L-PI-08-043, Supplemental Information Regarding Application for Renewed Operating Licenses

Supplemental Information Regarding Application for Renewed Operating Licenses

ML081400797
Person / Time
Site:	Prairie Island
Issue date:	05/16/2008
From:	Wadley M Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-08-043
Download: ML081400797 (6)

Text

NMC>

Commrtted to Nuclear Excellence Prairie lsland Nuclear Generating Plant Operated by Nuclear Management Company, LLC May 16,2008 L-PI-08-043 10 CFR Part 54 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie lsland Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Su~plementalInformation Regarding Application for Renewed Operatinq Licenses By letter dated April 11, 2008, the Nuclear Management Company, LLC (NMC) submitted an Application for Renewed Operating Licenses (LRA) for the Prairie lsland Nuclear Generating Plant (PINGP) Units 1 and 2. This letter supplements the LRA to incorporate within the scope of License Renewal, additional components related to Station Blackout recovery.

In a telephone conference call on May 15, 2008, the NRC staff communicated a concern with the License Renewal scoping boundary defined in the LRA for equipment in the Prairie lsland Substation. The boundary defined in the LRA is the jurisdictional boundary between plant equipment and non-plant transmission system equipment. The staff indicated that the scoping boundary would be required to encompass certain non-plant transmission system busses and breakers to comply with draft License Renewal Interim Staff Guidance LR-ISG-2008-01, "Staff Guidance Regarding the Station Blackout Rule (10 CFR 50.63) Associated With License Renewal Applications,"

published in the Federal Register for public comment on March 12, 2008 (73FR13258). provides the LRA changes necessary to comply with the staff position in draft LR-ISG-2008-01.

If there are any questions or if additional information is needed, please contact Mr. Eugene Eckholt, License Renewal Project Manager.

Summarv of Commitments This letter contains no new commitments or changes to existing commitments.

1717 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1 121

Document Control Desk Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on May 16,2008.

Michael D. Wadley Site Vice President, Prairie and Nuclear Generating Plant Units 1 and 2 Nuclear Management Company, LLC Enclosure (1) cc:

President of the Prairie Island Indian Community Tribal Council Minnesota Department of Commerce Administrator, Region Ill, USNRC License Renewal Project Manager, Prairie Island, USNRC Operating Reactor Licensing Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC

ENCLOSURE 1 LICENSE RENEWAL APPLICATION (LRA) CHANGES TO EXPAND THE SCOPING BOUNDARY FOR STATION BLACKOUT RECOVERY The Prairie Island Nuclear Generating Plant (PINGP) Application for Renewed Operating Licenses is hereby revised as follows:

LRA Section 2.1.I .3 In LRA Section 2.1 .I .3, Interim Staff Guidance (ISG) Discussion, replace the existing item 7 with new item 7, to read as follows:

"7. Draft LR-ISG-2008-01, "Staff Guidance Regarding the Station Blackout Rule (10 CFR 50.63) Associated with License Renewal Applications" On March 12, 2008, the NRC published draft LR-ISG-2008-01 in the Federal Register for public comment. This ISG is intended to provide additional clarification to the NRC staff position on License Renewal scoping requirements regarding the offsite power system for SBO recovery. Guidance was previously provided in LR-ISG-02 which was cancelled after incorporation into NUREG-1800 Revision 1, Section 2.5.2.1.I. The examples referenced in the draft ISG illustrate SBO scoping boundaries which incorporate portions of the transmission system high voltage substations in addition to plant equipment.

Based on the examples in this draft ISG, the Prairie Island Substation scoping boundaries have been expanded to include portions of the transmission system in scope of License Renewal. The transmission system components were brought into scope for License Renewal aging management purposes only, and are not part of the CLB description of SBO recovery paths under 10 CFR 50.63. The substation scoping boundaries and associated aging management review discussions provided in Sections 2 and 3 of this LRA reflect these expanded boundaries."

LRA Section 2.5 At the end of LRA Section 2.5, Scoping and Screening Results: Electrical and Instrumentation and Controls Systems, after the sentence, "Each of these power sources can power both safeguards busses for both Units using tie breakers," add new paragraphs to read as follows:

"As discussed in LRA Section 2.1 .I .3, the scoping boundaries in the Prairie Island Substation have been expanded beyond the plant system equipment to include portions of the transmission system that are controlled and maintained by the transmission system operator. Transmission system components have been brought into scope for License Renewal aging management purposes only, and are not part of the CLB description of SBO recovery paths under 10 CFR 50.63.

ENCLOSURE 1 LICENSE RENEWAL APPLICATION (LRA) CHANGES TO EXPAND THE SCOPING BOUNDARY FOR STATION BLACKOUT RECOVERY The scoping boundaries for the transmission system portion of the Prairie Island Substation begin at the SBO recovery path boundaries described above, and extend outward to the following breakers:

345 kV Breakers 8H7,8H9, 8H13,8H15,8HI6,8H18 161 kV Breaker 6H5 The major substation components within the expanded boundaries brought into scope of License Renewal include the listed breakers and the following:

345 kV Bus 1 345 kV Bus 2 161 kV Bus 1 including Breaker 6H2 No. 10 Transformer and associated 13.8 kV components" LRA Section 2.5.10 Delete the existing discussion in Section 2.5.10, Transmission Conductors and Connections, in its entirety, and insert the following new paragraph:

"345kV and 161kV transmission conductors and connections that feed in-scope PlNGP offsite power supply paths are in scope of License Renewal due to supporting the SBO recovery path. This electrical commodity requires an AMR."

LRA Appendix A, Section A2.0 To the end of the existing Section A2.0, Summary Descriptions of Programs that Manage the Effects of Aging, add the following new paragraph:

"Certain programs are being applied to non-plant transmission system equipment in the Prairie Island Substation which is controlled and maintained by the transmission system operator. Program activities for non-plant equipment are performed for aging management purposes only. For the affected substation equipment, PlNGP will assure that the program inspections are performed using procedures subject to plant administrative controls. Degraded conditions identified by those inspections will be entered into the plant Corrective Action Program. Actions required to resolve inspection findings will be referred to the transmission system operator to accomplish, and will be tracked to completion and trended within the plant Corrective Action Program."

ENCLOSURE I LICENSE RENEWAL APPLICATION (LRA) CHANGES TO EXPAND THE SCOPING BOUNDARY FOR STATION BLACKOUT RECOVERY LRA Appendix A, Section A2.11 To the end of the existing program description in Section A2.11, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, add the following sentence:

"For aging management purposes only, this program is also being applied to certain non-plant transmission system equipment in the Prairie lsland Substation."

LRA Appendix A, Section A2.38 To the end of the existing program description in Section A2.38, Structures Monitoring Program, add the following sentence:

"For aging management purposes only, this program is also being applied to certain non-plant transmission system equipment in the Prairie lsland Substation."

LRA Appendix B, Section 81.3 In LRA Section B1.3, Quality Assurance Program and Administrative Controls, after the second full existing paragraph, insert the following new paragraph:

"Certain AMPS are being applied to non-plant transmission system equipment in the Prairie lsland Substation which is controlled and maintained by the transmission system operator. The elements of corrective actions, confirmation process and administrative controls described in this section are also applicable to these aging management activities for non-plant equipment, and will be addressed, as applicable, in interface agreements between PlNGP and the transmission system operator."

LRA Appendix 6, Section 82.1. I 1 To the end of the program description in Section B2.1.I 1, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, add the following new paragraph:

"In response to draft LR-ISG-2008-01 discussed in LRA Section 2.1 .I .3, this program is being applied to certain non-plant transmission system equipment in the Prairie lsland Substation which is controlled and maintained by the transmission system operator."

ENCLOSURE I LICENSE RENEWAL APPLICATION (LRA) CHANGES TO EXPAND THE SCOPING BOUNDARY FOR STATION BLACKOUT RECOVERY LRA Appendix B, Section B2.1.38 To the end of the program description in Section B2.1.38, Structures Monitoring Program, add the following new paragraph:

"In response to draft LR-ISG-2008-01 discussed in LRA Section 2.1 .I .3, this program is being applied to certain non-plant transmission system equipment in the Prairie Island Substation which is controlled and maintained by the transmission system operator."