ML20211F421
| ML20211F421 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island  |
| Issue date: | 09/26/1997 |
| From: | Wadley M NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9710010058 | |
| Download: ML20211F421 (7) | |
Text
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Northern States Power Company 414 Neollet Mall Menneapohs, MN 55401 September 26,1997 10 CFR 50.71(e)
U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 i
MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50 263 License No.
DPR-22 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50 282 License Nos. DPR-42 50 306 DPR-60 Project Plans for USAR Review Project and Conversion to improved Technical Specifications (ITS)
A Nuclear Regulatory Commission (NRC) staff meeting was held August 8,1997 with representatives of Northern States Power (NSP) Company in Lisle, Illinois, for a i
predecisional enforcement conference on apparent testing violations at the Prairie Island Nuclear Generating Plant.
At that ting, NSP verbally committed to the following:
Within six weeks of tb.e August 8 meeting, provide the NRC Staff a letter outlining our planned schedule and process for our USAR Review Project and 4
our adoption of Improved Technical Specifications (ITS) for both our Prairie
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Island and Monticello Nuclear Generating Plants.
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e Attachment september 26,1997 Page 2 NSP provides the following commitments:
(1)
Prairie Island plans to complete its USAR Review Project in December of 2001.
(2)
Monticello plans to complete its USAR Review Project in June of 2001.
(3)
Prairie Island plans to provide an Improved Technical Specification conversion package submittal to the NRC in October of 1999.
(4)
Muuticello plans to provide an Improved Technical Specification conversion package submittalto the NRC in June of 2000.
NSP USAR REVIEW PROJECT OVERVIEW This letter describes the voluntary NSP initiative to review the Updated Safety Analysis Report (USAR). (
Reference:
NRC cnforcement policy on departures from tha UFSAR, October 18,1996.)
USAR review teams have been assembled at both Prairie Island and Monticello to ensure that the USAR provides a clear and accurate description of the plant and reflects the current design and operation of the facility. The USAR is not just a historical document, it is the basis for the operating license for the plant and must accurately describe the plant and be maintained current. They should be the primary documents reviewed, along with the Technical Specifications, to determine if the plant is designed, maintained and operated within the terms and conditions of the license.
The project teams will review the USAR and the applicable design basis documents (DBD) to minimize the duplication of information that must be maintained. In general, the USAR will contain the licensing basis for each plant and the DBDs will contain the design details. The USAR must contain sufficient technical detail to support the conclusion that the plant was built and is being operated safely and in accordance with the regulatory requirements.
The goal for the USAR Review Projects will be to assure the USAR is current, accurate and reflects the design and operation of each plant, and integrate it with the Improved Technical Specifications.
l Monticello and Prairie Island have differing needs due to their individual situations, such as Monticello's Rerate Project, that influence the details of accomplishing the above goal. Therefore, each plant has a uniquely tailored program as described in the following information.
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e Attachment September 26,1997 Page 3 Prairie Island USAR Review Project The Prairie Island project is using a phased process. It is believed that a logical, methodical approach will yield the most benefa:
l Phase I is a thorough review of the USAR document. The current USAR is being reviewed to identify and resolve potential discrepancies within and between chapters. The current USAR is also being reviewed against the FSAR and the SER. A database is in place to catalog the identified l
potential discrepancies. Also, a process is in place to evaluate the potential discrepancies for operability and reportability concerns.
Appropriate changes will be made to the USAR to resolve the identified j
discrepancies.
1 Phase ll will be a verification of precedures and the physical plant. The intent is that the USAR will be compared to plant procedures and the physical plant (systems, structures and components) to identify potential discrepancies. Tracking, evaluation and resolution of the potential discrepancies will be similar to the method employed in the first phase.
Phase ill will be a review of calculations which are important to the design basis as described in the USAR. The intent is to identify those calculations which support the design basis in the USAR and retrieve them, in general, the calculations will be reviewed for identification of assumptions, proper method, and ccmpatibility of results with other calculations. For those calculations that cannot be retrieved, an evaluation will be made as to the need to reconstruct the calculation.
Again, a method of tracking, evaluation and resolving potential discrepancies will be developed.
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i Attachment september 26,1997 Page 4 Prairie Island USAR Review Schedule Milestones NOTE: This schedule supersedes the draft schedule provided to the NRC at the August 8,1997 predecisional enforcement conference.
The schedule for the USAR project is projected to be as follows:
Phase I:
Draft document completed by 12/31/97 Final document completed by 6/30!98 Phase ll:
Begin development of implementation plan 4/1/98 Begin verification activities 7/1/98 Complete verification activities by 12/30/99 Phase Ill:
Define scope and develop implementation plan 6/1/98 Begin calculation recovery and evaluation 1/1/99 Complete calculation activities by 12/31/01 Monticello USAR Review Project Process The USAR project will be accomplished in two phases at Monticello:
Phase I is to develop the implementation procedure, and perform initial reviews conducted by designated owners of USAR sections (i.e., system engineers and other subject matter experts). The purpose of this initial review is to identify any discrepancies which may be immediately apparent. Procedures and training will be developed to ensure that the review is systematic.
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Attachment september 26.1997 Page 5 Phase ll, Part A is a comprehensive review which will be conducted by i
teams of individuals with knowledge of integrated plant design and operation. The goal of the comprehensive review is to identify discrepancies and omissions which would not normally be found through normal surveillance and quality assurance activities. It is also anticipated that the Power Rerate USAR changes would be incorporated early in this phase pending NRC approval of the Rerate License Amendment. A prioritization scheme will be used to select and schedule system and topic sections of the USAR. It will be the intent to maintain the existing USAR format.
Phase 11, Part B willinclude resolution of discrepancies. Discrepancies will be handled through existing processes for dealing with issues and will be modified by using guidance given in the NUMARC 90-12, Design Basis Program Guidelines (note: this document is currently being revised by NEl as97-004). This includes addressing immediate concerns (i.e.,
operability, reportability, communication) and tracking corrective actions.
Issue resolution will be prioritized on the basis of safety and regulatory compliance impact.
Monticello USAR Review Schedule Milestones Completion. as described above, is divided into two phases:
Phase I:
Initial review activity has begun and will be completed by September 30,1998.
Phase 11 Part A:
Comprehensive review activity will start on or before September 30,1998 and will be completed by June 30,2000.
Phase ll, Part B:
Discrepancy resolution process has begun to support phases I and ll and will be completed one year after phase ll, Part A is completed, June 30,2001.
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Attachment september 26.1997 Page 6 NSP IMPROVED TECH SPECS (ITS) PROJECT OVERVIEW The Prairie Island and Monticello custom Technical Specifications (TS), including Bases, will be converted to the improved Technical Specifications (ITS) format as presented in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants",
and NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4", respectively. The Technical Specification conversion will, to the extent practical, incorporate industry accepted NUREG change packages which improve or correct errors within the NUREG. The converted ITS will include current TS requirements with additional, more restrictive NUREG-1431/3 requirements only if NSP believes they are necessary to provide a complete Technical Specification requirement.
NSP will provide the NRC with background information and justification for not adding the remaining requirements using existing documentation from the current plant licensing basis, it is our understanding that the addition of any new requirements l
during the conversion process are subject to the backfit rule.
Currently, both NUREGs are at Revision 1. Both Prairie Island and Monticello intend to base the conversions on Revision 1 unless Revision 2 is issued early enough to be used as the base document. In either case, the Technical Specification conversions will, to the extent practical, incorporate industry accepted NUREG change packages which improve or correct errors within the NUREG up to a defined cutoff date to be established as the projects near completion.
To the extent practical, the conversion packages will conform to NRC and industry ITS conversion guidance available as of the date of this letter. As allowed in NEl-96-06, Improved Technical Specifications Conversion Guidance, NSP plans to incorporate changes to extend the refueling outage intervals to 2 years.
Prairie Island ITS Schedule Milestones For Prairie Island, NSP plans to submit the ITS conversion package to the NRC Staff in October of 1999. The ITS conversion package submittal will address Prairie Island's plans for implementation, including implementation of new Surveillance Requirements and interface with outage schedules.
Monticello ITS Schedule Milestones For Monticello, NSP plans to submit the ITS conversion package to the NRC Staff in June of 2000. The ITS conversion package submit'al will address Monticello's plans for implementation including implementation of new Surveillance Requirements and interface with outage schedules.
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.,j Attachment september 26,1997 Page 7
. In this letter NSP has made four new Nuclear Regulatory Commission commitments, the above italicized statements. In support of these commitments, NSP will provide semiannual status updates to the NRC Staff on the progress of these two projects at both Prairie Island and Monticello.
It is recognized that there are some activities that can significantly affect the proposed schedules for the USAR Review and ITS Projects. During any phase, when a significant discrepancy is identified, resources will be redirected to resolve the 6iscrepancy, in a timely manner. The number and extent of the discrepancies will l
determine the impact on the schedules. Also, elements of all of the phases of both l
projects are interrelated. For example, a single discrepancy identified in the first phase of USAR Review may involve the USAR document, a procedure and/or a calculation.
Resolution may extend the completion time for the first phase. The benefit is that portions of the later phases will have been completed.
Please contact Cathy Gjermo (612-330-6989) if you have any questions related to this letter.
Michael D. Wadley VP Nuclear Generation Northern States Power Company
- c: Regional Administrator-IlliNRC NRR Project Manager (Monticello), NRC NRR Project Manager (Prairie Island), NRC Resident inspector (Monticello), NRC -
Resident inspector (Prairie Island), NRC State of Minnesota,- Attn: Kris Sanda J Silberg
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