ML20083F420

NRR E-mail Capture - Plan for the Audit of the Prairie Island Nuclear Generating Plant TSTF-505 License Amendment Request (Epdi: L-2019-LLA-0283)

ML20083F420
Person / Time
Site:	Prairie Island
Issue date:	03/20/2020
From:	Robert Kuntz NRC/NRR/DORL/LPL3
To:	Gohdes P Northern States Power Company, Minnesota
References
L-2019-LLA-0283
Download: ML20083F420 (5)

Text

From: Kuntz, Robert Sent: Friday, March 20, 2020 3:48 PM To: Gohdes, Peter D.

Subject:

Plan for the audit of the Prairie Island Nuclear Generating Plant TSTF-505 License Amendment Request (EPDI: L-2019-LLA-0283)

Mr. Gohdes, The NRC staff has determined that an electronic audit is necessary to support its review of the Prairie Island Nuclear Generating Plant, Units 1 and 2, TSTF-505 application. The following is the plan for the audit. If Xcel Energy has any questions or requires information contact me.

Robert Kuntz Senior Project Manager (Monticello, Prairie Island, and Quad Cities)

NRC/NRR/DORL/LPL3 (301) 415-3733 AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUEST TO ADOPT TSTF-505, REVISION 2, "PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES -

RITSTF INITIATIVE 4b PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306

1.0 BACKGROUND

By letter dated December 16, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19350C188179), Northern States Power Company, a Minnesota corporation, doing business as Xcel Entergy (NSPM), submitted a license amendment request for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2. The proposed amendment would modify the licensing basis of PINGP to allow for the implementation of the provisions of Technical Specification Task Force (TSTF) Traveler - 505, Provide Risk-informed Extended Completion Times - RITSTF Initiative 4b (Reference 1). The U.S. Nuclear Regulatory Commission (NRC) staff's review of the subject LARs has commenced in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-101, "License Amendment Review Procedures" (Reference 2).

The NRC staff has determined that a regulatory audit of the LARs should be conducted in accordance with the NRR Office Instruction LIC-111, "Regulatory Audits" (Reference 3), for the staff to gain a better understanding of the proposed risk-informed completion time (RICT) program.

2.0 AUDIT BASES A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The bases are the LAR for the PINGP, Units 1 and 2 and the Standard Review Plan Section 19.2 (Reference 4). The audit is determined to be the most efficient approach toward a timely resolution of issues associated with this LAR review. This will ensure that the staff will have an opportunity to minimize the potential for multiple rounds of requests for additional information (RAIs) and that no unnecessary burden will be imposed to address issues that are no longer necessary to make a safety determination.

3.0 OBJECTIVES The objectives of this audit are to:

• Acquire understanding of the extent that the proposed amendments to modify TS requirements for RICTs are in accordance with TSTF-505, Revision 2 and Nuclear Energy Institute (NEI) 06-09, Revision 0-A (Reference 5).

• Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the staff's understanding of the LAR.

• Gain a better understanding of plant design features and their implications to the LAR.

• Acquire understanding of the technical acceptability of the probabilistic risk assessment (PRA) for use in the application.

• Identify necessary further information that should be submitted in order for staff to reach a licensing or regulatory decision and discuss potential RAls.

• Acquire understanding of whether the proposed configurations introduce any adverse effects on the ability or capacity of plant equipment to perform its design-basis function(s) when the plant is operated in the proposed TS allowable configuration.

4.0 SCOPE AND NECESSARY INFORMATION The areas of focus for the regulatory audit are the information contained in the LAR, the enclosed audit information needs, and all associated and relevant supporting documentations (e.g., methodology, process information, calculations, etc.). The relevant supporting documents are identified below.

The following documentation should be available to the audit team:

1. Facts and Observations (F&O) closure reports for the Independent Assessments conducted in October 2017 and May 2019, for the internal events, internal flooding and fire PRA.

2. Any draft or final RICT program procedures (i.e., Risk Management Action (RMA) procedure, PRA Functionality Determination Procedure, Recording Limiting Condition for Operation (LCO) procedures, etc.).

3. Plant specific documentation related to PRA model assumptions and sources of uncertainty for the internal events, internal flooding, and the fire PRA (i.e., PRA uncertainty).

4. Documentation supporting the example RICT calculations presented in LAR Enclosure 1 Table E1-2.

5. Design of PINPG, Unit 1 and PINPG, Unit 2 shared systems, including electrical and mechanical systems, and modeling of shared systems in the PINGP, Unit 1 and PINGP, Unit 2 PRAs.

6. Detailed justification or analysis to support Change #7 in Attachment 1 and Section 3.0 of Enclosure 1 of the LAR, which are related to RTS and ESFAS instrumentation.

The team will review the PRA methods used to determine the risk impact from which the revised completion times are obtained, including the internal events and fire PRAs, and the quantification of risk from significant external events through PRA or bounding methods.

The team will discuss audit questions and identify the need for any additional information or clarification.

5.0 LOGISTICS The audit will be conducted from March 20, 2020 to July 17, 2020 through an online portal (i.e., electronic portal, ePortal, electronic reading room) established by NSPM. NRC staff and contractors access to the online portal should be terminated on July 18, 2020.

6.0 TEAM AND REVIEW ASSIGNMENTS The audit will be conducted by the following NRC staff and contractors from Pacific Northwest National Laboratory (PNNL). Other NRC staff may participate by conference call.

Rob Kuntz, Project Manager Jeff Circle, Technical Reviewer, Team Leader.

Stephen Dinsmore, Technical Reviewer Medhi Reisi-fard, Technical Reviewer Keith Tetter, Technical Reviewer Jack Zhao, Technical Reviewer Mark Wilk, Technical Reviewer (PNNL)

Garill A. Coles, Technical Reviewer (PNNL)

Steve M. Short, Technical Reviewer (PNNL) 7.0 SPECIAL REQUESTS The NRC staff would like access to the documents listed above in Section 4.0 through an online portal that allows the NRC staff and contractors to access documents via the internet. The following conditions associated with the online portal must be maintained throughout the duration that the NRC staff and contractors have access to the online portal:

• The online portal will be password-protected, and separate passwords will be assigned to the NRC staff and contractors who are participating in the audit.

• The online portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information on the online portal.

• Conditions of use of the online portal will be displayed on the login screen and will require acknowledgement by each user.

User name and password information should be provided directly to the NRC staff and contractors. The NRC project manager will provide Exelon the names and contact information of the NRC staff and contractors who will be participating in the audit. All other communications should be coordinated through the NRC project manager.

8.0 DELIVERABLES An audit summary will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue RAIs.

9.0 REFERENCES

1. Letter from U.S. Nuclear Regulatory Commission to Technical Specifications Task Force, "Final Revised Model Safety Evaluation of Traveler TSTF-505, Revision 2,

'Provide Risk-Informed Extended Completion Times - RITSTF Initiative 48,"' dated November 21, 2018 (ADAMS Package Accession No. ML18269A041).

2. U.S. Nuclear Regulatory Commission, NRR Office Instruction, LIC-101, Revision 5, "License Amendment Review Procedures," dated January 9, 2017 (ADAMS Accession No. ML16061A451).

3. U.S. Nuclear Regulatory Commission, NRR Office Instruction, LIC-111, Revision 1, "Regulatory Audits," dated October 31, 2019 (ADAMS Accession No. ML19226A274).

4. U.S. Nuclear Regulatory Commission, Standard Review Plan (NUREG-0800) 19.2, Review of Risk Information Used to Support Permanent Plant-Specific changes to the Licensing Basis: General Guidance, June 2007 (ADAMS Accession No. ML071700658).

5. Nuclear Energy Institute, NEI 06-09, Revision 0-A, "Risk-Informed Technical Specification Initiative 4b Risk-Managed Technical Specification Guidelines," dated November 2006 (ADAMS Accession No. ML12286A322).

Hearing Identifier: NRR_DRMA Email Number: 487 Mail Envelope Properties (MN2PR09MB33423F70245A67FD788C540F99F50)

Subject:

Plan for the audit of the Prairie Island Nuclear Generating Plant TSTF-505 License Amendment Request (EPDI: L-2019-LLA-0283)

Sent Date: 3/20/2020 3:47:48 PM Received Date: 3/20/2020 3:47:00 PM From: Kuntz, Robert Created By: Robert.Kuntz@nrc.gov Recipients:

"Gohdes, Peter D." <Peter.Gohdes@xenuclear.com>

Tracking Status: None Post Office: MN2PR09MB3342.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 8868 3/20/2020 3:47:00 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: