Text

PINGP Lr - PINGP Responses to NRC RAI Letter of 12-2-08 and LRA 2.5.4 Clarification
	ML090390013
Person / Time
Site:	Prairie Island
Issue date:	01/16/2009
From:	; - No Known Affiliation
To:	; Division of License Renewal
References
	Download: ML090390013 (18)
	v • d • e

1 PrairieIslandNPEm Resource From:

Vincent, Robert [Robert.Vincent@xenuclear.com]

Sent:

Friday, January 16, 2009 4:46 PM To:

Richard Plasse; Nathan Goodman; Stuart Sheldon Cc:

Eckholt, Gene F.; Davis, Marlys E.

Subject:

PINGP Responses to NRC RAI Letter of 12-2-08 and LRA 2.5.4 Clarification Attachments:

20090116 Response to RAI Letter dtd 12-2-08.pdf; 20090116 Response to RAI Letter dtd 12-2-08.doc Attached is the PINGP letter responding to NRC RAI letter dated 12-2-08. The letter also includes the requested clarification of the commodity description in LRA 2.5.4. The letter was signed out this afternoon.

Call if you have any questions.

Bob Vincent X7259

Hearing Identifier:

Prairie_Island_NonPublic Email Number:

583 Mail Envelope Properties (9FA1D9F2F220C04F95D9394E3CF02DAB013A7197)

Subject:

PINGP Responses to NRC RAI Letter of 12-2-08 and LRA 2.5.4 Clarification Sent Date:

1/16/2009 4:45:51 PM Received Date:

1/16/2009 4:46:00 PM From:

Vincent, Robert Created By:

Robert.Vincent@xenuclear.com Recipients:

"Eckholt, Gene F." <Gene.Eckholt@xenuclear.com>

Tracking Status: None "Davis, Marlys E." <Marlys.Davis@xenuclear.com>

Tracking Status: None "Richard Plasse" <Richard.Plasse@nrc.gov>

Tracking Status: None "Nathan Goodman" <Nathan.Goodman@nrc.gov>

Tracking Status: None "Stuart Sheldon" <Stuart.Sheldon@nrc.gov>

Tracking Status: None Post Office:

enex02.ft.nmcco.net Files Size Date & Time MESSAGE 288 1/16/2009 4:46:00 PM 20090116 Response to RAI Letter dtd 12-2-08.pdf 528001 20090116 Response to RAI Letter dtd 12-2-08.doc 230976 Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received:

Document Control Desk Page 2 Enclosures (2) cc:

Administrator, Region III, USNRC License Renewal Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC Prairie Island Indian Community ATTN: Phil Mahowald Minnesota Department of Commerce NSPM Responses to NRC Requests for Additional Information Dated December 2, 2008 1

RAI 2.3.3.11-01 BACKGROUND:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to identify and list all components subject to an AMR. The staff confirms inclusion of all components subject to AMR by reviewing the component types within the license renewal boundary.

ISSUE:

During the scoping and screening review process the continuation of lines within the scope of license renewal from one drawing to another could not be established.

Drawing numbers and/or locations for the continuations were not identified.

x Drawing LR-39605-1, location A4 and B4: Continuation notes indicate To and From Dryers #121, #122, and #123, as well as To Washers #121, #122, and

123. No drawing number is given for these continuations.

x Drawing LR-39605-1, location A2: Continuation note indicates Radwaste Bldg Sply. but does not give a drawing number.

x Drawing LR-39605-1, location F2: Continuation note indicates To Aux Cond Ret. but does not give a drawing number.

x Drawing LR-39605-1, location F2: Continuation note indicates To Sample Station but does not give a drawing number.

x Drawing LR-39605-1, location F4: No continuation note on left side of 11/2 Deaerator Header.

REQUEST:

Provide additional information to locate the license renewal boundaries.

NSPM Response to RAI 2.3.3.11-01 On drawing LR-39605-1, location A-4, To #121, #122, & #123 Dryer, the License Renewal boundary continues through piping, fittings and flexible connections to the dryer heater assemblies, and returns at location B-4, From #121, #122 & #123 Dryer.

The piping, fittings, flexible connections and the dryer heaters are within the scope of License Renewal per 10 CFR 54.4(a)(2). The exhaust air side of the laundry dryers is shown on drawing LR-39600, location F-5, Laundry Dryers. The dryer heater assemblies which are supplied by the Heating System are not explicitly shown on License Renewal Boundary Drawings. Heaters and Piping/Fittings are included in LRA Table 2.3.3-11.

On drawing LR-39605-1, location A-4, To #121, #122 & #123 Washer, the License Renewal boundary continues through piping, fittings and flexible connections to the washer shell assembly. The piping, fittings, flexible connections and washer shell are within the scope of License Renewal per 10 CFR 54.4(a)(2). The laundry washers are NSPM Responses to NRC Requests for Additional Information Dated December 2, 2008 2

not explicitly shown on License Renewal Boundary Drawings. Piping and Fittings are included in LRA Table 2.3.3-11. The washer shell is evaluated in LRA Section 2.3.3.20, Waste Disposal System, as Decontamination Equipment and is included in LRA Table 2.3.3-20.

To address the flexible connections in the Heating System that are within the scope of License Renewal, the following changes are hereby made to the LRA:

In LRA Table 2.3.3-11, Heating System, on page 2.3-80, the following new line item is added:

Components Intended Function FLEX CONNECTIONS PRESSURE BOUNDARY In LRA Table 3.3.2-11, Auxiliary Systems -Heating System - Summary of Aging Management Evaluation, the following new line items are added:

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG

- 1801 Volume 2 Line Item Table 1 Item Notes Flex Connections Pressure Boundary Stainless Steel Plant Indoor Air -

Uncontrolled (Ext)

None None VII.J-15 3.3.1-94 A

Flex Connections Pressure Boundary Stainless Steel Steam (Int)

Cracking -

SCC/IGA Water Chemistry Program VIII.A-10 3.4.1-39 B

Flex Connections Pressure Boundary Stainless Steel Steam (Int)

Loss of Material -

Crevice Corrosion Water Chemistry Program VIII.A-12 3.4.1-37 B

Flex Connections Pressure Boundary Stainless Steel Steam (Int)

Loss of Material -

Pitting Corrosion Water Chemistry Program VIII.A-12 3.4.1-37 B

The continuation of drawing LR-39605-1, location A-2, Radwaste Building Supply, is at location D-1 on the 4 line downstream of valve AS-9-1 and prior to the wall shown on the 4 line continuing to the Radwaste Building. LR-39605-1 does not explicitly show this connection. The connecting line is within the scope of License Renewal per 10 CFR 54.4(a)(2).

The continuation of drawing LR-39605-1, location F-2, To Auxiliary Condenser Return, is at location G-10, Condenser 1A Standpipe Drain. The connection is shown as a dashed line connected to the stand pipe. The connecting line is within the scope of License Renewal per 10 CFR 54.4(a)(2).

NSPM Responses to NRC Requests for Additional Information Dated December 2, 2008 3

The continuation of drawing LR-39605-1, location F-2, To Sample Station, is at location G-7, Steam Boiler, at valve HS-51-1. The connecting line is within the scope of License Renewal per 10 CFR 54.4(a)(2).

On drawing LR-39605-1, location F-4, a welded pipe cap should be shown on the left side of the 11/2 line To Deaerator. The welded cap is within the scope of License Renewal. The right side of the 11/2 line To Deaerator connects to the 3 line shown on the Deaerator header (location F-5) upstream of PI 11140. The connecting line is within the scope of License Renewal per 10 CFR 54.4(a)(2). Scoping of the 3 line at the Deaerator as not within the scope of License Renewal is incorrect; this line should be shown as within the scope of License Renewal per 10 CFR 54.4(a)(2).

RAI 2.3.3.11-02 BACKGROUND:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to identify and list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing the component types within the license renewal boundary.

ISSUE:

On License Renewal Drawing LR-39605-1, location G7, G6, D5, and C2 there are lines with valves and no connection note in various locations. These appear to be vents and/or drains but are not marked V or D as in drawings LR-39605-2 and LR-39605-3.

REQUEST:

Confirm that these are vents and/or drains and constitute the end of the license renewal boundary on their respective pipe.

NSPM Response to RAI 2.3.3.11-02 On drawing LR-39605-1, location G-7, the line and valve shown upstream of valve HS-68F-2, continues at location H-7, Make-Up to the Sample Station at valve HS-51-4; the connecting line is within the scope of License Renewal per 10 CFR 54.4(a)(2).

On drawing LR-39605-1, location G-6, the 3/4 lines downstream of heating boiler pump suction line expansion joints are drain points; the License Renewal boundary ends at the free end of the drain pipe.

On drawing LR-39605-1, locations G-5 and G-6, the lines at valve HS-74-107 and HS-74-108, are pump casing drains; the License Renewal boundary ends at the free end of the drain pipe.

NSPM Responses to NRC Requests for Additional Information Dated December 2, 2008 4

On drawing LR-39605-1, location G-5, the line at valve HS-31B-26, continues on drawing LR-XH-248-1-1, location B-11, Sample Number 49. A License Renewal system boundary break should be shown at the outlet of valve HS-31B-26 between the Heating (HS) System and the Plant Sample (SM) System. The connecting line is within the scope of License Renewal per 10 CFR 54.4(a)(2).

On drawing LR-39605-1, location D-5, the lines at valves HS-128-2 and HS-31A-1, are line drains; the License Renewal boundary ends at the free end of the drain pipe.

On drawing LR-39605-1, location C-2, the line and valve shown below PI-11350, should be connected to PI-11350; the connecting line is within the scope of License Renewal per 10 CFR 54.4(a)(2).

RAI 2.3.3.11-03 BACKGROUND:

In License Renewal Application (LRA) Section 2.3.3.11, Tanks and Sight Glasses are listed as component types of the HS system in scope for criteria 10 CFR 54.4(a)(2) with a pressure boundary intended function.

ISSUE:

On drawing LR-39605-1, location D2, the Gauge Glass on #121 Process Steam Condensate Return Unit is not highlighted in scope for license renewal, while the Return Unit itself is in scope. Sight Glass components on other tanks are highlighted as in scope for license renewal.

REQUEST:

Provide justification for not including the Gauge Glass in the scope of license renewal.

If the Gauge Glass is in scope and does not belong to the Sight Glass component type, provide justification for not including this component type in Table 2.3.3-11.

NSPM Response to RAI 2.3.3.11-03 On drawing LR-39605-1, locations D-2 and D-6, the condensate return unit gauge glasses should be shown as within the scope of License Renewal. Gauge glasses are evaluated as Sight Glasses and are included in LRA Table 2.3.3-11.

NSPM Responses to NRC Requests for Additional Information Dated December 2, 2008 5

RAI 2.3.3.11-04 BACKGROUND:

In LRA Section 2.3.3.11, portions of the Heating System (HS) system are within scope based on criteria 10 CFR 54.4(a)(2).

ISSUE:

On drawing LR-39605-3, location B7, valve HS-35A-1 and attached piping are not highlighted as in scope for license renewal, but are directly connected to a 2 HWS line that is marked in scope for criteria 10 CFR 54.4(a)(2).

REQUEST:

Provide justification for not including valve HS-35A-1 in the scope of license renewal.

NSPM Response to RAI 2.3.3.11-04 On drawing LR-39605-3, location B-7, valve HS-35A-1 and attached piping should be shown as within the scope of License Renewal. Piping/Fittings and Valves are included in LRA Table 2.3.3-11.

NSPM Response to NRC Request for Clarification of LRA Section 2.5.4 1

Request for Clarification LRA section 2.5.4 Electrical Connector Contacts (Metallic Connector Pins Exposed to Borated Water) includes only Electrical Pinned connectors exposed to borated water.

However, NRC Staff position, stated in NUREG 1801, Rev. 1, Volume 1, Table 6, ID 5, and Volume 2 chapter XI.M10, includes all connector contacts for electrical connectors in the plant exposed to borated water leakage. NUREG 1801, Rev. 1, Table 6, ID 5, does not limit it to the Electrical Connector Pins only.

Clarify that LRA section 2.5.4 Electrical Connector Contacts covers all Electrical Connector Contacts (Metallic) including Electrical Connector Pins exposed to the borated water or provide justification for deviating from Staff position stated in NUREG 1801, Rev. 1.

NSPM Response The LRA refers to the electrical commodity group "Electrical Connector Contacts (metallic connector pins exposed to borated water)" using the terms:

x Electrical Connector Contacts x

Electrical Pinned Connectors x

Metallic Connector Pins These terms are synonymous with the NUREG-1801, Rev 1, Volume 1, Table 6, ID 5, component group wording "Connector contacts for electrical connectors."

1717 Wakonade Drive East

Welch, Minnesota 55089-9642 Telephone: 651.388.1121 January 16, 2009 L-PI-09-001 10 CFR 54 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Responses to NRC Requests for Additional Information Dated December 2, 2008 Regarding Application for Renewed Operating Licenses By letter dated April 11, 2008, Northern States Power Company, a Minnesota Corporation, (NSPM) submitted an Application for Renewed Operating Licenses (LRA) for the Prairie Island Nuclear Generating Plant (PINGP) Units 1 and 2. In a letter dated December 2, 2008, the NRC transmitted Requests for Additional Information (RAIs) regarding that application. This letter provides responses to those RAIs. provides the text of each RAI followed by the NSPM response.

In addition, during a telephone conference call on January 9, 2009, clarification was requested for the electrical commodity group "Electrical Connector Contacts (Metallic Connector Pins Exposed to Borated Water), discussed in LRA Section 2.5.4. The requested clarification is provided in Enclosure 2.

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

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

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

Executed on January 16, 2009.

/S/ Michael D. Wadley Michael D. Wadley Site Vice President, Prairie Island Nuclear Generating Plant Units 1 and 2 Northern States Power Company - Minnesota

Document Control Desk Page 2 Enclosures (2) cc:

Administrator, Region III, USNRC License Renewal Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC Prairie Island Indian Community ATTN: Phil Mahowald Minnesota Department of Commerce NSPM Responses to NRC Requests for Additional Information Dated December 2, 2008 1

RAI 2.3.3.11-01 BACKGROUND:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to identify and list all components subject to an AMR. The staff confirms inclusion of all components subject to AMR by reviewing the component types within the license renewal boundary.

ISSUE:

During the scoping and screening review process the continuation of lines within the scope of license renewal from one drawing to another could not be established.

Drawing numbers and/or locations for the continuations were not identified.

Drawing LR-39605-1, location A4 and B4: Continuation notes indicate To and From Dryers #121, #122, and #123, as well as To Washers #121, #122, and

123. No drawing number is given for these continuations.

Drawing LR-39605-1, location A2: Continuation note indicates Radwaste Bldg Sply. but does not give a drawing number.

Drawing LR-39605-1, location F2: Continuation note indicates To Aux Cond Ret. but does not give a drawing number.

Drawing LR-39605-1, location F2: Continuation note indicates To Sample Station but does not give a drawing number.

Drawing LR-39605-1, location F4: No continuation note on left side of 11/2 Deaerator Header.