ML091140020

2009/04/13 PINGP Lr - 20090413 Letter Transmitting the Annual Update of the Prairie Island License Renewal Application

ML091140020
Person / Time
Site:	Prairie Island
Issue date:	04/13/2009
From:	- No Known Affiliation
To:	Division of License Renewal
References
Download: ML091140020 (56)

Text

1 PrairieIslandNPEm Resource From: Eckholt, Gene F. [Gene.Eckholt@xenuclear.com]

Sent: Monday, April 13, 2009 12:27 PM To: Richard Plasse; Nathan Goodman Cc: Eckholt, Gene F.; Davis, Marlys E.; Vincent, Robert; Travers, Greg

Subject:

20090413 Letter Transmitting the Annual Update of the Prairie Island License Renewal Application Attachments:

20090413 LR Annual Update Letter.pdf; 20090413 LR Annual Update Letter.docAttached are pdf and WORD versions of the letter transmitting the Annual Update of the Prairie Island License Renewal Application.

Let me know if you have any questions.

Gene Eckholt Project Manager License Renewal Project Prairie Island Nuclear Generating Plant

<<20090413 LR Annual Update Letter.pdf>> <<20090413 LR Annual Update Letter.doc>>

Hearing Identifier: Prairie_Island_NonPublic Email Number: 1001 Mail Envelope Properties (7A9B2084CC9CEC45828E829CBF20D638033F6C15)

Subject:

20090413 Letter Transmitting the Annual Update of the Prairie Island License Renewal Application Sent Date: 4/13/2009 12:26:37 PM Received Date: 4/13/2009 12:26:44 PM From: Eckholt, Gene F.

Created By: Gene.Eckholt@xenuclear.com Recipients: "Eckholt, Gene F." <Gene.Eckholt@xenuclear.com> Tracking Status: None "Davis, Marlys E." <Marlys.Davis@xenuclear.com> Tracking Status: None "Vincent, Robert" <Robert.Vincent@xenuclear.com>

Tracking Status: None "Travers, Greg" <Greg.Travers@xenuclear.com> Tracking Status: None "Richard Plasse" <Richard.Plasse@nrc.gov> Tracking Status: None "Nathan Goodman" <Nathan.Goodman@nrc.gov>

Tracking Status: None Post Office: enex02.ft.nmcco.net

Files Size Date & Time MESSAGE 366 4/13/2009 12:26:44 PM 20090413 LR Annual Update Letter.pdf 424352 20090413 LR Annual Update Letter.doc 307776

Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

1717 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1121 April 13, 2009 L-PI-09-043 10 CFR 54.21(b)

U S Nuclear Regulatory Commission

ATTN: Document Control Desk

Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306

License Nos. DPR-42 and DPR-60 Annual Update of the Application for Renewed Operating Licenses By letter dated April 11, 2008, Northern States Power Company, a Minnesota Corporation, (NSPM) submitted an Application for Renewed Operating Licenses (LRA) for the Prairie Island Nuclear Generating Plant (PINGP) Units 1 and 2. 10 CFR 54.21(b)

requires that each year following submittal of a license renewal application, and at least three months before scheduled completion of the NRC review, an amendment to the application shall be submitted that identifies any changes to the CLB that materially affect the contents of the LRA.This letter provides that amendment. A review of the PINGP CLB changes since submittal of the LRA has been completed.Two CLB changes have been identified that materially affect the contents of the LRA.

The LRA revisions to reflect these CLB changes are provided as follows: Enclosure 1 provides a revised LRA Section 1.3 to reflect the transfer of the Facility Operating Licenses from Nuclear Management Company to NSPM. provides revisions to LRA Sections A2.28 and B2.1.28, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program, to reflect the incorporation of ASME Code Case

N-729-1 as required by a change to 10 CFR 50.55a, published in the Federal Register

on September 10, 2008 (73 FR 52730). provides the list of License Renewal Commitments updated to reflect NSPM correspondence to date.

If there are any questions or if additional information is needed, please contact Mr. Eugene Eckholt, License Renewal Project Manager.

Revision of LRA Section 1.3, Information Required by 10 CFR 54.17 and 10 CFR 54.19 1In an application dated April 16, 2008, Nuclear Management Company, LLC, the operating licensee for the Prairie Island Nuclear Generating Plant (PINGP), requested a

transfer of the Facility Operating Licenses No. DPR-42 for PINGP Unit 1 and DPR-60 for Unit 2, to the plant owner, Northern States Power Company. The conforming license amendments to affect the transfer of the operating licenses were issued on September 22, 2008, as Amendments 188 and 177 for Units 1 and 2, respectively. The LRA is being revised to reflect this license transfer.

LRA Section 1.3 is hereby revised in its entirety to read as follows: 1.3 Information Required by 10 CFR 54.17 and 10 CFR 54.19 1.3.1 Name of Applicant Northern States Power Company, a Minnesota Corporation (NSPM), the operating licensee, hereby applies for renewed operating licenses for the Prairie Island Nuclear Generating Plant Units 1 and 2.

In any place in this application where Nuclear Management Company (NMC) is referenced, it shall be understood to mean NSPM.

1.3.2 Address of Applicant Address of Owner and Licensee Northern States Power Company 414 Nicollet Mall

Minneapolis, MN 55401 Address of Prairie Island Nuclear Generating Plant Prairie Island Nuclear Generating Plant 1717 Wakonade Dr East

Welch, MN 55089 1.3.3 Description of Business or Occupation of Applicant Northern States Power Company, a Minnesota corporation (NSPM), is a utility principally involved in the generation, purchase, transmission, distribution and sale of

electricity. NSPM is a wholly owned utility operating company subsidiary of Xcel Energy, Inc. ("Xcel Energy"). Xcel Energy, a Minnesota corporation, is a major U.S.

electric and natural gas company that operates in eight Western and Midwestern states and provides a comprehensive portfolio of energy-related products and services to approximately 3.3 million electricity customers and 1.8 million natural gas customers. Revision of LRA Section 1.3, Information Required by 10 CFR 54.17 and 10 CFR 54.19 2NSPM is not owned, controlled, or dominated by an alien, a foreign corporation, or a foreign government. NSPM makes this application on its own behalf and is not acting

as an agent or representative of any other person.1.3.4 Organization and Management of Applicant NSPM is a Minnesota corporation. Its principal place of business is Minneapolis, Minnesota. The names and addresses of the directors and principal officers of NSPM, all of whom are U.S. citizens, are listed below:

NSPM Directors Name Business AddressBenjamin G.S. Fowke III 414 Nicollet Mall Minneapolis, MN 55401 Richard C. Kelly 414 Nicollet Mall Minneapolis, MN 55401 David M. Sparby 414 Nicollet Mall Minneapolis, MN 55401 NSPM Principal Officers Name Business AddressRichard C. Kelly 414 Nicollet Mall Chairman Minneapolis, MN 55401 David M. Sparby 414 Nicollet Mall President and Chief Executive Officer Minneapolis, MN 55401 Michael C. Connelly 414 Nicollet Mall Vice President and General Counsel Minneapolis, MN 55401 David M. Wilks 4653 Table Mountain Drive Vice President Golden, CO 80403 Benjamin G.S. Fowke III 414 Nicollet Mall Vice President and Chief Financial Officer Minneapolis, MN 55401 Dennis L. Koehl 250 Marquette Plaza Vice President and Chief Nuclear Officer Minneapolis, MN 55401 Revision of LRA Section 1.3, Information Required by 10 CFR 54.17 and 10 CFR 54.19 3 Legal CounselPeter M. Glass 414 Nicollet Mall Xcel Energy Minneapolis, MN 55401 David R. Lewis 2300 N Street, NW Pillsbury Winthrop Shaw Pittman LLP Washington, DC 20037 1.3.5 Class of License, Use of Facility, and Period of Time for which the License is SoughtNSPM requests renewal of the Class 104b operating licenses for the Prairie Island Nuclear Generating Plant (Facility Operating Licenses DPR-42 and DPR-60) for a

period of 20 years beyond the expiration of the current license. This would extend the operating license for Unit 1 from midnight August 9, 2013, to midnight August 9, 2033 and for Unit 2 from midnight October 29, 2014 to midnight October 29, 2034. The

facility will continue to be known as the Prairie Island Nuclear Generating Plant. This application includes a request for renewal of those NRC source material, special nuclear material, and by-product material licenses included within the current operating licenses and issued pursuant to 10 CFR Parts 30, 40 and 70.

1.3.6 Earliest and Latest Dates for Alterations, if Proposed NSPM does not propose to construct or alter any production or utilization facility in connection with this renewal application.The Current Licensing Basis (CLB) will be

continued and maintained throughout the period of extended operation. 1.3.7 Listing of Regulatory Agencies Having Jurisdiction and News Publications In addition to the Nuclear Regulatory Commission, the Federal Energy Regulatory Commission and the State of Minnesota Public Utilities Commission are the principal regulators of the company's electric operations in Minnesota.

Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426 Minnesota Public Utilities Commission 121 7th Place East, Suite 350

St. Paul, MN 55101-2147 News publications in circulation near PINGP which should be considered for public notices related to the application are as follows: Revision of LRA Section 1.3, Information Required by 10 CFR 54.17 and 10 CFR 54.19 4 The Republican Eagle

2760 North Service Drive

Red Wing, MN 55066 The Saint Paul Pioneer Press 345 Cedar Street St. Paul, MN 55101 The Star Tribune 425 Portland Avenue

Minneapolis, MN 55488-0002 Rochester Post-Bulletin 18 First Avenue, S.E.

Rochester, MN 55903-6118 Eau Claire Leader-Telegram 701 South Farwell Street

Eau Claire, WI 54701 Hastings Star - Gazette 741 Spiral Boulevard

Hastings, MN 55033 Pierce County Herald 126 South Chestnut Street Ellsworth, WI 54011 1.3.8 Conforming Changes to Standard Indemnity Agreement NSPM requests that conforming changes be made to indemnity agreement No. B-60 for the Prairie Island Nuclear Generating Plant Units 1 and 2, as required, to ensure that the indemnity agreement continues to apply during both the terms of the current licenses and the terms of the renewed licenses. NSPM understands that no changes may be necessary for this purpose if the current operating license numbers are

retained.1.3.9 Restricted Data Agreement This application does not contain restricted data or other national defense information, nor is it expected that subsequent amendments to the license application will contain such information. However, pursuant to 10 CFR 54.17(g) and 10 CFR 50.37, NSPM, as a part of the application for a renewed operating licenses, hereby agrees that it will not permit any individual to have access to, or any facility to possess, Restricted Data or classified National Security Information until the individual and/or facility has been

approved for such access under the provisions of 10 CFR Parts 25 and/or 95. Revision of LRA Sections A2.28 and B2.1.28, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program 1Federal Register Notice 73 FR 52730 of September 10, 2008, published a change to 10 CFR 50.55a which incorporated a requirement to implement ASME Code Case N-729-1

for the inspection of PWR Reactor Vessel Upper Heads. This code case supersedes

the previous inspection requirements embodied in the NRC First Revised Order EA-03-009, "Issuance of First Revised NRC Order (EA-03-009) Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors."

Conforming changes are being made to the PINGP Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program, described in LRA Sections A2.28 and B2.1.28, to reflect the incorporation of

ASME Code Case N-729-1.

LRA Section A2.28 on Page A-12 is revised in its entirety to read as follows: A2.28 Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program The Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program is a condition monitoring program that implements the requirements of ASME Code Case N-729-1, "Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds,Section XI, Division 1," modified by the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D). This program manages the aging effect of cracking due to primary water stress corrosion cracking of the nickel-alloy vessel head penetration nozzles welded to the upper reactor vessel head. In addition, the program monitors the upper reactor vessel head surface for boric acid deposits. This program is a mandated augmented inservice inspection program that supplements the leakage tests and visual VT-2 examinations required by ASME Section XI, Table IWB-2500-1, Examination Category B-P. The program incorporates the inspection methods, inspection frequencies, and acceptance standards in accordance with ASME Code Case N-729-1, subject to the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D). In LRA Section B2.0, Aging Management Programs Correlation, on Page B-8, line item XI.M11A of the NUREG-1801 program correlation table is revised to appear as follows: NUREG- 1801 ID NUREG-1801 Program PINGP Program NUREG-1801 ComparisonXI.M11ANickel-Alloy Penetration Nozzles Welded to the

Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program [Section B2.1.28]

Existing Program, Consistent with NUREG-1801 Revision of LRA Sections A2.28 and B2.1.28, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program 2 LRA Section B2.1.28 on Pages B-59 to B-61 is revised in its entirety to read as follows: B2.1.28 Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program Program Description The Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program (Nickel-Alloy Vessel Head Penetration Nozzle Program) is a condition monitoring program that implements the requirements of ASME Code Case N-729-1, "Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds,Section XI, Division 1," modified by the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D). This program manages the aging effect of cracking due to primary water stress corrosion cracking (PWSCC) of the nickel-alloy vessel head penetration nozzles welded to the upper reactor vessel head. The program also monitors the upper reactor vessel head surface for boric acid deposits. In addition, the Boric Acid Corrosion Program performs visual examinations of systems containing borated water for evidence of leakage and corrosion in the region above the reactor vessel head. This program is a mandated augmented inservice inspection program that supplements the leakage tests and visual VT-2 examinations required by ASME Section XI, Table IWB-2500-1, Examination Category B-P. The program incorporates the inspection methods, inspection frequencies, and acceptance standards in accordance with ASME Code Case N-729-1, subject to the conditions specified in 10

CFR 50.55a(g)(6)(ii)(D).Federal Register Notice 73 FR 52730 dated September 10, 2008, Industry Codes and Standards; Amended Requirements, states, "In March 2006, the ASME approved Code Case N-729-1, Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds, which provides an alternative long-term inspection program for RPV upper heads. The NRC participated in ASME Code development and approval of N-729-1. The NRC has reviewed the final version of Code Case N-729-1, and with conditions, finds it provides reasonable assurance of public health and safety from failure of the reactor pressure vessel upper head and penetration nozzles. Therefore, the NRC is pursuing this rulemaking activity to incorporate by reference the inspection requirements of Code Case N-729-1, as conditioned, into 10 CFR 50.55a." The Federal Register also states, "Paragraph 50.55a(g)(6)(ii)(D) is added to the regulation to require licensees to comply with the reactor vessel head inspection requirements of ASME Code Case N-729-1, subject to conditions, by December 31, 2008. Compliance to Code Case N-729-1; with conditions regarding inspection frequency, examination coverage, qualification of ultrasonic examination, and reinspection intervals; would be equivalent to complying with NRC Order EA-03-009, dated February 11, 2003, and First Revised Order EA-03-009, dated February 20, 2004. Thus, once a licensee implements Code Case N-729-1, with conditions, the First Revised NRC Order EA-03-009 no longer applies to that licensee and is deemed to be withdrawn." Revision of LRA Sections A2.28 and B2.1.28, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program 3In addition the Federal Register states, "For licensees that have been granted a renewed operating license and have committed to an AMP that is based on both conformance with GALL AMP XI.M11A and compliance with First Revised Order EA-03-009, the licensees may update the program elements of their AMP to reflect compliance with the new requirements in 10 CFR 50.55a(g)(6)(ii)(D) and (E) without having to identify an exception to GALL AMP XI.M11A. For new or current license renewal applicants, they may reference conformance with GALL AMP XI.M11A and compliance with the new augmented inspection requirements in paragraphs 10 CFR 50.55a(g)(6)(ii)(D) and (E) without the need for taking an exception to the program elements in GALL AMP XI.M11A." PINGP is in compliance with the new augmented inspection requirements in paragraph 10 CFR 50.55a(g)(6)(ii)(D) for the reactor vessel head inspections. 10 CFR 50.55a(g)(6)(ii)(E) does not apply to the PINGP upper reactor pressure vessel heads since the heads for both Units 1 and 2 have been replaced using Alloy 690 (versus Alloy 600) nozzles attached using A52 (versus A82/182) weld material. Therefore, the use of ASME Code Case N-729-1 modified by the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D), instead of the Order, as amended, is not considered an exception to NUREG-1801. NUREG-1801 Consistency The Prairie Island Nuclear Generating Plant Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program is an existing program. It is consistent with the recommendations of NUREG-1801, Chapter XI, Program XI.M11A, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors. Exceptions to NUREG-1801 None Enhancements None Operating Experience The upper reactor vessel heads for both Units 1 and 2 have been replaced. The Unit 1 head was replaced during the 1R24 refueling outage in 2006 and the Unit 2 head was replaced during the 2R23 refueling outage in 2005. The new heads now incorporate Nickel-Alloy 690 (SB167) for each of the reactor head penetration nozzles instead of the Nickel-Alloy 600 utilized in the previous heads. Inspections for the upper reactor vessel head surface and each nickel-alloy reactor head penetration nozzle are being implemented in accordance with the requirements of ASME Code Case N-729-1 modified by the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D). A review of operating experience for the Nickel-Alloy Vessel Head Penetration Nozzle Program identified no adverse trends or issues with program performance. A few Revision of LRA Sections A2.28 and B2.1.28, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program 4minor non-relevant leaks from valves were identified and corrected prior to causing any significant impact to safe operation or loss of intended functions. Adequate corrective actions were taken to prevent recurrence. The review of operating experience indicates the Nickel-Alloy Vessel Head Penetration Nozzle Program has been effective in monitoring and detecting degradation and taking effective corrective actions as needed when acceptance criteria are not met.

ConclusionThe Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program is an existing program that manages the effects of cracking due to PWSCC of the nickel-alloy vessel head penetration nozzles welded to the upper reactor vessel head. In addition the program provides for condition monitoring of the upper reactor vessel head surface for boric acid deposits. Implementation of the Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program provides reasonable assurance that aging effects will be managed such that structures, systems, and components within the scope of this program will continue to perform their intended function(s) during the period of extended operation. In the list of License Renewal Commitments, Commitment 22 is deleted in its entirety.

A revised commitment list which reflects this change is provided as Enclosure 3 to this

letter. License Renewal Commitment List 16 Pages Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 1The following table provides the list of commitments included in the Application for Renewed Operating Li cIsland Nuclear Generating Plant (PINGP) Units 1 and 2, as updated in subsequent correspondence.

The commitments in this list are anticipated to be the final commitments which will be confirmed in the NR CReport (SER) for the renewed operating licenses. These commitments, as confirmed in the SER, will bec oissuance of the renewed licenses. In addition, as stated in the LRA, the final commitments will be incorpo r Safety Analysis Report (USAR).

Commitment Number Commitment Implementation Schedule S 1Each year, following the submittal of the PINGP License Renewal Application and at least three months before the scheduled completion of the NRC review, NMC will submit amendments to the PINGP application pursuant to 10 CFR

54.21(b). These revisions will identify any changes to the Current Licensing Basis that materially affect the contents of the License Renewal Application, including the USAR supplements.

12 months after LRA submittal

date and at least

3 months before

completion of NRC review 2 Following the issuance of the renewed operating license, the summary descriptions of aging management programs and

TLAAs provided in Appendix A, and the final list of License Renewal commitments, will be incorporated into the PINGP USAR as part of a periodic USAR update in accordance with 10

CFR 50.71(e). Other changes to specific sections of the PINGP USAR necessary to reflect a renewed operating license will also be addressed at that time.

First USAR update in accordance with 10 CFR 50.71(e) following issuance

of renewed

operating licenses 3 An Aboveground Steel Tanks Program will be implemented.

Program features will be as described in LRA Section B2.1.2.

U1 - 8/9/2013 U2 - 10/29/2014 4 Procedures for the conduct of inspections in the External Surfaces Monitoring Program, Structures Monitoring Program, Buried Piping and Tanks Inspection Program, and the RG U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 2 Commitment Number Commitment Implementation Schedule S 1.127 Inspection of Water-Control Structures Associated with

Nuclear Power Plants Program will be enhanced to include

guidance for visual inspections of installed bolting. 5 A Buried Piping and Tanks Inspection Program will be implemented. Program features will be as described in LRA Section B2.1.8.

U1 - 8/9/2013 U2 - 10/29/2014 6 The Closed-Cycle Cooling Water System Program will be enhanced to include periodic inspection of accessible surfaces

of components serviced by closed-cycle cooling water when the systems or components are opened during scheduled

maintenance or surveillance activities. Inspections are

performed to identify the presence of aging effects and to confirm the effectiveness of the chemistry controls. Visual inspection of component internals will be used to detect loss of

material and heat transfer degradation. Enhanced visual or

volumetric examination techniques will be used to detect

cracking.[Revised in letter dated 1/20/2009 in response to RAI 3.3.2 01]U1 - 8/9/2013 U2 - 10/29/2014 7 The Compressed Air Monitoring Program will be enhanced as follows: Station and Instrument Air System air quality will be monitored and maintained in accordance with the instrument air quality guidance provided in ISA

S7.0.01-1996. Particulate testing will be revised

to use a particle size methodology as specified in

ISA S7.0.01.

U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 3 Commitment Number Commitment Implementation Schedule SThe program will incorporate on-line dew point

monitoring.[Revised in letter dated 2/6/2009 in response to Region III License Renewal Inspection] 8 An Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program will be

completed. Program features will be as described in LRA Section B2.1.11.

U1 - 8/9/2013 U2 - 10/29/2014 9An Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program will be implemented. Program features will be as described in LRA Section B2.1.12.

U1 - 8/9/2013 U2 - 10/29/2014 10 An Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in

Instrumentation Circuits Program will be implemented.

Program features will be as described in LRA Section B2.1.13.

U1 - 8/9/2013 U2 - 10/29/2014 11 The External Surfaces Monitoring Program will be enhanced as follows: The scope of the program will be expanded as necessary

to include all metallic and non-metallic components within

the scope of License Renewal that require aging

management in accordance with this program. The program will ensure that surfaces that are inaccessible or not readily visible during plant operations will be inspected during refueling outages. The program will ensure that surfaces that are U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 4 Commitment Number Commitment Implementation Schedule Sinaccessible or not readily visible during both plant operations and refueling outages will be inspected at

intervals that provide reasonable assurance that aging effects are managed such that the applicable components will perform their intended function during

the period of extended operation. The program will apply physical manipulation techniques, in addition to visual inspection, to detect aging effects in elastomers and plastics. The program will include acceptance criteria (e.g.,

threshold values for identified aging effects) to ensure

that the need for corrective actions will be identified

before a loss of intended functions. The program will ensure that program documentation

such as walkdown records, inspection results, and other records of monitoring and trending activities are auditable

and retrievable.[Revised in letter dated 2/6/2009 in response to RAI B2.1.14-1 Follow Up question] 12 The Fire Protection Program will be enhanced to require periodic visual inspection of the fire barrier walls, ceilings, and floors to be performed during walkdowns at least once every refueling cycle. [Revised in letter dated 12/5/2008 in response to RAI B2.1.15-3]

U1 - 8/9/2013 U2 - 10/29/2014 13 The Fire Water System Program will be enhanced as follows:

U1 - 8/9/2013 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 5 Commitment Number Commitment Implementation Schedule S The program will be expanded to include eight additional yard fire hydrants in the scope of the annual visual inspection and flushing activities. The program will require that sprinkler heads that have been in place for 50 years will be replaced or a

representative sample of sprinkler heads will be tested using the guidance of NFPA 25, "Inspection, Testing and

Maintenance of Water-Based Fire Protection Systems" (2002 Edition, Section 5.3.1.1.1). Sample testing, if

performed, will continue at a 10-year interval following the initial testing.

U2 - 10/29/2014 14 The Flux Thimble Tube Inspection Program will be enhanced as follows: The program will require that the interval between inspections be established such that no flux thimble tube is predicted to incur wear that exceeds the established

acceptance criteria before the next inspection. The program will require that re-baselining of the examination frequency be justified using plant-specific

wear rate data unless prior plant-specific NRC acceptance for the re-baselining was received. If design changes are made to use more wear-resistant thimble tube materials, sufficient inspections will be conducted at an adequate inspection frequency for the new materials. The program will require that flux thimble tubes that cannot be inspected must be removed from service.

U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 6 Commitment Number Commitment Implementation Schedule S15 The Fuel Oil Chemistry Program will be enhanced as follows: Particulate contamination testing of fuel oil in the eleven fuel oil storage tanks in scope of License Renewal will be

performed, in accordance with ASTM D 6217, on an annual basis. One-time ultrasonic thickness measurements will be performed at selected tank bottom and piping locations prior to the period of extended operation.

U1 - 8/9/2013 U2 - 10/29/2014 16 A Fuse Holders Program will be implemented. Program features will be as described in LRA Section B2.1.20.

U1 - 8/9/2013 U2 - 10/29/2014 17 An Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program will be implemented. Program features will be as described in LRA Section B2.1.21 U1 - 8/9/2013 U2 - 10/29/2014 18 An Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program will be implemented. Program

features will be as described in LRA section B2.1.22.

Inspections for stress corrosion cracking will be performed by

visual examination with a magnified resolution as described in 10 CFR 50.55a(b)(2)(xxi)(A) or with ultrasonic methods. [Revised in letter dated 2/6/2009 in response to RAI B2.1.22-1 Follow Up question]

U1 - 8/9/2013 U2 - 10/29/2014 19 The Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program will be enhanced as follows:

U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 7 Commitment Number Commitment Implementation Schedule S Program implementing procedures will be revised to ensure the components and structures subject to inspection are clearly identified. Program inspection procedures will be enhanced to include the parameters corrosion and wear where omitted.20A Metal-Enclosed Bus Program will be implemented. Program features will be as described in LRA Section B2.1.26.

U1 - 8/9/2013 U2 - 10/29/2014 21 Number Not Used

[Revised in letter dated 3/27/2009]

22 Number Not Used

[Revised in letter dated 4/13/2009]

23 A One-Time Inspection Program will be completed. Program features will be as described in LRA Section B2.1.29.

U1 - 8/9/2013 U2 - 10/29/2014 24A One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program will be completed. Program features will be as described in LRA Section B2.1.30.

U1 - 8/9/2013 U2 - 10/29/2014 25For the PWR Vessel Internals Program, PINGP commits to the following activities for managing the aging of reactor vessel internals components: Participate in the industry programs for investigating and managing aging effects on reactor internals; U1 - 8/9/2011 U2 - 10/29/2012 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 8 Commitment Number Commitment Implementation Schedule S Evaluate and implement the results of the industry programs as applicable to the reactor internals; and Upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval.

26The Reactor Head Closure Studs Program will be enhanced to incorporate controls that ensure that any future procurement of reactor head closure studs will be in accordance with the material and inspection guidance provided in NRC Regulatory Guide 1.65.

U1 - 8/9/2013 U2 - 10/29/2014 27The Reactor Vessel Surveillance Program will be enhanced as follows: A requirement will be added to ensure that all withdrawn and tested surveillance capsules, not discarded as of

August 31, 2000, are placed in storage for possible future reconstitution and use. A requirement will be added to ensure that in the event spare capsules are withdrawn, the untested capsules are placed in storage and maintained for future insertion.

U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 9 Commitment Number Commitment Implementation Schedule S 28 The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program will be enhanced as follows: The program will include inspections of concrete and steel components that are below the water line at the Screenhouse and Intake Canal. The scope will also require inspections of the Approach Canal, Intake Canal, Emergency Cooling Water Intake, and Screenhouse immediately following extreme environmental conditions

or natural phenomena including an earthquake, flood, tornado, severe thunderstorm, or high winds. The program parameters to be inspected will include an inspection of water-control concrete components that are below the water line for cavitation and erosion degradation. The program will visually inspect for damage such as cracking, settlement, movement, broken bolted and

welded connections, buckling, and other degraded conditions following extreme environmental conditions or natural phenomena.

U1 - 8/9/2013 U2 - 10/29/2014 29 A Selective Leaching of Materials Program will be completed.Program features will be as described in LRA B2.1.36.

U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 10 Commitment Number Commitment Implementation Schedule S 30 The Structures Monitoring Program will be enhanced as follows: The following structures, components, and component supports will be added to the scope of the inspections:

o Approach Canal o Fuel Oil Transfer House o Old Administration Building and Administration Building Addition o Component supports for cable tray, conduit, cable, tubing tray, tubing, non-ASME vessels, exchangers, pumps, valves, piping, mirror

insulation, non-ASME valves, cabinets, panels, racks, equipment enclosures, junction boxes, bus

ducts, breakers, transformers, instruments, diesel equipment, housings for HVAC fans, louvers, and

dampers, HVAC ducts, vibration isolation

elements for diesel equipment, and miscellaneous electrical and mechanical equipment items o Miscellaneous electrical equipment and instrumentation enclosures including cable tray, conduit, wireway, tube tray, cabinets, panels, racks, equipment enclosures, junction boxes, breaker housings, transformer housings, lighting

fixtures, and metal bus enclosure assemblies o Miscellaneous mechanical equipment enclosures including housings for HVAC fans, louvers, and

dampers o SBO Yard Structures and components including U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 11 Commitment Number Commitment Implementation Schedule S SBO cable vault and bus duct enclosures.

o Fire Protection System hydrant houses o Caulking, sealant and elastomer materials o Non-safety related masonry walls that support equipment relied upon to perform a function that

demonstrates compliance with a regulated

event(s). The program will be enhanced to include additional inspection parameters. The program will require an inspection frequency of once every five (5) years for structures and structural components within the scope of the program. The

frequency of inspections can be adjusted, if necessary, to

allow for early detection and timely correction of negative trends. The program will require periodic sampling of groundwater and river water chemistries to ensure they remain non-aggressive.

31A Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program will be implemented. Program features will be as described in LRA Section B2.1.39.

U1 - 8/9/2013 U2 - 10/29/2014 32 The Water Chemistry Program will be enhanced as follows: The program will require increased sampling to be performed as needed to confirm the effectiveness of corrective actions taken to address an abnormal chemistry condition.

U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 12 Commitment Number Commitment Implementation Schedule S The program will require Reactor Coolant System dissolved oxygen Action Level limits to be consistent with

the limits established in the EPRI PWR Primary Water Chemistry Guidelines." [Revised in letter dated 12/5/2008 in response to RAI B2.1.40-3]

33 The Metal Fatigue of Reactor Coolant Pressure Boundary Program will be enhanced as follows: The program will monitor the six component locations identified in NUREG/CR-6260 for older vintage

Westinghouse plants, either by tracking the cumulative number of imposed stress cycles using cycle counting, or

by tracking the cumulative fatigue usage, including the

effects of coolant environment. The following locations will be monitored:

o Reactor Vessel Inlet and Outlet Nozzles o Reactor Pressure Vessel Shell to Lower Head o RCS Hot Leg Surge Line Nozzle o RCS Cold Leg Charging Nozzle o RCS Cold Leg Safety Injection Accumulator Nozzle o RHR-to-Accumulator Piping Tee Program acceptance criteria will be clarified to require corrective action to be taken before a cumulative fatigue usage factor exceeds 1.0 or a design basis transient

cycle limit is exceeded. [Revised in letter dated 1/9/2009 in response to RAI 4.3.1.1-1]

U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 13 Commitment Number Commitment Implementation Schedule S 34 Reactor internals baffle bolt fatigue transient limits of 1835 cycles of plant loading at 5% per minute and 1835 cycles of plant unloading at 5% per minute will be incorporated into the

Metal Fatigue of Reactor Coolant Pressure Boundary Program and USAR Table 4.1-8.

U1 - 8/9/2013 U2 - 10/29/2014 35NSPM will perform an ASME Section III fatigue evaluation of the lower head of the pressurizer to account for effects of insurge/outsurge transients. The evaluation will determine the

cumulative fatigue usage of limiting pressurizer component(s)

through the period of extended operation. The analyses will

account for periods of both "Water Solid" and "Standard

Steam Bubble" operating strategies. Analysis results will be incorporated, as applicable, into the Metal Fatigue of Reactor

Coolant Pressure Boundary Program. [Revised in letter dated 1/9/2009 in response to RAI 4.3.1.1-1]

U1 - 8/9/2013 U2 - 10/29/2014 36 NSPM will complete fatigue calculations for the pressurizer surge line hot leg nozzle and the charging nozzle using the methodology of the ASME Code (Subsection NB) and will

report the revised CUFs and CUFs adjusted for environmental effects at these locations as an amendment to the PINGP LRA. Conforming changes to LRA Section 4.3.3, "PINGP EAF Results," will also be included in that amendment to reflect analysis results and remove references to stress-based

fatigue monitoring.

[Added in letter dated 1/9/2009 in response to RAI 4.3.1.1-1]

April 30, 2009 37NSPM will revise procedures for excavation and trenching controls and archaeological, cultural and historic resource

protection to identify sensitive areas and provide guidance for 8/9/2013 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 14 Commitment Number Commitment Implementation Schedule Sground-disturbing activities. The procedures will be revised to

include drawings and illustrations to assist users in identifying culturally sensitive areas, and pictures of artifacts that are prevalent in the area of the Plant site. The revised procedures

will also require training of the Site Environmental Coordinator

and other personnel responsible for proper execution of excavation or other ground-disturbing activities. [Added in ER revision submitted in letter dated 3/4/2009]

38NSPM will conduct a Phase I Reconnaissance Field Survey of the disturbed areas within the Plant's boundaries. In addition, NSPM will conduct Phase I field surveys of areas of known archaeological sites to precisely determine their boundaries.

NSPM will use the results of these surveys to designate areas for archaeological protection. [Added in ER revision submitted in letter dated 3/4/2009]

8/9/2013 39NSPM will prepare, maintain and implement a Cultural Resources Management Plan (CRMP) to protect significant historical, archaeological, and cultural resources that may currently exist on the Plant site. In

connection with the preparation of the CRMP, NSPM will

conduct botanical surveys to identify culturally and medicinally important species on the Plant site, and incorporate provisions to protect such plants into the CRMP.[Added in ER revision submitted in letter dated 3/4/2009]

8/9/2013 40NSPM will consult with a qualified archaeologist prior to conducting any ground-disturbing activity in any area 8/9/2013 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 15 Commitment Number Commitment Implementation Schedule S designated as undisturbed and in any disturbed area that is described as potentially containing archaeological resources (as determined by the Phase I Reconnaissance Field Survey

discussed in Commitment Number 38). [Added in ER revision submitted in letter dated 3/4/2009]

41During the first refueling outage following refueling cavity leak repairs in each Unit (scheduled for refueling outages 1R26 and 2R26), concrete will be removed from the sump C pit to expose

an area of the containment vessel bottom head. Visual examination and ultrasonic thickness measurement will be

performed on the portions of the containment vessels exposed

by the excavations. An assessment of the condition of exposed

concrete and rebar will also be performed. Degradation

observed in the exposed containment vessel, concrete or rebar

will be entered into the Corrective Action Program and evaluated for impact on structural integrity and identification of

additional actions that may be warranted.

[Added in letter dated 4/6/09 in response to Follow Up RAI B2.1.38]U1 - 8/9/2013 U2 - 10/29/2014 42During the two consecutive refueling outages following refueling cavity leak repairs in each Unit (scheduled for refueling outages

1R26 and 2R26), visual inspections will be performed of the areas where reactor cavity leakage had been observed previously to confirm that leakage has been resolved. The inspection results will be documented. If refueling cavity

leakage is again identified, the issue will be entered into the

Corrective Action Program and evaluated for identification of additional actions to mitigate leakage and monitor the condition of the containment vessel and internal structures.

U1 - 8/9/2013 U2 - 10/29/2014 Prairie Island Nuclear Generating Plant License Renewal CommitmentsUpdated through 4/13/2009 16 Commitment Number Commitment Implementation Schedule S[Added in letter dated 4/6/09 in response to Follow Up RAI

B2.1.38]43Preventive maintenance requirements will be implemented to require periodic replacement of rubber flexible hoses in the Diesel Generators and Support System that are exposed to fuel oil or lubricating oil internal environments.

[Added in letter dated 4/6/09 in response to RAI 3.3.2-8-1]

U1 - 8/9/2013 U2 - 10/29/2014 1717 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1121 April 13, 2009 L-PI-09-043 10 CFR 54.21(b)

U S Nuclear Regulatory Commission

ATTN: Document Control Desk

Washington, DC 20555-0001

Prairie Island Nuclear Generating Plant Units 1 and 2

Dockets 50-282 and 50-306

License Nos. DPR-42 and DPR-60

Annual Update of the A pplication for Renewed Operating Licenses

By letter dated April 11, 2008, Norther n States Power Company, a Minnesota Corporation, (NSPM) submitted an Application for Renewed Operating Licenses (LRA) for the Prairie Island Nuclear Generating Pl ant (PINGP) Units 1 and 2. 10 CFR 54.21(b) requires that each year following submittal of a license renewal application, and at least three months before scheduled completion of the NRC review, an amendment to the application shall be submitted that identifies any changes to the CLB that materially affect the contents of the LRA. Th is letter provides that amendment.

A review of the PINGP CLB changes since submittal of the LRA has been completed. Two CLB changes have been identified that materi ally affect the contents of the LRA. The LRA revisions to reflect these CLB changes are provided as follows:

Enclosure 1 provides a revised LRA Section 1.3 to reflect the transfer of the Facility Operating Licenses from Nuclear Management Company to NSPM.

provides revisions to LRA Sections A2.28 and B2.1.28, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program, to refl ect the incorporation of ASME Code Case N-729-1 as required by a change to 10 CFR 50.

55a, published in the Federal Register on September 10, 2008 (73 FR 52730).

provides the list of Licens e Renewal Commitments updated to reflect NSPM correspondence to date.

If there are any questions or if additional information is needed, please contact Mr. Eugene Eckholt, License Renewal Project Manager.

Document Control Desk Page 2 Summary of Commitments This letter contains no new commitment

s. Commitment No. 22 in the list of Preliminary License Renewal Commitm ents contained in the LRA transmittal letter dated April 11, 2008 is withdrawn.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on April 13, 2009.

/S/ Michael D. Wadley

Michael D. Wadley

Site Vice President, Prairie Island Nuclear Generating Plant Units 1 and 2 Northern States Power Company - Minnesota

Enclosures (3)

cc:

Administrator, Region III, USNRC License Renewal Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC

Prairie Island Indian Communi ty ATTN: Phil Mahowald Minnesota Department of Commerce

Revision of LRA Section 1.3, Information Required by 10 CFR 54.17 and 10 CFR 54.19 1In an application dated April 16, 2008, Nuclear Management Company, LLC, the operating licensee for the Prairie Island Nucl ear Generating Plant (PINGP), requested a transfer of the Facility Operating Licens es No. DPR-42 for PINGP Unit 1 and DPR-60 for Unit 2, to the plant ow ner, Northern States Power Company. The conforming license amendments to affect the transfer of the operating license s were issued on September 22, 2008, as Amendments 188 and 177 for Units 1 and 2, respectively. The LRA is being revised to reflect th is license transfer.

LRA Section 1.3 is hereby revised in its entirety to read as follows:

1.3 Information Required by 10 CFR 54.17 and 10 CFR 54.19

1.3.1 Name of Applicant Northern States Power Company, a Minnes ota Corporation (NSPM), the operating licensee, hereby applies for renewed operating licenses for the Prairie Island Nuclear Generating Plant Units 1 and 2.

In any place in this application where Nuclear Management Company (NMC) is referenced, it shall be understood to mean NSPM.

1.3.2 Address of Applicant Address of Owner and Licensee

Northern States Power Company

414 Nicollet Mall

Minneapolis, MN 55401

Address of Prairie Island Nuclear Generating Plant

Prairie Island Nuclear Generating Plant

1717 Wakonade Dr East

Welch, MN 55089

1.3.3 Description of Business or Occupation of Applicant Northern States Power Company, a Minnes ota corporation (NSPM), is a utility principally involved in the generation, purchase, transmissi on, distribution and sale of electricity. NSPM is a wholly owned utility operating company subsidiary of Xcel Energy, Inc. ("Xcel Energy"). Xcel Energy , a Minnesota corporation, is a major U.S.

electric and natural gas company that operat es in eight Western and Midwestern states and provides a comprehensive portfolio of energy-related products and services to approximately 3.3 million electr icity customers and 1.8 million natural gas customers.

Revision of LRA Section 1.3, Information Required by 10 CFR 54.17 and 10 CFR 54.19 2 NSPM is not owned, controlled, or dominated by an alien, a foreign corporation, or a foreign government. NSPM makes this application on its own behalf and is not acting as an agent or representativ e of any other person.

1.3.4 Organization and Management of Applicant NSPM is a Minnesota corporation. Its principal place of business is Minneapolis, Minnesota. The names and addresses of the di rectors and principal officers of NSPM, all of whom are U.S. citizens, are listed below:

NSPM Directors

Name Business Address

Benjamin G.S. Fowke III 414 Nicollet Mall Minneapolis, MN 55401

Richard C. Kelly 414 Nicollet Mall Minneapolis, MN 55401

David M. Sparby 414 Nicollet Mall Minneapolis, MN 55401

NSPM Principal Officers

Name Business Address

Richard C. Kelly 414 Nicollet Mall Chairman Minneapolis, MN 55401

David M. Sparby 414 Nicollet Mall President and Chief Executive Officer Minneapolis, MN 55401

Michael C. Connelly 414 Nicollet Mall

Vice President and General Counsel Minneapolis, MN 55401

David M. Wilks 4653 Table Mountain Drive Vice President Golden, CO 80403

Benjamin G.S. Fowke III 414 Nicollet Mall

Vice President and Chief Financial Officer Minneapolis, MN 55401

Dennis L. Koehl 250 Marquette Plaza

Vice President and Chief Nuclear Officer Minneapolis, MN 55401

Revision of LRA Section 1.3, Information Required by 10 CFR 54.17 and 10 CFR 54.19 3 Legal Counsel

Peter M. Glass 414 Nicollet Mall Xcel Energy Minneapolis, MN 55401

David R. Lewis 2300 N Street, NW Pillsbury Winthrop Shaw Pittman LLP Washington, DC 20037

1.3.5 Class of License, Use of Facility, and Period of Time for which the License is Sought NSPM requests renewal of the Class 104b oper ating licenses for the Prairie Island Nuclear Generating Plant (Facility Operat ing Licenses DPR-42 and DPR-60) for a period of 20 years beyond the expiration of t he current license. This would extend the operating license for Unit 1 from midnight August 9, 2013, to midnight August 9, 2033 and for Unit 2 from midnight October 29, 2014 to midnight Oct ober 29, 2034. The facility will continue to be known as the Prairie Island Nuclear Generating Plant.

This application includes a request for renewal of those NRC source material, special nuclear material, and by-product material lic enses included within the current operating licenses and issued pursuant to 10 CFR Parts 30, 40 and 70.

1.3.6 Earliest and Latest Dat es for Alterations, if Proposed NSPM does not propose to construct or alte r any production or utilization facility in connection with this renewal application.

The Current Licensing Basis (CLB) will be continued and maintained throughout the period of extended operation.

1.3.7 Listing of Regulatory Agencies Having Jurisdiction and News Publications In addition to the Nuclear Regulatory Commission, the Federal Energy Regulatory Commission and the State of Minnesota Public Utilities Commission are the principal regulators of the company's elec tric operations in Minnesota.

Federal Energy Regul atory Commission 888 First Street, NE

Washington, DC 20426

Minnesota Public Utilities Commission

121 7th Place East, Suite 350

St. Paul, MN 55101-2147

News publications in circulation near PI NGP which should be considered for public notices related to the application are as follows:

Revision of LRA Section 1.3, Information Required by 10 CFR 54.17 and 10 CFR 54.19 4 The Republican Eagle 2760 North Service Drive

Red Wing, MN 55066

The Saint Paul Pioneer Press 345 Cedar Street St. Paul, MN 55101

The Star Tribune

425 Portland Avenue

Minneapolis, MN 55488-0002

Rochester Post-Bulletin

18 First Avenue, S.E.

Rochester, MN 55903-6118

Eau Claire Leader-Telegram

701 South Farwell Street

Eau Claire, WI 54701

Hastings Star - Gazette

741 Spiral Boulevard

Hastings, MN 55033

Pierce County Herald

126 South Chestnut Street Ellsworth, WI 54011

1.3.8 Conforming Changes to Standard Indemnity Agreement NSPM requests that conforming changes be made to indemnity agreement No. B-60 for the Prairie Island Nuclear Generating Plant Un its 1 and 2, as requi red, to ensure that the indemnity agreement continues to appl y during both the term s of the current licenses and the terms of the renewed licenses. NSPM understands that no changes may be necessary for this purpose if the current operating license numbers are retained.

1.3.9 Restricted Data Agreement This application does not contain restricted data or other national defense information, nor is it expected that s ubsequent amendments to the license application will contain such information. However, pursuant to 10 CFR 54.17(g) and 10 CFR 50.37, NSPM, as a part of the application for a renewed operating licenses, hereby agrees that it will not permit any individual to have access to, or an y facility to possess, Restricted Data or classified National Security Information until the individual and/or facility has been approved for such access under the provisions of 10 CFR Parts 25 and/or 95.

Revision of LRA Sections A2.28 and B2.1.28, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program 1 Federal Register Notice 73 FR 52730 of September 10, 2008, published a change to 10 CFR 50.55a which incorporat ed a requirement to implem ent ASME Code Case N-729-1 for the inspection of PWR Reactor Vessel U pper Heads. This code case supersedes the previous inspection requirements embodied in the NRC First Revised Order EA 009, "Issuance of First Revised NRC Order (EA-03-009) Establishing Interim Inspection Requirements for Reactor Pressure Vessel H eads at Pressurized Water Reactors."

Conforming changes are being made to the PINGP Nickel-Alloy P enetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program, described in LRA Sections A2.28 and B2.1.28, to reflect the incorporation of ASME Code Case N-729-1.

LRA Section A2.28 on Page A-12 is revis ed in its entirety to read as follows:

A2.28 Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program The Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program is a condition monitoring program that implements the requirements of ASME Code Case N-729-1, "Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds,Section XI, Division 1," modified by the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D). This program manages the aging effect of cracking due to primary water stress corrosion cracking of the nickel-alloy vessel head penetration nozzles welded to the upper reactor vessel head. In addition, the program monitors the upper reactor vessel head surface for boric acid deposits.

This program is a mandated augmented inservice inspection program that supplements the leakage tests and visual VT-2 examinations required by ASME Section XI, Table IWB-2500-1, Examination Category B-P. The program incorporates the inspection methods, inspection frequencies, and acceptance standards in accordance with ASME Code Case N-729-1, subject to the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D).

In LRA Section B2.0, Aging Management Programs Correlation, on Page B-8, line item XI.M11A of the NUREG-1801 program correlation table is revised to appear as follows:

NUREG- 1801 ID NUREG-1801 Program PINGP Program NUREG-1801 Comparison XI.M11A Nickel-Alloy Penetration Nozzles Welded to the

Upper Reactor Vessel

Closure Heads of Pressurized Water Reactors Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads

of Pressurized Water Reactors Program [Section B2.1.28]

Existing Program, Consistent with NUREG-1801

Revision of LRA Sections A2.28 and B2.1.28, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program 2 LRA Section B2.1.28 on Pages B-59 to B-61 is revised in its entiret y to read as follows:

B2.1.28 Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program Program Description The Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program (Nickel-Alloy Vessel Head Penetration Nozzle Program) is a condition monitoring program that implements the requirements of ASME Code Case N-729-1, "Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds,Section XI, Division 1," modified by the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D). This program manages the aging effect of cracking due to primary water stress corrosion cracking (PWSCC) of the nickel-alloy vessel head penetration nozzles welded to the upper reactor vessel head. The program also monitors the upper reactor vessel head surface for boric acid deposits. In addition, the

Boric Acid Corrosion Program performs visual examinations of systems containing borated water for evidence of leakage and corrosion in the region above the reactor vessel head.

This program is a mandated augmented inservice inspection program that supplements the leakage tests and visual VT-2 examinations required by ASME Section XI, Table IWB-2500-1, Examination Category B-P. The program incorporates the inspection methods, inspection frequencies, and acceptance standards in accordance with ASME Code Case N-729-1, subject to the conditions specified in 10

CFR 50.55a(g)(6)(ii)(D).

Federal Register Notice 73 FR 52730 dated September 10, 2008, Industry Codes and Standards; Amended Requirements, states, "In March 2006, the ASME approved Code Case N-729-1, Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds, which provides an alternative long-term inspection program for RPV upper heads. The NRC participated in ASME Code development and approval of N-729-1. The NRC has reviewed the final version of Code Case N-729-1, and with conditions, finds it provides reasonable assurance of public health and safety from failure of the reactor pressure vessel upper head and penetration noz zles. Therefore, the NRC is pursuing this rulemaking activity to incorporate by reference the inspection requirements of Code Case N-729-1, as conditioned, into 10 CFR 50.55a." The Federal Register also states, "Paragraph 50.55a(g)(6)(ii)(D) is added to the regulation to require licensees to comply with the reactor vessel head inspection requirements of ASME Code Case N-729-1, subject to conditions, by December 31, 2008. Compliance to Code Case N-729-1; with conditions regarding inspection frequency, examination coverage, qualification of ultrasonic examination, and reinspection intervals; would be equivalent to complying with NRC Order EA-03-009, dated February 11, 2003, and First Revised Order EA-03-009, dated February 20, 2004. Thus, once a licensee implements Code Case N-729-1, with conditions, the First Revised NRC Order EA-03-009 no longer applies to that licensee and is deemed to be withdrawn."

Revision of LRA Sections A2.28 and B2.1.28, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program 3In addition the Federal Register states, "For licensees that have been granted a renewed operating license and have committed to an AMP that is based on both conformance with GALL AMP XI.M11A and compliance with First Revised Order EA-03-009, the licensees may update the program elements of their AMP to reflect compliance with the new requirements in 10 CFR 50.55a(g)(6)(ii)(D) and (E) without having to identify an exception to GALL AMP XI.M11A. For new or current license renewal applicants, they may reference conformance with GALL AMP XI.M11A and compliance with the new augmented inspection requirements in paragraphs 10 CFR 50.55a(g)(6)(ii)(D) and (E) without the need for taking an exception to the program elements in GALL AMP XI.M11A."

PINGP is in compliance with the new augmented inspection requirements in paragraph 10 CFR 50.55a(g)(6)(ii)(D) for the reactor vessel head inspections. 10 CFR 50.55a(g)(6)(ii)(E) does not apply to the PINGP upper reactor pressure vessel heads since the heads for both Units 1 and 2 have been replaced using Alloy 690 (versus Alloy 600) nozzles attached using A52 (versus A82/182) weld material.

Therefore, the use of ASME Code Case N-729-1 modified by the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D), instead of the Order, as amended, is not considered an exception to NUREG-1801.

NUREG-1801 Consistency The Prairie Island Nuclear Generating Plant Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program is an existing program. It is consistent with the recommendations of NUREG-1801, Chapter XI, Program XI.M11A, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors.

Exceptions to NUREG-1801 None Enhancements None Operating Experience

The upper reactor vessel heads for both Units 1 and 2 have been replaced. The Unit 1 head was replaced during the 1R24 refueling outage in 2006 and the Unit 2 head was replaced during the 2R23 refueling outage in 2005. The new heads now incorporate Nickel-Alloy 690 (SB167) for each of the reactor head penetration nozzles instead of the Nickel-Alloy 600 utilized in the previous heads. Inspections for the upper reactor vessel head surface and each nickel-alloy reactor head penetration nozzle are being implemented in accordance with the requirements of ASME Code Case N-729-1 modified by the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D).

A review of operating experience for the Nickel-Alloy Vessel Head Penetration Nozzle Program identified no adverse trends or issues with program performance. A few Revision of LRA Sections A2.28 and B2.1.28, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program 4minor non-relevant leaks from valves were identified and corrected prior to causing any significant impact to safe operation or loss of intended functions. Adequate corrective actions were taken to prevent recurrence.

The review of operating experience indicates the Nickel-Alloy Vessel Head Penetration

Nozzle Program has been effective in monitoring and detecting degradation and taking effective corrective actions as needed when acceptance criteria are not met.

Conclusion The Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program is an existing program that manages the effects of cracking due to PWSCC of the nickel-alloy vessel head penetration nozzles welded to the upper reactor vessel head. In addition the program provides for condition monitoring of the upper reactor vessel head surface for boric acid deposits.

Implementation of the Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program provides reasonable assurance that aging effects will be managed such that structures, systems, and components within the scope of this program will continue to perform their intended function(s) during the period of extended operation.

In the list of License Renewal Commitments, Commitment 22 is deleted in its entirety.

A revised commitment list which reflects this change is provided as Enclosure 3 to this letter.

Enclosure 3 License Renewal Commitment List

16 Pages Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 1 The following table provides the list of commitments included in the Application for Renewed Operating Licenses (LRA) for Prair ie Island Nuclear Generating Plant (PINGP) Units 1 and 2, as updated in subsequent correspondence.

The commitments in this list are anticipat ed to be the final commitments which will be confirmed in the NRC's Safety Evaluation Report (SER) for the renewed operating licen ses. These commitments, as confirmed in the SER, will become effective upon NRC issuance of the renewed licenses. In addition, as stated in the LRA, the final commi tments will be incorporated into the Updat ed Safety Analysis Report (USAR).

Commitment Number Commitment Implementation Schedule Related LRA Section Number 1 Each year, following the submittal of the PINGP License Renewal Application and at l east three months before the scheduled completion of the NRC review, NMC will submit

amendments to the PINGP application pursuant to 10 CFR 54.21(b). These revisions will identify any changes to the Current Licensing Basis that materially affect the contents of the License Renewal Application, including the USAR supplements.

12 months after LRA submittal

date and at least

3 months before

completion of NRC review 1.4 2 Following the issuance of the renewed operating license, the summary descriptions of aging management programs and TLAAs provided in Appendix A, a nd the final list of License Renewal commitments, will be in corporated into the PINGP USAR as part of a periodic USAR update in accordance with 10

CFR 50.71(e). Other changes to specific sections of the PINGP USAR necessary to reflect a renewed operating license will also be addressed at that time.

First USAR update in accordance with 10 CFR 50.71(e) following issuance of renewed operating licenses A1.0 3 An Aboveground Steel Tanks Program will be implemented.

Program features will be as descr ibed in LRA Section B2.1.2.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.2 4 Procedures for the conduct of inspections in the External Surfaces Monitoring Program, St ructures Monitoring Program, Buried Piping and Tanks Insp ection Program, and the RG U1 - 8/9/2013 U2 - 10/29/2014 B2.1.6 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 2 Commitment Number Commitment Implementation Schedule Related LRA Section Number 1.127 Inspection of Water-Control Structures Associated with Nuclear Power Plants Program will be enhanced to include guidance for visual inspections of installed bolting. 5 A Buried Piping and Tanks Inspection Program will be implemented. Program features will be as described in LRA Section B2.1.8.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.8 6 The Closed-Cycle Cooling Water System Program will be enhanced to include periodic inspection of accessible surfaces

of components serviced by closed-cycle cooling water when the systems or components are opened during scheduled maintenance or surveillance ac tivities. Inspections are performed to identify the pres ence of aging effects and to confirm the effectiveness of the chemistry controls. Visual inspection of component internals will be used to detect loss of

material and heat transfer degr adation. Enhanced visual or volumetric examination tec hniques will be used to detect cracking.

[Revised in letter dated 1/20/2009 in response to RAI 3.3.2 01] U1 - 8/9/2013 U2 - 10/29/2014 B2.1.9 7 The Compressed Air Monitoring Program will be enhanced as follows:

Station and Instrument Ai r System air quality will be monitored and maintained in accordance with

the instrument air quality guidance provided in ISA S7.0.01-1996. Particulat e testing will be revised to use a particle size methodology as specified in

ISA S7.0.01.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.10 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 3 Commitment Number Commitment Implementation Schedule Related LRA Section Number The program will incorpor ate on-line dew point monitoring. [Revised in letter dated 2/6/2009 in response to Region III License Renewal Inspection] 8 An Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program will be completed. Program features will be as described in LRA Section B2.1.11.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.11 9 An Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program will be implemented. Program features will be as described in LRA Section B2.1.12.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.12 10 An Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualific ation Requirements Used in Instrumentation Circuits Program will be implemented.

Program features will be as descr ibed in LRA Section B2.1.13.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.13 11 The External Surfaces Monitoring Program will be enhanced as follows: The scope of the program will be expanded as necessary to include all metallic and non-metallic components within

the scope of License Renewal that require aging

management in accordance with this program.

The program will ensure that surfaces that are inaccessible or not readily visible during plant operations will be inspected durin g refueling outages.

The program will ensure that surfaces that are U1 - 8/9/2013 U2 - 10/29/2014 B2.1.14 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 4 Commitment Number Commitment Implementation Schedule Related LRA Section Number inaccessible or not readily visible during both plant operations and refueling outages will be inspected at intervals that provide reasonable assurance that aging effects are managed such that the applicable components will perform their intended function during

the period of ex tended operation.

The program will apply physical manipulation techniques, in addition to visual inspection, to detect aging effects in elastomers and plastics.

The program will include acc eptance criteria (e.g., threshold values for identif ied aging effects) to ensure that the need for corrective actions will be identified

before a loss of intended functions.

The program will ensure that program documentation such as walkdown records, inspection results, and other

records of monitoring and trending activities are auditable and retrievable. [Revised in letter dated 2/6/2009 in response to RAI B2.1.14-1 Follow Up question] 12 The Fire Protection Program will be enhanced to require periodic visual inspection of the fire barrier walls, ceilings, and floors to be performed during walkdowns at least once every refueling cycle. [Revised in letter dated 12/5/2008 in response to RAI B2.1.15-3]

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.15 13 The Fire Water System Program will be enhanced as follows: U1 - 8/9/2013 B2.1.16 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 5 Commitment Number Commitment Implementation Schedule Related LRA Section Number The program will be expanded to include eight additional yard fire hydrants in the scope of the annual visual inspection and flushing activities. The program will require that sprinkler heads that have been in place for 50 years will be replaced or a representative sample of sprinkler heads will be tested using the guidance of NFPA 25, "Inspection, Testing and Maintenance of Water-Based Fire Protection Systems" (2002 Edition, Section 5.3.1.

1.1). Sample testing, if performed, will continue at a 10-year interval following the initial testing.

U2 - 10/29/2014 14 The Flux Thimble Tube Ins pection Program will be enhanced as follows: The program will require t hat the interval between inspections be established such that no flux thimble tube is predicted to incur wear that exceeds the established acceptance criteria before the next inspection. The program will require that re-baselining of the examination frequency be justif ied using plant-specific wear rate data unless prior plant-specific NRC acceptance for the re-baselining was received. If design changes are made to use more wear-resistant thimble tube materials, sufficient inspections will be conducted at an adequate inspection frequency for the new materials. The program will require that flux thimble tubes that cannot be inspected must be removed from service.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.18 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 6 Commitment Number Commitment Implementation Schedule Related LRA Section Number 15 The Fuel Oil Chemistry Progr am will be enhanced as follows: Particulate contamination test ing of fuel oil in the eleven fuel oil storage tanks in scope of License Renewal will be performed, in accordance with ASTM D 6217, on an annual basis. One-time ultrasonic thickness measurements will be performed at selected tank bottom and piping locations prior to the period of extended operation.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.19 16 A Fuse Holders Program will be implemented. Program features will be as described in LRA Section B2.1.20.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.20 17 An Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program will be implemented. Program features will be as described in LRA Section B2.1.21 U1 - 8/9/2013 U2 - 10/29/2014 B2.1.21 18 An Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program will be implemented. Program features will be as described in LRA section B2.1.22. Inspections for stress corrosion cracking will be performed by visual examination with a magni fied resolution as described in 10 CFR 50.55a(b)(2)(xxi)(A) or with ultrasonic methods. [Revised in letter dated 2/6/2009 in response to RAI B2.1.22-1 Follow Up question]

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.22 19 The Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program will be enhanced as follows:

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.23 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 7 Commitment Number Commitment Implementation Schedule Related LRA Section Number Program implementing procedures will be revised to ensure the components and structures subject to inspection are clearly identified. Program inspection procedures will be enhanced to include the parameters corrosion and wear where omitted. 20 A Metal-Enclosed Bus Program will be implemented. Program features will be as described in LRA Section B2.1.26.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.26 21 Number Not Used

[Revised in letter dated 3/27/2009]

22 Number Not Used

[Revised in letter dated 4/13/2009]

23 A One-Time Inspection Program will be completed. Program features will be as described in LRA Section B2.1.29.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.29 24 A One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program will be completed.

Program featur es will be as described in LRA Section B2.1.30.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.30 25 For the PWR Vessel Internals Program, PINGP commits to the following activities for managing the aging of reactor vessel internals components: Participate in the industry programs for investigating and managing aging effects on reactor internals; U1 - 8/9/2011 U2 - 10/29/2012 B2.1.32 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 8 Commitment Number Commitment Implementation Schedule Related LRA Section Number Evaluate and implement the results of the industry programs as applicable to the reactor internals; and Upon completion of these pr ograms, but not less than 24 months before entering the per iod of extend ed operation, submit an inspection plan for reactor internals to the NRC for review and approval.

26 The Reactor Head Closure Studs Program will be enhanced to incorporate controls that ensure that any future procurement of reactor head closure studs will be in accordance with the material and inspection guidance provided in NRC Regulatory Guide 1.65.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.33 27 The Reactor Vessel Surveillance Program will be enhanced as follows: A requirement will be added to ensure that all withdrawn and tested surveillance capsules, not discarded as of August 31, 2000, are placed in storage for possible future reconstitution and use. A requirement will be added to ensure that in the event spare capsules are withdrawn, the untested capsules are placed in storage and maintained for future insertion.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.34 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 9 Commitment Number Commitment Implementation Schedule Related LRA Section Number 28 The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program will be enhanced as follows: The program will include inspections of concrete and steel components that are bel ow the water line at the Screenhouse and Intake Canal. The scope will also require inspections of the Approach Canal, Intake Canal, Emergency Cooling Water Intake, and Screenhouse

immediately following extreme environmental conditions or natural phenomena includi ng an earthquake, flood, tornado, severe thunderstorm, or high winds. The program parameters to be inspected will include an inspection of water-control concrete components that are below the water line for cavitation and erosion degradation. The program will visually inspect for damage such as cracking, settlement, mo vement, broken bolted and welded connections, bu ckling, and other degraded conditions following extreme environmental conditions or natural phenomena.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.35 29 A Selective Leaching of Material s Program will be completed.

Program features will be as described in LRA B2.1.36.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.36 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 10 Commitment Number Commitment Implementation Schedule Related LRA Section Number 30 The Structures Monitoring Program will be enhanced as follows: The following structures, components, and component supports will be added to the scope of the inspections:

o Approach Canal o Fuel Oil Transfer House o Old Administration Building and Administration Building Addition o Component supports for cable tray, conduit, cable, tubing tray, tubing, non-ASME vessels, exchangers, pumps, valves, piping, mirror

insulation, non-ASME valv es, cabinets, panels, racks, equipment enclosures, junction boxes, bus

ducts, breakers, transformers, instruments, diesel equipment, housings for HVAC fans, louvers, and

dampers, HVAC ducts, vibration isolation elements for diesel equipment, and miscellaneous

electrical and mechanical equipment items o Miscellaneous electrical equipment and instrumentation enclosures including cable tray, conduit, wireway, tube tray, cabinets, panels, racks, equipment enclosures, junction boxes, breaker housings, transformer housings, lighting

fixtures, and metal bus enclosure assemblies o Miscellaneous mechanical equipment enclosures including housings for H VAC fans, louvers, and dampers o SBO Yard Structures and components including U1 - 8/9/2013 U2 - 10/29/2014 B2.1.38 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 11 Commitment Number Commitment Implementation Schedule Related LRA Section Number SBO cable vault and bus duct enclosures.

o Fire Protection System hydrant houses o Caulking, sealant and elastomer materials o Non-safety related masonry walls that support equipment relied upon to perform a function that demonstrates compliance with a regulated

event(s). The program will be enhanced to include additional inspection parameters. The program will require an inspection frequency of once every five (5) years for structures and structural components within the scope of the program. The

frequency of inspections can be adjusted, if necessary, to

allow for early detection and timely correction of negative trends. The program will require periodic sampling of groundwater and river water c hemistries to ensure they remain non-aggressive.

31 A Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program will be impl emented. Program features will be as described in LRA Section B2.1.39.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.39 32 The Water Chemistry Program will be enhanced as follows: The program will require increased sampling to be performed as needed to confi rm the effectiveness of corrective actions taken to address an abnormal chemistry condition.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.40 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 12 Commitment Number Commitment Implementation Schedule Related LRA Section Number The program will require R eactor Coolant System dissolved oxygen Action Level limits to be consistent with the limits established in the EPRI PWR Primary Water Chemistry Guidelines." [Revised in letter dated 12/5/2008 in response to RAI B2.1.40-3]

33 The Metal Fatigue of Reactor Coolant Pressure Boundary Program will be enhanced as follows:

The program will monitor t he six component locations identified in NUREG/CR-6260 for older vintage Westinghouse plants, either by tracking the cumulative number of imposed stress cycles using cycle counting, or

by tracking the cumulative fatigue usage, including the

effects of coolant environmen

t. The following locations will be monitored:

o Reactor Vessel Inlet and Outlet Nozzles o Reactor Pressure Vessel Shell to Lower Head o RCS Hot Leg Surge Line Nozzle o RCS Cold Leg Charging Nozzle o RCS Cold Leg Safety Injection Accumulator Nozzle o RHR-to-Accumulator Piping Tee Program acceptance criteria will be clarified to require corrective action to be taken before a cumulative fatigue usage factor exceeds 1.0 or a design basis transient

cycle limit is exceeded. [Revised in letter dated 1/9/2009 in response to RAI 4.3.1.1-1]

U1 - 8/9/2013 U2 - 10/29/2014 B3.2 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 13 Commitment Number Commitment Implementation Schedule Related LRA Section Number 34 Reactor internals baffle bolt fatigue transient limits of 1835 cycles of plant loading at 5%

per minute and 1835 cycles of plant unloading at 5% per minut e will be incorpor ated into the Metal Fatigue of Reactor Coolant Pressure Boundary Program and USAR Table 4.1-8.

U1 - 8/9/2013 U2 - 10/29/2014 B3.2 35 NSPM will perform an ASME Sect ion III fatigue evaluation of the lower head of the pressurize r to account for effects of insurge/outsurge transients.

The evaluation will determine the cumulative fatigue usage of limiting pressurizer component(s)

through the period of extended operation. The analyses will account for periods of both "Water Solid" and "Standard Steam Bubble" operating strat egies. Analysis results will be incorporated, as applicable, into the Metal Fatigue of Reactor

Coolant Pressure Boundary Program. [Revised in letter dated 1/9/2009 in response to RAI 4.3.1.1-1]

U1 - 8/9/2013 U2 - 10/29/2014 4.3.1.3 36 NSPM will complete fatigue calc ulations for the pressurizer surge line hot leg nozzle and the charging nozzle using the methodology of the ASME Code (Subsection NB) and will

report the revised CUFs and CUFs adjusted for environmental effects at these locations as an amendment to the PINGP LRA. Conforming changes to LR A Section 4.3.3, "PINGP EAF Results," will also be included in that amendment to reflect analysis results and remove references to stress-based

fatigue monitoring.

[Added in letter dated 1/9/2009 in response to RAI 4.3.1.1-1] April 30, 2009 4.3.3 37 NSPM will revise procedures for excavation and trenching controls and archaeological, cult ural and historic resource protection to identify sensitiv e areas and provide guidance for 8/9/2013 ER 4.16.1 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 14 Commitment Number Commitment Implementation Schedule Related LRA Section Number ground-disturbing activities. The procedures will be revised to

include drawings and illustrations to assist users in identifying culturally sensitive areas, and pi ctures of artifacts that are prevalent in the area of the Plant site. The revised procedures will also require training of the Site Environmental Coordinator and other personnel responsible for proper execution of excavation or other ground-disturbing activities.

[Added in ER revision submi tted in letter dated 3/4/2009]

38 NSPM will conduct a Phase I Reconnaissance Field Survey of the disturbed areas within the Pl ant's boundaries. In addition, NSPM will conduct Phase I field surveys of areas of known archaeological sites to precisely determine their boundaries.

NSPM will use the results of these surveys to designate areas for archaeological protection.

[Added in ER revision submi tted in letter dated 3/4/2009] 8/9/2013 ER 4.16.2 39 NSPM will prepare, maintain and implement a Cultural Resources Management Plan (CRMP) to protect significant historical, archaeological, and cultural resources that may currently exist on the Plant site. In connection with the preparation of the CRMP, NSPM will conduct botanical surveys to identify culturally and medicinally important spec ies on the Plant site, and incorporate provisions to protect such plants into the

CRMP. [Added in ER revision submi tted in letter dated 3/4/2009] 8/9/2013 ER 4.16.2 40 NSPM will consult with a qualif ied archaeologist prior to conducting any ground-disturbing activity in any area 8/9/2013 ER 4.16.2 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 15 Commitment Number Commitment Implementation Schedule Related LRA Section Number designated as undisturbed and in any disturbed area that is

described as potentially containi ng archaeological resources (as determined by the Phase I Reconnaissance Field Survey

discussed in Commitment Number 38).

[Added in ER revision submi tted in letter dated 3/4/2009]

41 During the first refueling outage following refueling cavity leak repairs in each Unit (scheduled for refueling outages 1R26 and 2R26), concrete will be removed from the sump C pit to expose an area of the containment vessel bottom head. Visual

examination and ultrasonic thickness measurement will be performed on the portions of the containment vessels exposed by the excavations. An assessment of the condition of exposed concrete and rebar will also be performed. Degradation observed in the exposed containm ent vessel, concrete or rebar will be entered into the Co rrective Action Program and evaluated for impact on structural integrity and identification of additional actions that may be warranted.

[Added in letter dated 4/6/09 in response to Follow Up RAI

B2.1.38] U1 - 8/9/2013 U2 - 10/29/2014 B2.1.38 42 During the two consecutive refueling outages following refueling cavity leak repairs in each Unit (scheduled for refueling outages

1R26 and 2R26), visual inspecti ons will be performed of the areas where reactor cavity leakage had been observed previously to confirm that leakage has been resolved. The inspection results will be documented. If refueling cavity leakage is again identified, the issue will be entered into the Corrective Action Program and evaluated for identification of additional actions to mitigate leakage and monitor the condition of the containment vessel and internal structures.

U1 - 8/9/2013 U2 - 10/29/2014 B2.1.38 Prairie Island Nuclear Generating Plant License Renewal Commitments Updated through 4/13/2009 16 Commitment Number Commitment Implementation Schedule Related LRA Section Number

[Added in letter dated 4/6/09 in response to Follow Up RAI

B2.1.38] 43 Preventive maintenance requirements will be implemented to require periodic replacement of rubber flexible hoses in the Diesel Generators and Support System that are exposed to fuel oil or lubricating oil internal environments.

[Added in letter dated 4/6/09 in response to RAI 3.3.2-8-1]

U1 - 8/9/2013 U2 - 10/29/2014 Table 3.3.2-8