ML14125A106
| ML14125A106 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 04/30/2014 |
| From: | Northern States Power Co, Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14125A146 | List: |
| References | |
| L-PI-14-045 | |
| Download: ML14125A106 (4) | |
Text
Portions of the Enclosure contain Security-Related Information to be Withheld from Public Disclosure In Accordance with 10 CFR 2.390&XceIEnergy Prairie Island Nuclear Generating Plant 1717 Wakonade Drive East Welch, MN 55089 April 30, 2014 L-PI-14-045 10 CFR 50.90 10 CFR 50.48(c)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 Renewed License Nos. DPR-42 and DPR-60 Supplement to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Liaht Water Reactors
References:
- 1. NSPM letter, J.P. Sorensen to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, L-PI-1 2-089, dated September 28, 2012, ADAMS Accession No.ML12278A405.
- 2. NRC letter, T.J. Wengert to J.E. Lynch (NSPM), Prairie Island Nuclear Generating Plant, Units 1 and 2 -Acceptance for Review of License Amendment Request for National Fire Protection Association Standard NFPA 805 (TAC Nos. ME9734 and ME9735), dated January 2, 2013, ADAMS Accession No.ML13002A209.
- 3. NSPM letter, J.E. Lynch to NRC Document Control Desk, Commitment to Submit a Supplement to the PINGP NFPA 805 License Amendment Request (TAC Nos. ME9734 and ME9735), L-PI-13-044, dated May 3, 2013, ADAMS Accession No. ML13126A115.
This letter provides supplemental information in support of the License Amendment Request (LAR) submitted in Reference 1 by the Northern States Power Company, a Portions of the Enclosure contain Security-Related Information to be Withheld from Public Disclosure in accordance with 10 CFR 2.390.Upon removal of Attachment W from the Enclosure, this letter is uncontrolled.
Ac oQ Document Control Desk Page 2 Minnesota Corporation (NSPM) doing business as Xcel Energy. The Reference 1 LAR requested approval from the Nuclear Regulatory Commission (NRC) to adopt a new fire protection licensing basis for the Prairie Island Nuclear Generating Plant (PINGP). The new proposed licensing basis complies with the requirements in 10 CFR 50.48(a) and 10 CFR 50.48(c) which incorporates by reference National Fire Protection Standard 805 (NFPA 805). Supplemental information was provided in letters dated November 8, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12314A144) and December 18, 2012 (ADAMS Accession No. ML12354A464).
After the Reference 1 LAR was accepted for review by the NRC (Reference 2), NSPM identified a number of issues regarding information provided in the LAR and in supporting analyses.
In Reference 3, NSPM explained that a revision was required to the PINGP Fire Probabilistic Risk Assessment (PRA), and committed to provide the results of this revision in a supplement to the LAR by May 1, 2014. Submittal of this LAR supplement satisfies NSPM's commitment.
The enclosure to this letter contains Revision 1 to the PINGP NFPA 805 Transition Report (TR) and supporting attachments.
To simplify the NRC Staff's review, the entire TR and attachments are included.
The front matter of the TR has been revised to include a Revision Status table and a Summary of Changes. Changes to text are generally indicated by revision marks in the margins, with a few exceptions described in the TR where changes were extensive and revision marks would provide little benefit.As discussed with the NRC Staff in an informal telephone conference on May 21, 2013, Revision 1 to the Transition Report reflects a comprehensive review of the Fire PRA and other parts of the LAR. Major changes include the following: " The Fire PRA has been revised to correct previous errors* Additional fire modeling has been performed" The modifications previously identified in Attachment S have been revised based on further evaluations; items no longer required have been deleted and new modifications have been added" Recovery actions have been revised based on credit taken in the revised Fire PRA model, and the recovery action discussion was revised to clarify that PINGP does not have a primary control station that meets the requirements of Regulatory Guide 1.205* A focused-scope peer review was performed for use of a new hot gas layer methodology, and a focused-scope peer review is being performed for a new Reactor Coolant Pump seal model* The component data base used for the previous Fire PRA, PRISM, has been replaced with FRANX" New NSCA and NPO models have been created to reflect the transition from PRISM* Generic RAIs and revisions to the LAR template in NEI 04-02 (more recent than Revision 1 L, which was the basis for the Reference 1 LAR) have been considered.
Document Control Desk Page 3 The revisions to the LAR submitted in Reference 1 have been comprehensive, as noted above; however, this is not a re-submittal of the Reference 1 LAR. Many TR sections and attachments have not been changed. Upon completion of the modifications identified in the LAR, fire and total plant risk metrics will remain below the acceptance guideline values in Regulatory Guide 1.174. Also, the revised analyses did not utilize any unreviewed analysis methods (UAMs).As part of the effort to address the fire risks indicated by the Fire PRA, NSPM has also initiated work on a number of the modifications identified in Attachment S of the Reference 1 LAR. Of the 22 modifications originally identified in Table S-2 in Reference 1, seven are being actively pursued. The RCP Seal replacement modification has been installed in Unit 2 (Item 1 in Table S-1 in the Enclosure) and is scheduled for installation in Unit 1 in the Fall 2014 refueling outage (Item 18 in Table S-2 in the Enclosure).
Design efforts are complete for five other modifications (Items 6, 8, 9, 12, and 16) and are in progress for Item 13.NSPM requests approval of this license amendment request less than 24 months after the date of this letter, and proposes to implement the new fire protection licensing basis in accordance with the implementation schedule provided in Section 5.5 of the attached Transition Report. Specifically, per the transition license condition, the plant modifications identified in Table S-2 of the Transition Report will be implemented in accordance with the schedule provided in Attachment S of the TR, based on their complexity, risk significance, and need for compliance with code requirements.
Implementation of activities listed in Table S-3 of the attached TR, including procedure changes, process updates, and training of affected personnel, will be completed within the later of six months after NRC approval, or six months after a refueling outage if in progress at the time of NRC approval.
This is consistent with the commitment provided in the Reference 1 LAR.Portions of the enclosure contain Security-Related information.
Specifically, Attachment W contains Security-Related information and NSPM requests that this attachment be withheld from public disclosure under 10 CFR 2.390(d)(1).
This letter is submitted in accordance with 10 CFR 50.90. The supplemental information provided in this letter does not impact the conclusions of the No Significant Hazards Evaluation or Environmental Considerations Evaluation presented in Reference 1.In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this LAR supplement by transmitting a copy of this letter to the designated State Official.If there are any questions or if additional information is needed, please contact Gene Eckholt at 651-267-1742.
I.Document Control Desk Page 4 Summary of Commitments Submittal of the enclosed information completes the Commitment provided in Reference 3, and this letter does not result in any new or otherwise changed commitments.
I declare under penalty of perjury that the foregoing is true and correct.Executed on "/C)/20/Y' Scott M. Sharp Director, Site Operations, Prairie Island Nuclear Generating Plant Northern States Power Company -Minnesota Enclosure cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota