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Summary of Meeting with Northern States Power Company, Post Submittal Meeting for the Independent Spent Fuel Storage Installation License Renewal at the Prairie Island Nuclear Generating Plant
	ML113540581
Person / Time
Site:	Prairie Island
Issue date:	12/18/2011
From:	Michael Waters; NRC/NMSS/SFST
To:	Eric Benner; NRC/NMSS/SFST
	Longmire P, NMSS/SFST 301-492-3562
Shared Package
ML113540578	List: ML113540581; ML113540582;
References
	TAC L24589
	Download: ML113540581 (8)
	v • d • e

December 18, 2011 MEMORANDUM TO:

Eric Benner, Acting Deputy Director Licensing and Inspection Directorate Division of Spent Fuel Storage and Transportation, NMSS FROM:

Michael D. Waters, Chief

/RA/

Licensing Branch Division of Spent Fuel Storage and Transportation, NMSS

SUBJECT:

SUMMARY

OF NOVEMBER 18, 2011, MEETING WITH NORTHERN STATES POWER COMPANY - A MINNESOTA CORPORATION (NSPM), FORMERLY NUCLEAR MANAGEMENT COMPANY D/B/A XCEL ENERGY, POST SUBMITTAL MEETING FOR THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) LICENSE RENEWAL AT THE PRAIRIE ISLAND NUCLEAR GENERATING PLANT (PINGP)

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Background===

Northern States Power Company (NSPM) doing business as (d/b/a) Xcel Energy submitted an application to renew the Prairie Island (site-specific) ISFSI License No. SNM-2506. The site specific license for the Prairie Island ISFSI expires on October 31, 2013. The license renewal regulation, Energy - Title 10 of the Code of Federal Regulations, 10 CFR 72.42 requires submittal of the renewal application at least two (2) years prior to the license expiration. In October 1993, Prairie Island was licensed to store spent fuel in the TN-40 bolted cask design.

Therefore, Prairie Island submitted an application for renewal by letter dated October 20, 2011.

The application requests to extend the license by an additional 40 years. The purpose of the scheduled post-submittal public meeting was to discuss with the NRC staff Prairie Islands licensing approach, the technical content of the license renewal application, and the results of the process used for the scoping, screening, and aging management reviews. The intent of the meeting was to provide the NRC staff an understanding of the approach and the process that Prairie Island used to develop its application and to facilitate an open dialog between NSPM and the NRC staff. The four topics discussed in the meeting included: ISFSI Site & License Background; Licensing Approach for Application; License Renewal Application (technical content review); and the Environmental Report Supplement.

The meeting was noticed on November 3, 2011. The Agency-wide Documents Access and Management System (ADAMS) accession number for the meeting notice is ML113120114. The meeting agenda is provided as Enclosure 1. The meeting attendance list is provided as. Enclosure 3 is the handout from the public meeting.

Discussion NSPM started the discussion by describing the location and licensing history of the Prairie Island Independent Spent Fuel Storage Installation (PI-ISFSI). The PI-ISFSI is located approximately 30 miles southeast of the St. Paul/Minneapolis metropolitan area. The PI-ISFSI is located in the owner-controlled area of the PINGP. There are twenty-nine (29) TN-40 casks

loaded and stored at the PI-ISFSI. When discussing the topic of Licensing Approach for Application, NSPM cited the use of NUREG-1927, Standard Review Plan for Renewal of Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance, in the development of their renewal application. NSPM claimed to have satisfied the requirements of 10 CFR 72.42 by including an Aging Management Program, Time-Limited Aging Analyses, and the most recent design bases.

For the License Renewal Application Content part of the discussion, NSPM walked through the technical content for each of the individual sections and appendices of the license renewal application. NSPM described the process used for the scoping, screening, and aging management reviews. NSPM also described the ten elements of its Aging Management Program and the identified Time-Limited Aging Analyses. Included in a section titled supporting slides located at the end of the presentation handout are the results from the scoping process and aging management reviews.

The bullets listed below provide a synopsis of the discussion for each of the individual sections and appendices of the license renewal application.

General Information: Section 1.0 of the application includes information to satisfy the requirements of 10 CFR 72.22. It also has information on the format and content of the application, as well as abbreviations for intended functions. NSPM also included information on the financial assurance for decommissioning in Section 1.0.

Scoping Evaluations: Section 2.0 of the application includes the criteria used for determining what structures, systems or components (SSC) are in-scope for the license renewal. This section of the application also includes results of the scoping evaluation and the intended functions for each of the SSCs.

o NRC staff had questions regarding the scoping results for the interseal pressure monitoring system, the intended function of a fuel pellet, and whether or not retrievability should be considered an intended function.

Aging Management Reviews: Section 3.0 of the application includes information on the identified aging effects for ISFSI subcomponents and the results of aging management reviews.

o NRC staff had several questions on the process and results of the aging management reviews.

o NRC staff had questions on the function and design of the interseal pressure monitoring system; of particular concern, was the reliability of the equipment and its alarming function. NRC staff was concerned that if the monitoring equipment failed, there would be no means to detect seal failure. NSPM agreed to provide a summary of the operations and surveillance procedures for the daily alarm surveillance check and any preventative maintenance performed on the system.

o NRC staff wanted to know how the alarm setpoint for the pressure monitoring system equated to seal leakage. NRC staff was concerned that there would be gross leakage from the seals before the monitoring system alarmed. NSPM agreed to equate the pressure monitoring system alarm setpoint to seal leakage.

o NSPM and NRC staff discussed whether or not guide tube anchors should have an aging management activity, as the anchors are relied on for retrieving spent fuel assemblies.

Aging Management Program: Appendix A includes information on each of the ten elements proscribed by NUREG-1927 for an Aging Management Program. It also includes a summary of Prairie Island and industry Operating Experience (OE) for aging effects and aging management.

o NSPM described the results of the lead cask inspection it performed in June 2011. NRC staff had questions regarding the thresholds for initiating corrective actions and the frequency of visual inspections of inaccessible areas of the cask.

The NRC mentioned that new requirements for inspecting the metallic seals may be needed to address recent OE from Peach Bottom.

Time-Limited Aging Analyses (TLAA): Appendix B defines the criteria for a TLAA and summarizes the two TLAAs identified for the TN-40HT cask design.

o NSPM described the two TLAAs identified in its reviews of the licensing and design bases, and described how NSPM dispositioned these TLAAs.

Safety Analysis Report Supplement and Changes (Appendix C): NSPM commits to updating the ISFSI Safety Analysis Report (SAR) to include summary descriptions of the ISFSI Aging Management Program and Time-Limited Aging Analyses. The changes to the SAR will be incorporated in the first SAR update made in accordance with 10 CFR 72.70 following the issuance of the renewed materials license.

Technical Specification Changes (Appendix D): No changes were made to the ISFSI Technical Specifications as a result of the license renewal. In accordance with NUREG-1927, NSPM has proposed no changes to its licensing or design basis in the license renewal application.

Additional Information: Appendix F provides information on technical qualifications, personnel training, and the operating organization of the ISFSI to satisfy the requirements of 10 CFR 72.28. NSPM did not provide information on its Emergency Plan or Security Plan in its application, as these programs were unaffected by the license renewal, and are not considered in-scope.

The last topic of the presentation NSPM discussed was the content of Appendix E, the Environmental Report Supplement. NSPM summarized the results of its Environmental reviews and described which sections of their Environmental Report that required updating as part of the license renewal.

NRC staff and NSPM discussed the possibility of a site visit or audit at the PINGP. NSPM was of the opinion that a site visit would help the technical reviewers become familiar with the location and configuration of the Prairie Island ISFSI. A site visit would also allow the NRC to review Prairie Islands aging management procedures and supporting documentation. NRC staff from the Federal and State Materials and Environmental Management Programs (FSME) suggested that a public meeting be held with stakeholders for the National Environmental Policy Act (NEPA) or Environmental Report review during the NRCs site visit.

Actions items:

NSPM Evaluate whether or not the top nozzle anchors should be considered in the aging management review.

Explain why NSPM identified no aging effects/mechanisms for subcomponents in air/gas environments.

Equate the alarm setpoint for the interseal pressure monitoring system to leakage of helium through the metallic seals.

Describe the vent path for the buildup of gases in the radial neutron shield. Reference the applicable SAR sections.

Provide a summary of the Operations procedure for the daily alarm surveillance of the interseal pressure monitoring system. Also, provide details of any preventative maintenance of the equipment in the interseal pressure monitoring system.

Ensure the results from the lead cask inspection performed in June 2011 at the Prairie Island ISFSI are available to the NRC technical reviewers.

NRC Schedule a 2012 site visit or audit at the Prairie Island Nuclear Generating Plant. NRC staff will consider contacting a representative of the Prairie Island Indian Community to observe the activity.

NRC staff will consider a public meeting with stakeholders for the National Environmental Policy Act (NEPA) or Environmental Report review. Additional public meetings to discuss the license renewal application (LRA) with stakeholders are not required, but may occur at NRCs discretion.

Neither, NRC staff nor NSPM, made any regulatory commitments at the meeting. This meeting summary closes TAC No. L24589.

Docket No. 72-10 TAC No. L24589

Enclosures:

1. Meeting Agenda

2. List of Meeting Attendees

3. Presentation Slides