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| {{#Wiki_filter:}} | | {{#Wiki_filter:From: Kuntz, Robert Sent: Monday, August 30, 2021 2:48 PM To: Kivi, Jeffrey L. |
| | Cc: Scott, Sara |
| | |
| | ==Subject:== |
| | Request for Additional Information RE: Amendment request to adopt TSTF-471 and 517-T for Prairie Island By {{letter dated|date=April 19, 2021|text=letter dated April 19, 2021}} (Agencywide Documents Access and Management System (ADAMS) at Accession No. ML21109A385) Northern States Power Company, doing business as Xcel Energy (Xcel Energy), requested an amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP) Units 1 and 2. The proposed amendment would adopt TSTF-471, Eliminate Use of the Term CORE ALTERATIONS in ACTIONS and Notes, with site-specific variations. The proposed change would eliminate the defined term CORE ALTERATIONS and all uses of the term from the TS and Bases. The proposed amendment would also adopt TSTF-571-T, Revise Actions for Inoperable Source Range Neutron Flux Monitor, which changes TS 3.9.3, Nuclear Instrumentation, to ensure that no actions are taken that could alter the core reactivity when a required core subcritical neutron flux monitor is inoperable. The Nuclear Regulatory Commission (NRC) staff has determined that additional information is required to complete the review of the amendment request. The following is the NRC staffs request for additional information (RAI). During a meeting for the staff to provide clarification on the draft RAI conducted on August 30, 2021 a 30 day response was agreed upon. Therefore, the NRC staff expects a response to this RAI by September 30, 2021. If Xcel Energy has any issues with providing the response contact me. |
| | Robert Kuntz Senior Project Manager (Monticello and Prairie Island) |
| | NRC/NRR/DORL/LPL3 (301) 415-3733 REQUESTS FOR ADDITIONAL INFORMATION ADOPTION OF TSTF-471 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306 REGULATORY BASIS Part 50.36, "Technical Specifications," of Title 10 of the Code of Federal Regulations requires, in part, that the operating license of a nuclear production facility include TS. Paragraph 50.36(c)(2) of Title 10 of the Code of Federal Regulations requires, in part, that the TS include limiting conditions for operation (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS, until the condition can be met. |
| | Appendix A to 10 CFR 50 establishes minimum criteria (General Design Criteria or GDC) for the design of light water reactors. GDC 13 requires that instrumentation be provided to monitor |
| | |
| | variables over anticipated ranges for normal operations, for anticipated operational occurrences, and for accident conditions. |
| | Prairie Island Nuclear Generating Plant (PINGP) was not licensed to the 10 CFR 50, Appendix A GDC. PINGP was designed and constructed to comply with the licensees understanding of the intent of the AEC General Design Criteria (AEC GDC) for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. Since the construction of the plant was significantly completed prior to the issuance of the February 20, 1971, 10 CFR 50, Appendix A GDC, the plant was not reanalyzed and the Updated Safety Analysis Report (USAR) was not revised to reflect these later criteria. However, the AEC Safety Evaluation Report acknowledged that the AEC staff assessed the plant, as described in the USAR, against the Appendix A design criteria and ... are satisfied that the plant design generally conforms to the intent of these criteria. GDC 13 is equivalent to AEC GDC 12 and 13. |
| | |
| | ===RAI-1=== |
| | The amendment proposes to remove Required Action C.2 from LCO 3.9.3. This Required Action is included in the PINGP technical specifications, but not in the standard technical specifications for Westinghouse plants. Since Technical Specification Task Force (TSTF) |
| | Traveler TSTF-471 was written to modify standard technical specifications (TSs), it does not refer to this Required Action. |
| | This action requires suspension of core alterations when one required core subcritical neutron flux monitor audible count rate circuit is inoperable. However, the basis for this limiting condition of operation states that audible count rate circuits serve to alert the operator in containment in the event of a dilution accident or improperly loaded fuel assembly, as noted in Section 3.1 of the amendment request. The amendment request also stated that considering an improperly loaded fuel assembly in discussion of the audible count rate circuit is not consistent with the rest of the PINGP TS 3.9.3 bases. |
| | Request Describe the portions of PINGPs licensing basis that consider improper loading of a fuel assembly and explain why these basis support removal of Required Action C.2. |
| | |
| | ===RAI-2=== |
| | Technical or Regulatory Issue In the current TSs, Required Action C.2 of LCO 3.9.3 requires that core alterations be suspended if one required core subcritical neutron flux monitor audible count rate circuit is inoperable. The current LAR proposes to remove this Required Action. Section TS 3.9.3, Required Actions A.1 and C.2 of the LAR, states that this Required Action has no effect on the initial conditions or mitigation of a boron dilution accident. However, as written, the proposed change would allow for positive reactivity additions when in Condition C. This contradicts the statement in section TS 3.9.1 of the LAR that suspending positive reactivity additions is the only action needed to mitigate a boron dilution event. It also appears to be inconsistent with TSTF-471, which explains that suspending core alterations provides no safety benefit if Required Actions that suspend core alterations also suspend movement of recently irradiated fuel. The proposed Required Actions in Condition C would not require suspension of movement of recently irradiated fuel. |
| | |
| | Request Please clarify why a requirement to suspend positive reactivity additions or movement of recently irradiated fuel is not needed to replace the requirement to suspend core alterations in Condition C of LCO 3.9.3, and why this change would have no effect on the initial conditions or mitigation of a boron dilution accident in this condition. |
| | |
| | Hearing Identifier: NRR_DRMA Email Number: 1329 Mail Envelope Properties (SA9PR09MB4640A454FA74CFC4EC2497EF99CB9) |
| | |
| | ==Subject:== |
| | Request for Additional Information RE: Amendment request to adopt TSTF-471 and 517-T for Prairie Island Sent Date: 8/30/2021 2:48:19 PM Received Date: 8/30/2021 2:48:00 PM From: Kuntz, Robert Created By: Robert.Kuntz@nrc.gov Recipients: |
| | "Scott, Sara" <sara.scott@xcelenergy.com> |
| | Tracking Status: None "Kivi, Jeffrey L." <jeffrey.l.kivi@xcelenergy.com> |
| | Tracking Status: None Post Office: SA9PR09MB4640.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 6168 8/30/2021 2:48:00 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:}} |
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Category:E-Mail
MONTHYEARML23348A3472023-12-12012 December 2023 NRR E-mail Capture - (External_Sender) NRC Notification to the State of Minnesota Regarding a Prairie Island Nuclear Generating Plant, Units 1 & 2, Amendment ML23335A1152023-12-0101 December 2023 NRR E-mail Capture - Prairie Island Units 1 and 2 - Request for Additional Information LAR to Revise TS 3.7.8 Required Actions ML23312A0882023-11-0808 November 2023 Acceptance of Request to Revise Alternatives 1-RR-5-10 and 2-RR-5-10 ML23248A3462023-09-0505 September 2023 NRR E-mail Capture - Request for Additional Information for Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant - Decommissioning Funding Status Reports ML23207A1962023-07-26026 July 2023 NRR E-mail Capture - Prairie Island Units 1 and 2 - Acceptance of Requested Licensing Action Request to Revise Technical Specification 3.7.8 Required Actions ML23075A2802023-03-16016 March 2023 NRR E-mail Capture - Prairie Island Units 1 and 2 - Acceptance of Relief Requests 1-RR-5-15 and 2-RR-5-15 to Use Subsequent ASME Code Edition and Addenda ML23065A0592023-02-27027 February 2023 NRR E-mail Capture - (External_Sender) Prairie Island Request for Pre-application Meeting for Proposed LAR to Change TS 3.7.8, Condition B Required Actions ML23018A2952023-01-18018 January 2023 Acceptance of Requested Licensing Action to Revise Technical Specification 5.6.6, Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR) (EPID L-2022-LLA-0184) (Email) ML22167A0452022-06-16016 June 2022 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action Request to Adopt TSTF-277 ML22166A4112022-06-15015 June 2022 NRR E-mail Capture - Request for Additional Information Prairie Island Nuclear Generating Plant, Unit 2, Alternative RR-08, PIV Leakage ML22160A6022022-06-0909 June 2022 NRR E-mail Capture - Draft Request for Additional Information Prairie Island Nuclear Generating Plant, Units 1 and 2, 24-Month Operating Cycle Amendment ML22131A2652022-05-11011 May 2022 NRR E-mail Capture - Request for Additional Information Xcel Energy Amendment Request to Create a Common Eplan and EOF for Monticello and Prairie Island ML22045A4972022-02-14014 February 2022 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Unit 2 - Acceptance of Alternative Request Alternative Related PIV Leakage Monitoring ML21347A0082021-12-10010 December 2021 NRR E-mail Capture - Monticello and Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested License Amendment Standard Emergency Plan and Consolidated Emergency Operations Facility ML21321A0452021-11-10010 November 2021 Request for Additional Information: Prairie Island 24-Month Cycle Amendment Request ML21302A1252021-10-29029 October 2021 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action RTS Power Range Amendment ML21305A0102021-10-29029 October 2021 NRR E-mail Capture - Request for Additional Information Prairie Island Cooling Water Amendment ML21252A0152021-09-0202 September 2021 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action Change in the Maximum Surveillance Intervals from 24 Months to 30 Months ML21252A0122021-08-30030 August 2021 NRR E-mail Capture - Request for Additional Information Amendment Request to Adopt TSTF-471 and 517-T for Prairie Island ML21133A2502021-05-13013 May 2021 NRR E-mail Capture - Prairie Island - Acceptance Review of TSTF-471 and TSTF-571-T ML20343A1292020-12-0808 December 2020 NRR E-mail Capture - Request for Additional Information ML20253A2782020-09-0909 September 2020 E-Mail Submitting Proposed New License Condition ML20254A1162020-09-0909 September 2020 Draft License Transmittal E-Mail ML20223A0632020-08-10010 August 2020 Email Shpo Comment Letter: Proposed License Amendment for the Prairie Island Independent Spent Fuel Storage Installation ML20192A1442020-07-0707 July 2020 NRR E-mail Capture - Request for Additional Information Prairie Island License Amendment Request to Adopt TSTF-505 ML20163A4282020-06-10010 June 2020 Email from MPCA Comment Letter - Prairie Island ISFSI ML20154K7632020-06-0202 June 2020 NRR E-mail Capture - Revision 2 to the Plan for the Audit of the Prairie Island Nuclear Generating Plant TSTF-505 License Amendment Request (Epdi: L-2019-LLA-0283) ML20135G8212020-05-14014 May 2020 NRR E-mail Capture - Revision to the Plan for the Audit of the Prairie Island Nuclear Generating Plant TSTF-505 License Amendment Request (Epdi: L-2019-LLA-0283) ML20112F4582020-04-21021 April 2020 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action Low Temperature Overpressure Protection ML20083F4202020-03-20020 March 2020 NRR E-mail Capture - Plan for the Audit of the Prairie Island Nuclear Generating Plant TSTF-505 License Amendment Request (Epdi: L-2019-LLA-0283) ML20077L4632020-03-17017 March 2020 NRR E-mail Capture - Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant, Units 1 and 2 -Acceptance of Requested Licensing Action Request to Adopt TSTF-529 ML20052C7582020-02-21021 February 2020 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action Westinghouse NSAL-09-05 and NSAL-09-05 ML20035F1552020-02-0404 February 2020 NRR E-mail Capture - Request for Additional Information Monticello and Prairie Island Alternative Requests to Adopt Code Cases N-786-3 and N-789-3 (Epids: L-2019-LLR-0078 and L-2019-LLR-0079) ML20022A1762020-01-22022 January 2020 NRR E-mail Capture - Prairie Units 1 and 2 - Acceptance of Requested Licensing Action Application to Revise Technical Specifications to Adopt TSTF-547, Clarification of Rod Position Requirements ML20021A1832020-01-21021 January 2020 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2 ML19316A0172019-11-0101 November 2019 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action Integrated Leak Rate Test Extension Request ML19253B9642019-09-10010 September 2019 NRR E-mail Capture - Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Relief Request Adoption of Code Case N-786-3 ML19233A0032019-08-14014 August 2019 NRR E-mail Capture - Request for Additional Information Prairie Island Relief Requests 1-RR-10 and 2-RR-10 ML19193A0142019-07-0909 July 2019 NRR E-mail Capture - Acceptance of Prairie Island Nuclear Generating Plant, Units 1 and 2 Relief Request Nos. 1-RR-5-10 and 2-RR-5-10 Related to Reactor Vessel Inspection Intervals) ML19057A1652019-02-26026 February 2019 NRR E-mail Capture - Request for Additional Information Prairie Island 50.69 Amendment Request ML19057A4212019-02-26026 February 2019 NRR E-mail Capture - Acceptance of Prairie Island Reactor Vessel Capsule Removal Schedule Request ML19008A3562019-01-0707 January 2019 NRR E-mail Capture - Prairie Island Nuclear Generating Plant - Audit Plan Related to the License Amendment Request to Implement 10 CFR 50.69 ML18351A0142018-12-14014 December 2018 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action Classification of Certain Fuel Handling Equipment ML18347A3282018-12-12012 December 2018 E-Mail from M. Krick/Sses SSES ISFSI (Conversation Held on December 12, 2018) ML18313A0832018-11-0707 November 2018 NRR E-mail Capture - Request for Additional Information Prairie Island NFPA-805 License Condition Modification Amendment Request ML18235A2982018-08-23023 August 2018 NRR E-mail Capture - Request for Additional Information Prairie Island TSTF-425 License Amendment Request ML18233A3692018-08-21021 August 2018 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action Adoption of 10 CFR 50.69 ML18201A4132018-07-20020 July 2018 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action Amendment to Adopt TSTF-439 ML18159A3052018-06-0808 June 2018 NRR E-mail Capture - Monticello - Acceptance of Requested Relief Request RR-012: Lnservice Inspection Impracticality in Accordance with 10 CFR 50.55a(g)(5)(iii) During the Fifth Ten-Year Interval ML18113A2252018-04-23023 April 2018 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance of Requested Licensing Action Amendment to Adopt TSTF-425 2023-09-05
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23335A1152023-12-0101 December 2023 NRR E-mail Capture - Prairie Island Units 1 and 2 - Request for Additional Information LAR to Revise TS 3.7.8 Required Actions ML23248A3462023-09-0505 September 2023 NRR E-mail Capture - Request for Additional Information for Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant - Decommissioning Funding Status Reports ML23214A2032023-08-0202 August 2023 Request for Information for an NRC Quadrennial Comprehensive Engineering Team Inspection: Inspection Report 05000282/2024010; 05000306/2024010 ML23199A0922023-07-18018 July 2023 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000306/2023004 ML23096A3082023-04-0707 April 2023 Notification of Inspection an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information ML23055B0562023-02-27027 February 2023 Request for Information for NRC Commercial Grade Dedication Inspection Inspection Report 05000282/2023010 and 05000306/2023010 ML23053A1432023-02-22022 February 2023 Information Request to Support Upcoming Problem Identification and Resolution (Pi&R) Inspection at Prairie Island Nuclear Generating Plant ML22166A4112022-06-15015 June 2022 NRR E-mail Capture - Request for Additional Information Prairie Island Nuclear Generating Plant, Unit 2, Alternative RR-08, PIV Leakage ML22160A6022022-06-0909 June 2022 NRR E-mail Capture - Draft Request for Additional Information Prairie Island Nuclear Generating Plant, Units 1 and 2, 24-Month Operating Cycle Amendment ML22145A4152022-05-25025 May 2022 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000282/2022402 05000306/2022402 ML22131A2652022-05-11011 May 2022 NRR E-mail Capture - Request for Additional Information Xcel Energy Amendment Request to Create a Common Eplan and EOF for Monticello and Prairie Island ML22130A5792022-05-11011 May 2022 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection ML21321A0452021-11-10010 November 2021 Request for Additional Information: Prairie Island 24-Month Cycle Amendment Request ML21305A0102021-10-29029 October 2021 NRR E-mail Capture - Request for Additional Information Prairie Island Cooling Water Amendment ML21252A0122021-08-30030 August 2021 NRR E-mail Capture - Request for Additional Information Amendment Request to Adopt TSTF-471 and 517-T for Prairie Island ML21147A5232021-06-0303 June 2021 Prarie Island Nuclear Generating Plant, Units 1 and 2 - Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection ML21131A0752021-05-10010 May 2021 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000282/2021004; 05000306/2021004 ML21099A0972021-04-0909 April 2021 Information Request to Support Upcoming Temporary Instruction 2515/194 Inspection; Inspection Report 05000282/2021012 and 05000306/2021012 ML21062A0532021-03-0202 March 2021 Information Request to Support Upcomng Problem Identification and Resolution (Pi&R) Inspection at the Prairie Island Nuclear Generating Plant ML21033A6112021-02-0101 February 2021 Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000282/2021010 and 05000306/2021010 ML20343A1292020-12-0808 December 2020 NRR E-mail Capture - Request for Additional Information ML20192A1442020-07-0707 July 2020 NRR E-mail Capture - Request for Additional Information Prairie Island License Amendment Request to Adopt TSTF-505 ML20189A1782020-07-0606 July 2020 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000282/2020004; 05000306/2020004 ML20133K0692020-05-14014 May 2020 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection ML20077K6242020-04-13013 April 2020 License Amendment Request - Request for Additional Information ML20052F4102020-02-21021 February 2020 Notification of Nrc Design Bases Assurance Inspection (Programs) (05000282/202010; 05000306/202010) and Initial Request for Information ML20035F1552020-02-0404 February 2020 NRR E-mail Capture - Request for Additional Information Monticello and Prairie Island Alternative Requests to Adopt Code Cases N-786-3 and N-789-3 (Epids: L-2019-LLR-0078 and L-2019-LLR-0079) ML19233A0032019-08-14014 August 2019 NRR E-mail Capture - Request for Additional Information Prairie Island Relief Requests 1-RR-10 and 2-RR-10 ML19057A1652019-02-26026 February 2019 NRR E-mail Capture - Request for Additional Information Prairie Island 50.69 Amendment Request ML18313A0832018-11-0707 November 2018 NRR E-mail Capture - Request for Additional Information Prairie Island NFPA-805 License Condition Modification Amendment Request ML18264A1912018-09-19019 September 2018 NRC Information Request (9/19/2018); Part B Items (Onsite) IP 71111.08 - E-Mailed 09/19/18 (DRS-M.Holmberg) ML18235A2982018-08-23023 August 2018 NRR E-mail Capture - Request for Additional Information Prairie Island TSTF-425 License Amendment Request ML18169A4202018-06-25025 June 2018 Supplemental Information Needed for Acceptance of Requested Licensing Action Amendment to Modify Renewed Facility Operating License Paragraph 2.C(4)(c) ML18025C0152018-01-24024 January 2018 Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team): Inspection Report 05000282/2018011; 05000306/2018011 (DRS-A.Dunlop) ML17277B3332017-10-0404 October 2017 NRR E-mail Capture - Request for Additional Information Prairie Island Special Heavy Lifting Devices LAR ML17249A9232017-09-0606 September 2017 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000282/2017004; 05000306/2017004 (Exf) ML17235A9982017-08-23023 August 2017 NRR E-mail Capture - Request for Additional Information Prairie Island EAL Scheme Change ML17221A3892017-08-0909 August 2017 NRR E-mail Capture - Request for Additional Information for Prairie Island Nuclear Generating Plant License Amendment Request Dated February 23, 2017 Emergency Response Organization ML17219A0762017-08-0707 August 2017 NRR E-mail Capture - Request for Additional Information for Prairie Island Nuclear Generating Plant License Amendment Request Dated February 23, 2017 Emergency Response Organization ML17038A5132017-02-0707 February 2017 NRR E-mail Capture - Prairie Island NFPA 805 LAR, PRA RAI 21.01 ML17018A4272017-01-18018 January 2017 NRR E-mail Capture - Request for Additional Information: Prairie Island License Amendment Request to Revise Technical Specification 3.8.7 to Remove Non-Conservative Required Action ML16326A3532016-11-18018 November 2016 NRR E-mail Capture - Draft Request for Information Related to Prairie Island NFPA-805 License Amendment ML16265A1652016-09-20020 September 2016 Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information; Inspection Report 05000282/2016004; 05000306/2016004 (Gfo) ML16189A2052016-07-0707 July 2016 Notification of NRC Inspection and Request for Information ML16113A1612016-04-21021 April 2016 Information Request to Support Upcoming Problem Identification and Resolution (Pi&R) Inspection at Prairie Island Nuclear Generating Plant, Units 1 and 2 ML16075A0802016-03-15015 March 2016 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 Request for Additional Information Related to License Amendment Request to Adopt TSTF-523, GL 2008-01, Managing Gas Accumulation ML16008A1092016-01-0808 January 2016 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - Requests for Additional Information (Afpb) License Amendment Request to Adopt NFPA 805 ML15195A6562015-07-10010 July 2015 Prairie Island Notification of NRC Inspection and Request for Information ML15149A1662015-05-28028 May 2015 Plan - Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection (Mxg) ML15121A6512015-04-29029 April 2015 Request for Information for an NRC Triennial Baseline Component Design Bases Inspection (CDBI) Inspection Report 05000282/2015007; 05000306/2015007 (Jen) 2023-09-05
[Table view] |
Text
From: Kuntz, Robert Sent: Monday, August 30, 2021 2:48 PM To: Kivi, Jeffrey L.
Cc: Scott, Sara
Subject:
Request for Additional Information RE: Amendment request to adopt TSTF-471 and 517-T for Prairie Island By letter dated April 19, 2021 (Agencywide Documents Access and Management System (ADAMS) at Accession No. ML21109A385) Northern States Power Company, doing business as Xcel Energy (Xcel Energy), requested an amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP) Units 1 and 2. The proposed amendment would adopt TSTF-471, Eliminate Use of the Term CORE ALTERATIONS in ACTIONS and Notes, with site-specific variations. The proposed change would eliminate the defined term CORE ALTERATIONS and all uses of the term from the TS and Bases. The proposed amendment would also adopt TSTF-571-T, Revise Actions for Inoperable Source Range Neutron Flux Monitor, which changes TS 3.9.3, Nuclear Instrumentation, to ensure that no actions are taken that could alter the core reactivity when a required core subcritical neutron flux monitor is inoperable. The Nuclear Regulatory Commission (NRC) staff has determined that additional information is required to complete the review of the amendment request. The following is the NRC staffs request for additional information (RAI). During a meeting for the staff to provide clarification on the draft RAI conducted on August 30, 2021 a 30 day response was agreed upon. Therefore, the NRC staff expects a response to this RAI by September 30, 2021. If Xcel Energy has any issues with providing the response contact me.
Robert Kuntz Senior Project Manager (Monticello and Prairie Island)
NRC/NRR/DORL/LPL3 (301) 415-3733 REQUESTS FOR ADDITIONAL INFORMATION ADOPTION OF TSTF-471 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306 REGULATORY BASIS Part 50.36, "Technical Specifications," of Title 10 of the Code of Federal Regulations requires, in part, that the operating license of a nuclear production facility include TS. Paragraph 50.36(c)(2) of Title 10 of the Code of Federal Regulations requires, in part, that the TS include limiting conditions for operation (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS, until the condition can be met.
Appendix A to 10 CFR 50 establishes minimum criteria (General Design Criteria or GDC) for the design of light water reactors. GDC 13 requires that instrumentation be provided to monitor
variables over anticipated ranges for normal operations, for anticipated operational occurrences, and for accident conditions.
Prairie Island Nuclear Generating Plant (PINGP) was not licensed to the 10 CFR 50, Appendix A GDC. PINGP was designed and constructed to comply with the licensees understanding of the intent of the AEC General Design Criteria (AEC GDC) for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. Since the construction of the plant was significantly completed prior to the issuance of the February 20, 1971, 10 CFR 50, Appendix A GDC, the plant was not reanalyzed and the Updated Safety Analysis Report (USAR) was not revised to reflect these later criteria. However, the AEC Safety Evaluation Report acknowledged that the AEC staff assessed the plant, as described in the USAR, against the Appendix A design criteria and ... are satisfied that the plant design generally conforms to the intent of these criteria. GDC 13 is equivalent to AEC GDC 12 and 13.
RAI-1
The amendment proposes to remove Required Action C.2 from LCO 3.9.3. This Required Action is included in the PINGP technical specifications, but not in the standard technical specifications for Westinghouse plants. Since Technical Specification Task Force (TSTF)
Traveler TSTF-471 was written to modify standard technical specifications (TSs), it does not refer to this Required Action.
This action requires suspension of core alterations when one required core subcritical neutron flux monitor audible count rate circuit is inoperable. However, the basis for this limiting condition of operation states that audible count rate circuits serve to alert the operator in containment in the event of a dilution accident or improperly loaded fuel assembly, as noted in Section 3.1 of the amendment request. The amendment request also stated that considering an improperly loaded fuel assembly in discussion of the audible count rate circuit is not consistent with the rest of the PINGP TS 3.9.3 bases.
Request Describe the portions of PINGPs licensing basis that consider improper loading of a fuel assembly and explain why these basis support removal of Required Action C.2.
RAI-2
Technical or Regulatory Issue In the current TSs, Required Action C.2 of LCO 3.9.3 requires that core alterations be suspended if one required core subcritical neutron flux monitor audible count rate circuit is inoperable. The current LAR proposes to remove this Required Action. Section TS 3.9.3, Required Actions A.1 and C.2 of the LAR, states that this Required Action has no effect on the initial conditions or mitigation of a boron dilution accident. However, as written, the proposed change would allow for positive reactivity additions when in Condition C. This contradicts the statement in section TS 3.9.1 of the LAR that suspending positive reactivity additions is the only action needed to mitigate a boron dilution event. It also appears to be inconsistent with TSTF-471, which explains that suspending core alterations provides no safety benefit if Required Actions that suspend core alterations also suspend movement of recently irradiated fuel. The proposed Required Actions in Condition C would not require suspension of movement of recently irradiated fuel.
Request Please clarify why a requirement to suspend positive reactivity additions or movement of recently irradiated fuel is not needed to replace the requirement to suspend core alterations in Condition C of LCO 3.9.3, and why this change would have no effect on the initial conditions or mitigation of a boron dilution accident in this condition.
Hearing Identifier: NRR_DRMA Email Number: 1329 Mail Envelope Properties (SA9PR09MB4640A454FA74CFC4EC2497EF99CB9)
Subject:
Request for Additional Information RE: Amendment request to adopt TSTF-471 and 517-T for Prairie Island Sent Date: 8/30/2021 2:48:19 PM Received Date: 8/30/2021 2:48:00 PM From: Kuntz, Robert Created By: Robert.Kuntz@nrc.gov Recipients:
"Scott, Sara" <sara.scott@xcelenergy.com>
Tracking Status: None "Kivi, Jeffrey L." <jeffrey.l.kivi@xcelenergy.com>
Tracking Status: None Post Office: SA9PR09MB4640.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 6168 8/30/2021 2:48:00 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: