L-PI-11-069, Day Response to NRC Bulletin 2011-01, Mitigating Strategies.: Difference between revisions

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| issue date = 07/11/2011
| issue date = 07/11/2011
| title = Day Response to NRC Bulletin 2011-01, Mitigating Strategies.
| title = Day Response to NRC Bulletin 2011-01, Mitigating Strategies.
| author name = Schimmel M A
| author name = Schimmel M
| author affiliation = Northern States Power Co, Xcel Energy
| author affiliation = Northern States Power Co, Xcel Energy
| addressee name =  
| addressee name =  
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{{#Wiki_filter:July 11, 201 1 L-PI-11-069 10 CFR 50.54(f) U S Nuclear Regulatory Commission ATTN: Document Control Desk 1 1555 Rockville Pike Rockville, MD 20852 Prairie Island Nuclear Generating Plant, Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 60-Dav Response to NRC Bulletin 201 1-01, "Mitigating Strategies"  
{{#Wiki_filter:July 11, 201 1                                                             L-PI-11-069 10 CFR 50.54(f)
U S Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Prairie Island Nuclear Generating Plant, Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 60-Dav Response to NRC Bulletin 201 1-01, "Mitigating Strategies"


==Reference:==
==Reference:==
NRC Bulletin 201 1-01, "Mitigating Strategies," dated May 11, 201 1 (MLI 11250360).
On May 1I , 201 1, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 201 1-01, "Mitigating Strategies" (Reference). The NRC issued this Bulletin to achieve the following objectives:
1.. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2),
: 2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima-Daiichi facility in order to determine if
      . I ) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and
: 3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).
The Bulletin requested each licensee to submit a written response within 30 days of the date of the Bulletin. This 30-day response letter was provided by Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), on June 9,201 1.
1717 Wakonade Drive East  Welch, Minnesota 55089-9642 Telephone: 651.388.1121


NRC Bulletin 201 1-01, "Mitigating Strategies," dated May 11, 201 1 (MLI 11 250360).
Document Control Desk Page 2 The Bulletin also requested that within 60 days of the date of the Bulletin that NSPM provide the following information on their mitigating strategies:
On May 1 I, 201 1, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 201 1-01, "Mitigating Strategies" (Reference). The NRC issued this Bulletin to achieve the following objectives:
      ' How essential resources are maintained, tested and controlled to ensure availability; How strategies are re-evaluated if plant conditions or configurations change; and How arrangements are reached and maintained with local emergency response organizations.
1 .. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.54(hh)(2), 2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima-Daiichi facility in order to determine if . I) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and 3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).
The enclosure to this letter contains the 60-day response to the requested information pursuant to the provisions of 10 CFR 50.54(f) for the Prairie Island Nuclear Generating Plant (PINGP).
The Bulletin requested each licensee to submit a written response within 30 days of the date of the Bulletin. This 30-day response letter was provided by Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), on June 9,201 1. 171 7 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone:
Summaw of Commitments This letter contains one new commitment and no changes to existing commitments. In response to Question 4 in the Enclosure, NSPM makes the following commitment:
651.388.1 121 Document Control Desk Page 2 The Bulletin also requested that within 60 days of the date of the Bulletin that NSPM provide the following information on their mitigating strategies:  
NSPM will include a requirement for continuing training on Extensive Damage Mitigation Guidelines (EDMG) in the PINGP training program for the Emergency Response Organization (ERO) qualified decision makers by January 13,2012.
' How essential resources are maintained, tested and controlled to ensure availability; How strategies are re-evaluated if plant conditions or configurations change; and How arrangements are reached and maintained with local emergency response organizations. The enclosure to this letter contains the 60-day response to the requested information pursuant to the provisions of 10 CFR 50.54(f) for the Prairie Island Nuclear Generating Plant (PINGP).
I declare under penalty of perjury that the foregoing is true and correct. Executed on July 11, 201 1.
Summaw of Commitments This letter contains one new commitment and no changes to existing commitments.
L Mark A. Schimmel Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc:     Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC
In response to Question 4 in the Enclosure, NSPM makes the following commitment: NSPM will include a requirement for continuing training on Extensive Damage Mitigation Guidelines (EDMG) in the PINGP training program for the Emergency Response Organization (ERO) qualified decision makers by January 13,2012. I declare under penalty of perjury that the foregoing is true and correct. Executed on July 11, 201
 
: 1. Mark A. Schimmel L Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC Prairie Island Nuclear Generating Plant Enclosure I 60-Day Response for NRC Bulletin 201 1-01 On May 11, 201 1, the NRC issued Bulletin 201 1-01, "Mitigating Strategies." The Bulletin requested that within 60 days of the date of this Bulletin, licensees provide information on their mitigating strategies programs. The NRC questions related to the 60-day response are restated below followed by the Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), response for the Prairie Island Nuclear Generating Plant'(PINGP). The items described below represent current plant practices, Individual items may be revised or adjusted in the future based on new or revised vendor recommendations, industry experience, etc., in accordance with established processes. Any changes involving commitments will be executed in accordance with NEI 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes." Page 1 of 13 Prairie Island Nuclear Generating Plant Request: 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.
Prairie Island Nuclear Generating Plant Enclosure I 60-Day Response for NRC Bulletin 201 1-01 On May 11, 201 1, the NRC issued Bulletin 201 1-01, "Mitigating Strategies." The Bulletin requested that within 60 days of the date of this Bulletin, licensees provide information on their mitigating strategies programs. The NRC questions related to the 60-day response are restated below followed by the Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), response for the Prairie Island Nuclear Generating Plant'(PINGP).
Examples of the types of information to include when providing your response to Question (1) are: a. Measures implemented to maintain the equipment, including periodicity.
The items described below represent current plant practices, Individual items may be revised or adjusted in the future based on new or revised vendor recommendations, industry experience, etc., in accordance with established processes. Any changes involving commitments will be executed in accordance with NEI 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes."
: b. Basis for establishing each maintenance item (e.g., manufacturer's recommendation, code or standard applicable to the craft). This should include consideration of storage environment impact on the maintenance necessary. These examples are not meant to limit your response if you use other methods to address the issues described above.
Page 1 of 13
 
Prairie Island Nuclear Generating Plant Request:
: 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.
Examples of the types of information to include when providing your response to Question (1) are:
: a. Measures implemented to maintain the equipment, including periodicity.
: b. Basis for establishing each maintenance item (e.g., manufacturer's recommendation, code or standard applicable to the craft). This should include consideration of storage environment impact on the maintenance necessary.
These examples are not meant to limit your response if you use other methods to address the issues described above.
NSPM Response:
NSPM Response:
The maintenance activities listed below in Table I have been established to ensure that the equipment procured to support the B.5.b mitigation strategies is functional when needed.
The maintenance activities listed below in Table Ihave been established to ensure that the equipment procured to support the B.5.b mitigation strategies is functional when needed.
Table 1 - Preventative Maintenance Page 2 of 13 Equipment 125 VDC Battery Cart Portable Diesel Fire Pump Preventive Maintenance Replace batteries.
Table 1 Preventative Maintenance Equipment             Preventive Maintenance          periodicity*        Basis 125 VDC             Replace batteries.                30 months    Vendor Battery Cart                                                         Specifications.
Change engine oil and filter. Replace fuel filter. Check battery condition.
Portable Diesel Change engine oil and filter.         Annually      Based on plant Fire Pump                                                            experience.
Inspect and clean (if necessary) radiator coils.
Replace fuel filter.               Annually      Based on plant experience.
Inspect all hoses and belts for wear and tension. Replaceladjust as necessary. Inspect engine air cleaner for excessive dirt. Replace filter as required. Check gauges and hour meter for damage.
Check battery condition.            Annually      Based on plant experience.
Repairlreplace as necessary.
Inspect and clean (if necessary)   Annually      Based on plant radiator coils.                                  experience.
periodicity*
Inspect all hoses and belts for   Annually      Based on plant wear and tension.                                 experience.
30 months Annually Annually Annually Annually Annually Annually Annually Basis Vendor Specifications.
Replaceladjust as necessary.
Based on plant experience.
Inspect engine air cleaner for     Annually      Based on plant excessive dirt. Replace filter as                 experience.
Based on plant experience.
required.
Based on plant experience.
Check gauges and hour meter         Annually      Based on plant for damage. Repairlreplace as                     experience.
Based on plant experience.
necessary.
Based on plant experience.
Page 2 of 13


Based on plant experience.
Prairie Island Nuclear Generating Plant 1   Equipment     I     Preventive Maintenance       I periodicity' I       Basis   I Verify lug nuts tight on wheels. Annually       Based on plant experience.
Based on plant experience.
Verify proper air pressure in       Annually        Based on plant tires. Adjust as necessary.                         experience.
Prairie Island Nuclear Generating Plant 1 Equipment I Preventive Maintenance I periodicity' I Basis I Verify lug nuts tight on wheels. Annually Based on plant experience. Verify proper air pressure in tires. Adjust as necessary.
Verify jack stands operational     Annually        Based on plant and in good condition. Lubricate                   experience.
Based on plant experience.
with grease.
Annually Verify jack stands operational and in good condition. Lubricate with grease.
Remove compressor guards and Annually              Based on plant inspect the compressor belt, oil                   experience.
Remove compressor guards and inspect the compressor belt, oil lines and air lines, checking for wear. Replace as necessary.
lines and air lines, checking for wear. Replace as necessary.
Annually Based on plant experience.
Change the mechanical seal oil. Annually       Based on plant experience.
Annually Based on plant experience. Change the mechanical seal oil.
Replace display panel battery.     8 years        Based on plant experience.
Page 3 of 13 Replace display panel battery.
  *Note: The Preventative Maintenance program is condition based and frequencies are adjusted based on conditions found during maintenance and equipment performance.
Annually Based on plant experience.  
The periodicity shown is the present frequency.
*Note: The Preventative Maintenance program is condition based and frequencies are adjusted based on conditions found during maintenance and equipment performance. The periodicity shown is the present frequency.
Page 3 of 13
8 years Based on plant experience.
 
Prairie Island Nuclear Generating Plant Request: 2. Describe in detail the testing of equipment procured to support the strategies arid guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed. Examples of the types of information to include when providing your response to Question (2) are: a. A description of any testing accomplished to ensure the strategies were initially feasible.
Prairie Island Nuclear Generating Plant Request:
: 2. Describe in detail the testing of equipment procured to support the strategies arid guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed.
Examples of the types of information to include when providing your response to Question (2) are:
: a. A description of any testing accomplished to ensure the strategies were initially feasible.
: b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement
: b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement
: c. A description of the corrective action process used when the equipment fails to adequately perform its test.
: c. A description of the corrective action process used when the equipment fails to adequately perform its test.
These examples are not meant to limit your response if you use other methods to address the issues described above.
These examples are not meant to limit your response if you use other methods to address the issues described above.
NSPM Response:
NSPM Response:
During the initial development of the B.5.b mitigating strategies, NSPM validated strategies by performing engineering evaluations, time validations and/or tabletop reviews.
During the initial development of the B.5.b mitigating strategies, NSPM validated strategies by performing engineering evaluations, time validations and/or tabletop reviews. The following Table 2.a describes the testing and evaluations accomplished to verify the initial feasibility of the mitigating strategies.
The following Table 2.a describes the testing and evaluations accomplished to verify the initial feasibility of the mitigating strategies.
Table 2.a - Mitigating Strategies Validation Strategy                                         Description External Spent Fuel Pool         Time validation performed to demonstrate water could Makeup                  be delivered within 2 hours. Portable diesel fire pump and I 0 0 foot aerial fire truck tested. A plant walkdown and an engineering evaluation completed to analyze the B.5.b flow path scenarios.
Table 2.a - Mitigating Strategies Validation Page 4 of 13 Strategy External Spent Fuel Pool Makeup Internal Spent Fuel Pool Makeup Spent Fuel Pool Spray Steam Generator Injection Containment Flooding Description Time validation performed to demonstrate water could be delivered within 2 hours. Portable diesel fire pump and I00 foot aerial fire truck tested.
Internal Spent Fuel Pool        A plant walkdown and an engineering evaluation Makeup                  completed to analyze the B.5.b flow path scenarios.
A plant walkdown and an engineering evaluation completed to analyze the B.5.b flow path scenarios.
Spent Fuel Pool Spray          Engineering evaluation completed to analyze the B.5.b flow path scenarios.
A plant walkdown and an engineering evaluation completed to analyze the B.5.b flow path scenarios.
Steam Generator Injection        Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.
Engineering evaluation completed to analyze the B.5.b flow path scenarios.
Containment Flooding            Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.
Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.
Page 4 of 13
Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.
 
Prairie Island Nuclear Generating Plant The following Table 2.b describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.
Prairie Island Nuclear Generating Plant Strategy                                     Description Refueling Water Storage Tank         Engineering evaluation completed to analyze the Makeup                  B.5.b flow path scenarios.
Strategy Refueling Water Storage Tank Makeup Condensate Storage Tank Makeup Remote Battery Operation of the PORV Table 2.b - Surveillances Description Engineering evaluation completed to analyze the B.5.b flow path scenarios. Engineering evaluation completed to analyze the B.5.b flow path scenarios. Engineering evaluation completed to ensure battery capable of supplying power to the solenoids.
Condensate Storage Tank          Engineering evaluation completed to analyze the Makeup                  B.5.b flow path scenarios.
Equipment Portable Diesel Fire Pump Pagers Cell Phone Radios Surveillances General unit inspection is performed prior to performing the test. The oil, coolant, fuel, and mechanical seal level is checked. The trailer is attached to the truck and transported to test location. Pump is run for 5-1 0 minutes at 1500-2000 rpm and then reduced to 900 rpm for an additional 3 minutes. The engine operating data (coolant temperature, oil pressure, etc.)
Remote Battery Operation of        Engineering evaluation completed to ensure battery the PORV                  capable of supplying power to the solenoids.
is recorded. Perform general visual inspection of diesel and pump (i.e., engine hoses, clamps, connections, etc.)
The following Table 2.b describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.
Similar to quarterly surveillance, plus hoses are attached to the suction and discharge of the pump and run for 30 minutes. The pump is also run at elevated rpm to obtain flow vs, pressure data.
Table 2.b - Surveillances Equipment                     Surveillances                  Periodicity      Basis Portable       General unit inspection is performed prior     Quarterly    Vendor Diesel Fire    to performing the test. The oil, coolant,                   Recommended.
Tested weekly to verify that pagers used for Emergency Response are functional. Ensure the functionality of the Emergency Operations Facility cellular telephone.
Pump          fuel, and mechanical seal level is checked.
Check the functionality of the radios every quarter. Periodicity Quarterly Quarterly Quarterly Annual Weekly Every other month Quarterly Basis Vendor Recommended.
The trailer is attached to the truck and       Quarterly    Vendor transported to test location. Pump is run                   Recommended.
Vendor Recommended.
for 5-10 minutes at 1500-2000 rpm and then reduced to 900 rpm for an additional 3 minutes. The engine operating data (coolant temperature, oil pressure, etc.) is recorded.
Vendor Recommended.
Perform general visual inspection of           Quarterly    Vendor diesel and pump (i.e., engine hoses,                         Recommended.
Vendor Recommended.
clamps, connections, etc.)
Based on plant experience.
Similar to quarterly surveillance, plus       Annual        Vendor hoses are attached to the suction and                       Recommended.
Based on plant experience.
discharge of the pump and run for 30 minutes. The pump is also run at elevated rpm to obtain flow vs, pressure data.
Based on plant experience.
Pagers        Tested weekly to verify that pagers used       Weekly        Based on plant for Emergency Response are functional.                       experience.
Prairie Island Nuclear Generating Plant In regards to question 2.c1 The 10 CFR 50 Appendix B Corrective Action Program (CAP) is used to document failures, establish priorities for corrective actions and perform trending. When an issue is identified, a CAP Action Request (AR) is initiated, a management review team determines level of review required, and corrective actions are determined and implemented in accordance with the significance.  
Cell Phone    Ensure the functionality of the Emergency Every other        Based on plant Operations Facility cellular telephone.        month        experience.
~~uibent Fire Hoses and Adapters Page 6 of 13 Surveillances Fire hoses are hydrostatically tested every two years, except the hose on the turbine building roof which is tested annually. Inspect fire hoses and gaskets. Periodicity Biennially Biennially Basis 10 CFR 50 Appendix R and plant experience.
Radios        Check the functionality of the radios every   Quarterly    Based on plant quarter.                                                     experience.
Based on plant experience.
 
Prairie Island Nuclear Generating Plant Request: 3. Describe in detail the controls for assuring that the equipment is available when needed. Examples of the types of information to include when providing your response to Question (3) are: a. A description of any inventory requirements established for the equipment.
Prairie Island Nuclear Generating Plant
~ ~ u i b e n t                Surveillances                  Periodicity      Basis Fire Hoses      Fire hoses are hydrostatically tested        Biennially  10 CFR 50 and            every two years, except the hose on the                  Appendix R and Adapters        turbine building roof which is tested                    plant annually.                                                experience.
Inspect fire hoses and gaskets.             Biennially  Based on plant experience.
In regards to question 2.c1The 10 CFR 50 Appendix B Corrective Action Program (CAP) is used to document failures, establish priorities for corrective actions and perform trending. When an issue is identified, a CAP Action Request (AR) is initiated, a management review team determines level of review required, and corrective actions are determined and implemented in accordance with the significance.
Page 6 of 13
 
Prairie Island Nuclear Generating Plant Request:
: 3. Describe in detail the controls for assuring that the equipment is available when needed.
Examples of the types of information to include when providing your response to Question (3) are:
: a. A description of any inventory requirements established for the equipment.
: b. A listing of deficiencies noted in inventories for the equipment and corrective actions taken to prevent loss.
: b. A listing of deficiencies noted in inventories for the equipment and corrective actions taken to prevent loss.
These examples are not meant to limit your response if you use other methods to address the issues described above.
These examples are not meant to limit your response if you use other methods to address the issues described above.
NSPM Response:
NSPM Response:
In.addition to the controls described in responses 1 and 2, procured non - permanently installed B.5.b equipment is inventoried quarterly in accordance with plant processes or procedures. This inventory assures the items are stored in the proper quantities and location.
In.addition to the controls described in responses 1 and 2, procured non -
Access to equipment storage locations is controlled by postings on lockers and trailers where they are stored, citing the equipment is designated for use only for B.5.b scenarios. lnventory deficiencies are entered into the CAP.
permanently installed B.5.b equipment is inventoried quarterly in accordance with plant processes or procedures. This inventory assures the items are stored in the proper quantities and location. Access to equipment storage locations is controlled by postings on lockers and trailers where they are stored, citing the equipment is designated for use only for B.5.b scenarios.
As of the date of this response, there are no outstanding inventory deficiencies that would render the strategies not viable.
lnventory deficiencies are entered into the CAP. As of the date of this response, there are no outstanding inventory deficiencies that would render the strategies not viable.
Table 3 - Inventories Page 7 of 13 Actions Performed Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Special Storage Controls Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Equipment Carts, trucks and trailers for staging equipment Portable Diesel Fire Pump and battery charger Set(s) of wheel chocks Floating suction strainer and suction hose steak Generator fill connector Reverse Osmosis connector for Refueling Water Storage Tank fill Inventory Frequency Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Prairie Island Nuclear Generating Plant Page 8 of 13 Equipment Fire Hose (6, 5, 4, 2 % and 1-112 - inch) nozzles, valves, adapters, splitters, monitors, manifolds, strainer, connectors, wrenches, etc. DllD2 connector (replaces spool pieces) Deepwell supply connector for Dl ID2 cooling 5-inch discharge flow indicator 125 VDC Battery Cart Turnout gear ( coats, pants, helmets, gloves, boots)
Table 3 Inventories Equipment                  Inventory    Special    Actions Performed Frequency      Storage Controls Carts, trucks and trailers for         Quarterly  Indoors,      Verify proper staging equipment                                 Heated        quantities Portable Diesel Fire Pump and         Quarterly    Indoors,    Verify proper battery charger                                   Heated        quantities Set(s) of wheel chocks                 Quarterly  Indoors,      Verify proper Heated        quantities Floating suction strainer and         Quarterly  Indoors,      Verify proper suction hose                                       Heated        quantities steak Generator fill connector         Quarterly  Indoors,      Verify proper Heated        quantities Reverse Osmosis connector for         Quarterly    Indoors,    Verify proper Refueling Water Storage Tank fill                 Heated        quantities Page 7 of 13
Self-contained Breathing Apparatuslmasksltanks Radios and chargers Portable lights (flashlights, quartz lights, halogen lights, etc.)
 
Dosimetry Tools (extension cords, hand tools, specialty tools, etc)
Prairie Island Nuclear Generating Plant Equipment                   Inventory    Special    Actions Performed Frequency      Storage Controls Fire Hose (6, 5, 4, 2 % and 1-112 -     Quarterly    Indoors,    Verify proper inch) nozzles, valves, adapters,                     Heated      quantities splitters, monitors, manifolds, strainer, connectors, wrenches, etc.
Rescue equipmentlmedical supplies Fuel oil for Portable Diesel Fire Pump Special Storage Controls Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Inventory Frequency Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Actions Performed Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Prairie Island Nuclear Generating Plant Request: 4. Describe in detail how configuration and guidance management is assured so that strategies remain feasible.
DllD2 connector (replaces spool         Quarterly    Indoors,    Verify proper pieces)                                             Heated      quantities Deepwell supply connector for           Quarterly    Indoors,    Verify proper D l ID2 cooling                                     Heated      quantities 5-inch discharge flow indicator         Quarterly    Indoors,    Verify proper Heated      quantities 125 VDC Battery Cart                   Quarterly    Indoors,    Verify proper Heated      quantities Turnout gear ( coats, pants,           Quarterly    Indoors,    Verify proper helmets, gloves, boots)                             Heated      quantities Self-contained Breathing               Quarterly    Indoors,    Verify proper Apparatuslmasksltanks                               Heated      quantities Radios and chargers                     Quarterly    Indoors,    Verify proper Heated      quantities Portable lights (flashlights, quartz   Quarterly    Indoors,    Verify proper lights, halogen lights, etc.)                       Heated      quantities Dosimetry                               Quarterly    Indoors,    Verify proper Heated      quantities Tools (extension cords, hand tools, Quarterly        Indoors,    Verify proper specialty tools, etc)                               Heated        quantities Rescue equipmentlmedical               Quarterly  Indoors,      Verify proper supplies                                           Heated        quantities Fuel oil for Portable Diesel Fire       Quarterly  Indoors,     Verify proper Pump                                                Heated        quantities Page 8 of 13
Examples of the types of information to include when providing your response to Question (4) are: . a. Measures taken to evaluate any plant configuration changes for their effect on feasibility of the mitigating strategies.
 
Prairie Island Nuclear Generating Plant Request:
: 4. Describe in detail how configuration and guidance management is assured so that strategies remain feasible.
Examples of the types of information to include when providing your response to Question (4) are:
    . a. Measures taken to evaluate any plant configuration changes for their effect on feasibility of the mitigating strategies.
: b. Measures taken to validate that the procedures or guidelines developed to support the strategies can be executed. These measures could include drills, exercises, or walk through of the procedures by personnel that would be expected to accomplish the strategies.
: b. Measures taken to validate that the procedures or guidelines developed to support the strategies can be executed. These measures could include drills, exercises, or walk through of the procedures by personnel that would be expected to accomplish the strategies.
: c. Measures taken to ensure procedures remain up-to-date and consistent with the current configuration of the plant. d. A description of the training program implemented in support of the mitigating strategies and the manner in which you evaluate its effectiveness. These examples are not meant to limit your response if you use other methods to address the issues described above. NSPM Response: Plant configuration changes are procedurally evaluated against the licensing basis, including the license conditions and their associated safety evaluation. Initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews. Subsequent procedure changes are validated to ensure that the guideline remains viable. In 201 1, B.5.b mitigating strategies were revalidated by similar techniques. The training discussed below also validates that the associated mitigating strategies can be deployed. The design change process requires a review of affected procedures and any necessary changes to be made. The mitigating strategy guidelines are controlled consistent with procedural controls under established administrative processes.
: c. Measures taken to ensure procedures remain up-to-date and consistent with the current configuration of the plant.
: d. A description of the training program implemented in support of the mitigating strategies and the manner in which you evaluate its effectiveness.
These examples are not meant to limit your response if you use other methods to address the issues described above.
NSPM Response:
Plant configuration changes are procedurally evaluated against the licensing basis, including the license conditions and their associated safety evaluation.
Initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews. Subsequent procedure changes are validated to ensure that the guideline remains viable. In 201 1, B.5.b mitigating strategies were revalidated by similar techniques. The training discussed below also validates that the associated mitigating strategies can be deployed.
The design change process requires a review of affected procedures and any necessary changes to be made.
The mitigating strategy guidelines are controlled consistent with procedural controls under established administrative processes.
The following table describes the training program implemented in support of the mitigating strategies and the manner in which effectiveness is evaluated.
The following table describes the training program implemented in support of the mitigating strategies and the manner in which effectiveness is evaluated.
Page 9 of 13 Prairie Island Nuclear Generating Plant Table 4 - Training Page 10 of 13 Plant Personnel Non-Licensed Operators Licensed Operators Fire Brigade Emergency Reponse Organzation - Key Decision Makers Security Training Training on the Non-Licensed Operator role in implementing Extensive Damage Mitigation Guidelines (EDMG) is part of the Initial Non-Licensed Operator Training programs and retrained per the NLO continuing training plan. Licensed Operators are initially trained on EDMGs per the Initial Licensed Operator training program. Licensed Operators are retrained per the biennial training plan as described in the Licensed Operator Requalification Training Program Description. Fire Brigade members are Non-Licensed Operators and are initially trained in EDMGs. Refresher training on B.5.b events is offered every 3 years. The Emergency Response Organization (ERO) qualified decision makers receive initial training on EDMGs. However, NSPM currently has no procedural requirements to provide continuing training. NSPM recognizes the need for ongoing training for its qualified decision makers. Therefore, NSPM makes the following commitment for the PINGP:
Page 9 of 13
NSPM will include a requirement for continuing training on EDMGs in the PINGP training program for the ERO qualified decision makers by January 13, 2012. Training on mitigating strategies was done as part of the implementation of B.5.b. Security EDMG actions are incorporated into Security Implementing Procedures, Contingency Plan Implementing Procedure and site procedures that are trained in initial training and are re-qualified per the Security Training Program Description.
 
Periodicity 3 years 2 years 3 Years None 2 Years Evaluation Testing I Qualification Testing and DrillsIExercises Testing Qualification Testing Prairie Island Nuclear Generating Plant Request: 5. Describe in detail how you assure availability of off-site support. Examples of the types of information to include when providing your response to Question (5) are: a. A listing of off-site organizations you rely on for emergency response.
Prairie Island Nuclear Generating Plant Table 4 - Training Plant         Training                                      Periodicity Evaluation Personnel Non-Licensed Training on the Non-Licensed Operator           3 years    Testing I Operators      role in implementing Extensive Damage                     Qualification Mitigation Guidelines (EDMG) is part of the Initial Non-Licensed Operator Training programs and retrained per the NLO continuing training plan.
Licensed      Licensed Operators are initially trained       2 years    Testing and Operators      on EDMGs per the Initial Licensed                         DrillsIExercises Operator training program. Licensed Operators are retrained per the biennial training plan as described in the Licensed Operator Requalification Training Program Description.
Fire Brigade  Fire Brigade members are Non-Licensed         3 Years    Testing Operators and are initially trained in EDMGs. Refresher training on B.5.b events is offered every 3 years.
Emergency    The Emergency Response Organization             None        Qualification Reponse        (ERO) qualified decision makers receive Organzation -  initial training on EDMGs. However, Key Decision  NSPM currently has no procedural Makers        requirements to provide continuing training. NSPM recognizes the need for ongoing training for its qualified decision makers. Therefore, NSPM makes the following commitment for the PINGP:
NSPM will include a requirement for continuing training on EDMGs in the PINGP training program for the ERO qualified decision makers by January 13, 2012.
Security      Training on mitigating strategies was         2 Years      Testing done as part of the implementation of B.5.b. Security EDMG actions are incorporated into Security Implementing Procedures, Contingency Plan Implementing Procedure and site procedures that are trained in initial training and are re-qualified per the Security Training Program Description.
Page 10 of 13
 
Prairie Island Nuclear Generating Plant Request:
: 5. Describe in detail how you assure availability of off-site support.
Examples of the types of information to include when providing your response to Question (5) are:
: a. A listing of off-site organizations you rely on for emergency response.
: b. Measures taken to ensure the continuity of memoranda of agreement or understanding or other applicable contractual arrangements. This should include a listing of periods of lapsed contractual arrangements.
: b. Measures taken to ensure the continuity of memoranda of agreement or understanding or other applicable contractual arrangements. This should include a listing of periods of lapsed contractual arrangements.
: c. A listing of any training or site familiarization provided to off-site responders.
: c. A listing of any training or site familiarization provided to off-site responders. This should include any measures taken to ensure continued familiarity of personnel of the off-site responders in light of turnover and the passage of time.
This should include any measures taken to ensure continued familiarity of personnel of the off-site responders in light of turnover and the passage of time. These examples are not meant to limit your response if you use other methods to address the issues described above. NSPM Response:
These examples are not meant to limit your response if you use other methods to address the issues described above.
NSPM Response:
The following off-site organizations in Table 5 are relied on for emergency response.
The following off-site organizations in Table 5 are relied on for emergency response.
Table 5 - Offsite Organizations Page 1 1. of 13 Off-site Organization State of Minnesota State of Wisconsin City of Red Wing (includes Red Wing Fire Department)
Table 5 - Offsite Organizations Off-site Organization     Implementing Date of             Training1 Periodicity Document         Agreement State of Minnesota        Letter of         1211712008  Annual training provided by Agreement                      the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Dakota County Implementing Document Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Date of Agreement 1211 712008 101612010 21241201 1 41281201 1 Training1 Periodicity Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan. Annual training provided by the State of Wisconsin as stated in Wisconsin Emergency Operations Plan. Annual training for the Red Wing Fire Department is provided by the site and the State of Minnesota. Annual training is provided to the City of Red Wing via the Minnesota Emergency Operations Plan.
State of Wisconsin        Letter of        101612010    Annual training provided by Agreement                      the State of Wisconsin as stated in Wisconsin Emergency Operations Plan.
Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan.
City of Red Wing          Letter of        21241201 1    Annual training for the Red (includes Red Wing        Agreement                      Wing Fire Department is Fire Department)                                          provided by the site and the State of Minnesota. Annual training is provided to the City of Red Wing via the Minnesota Emergency Operations Plan.
Prairie Island Nuclear Generating Plant Page 12 of 13 Training1 Periodicity Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Dakota County              Letter of        41281201 1    Annual training provided by Agreement                      the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Initial and annual training is provided by Pierce County as stated in the Pierce County Emergency Operations Plan. Annual training is provided by the site. Annual training provided by the Wisconsin Department of Health Services. NSPM supports emergency response services provided by the Prairie Island Indian Community, including providing training. Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan. Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Page 11.of 13
N/A NIA N/A N/A N/A N/A Date of Agreement 1 111 11201 0 1/4/2011 3/18/2010 311 81201 0 1/31/2011 6/7/201 1 10/2512010 10/12/2010 31251201 0 9/30/20 1 0 1 0/5/2010 1211 51201 0 9/29/2010 Off-site Organization Goodhue County Pier~e County Fairview Red Wing Hospital Sacred Heart Hospital Prairie Island Indian Community Regions Hospital North Memorial Medical Center Westinghouse Canadian Pacific Railway Institute of Nuclear Power Operations (INPO) Environmental, Inc. Midwest Laboratory Pooled Inventory Management Department of Energy- Radiation Emergency Assistance CenteriTraining Site Implementing Document Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Prairie Island Nuclear Generating Plant All Letters of Agreement are reviewed annually by procedure to ensure they are current and are renewed periodically.
 
NSPM reviewed the corrective action program for issues involving lapsed Letters of Agreement related to B.5.b and found no examples of lapsed contractual agreements. All of the Letters of Agreement identified above meet the procedural requirements for renewal. Page 13 of 13}}
Prairie Island Nuclear Generating Plant Off-site Organization  Implementing Date of           Training1 Periodicity Document          Agreement Goodhue County          Letter of        1111112010  Annual training provided by Agreement                      the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Pier~e  County          Letter of        1/4/2011    Initial and annual training is Agreement                      provided by Pierce County as stated in the Pierce County Emergency Operations Plan.
Fairview Red Wing      Letter of        3/18/2010    Annual training is provided by Hospital              Agreement                      the site.
Sacred Heart Hospital  Letter of        311812010    Annual training provided by Agreement                      the Wisconsin Department of Health Services.
Prairie Island Indian  Letter of          1/31/2011    NSPM supports emergency Community              Agreement                      response services provided by the Prairie Island Indian Community, including providing training.
Regions Hospital        Letter of        6/7/2011    Annual training provided by Agreement                      the State of Minnesota as stated in Minnesota Emergency Operations Plan.
North Memorial        Letter of          10/2512010  Annual training provided by Medical Center        Agreement                      the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Westinghouse          Letter of          10/12/2010  N/A Agreement Canadian Pacific      Letter of         312512010    NIA Railway                Agreement Institute of Nuclear  Letter of          9/30/2010   N/A Power Operations       Agreement (INPO)
Environmental, Inc. Letter of          10/5/2010    N/A Midwest Laboratory     Agreement Pooled Inventory       Letter of          1211512010  N/A Management             Agreement Department of Energy- Letter of        9/29/2010    N/A Radiation Emergency   Agreement Assistance CenteriTraining Site Page 12 of 13
 
Prairie Island Nuclear Generating Plant All Letters of Agreement are reviewed annually by procedure to ensure they are current and are renewed periodically.
NSPM reviewed the corrective action program for issues involving lapsed Letters of Agreement related to B.5.b and found no examples of lapsed contractual agreements. All of the Letters of Agreement identified above meet the procedural requirements for renewal.
Page 13 of 13}}


=Text=
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{{#Wiki_filter:July 11, 201 1 L-PI-11-069 10 CFR 50.54(f) U S Nuclear Regulatory Commission ATTN: Document Control Desk 1 1555 Rockville Pike Rockville, MD 20852 Prairie Island Nuclear Generating Plant, Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 60-Dav Response to NRC Bulletin 201 1-01, "Mitigating Strategies"  
{{#Wiki_filter:July 11, 201 1                                                             L-PI-11-069 10 CFR 50.54(f)
U S Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Prairie Island Nuclear Generating Plant, Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 60-Dav Response to NRC Bulletin 201 1-01, "Mitigating Strategies"


==Reference:==
==Reference:==
NRC Bulletin 201 1-01, "Mitigating Strategies," dated May 11, 201 1 (MLI 11250360).
On May 1I , 201 1, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 201 1-01, "Mitigating Strategies" (Reference). The NRC issued this Bulletin to achieve the following objectives:
1.. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2),
: 2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima-Daiichi facility in order to determine if
      . I ) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and
: 3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).
The Bulletin requested each licensee to submit a written response within 30 days of the date of the Bulletin. This 30-day response letter was provided by Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), on June 9,201 1.
1717 Wakonade Drive East  Welch, Minnesota 55089-9642 Telephone: 651.388.1121
Document Control Desk Page 2 The Bulletin also requested that within 60 days of the date of the Bulletin that NSPM provide the following information on their mitigating strategies:
      ' How essential resources are maintained, tested and controlled to ensure availability; How strategies are re-evaluated if plant conditions or configurations change; and How arrangements are reached and maintained with local emergency response organizations.
The enclosure to this letter contains the 60-day response to the requested information pursuant to the provisions of 10 CFR 50.54(f) for the Prairie Island Nuclear Generating Plant (PINGP).
Summaw of Commitments This letter contains one new commitment and no changes to existing commitments. In response to Question 4 in the Enclosure, NSPM makes the following commitment:
NSPM will include a requirement for continuing training on Extensive Damage Mitigation Guidelines (EDMG) in the PINGP training program for the Emergency Response Organization (ERO) qualified decision makers by January 13,2012.
I declare under penalty of perjury that the foregoing is true and correct. Executed on July 11, 201 1.
L Mark A. Schimmel Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc:    Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC


NRC Bulletin 201 1-01, "Mitigating Strategies," dated May 11, 201 1 (MLI 11 250360).
Prairie Island Nuclear Generating Plant Enclosure I 60-Day Response for NRC Bulletin 201 1-01 On May 11, 201 1, the NRC issued Bulletin 201 1-01, "Mitigating Strategies." The Bulletin requested that within 60 days of the date of this Bulletin, licensees provide information on their mitigating strategies programs. The NRC questions related to the 60-day response are restated below followed by the Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), response for the Prairie Island Nuclear Generating Plant'(PINGP).
On May 1 I, 201 1, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 201 1-01, "Mitigating Strategies" (Reference). The NRC issued this Bulletin to achieve the following objectives:
The items described below represent current plant practices, Individual items may be revised or adjusted in the future based on new or revised vendor recommendations, industry experience, etc., in accordance with established processes. Any changes involving commitments will be executed in accordance with NEI 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes."
1 .. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.54(hh)(2), 2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima-Daiichi facility in order to determine if . I) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and 3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).
Page 1 of 13
The Bulletin requested each licensee to submit a written response within 30 days of the date of the Bulletin. This 30-day response letter was provided by Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), on June 9,201 1. 171 7 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone:
 
651.388.1 121 Document Control Desk Page 2 The Bulletin also requested that within 60 days of the date of the Bulletin that NSPM provide the following information on their mitigating strategies:
Prairie Island Nuclear Generating Plant Request:
' How essential resources are maintained, tested and controlled to ensure availability; How strategies are re-evaluated if plant conditions or configurations change; and How arrangements are reached and maintained with local emergency response organizations. The enclosure to this letter contains the 60-day response to the requested information pursuant to the provisions of 10 CFR 50.54(f) for the Prairie Island Nuclear Generating Plant (PINGP).
: 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.
Summaw of Commitments This letter contains one new commitment and no changes to existing commitments.
Examples of the types of information to include when providing your response to Question (1) are:
In response to Question 4 in the Enclosure, NSPM makes the following commitment: NSPM will include a requirement for continuing training on Extensive Damage Mitigation Guidelines (EDMG) in the PINGP training program for the Emergency Response Organization (ERO) qualified decision makers by January 13,2012. I declare under penalty of perjury that the foregoing is true and correct. Executed on July 11, 201
: a. Measures implemented to maintain the equipment, including periodicity.
: 1. Mark A. Schimmel L Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC Prairie Island Nuclear Generating Plant Enclosure I 60-Day Response for NRC Bulletin 201 1-01 On May 11, 201 1, the NRC issued Bulletin 201 1-01, "Mitigating Strategies." The Bulletin requested that within 60 days of the date of this Bulletin, licensees provide information on their mitigating strategies programs. The NRC questions related to the 60-day response are restated below followed by the Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), response for the Prairie Island Nuclear Generating Plant'(PINGP). The items described below represent current plant practices, Individual items may be revised or adjusted in the future based on new or revised vendor recommendations, industry experience, etc., in accordance with established processes. Any changes involving commitments will be executed in accordance with NEI 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes." Page 1 of 13 Prairie Island Nuclear Generating Plant Request: 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.
: b. Basis for establishing each maintenance item (e.g., manufacturer's recommendation, code or standard applicable to the craft). This should include consideration of storage environment impact on the maintenance necessary.
Examples of the types of information to include when providing your response to Question (1) are: a. Measures implemented to maintain the equipment, including periodicity.
These examples are not meant to limit your response if you use other methods to address the issues described above.
: b. Basis for establishing each maintenance item (e.g., manufacturer's recommendation, code or standard applicable to the craft). This should include consideration of storage environment impact on the maintenance necessary. These examples are not meant to limit your response if you use other methods to address the issues described above.
NSPM Response:
NSPM Response:
The maintenance activities listed below in Table I have been established to ensure that the equipment procured to support the B.5.b mitigation strategies is functional when needed.
The maintenance activities listed below in Table Ihave been established to ensure that the equipment procured to support the B.5.b mitigation strategies is functional when needed.
Table 1 - Preventative Maintenance Page 2 of 13 Equipment 125 VDC Battery Cart Portable Diesel Fire Pump Preventive Maintenance Replace batteries.
Table 1 Preventative Maintenance Equipment             Preventive Maintenance          periodicity*        Basis 125 VDC             Replace batteries.                30 months    Vendor Battery Cart                                                         Specifications.
Change engine oil and filter. Replace fuel filter. Check battery condition.
Portable Diesel Change engine oil and filter.         Annually      Based on plant Fire Pump                                                            experience.
Inspect and clean (if necessary) radiator coils.
Replace fuel filter.               Annually      Based on plant experience.
Inspect all hoses and belts for wear and tension. Replaceladjust as necessary. Inspect engine air cleaner for excessive dirt. Replace filter as required. Check gauges and hour meter for damage.
Check battery condition.            Annually      Based on plant experience.
Repairlreplace as necessary.
Inspect and clean (if necessary)   Annually      Based on plant radiator coils.                                  experience.
periodicity*
Inspect all hoses and belts for   Annually      Based on plant wear and tension.                                 experience.
30 months Annually Annually Annually Annually Annually Annually Annually Basis Vendor Specifications.
Replaceladjust as necessary.
Based on plant experience.
Inspect engine air cleaner for     Annually      Based on plant excessive dirt. Replace filter as                 experience.
Based on plant experience.
required.
Based on plant experience.
Check gauges and hour meter         Annually      Based on plant for damage. Repairlreplace as                     experience.
Based on plant experience.
necessary.
Based on plant experience.
Page 2 of 13


Based on plant experience.
Prairie Island Nuclear Generating Plant 1   Equipment     I     Preventive Maintenance       I periodicity' I       Basis   I Verify lug nuts tight on wheels. Annually       Based on plant experience.
Based on plant experience.
Verify proper air pressure in       Annually        Based on plant tires. Adjust as necessary.                         experience.
Prairie Island Nuclear Generating Plant 1 Equipment I Preventive Maintenance I periodicity' I Basis I Verify lug nuts tight on wheels. Annually Based on plant experience. Verify proper air pressure in tires. Adjust as necessary.
Verify jack stands operational     Annually        Based on plant and in good condition. Lubricate                   experience.
Based on plant experience.
with grease.
Annually Verify jack stands operational and in good condition. Lubricate with grease.
Remove compressor guards and Annually              Based on plant inspect the compressor belt, oil                   experience.
Remove compressor guards and inspect the compressor belt, oil lines and air lines, checking for wear. Replace as necessary.
lines and air lines, checking for wear. Replace as necessary.
Annually Based on plant experience.
Change the mechanical seal oil. Annually       Based on plant experience.
Annually Based on plant experience. Change the mechanical seal oil.
Replace display panel battery.     8 years        Based on plant experience.
Page 3 of 13 Replace display panel battery.
  *Note: The Preventative Maintenance program is condition based and frequencies are adjusted based on conditions found during maintenance and equipment performance.
Annually Based on plant experience.  
The periodicity shown is the present frequency.
*Note: The Preventative Maintenance program is condition based and frequencies are adjusted based on conditions found during maintenance and equipment performance. The periodicity shown is the present frequency.
Page 3 of 13
8 years Based on plant experience.
 
Prairie Island Nuclear Generating Plant Request: 2. Describe in detail the testing of equipment procured to support the strategies arid guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed. Examples of the types of information to include when providing your response to Question (2) are: a. A description of any testing accomplished to ensure the strategies were initially feasible.
Prairie Island Nuclear Generating Plant Request:
: 2. Describe in detail the testing of equipment procured to support the strategies arid guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed.
Examples of the types of information to include when providing your response to Question (2) are:
: a. A description of any testing accomplished to ensure the strategies were initially feasible.
: b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement
: b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement
: c. A description of the corrective action process used when the equipment fails to adequately perform its test.
: c. A description of the corrective action process used when the equipment fails to adequately perform its test.
These examples are not meant to limit your response if you use other methods to address the issues described above.
These examples are not meant to limit your response if you use other methods to address the issues described above.
NSPM Response:
NSPM Response:
During the initial development of the B.5.b mitigating strategies, NSPM validated strategies by performing engineering evaluations, time validations and/or tabletop reviews.
During the initial development of the B.5.b mitigating strategies, NSPM validated strategies by performing engineering evaluations, time validations and/or tabletop reviews. The following Table 2.a describes the testing and evaluations accomplished to verify the initial feasibility of the mitigating strategies.
The following Table 2.a describes the testing and evaluations accomplished to verify the initial feasibility of the mitigating strategies.
Table 2.a - Mitigating Strategies Validation Strategy                                         Description External Spent Fuel Pool         Time validation performed to demonstrate water could Makeup                  be delivered within 2 hours. Portable diesel fire pump and I 0 0 foot aerial fire truck tested. A plant walkdown and an engineering evaluation completed to analyze the B.5.b flow path scenarios.
Table 2.a - Mitigating Strategies Validation Page 4 of 13 Strategy External Spent Fuel Pool Makeup Internal Spent Fuel Pool Makeup Spent Fuel Pool Spray Steam Generator Injection Containment Flooding Description Time validation performed to demonstrate water could be delivered within 2 hours. Portable diesel fire pump and I00 foot aerial fire truck tested.
Internal Spent Fuel Pool        A plant walkdown and an engineering evaluation Makeup                  completed to analyze the B.5.b flow path scenarios.
A plant walkdown and an engineering evaluation completed to analyze the B.5.b flow path scenarios.
Spent Fuel Pool Spray          Engineering evaluation completed to analyze the B.5.b flow path scenarios.
A plant walkdown and an engineering evaluation completed to analyze the B.5.b flow path scenarios.
Steam Generator Injection        Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.
Engineering evaluation completed to analyze the B.5.b flow path scenarios.
Containment Flooding            Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.
Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.
Page 4 of 13
Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.
 
Prairie Island Nuclear Generating Plant The following Table 2.b describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.
Prairie Island Nuclear Generating Plant Strategy                                     Description Refueling Water Storage Tank         Engineering evaluation completed to analyze the Makeup                  B.5.b flow path scenarios.
Strategy Refueling Water Storage Tank Makeup Condensate Storage Tank Makeup Remote Battery Operation of the PORV Table 2.b - Surveillances Description Engineering evaluation completed to analyze the B.5.b flow path scenarios. Engineering evaluation completed to analyze the B.5.b flow path scenarios. Engineering evaluation completed to ensure battery capable of supplying power to the solenoids.
Condensate Storage Tank          Engineering evaluation completed to analyze the Makeup                  B.5.b flow path scenarios.
Equipment Portable Diesel Fire Pump Pagers Cell Phone Radios Surveillances General unit inspection is performed prior to performing the test. The oil, coolant, fuel, and mechanical seal level is checked. The trailer is attached to the truck and transported to test location. Pump is run for 5-1 0 minutes at 1500-2000 rpm and then reduced to 900 rpm for an additional 3 minutes. The engine operating data (coolant temperature, oil pressure, etc.)
Remote Battery Operation of        Engineering evaluation completed to ensure battery the PORV                  capable of supplying power to the solenoids.
is recorded. Perform general visual inspection of diesel and pump (i.e., engine hoses, clamps, connections, etc.)
The following Table 2.b describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.
Similar to quarterly surveillance, plus hoses are attached to the suction and discharge of the pump and run for 30 minutes. The pump is also run at elevated rpm to obtain flow vs, pressure data.
Table 2.b - Surveillances Equipment                     Surveillances                  Periodicity      Basis Portable       General unit inspection is performed prior     Quarterly    Vendor Diesel Fire    to performing the test. The oil, coolant,                   Recommended.
Tested weekly to verify that pagers used for Emergency Response are functional. Ensure the functionality of the Emergency Operations Facility cellular telephone.
Pump          fuel, and mechanical seal level is checked.
Check the functionality of the radios every quarter. Periodicity Quarterly Quarterly Quarterly Annual Weekly Every other month Quarterly Basis Vendor Recommended.
The trailer is attached to the truck and       Quarterly    Vendor transported to test location. Pump is run                   Recommended.
Vendor Recommended.
for 5-10 minutes at 1500-2000 rpm and then reduced to 900 rpm for an additional 3 minutes. The engine operating data (coolant temperature, oil pressure, etc.) is recorded.
Vendor Recommended.
Perform general visual inspection of           Quarterly    Vendor diesel and pump (i.e., engine hoses,                         Recommended.
Vendor Recommended.
clamps, connections, etc.)
Based on plant experience.
Similar to quarterly surveillance, plus       Annual        Vendor hoses are attached to the suction and                       Recommended.
Based on plant experience.
discharge of the pump and run for 30 minutes. The pump is also run at elevated rpm to obtain flow vs, pressure data.
Based on plant experience.
Pagers        Tested weekly to verify that pagers used       Weekly        Based on plant for Emergency Response are functional.                       experience.
Prairie Island Nuclear Generating Plant In regards to question 2.c1 The 10 CFR 50 Appendix B Corrective Action Program (CAP) is used to document failures, establish priorities for corrective actions and perform trending. When an issue is identified, a CAP Action Request (AR) is initiated, a management review team determines level of review required, and corrective actions are determined and implemented in accordance with the significance.  
Cell Phone    Ensure the functionality of the Emergency Every other        Based on plant Operations Facility cellular telephone.        month        experience.
~~uibent Fire Hoses and Adapters Page 6 of 13 Surveillances Fire hoses are hydrostatically tested every two years, except the hose on the turbine building roof which is tested annually. Inspect fire hoses and gaskets. Periodicity Biennially Biennially Basis 10 CFR 50 Appendix R and plant experience.
Radios        Check the functionality of the radios every   Quarterly    Based on plant quarter.                                                     experience.
Based on plant experience.
 
Prairie Island Nuclear Generating Plant Request: 3. Describe in detail the controls for assuring that the equipment is available when needed. Examples of the types of information to include when providing your response to Question (3) are: a. A description of any inventory requirements established for the equipment.
Prairie Island Nuclear Generating Plant
~ ~ u i b e n t                Surveillances                  Periodicity      Basis Fire Hoses      Fire hoses are hydrostatically tested        Biennially  10 CFR 50 and            every two years, except the hose on the                  Appendix R and Adapters        turbine building roof which is tested                    plant annually.                                                experience.
Inspect fire hoses and gaskets.             Biennially  Based on plant experience.
In regards to question 2.c1The 10 CFR 50 Appendix B Corrective Action Program (CAP) is used to document failures, establish priorities for corrective actions and perform trending. When an issue is identified, a CAP Action Request (AR) is initiated, a management review team determines level of review required, and corrective actions are determined and implemented in accordance with the significance.
Page 6 of 13
 
Prairie Island Nuclear Generating Plant Request:
: 3. Describe in detail the controls for assuring that the equipment is available when needed.
Examples of the types of information to include when providing your response to Question (3) are:
: a. A description of any inventory requirements established for the equipment.
: b. A listing of deficiencies noted in inventories for the equipment and corrective actions taken to prevent loss.
: b. A listing of deficiencies noted in inventories for the equipment and corrective actions taken to prevent loss.
These examples are not meant to limit your response if you use other methods to address the issues described above.
These examples are not meant to limit your response if you use other methods to address the issues described above.
NSPM Response:
NSPM Response:
In.addition to the controls described in responses 1 and 2, procured non - permanently installed B.5.b equipment is inventoried quarterly in accordance with plant processes or procedures. This inventory assures the items are stored in the proper quantities and location.
In.addition to the controls described in responses 1 and 2, procured non -
Access to equipment storage locations is controlled by postings on lockers and trailers where they are stored, citing the equipment is designated for use only for B.5.b scenarios. lnventory deficiencies are entered into the CAP.
permanently installed B.5.b equipment is inventoried quarterly in accordance with plant processes or procedures. This inventory assures the items are stored in the proper quantities and location. Access to equipment storage locations is controlled by postings on lockers and trailers where they are stored, citing the equipment is designated for use only for B.5.b scenarios.
As of the date of this response, there are no outstanding inventory deficiencies that would render the strategies not viable.
lnventory deficiencies are entered into the CAP. As of the date of this response, there are no outstanding inventory deficiencies that would render the strategies not viable.
Table 3 - Inventories Page 7 of 13 Actions Performed Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Special Storage Controls Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Equipment Carts, trucks and trailers for staging equipment Portable Diesel Fire Pump and battery charger Set(s) of wheel chocks Floating suction strainer and suction hose steak Generator fill connector Reverse Osmosis connector for Refueling Water Storage Tank fill Inventory Frequency Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Prairie Island Nuclear Generating Plant Page 8 of 13 Equipment Fire Hose (6, 5, 4, 2 % and 1-112 - inch) nozzles, valves, adapters, splitters, monitors, manifolds, strainer, connectors, wrenches, etc. DllD2 connector (replaces spool pieces) Deepwell supply connector for Dl ID2 cooling 5-inch discharge flow indicator 125 VDC Battery Cart Turnout gear ( coats, pants, helmets, gloves, boots)
Table 3 Inventories Equipment                  Inventory    Special    Actions Performed Frequency      Storage Controls Carts, trucks and trailers for         Quarterly  Indoors,      Verify proper staging equipment                                 Heated        quantities Portable Diesel Fire Pump and         Quarterly    Indoors,    Verify proper battery charger                                   Heated        quantities Set(s) of wheel chocks                 Quarterly  Indoors,      Verify proper Heated        quantities Floating suction strainer and         Quarterly  Indoors,      Verify proper suction hose                                       Heated        quantities steak Generator fill connector         Quarterly  Indoors,      Verify proper Heated        quantities Reverse Osmosis connector for         Quarterly    Indoors,    Verify proper Refueling Water Storage Tank fill                 Heated        quantities Page 7 of 13
Self-contained Breathing Apparatuslmasksltanks Radios and chargers Portable lights (flashlights, quartz lights, halogen lights, etc.)
 
Dosimetry Tools (extension cords, hand tools, specialty tools, etc)
Prairie Island Nuclear Generating Plant Equipment                   Inventory    Special    Actions Performed Frequency      Storage Controls Fire Hose (6, 5, 4, 2 % and 1-112 -     Quarterly    Indoors,    Verify proper inch) nozzles, valves, adapters,                     Heated      quantities splitters, monitors, manifolds, strainer, connectors, wrenches, etc.
Rescue equipmentlmedical supplies Fuel oil for Portable Diesel Fire Pump Special Storage Controls Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Indoors, Heated Inventory Frequency Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Quarterly Actions Performed Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Verify proper quantities Prairie Island Nuclear Generating Plant Request: 4. Describe in detail how configuration and guidance management is assured so that strategies remain feasible.
DllD2 connector (replaces spool         Quarterly    Indoors,    Verify proper pieces)                                             Heated      quantities Deepwell supply connector for           Quarterly    Indoors,    Verify proper D l ID2 cooling                                     Heated      quantities 5-inch discharge flow indicator         Quarterly    Indoors,    Verify proper Heated      quantities 125 VDC Battery Cart                   Quarterly    Indoors,    Verify proper Heated      quantities Turnout gear ( coats, pants,           Quarterly    Indoors,    Verify proper helmets, gloves, boots)                             Heated      quantities Self-contained Breathing               Quarterly    Indoors,    Verify proper Apparatuslmasksltanks                               Heated      quantities Radios and chargers                     Quarterly    Indoors,    Verify proper Heated      quantities Portable lights (flashlights, quartz   Quarterly    Indoors,    Verify proper lights, halogen lights, etc.)                       Heated      quantities Dosimetry                               Quarterly    Indoors,    Verify proper Heated      quantities Tools (extension cords, hand tools, Quarterly        Indoors,    Verify proper specialty tools, etc)                               Heated        quantities Rescue equipmentlmedical               Quarterly  Indoors,      Verify proper supplies                                           Heated        quantities Fuel oil for Portable Diesel Fire       Quarterly  Indoors,     Verify proper Pump                                                Heated        quantities Page 8 of 13
Examples of the types of information to include when providing your response to Question (4) are: . a. Measures taken to evaluate any plant configuration changes for their effect on feasibility of the mitigating strategies.
 
Prairie Island Nuclear Generating Plant Request:
: 4. Describe in detail how configuration and guidance management is assured so that strategies remain feasible.
Examples of the types of information to include when providing your response to Question (4) are:
    . a. Measures taken to evaluate any plant configuration changes for their effect on feasibility of the mitigating strategies.
: b. Measures taken to validate that the procedures or guidelines developed to support the strategies can be executed. These measures could include drills, exercises, or walk through of the procedures by personnel that would be expected to accomplish the strategies.
: b. Measures taken to validate that the procedures or guidelines developed to support the strategies can be executed. These measures could include drills, exercises, or walk through of the procedures by personnel that would be expected to accomplish the strategies.
: c. Measures taken to ensure procedures remain up-to-date and consistent with the current configuration of the plant. d. A description of the training program implemented in support of the mitigating strategies and the manner in which you evaluate its effectiveness. These examples are not meant to limit your response if you use other methods to address the issues described above. NSPM Response: Plant configuration changes are procedurally evaluated against the licensing basis, including the license conditions and their associated safety evaluation. Initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews. Subsequent procedure changes are validated to ensure that the guideline remains viable. In 201 1, B.5.b mitigating strategies were revalidated by similar techniques. The training discussed below also validates that the associated mitigating strategies can be deployed. The design change process requires a review of affected procedures and any necessary changes to be made. The mitigating strategy guidelines are controlled consistent with procedural controls under established administrative processes.
: c. Measures taken to ensure procedures remain up-to-date and consistent with the current configuration of the plant.
: d. A description of the training program implemented in support of the mitigating strategies and the manner in which you evaluate its effectiveness.
These examples are not meant to limit your response if you use other methods to address the issues described above.
NSPM Response:
Plant configuration changes are procedurally evaluated against the licensing basis, including the license conditions and their associated safety evaluation.
Initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews. Subsequent procedure changes are validated to ensure that the guideline remains viable. In 201 1, B.5.b mitigating strategies were revalidated by similar techniques. The training discussed below also validates that the associated mitigating strategies can be deployed.
The design change process requires a review of affected procedures and any necessary changes to be made.
The mitigating strategy guidelines are controlled consistent with procedural controls under established administrative processes.
The following table describes the training program implemented in support of the mitigating strategies and the manner in which effectiveness is evaluated.
The following table describes the training program implemented in support of the mitigating strategies and the manner in which effectiveness is evaluated.
Page 9 of 13 Prairie Island Nuclear Generating Plant Table 4 - Training Page 10 of 13 Plant Personnel Non-Licensed Operators Licensed Operators Fire Brigade Emergency Reponse Organzation - Key Decision Makers Security Training Training on the Non-Licensed Operator role in implementing Extensive Damage Mitigation Guidelines (EDMG) is part of the Initial Non-Licensed Operator Training programs and retrained per the NLO continuing training plan. Licensed Operators are initially trained on EDMGs per the Initial Licensed Operator training program. Licensed Operators are retrained per the biennial training plan as described in the Licensed Operator Requalification Training Program Description. Fire Brigade members are Non-Licensed Operators and are initially trained in EDMGs. Refresher training on B.5.b events is offered every 3 years. The Emergency Response Organization (ERO) qualified decision makers receive initial training on EDMGs. However, NSPM currently has no procedural requirements to provide continuing training. NSPM recognizes the need for ongoing training for its qualified decision makers. Therefore, NSPM makes the following commitment for the PINGP:
Page 9 of 13
NSPM will include a requirement for continuing training on EDMGs in the PINGP training program for the ERO qualified decision makers by January 13, 2012. Training on mitigating strategies was done as part of the implementation of B.5.b. Security EDMG actions are incorporated into Security Implementing Procedures, Contingency Plan Implementing Procedure and site procedures that are trained in initial training and are re-qualified per the Security Training Program Description.
 
Periodicity 3 years 2 years 3 Years None 2 Years Evaluation Testing I Qualification Testing and DrillsIExercises Testing Qualification Testing Prairie Island Nuclear Generating Plant Request: 5. Describe in detail how you assure availability of off-site support. Examples of the types of information to include when providing your response to Question (5) are: a. A listing of off-site organizations you rely on for emergency response.
Prairie Island Nuclear Generating Plant Table 4 - Training Plant         Training                                      Periodicity Evaluation Personnel Non-Licensed Training on the Non-Licensed Operator           3 years    Testing I Operators      role in implementing Extensive Damage                     Qualification Mitigation Guidelines (EDMG) is part of the Initial Non-Licensed Operator Training programs and retrained per the NLO continuing training plan.
Licensed      Licensed Operators are initially trained       2 years    Testing and Operators      on EDMGs per the Initial Licensed                         DrillsIExercises Operator training program. Licensed Operators are retrained per the biennial training plan as described in the Licensed Operator Requalification Training Program Description.
Fire Brigade  Fire Brigade members are Non-Licensed         3 Years    Testing Operators and are initially trained in EDMGs. Refresher training on B.5.b events is offered every 3 years.
Emergency    The Emergency Response Organization             None        Qualification Reponse        (ERO) qualified decision makers receive Organzation -  initial training on EDMGs. However, Key Decision  NSPM currently has no procedural Makers        requirements to provide continuing training. NSPM recognizes the need for ongoing training for its qualified decision makers. Therefore, NSPM makes the following commitment for the PINGP:
NSPM will include a requirement for continuing training on EDMGs in the PINGP training program for the ERO qualified decision makers by January 13, 2012.
Security      Training on mitigating strategies was         2 Years      Testing done as part of the implementation of B.5.b. Security EDMG actions are incorporated into Security Implementing Procedures, Contingency Plan Implementing Procedure and site procedures that are trained in initial training and are re-qualified per the Security Training Program Description.
Page 10 of 13
 
Prairie Island Nuclear Generating Plant Request:
: 5. Describe in detail how you assure availability of off-site support.
Examples of the types of information to include when providing your response to Question (5) are:
: a. A listing of off-site organizations you rely on for emergency response.
: b. Measures taken to ensure the continuity of memoranda of agreement or understanding or other applicable contractual arrangements. This should include a listing of periods of lapsed contractual arrangements.
: b. Measures taken to ensure the continuity of memoranda of agreement or understanding or other applicable contractual arrangements. This should include a listing of periods of lapsed contractual arrangements.
: c. A listing of any training or site familiarization provided to off-site responders.
: c. A listing of any training or site familiarization provided to off-site responders. This should include any measures taken to ensure continued familiarity of personnel of the off-site responders in light of turnover and the passage of time.
This should include any measures taken to ensure continued familiarity of personnel of the off-site responders in light of turnover and the passage of time. These examples are not meant to limit your response if you use other methods to address the issues described above. NSPM Response:
These examples are not meant to limit your response if you use other methods to address the issues described above.
NSPM Response:
The following off-site organizations in Table 5 are relied on for emergency response.
The following off-site organizations in Table 5 are relied on for emergency response.
Table 5 - Offsite Organizations Page 1 1. of 13 Off-site Organization State of Minnesota State of Wisconsin City of Red Wing (includes Red Wing Fire Department)
Table 5 - Offsite Organizations Off-site Organization     Implementing Date of             Training1 Periodicity Document         Agreement State of Minnesota        Letter of         1211712008  Annual training provided by Agreement                      the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Dakota County Implementing Document Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Date of Agreement 1211 712008 101612010 21241201 1 41281201 1 Training1 Periodicity Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan. Annual training provided by the State of Wisconsin as stated in Wisconsin Emergency Operations Plan. Annual training for the Red Wing Fire Department is provided by the site and the State of Minnesota. Annual training is provided to the City of Red Wing via the Minnesota Emergency Operations Plan.
State of Wisconsin        Letter of        101612010    Annual training provided by Agreement                      the State of Wisconsin as stated in Wisconsin Emergency Operations Plan.
Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan.
City of Red Wing          Letter of        21241201 1    Annual training for the Red (includes Red Wing        Agreement                      Wing Fire Department is Fire Department)                                          provided by the site and the State of Minnesota. Annual training is provided to the City of Red Wing via the Minnesota Emergency Operations Plan.
Prairie Island Nuclear Generating Plant Page 12 of 13 Training1 Periodicity Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Dakota County              Letter of        41281201 1    Annual training provided by Agreement                      the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Initial and annual training is provided by Pierce County as stated in the Pierce County Emergency Operations Plan. Annual training is provided by the site. Annual training provided by the Wisconsin Department of Health Services. NSPM supports emergency response services provided by the Prairie Island Indian Community, including providing training. Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan. Annual training provided by the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Page 11.of 13
N/A NIA N/A N/A N/A N/A Date of Agreement 1 111 11201 0 1/4/2011 3/18/2010 311 81201 0 1/31/2011 6/7/201 1 10/2512010 10/12/2010 31251201 0 9/30/20 1 0 1 0/5/2010 1211 51201 0 9/29/2010 Off-site Organization Goodhue County Pier~e County Fairview Red Wing Hospital Sacred Heart Hospital Prairie Island Indian Community Regions Hospital North Memorial Medical Center Westinghouse Canadian Pacific Railway Institute of Nuclear Power Operations (INPO) Environmental, Inc. Midwest Laboratory Pooled Inventory Management Department of Energy- Radiation Emergency Assistance CenteriTraining Site Implementing Document Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Letter of Agreement Prairie Island Nuclear Generating Plant All Letters of Agreement are reviewed annually by procedure to ensure they are current and are renewed periodically.
 
NSPM reviewed the corrective action program for issues involving lapsed Letters of Agreement related to B.5.b and found no examples of lapsed contractual agreements. All of the Letters of Agreement identified above meet the procedural requirements for renewal. Page 13 of 13}}
Prairie Island Nuclear Generating Plant Off-site Organization  Implementing Date of           Training1 Periodicity Document          Agreement Goodhue County          Letter of        1111112010  Annual training provided by Agreement                      the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Pier~e  County          Letter of        1/4/2011    Initial and annual training is Agreement                      provided by Pierce County as stated in the Pierce County Emergency Operations Plan.
Fairview Red Wing      Letter of        3/18/2010    Annual training is provided by Hospital              Agreement                      the site.
Sacred Heart Hospital  Letter of        311812010    Annual training provided by Agreement                      the Wisconsin Department of Health Services.
Prairie Island Indian  Letter of          1/31/2011    NSPM supports emergency Community              Agreement                      response services provided by the Prairie Island Indian Community, including providing training.
Regions Hospital        Letter of        6/7/2011    Annual training provided by Agreement                      the State of Minnesota as stated in Minnesota Emergency Operations Plan.
North Memorial        Letter of          10/2512010  Annual training provided by Medical Center        Agreement                      the State of Minnesota as stated in Minnesota Emergency Operations Plan.
Westinghouse          Letter of          10/12/2010  N/A Agreement Canadian Pacific      Letter of         312512010    NIA Railway                Agreement Institute of Nuclear  Letter of          9/30/2010   N/A Power Operations       Agreement (INPO)
Environmental, Inc. Letter of          10/5/2010    N/A Midwest Laboratory     Agreement Pooled Inventory       Letter of          1211512010  N/A Management             Agreement Department of Energy- Letter of        9/29/2010    N/A Radiation Emergency   Agreement Assistance CenteriTraining Site Page 12 of 13
 
Prairie Island Nuclear Generating Plant All Letters of Agreement are reviewed annually by procedure to ensure they are current and are renewed periodically.
NSPM reviewed the corrective action program for issues involving lapsed Letters of Agreement related to B.5.b and found no examples of lapsed contractual agreements. All of the Letters of Agreement identified above meet the procedural requirements for renewal.
Page 13 of 13}}

Latest revision as of 20:15, 10 March 2020

Day Response to NRC Bulletin 2011-01, Mitigating Strategies.
ML111930159
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 07/11/2011
From: Schimmel M
Northern States Power Co, Xcel Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-11-001, L-PI-11-069
Download: ML111930159 (15)
v • d • e


Text

July 11, 201 1 L-PI-11-069 10 CFR 50.54(f)

U S Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Prairie Island Nuclear Generating Plant, Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 60-Dav Response to NRC Bulletin 201 1-01, "Mitigating Strategies"

Reference:

NRC Bulletin 201 1-01, "Mitigating Strategies," dated May 11, 201 1 (MLI 11250360).

On May 1I , 201 1, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 201 1-01, "Mitigating Strategies" (Reference). The NRC issued this Bulletin to achieve the following objectives:

1.. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2),

2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima-Daiichi facility in order to determine if

. I ) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and

3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).

The Bulletin requested each licensee to submit a written response within 30 days of the date of the Bulletin. This 30-day response letter was provided by Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), on June 9,201 1.

1717 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1121

Document Control Desk Page 2 The Bulletin also requested that within 60 days of the date of the Bulletin that NSPM provide the following information on their mitigating strategies:

' How essential resources are maintained, tested and controlled to ensure availability; How strategies are re-evaluated if plant conditions or configurations change; and How arrangements are reached and maintained with local emergency response organizations.

The enclosure to this letter contains the 60-day response to the requested information pursuant to the provisions of 10 CFR 50.54(f) for the Prairie Island Nuclear Generating Plant (PINGP).

Summaw of Commitments This letter contains one new commitment and no changes to existing commitments. In response to Question 4 in the Enclosure, NSPM makes the following commitment:

NSPM will include a requirement for continuing training on Extensive Damage Mitigation Guidelines (EDMG) in the PINGP training program for the Emergency Response Organization (ERO) qualified decision makers by January 13,2012.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 11, 201 1.

L Mark A. Schimmel Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC

Prairie Island Nuclear Generating Plant Enclosure I 60-Day Response for NRC Bulletin 201 1-01 On May 11, 201 1, the NRC issued Bulletin 201 1-01, "Mitigating Strategies." The Bulletin requested that within 60 days of the date of this Bulletin, licensees provide information on their mitigating strategies programs. The NRC questions related to the 60-day response are restated below followed by the Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), response for the Prairie Island Nuclear Generating Plant'(PINGP).

The items described below represent current plant practices, Individual items may be revised or adjusted in the future based on new or revised vendor recommendations, industry experience, etc., in accordance with established processes. Any changes involving commitments will be executed in accordance with NEI 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes."

Page 1 of 13

Prairie Island Nuclear Generating Plant Request:

1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.

Examples of the types of information to include when providing your response to Question (1) are:

a. Measures implemented to maintain the equipment, including periodicity.
b. Basis for establishing each maintenance item (e.g., manufacturer's recommendation, code or standard applicable to the craft). This should include consideration of storage environment impact on the maintenance necessary.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

The maintenance activities listed below in Table Ihave been established to ensure that the equipment procured to support the B.5.b mitigation strategies is functional when needed.

Table 1 Preventative Maintenance Equipment Preventive Maintenance periodicity* Basis 125 VDC Replace batteries. 30 months Vendor Battery Cart Specifications.

Portable Diesel Change engine oil and filter. Annually Based on plant Fire Pump experience.

Replace fuel filter. Annually Based on plant experience.

Check battery condition. Annually Based on plant experience.

Inspect and clean (if necessary) Annually Based on plant radiator coils. experience.

Inspect all hoses and belts for Annually Based on plant wear and tension. experience.

Replaceladjust as necessary.

Inspect engine air cleaner for Annually Based on plant excessive dirt. Replace filter as experience.

required.

Check gauges and hour meter Annually Based on plant for damage. Repairlreplace as experience.

necessary.

Page 2 of 13

Prairie Island Nuclear Generating Plant 1 Equipment I Preventive Maintenance I periodicity' I Basis I Verify lug nuts tight on wheels. Annually Based on plant experience.

Verify proper air pressure in Annually Based on plant tires. Adjust as necessary. experience.

Verify jack stands operational Annually Based on plant and in good condition. Lubricate experience.

with grease.

Remove compressor guards and Annually Based on plant inspect the compressor belt, oil experience.

lines and air lines, checking for wear. Replace as necessary.

Change the mechanical seal oil. Annually Based on plant experience.

Replace display panel battery. 8 years Based on plant experience.

  • Note: The Preventative Maintenance program is condition based and frequencies are adjusted based on conditions found during maintenance and equipment performance.

The periodicity shown is the present frequency.

Page 3 of 13

Prairie Island Nuclear Generating Plant Request:

2. Describe in detail the testing of equipment procured to support the strategies arid guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed.

Examples of the types of information to include when providing your response to Question (2) are:

a. A description of any testing accomplished to ensure the strategies were initially feasible.
b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement
c. A description of the corrective action process used when the equipment fails to adequately perform its test.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

During the initial development of the B.5.b mitigating strategies, NSPM validated strategies by performing engineering evaluations, time validations and/or tabletop reviews. The following Table 2.a describes the testing and evaluations accomplished to verify the initial feasibility of the mitigating strategies.

Table 2.a - Mitigating Strategies Validation Strategy Description External Spent Fuel Pool Time validation performed to demonstrate water could Makeup be delivered within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Portable diesel fire pump and I 0 0 foot aerial fire truck tested. A plant walkdown and an engineering evaluation completed to analyze the B.5.b flow path scenarios.

Internal Spent Fuel Pool A plant walkdown and an engineering evaluation Makeup completed to analyze the B.5.b flow path scenarios.

Spent Fuel Pool Spray Engineering evaluation completed to analyze the B.5.b flow path scenarios.

Steam Generator Injection Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.

Containment Flooding Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.

Page 4 of 13

Prairie Island Nuclear Generating Plant Strategy Description Refueling Water Storage Tank Engineering evaluation completed to analyze the Makeup B.5.b flow path scenarios.

Condensate Storage Tank Engineering evaluation completed to analyze the Makeup B.5.b flow path scenarios.

Remote Battery Operation of Engineering evaluation completed to ensure battery the PORV capable of supplying power to the solenoids.

The following Table 2.b describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.

Table 2.b - Surveillances Equipment Surveillances Periodicity Basis Portable General unit inspection is performed prior Quarterly Vendor Diesel Fire to performing the test. The oil, coolant, Recommended.

Pump fuel, and mechanical seal level is checked.

The trailer is attached to the truck and Quarterly Vendor transported to test location. Pump is run Recommended.

for 5-10 minutes at 1500-2000 rpm and then reduced to 900 rpm for an additional 3 minutes. The engine operating data (coolant temperature, oil pressure, etc.) is recorded.

Perform general visual inspection of Quarterly Vendor diesel and pump (i.e., engine hoses, Recommended.

clamps, connections, etc.)

Similar to quarterly surveillance, plus Annual Vendor hoses are attached to the suction and Recommended.

discharge of the pump and run for 30 minutes. The pump is also run at elevated rpm to obtain flow vs, pressure data.

Pagers Tested weekly to verify that pagers used Weekly Based on plant for Emergency Response are functional. experience.

Cell Phone Ensure the functionality of the Emergency Every other Based on plant Operations Facility cellular telephone. month experience.

Radios Check the functionality of the radios every Quarterly Based on plant quarter. experience.

Prairie Island Nuclear Generating Plant

~ ~ u i b e n t Surveillances Periodicity Basis Fire Hoses Fire hoses are hydrostatically tested Biennially 10 CFR 50 and every two years, except the hose on the Appendix R and Adapters turbine building roof which is tested plant annually. experience.

Inspect fire hoses and gaskets. Biennially Based on plant experience.

In regards to question 2.c1The 10 CFR 50 Appendix B Corrective Action Program (CAP) is used to document failures, establish priorities for corrective actions and perform trending. When an issue is identified, a CAP Action Request (AR) is initiated, a management review team determines level of review required, and corrective actions are determined and implemented in accordance with the significance.

Page 6 of 13

Prairie Island Nuclear Generating Plant Request:

3. Describe in detail the controls for assuring that the equipment is available when needed.

Examples of the types of information to include when providing your response to Question (3) are:

a. A description of any inventory requirements established for the equipment.
b. A listing of deficiencies noted in inventories for the equipment and corrective actions taken to prevent loss.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

In.addition to the controls described in responses 1 and 2, procured non -

permanently installed B.5.b equipment is inventoried quarterly in accordance with plant processes or procedures. This inventory assures the items are stored in the proper quantities and location. Access to equipment storage locations is controlled by postings on lockers and trailers where they are stored, citing the equipment is designated for use only for B.5.b scenarios.

lnventory deficiencies are entered into the CAP. As of the date of this response, there are no outstanding inventory deficiencies that would render the strategies not viable.

Table 3 Inventories Equipment Inventory Special Actions Performed Frequency Storage Controls Carts, trucks and trailers for Quarterly Indoors, Verify proper staging equipment Heated quantities Portable Diesel Fire Pump and Quarterly Indoors, Verify proper battery charger Heated quantities Set(s) of wheel chocks Quarterly Indoors, Verify proper Heated quantities Floating suction strainer and Quarterly Indoors, Verify proper suction hose Heated quantities steak Generator fill connector Quarterly Indoors, Verify proper Heated quantities Reverse Osmosis connector for Quarterly Indoors, Verify proper Refueling Water Storage Tank fill Heated quantities Page 7 of 13

Prairie Island Nuclear Generating Plant Equipment Inventory Special Actions Performed Frequency Storage Controls Fire Hose (6, 5, 4, 2 % and 1-112 - Quarterly Indoors, Verify proper inch) nozzles, valves, adapters, Heated quantities splitters, monitors, manifolds, strainer, connectors, wrenches, etc.

DllD2 connector (replaces spool Quarterly Indoors, Verify proper pieces) Heated quantities Deepwell supply connector for Quarterly Indoors, Verify proper D l ID2 cooling Heated quantities 5-inch discharge flow indicator Quarterly Indoors, Verify proper Heated quantities 125 VDC Battery Cart Quarterly Indoors, Verify proper Heated quantities Turnout gear ( coats, pants, Quarterly Indoors, Verify proper helmets, gloves, boots) Heated quantities Self-contained Breathing Quarterly Indoors, Verify proper Apparatuslmasksltanks Heated quantities Radios and chargers Quarterly Indoors, Verify proper Heated quantities Portable lights (flashlights, quartz Quarterly Indoors, Verify proper lights, halogen lights, etc.) Heated quantities Dosimetry Quarterly Indoors, Verify proper Heated quantities Tools (extension cords, hand tools, Quarterly Indoors, Verify proper specialty tools, etc) Heated quantities Rescue equipmentlmedical Quarterly Indoors, Verify proper supplies Heated quantities Fuel oil for Portable Diesel Fire Quarterly Indoors, Verify proper Pump Heated quantities Page 8 of 13

Prairie Island Nuclear Generating Plant Request:

4. Describe in detail how configuration and guidance management is assured so that strategies remain feasible.

Examples of the types of information to include when providing your response to Question (4) are:

. a. Measures taken to evaluate any plant configuration changes for their effect on feasibility of the mitigating strategies.

b. Measures taken to validate that the procedures or guidelines developed to support the strategies can be executed. These measures could include drills, exercises, or walk through of the procedures by personnel that would be expected to accomplish the strategies.
c. Measures taken to ensure procedures remain up-to-date and consistent with the current configuration of the plant.
d. A description of the training program implemented in support of the mitigating strategies and the manner in which you evaluate its effectiveness.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

Plant configuration changes are procedurally evaluated against the licensing basis, including the license conditions and their associated safety evaluation.

Initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews. Subsequent procedure changes are validated to ensure that the guideline remains viable. In 201 1, B.5.b mitigating strategies were revalidated by similar techniques. The training discussed below also validates that the associated mitigating strategies can be deployed.

The design change process requires a review of affected procedures and any necessary changes to be made.

The mitigating strategy guidelines are controlled consistent with procedural controls under established administrative processes.

The following table describes the training program implemented in support of the mitigating strategies and the manner in which effectiveness is evaluated.

Page 9 of 13

Prairie Island Nuclear Generating Plant Table 4 - Training Plant Training Periodicity Evaluation Personnel Non-Licensed Training on the Non-Licensed Operator 3 years Testing I Operators role in implementing Extensive Damage Qualification Mitigation Guidelines (EDMG) is part of the Initial Non-Licensed Operator Training programs and retrained per the NLO continuing training plan.

Licensed Licensed Operators are initially trained 2 years Testing and Operators on EDMGs per the Initial Licensed DrillsIExercises Operator training program. Licensed Operators are retrained per the biennial training plan as described in the Licensed Operator Requalification Training Program Description.

Fire Brigade Fire Brigade members are Non-Licensed 3 Years Testing Operators and are initially trained in EDMGs. Refresher training on B.5.b events is offered every 3 years.

Emergency The Emergency Response Organization None Qualification Reponse (ERO) qualified decision makers receive Organzation - initial training on EDMGs. However, Key Decision NSPM currently has no procedural Makers requirements to provide continuing training. NSPM recognizes the need for ongoing training for its qualified decision makers. Therefore, NSPM makes the following commitment for the PINGP:

NSPM will include a requirement for continuing training on EDMGs in the PINGP training program for the ERO qualified decision makers by January 13, 2012.

Security Training on mitigating strategies was 2 Years Testing done as part of the implementation of B.5.b. Security EDMG actions are incorporated into Security Implementing Procedures, Contingency Plan Implementing Procedure and site procedures that are trained in initial training and are re-qualified per the Security Training Program Description.

Page 10 of 13

Prairie Island Nuclear Generating Plant Request:

5. Describe in detail how you assure availability of off-site support.

Examples of the types of information to include when providing your response to Question (5) are:

a. A listing of off-site organizations you rely on for emergency response.
b. Measures taken to ensure the continuity of memoranda of agreement or understanding or other applicable contractual arrangements. This should include a listing of periods of lapsed contractual arrangements.
c. A listing of any training or site familiarization provided to off-site responders. This should include any measures taken to ensure continued familiarity of personnel of the off-site responders in light of turnover and the passage of time.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

The following off-site organizations in Table 5 are relied on for emergency response.

Table 5 - Offsite Organizations Off-site Organization Implementing Date of Training1 Periodicity Document Agreement State of Minnesota Letter of 1211712008 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

State of Wisconsin Letter of 101612010 Annual training provided by Agreement the State of Wisconsin as stated in Wisconsin Emergency Operations Plan.

City of Red Wing Letter of 21241201 1 Annual training for the Red (includes Red Wing Agreement Wing Fire Department is Fire Department) provided by the site and the State of Minnesota. Annual training is provided to the City of Red Wing via the Minnesota Emergency Operations Plan.

Dakota County Letter of 41281201 1 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

Page 11.of 13

Prairie Island Nuclear Generating Plant Off-site Organization Implementing Date of Training1 Periodicity Document Agreement Goodhue County Letter of 1111112010 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

Pier~e County Letter of 1/4/2011 Initial and annual training is Agreement provided by Pierce County as stated in the Pierce County Emergency Operations Plan.

Fairview Red Wing Letter of 3/18/2010 Annual training is provided by Hospital Agreement the site.

Sacred Heart Hospital Letter of 311812010 Annual training provided by Agreement the Wisconsin Department of Health Services.

Prairie Island Indian Letter of 1/31/2011 NSPM supports emergency Community Agreement response services provided by the Prairie Island Indian Community, including providing training.

Regions Hospital Letter of 6/7/2011 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

North Memorial Letter of 10/2512010 Annual training provided by Medical Center Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

Westinghouse Letter of 10/12/2010 N/A Agreement Canadian Pacific Letter of 312512010 NIA Railway Agreement Institute of Nuclear Letter of 9/30/2010 N/A Power Operations Agreement (INPO)

Environmental, Inc. Letter of 10/5/2010 N/A Midwest Laboratory Agreement Pooled Inventory Letter of 1211512010 N/A Management Agreement Department of Energy- Letter of 9/29/2010 N/A Radiation Emergency Agreement Assistance CenteriTraining Site Page 12 of 13

Prairie Island Nuclear Generating Plant All Letters of Agreement are reviewed annually by procedure to ensure they are current and are renewed periodically.

NSPM reviewed the corrective action program for issues involving lapsed Letters of Agreement related to B.5.b and found no examples of lapsed contractual agreements. All of the Letters of Agreement identified above meet the procedural requirements for renewal.

Page 13 of 13

Text

July 11, 201 1 L-PI-11-069 10 CFR 50.54(f)

U S Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Prairie Island Nuclear Generating Plant, Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 60-Dav Response to NRC Bulletin 201 1-01, "Mitigating Strategies"

Reference:

NRC Bulletin 201 1-01, "Mitigating Strategies," dated May 11, 201 1 (MLI 11250360).

On May 1I , 201 1, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 201 1-01, "Mitigating Strategies" (Reference). The NRC issued this Bulletin to achieve the following objectives:

1.. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2),

2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima-Daiichi facility in order to determine if

. I ) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and

3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).

The Bulletin requested each licensee to submit a written response within 30 days of the date of the Bulletin. This 30-day response letter was provided by Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), on June 9,201 1.

1717 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1121

Document Control Desk Page 2 The Bulletin also requested that within 60 days of the date of the Bulletin that NSPM provide the following information on their mitigating strategies:

' How essential resources are maintained, tested and controlled to ensure availability; How strategies are re-evaluated if plant conditions or configurations change; and How arrangements are reached and maintained with local emergency response organizations.

The enclosure to this letter contains the 60-day response to the requested information pursuant to the provisions of 10 CFR 50.54(f) for the Prairie Island Nuclear Generating Plant (PINGP).

Summaw of Commitments This letter contains one new commitment and no changes to existing commitments. In response to Question 4 in the Enclosure, NSPM makes the following commitment:

NSPM will include a requirement for continuing training on Extensive Damage Mitigation Guidelines (EDMG) in the PINGP training program for the Emergency Response Organization (ERO) qualified decision makers by January 13,2012.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 11, 201 1.

L Mark A. Schimmel Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC

Prairie Island Nuclear Generating Plant Enclosure I 60-Day Response for NRC Bulletin 201 1-01 On May 11, 201 1, the NRC issued Bulletin 201 1-01, "Mitigating Strategies." The Bulletin requested that within 60 days of the date of this Bulletin, licensees provide information on their mitigating strategies programs. The NRC questions related to the 60-day response are restated below followed by the Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), response for the Prairie Island Nuclear Generating Plant'(PINGP).

The items described below represent current plant practices, Individual items may be revised or adjusted in the future based on new or revised vendor recommendations, industry experience, etc., in accordance with established processes. Any changes involving commitments will be executed in accordance with NEI 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes."

Page 1 of 13

Prairie Island Nuclear Generating Plant Request:

1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.

Examples of the types of information to include when providing your response to Question (1) are:

a. Measures implemented to maintain the equipment, including periodicity.
b. Basis for establishing each maintenance item (e.g., manufacturer's recommendation, code or standard applicable to the craft). This should include consideration of storage environment impact on the maintenance necessary.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

The maintenance activities listed below in Table Ihave been established to ensure that the equipment procured to support the B.5.b mitigation strategies is functional when needed.

Table 1 Preventative Maintenance Equipment Preventive Maintenance periodicity* Basis 125 VDC Replace batteries. 30 months Vendor Battery Cart Specifications.

Portable Diesel Change engine oil and filter. Annually Based on plant Fire Pump experience.

Replace fuel filter. Annually Based on plant experience.

Check battery condition. Annually Based on plant experience.

Inspect and clean (if necessary) Annually Based on plant radiator coils. experience.

Inspect all hoses and belts for Annually Based on plant wear and tension. experience.

Replaceladjust as necessary.

Inspect engine air cleaner for Annually Based on plant excessive dirt. Replace filter as experience.

required.

Check gauges and hour meter Annually Based on plant for damage. Repairlreplace as experience.

necessary.

Page 2 of 13

Prairie Island Nuclear Generating Plant 1 Equipment I Preventive Maintenance I periodicity' I Basis I Verify lug nuts tight on wheels. Annually Based on plant experience.

Verify proper air pressure in Annually Based on plant tires. Adjust as necessary. experience.

Verify jack stands operational Annually Based on plant and in good condition. Lubricate experience.

with grease.

Remove compressor guards and Annually Based on plant inspect the compressor belt, oil experience.

lines and air lines, checking for wear. Replace as necessary.

Change the mechanical seal oil. Annually Based on plant experience.

Replace display panel battery. 8 years Based on plant experience.

  • Note: The Preventative Maintenance program is condition based and frequencies are adjusted based on conditions found during maintenance and equipment performance.

The periodicity shown is the present frequency.

Page 3 of 13

Prairie Island Nuclear Generating Plant Request:

2. Describe in detail the testing of equipment procured to support the strategies arid guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed.

Examples of the types of information to include when providing your response to Question (2) are:

a. A description of any testing accomplished to ensure the strategies were initially feasible.
b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement
c. A description of the corrective action process used when the equipment fails to adequately perform its test.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

During the initial development of the B.5.b mitigating strategies, NSPM validated strategies by performing engineering evaluations, time validations and/or tabletop reviews. The following Table 2.a describes the testing and evaluations accomplished to verify the initial feasibility of the mitigating strategies.

Table 2.a - Mitigating Strategies Validation Strategy Description External Spent Fuel Pool Time validation performed to demonstrate water could Makeup be delivered within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Portable diesel fire pump and I 0 0 foot aerial fire truck tested. A plant walkdown and an engineering evaluation completed to analyze the B.5.b flow path scenarios.

Internal Spent Fuel Pool A plant walkdown and an engineering evaluation Makeup completed to analyze the B.5.b flow path scenarios.

Spent Fuel Pool Spray Engineering evaluation completed to analyze the B.5.b flow path scenarios.

Steam Generator Injection Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.

Containment Flooding Engineering evaluation completed to analyze the ability of the portable pump to deliver the flow required for scenario.

Page 4 of 13

Prairie Island Nuclear Generating Plant Strategy Description Refueling Water Storage Tank Engineering evaluation completed to analyze the Makeup B.5.b flow path scenarios.

Condensate Storage Tank Engineering evaluation completed to analyze the Makeup B.5.b flow path scenarios.

Remote Battery Operation of Engineering evaluation completed to ensure battery the PORV capable of supplying power to the solenoids.

The following Table 2.b describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.

Table 2.b - Surveillances Equipment Surveillances Periodicity Basis Portable General unit inspection is performed prior Quarterly Vendor Diesel Fire to performing the test. The oil, coolant, Recommended.

Pump fuel, and mechanical seal level is checked.

The trailer is attached to the truck and Quarterly Vendor transported to test location. Pump is run Recommended.

for 5-10 minutes at 1500-2000 rpm and then reduced to 900 rpm for an additional 3 minutes. The engine operating data (coolant temperature, oil pressure, etc.) is recorded.

Perform general visual inspection of Quarterly Vendor diesel and pump (i.e., engine hoses, Recommended.

clamps, connections, etc.)

Similar to quarterly surveillance, plus Annual Vendor hoses are attached to the suction and Recommended.

discharge of the pump and run for 30 minutes. The pump is also run at elevated rpm to obtain flow vs, pressure data.

Pagers Tested weekly to verify that pagers used Weekly Based on plant for Emergency Response are functional. experience.

Cell Phone Ensure the functionality of the Emergency Every other Based on plant Operations Facility cellular telephone. month experience.

Radios Check the functionality of the radios every Quarterly Based on plant quarter. experience.

Prairie Island Nuclear Generating Plant

~ ~ u i b e n t Surveillances Periodicity Basis Fire Hoses Fire hoses are hydrostatically tested Biennially 10 CFR 50 and every two years, except the hose on the Appendix R and Adapters turbine building roof which is tested plant annually. experience.

Inspect fire hoses and gaskets. Biennially Based on plant experience.

In regards to question 2.c1The 10 CFR 50 Appendix B Corrective Action Program (CAP) is used to document failures, establish priorities for corrective actions and perform trending. When an issue is identified, a CAP Action Request (AR) is initiated, a management review team determines level of review required, and corrective actions are determined and implemented in accordance with the significance.

Page 6 of 13

Prairie Island Nuclear Generating Plant Request:

3. Describe in detail the controls for assuring that the equipment is available when needed.

Examples of the types of information to include when providing your response to Question (3) are:

a. A description of any inventory requirements established for the equipment.
b. A listing of deficiencies noted in inventories for the equipment and corrective actions taken to prevent loss.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

In.addition to the controls described in responses 1 and 2, procured non -

permanently installed B.5.b equipment is inventoried quarterly in accordance with plant processes or procedures. This inventory assures the items are stored in the proper quantities and location. Access to equipment storage locations is controlled by postings on lockers and trailers where they are stored, citing the equipment is designated for use only for B.5.b scenarios.

lnventory deficiencies are entered into the CAP. As of the date of this response, there are no outstanding inventory deficiencies that would render the strategies not viable.

Table 3 Inventories Equipment Inventory Special Actions Performed Frequency Storage Controls Carts, trucks and trailers for Quarterly Indoors, Verify proper staging equipment Heated quantities Portable Diesel Fire Pump and Quarterly Indoors, Verify proper battery charger Heated quantities Set(s) of wheel chocks Quarterly Indoors, Verify proper Heated quantities Floating suction strainer and Quarterly Indoors, Verify proper suction hose Heated quantities steak Generator fill connector Quarterly Indoors, Verify proper Heated quantities Reverse Osmosis connector for Quarterly Indoors, Verify proper Refueling Water Storage Tank fill Heated quantities Page 7 of 13

Prairie Island Nuclear Generating Plant Equipment Inventory Special Actions Performed Frequency Storage Controls Fire Hose (6, 5, 4, 2 % and 1-112 - Quarterly Indoors, Verify proper inch) nozzles, valves, adapters, Heated quantities splitters, monitors, manifolds, strainer, connectors, wrenches, etc.

DllD2 connector (replaces spool Quarterly Indoors, Verify proper pieces) Heated quantities Deepwell supply connector for Quarterly Indoors, Verify proper D l ID2 cooling Heated quantities 5-inch discharge flow indicator Quarterly Indoors, Verify proper Heated quantities 125 VDC Battery Cart Quarterly Indoors, Verify proper Heated quantities Turnout gear ( coats, pants, Quarterly Indoors, Verify proper helmets, gloves, boots) Heated quantities Self-contained Breathing Quarterly Indoors, Verify proper Apparatuslmasksltanks Heated quantities Radios and chargers Quarterly Indoors, Verify proper Heated quantities Portable lights (flashlights, quartz Quarterly Indoors, Verify proper lights, halogen lights, etc.) Heated quantities Dosimetry Quarterly Indoors, Verify proper Heated quantities Tools (extension cords, hand tools, Quarterly Indoors, Verify proper specialty tools, etc) Heated quantities Rescue equipmentlmedical Quarterly Indoors, Verify proper supplies Heated quantities Fuel oil for Portable Diesel Fire Quarterly Indoors, Verify proper Pump Heated quantities Page 8 of 13

Prairie Island Nuclear Generating Plant Request:

4. Describe in detail how configuration and guidance management is assured so that strategies remain feasible.

Examples of the types of information to include when providing your response to Question (4) are:

. a. Measures taken to evaluate any plant configuration changes for their effect on feasibility of the mitigating strategies.

b. Measures taken to validate that the procedures or guidelines developed to support the strategies can be executed. These measures could include drills, exercises, or walk through of the procedures by personnel that would be expected to accomplish the strategies.
c. Measures taken to ensure procedures remain up-to-date and consistent with the current configuration of the plant.
d. A description of the training program implemented in support of the mitigating strategies and the manner in which you evaluate its effectiveness.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

Plant configuration changes are procedurally evaluated against the licensing basis, including the license conditions and their associated safety evaluation.

Initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews. Subsequent procedure changes are validated to ensure that the guideline remains viable. In 201 1, B.5.b mitigating strategies were revalidated by similar techniques. The training discussed below also validates that the associated mitigating strategies can be deployed.

The design change process requires a review of affected procedures and any necessary changes to be made.

The mitigating strategy guidelines are controlled consistent with procedural controls under established administrative processes.

The following table describes the training program implemented in support of the mitigating strategies and the manner in which effectiveness is evaluated.

Page 9 of 13

Prairie Island Nuclear Generating Plant Table 4 - Training Plant Training Periodicity Evaluation Personnel Non-Licensed Training on the Non-Licensed Operator 3 years Testing I Operators role in implementing Extensive Damage Qualification Mitigation Guidelines (EDMG) is part of the Initial Non-Licensed Operator Training programs and retrained per the NLO continuing training plan.

Licensed Licensed Operators are initially trained 2 years Testing and Operators on EDMGs per the Initial Licensed DrillsIExercises Operator training program. Licensed Operators are retrained per the biennial training plan as described in the Licensed Operator Requalification Training Program Description.

Fire Brigade Fire Brigade members are Non-Licensed 3 Years Testing Operators and are initially trained in EDMGs. Refresher training on B.5.b events is offered every 3 years.

Emergency The Emergency Response Organization None Qualification Reponse (ERO) qualified decision makers receive Organzation - initial training on EDMGs. However, Key Decision NSPM currently has no procedural Makers requirements to provide continuing training. NSPM recognizes the need for ongoing training for its qualified decision makers. Therefore, NSPM makes the following commitment for the PINGP:

NSPM will include a requirement for continuing training on EDMGs in the PINGP training program for the ERO qualified decision makers by January 13, 2012.

Security Training on mitigating strategies was 2 Years Testing done as part of the implementation of B.5.b. Security EDMG actions are incorporated into Security Implementing Procedures, Contingency Plan Implementing Procedure and site procedures that are trained in initial training and are re-qualified per the Security Training Program Description.

Page 10 of 13

Prairie Island Nuclear Generating Plant Request:

5. Describe in detail how you assure availability of off-site support.

Examples of the types of information to include when providing your response to Question (5) are:

a. A listing of off-site organizations you rely on for emergency response.
b. Measures taken to ensure the continuity of memoranda of agreement or understanding or other applicable contractual arrangements. This should include a listing of periods of lapsed contractual arrangements.
c. A listing of any training or site familiarization provided to off-site responders. This should include any measures taken to ensure continued familiarity of personnel of the off-site responders in light of turnover and the passage of time.

These examples are not meant to limit your response if you use other methods to address the issues described above.

NSPM Response:

The following off-site organizations in Table 5 are relied on for emergency response.

Table 5 - Offsite Organizations Off-site Organization Implementing Date of Training1 Periodicity Document Agreement State of Minnesota Letter of 1211712008 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

State of Wisconsin Letter of 101612010 Annual training provided by Agreement the State of Wisconsin as stated in Wisconsin Emergency Operations Plan.

City of Red Wing Letter of 21241201 1 Annual training for the Red (includes Red Wing Agreement Wing Fire Department is Fire Department) provided by the site and the State of Minnesota. Annual training is provided to the City of Red Wing via the Minnesota Emergency Operations Plan.

Dakota County Letter of 41281201 1 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

Page 11.of 13

Prairie Island Nuclear Generating Plant Off-site Organization Implementing Date of Training1 Periodicity Document Agreement Goodhue County Letter of 1111112010 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

Pier~e County Letter of 1/4/2011 Initial and annual training is Agreement provided by Pierce County as stated in the Pierce County Emergency Operations Plan.

Fairview Red Wing Letter of 3/18/2010 Annual training is provided by Hospital Agreement the site.

Sacred Heart Hospital Letter of 311812010 Annual training provided by Agreement the Wisconsin Department of Health Services.

Prairie Island Indian Letter of 1/31/2011 NSPM supports emergency Community Agreement response services provided by the Prairie Island Indian Community, including providing training.

Regions Hospital Letter of 6/7/2011 Annual training provided by Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

North Memorial Letter of 10/2512010 Annual training provided by Medical Center Agreement the State of Minnesota as stated in Minnesota Emergency Operations Plan.

Westinghouse Letter of 10/12/2010 N/A Agreement Canadian Pacific Letter of 312512010 NIA Railway Agreement Institute of Nuclear Letter of 9/30/2010 N/A Power Operations Agreement (INPO)

Environmental, Inc. Letter of 10/5/2010 N/A Midwest Laboratory Agreement Pooled Inventory Letter of 1211512010 N/A Management Agreement Department of Energy- Letter of 9/29/2010 N/A Radiation Emergency Agreement Assistance CenteriTraining Site Page 12 of 13

Prairie Island Nuclear Generating Plant All Letters of Agreement are reviewed annually by procedure to ensure they are current and are renewed periodically.

NSPM reviewed the corrective action program for issues involving lapsed Letters of Agreement related to B.5.b and found no examples of lapsed contractual agreements. All of the Letters of Agreement identified above meet the procedural requirements for renewal.

Page 13 of 13

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