. NSPM Letter (L-PI-15-065) to NRC, "Prairie Island Nuclear Generating Plant's Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049) (TAG Nos. MF0834 and MF0835)," dated August 25, 2015 (ADAMS Accession No. ML15237A403).

12. NSPM Letter (L-PI-16-001) to NRC, "Notification of Compliance with NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,' Prairie Island Nuclear Generating Plant Unit 2 (TAG No. MF0835)," dated January 14, 2016 (ADAMS Accession Nos. ML16014A754, ML16014A755, and ML16014A756).

On March 12, 2012, the NRC staff issued Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," (Reference 1) to all NRC power reactor licensees and holders of construction permits in active or deferred status. Reference 1 was immediately effective and directs Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event for the Prairie Island Nuclear Generating Plant (PINGP). Specific requirements are outlined in Attachment 2 of Reference 1.

Pursuant to Condition C of Section IV, Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (ISG), an overall integrated plan, and status reports at six-month intervals following the submittal of the overall integrated plan. The ISG (Reference 2) endorses, with exceptions and clarifications, the industry guidance document, NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0 (Reference 3). Reference 4 provided the PINGP initial 60-day status report regarding mitigation strategies.

Reference 5 provided the overall integrated plan for PINGP. The first, second, third, fourth, and fifth six-month status reports were provided in References 6, 7, 9, 10, and 11, respectively. Reference 8 provided a correction to the second six-month status report (Reference 7).

The purpose of this letter is to provide the sixth six-month status report pursuant to Section IV, Condition C.2 of Reference 1, which delineates the progress made in implementing the requirements of the Reference 1 Order. The enclosed report provides an update of milestone accomplishments since the overall integrated plan was submitted, including changes to the compliance method, schedule, or the need and basis for relief, if any. This update is applicable to PINGP Unit 1 only. The PINGP Unit 2

Document Control Desk Page4 has completed the Order requirements and has reported compliance to the Commission (Reference 12).

Please contact Lynne Gunderson, Licensing Engineer, at 651-267-7421, if additional information or clarification is required.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on February ~t/, 2016.

/.~J~

K~avison Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region Ill, USNRC Project Manager, Prairie Island Nuclear Generating Plant, USNRC Resident Inspector, Prairie Island Nuclear Generating Plant, USNRC

L-PI-16-007 NSPM Enclosure Prairie Island Nuclear Generating Plant, Unit 1 Sixth Six-Month Status Report for Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1.0 Introduction The Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," on March 12, 2012 (Reference 1). The Order required licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event. The Order required licensees to submit an overall integrated plan (OIP), including a description of how the requirements in of the Order would be achieved. Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, submitted the OIP (Reference 2) for the Prairie Island Nuclear Generating Plant (PINGP) on February 26, 2013. In accordance with Section IV, Condition C.2 of Reference 1, the first, second, third, fourth and fifth six-month status reports were provided in References 3, 4, 5, 8, and 9, respectively. Reference 12 provided a correction to the second six-month status report (Reference 4).

This Enclosure provides the sixth six-month status report. This status report includes an update of milestone accomplishments since submittal of the last status report including changes to the compliance method, schedule, or the need and basis for relief, if any.

PINGP Unit 2 has completed the requirements of Order EA-12-049 and has reported compliance to the Commission (Reference 10). Therefore, Unit 2 status is no longer included in this report and this update is applicable only to Unit 1.

2.0 Milestone Accomplishments The original milestone schedule with target dates was provided in Attachment 2 of the Reference 2 Enclosure. NSPM has accomplished the following milestones since the last six-month status (Reference 9). This report reflects status as of January 29, 2016.

• Commence Installation for Online Modifications- Phase 2 and 3

• Implement Storage

• Issue Maintenance Procedures Page 1 of 9

L-PI-16-007 NSPM Enclosure 3.0 Milestone Schedule Status The following table provides an update of the milestone schedule for the OIP, which has been updated to show only Unit 1 compliance status. This table reflects status as of January 29, 2016. This table includes a brief milestone status and the revised target date if that target date has changed. Target dates updated for Unit 1 Compliance are noted in the "Revised Target Date Column." The target dates are planning dates subject to change as design and implementation details are developed. The following describe schedule changes for Unit 1 since the previous status update (Reference 9).

• Procure Equipment The milestone target completion date is updated for Unit 1 compliance and will cover any gaps in equipment needed for Unit 1 compliance. Note that major FLEX equipment has been procured and is stored in the existing FLEX Storage Building. The Procure Equipment target milestone date for Unit 1 is Fall 2016, prior to the startup from the Unit 1 implementation outage.

• Implement Training The milestone target completion date for Unit 1 is Fall 2016, prior to the startup from the Unit 1 implementation outage. This milestone will cover any gap training needed.

• Issue Procedures Updated for FLEX Strategies The milestone target completion date for Unit 1 is Fall 2016, prior to the startup from the Unit 1 implementation outage. This milestone covers issuing the Unit 1 FLEX procedures.

• Submit Sixth Six-Month Status Update This activity is complete with this submittal.

• Validation Walk-throughs The Unit 2 validation encompassed the strategies for Unit 1. Any gaps in validation for Unit 1 compliance will be completed prior to startup from the Unit 1 implementation outage in Fall 2016. The Validation Walk-throughs target milestone status has changed to "Started".

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L-PI-16-007 NSPM Enclosure Table - Overall Integrated Plan Milestone Schedule Milestone Target Activity Status Revised Target Completion Date Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated February 2013 Complete Plan Submit First Six-Month August 2013 Complete Status Update Commence Engineering September 2013 Complete Modification Design- Phase 2 & 3 (Unit 1)

Submit Second Six-Month February 2014 Complete Status Update National SAFER Response August 2015 Complete Center Operational Procure Equipment (Unit 1) Fall 2016, prior to Started Updated Target startup from Unit Completion Date 1 Implementation to reflect Unit 1 Outage date Submit Third Six-Month August 2014 Complete Status Update Commence Installation for January 2016 Complete Updated Target Online Modifications- Phase Completion Date 2 and 3 (Unit 1) to reflect Unit 1 date Implement Storage October 2015 Complete Completion date ,

was November 2015 per Reference 10 Issue Maintenance Fall 2015, prior to Complete Procedures startup from Unit 2 Implementation Outage Page 3 of 9

L-PI-16-007 ~~SPM Enclosure Table ~ Overall Integrated Plan Milestone Schedule Milestone Target Activity Status Revised Target Completion Date Date Implement Training (Unit 1) Fall 2016, prior to Started Updated Target startup from Unit Completion Date 1 Implementation to reflect Unit 1 Outage date Submit Fourth Six-Month February 2015 Complete Status Update Submit Phase 2 Staffing Four months prior Complete Assessment to 2R29 Implement Communication Four months prior Complete Recommendations to 2R29 Issue Procedures updated for Fall 2016, prior to Started Updated Target FLEX strategies (Unit 1) startup from Unit Completion Date 1 Implementation to reflect Unit 1 Outag~ date Submit Fifth Six-Month August 2015 Complete Status Update Submit Sixth Six-Month February 2016 Complete with Status this submittal Unit 1 Implementation Fall 2016 Not Started Outage Validation Walk-throughs Fall 2016 Started Submit Seventh Six-Month August 2016 Not Started Status Submit Completion Report December 2016 Not Started Page 4 of 9

L-PI-16-007 NSPM Enclosure 4.0 Proposed Changes to Compliance Method There are changes and one clarification to the compliance method as documented in the OIP (Reference 2) since the last status report. These changes and additional clarification to the OIP information are discussed below.

• OIP Compliance Change- Flood Strategy (Audit Open Item SE.18)

The OIP submitted for PINGP stated the flood hazard has ample warning time to allow deployment of FLEX equipment:

There will be sufficient time for pre-staging of the Phase 2 FLEX equipment within the flood-protected areas of the building or above the flood level before the design basis flood level is reached. Phase 3 equipment from the Regional Response Center can be requested prior to the flooding of the main access road and set up on site in advance of the probable maximum flood.

NSPM has revised the FLEX strategy for mitigating an extended loss of alternating current (ac) power (ELAP) condition during a design basis flood. This FLEX strategy change also changed the method of compliance. The revised strategy will rely on the off-site Strategic Alliance for FLEX Emergency Response (SAFER) 4 kV Turbine Generators (Phase 3 equipment) to repower installed equipment rather than the PINGP Phase 2 FLEX portable pumps and 480V generators. The PINGP support equipment needed for operation of the SAFER 4 kV Turbine Generators is stored in the FLEX building. There is sufficient time prior to the design basis flood to pre-stage the SAFER 4 kV equipment and the necessary PINGP support equipment before the site grade floods.

Although the revised strategy meets the Order requirements, NSPM considers the strategy an alternative to meeting the baseline capabilities discussed in Section 3.2.2 of the NRC endorsed NEI 12-06 guidance. The repowered installed plant equipment maintains the functions of core cooling, spent fuel pool (SFP) cooling, and containment integrity, and therefore, meets the requirements of Order EA-12-049. For a more detailed explanation of the flooding strategy, see NSPM's response to Audit Open Item SE.18 in Enclosure 2 of the Unit 2 compliance notification letter (Reference 10).

• OIP Compliance Clarification- Access paths through seismic structures (Audit Open Item - Confirmatory Item (CI) 3.1.1.2.A)

The OIP submitted for PINGP included a conceptual design for the deployment of the portable equipment that discussed multiple access pathways being available to connection points. Based on the mixed design classification of the PINGP Turbine Building, PINGP's mitigating strategies (deployment paths for FLEX equipment, cables, and hoses) require access to areas of the Turbine Page 5 of 9

L-PI-16-007 NSPM Enclosure Building that do not meet the definition of robust and, therefore, are not in full compliance with NEI 12-06, Section 5.3.2, Consideration 2. NSPM is clarifying that the PINGP deployment paths internal to the Turbine Building are being treated as an alternative method of compliance to NEI 12-06, Section 5.3.2, Consideration 2. Based on the robust design of the main structures, the multiple and spatially diverse deployment paths, the use of paths that are adjacent to the exterior wall of the Class I structure, and the debris removal equipment available for clearing the path in these internal structures, sufficient access and timely deployment are ensured for the hoses and cables for portable equipment following a seismic event. For a detailed explanation, see the response to Audit Open Item Cl 3.1.1.2.A in Enclosure 2 of the Unit 2 compliance notification letter (Reference 10).

• OIP Compliance Change- Auxiliary Feedwater (AFW) Connection Points The OIP submitted for PINGP included for following statement regarding portable feedwater capability:

The discharge from the portable pump will be split to provide flow into a connection into the AFW lines downstream of each Motor Driven AFW Pumps (MDAFWP) - shown on Figure 3 in Attachment 3. This will provide flow to the SGs in both Units. In addition, the AFW System includes the capability to cross-connect the piping downstream of each MDA WFP. This cross-connection would provide the capability to feed the SGs for one or both of the Units from either of the two FLEX connection points.

Note that the fourth six-month status report (Reference 8) discussed a change that would allow the Unit 2 alternate steam generator (SG) makeup connection to be the Unit 1 MDAFWP discharge check valve until the Unit 1 makeup connection is installed. This change was based on the timing of Unit 2 compliance and the scheduled installation the Unit 1 SG makeup connection.

Rather than splitting the discharge of the portable pump and connecting downstream of each MDAFWP, the strategy change is to connect downstream of either MDAFWP and use the AFW cross-connect to supply water to the other unit. This reduces the number of connections that need to be made during an ELAP by establishing the same primary and alternate connection points into the AFW system for both Unit 1 and 2.

5.0 Need and Basis for Relief from the Requirements of the Order NSPM expects to comply with the Order implementation date and requirements and no relief is required at this time.

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L-PI-16-007 NSPM Enclosure 6.0 Open Items from Overall Integrated Plan and Interim Staff Evaluation NSPM did not identify any open items in the PINGP mitigating strategies OIP. The NRC Interim Staff Evaluation (ISE) was issued on February 27, 2014 (Reference 6). The NRC did not identify any open items in the IS E. Closure of the ISE confirmatory items will be completed as part of the NRC's audit process, as described in Reference 7.

7.0 Potential Interim Staff Evaluation Impacts The ISE (Reference 6) was reviewed and the following sections are potentially impacted by the changes and clarification to the compliance method as described in Section 4.0 above.

• ISE Sections o 3.1.2.2, Deployment of FLEX Equipment- Flooding Hazard o 3.1.2.3, Procedural Interfaces- Flooding Hazard The compliance change described above in Section 4.0 regarding the flood strategy potentially affects these ISE Sections. The referenced ISE sections note the pre-staging of Phase 2 FLEX equipment prior to the design basis flood level.

• ISE Section 3.1.1.2, Deployment of FLEX Equipment- Seismic Hazard The compliance clarification described above in Section 4.0 regarding access paths through seismic structures potentially affects this ISE Section. The ISE Section discusses deployment routes to the connection points and notes multiple access pathways. Confirmation of the deployment routes is tracked by Cl 3.1.1.2.A.

• ISE Section 3.2.1, RCS Cooling and Heat Removal, and RCS Inventory Control Strategies The compliance change described above in Section 4.0 regarding the AFW Connection Points potentially affects this ISE Section. The ISE section discusses the AFW connection points as described in the OIP (Reference 2).

8.0 References The following references support the updates to the overall integrated plan described in this enclosure:

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L-PI-16-007 NSPM Enclosure

1. NRC Order 2-049, "Issuance Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 12 (ADAMS Accession No. ML12054A735).

2. NSPM Letter (L-PI-13-007) to NRC, "Prairie Island Nuclear Generating Plant's Overall integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049)," dated February 26, 2013 (ADAMS Accession No. ML13060A379).

3. NSPM Letter (L-PI-13-080) to NRC, "Prairie Island's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 26, 2013 (ADAMS Accession No. ML13239A094).

4. NSPM Letter (L-PI-14-018) to NRC, "Prairie Island Nuclear Generating Plant's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 26, 2014 (ADAMS Accession No. ML14057A771).

5. NSPM Letter (L-PI-14-078) to NRC, "Prairie Island Nuclear Generating Plant's Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA 049) (TAC Nos. MF0834 and MF0835)," dated August 25, 2014 (ADAMS Accession No. ML14237A512).

6. NRC Interim Staff Evaluation "Prairie Island Nuclear Generating Plant Units 1 and 2- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)(TAC Nos. MF0834 and MF0835)," dated February 27, 2014 (ADAMS Accession No. ML14030A540).

7. NRC memorandum, "Supplemental Staff Guidance for Addressing Order EA 049 on Mitigation Strategies for Beyond-Design-Basis External Events," dated August 28, 2013 (ADAMS Accession No. ML13238A263).

8. NSPM Letter (L-PI-15-021) to NRC, "Prairie Island Nuclear Generating Plant's Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA 049) (TAC Nos. MF0834 and MF0835)," dated February 26, 2015 (ADAMS Accession No. ML15057A323).

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L-PI-16-007 NSPM Enclosure

9. NSPM Letter (L-PI-15-065) to NRC, "Prairie Island Nuclear Generating Plant's Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049) (TAG Nos. MF0834 and MF0835)," dated August 25, 2015 (ADAMS Accession No. ML15237A403).

10. NSPM Letter (L-PI-16-001) to NRC, "Notification of Compliance with NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Prairie Island Nuclear Generating Plant Unit 2 (TAG No. MF0835)," dated January 14, 2016 (ADAMS Accession Nos. ML16014A754, ML16014A755, and ML16014A756).

11. Not used.

12. NSPM Letter (L-PI-14-104) to NRC, "Prairie Island Nuclear Generating Plant's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), CORRECTED" dated October 20, 2014 (ADAMS Accession No. ML14295A761).

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