ML12164A801
| ML12164A801 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 06/15/2012 |
| From: | Thomas Wengert Plant Licensing Branch III |
| To: | Molden J Northern States Power Co |
| Wengert T | |
| References | |
| TAC ME6471, TAC ME6472 | |
| Download: ML12164A801 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 15, 2012 Mr. James E. Molden 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 CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NOS. ME6471 AND ME6472)
Dear Mr. Molden:
On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies" (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML111250360), to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The purpose of the bulletin was to obtain a comprehensive verification that licensees' mitigating strategies to maintain or restore core cooling, spent fuel cooling, and containment following a large explosion or fire were compliant with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2).
The bulletin required two sets of responses pursuant to the provisions of 10 CFR 50.54(f). By letters dated June 9 and July 11, 2011 (ADAMS Accession Nos. ML111610510 and ML111930159, respectively), Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy, (NSPM, the licensee) provided its responses to the bulletin for Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2. By letter dated November 28, 2011 (ADAMS Accession No. ML113220222), the NRC sent the licensee a request for additional information (RAI) on its July 11, 2011, response. The licensee responded to the RAI by letter dated December 21,2011 (ADAMS Accession No. ML113570165).
The NRC staff reviewed the information submitted by NSPM for PINGP, Units 1 and 2, and concludes that its response to the bulletin is acceptable. As summarized in the enclosure, the NRC staff verified that the licensee provided the information requested in the bulletin. No further information or actions under the bulletin are requested.
J. Molden -2 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
SUMMARY
OF NRC REVIEW OF LICENSEE'S RESPONSES TO NRC BULLETIN 2011-01. "MITIGATING STRATEGIES" NORTHERN STATES POWER COMPANY - MINNESOTA PRAIRIE ISLAND NUCLEAR GENERATING PLANT. UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306
1.0 INTRODUCTION
On May 11,2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies," (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML111250360) to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The bulletin required two sets of responses pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(f). The first responses were due 30 days after issuance of the bulletin. By letter dated June 9,2011 (ADAMS Accession No. ML111610510), Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy, (NSPM, the licensee) provided its response to this first set of questions (first response) for Prairie Island Nuclear Generating Plant (PINGP),
Units 1 and 2. The second responses were due 60 days after issuance of the bulletin. By letter dated July 11, 2011 (ADAMS Accession No. ML111930159), the licensee provided its response to this second set of questions (second response). By letter dated November 28,2011 (ADAMS Accession No. ML113220222), the NRC sent a request for additional information (RAI) on the second response. The licensee responded to the RAI by letter dated December 21, 2011 (ADAMS Accession No. ML113570165). As summarized below, the NRC staff has verified that the licensee provided the information requested in the bulletin.
2.0 BACKGROUND
On February 25, 2002, the NRC issued EA-02-026, "Order for Interim Safeguards and Security Compensatory Measures" (ICM Order). Section B.5.b of the ICM Order required licensees to develop specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using readily available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with the loss of large areas of the plant due to explosions or fire.
By letter dated August 16, 2007 (ADAMS Accession No. ML072260364), the NRC staff issued its Safety Evaluation (SE) to document the final disposition of information submitted by the licensee regarding Section B.5.b of the ICM Order. Along with the SE, the staff issued a conforming license condition to incorporate the B.5.b mitigating strategies into the licensing basis.
On March 27, 2009, the NRC issued 10 CFR 50.54(hh)(2) as a new rule, in order to capture the B.5.b mitigating strategies and related license conditions as regulatory requirements for both Enclosure
-2 current and future licensees. At that time, licensee compliance with the conforming license conditions was sufficient to demonstrate compliance with 10 CFR 50.54(hh)(2) (74 FR 13926) so no further actions were required on the part of current licensees.
3.0 30-DAY REQUEST In order to confirm continued compliance with 10 CFR 50.54(hh)(2), the bulletin requested that licensees address the following two questions within 30 days of issuing the bulletin:
- 1. Is the equipment necessary to execute the mitigating strategies, as described in your submittals to the NRC, available and capable of performing its intended function?
- 2. Are the guidance and strategies implemented capable of being executed considering the current configuration of your facility and current staffing and skill levels of the staff?
The NRC staff reviewed the licensee's first response to determine if it had adequately addressed these questions.
3.1 Question 1: Availabilitv and Capability of Equipment In its first response, the licensee confirmed that the equipment it needs to execute the 10 CFR 50.54(hh)(2) mitigating strategies is available and capable of performing its intended function.
The NRC staff verified that this confirmation covered equipment needed for each of the three phases of B.5.b mitigation strategies. Therefore, the NRC staff finds that the licensee has adequately responded to Question 1.
3.2 Question 2: Guidance and Strategies Can Be Executed In its first response, the licensee confirmed that the guidance and strategies it has implemented for 10 CFR 50.54(hh)(2) are capable of being executed considering the current facility configuration, staffing levels, and staff skills. Since the licensee has considered its current facility configuration, staffing levels, and staff skills, and confirmed that it can execute its implemented guidance and strategies, the NRC staff finds that the licensee has adequately responded to Question 2.
4.0 60-DAY REQUEST The bulletin required a response to the following five questions within 60 days of issuing the bulletin:
- 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.
- 2. Describe in detail the testing of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed.
- 3. Describe in detail the controls for ensuring that the equipment is available when needed.
- 4. Describe in detail how configuration and guidance management is ensured so that strategies remain feasible.
- 3
- 5. Describe in detail how you ensure availability of offsite support.
The NRC staff reviewed the licensee's submittals to determine if it had adequately addressed these questions. This was accomplished by verifying that the submittals listed equipment, training, and offsite resources that were relied upon to make conclusions in the August 16, 2007, SE or are commonly needed to implement the mitigating strategies.
4.1 Questions 1 and 2: Maintenance and Testing of Equipment Questions 1 and 2 of the 60-day request required licensees to describe in detail the maintenance and testing of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed. In its second response, the licensee listed the equipment used to support the 10 CFR 50.54(hh)(2) mitigating strategies which receives maintenance or testing. For each item, the licensee described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity.
The NRC staff verified that the licensee listed equipment that typically requires maintenance or testing which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, the licensee stated that the portable pump, portable power supply, hoses, and communications equipment receive maintenance or testing.
The second response did not identify any maintenance or testing of nozzles. In its RAI response, the licensee stated that it will inspect or monitor the spray nozzles during inventory to ensure that they will be functional when needed. The NRC staff noted that the fuel level for the portable pump is checked during testing and fuel oil is also included in the inventory. The licensee also identified other items that support the mitigating strategies that receive maintenance or testing.
The NRC staff verified that the licensee described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. The licensee stated in its second response that its 10 CFR Part 50, Appendix B, corrective action program is used to document equipment failure, establish priorities, and perform trending.
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Questions 1 and 2.
4.2 Question 3: Controls on Equipment Question 3 of the 60-day request required licensees to describe in detail the controls on equipment, such as inventory requirements, to ensure that the equipment is available when needed. A list of inventory deficiencies and associated corrective actions to prevent loss was also requested.
The NRC staff verified that the licensee described its process for ensuring that B.5.b equipment will be available when needed. In its second response, the licensee identified equipment included in its inventory, the inventory frequency, storage requirements, and items verified.
Items verified include proper quantity and location of equipment. The licensee also stated that access to equipment storage locations is also controlled. The licensee stated that at the time of
-4 its second response there were no outstanding inventory deficiencies that would render the strategies not viable.
The NRC staff verified that the licensee inventoried equipment that was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, the licensee stated that procured non-permanently installed B.S.b equipment is inventoried at least quarterly in accordance with station procedures. The second response specifically stated that the following items are included in the inventory: portable pump; portable power supply; hoses; communications equipment; spray nozzles; connectors; and firefighter turnout gear. The NRC staff noted that a truck is used to tow the pump for periodic testing, which would also ensure that the truck was available. The licensee also identified other items that support the mitigating strategies that are inventoried.
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Question 3.
4.3 Question 4: Configuration and Guidance Management Question 4 of the 60-day request required licensees to describe in detail how configuration and guidance management is assured so that the strategies remain feasible.
The NRC staff verified that the licensee described its measures to evaluate plant configuration changes for their effects on the mitigating strategies and to ensure its procedures are current.
In its second response, the licensee stated that plant configuration changes are procedurally evaluated against the licensing basis, which includes the B.S.b mitigating strategies. The licensee stated that the design change process requires a review of affected procedures and that procedure changes are validated to ensure that the B.S.b mitigating strategies remain viable.
The NRC staff verified that the licensee described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. In its second response, the licensee identified testing in response to Question 2 that demonstrated the ability to execute some strategies. The licensee also stated that "initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews" and they were similarly revalidated in 2011.
The NRC staff verified that the licensee described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. In its second response, the licensee identified the training provided to its operations personnel, emergency response organization key decision makers, security personnel, and fire brigade. The licensee also identified the frequency with which each type of training is provided and the methods for training evaluating.
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Question 4.
-5 4.4 Question 5: Offsite Support Question 5 of the 60-day request required licensees to describe in detail how offsite support availability is assured.
The NRC staff verified that the licensee listed the offsite organizations it relies upon for emergency response, including a description of agreements and related training. The NRC staff compared the list of offsite organizations that the licensee provided in its second response with the information relied upon to make conclusions in the SE. The licensee stated that it maintains letters of agreement with these offsite organizations, which are reviewed annually. The licensee also described the training and site familiarization it provides to these offsite organizations. The licensee stated that it reviewed its corrective action program and found no issues involving lapsed agreements related to offsite support for B.5.b events.
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Question 5.
5.0 CONCLUSION
As described above, the NRC staff has verified that NSPM has provided the information requested in Bulletin 2011-01 for PINGP, Units 1 and 2. Specifically, the licensee responded to each of the questions in the bulletin as requested. The NRC staff concludes that the licensee has completed all of the requirements of the bulletin and no further information or actions under the bulletin are needed.
J. Molden -2 If you have any questions, please contact me at 301-415-4037 or via e-mail at thomas. wengert@nrc.gov.
Sincerely, IRAI Thomas J. Wengert, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Enclosure:
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