ML073240244

Clarification Letter for Gothic (TAC MC4245 and MC4246)

ML073240244
Person / Time
Site:	Prairie Island
Issue date:	12/03/2007
From:	Mahesh Chawla NRC/NRR/ADRO/DORL/LPLIII-1
To:	Wadley M Nuclear Management Co
Chawla M, NRR/DORL/LPL3-1, 301-415-8371
References
TAC MC4245, TAC MC4246
Download: ML073240244 (5)

Text

December 3, 2007 Mr. Michael D.

Wadley 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 RE: CLARIFICATION LETTER FOR USE OF GOTHIC (TAC NOS. MC4245 AND MC4246)

Dear Mr. Wadley:

On September 1, 2004, the Nuclear Management Company (NMC, the licensee) submitted a license amendment request (LAR) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML042570289) requesting approval to use the GOTHIC methodology for Prairie Island Nuclear Generating Plant (PINGP) analyses. The Nuclear Regulatory Commission (NRC) approved the LAR by a safety evaluation (SE) dated August 12, 2005 (ADAMS Accession No. ML052000046), which had the following statement in the conclusion:

The mass and energy releases and the initial and boundary conditions used in future PINGP license applications using GOTHIC 7 will be reviewed by the staff to assure that the analyses are performed consistent with the guidance in the SRPs and the description presented in WCAP-16219-P.

However, your staff has expressed concern with the above statement in the SE. In an e-mail dated October 30, 2007 (ADAMS Accession No. ML073310572), NMC stated that according to its interpretation, each use (application) of GOTHIC would require the submittal of an LAR. It further stated that requiring an LAR for each use would not be consistent with the industry use of approved topical reports, such as WCAP-16219-P, and would preclude the use of Section 50.59 of Part 50 to Title 10 of the Code of Federal Regulations (10 CFR 50.59) for determining whether prior NRC approval is required. Thus, NMC requested that the NRC withdraw this SE statement or provide clarification.

The NRC staff does not agree with NMCs interpretation of the SE statement. The following interpretation is provided by the staff.

The NRC staff notes that 10 CFR 50.59 is the controlling regulation in determining whether GOTHIC analyses must receive prior NRC review and approval. The intent of the staffs statement is that when an LAR is submitted, the staff will review the mass and energy release calculations, not that every GOTHIC analysis must be submitted.

M. Wadley I hope this provides the necessary clarification requested by NMC. If you have any further questions, please contact me at 301-415-8371.

Sincerely,

/RA/

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 cc: See next page

ML073240244 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/DSS/SCVB/BC NRR/LPL3-1/(A)BC NAME MChawla THarris RDennig RL for CMunson PDM for DATE 11/21/07 11/29/07 11/30/07 12/3/07 Prairie Island Nuclear Generating Plant, Units 1 and 2 cc:

Jonathan Rogoff, Esquire Tribal Council Vice President, Counsel & Secretary Prairie Island Indian Community Nuclear Management Company, LLC ATTN: Environmental Department 700 First Street 5636 Sturgeon Lake Road Hudson, WI 54016 Welch, MN 55089 Manager, Regulatory Affairs Nuclear Asset Manager Prairie Island Nuclear Generating Plant Xcel Energy, Inc.

Nuclear Management Company, LLC 414 Nicollet Mall, R.S. 8 1717 Wakonade Drive East Minneapolis, MN 55401 Welch, MN 55089 Michael B. Sellman Manager - Environmental Protection Division President and Chief Executive Officer Minnesota Attorney General=s Office Nuclear Management Company, LLC 445 Minnesota St., Suite 900 700 First Street St. Paul, MN 55101-2127 Hudson, MI 54016 U.S. Nuclear Regulatory Commission Dennis L. Koehl Resident Inspector's Office Chief Nuclear Officer 1719 Wakonade Drive East Nuclear Management Company, LLC Welch, MN 55089-9642 700 First Street Hudson, WI 54016 Administrator Goodhue County Courthouse Joel P. Sorenson Box 408 Director, Site Operations Red Wing, MN 55066-0408 Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC Commissioner 1717 Wakonade Drive East Minnesota Department of Commerce Welch, MN 55089 85 7th Place East, Suite 500 St. Paul, MN 55101-2198 July 2006