ML22124A045

Submittal of Revision 37 to Updated Safety Analysis Report, Cover Letter and Information on Enclosures

ML22124A045
Person / Time
Site:	Prairie Island
Issue date:	04/28/2022
From:	Hanson H Xcel Energy, Northern States Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22124A040	List: L-PI-22-001, 7 to Updated Safety Analysis Report, Enclosure 4, Bases Changes and License Amendments ML22124A045
References
L-PI-22-001
Download: ML22124A045 (14)

Text

ENCLOSURE 2 CONTAINS SECURITY - RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390 Xcel Energy 1717 Wakonade Drive Welch, MN 55089 April 28, 2022 L-Pl-22-001 10 CFR 50.59(d)(2) 10 CFR 50.71(e)(4) 10 CFR 54.37(b)

T.S 5.5.12(d)

ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Docket Nos. 50-282 and 50-306 Renewed Facility Operating License DPR-42 and DPR-60 Updated Safety Analysis Report (USAR) Revision 37 Pursuant to 10CFR 50 .71 (e)(4) and Nuclear Regulatory Commission (NRC) specific exemption granted May 22, 2006 (ADAMS Accession Number ML061110032), Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM") , by this letter submits USAR, Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2. , Information Regarding Changes to the USAR, identifies those changes made based on approved license amendments, changes made under the provisions of 10 CFR 50.59, 10 CFR 50.46 , and editorial changes including deletion of particular information and the basis for that deletion. contains Revision 37 of the PINGP USAR. The USAR is being submitted electronically, in its entirety, on CD-ROM according to the instructions in Regulatory Issues Summary (RIS) 2001-005, "Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-ROM".

Consistent with the guidance in RIS 2007-16 , "Implementation of the Requirements of 10 CFR 54 .37(b) for Holders of Renewed Licenses" , Enclosure 3 contains a review of engineering .

changes, equipment list changes, USAR changes , changes to SSCs credited to 10 CFR 54.4(a)(3) regulated events, and changes to time limited aging analyses (TLAAs) was conducted for the review period from October 29, 2019 to October 18, 2021 . These changes were reviewed to identify components installed before June 27, 2011 that had not previously been screened or screened incorrectly for being in scope of License Renewal Aging Management. From the review, newly identified SSCs were found .

In accordance with TS 5.5.12 , "Technical Specifications (TS) Bases Control Program ," , contains the TS Bases for the Prairie Island Nuclear Generating Plant, Units 1 and 2, that includes the changes to the bases from Revisions 247 through 254 that have been implemented since the previous submittal. The TS Bases is being submitted electronically, in its entirety, on CD-ROM.

L-Pl-22-001 Page 2 of 2 contains a brief description and a summary of the safety evaluation for each of those changes, tests, and experiments made under the provisions of 10 CFR 50.59 during the period of ~pril 27, 2020 through present.

If there are any questions, please contact Ms. Pamela Johnson at 651-267-6829.

Summary of Commitments This letter contains no new commitments and one revision to existing commitments as listed below. The following commitment has been retired:

COMM 01009292 - Added provisions for an extended Completion Time for an inoperable EOG during the submittal of License Amendment Request (LAR) for Extension of Technical Specification (TS) 3.8.1, "AC Sources-Operating," Emergency Diesel Generator Completion Time (ADAMS Accession Number ML053260088). As noted in NSPM's license amendment request to adopt TSTF 505, Risk Informed Completion Time (RICT) (ADAMS Accession Number ML19350C188), this commitment is no longer required.

Harlan . Hanson Jr.

Plant Manager, Prairi sland Nucle enerating Plant Northern States Power Company - Minnesota Enclosures (5) cc: Regional Administrator, USNRC, Region Ill Project Manager, PINGP, USNRC,

.NRC Resident Inspector, PINGP USNRC State of Minnesota w/ENCL 1&5 only

ENCLOSURE 1 INFORMATION REGARDING CHANGES TO THE USAR 3 pages follow

ENCLOSURE 1 INFORMATION REGARDING CHANGES TO THE USAR Changes made to the Updated Safety Analysis Report (USAR) are identified in the following list by their input numbers (with which side-barred changes are denoted). Note that USAR Input Numbers can be searched on the USAR, Enclosure 2, to locate each change.

USAR Input Revised Basis Description No. Section Reflects changes made by ECR Figure 50.59 Screening 5610, 604000000314 601000001465, "PINGP Security 1.1-3 Rev. 0 Upgrades".

Alternate Screening Reflects changes made by ECR 604000000334 10 Criteria in IP-ENG-001, 601000001320, "Increase Control Attachment 5. Room Chiller Backup Air Supply".

Editorial change to state that the 604000000356 9 AD 7723, Rev 0 waste gas high level loop recombiner is not used.

The changes are related to CAP 50100003743 which noted that the USAR had not been updated 604000000431 7, 12 AD 7075, Rev 0 following implementation of Alternate Source Term (AST) methodology within ECR 6DOC00013720.

Goodhue Country changed to 604000000462 1 Ed itorial/I nconseq uential Goodhue County.

An incorrect statement identified by 604000000463 10 AD 7194, Rev 0 CAP 501000039298 on instrument air compressor operation was corrected.

Reference'to an outdated rigging 50.59 Screening 5689, equipment standard was replaced 604000000465 12 Rev 0 with reference to plant procedure D58 "Control of Heavy Loads".

Corrected containment leak rate test pressure and allowable leakage rate 604000000483 5 AD 7453, Rev 0 as documented in License Amendment 206/193.

Changes the amount of 12 wt/% boric 604000000500 T10.2-7 AD 7473, Rev 0 acid solution required to meet cold shutdown requirements.

1

- USAR Changes USAR Input Revised Basis Description No. Section Reflects piping flow path installed by 50.59 Screening 5666, ECR 601000002046, "Unit 1 RHR 604000000510 10 Rev 0 Purification Modification" for use in Modes 5, 6 and defueled.

Incorporates the NRG approved methodology PWROG-18034-P for analysis of the lower internals baffle 50.59 Evaluation 1154, 604000000511 3 assembly as documented by the NRR Rev 0 final safety evaluation ML20134M168 along with NRG required limitations for use.

Revises RV Surveillance Capsule 604000000517 4 AD 7537, Rev 0 withdrawal schedule as approved by the NRG in letter dated 9/30/2020.

Reflects changes made by ECR 604000000522 14 AD 7473, Rev 0 601000002047, "RCCA Ejection Analysis For Unit 1".

Change limit on Baffle Former Bolt Cycles to reflect NRG acceptance of TABLE 50.59 Screening 5685, WCAP-17586-P Rev 2, 604000000531 4.1-8 Rev 0 "Determination of Acceptable Baffle-Barrel Bojting for Prairie Island Units 1 and 2".

Change limit on Baffle Former Bolt 50.59 Screening 5685, 604000000532 App L Cycles to reflect acceptance of Rev 0 WCAP-17586-P Rev 2.

ECR 601000001267 updated USAR 50.59 Screening 5590, 604000000541 7 Section 7 with dose assessment Rev 0 results per QIM 501000041890.

Include newly identified SSCs in 604000000561 App L AD 8040, Rev 0 Appendix L. Also includes minor editorial chanQes.

Changes due to ECR 50.59 Screening 5236, 604000000565 8 6MOD00025120, "NFPA 805 -

Rev6 PINGP Station Unit 1, 2".

Changes reflecting NRG acceptance of WCAP-17586-P Rev 2, 50.59 Screening 5685, 604000000581 4 "Determination of Acceptable Baffle-Rev 0 Barrel Bolting for Prairie Island Units 1 and 2".

This clarifies which CIVs are 604000000586 7 Ed itorial/I nconseq uential monitored on the main control board as requested by QIM 501000051160.

2

- USAR Changes USAR Input Revised Basis Description No. Section AD 8011, Rev 0, 50.59 Adds discussion on Open Phase Screening 5335, Rev 0, Conditions and reflects changes 604000000670 8 50.59 Screening 5450, made by ECRs 6MOD00026784, Rev 1 6MOD00027249, 606000000926.

Adds details regarding the closeout of 604000000690 6 AD 8068, Rev 0 IEB 80-24.

Removes operability and availability 50.59 Screening 5735, statements from Section 8.4 in 604000000751 8 Rev 0 response to quality issue 501000057512.

This change prepares the USAR for 1, 2, 4, 5, ['JRC submittal by updating all figures 604000000752 6, 8, 9, 10, Editorial/Inconsequential that are controlled drawings and by 11, App I ensuring SUNSI information is properly labeled.

Summaries of evaluations prepared under the provisions of 10CFR 50.59 are submitted separately.

3

CONTAINS SECURITY - RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390 ENCLOSURE 2 UPDATED SAFETY ANLYSIS REPORT (USAR)

A COMPLETE COPY OF USAR REVISION 37 IS INCLUDED ON THE ENCLOSED CD-ROM

ENCLOSURE 3 REPORT CONSISTENT WITH 10CFR 54.37(b) 4 pages follow

ENCLOSURE 3 REPORT CONSISTENT WITH 10 CFR 54.37(b)

This summary report is in lieu of adding a level of detail to the Prairie Island Nuclear Generating Plant (PINGP) Updated Safety Evaluation Report (USAR) that is greater in the remainder of the USAR, including the License Renewal Supplement in Appendix L.

The contents of this report are consistent with the requirements of 10 CFR 54.37(b) and the guidance of Regulatory Issue Summary (RIS) 2007-16, "Implementation of the Requirements of 10 CFR 54.37(b) for Holders of Renewed Licenses" (ADAMS Accession Number ML100250279).

A review of engineering changes, equipment list changes, USAR changes, changes to SSCs credited for response to 10 CFR 54.4(a)(3) regulated events, and changes to time-limited aging analyses (TLAAs) was conducted for the review period from October 29, 2019 to October 18, 2021. These changes were reviewed to identify components installed before June 27, 2011 that had not previously been screened or screened incorrectly for being in scope of License Renewal Aging Management. The review process found eight valves in the plant Safeguards Chilled Water System (ZH), one valve in the Radiation Monitoring System (RD), and two valves in the Containment Ventilation System (ZC) added to the plant's equipment database whose component type, material, internal and/or external environments, aging effects, and associated aging management programs were not described in the applicable License Renewal Application (LRA) aging management evaluation tables. The list of the valves' functional locations (FLOCs) is as follows: *

• Pl:1:_ZH:ZH-26-1 (121 CONT RM CHLR CDSR CV-31769 FREON PRESS ISOL)

• Pl:1 :_ZH:ZH-26-2 (122 CONT RM CHLR CDSR CV-31785 FREON PRESS ISOL)

• Pl:1:_ZH:ZH-26-3 (121 CONT RM CHLR CDSR PRG RTRN ISOL)

• Pl:1 :~ZH:ZH-26-4 (122 CONT RM CHLR CDSR PRG RTRN ISOL)

• Pl:1:_ZH:ZH-26-5 (121 CONT RM CHLR CDSR PRG SPLY ISOL)

• Pl:1 :_ZH:ZH-26-6 (122 CONT RM CHLR CDSR PRG SPLY ISOL)

• Pl:1:_ZH:ZH-26-7 (121 CONT RM EVAP PRESS ISOL)

• Pl:1 :_ZH:ZH-26-8 (122 CONT RM EVAP PRESS ISOL)

• Pl:0: RD:2RD-9-2, 2R-50 SMPL BLOWER DISCH EMERG 8-U SMPL CONN

• Pl:1 :_ZC:ZC-141-1, 121/122/123/124 CNTMT PRG EXHT FLTR Fl 5701301 HI INSTR ISOL

• Pl:1 :_ZC:ZC-141-2, 121/122/123/124 CNTMT PRG EXHT FLTR Fl 5701301 LO INSTR ISOL 1

ENCLOSURE 3 REPORT CONSISTENT WITH 10 CFR 54.37(b)

Aging Management discussion of ZH System brass valves:

The valve bodies of ZH-26-1 through ZH-26-8 were all found to be made of brass with internal environments of Freon (refrigerant) and external environments of plant indoor air-uncontrolled. While brass valve bodies in plant indoor air-uncontrolled external environments were listed in Table 3.3.2-5 (License Renewal Control Room and Miscellaneous Area Ventilation System), Freon internal environments were not. This makes the valves newly identified SSCs that would have been subject to aging management review or evaluation of time-limited aging analysis in accordance with 10 CFR 54.21.

Appropriate aging management for brass valve bodies in Freon internal environments was determined to be no aging management programs. This was based on brass being a copper alloy and copper alloy piping and fittings with Freon internal environments being assigned no aging management programs in LRA Table 3.3.2-5 (Control Room and Miscellaneous Ventilation System) due to not having aging effects requiring management. As mentioned before, brass valve bodies in plant indoor air-uncontrolled external environments were already found in LRA Table 3.3.2-5. No aging effects requiring aging management was also the evaluation in the table for this material/environment combination.

10 CFR 54.37(b) states that the FSAR update IAW 10 CFR 50.71(e) must describe how the effects of aging will be managed such that the intended function(s) in 10 CFR 54.4(b) will be effectively maintained during the period of extended operation. In the case of ZH valves in Freon internal environments, both their internal and external surfaces would not have any aging effects requiring aging management. Thus, no aging management programs will be assigned to them.

If the actual LRA Table 3.3.2-5 were updated for the new material and environment combination of the ZH valves discussed here, the addition would look like the following table entry below.

Summary of Addition to LRA Table 3.3.2-5 Component Intended Material Environment Aging Aging Type Function Effects Management Requiring Program Management Valve Pressure Brass Freon None None Bodies Boundary (Internal) 2

ENCLOSURE 3 REPORT CONSISTENT WITH 10 CFR 54.37(b)

Aging Management discussion of valve 2RD-9-2:

The body of valve 2RD-9-2 was determined to be cast austenitic stainless steel with an internal environment of plant indoor air-uncontrolled and an external environment also of plant indoor air-uncontrolled. Although stainless steel valve bodies in plant indoor air-uncontrolled (ext) environment are included in LRA Table 3.3.2-15 (Radiation Monitoring System), no cast austenitic stainless steel valve bodies in this environment were found in the table. Therefore, 2RD-9-2 is a newly identified SSC subject to aging management review.

The determination of appropriate aging management for cast austenitic stainless steel valve bodies in plant indoor air-uncontrolled is as follows: For another system, LRA Table 3.2.2-1 (Containment Spray System) lists no aging effects that require management for cast austenitic stainless steel valve bodies in plant indoor air-uncontrolled environments. Since aging effects are the same for the same materials in the same environments, it can safely be concluded that cast austenitic stainless steel valve bodies in the Radiation Monitoring System have no aging effects requiring management either. So, although 2RD-9-2 is a newly identified SSC subject to aging management review, the review determined that neither its internal nor its external surfaces require aging management for license renewal.

If the actual LRA Table 3.3.2-15 were updated for the new material and environment combination of 2RD-9-2 discussed here, the addition would look like the following table entry below.

• Summary of Addition to LRA Table 3.3.2-15 Component Intended Material Environment Aging Aging Type Function Effects Management Requiring Program Management Valve Pressure Cast Plant Indoor None None Bodies Boundary Austenitic Air-Stainless Uncontrolled Steel (Internal)

Plant Indoor None None Air-Uncontrolled (External) 3

ENCLOSURE 3 REPORT CONSISTENT WITH 10 CFR 54.37(b)

Aging Management discussion of valves ZC-141-1 and ZC-141-2:

The bodies of valves ZC-141-1 and ZC-141-2 were determined to be bronze with an internal environment of primary containment air and an external environment of plant indoor air-uncontrolled. Bronze or copper alloy valve bodies are not included in LRA Table 3.3.2-14 (Primary Containment Ventilation System). Therefore, ZC-141-1 and ZC-141-2 are newly identified SSCs subject to aging management review.

The determination of appropriate aging management for copper alloy valve bodies in primary containment air (int) and plant indoor air-uncontrolled (ext) is as follows: LRA Table 3.3.2-14 lists no aging effects requiring management for copper alloy piping/fittings in primary containment air (int) and plant indoor air-uncontrolled (ext) environments.

Since aging effects are the same for the same materials in the same environments, it can safely be concluded that copper alloy valve bodies in the Primary Containment Ventilation System have no aging effects requiring management either. So, although ZC-141-1 and ZC-141-2 are newly identified SSCs subject to aging management review, the review determined that neither their internal nor their external surfaces require aging management for license renewal.

If the actual LRA Table 3.3.2-14 were updated for the new material and environment combination of ZC-141-1 and ZC-141-2 discussed here, the addition would look like the following table entry below.

Summary of Addition to LRA Table 3.3.2-14 Component Intended , Material Environment Aging Aging Type Function Effects Management Requiring Program Management Valve Pressure Copper Primary None None Bodies Boundary Alloy Containment Air (Internal)

Plant Indoor None None Air-

• Uncontrolled (External) 4

ENCLOSURE 4 TECHNICAL SPECIFICATONS (TS) BASES CONTROL PROGRAM The TS Bases is being submitted electronically, in its entirely, on CD-ROM.

ENCLOSURE 5 PRAIRIE ISLAND NUCLAER GENERA TING PLANT REPORT OF CHANGES, TESTS, AND EXPERIMENTS 50.59 Evaluation No. 1154, Rev 0 - Change to Methodology for Evaluating Baffle-Former-Barrel Bolting Distributions (9/11/20)

Activity

Description:

The purpose of this evaluation is to incorporate, into the licensing basis as described in the UFSAR, the NRC approved methodology PWROG-18034-P-Aa, along with NRC required limitations for use described in the associated safety evaluation contained within the report.

This is an acceptable methodology for analysis of the lower internals baffle assembly as documented by the NRR final safety evaluation. Irradiated bolt material properties and bolt faulted condition stress acceptance criteria are defined by this methodology.

Summary of 50.59 Evaluation:

This activity does not require prior NRC approval as the methodology for evaluating the impact on fuel assembly structural integrity associated with a reduced number (less than 100 percent) of baffle-to-former and barrel-to-former bolts during faulted conditions discussed in PWROG-18034-P-Aa is an extension of the current methodology in WCAP-15029-P-A, is applicable to Prairie Island, and has. been previously approved by the NRC for application at 2-loop Pressurized Water Reactors (PWRs) such as Prairie Island Units 1 and 2.

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