ML093130076

Request for Additional Information Related to License Amendment Request to Revise Technical Specifications in Accordance with TSTF-448, Revision 3 - Control Room Habitability

ML093130076
Person / Time
Site:	Prairie Island
Issue date:	11/17/2009
From:	Thomas Wengert Plant Licensing Branch III
To:	Schimmel M Northern States Power Co
Wengert, Thomas J, NRR/DORL, 415-4037
References
TAC ME1605, TAC ME1606
Download: ML093130076 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 17, 2009 Mr. Mark A. Schimmel Site Vice President Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota 1717 Wakonade Drive East Welch, MN 55089-9642

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IN ACCORDANCE WITH TSTF-448, REVISION 3 - CONTROL ROOM HABITABILITY (TAC I\IOS. ME1605 AND ME1606)

Dear Mr. Schimmel:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated June 24, 2009 (Agencywide Documents Access and Management System Accession No. ML091760988), Northern States Power Company, a Minnesota corporation (the licensee), doing business as Xcel Energy, submitted a request to revise Technical Specifications (TSs) in accordance with TS Task Force (TSTF)-448, Revision 3, for the Prairie Island Nuclear Generating Plant, Units 1 and 2.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on October 29, 2009, it was agreed that you would provide a response within 45 days of the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.

Sincerely, Thomas J. Wengert, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306

Enclosure:

Request for Additional Information cc w/encl: Distribution via ListServ

REQUEST FOR ADDITIONAL INFORMATION PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306 In reviewing the Northern States Power Company, a Minnesota corporation (NSPM, the licensee), doing business as Xcel Energy, submittal dated June 24, 2009 (Agencywide Documents Access and Management System Accession No. ML091760988),

which requested Technical Specification (TS) changes related to control room envelope (CRE) habitability in accordance with TS Task Force (TSTF)-448, Revision 3, "Control Room Habitability," for the Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP), the U.S. Nuclear Regulatory Commission (NRC) staff has determined that the following information is needed to complete its review:

1. In order to be consistent with TSTF-448, the title of the "Control Room Habitability Program" in TS section 5.5.16 of your submittal should be "Control Room Envelope Habitability Program." Please update your submittal to include this change.

2. On page 3 of 6 of your submittal concerning Section 5.5.18.d (5.5.16.d of your submittal),

you stated that in lieu of the pressure test, NSPM proposes a PINGP Surveillance Requirement (SR) that will require a leakage test of outside air intake and boundary exhaust dampers. You also stated that the damper leakage SR would be included in the CRE Habitability Program as 5.5.16, sub-item (d), and that the addition of this SR will require the damper test to be performed at least once per operating cycle. The NRC staff believes that limiting a SR to outside air intake and boundary exhaust dampers is not consistent with the intent of TSTF-448, Rev. 3, Section 5.5.18.d.

To address this issue, other licensees have developed licensee-controlled programs that verify the integrity of the CRE boundary. Such a licensee-controlled program mayor may not include intake and exhaust dampers; the inclusion or exclusion of such dampers would be determined by the developer of the program. Therefore, in order to be in compliance with the intent of Section 5.5.18.d, PINGP should develop a program that includes a method to collect data that will serve as input to a periodic assessment of the CRE boundary. This position is supported by the technical analysis section of TSTF-448 Revision 3, page 8, where an explanation of the basis for paragraph (d) is provided.

3. In TSTF-448, Revision 3, the CRE Habitability Program TS Section 5.5.18.e (5.5.16.e of PINGP's submittal) states that the quantitative limits on unfiltered air inleakage into the CRE shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph (c). The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of design-basis accident consequences.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

ENCLOSURE

-2 PINGP elected to omit the last sentence that states, "Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis." As stated in your June 24, 2009, letter, you provided information by letter dated December 9, 2003 (ADAMS Accession No. ML033500298), indicating that the PINGP licensing basis does not assume limiting CR unfiltered in-leakage during these events. It is the NRC staff position that this is not consistent with the intent of the omitted sentence. The staff understands that there are no specific limits on hazardous chemicals and smoke. Nevertheless, the inclusion of the omitted sentence assures that licensees will abide by the licensing basis requirement for this issue. It does not change the licensing basis. Therefore, the staff is requesting that PINGP update the submittal to include the omitted sentence.

4. When section 5.5.16.d is updated in accordance this request, Section 5.5.16.f should also be updated to reflect the change is section 5.5.16.d.

Mr. Mark A. Schimmel Site Vice President Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota 1717 Wakonade Drive East Welch, MN 55089-9642

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IN ACCORDANCE WITH TSTF-448, REVISION 3 - CONTROL ROOM HABITABILITY (TAC NOS. ME1605 AND ME1606)

Dear Mr. Schimmel:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated June 24,2009 (Agencywide Documents Access and Management System Accession No. ML091760988), Northern States Power Company, a Minnesota corporation (the licensee), doing business as Xcel Energy, submitted a request to revise Technical Specifications (TSs) in accordance with TS Task Force (TSTF)-448, Revision 3, for the Prairie Island Nuclear Generating Plant, Units 1 and 2.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on October 29, 2009, it was agreed that you would provide a response within 45 days of the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.

Sincerely, IRA!

Thomas J. Wengert, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306

Enclosure:

Request for Additional Information cc w/encl: Distribution via ListServ DISTRIBUTION:

PUBLIC LPL3-1 R/F RidsNrrDorlLpl3-1 Resource RidsOgcRp Resource RidsNRRPMPrairielsland Resource RidsNrrLATHarris Resource RidsNrrDssScvb Resource H. Walker, NRR RidsAcrsAcnw MailCTR Resource RidsNrrDirsltsb Resource RidsNrrDorlDpr Resource V. Cusumano, NRR RidsRgn3MailCenter Resource ADAMS Accession Number' ML093130076 *via memo dated 10/5/09 OFFICE LPL3-1/PM LPL3-1/LA NRR/DSS/SCVB/BC LPL3-1/BC NAME TWengert THarris RDennig* RPascarelli DATE 11/16/09 11/17/09 10105/09 11/17/09 OFFICIAL RECORD COPY