ML112990018

Audit of the Licensees Regulatory Commitment Management Program

ML112990018
Person / Time
Site:	Prairie Island
Issue date:	12/19/2011
From:	Thomas Wengert Plant Licensing Branch III
To:	Schimmel M Northern States Power Co
Wengert, Thomas J, NRR/DORL, 415-4037
References
TAC ME6394, TAC ME6395
Download: ML112990018 (25)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 19, 2011 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 -AUDIT OF THE LICENSEE'S REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NOS. ME6394 AND ME6395)

Dear Mr. Schimmel:

An audit of the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, commitment management program was performed at the plant site on September 12 - 14, 2011. In U.S.

Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21,2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to NRC.

The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

Based on the audit, the NRC staff concludes that Northern States Power Company, a Minnesota corporation (the licensee) has implemented NRC commitments on a timely basis, and the licensee has implemented an effective program for managing NRC commitment changes at PINGP, Units 1 and 2. The details of the results of the audit are set forth in the enclosed audit report.

M. Schimmel

- 2 The NRC staff appreciates the resources that were made available by your staff for performing the audit. If you have any questions, please contact me at (301) 415-4037 or via e-mail at Thomas.Wengert@nrc.gov.

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:

As stated cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS NORTHERN STATES POWER COMPANY - MINNESOTA PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306

1.0 INTRODUCTION AND BACKGROUND

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that commitments are implemented and that changes to the commitments are evaluated and, when appropriate, reported to NRC.

The NRC's Office of Nuclear Reactor Regulation (NRR) prepared and issued Office Instruction LlC-105, "Managing Regulatory Commitments Made by Licensees to the NRC." Revision 3 to LlC-105 was issued on March 30,2009 (ADAMS Accession No. ML090640415). LlC-105 is consistent with the NEI 99-04 guidance, and provides guidance to the NRC staff for handling regulatory commitments made by licensees of commercial nuclear reactors. NRR, through LlC-105, has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory commitments are being effectively implemented.

As defined in NEI 99-04 and LlC-105, a "regulatory commitment" is an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. The guidance provided in LlC-105 instructs the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and licensing activities (bulletins, generic letters, etc.).

A summary of the NRC staff's activities, reviews, and conclusions is presented below.

Enclosure

- 2 2.0 AUDIT PROCEDURE AND RESULTS An audit of the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, commitment management program was performed at the plant site on September 12 - 14, 2011. The audit scope included a review of commitments made by Northern States Power Company, a Minnesota corporation (NSPM, the licensee), since the previous audit on June 23,2008, which was documented in an audit report dated August 6, 2008 (ADAMS Accession No. ML082120603).

The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments.

2.1 Verification of Licensee's Implementation of Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.

2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments, as defined above, made in writing to the NRC as a result of past licensing actions (amendments, exemptions, relief requests, etc.) and licensing activities (bulletins, generic letters, etc.). Prior to the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit, and selected a representative sample of commitments for verification. In addition, the licensee prepared a listing of commitments and commitment changes made during the period of interest. From the lists, the NRC staff selected a representative sample of regulatory commitments and commitment changes to audit. The identified list of commitments and changes was forwarded to the licensee on August 25, 2011, with a request to collect the associated documentation for the listed commitments in advance of the NRC staff audit.

The audit excluded the following types of commitments:

(1)

Commitments made on the licensee's own initiative among internal organizational components.

(2)

Commitments that pertain to milestones of licensing actions/activities (e.g.,

responding to an NRC request for additional information by a certain date).

Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3)

Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

- 3 (4)

Commitments related to the PINGP license renewal.

2.1.2 Audit Results The licensee has implemented procedure FP-R-LlC-24, Rev.O, "NRC Commitment Management," dated February 24, 2011, which describes the method and responsibilities for the maintenance of regulatory commitments made to the NRC to ensure that the commitments are properly identified, tracked, closed out, revised/changed, or deleted. The licensee uses the program to track the status and manage the closure of commitments at PINGP. This procedure, which is based on the guidance provided by NEI 99-04, has replaced licensee procedures FG-R-CM-01, "Regulatory Commitment Management," and 5AWI, "Control of Commitments."

The licensee explained that FG-R-CM-01 has been retired to FP-R-LlC-24, while 5AWI is now used exclusively for non-NRC commitments.

Two deficiencies in the licensee's commitment management program documents were identified during the audit, as noted below:

• The flow chart in licensee procedure FP-R-LlC-24, Figure 1 (comparable to NEI 99-01, Figure A-1), refers to Figure 2 within the flow chart. However, Figure 2 is not included in the procedure document. Figure 2 is presumably comparable to Figure A-2 of NEI 99

01. During the audit, the licensee entered this apparent deficiency into their corrective action program for resolution (AIR No. 01303685).

• Licensee procedure 5AWI (concerning non-NRC commitments) Section 1.7.0 was not updated to reflect that the new NRC commitment procedure (FP-R-LlC-24) had been implemented. The references to NRC commitments should have been deleted or superseded. During the audit, the licensee entered this apparent deficiency into their corrective action program for resolution (AIR No. 01303464).

The licensee's program provides acceptable tools and guidance for the licensee to capture the NRC guidance on commitment management programs. The licensee enters commitments made to the NRC into a commitment management database called "PassPort." This database is used to track regulatory commitments, as well as corrective action items. The field for Action Request ("AIR") type in the database further identifies the item as a General Action Request

("GAR"), which includes regulatory commitments, or as a corrective action item ("CAP") for the purposes of tracking. The status of the commitments, implementation dates, target implementation document information, and comments associated with each specific commitment are captured in the program and can be summarized in a report.

The documents furnished by the licensee during the audit included summary sheets from the PassPort system, which provided the status of the commitments, and the appropriate backup documentation, as needed (e.g., plant procedures, examination records, and/or other plant documentation incorporating the commitments). The NRC staff reviewed the documents and summarized the results of the review in the table attached to this audit report.

This part of the NRC staff's audit was intended to confirm that the licensee has documented its implementation of commitments made to the NRC staff as part of past licensing communications, and that the commitments that had not yet been implemented or incorporated in design bases documents were captured in an effective manner for future implementation.

-4 During the review, the staff identified the following deficiencies in the implementation of the licensee's commitment management program for PINGP, Units 1 and 2 (refer to the table attached to this report for the commitment number and description of the commitments sampled):

• Commitment 01291634-01: This commitment was made in a letter dated January 30, 2009, but was not entered into the system until June 28, 2011. The commitment was fulfilled via a letter dated February 20, 2009, however, the commitment was not closed in the system until June 28, 2011. This commitment is identified as a "Legacy Commitment" in the PassPort database because it had not been entered into the tracking system until after it had been completed. Note: During the audit, the licensee informed the reviewer that they have prepared and instituted an "Outgoing Correspondence Checklist" (Form OF-0743, Rev. 0) that includes a check-off box for commitments/changes and their entry into the PassPort system.

• Commitment 01298011-01: This commitment was made in a letter dated April 15, 2009, but was not entered into the system until August 5, 2011. The commitment was fulfilled via license amendments 193 (Unit 1) and 182 (Unit 2), which were implemented in 2009, however, the commitment was not closed in the system until August 5, 2011. This commitment is identified as a "Legacy Commitment" in the PassPort database because it had not been entered into the tracking system until after it had been completed. Note:

During the audit, the licensee informed the reviewer that they have prepared and instituted an "Outgoing Correspondence Checklist" (Form OF-0743, Rev. 0) that includes a check-off box for commitments/changes and their entry into the PassPort system.

• Commitment 01207012-01: This commitment, which concerns satisfying certain (one time and continuous) conditions and limitations associated with the use of Optimized ZIRLO' fuel, was made in a "L-PI-09-122, Supplement to Responses to Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated November 24,2009]], and was originally closed in the PassPort database on November 8, 2010. In January, 2011, an on-site Commitment Control Challenge Board determined that this commitment had been closed prematurely, and requested that the commitment be re-opened and tracked until the associated topical report was approved by the NRC staff. However, following the Challenge Board's decision in January 2011, the original commitment was not correctly re-opened in the commitment tracking system and, consequently, two commitments were open for the same issue. The original commitment was properly re-opened in the tracking system on October 3, 2011, and was assigned a due date of April 30, 2015.

• Commitment 01207012-02: This commitment, which concerns satisfying certain (one time and continuous) conditions and limitations associated with the use of Optimized ZIRLO' fuel, was made in a "L-PI-09-122, Supplement to Responses to Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated November 24,2009]], and was originally closed in the PassPort database on November 8, 2010. In January, 2011, an on-site Commitment Control Challenge Board determined that this commitment had been closed prematurely, and requested that the commitment be re-opened until additional closure documentation was provided. However, following the Challenge Board's decision in January 2011, the original commitment was not correctly re-opened in the commitment tracking system and, consequently, two commitments were open for the same issue. The original commitment was properly re-opened in the tracking system on October 3,2011, and was assigned a due date of April 30, 2015.

- 5 Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented the regulatory commitment management program adequately and consistent with NEI 99-04, with the exception of the deficiencies identified during the audit. The deficiencies identified had no safety significance and, as noted, the licensee has taken appropriate corrective actions to address the deficiencies.

2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes 2.2.1 Audit Scope The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at PINGP, Units 1 and 2, is contained in procedure FP-R-LlC-24, Rev. O.

The NRC staff reviewed the licensee's procedure against the guidance provided in NEI 99-01.

The change process is based on the NEI 99-01 guidance. Regulatory commitment changes are processed and tracked by Regulatory Affairs Department (Site Licensing) and are approved by the Site Management. Regulatory Commitment Change Request Form QF-0729 is used to document the evaluation of commitment changes.

The primary focus of the audit was to ensure that commitments are implemented without a change or, if a change is made, it is made in accordance with approved plant procedures and with the approval of licensee management. Another purpose of the audit was to verify whether the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to design features or operating procedures, which may be subject to regulatory commitments, require evaluation in accordance with the commitment change control process.

2.2.2 Audit Results 2.2.2.1 Commitment Changes Reported to the NRC The NRC staff sampled two commitment changes that were reported to the NRC, as follows:

• Commitment Change No. 09-02, concerning the licensee's 9-Month Response to NRC Generic Letter 2008-01. This change was appropriately evaluated and documented.

The NRC was notified of this change by letter dated September 28, 2009 (ADAMS Accession No. ML092730109).

• Commitment Change No. 09-04, concerning the licensee's 30-Day Response to NRC Bulletin 2003-02. This change was appropriately evaluated and documented. The NRC was notified of this change by letter dated October 9, 2009 (ADAMS Accession No. ML092860612).

The NRC staff found no deficiencies in the documents sampled for this part of the audit.

-6 2.2.2.2 Commitment Changes Not Reported to the NRC The NRC staff sampled two commitment changes that were not reported to the NRC, as follows:

Commitment Change No. 08-05, concerning the anticipated transient without scram mitigating system actuating circuitry. The NRC reviewer noted that the Commitment Change Evaluation for 08-05 did not include any documentation demonstrating that that the change had been approved by the site management, as required by procedure FP R-LlC-24. The licensee informed the reviewer that this evaluation was prepared in 2008, and that the procedure in effect at that time (FG-R-CM-01) did not require approval for this type of change. The licensee further noted that site management approval is now required per the licensee's new procedure. No other deficiencies were identified.

• Commitment Change No. 10-05, concerning a corrective action associated with LER-1 97-02. This change was appropriately evaluated and documented. No deficiencies were identified.

2.2.2.3 Summary Based on its review, the NRC staff concludes that the licensee has properly addressed each regulatory commitment change selected for this part of the audit and that the licensee has implemented an effective program to manage commitment changes. In addition, the NRC staff noted that the method of linking specific changes in procedures to specific regulatory commitments was adequate, and resulted in traceability in the most recently revised procedures.

3.0 CONCLUSION

Based on the results of the audit, the NRC staff concludes that the licensee has implemented the commitment management program effectively, and has implemented commitment changes appropriately consistent with NEI 99-04. The deficiencies identified during the audit, which are summarized in Sections 2.1.2 and 2.2.2 of this report, did not have any safety significance. The NRC staff notes that the licensee has taken appropriate actions to correct the deficiencies identified during the audit.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Marlys Davis, Regulatory Affairs Dale Vincent, Site Licensing Principal Contributor: T. Wengert Date:

December 19, 2011

Attachment:

Audit Summary Table

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2

,l.etter No.

, Subject mm Commitment No. ((ascription of Commitment

'Implementation Status L-PI-08-072, dated September 15, 2008 (ADAMS Accession No. ML082600139) r~~~~~~~~~~~

Updated Three month Response to GL 08-01 01150334-01 N MC will submit all the information requested in GL 2008-01 for the nine-month response, with the exception of the results of the evaluation of piping walkdowns.

Closed 10/14/08 Requested information was submitted in 9-month response dated 10/14/08 (L-PI-08-088) 01150334-02 NMC will submit the results of the evaluation of accessible area walkdowns and Unit 2 containment and RHR pit walkdowns with the follow-up report 90 days following the completion of 2R25.

This letter revises the second commitment made in Reference 2 to:

NMC will submit results of the evaluations of the walkdowns of Unit 1 containment and RHR pits 90 days following the completion of 1 R26.

Closed 1130109 The letter and report were submitted on 1/30/2009 (L-PI-09-0 12)

Closed 2/18/2010 The letter and report were submitted on 2/18/2010 (L-PI-10-005) 01150334-03 1

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 I Letter No.

I SubjeCt:

I Commitment No. I Description of Commifment

• .. 1Implementation Status L-PI-08-080 dated November 4, 2008 (ADAMS Accession No. ML083110125)

LAR to Revise EDG Test Loads in SR 3.8.1.3 and 3.8.1.9 01158774-01 Upon approval by the NRC, NSPM will implement the following commitment with implementation of the monthly test load changes proposed in this LAR:

The Prairie Island Nuclear Generating Plant Unit 2 Emergency Diesel Generators (EDGs) will be tested at or above 90% of their rated load on a schedule consistent with SR 3.8.1.3. Abnormalities in EDG performance between the SR 3.8.1.3 test load and the rated load will be evaluated under NSPM's corrective action program, which incorporates trending capabilities, and corrected under the maintenance program.

Closed 4/26/2010 Commitment was withdrawn per letter dated 3/30/2010 (L-PI-10-023) 2

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED I Letter NC>.

L-PI-08-088, dated October 14, 2008 (ADAMS Accession No. ML082880483)

L-PI-08-088, dated October 14, 2008 (ADAMS Accession No. ML082880483)

FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2

[SlI6jeCt

~mmitment No.1 Description of Commitment IlmplementatiolJ Status Nine Month Responses to GL 08 01 Nine Month Responses to GL 08 01 01155174-01

1. NSPM will develop a Technical Requirements Manual Surveillance Requirement to periodically verify the piping is suffiCiently full such that its functional requirements are maintained.

Closed 7/9/2009 This commitment was revised in letter dated 1/30/2009 (L-PI-09 012).

01155174-02

2. NSPM will evaluate the resolution of TS issues with respect to the changes contained in the TSTF traveler to determine applicability and further assess any changes to the TS and TS Bases.

Closed 1118/2010 This commitment was closed since it was superseded by 0115517408.

01155174-03

3. NSPM will identify corrective actions to minimize gas accumulation and its consequences for Unit 1 outside containment accessible areas and Unit 2 inside and outside containment and the Unit 2 RHR pit areas in the 90-day 2R25 post outage report.

Closed 1/30/2009 The commitment was fulfilled with the submittal of the 90-day 2R25 post-outage report (L-PI-09-0 12).

01155174-04

4. NSPM will identify corrective actions to minimize gas accumulation and its consequences for Unit 1 inside containment and the Unit 1 RHR pit areas in the 90-day 1 R26 post-outage report.

Closed 1/1112010 The commitment was fulfilled with the submittal of the 90-day 1 R26 post-outage report (L-PI-10-005).

3

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14,2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 1"'":1L-e-tte-r-=-N-:-o-.--'Ir-":S=-u-:--"bj-:-'e-ct--

I Commitment No. I Description of Commitment I Implementation StatusJ 01155174-05

5. NSPM will complete a formal evaluation of vortexing in the caustic addition standpipe.

Closed 4/13/2009 Calculation ENG-ME 650 Rev. 0, "Caustic Addition Standpipe Volume Calculation,"

was approved on 4/13/09, fulfilling the commitment.

01155174-06

6. NSPM will state in the procedure purpose for procedures that perform RHR and SI check valve testing (e.g., SP 1092A) that they also dynamically vent the RHR and SI systems. These procedures will explicitly recognize their dynamic vent capability. NSPM will ensure that these outage procedures will be scheduled appropriately as a post-maintenance verification for activities in an outage that may introduce voids into the systems.

Closed 12/15/2009 Commitment was revised by QF-0729 on 10/14/08 and captured in commitment no.

01155174-07 4

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 I Letter No.

ISubject I Commitment No. I Description of Commitment I Implementation Status L-PI-09-011 dated January 30, 2009 (ADAMS Accession No. ML090300684)

Response to RAI Regarding LAR for Heavy Bundle Fuel LAR 01291634-01 NSPM shall respond to Question 3 no later than February 20,2009.

Closed 6/28/11 This one-time commitment was fulfilled via letter L-PI-09-025 dated 2/20/2009. This is identified by the licensee as a "Legacy Commitment. n Note: The due date of the commitment in the January 30, 2009 letter was incorrectly identified as February 20, 2008.

5

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 I [etter No.

I Subject

~rr'lrr'litr'l'1el"lt No: [ Description of Commitment I Implementation Status L-PI-09-012 90 Day 2R25 Report 01168385-01

1. Corrective actions for fourteen locations Closed 3/9/2009 dated for GL 08-01 (U1) were identified during the drawing reviews January 30, as inverted U or dead end tee pipe These commitments 2009 (ADAMS 01168385-02 config urations and corrective actions were entered into the Accession No.

(U2) for an additional eleven locations were system incorrectly (had ML090300705) discussed in Statement 7 of the incorrect descriptions)

Enclosure. Unit 1 corrective actions will be and were reopened completed by the end of refueling outage 1 under different R27 in 201 1, and Unit 2 corrective actions commitment numbers.

will be completed by the end of refueling outage 2R26 in 2010.

01168385-03

2. An analysis, that assumes a void is Closed 6/30/2009 present, will be completed on the inaccessible susceptible void location (2SI An evaluation of

32) on the cross-tie line from 21 RHR susceptible locations pump to the 21 SI pump in the second was performed per EC quarter of 2009.

131617. The evaluation demonstrated that the stresses and loads are acceptable.

6

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 IULetterNo.mml Subject ICommitment No. I Description of Commitment Ilmplementatic)O Status 01168385-04 (U1) 01168385-05 (U2)

3. An extent of condition review of flow element and orifices considering lessons learned from evaluating the voids in the RHR pump miniflow lines, completed January 24,2009, identified additional locations to evaluate. The corrective actions (that is, walkdowns) for this extent of condition review will be completed for the Units 1 and 2 locations outside containment in the second quarter of 2009. The Units 1 and 2 locations inside containment will be completed consistent with accessibility no later than 1 R26 in 2009 and 2R26 in 2010, respectively.

Closed 3/9/2009 These commitments were entered into the system incorrectly (had incorrect descriptions) and were reopened under different commitment numbers.

7

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 I Letter No.

I Subject I Commitment No. I Description of Commitment I Implementation Status L-XE-09-006, LAR for Adoption of Removal of the plant-specific TS 01298011-01 Closed 8/5/2011 dated April 15, TSTF-511, Eliminate requirements will be performed 2009 Working Hour concurrently with the implementation of the This commitment was I

(ADAMS Restrictions from TS 10 CFR Part 26, Subpart I requirements.

fulfilled via license Accession No.

5.2.2 This commitment will be completed no later amendments 193 (U 1 )

ML091050619) than October 1, 2009.

and 182 (U2). This is identified by the licensee as a "Legacy Commitment."

L-PI-09-125, LAR for Optimized 01207012-01

1. In the course of the core reload process Closed/Re-opened dated ZIRLO' approved for use at PINGP, and~rior to November 24, first loading of Optimized ZIRLO M The TS changes were 2009 (ADAMS Westinghouse will be programmatically incorporated in TS Accession No.

required to evaluate the effects of Amendment 148, issued ML093280883)

Optimized ZIRLO' on PINGP core on October 1, 2009.

performance and accident analysis. To satisfy NRC Safety Evaluation An on-site Commitment (SE) for Optimized ZIRLO ' NSPM will Control Challenge confirm that core reload safety evaluations Board determined that satisfy conditions and limitations 3, 4, 5, 8, the commitment had and 10 of the NRC SE for Optimized been closed ZIRLOTM. Continuous, until the prematurely. The contingency requirements of the conditions commitment was and limitations have been satisfied.

subsequently re-opened on October 3, 2011.

8

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 I Letter No.

I Subject I Commitment No. I Description of Commitment I Implementation Status 01207012-02

2. To satisfy NRC SE for Optimized ZIRLO', NSPM will confirm that Westinghouse provides additional confirmatory data associated with Lead Test Assembly (L TA) programs at other facilities prior to operation with Optimized ZIRLO' fuel rod cladding. This commitment relates to conditions and limitations 6 and 7 of the NRC SE for Optimized ZIRLOTM. Continuous, until the LTA data up through the fuel burnup limit applicable for PINGP has been provided to the NRC.

Closed/Re-opened The TS changes were incorporated in TS Amendment 148, issued on October 1, 2009.

An on-site Commitment Control Challenge Board determined that the commitment had been closed prematurely. The commitment was subsequently re-opened on October 3, 2011.

9

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14,2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT1 UNITS 1 AND 2 I Letter No.

I Subject I Commitment Nc;). I Description of Commitment Ilmplementatic;)n Status L-PI-09-122, dated November 24, 2009 (ADAMS Accession No. ML093280925)

Supplement to Responses to GL 2008-01 01155174-08 Industry resolution of the gas accumulation Technical Specification (TS) issues will be monitored and, if necessary, a license amendment request will be submitted within one year following NRC approval of the Technical Specification Task Force Traveler (TSTF) or consolidated line item improvement process (CUIP) Notice of Availability, that is consistent with resolution of the generic changes process.

Open The NRC has not yet approved a TSTF or CUIP associated with this item.

L-PI-09-133, dated December 28, 2009 (ADAMS Accession No. ML093650046}

LAR for MUR Power Uprate 01212954-01

1. The PINGP Technical Requirements Manual (TRM) will be revised to include LEFM administrative controls. Prior to operating above 1650 MWt (typical for all MUR commitments).

Closed 9/21/2010 New TRM Section 3.3.6 was implemented in TRM Revision 18.

01212954-02

2. Revise ERCS Alarm Response Procedure to reflect any changes in LEFM status such as outage time and power limits.

Closed 9/17/2010 ERCS Alarm Response Procedure C47041 Revision 12.

10

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14,2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 I Letter No.

I Subject I Commitment No.,Description of Commitment I Implementation Status 01212954-03

3. Revise CHECWORKS models to incorporate flow and process system conditions that are determined for the MUR PU conditions.

Closed 9/21/2010 U1 and U2 CHECWORKS SFA 2.1 models were revised to incorporate new MUR power level.

01212954-04

4. Revise Emergency and Abnormal Operating Procedures that are power dependent.

Closed 8/23/2010 EOPs required to support MUR have been issued as part of EC 13597. No Abnormal Procedures required revision.

01212954-05

5. Recalibrate BOP system alarms due to small process condition changes.

Closed 9/9/2010 Licensee verified that no BOP alarms are impacted by MUR implementation.

01212954-06

6. Revise ERCS and Simulator Calorimetric and TPM programs with new administrative power limits based on LEFM status. Other core power dependent ERCS and Simulator programs such as Xenon, NIS Power, and Boron Concentration will be revised to reflect a core power of 1677 MWt.

Closed 10/11/2010 Simulator updated with MUR Uprate values on 917/10. Simulator testing complete 9/29/10. U2 ERCS calorimetric, TPM, Xenon, etc. updated on 10/4 and 10/11/2010.

11

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 I Letter N().

I Subject

-_.. I Commitment No. I DesCrij?Hon of Commitment I Implementation Status 01212954-07

7. Revise Operator Training Program to include changes to plant procedures and alarm responses in addition to Operator Training regarding the implementation of the allowable at-power administrative limits and new TRM governing LEFM out-of service time.

Closed 9/17/2010 Operator training required by this commitment is covered in Operator Training lesson plan.

01212954-08

8. Re-scale applicable control and protection instrumentation consistent with the increase in 100 percent nominal core power from 1650 MWt to 1677 MWt.

Closed 10/15/2010 Completed by work orders 404305 (U 1) and 404306 (U2) on 10/14/2011.

01212954-09

9. Revise ERCS TPM and CALM Programs to adjust the allowable licensed thermal power values used in these programs. Alarms will require evaluation and re-calibration, as required, to reflect small process changes in certain BOP systems. Other core power dependent ERCS programs such as Xenon, NIS Power, and Boron Concentration will be revised to reflect a core power of 1677 MWt.

Closed 10/11/2010 No BOP alarms impacted by MUR.

Other programs revised to reflect 1677 MWt.

01212954-10

10. As part of the ERCS TPM program changes, the time greater than 100 percent power incremental monitoring levels will be based on a power measurement uncertainty of 0.36 percent.

Closed 10/11/2010 Updates made under W.O. 404305 (U1) and 404306 (U2) 12

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2

[LetterNo.-. [SUbject I Commitment No. I Description of Commitment I Implementation Status L-PI-10-005, dated February 18, 2010,2010 (ADAMS Accession No. ML100500066) 90-Day 1 R26 Post Outage Report for GL 08-01 01168385-15 Corrective actions for three susceptible locations were identified as inverted U or dead end tee pipe configurations (Enclosure Table 2) and for six additional susceptible locations discussed in Statement 7 of the Enclosure. Unit 1 corrective actions will be completed by the end of refueling outage 1 R27 in 2011.

Closed 5/27/2011 All locations that were committed to have corrective actions completed by the end of 1 R27 in 2011 are complete. These were completed via modifications to add vent valves at each location. Completed under various work orders.

L-PI-10-036, dated April 19, 2010 (ADAMS Accession No. ML101090498)

Supplement to LAR for MUR Power Uprate 01212954-11 NSPM will submit justification for the Main Steam system stress analysis, including piping, supports, and components by August 27,2010.

Closed 8/2/2010 Justification provided by licensee in supplemental letter dated 6/17/2010.

13

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2

, Letter No.

, Subject

, Commitme'ltNo., Description of Commitment

'Implementation Status.,

L-PI-10-052, dated June 14, 2010 (ADAMS Accession No. ML101650544)

LAR to Use BEACON Power Distribution Monitoring System 01236136-01

1. Cycle-specific BEACON calibrations performed before startup and at beginning-of cycle conditions will ensure that power peaking uncertainties provide 95%

probability upper tolerance limits at the 95% confidence level. These calibrations are to be performed using the Westinghouse methodology. Until these calibrations are complete, more conservative default uncertainties will be applied. The calibrations will be documented and retained as records.

Open Licensee has action to issue procedure to initiate BEACON TSM calibrations described by the license amendment. Action due by 11/1/2011.

L-PI-10-098, dated October 14, 2010 (ADAMS Accession No. ML102880105)

Exigent LAR to Modify TS 3.8.1.10 for PINGP U1 01263702-01 NSPM will install a modification that will automatically shed the 12 Battery Charger from its normal bus and then repower the charger from the bus within the 60 seconds required by the Prairie Island Nuclear Generating Plant Technical SpeCifications surveillance requirement 3.B.1.10(c}.

NSPM will perform the modification during the Unit 1 2011 refueling outage.

Closed 12/20/201 0 Commitment was withdrawn via RAI response dated 10/18/2010 (L-PI-10 102}.

L 14

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 I Letter No.

I Subject I Commitrn~'ltN(). I Description of Commitment Ilmplementati()_r1Status L-PI-10-104, RAI Response 01263702-02 Northern States Power Company, a Open dated Associated with Minnesota corporation, will develop a October 20, Exigent LAR to Modify dynamiC electrical model for the Prairie Action is due by 2010 (ADAMS TS SR 3.8.1.10 Island Nuclear Generating Plant Unit 1 12/15/2011.

Accession No.

emergency diesel generators by ML102930575)

December 15, 2011.

L-PI-11-024, Supplement 1 to LAR 01284353-01 The Updated Safety Analysis Report will be Open dated concerning Battery updated to include the description of March15, 2011 Charger Replacement existing and new Unit 1 battery chargers, License amendment (ADAMS as applicable, within 6 months following where the commitment Accession No.

completion of the Unit 1 2011 refueling was made was ML110750198) outage.

approved on 4/29/2011.

Current due date is 12/3/2011.

L-PI-11-057, Request for Extension 01292172-01 NSPM will submit the License Amendment Open dated June 22, of Enforcement Request (LAR) implementing 10 CFR 2011(ADAMS Discretion and 50.48(c) for Prairie Island Nuclear Due date is 9/30/2012.

Accession No.

Commitment to Submit Generating Plant no later than ML111740866)

Date for September 30,2012.

10 CFR 50.48(c) LAR 15

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PERFORMED FROM SEPTEMBER 12 TO SEPTEMBER 14, 2011 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 I Letter No.

=rsUbjeCt~-------- TCQmmitment NO.1 Description of Commitment

___ I Implementation StatLJ§ J L-PI-11-069, dated July 11, 2011 (ADAMS Accession No. ML111930159) 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies 01296934-01 NSPM will include a requirement for continuing training on Extensive Damage Mitigation Guidelines (EDMG) in the PINGP training program for the Emergency Response Organization (ERO) qualified decision makers by January 13, 2012.

Open Due date is 1/13/2012.

16

ML112990018 Sincerely, IRA!

Thomas J. Wengert, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation OFFI RlLPL3-1/PM NRR/LPL3-1/LA NRR/LPL3-1/PM NAME TWengert BTuily illiams TWengert

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+--~~----~I DATE 12/16/11 12/16/11 12/19/11 12/19/11