ML20054F182

Forwards Info Re Status of NUREG-0737 Items W/Implementation Dates After 820301 in Response to Generic Ltr 82-10

ML20054F182
Person / Time
Site:	Prairie Island
Issue date:	06/04/1982
From:	Musolf D NORTHERN STATES POWER CO.
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-1.C.1, TASK-1.D.1, TASK-1.D.2, TASK-2.B.1, TASK-2.B.2, TASK-2.D.1, TASK-2.F.2, TASK-2.K.3.18, TASK-2.K.3.30, TASK-2.K.3.31, TASK-3.A.1.2, TASK-3.A.2.2, TASK-3.D.3.4, TASK-TM GL-82-10, NUDOCS 8206150288
Download: ML20054F182 (20)

Text

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Northern States Power Company 414 Nicollet Mall Minneapoks, Minnesota 55401 Telephone (612) 330-5500 June 4, 1982 Director Office of Nuclear Reactor Regulation U S Nuclear Regulatory Commission Wa shington , DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60

_I_n f orma t_ ion _ _R_e_la_t_e_d_ _to Po_s t-T_MI_ Requ_i_r_emen_t_s In a letter dated May 5, 1982 from Mr Darrell G Eisenhut, Director, Division of Licensing, USNRC (Generic Letter 82-10) we were requested to provide information related to the status of the last group of NUREG-0737 requi ements. We were requested to reply in accordance with 10 CFR Part 50, Section 50.54(f) within 30 days.

The requested information is provided on the attached forms for each of the NUREG-0737 items listed in the enclosure to Mr Eisenhut's letter.

Please contact us if you have any questions related to the information we have provided.

LA4 D M Musolf, PE

' Acting Head-Nuclear .. pport Fervices DMM/bd .

cc: Regional Administracor-III, USNRC NRR Project Manager, UShTC Resident Inspector, USNRC C Charnoff Attachments i

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UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHERN STATES POWER COMPANY t

PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket No. 50-282 50-306 LETTER DATED JUNE 4, 1982 INFORMATION RELATED TO POST-TMI REQUIREMENTS Northern States Power Company, a Minnesota corporation, by this letter dated June 4,1982 hereby submits information relac.ad to Post-TMI Requirements in response to a letter dated May 5,1982 from Mr Darrel G Eisenhut, Director, Division of Licensing, USNRC (Generic Letter 82-10) .

This letter contains no restricted or other defense information.

NORTHERN STATES POWER COMPANY.

By __ _ u_$ -

D M Musolf Acting Head-Nuclear Support Se vices On this ___ _ day of__ Og_, jM_ before me a notary public in and for said County, persona 11f' appeared D M Musolf, Acting Head-Nuclear Support Services, and beinr first duly sworn acknowledged that he is authorized to execute _this document .. behalf of Northern States Power Company, that he knows the contents thereof and that to the best of his knowledge, information and belief, the statements made in it are true and that it is not interposed for delay.

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PRAIRIE ISLAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1,1982 NUREG-0737 Item No. I.A.1.3.1 i

Applicability All NUREG-0737 Schedule October 1, 1982

Requirement Revise administrative procedures to limit overtime in accordance with NRC Policy Statement issued by Generic Istter No. 82-02

Implementation Status Not comoleted 4

Remarks i

The guidelines of Generic Letter 82-02 will be implemented by October 1, 1982. Appropriate Technical Specification changes will be submitted by NSP by January 1, 1983.

The guidelines are understood to apply only to periods when the unit is above cold shutdown (i.e. not to refueling or maintenance outages).

Justification for Prooosed Schedule Demonstration of Need for Prooosed Schedule i

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PRAIRIE ISLAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREC-0737 Item No. I.A.1.3.2 Applicability All NUREG-0737 Schedule July 1, 1982 Requirement Augment current shift staffing to confrom with minimum levels set forth on page 3-9 of NUREG-0737 Implementation Status Completed 12/30/80 Remarks By our letter dated December 30, 1980 we agreed to implement the requirements of NUREG-0737, Item I.A.1.3.2, with respect to shift manning. Minor exceptions were taken. These exception were reviewed and found acceptable. The Technical Specification

" Minimum Shift Crew Composition" table was revised and found to

, be acceptabic with minor departures from NUREG-0737, page 3-9.

Refer to NRC letter dated January 4,1982.

Justification for Procosed Schedule Demonstration of Need for Prooosed Schedule _

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Descriotion of Comoensatorv Measures Peine Taken in the Interim I

PRAIRIE ISLAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREG-0737 Item No. I.C.1 Applicability All NUREG-0737 Schedule First re fueling after 10/1/82 Requirement Ravine amareenev orocedures by nave refneffne ournee Implementation Status Not complete

' Remarks Emergency procedure guidelines developed by the Westinghouse Owners

• Group have not yet been approved by the NRC Staff as required by NUREG-0737. This schedule can therefore not be met.

2 Justification for Proposed Schedule We understand that the Commission is presently considering a revised implementation schedule for this item with action schedule for this month. A committment will be made. to a revised schedule when the revised requirements have been issued.

Demonstration of Need for Prooosed Schedule i

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PRAIRIE ISIAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREG-0737 Item No. I.D.1 Control Room Design Review Applicability All NUREG-0737 Schedule Plant specific proposals Requirement Under development; no repiv needed at this time Implementation Status Not completed Remarks As noted in our letter dated April 1, 1982 a preliminary program plan report will be submitted by August 31, 1982.

Justification for Prooosed Schedule Demonstration of Need for Prooosed Schedule Descriotion of Comoensatorv Measures Peine Taken in the Interim PRAIRIE ISIAND NUCLEAR GENERATING PIANT STATUS OF NUREC-0737 ITEMS REQUIRING LICENTEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREG-0737 Item No. I.D.2 SPDS Applicability All NUREG-0737 Schedule Plant specific proposals Requirement Under develonment no repiv needed sur Phle Pfmp Impicmentation Status Not completed Remarks A proposed schedule will be provided following the receipt of additional guidance from the NRC.

Justification for Proposed Schedule Demonstration of Need for Prooosed Schedule

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PRAIRIE ISIAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREG-0737 Item No. II.B.1 Applicability All NUREG-0737 Schedule First refueling after July 1, 1982 Requirement Install vents in accordance with revised 10 CFR 50.44 dated 12/2/81 Mn vnniv vonnfend_

Implementation Status Not complete Remarks This modification was described in our letters dated July 6, 1981 and April 26, 1982. The installation schedule was described in our letter dated April 23, 1982. We anticipate no difficulty in completing this modification in both units by the date specified in the rule.

Justification for Prooosed Schedule Demonstration of Need for Prooosed Schedule Descriotion of Comoensatorv Measures Peine Taken in the Interim PRAIRIE ISIAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREG-0737 Item No. II. B. 2.3 Applicability All NUREG-0737 Schedule June 30, 1982 Requirement Document that all safety-related equipment is fully qualified. No reolv needed.

Iciple=entation Status schedule relief reauested Remark's All safety related electrical equipment will not be qualified by June 30, 1982. Schedule relief is expected through the current NRC rule making process. Refer to our letter dated April 30, 1982 for the current status of environmental qualification of electrical equipment.

Justification for Proposed Schedule Demonstration of Need for Prooosed Schedule Descriotion of Comoensatorv Measures me ine Taken in the Interim

PRAIRIE ISIAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER NARCH 1, 1982 NUREG-0737 Item No. II.D.1.2 Applicability PWRs NUREG-0737 Schedule April 1. 1982 Requirement stibmi t ninne sneef fic renorts on relief and safety valve program.

Implementation Status Not complete Remarks f

Our letter dated April 1,1982 referenced submittal of the EPRI reports documenting results of the test program. These reports included the results of valve tests representing the designs and conditions applicable to Prairie Island Units 1 and 2.

We are currently working on completing plant specific final evaluations for Prairie Island. A July 1,1982 submittal will be made. If all work is not completed by that date, additional relief will be requested and a schedule provided for the remaining work.

Justification for Proposed Schedule The required April 1, 1982 submittal date was met. A submittal will be made, as required by the Comission's letter dated September 29, 1981, by July 1, 1982. If needed, relief will be requested at that time.

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} Demonstration of Need for Prooosed Schedule Descriotion of Comoensatorv Measures ne ine Taken in the Interim

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PRAIRIE ISIAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE l WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREG-0737 Item No. II.D.1.3 Applicability PWRs NUREG-0737 Schedule July 1. 1982 Requirement Submit report of results of block valve test program Implementation Status Not complete Remarks We are currently working on completing the plant specific submittal for block valve qualification by July 1,1982. If all work is not completed by that date, additional relief will be requested and a schedule provided for the remaining work.

Justification for Prooosed Schedule l

Demonstration of Need for Prooosed Schedule Descriotion of Comoensatorv Measures neine Taken in the Interim

1 PRAIKIE ISTA*D NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1,1982 NUREG-0737 Item No. II.F.2 Inadequate Core Cooling Instrumentation Applicability All NUREG-073i Schedule Plant specific proposals Requirement Under development; no reply needed at this time Implementacion Status Schedule relief reauested Remarks In past correspondence we committed to install a qualified core exit thermocouple temperature monitoring system in each unit.

As noted in our letter dated March 1,1982 schedule relief until the next refueling outage of each unit was requested to complete this installation. A proposed schedule for other instrumentation required for II.F.2 will be submitted following the receipt of additional guidance from the NRC.

Justification for Prooosed Schedule 1

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Demonstration of Need for Prooosed Schedule I

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PRAIRIE ISIXQ LLEAR GENERATIUG PULNT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREG-0737 Item No. TT 1c 1_18 ADS Actuatlon Applicability Ms NUREG-0737 Schedule September 30, 1982 Requirement Submit revised position on need for modifications Implementation Status Not Applicable

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1 PRAIRIE I5*a?Q NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREG-0737 Item No. II.K.3.30 SB LOCA Analysis Applicability All NUREG-0737 Schedule 1/1/82 Requirement Revise SB LOCA Analysis Methods Implementation Status Schedule relief requested Remarks Westinghouse has submitted its model revisions. Exxon is on schedule for a June 30, 1982 submittal. Schedule relief was requested in our letter dated December 29, 1981.

Justification for Prooosed Schedule This is an extremely difficult and time consuming task. Review of the small break loss of coolant accident analysis methods in the required detailed manner could not be completed within the amount of time originally provided by the NRC's schedule.

Demonstration of Need for Prooosed Schedule Refer to our letter dated December 29, 1981.

Descriotion of Comnensatorv Measures neine Taken in the Interim None. Existing analyses provide significant conservatisms.

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NUREC-0737 Item No. II.K.3. 31 SB IDCA Analysis Applicability All NUREG-0737 Schedule One year after staff approval of model Requirement Submit plant specific analysis Implemencation Status Not complete i

Remarks Reanalysis, if required, will be performed following NRC review and approval of model changes. See response to item II.K.3.30.

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Descrintion of Comnensatorv Measures Feine Taken in the Interim

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STATUS OF FJREG-0737 ITEMS REQUIRING LICENSEE RESPONSE l WITH IMPLEMENTATION DATES AFTER MARCH 1,1982 NUREG-0737 Item No. III.A.I.2 Applicability All NUREG-0737 Schedule July 1, 1982 Requirement Provide for augmentation of staffing in accordance with Generic Letter 81-10 dated 2/18/81.

Implet:entation Status Will be implemented Remarks Will be fully implemented on July 1,1982.

Justification for Prooosed Schedule Demonstration of Need for Procosed Schedule i

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Descriotion of Comnensatorv Measures ?eine Taken in the Interim l

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,c )' PRAIRIE ISIAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREG-0737 Item No. III.A.1.2 Applicability All NUREG-0737 Schedule October 1, 1982 Requirement Upgrade TSC, OSC and EOF to include systems and equipment as described in regulatory guidance documents Implementation Status interim TSC and EOF operational; permanent OSC now operational

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Remarks Due to lack of integrated regulatory guidance on requirements, a firm design basis cannot be established and therefore implementation dates cannot be committed for the upgraded permanent TSC and EOF.

Justification for Pronosed Schedule Succinct regulatory guidance is anticipated in the near future based on recommendations of the CRGR committee and ACRS. Our letters of April 8, June 8, and December 1, 1981 provided conceptual design information and followup status reporting. Our December 1 letter committed to furnish by June 1, 1982, a further update which this submittal consitutes.

Demonstration of Need for Prooosed Schedule Descriotion of Comnensatorv Measures ne ine Taken in the Interim During the period November 2-13, 1981, the NRC conducted a special appraisal of the emergency preparedness program at the Prairie Island Nuclear Generating Plant. The inspectors evaluated the licensee's OSC for compliance with NUREG-0654 and 0696. Based on the findings this portion of the licensee's program was found adequate, except, fixed permanent emergency lighting should be provided in the OSC. The required emergency lighting was installed prior to April 1, 1982.

The inspectors examined the TSC and, according to the Inspection Summary, no items of noncompliance or deviations were identified. However the TSC

, g- s is considered an open item pending completion of the TSC in accordance with the position of NUREC-0696.

The inspectors also examined the interim nearsite EOF and no items of-noncompliance or deviations were identified. However this portion of the program is considered an open item pending completion of the permanent EOF.

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PRAIRIE ISIAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WITH IMPLEMENTATION DATES AFTER MARCH 1, 1982 NUREG-0737 Item No. III. A. 2 .2 Applicability All NUREG-0737 Schedule Scaled milestones to 6/1/83 Requirement Meteorological and other equipment to assess and monitor offsite consequences of radiological emergency conditions Implementation Status interim system now operational see below Remarks Due to lack of integrated regulatory guidance on requirements for later milestones, a firm design basis cannot be set and consequently no final.

implementation dates can be established.

Justification for Proposed Schedule Succinct regulatory guidance is anticipated in near future based on recommendation of the CRCR Committee and ACRS. Our letters of January 30, February 6, April 8, June 8 and December 1, 1981 furnished conceptual design information and followup status reporting. Our December 1 letter committed to furnish by June 1, 1982, a further update which this submittal consitutes.

Demonstration of Need for Prooosed Schedule Descriction of Comoensatorv Measures peine Taken in the Interim During the period November 2-13, 1981, the NRC conducted a special appraisal of the emergency preparedness program at the Prairie Island Nuclear Generating Plant. As a result, prompt corrective action was required for the meteor-ological measurement system. According to the inspectors, these improvements, implemented by March 13, 1982, were needed to achieve an adequate program.

The inspectors determined that the licensee's meteorological capabilities address the requirements of NUREG-0737, TAP III.A.2 and the criteria set forth in NUREG-0654, Appendix 2 in adopting the interim compensating measures to milestone three.

1 PRAEIE ISIAND NUCLEAR GENERATING PIANT STATUS OF NUREG-0737 ITEMS REQUIRING LICENSEE RESPONSE WIT 11 IMPLEMENTATION DATES AFTER MAPC11 1,1982 NUREG-0737 Item No. III.D.3.4 Control Room Habitability Applicability All NUREG-0737 Schedule Plant specific proposals Requirement Modifv facility as identified by licancop crudy Implec:encation Status Not completed Remarks Modifications described in our letter dated July 20, 1981 (toxic gas monitors) are scheduled for installation by January 1,1983.

This date is consistent with the implementation schedule contained in NUREG-0730.

NRC review and approval of our habitability analysis and proposed modifications is documented in a letter dated April 9,1982.

Justification for Prooosed Schedule Demonstration of Need for Prooosed Schedule i

Descriotion of Comoensatorv Measures oeine Taken in the Interim

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