ML20248M150
| ML20248M150 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 06/08/1998 |
| From: | Sorensen J NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9806150085 | |
| Download: ML20248M150 (3) | |
Text
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Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonade Dr. East Welch, Minnesota 55089 l
June 8,1998 I
U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 l
PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Follow-up to Pressure and Temperature Limits Report License Amendment l
l On May 4,1998 the Commission approved a License Amendment for Prairie Island Units 1 and 2 which updated the Technical Specification reactor vessel pressure and temperature limitations and approved the use of a Pressure and Temperature Limitations Report. In the cover letter for that License Amendment, the NRC Staff noted that the submittal of the related license amendment request was not timely. We I
apologize for any inconvenience caused by the delayed submittal and thank the NRC Staff for their efforts in completing their review of the amendment request prior to the expiration of the Technical Specification reactor vessel pressure and temperature limitations.
We would also like to take this opportunity to offer some comments on the delay in the submittal of the March 6,1998 License Amendment Request. From the beginning of the development of the license amendment request NSP understood the complexity of the package and the need to submit it as early as possible. The completion of the supporting analyses was expedited to the extent possible; however, as a result of errors discovered in early 1997, the analyses and resulting reports were not completed until the Summer of 1997. At that time, preparation of the license amendment request was on track for submittal to the NRC in October of 1997. However, as explained in the March 6,1998 License Amendment Request, each of the following independent events ji made it necessary to re-perform the required analyses:
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- 1. The NRC staff requested, by lettu
.ed September 18,1997, additional l
information regarding Prairie Islano Unit 1 "S" Vessel Capsule data and the o
treatment of the data with regards to the Pressurized Thermal Shock (PTS)
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9806150005 990600 PDR ADOCK 05000282 P
6 USNRC NORTHERN STATES POWER COMPANY June 8,1998 I
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Evaluation. In the response, by letter dated December 5,1997, Prairie Island stated that new evaluations were under preparation for the Unit 1 Capsule and PTS reports based upon assessment of the NRC's Request for Additional Information (RAI). The RAI assessment contained conclusions that affected the Unit 2 Capsule and PTS reports as well.
- 2. A November 12,1997 meeting between representatives of NEl, the four NSSS Owners Groups and NRC staff provided information about the review methods used to evaluate licensee GL 92-01 responses. Some of these NRC review methods were new and did not appear in either the regulations or existing regulatory guides.
These new NRC expectations affected the methodology of evaluation of Prairie Island's Surveillance Capsules and PTS for both units.
These events resulted in the revision of all of the analyses related to the license amendment request, including the surveillance capsule analyses, PTS analyses, heatup and cooldown curves, and analysis of low temperature overpressure protection.
The re-analysis took several months to complete and the reports were issued at the end of February 1998. The license amendment request was then finalized, reviewed and submitted on March 6,1998.
During the period when the analyses were being revised, NSP had several discussions with the NRC Staff with respect to whether earlier submittal of the license amendment request without the supporting analysis would facilitate the review process. It was concluded that an early submittal of an incomplete package would not offer any advantage and that it was best to delay the submittal until the analyses were complete and a complete license amendment request could be submitted.
The delay in the submittal of the license amendment request made it imperative that the submittal be as complete as possible to facilitate NRC review. Therefore, during the period of delay, NSP staff expended considerable effort to ensure that in addition to l
meeting all NRC regulations, the license amendment request would include all industry experience to date and would meet all NRC Staff expectations.
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NSP agrees that the March 6,1998 License Amendment Request was not timely.
j However, we believe the delay in submittal of the license amendment request was l
unavoidable and was in part the result of events within the responsibility of NSP and in l
part the result of unforeseen changes in the expectations of the NRC Staff. While NSP i
will continue to make every effort to develop timely and high quality submittals, the I
NRC Staff must understand that the imposition of new requirements or expectations without prior notice, without the opportunity for comment, and without adequate time for implementation, can have significant adverse impacts.
.USNRC NORTHERN STATES POWER COMPANY I.
Jun) 8,1998 -
Pag) 3 In this letter we have made no new Nuclear Regulatory Commission commitments.
Please contact Gene Eckholt (612-388-1121) if you have any questions related to this
' letter.
W.
Joel P Sorensen Plant Manager Prairie Island Nuclear Generating Plant c: Regional Administrator - Region lil, NRC Senior Resident Inspector, NRC NRR Project Manager, NRC J E Silberg l
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