ML20035F155

NRR E-mail Capture - Request for Additional Information Monticello and Prairie Island Alternative Requests to Adopt Code Cases N-786-3 and N-789-3 (Epids: L-2019-LLR-0078 and L-2019-LLR-0079)

ML20035F155
Person / Time
Site:	Monticello, Prairie Island
Issue date:	02/04/2020
From:	Robert Kuntz NRC/NRR/DORL/LPL3
To:	Loeffler R Northern States Power Company, Minnesota
References
L-2019-LLR-0078, L-2019-LLR-0079
Download: ML20035F155 (3)

Text

From: Kuntz, Robert Sent: Tuesday, February 4, 2020 2:18 PM To: Loeffler, Richard A.

Subject:

Request for Additional Information RE: Monticello and Prairie Island alternative requests to adopt Code Cases N-786-3 and N-789-3 (EPIDS: L-2019-LLR-0078 and L-2019-LLR-0079)

Mr. Loeffler, By letter dated August 16, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19231A224), Northern States Power Company, doing business as Xcel Energy (Xcel), submitted its proposed alternative to use American Society of Mechanical Engineers Boiler and Pressure Vessel (BPV) Code Cases (ASME Code Case) N-786-3 Alternative Requirements for Sleeve Reinforcement of Class 2 and 3 Moderate-Energy Carbon Steel Piping and N-789-3, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate-Energy Carbon Steel Piping for Raw Water Service,Section XI, Division 1, for the fifth inservice inspection (ISI) intervals of Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2 and Monticello Nuclear Generating Plant (MNGP), pursuant to 10 CFR 50.55a(z)(2). To complete its review, the NRC staff requires additional information. The the NRC staffs request for additional information (RAI) is included below.

During a clarification call held on February 4, 2020, it was agreed a response could be provided within 30 days which is March 5, 2020. If Xcel determines it can not meet this date contact me to discuss.

Robert Kuntz Senior Project Manager NRC/NRR/DORL/LPL3 (301) 415-3733

RAI-1

BACKGROUND The regulations in 10 CFR 50.55a(z) allow the NRC staff to authorize alternatives to the requirements in paragraphs (b) through (h) of 10 CFR 50.55a, but do not allow the staff to approve alternatives to requirements not currently in these paragraphs. The staff does not generally approve alternatives to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a and the ASME BPV Code beyond the current inservice inspection or test intervals, unless specific circumstances would justify a longer interval. The staff can approve alternatives for the next inservice inspection or test interval when it is near the end of the current interval and the applicable requirements for the next interval are known (e.g., see 10 CFR 50.55a(g)(4)(ii)).

Section 6 of each of the proposed alternatives requested a duration of the fifth ISI interval at each reactor unit of PINGP and MNGP or until such time as the NRC approves Code Cases N-786-3 and N-789-3 in Regulatory Guide 1.147. However, the application does not identify the ASME BPV Code edition and addenda applicable to future 10-year inservice inspection intervals. Thus, the request has not demonstrated that the proposed alternative is limited to the current requirements in paragraphs (b) through (h) of 10 CFR 50.55a.

REQUEST

a. Clarify whether the duration of the proposed alternative is the end of the fifth interval or the approval of the relevant Code Case, whichever occurs first.

b. If the request is intended to extend into the subsequent interval identify the specific ASME Code edition and addenda applicable to future 10-year inservice inspection intervals in which the proposed alternative will be used. In addition, provide a basis for each plant where use of the alternative is requested beyond the current interval.

Hearing Identifier: NRR_DRMA Email Number: 429 Mail Envelope Properties (DM6PR09MB496746F07866F4C1BD1C7A9D99030)

Subject:

Request for Additional Information RE: Monticello and Prairie Island alternative requests to adopt Code Cases N-786-3 and N-789-3 (EPIDS: L-2019-LLR-0078 and L-2019-LLR-0079)

Sent Date: 2/4/2020 2:17:58 PM Received Date: 2/4/2020 2:17:00 PM From: Kuntz, Robert Created By: Robert.Kuntz@nrc.gov Recipients:

"Loeffler, Richard A." <Rick.Loeffler@xenuclear.com>

Tracking Status: None Post Office: DM6PR09MB4967.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 3080 2/4/2020 2:17:00 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: