ML14258A377

Audit of the Licensee'S Management of Regulatory Commitments, Audit Performed September 9-11, 2014 (TAC Nos. MF4414 and MF4415)

ML14258A377
Person / Time
Site:	Prairie Island
Issue date:	09/25/2014
From:	Wall S P Plant Licensing Branch III
To:	Davison K K Northern States Power Co, Xcel Energy
Wall S P
References
TAC MF4414, TAC MF4415
Download: ML14258A377 (21)

Text

Mr. Kevin K. Davison Site Vice President UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 25, 2014 Prairie Island Nuclear Generating Plant Northern States Power Company -Minnesota 1717 Wakonade Drive East Welch, MN 55089

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 -AUDIT OF THE LICENSEE'S REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NOS. MF4414 AND MF4415)

Dear Mr. Davison:

The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments.

RIS 2000-17 encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

An audit of Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, commitment management program was performed at the plant site on September 9-11, 2014. The NRC staff concludes, based on the audit, that Northern States Power Company-Minnesota (NSPM, the licensee).

doing business as Xcel Energy, Inc., has implemented NRC commitments on a timely basis, and the licensee has implemented an effective program for managing NRC commitment changes at PINGP, Units 1 and 2. The details of the audit including the NRC staff's observations and recommendations are set forth in the enclosed audit report.

K. Davison The NRC staff appreciates the resources that were made available by your staff for performing the audit. If you have any questions, please contact me at (301) 415-2855 or via e-mail at Scott.Wall@nrc.gov.

Docket Nos. 50-282 and 50-306

Enclosure:

Audit Report cc w/encl: Distribution via Listserv Sincerely, Scott P. Wall, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS NORTHERN STATES POWER COMPANY-MINNESOTA PRAIRIE ISLAND NUCLEAR GENERATING PLANT. UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306

1.0 INTRODUCTION

AND BACKGROUND In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that commitments are implemented and that changes to the commitments are evaluated and, when appropriate, reported to NRC. The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. An audit of Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, commitment management program was performed at the plant site on September 9-11, 2014. The audit reviewed commitments made since the previous audit on September 12-14, 2011 (audit report issued on December 19, 2011 (ADAMS Accession No. ML 112990018).

NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests., exemptions, etc.) and licensing activities (bulletins, generic letters, etc.). Enclosure 2.0 AUDIT PROCEDURE AND RESULTS The audit consisted of three major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, (2) verification of the licensee's program for managing changes to NRC commitments, and (3) verification that all regulatory commitments reviewed were correctly applied in NRC staff licensing action reviews. 2.1 Verification of Licensee's Implementation of Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities.

For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.

The audit also verifies that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation.

This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process. 2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments, as defined above, made in writing to the NRC as a result of past licensing actions (amendments, exemptions, relief requests, etc.) and licensing activities (bulletins, generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices of Violation may be included in the sample, but the review will be limited to verification of restoration of compliance, not the specific methods used. Before the audit, the NRC staff searched ADAMS for the licensee's submittals since the last audit and selected a representative sample of regulatory commitments for verification.

The audit excluded the following types of commitments:

(1) Commitments made on the licensee's own initiative among internal organizational components.

(2) Commitments that pertain to milestones of licensing actions/activities (e.g., responding to an NRC request for additional information by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

(4) Commitments related to the PINGP license renewal. Northern States Power Company-Minnesota (NSPM, the licensee), doing business as Xcel Energy, Inc., has implemented procedure FP-R-LIC-24, Rev.2, "NRC Commitment Management," dated March 31, 2014, for handling regulatory commitments.

This procedure establishes a defined methodology for the assignment, tracking, revision, and closing of commitment tasks. An electronic commitment management database called "PassPort" is used to track regulatory commitments, as well as corrective action items. Since the last audit, the licensee conducted an extensive review of its NRC Commitment database with a focus of creating a new Action Request ("AIR") type in the database that would increase the quality of the record and have attributes that would allow migration of records from legacy commitment tracking databases to PassPort and provide a standardized platform.

The documents furnished by the licensee during the audit included summary sheets from the PassPort system, which provided the status of the commitments, and the appropriate backup documentation, as needed (e.g., plant procedures, examination records, and/or other plant documentation incorporating the commitments).

The NRC staff reviewed the documents and summarized the results of the review in the table attached to this audit report. The NRC staff's audit was intended to confirm that the licensee has documented its implementation of its regulatory commitments made to the NRC staff as part of past licensing communications, and the commitments that had not yet been implemented or incorporated in design bases documents are captured in an effective manner for future implementation.

2.1.2 Audit Results The PassPort database and the licensee's FP-R-LIC-24 procedure provide acceptable tools for the licensee to capture the NRC guidance on commitment management programs.

The licensee enters the regulatory commitments made to the NRC into a database.

The regulatory commitments are labeled as regulatory commitments.

Each commitment is numbered and described by a commitment title and a brief description.

Status of the commitments, implementation dates, target implementation (documents which finally capture the commitment) document information associated with each specific commitment, and comments are captured in the database.

The licensee's staff is trained in updating the commitment management program. However, a potential vulnerability of the Commitment Management program is the limited number of experts with the Regulatory Affairs team with experience to navigate the nuances of the program The licensee has maintained the PassPort database very well and all the commitments selected for this audit were traceable in the database.

For commitments already incorporated, the database provided an accurate status of the commitment providing reference to the implementation document.

The NRC staff's audit of the licensee's commitment management program for PINGP, Units 1 and 2, did not identify any regulatory commitments that were not satisfied or incorporated.

The staff identified the following two issues that the licensee had documented in its corrective action program:

• Fleet Procedure FP-R-LIC-24 The previous audit on September 12-14, 2011, (audit report issued on December 19, 2011 (ADAMS Accession No. ML 112990018))

noted the following:

Licensee procedure 5AWI (concerning non-NRC commitments)

Section 1.7.0 was not updated to reflect that the new NRC commitment procedure (FP-R-LIC-24) had been implemented.

The references to NRC commitments should have been deleted or superseded.

A corrective action was written to update 5AWI to remove any notation of NRC commitments and ensure that NRC commitments are strictly controlled by FP-R-LIC-24.

However, 5AWI was deleted and FP-R-LIC-24 still has it as a reference.

The primary concern is verifying that the licensee has no other commitment management documents that could conflict with FP-R-LIC-24. During the audit, the licensee entered this issue into their corrective action program for resolution (AIR No. 01445994)

• Fleet Procedure FP-R-LIC-24 During discussions between the NRC staff and the licensee regarding Commitment Nos. 01361825 and 01361842, the NRC staff requested that the licensee change its commitment.

Specifically, the NRC requested that the licensee expedite completion of the seismic walkdowns for Units 1 and 2. NRC commitment procedure (FP-R-LIC-24) provides guidance from the assumption that commitment changes are initiated by the licensee.

However, FP-R-LIC-24 is unclear when commitment changes are initiated at the request of the NRC. While the change does occur in the database, the specific documentation and review requirements are unclear.

During the audit, the licensee entered this issue into their corrective action program for resolution (AIR No. 01444011)

Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented the regulatory commitment management program effectively in accordance with LIC-1 05, Revision 5, "Managing Regulatory Commitments Made by Licensees to the NRC," (ADAMS Accession No. ML 13193A358) and is consistent with NEI 99-04. The issues identified by the NRC staff are minor in nature and do not have any safety significance.

The Attachment to this audit report contains details of the audit and a summary of the audit results. 2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments.

The process used at PINGP, Units 1 and 2, is contained in procedure FP-R-LIC-24, Rev. 2, dated March 31, 2014. The NRC staff reviewed the licensee's procedure against the guidance provided in NEI 99-01. The change process is based on the NEI 99-0,1 guidance.

Regulatory commitment changes are processed and tracked by the Regulatory Affairs Department (Site Licensing) and are approved by the Site Management.

Regulatory Commitment Change Request Form QF-0729 is used to document the evaluation of commitment changes. The primary focus of the audit was to ensure that commitments are implemented without a change or, if a change is made, it is made in accordance with approved plant procedures and with the approval of licensee management.

Another purpose of the audit was to verify whether the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation.

This ensures that licensee personnel are able to recognize that future proposed changes to design features or operating procedures, which may be subject to regulatory commitments, require evaluation in accordance with the commitment change control process. 2.2.1 Audit Results Detailed processes are outlined by which the licensee carries out actions under its regulatory commitments.

Any changes to the commitments are processed through the FP-R-LIC-24 process. Changes to regulatory commitments are reported to the NRC in accordance with the recommendations of LIC-105 and NEI 99-04 guidelines.

FP-R-LIC-24 identifies the affected commitments, their origin, original criteria, proposed changes, and justification for change. The commitment changes are documented in FP-R-LIC-24 forms for submittal to the NRC staff. The licensee performed a PassPort database search and provided a list of commitment changes made since the last audit. The NRC staff reviewed a sample of these changes. Licensee personnel were able to effectively track commitments through the PassPort system through implementing documents.

The attached Audit Summary table provides details of this portion of the audit and its results. Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented regulatory commitment changes appropriately, in accordance with LIC-105 and consistent with NEI 99-04. In addition, the NRC staff noted that the method of linking specific changes in procedures to specific regulatory commitments was adequate, and resulted in traceability in the most recently revised procedures.

2.3 Verification that Reviewed Regulatory Commitments were Correctly Applied in NRC Staff Licensing Action Reviews The commitments reviewed for this audit were also evaluated to determine if they had been misapplied.

A commitment is considered to be misapplied if the action comprising the commitment was relied on by the NRC staff in making a regulatory decision such as a finding of public health and safety in an NRC safety evaluation associated with a licensing action. Reliance on an action to support a regulatory decision must be elevated from a regulatory commitment to a legal obligation (e.g., license condition, condition of a relief request, regulatory exemption limitation or condition).

A commitment is also considered to have been misapplied if the commitment involves actions that were safety significant (i.e., commitments used to ensure safety). Each of the commitments selected for the audit sample were reviewed to determine if any had been misapplied.

Based on the NRC staff review of the safety evaluations and staff assessments issued for the audit period, it was determined that the commitments reviewed by the NRC staff were explicit statements made by the licensee to take specific action in support of the specific licensing action and were correctly applied while reviewing the licensing actions. 2.4 Verification of Corrective Actions from Last Commitment Audit Report The previous audit on September 12-14,2011, (audit report issued on December 19,2011 (ADAMS Accession No. ML 112990018) noted two deficiencies in the licensee's commitment management program documents.

1. The flow chart in licensee procedure FP-R-LIC-24, Rev 0, dated February 24, 2011, Figure 1 (comparable to NEI 99-01, Figure A-1 ), refers to Figure 2 within the flow chart. However, Figure 2 is not included in the procedure document.

Figure 2 is presumably comparable to Figure A-2 of NEI 99-01.

• Closed. FP-R-LIC-24 has been updated to remove the incorrect reference to a Figure that is not contained in the licensee's commitment management procedures.

When evaluating changes to regulatory commitments, FP-R-LIC-24 requires the licensee to use Form QF-0729. QF-0729 contains all the procedural elements outlines in both Figure A-1 and A-2 of NEI 99-01. 2. Licensee procedure 5AWI (concerning non-NRC commitments)

Section 1.7.0 was not updated to reflect that the new NRC commitment procedure (FP-R-LIC-

24) had been implemented.

The references to NRC commitments should have been deleted or superseded.

• Open. Further details can be found in Section 2.1.2 above and AIR No. 01445994).

3.0 CONCLUSION

Based on the results of the audit, the NRC staff concludes that the licensee has implemented the commitment management program effectively, and has implemented commitment changes appropriately consistent with NEI 99-04. The deficiencies identified during the audit, which are summarized in Section 2.0 of this report, did not have any safety significance.

The NRC staff notes that the licensee has taken appropriate actions to correct the deficiencies identified during the audit. 4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Penny S. Oleson, Regulatory Affairs Dale Vincent, Site Licensing Principal Contributor:

S. Wall Date: September 25, 2014

Attachment:

Audit Summary Table NSPM Letter No. Subject L-PI-09-012, dated 90 Day 2R25 January 30, 2009 Report for GL (ADAMS 2008-01 Accessions No. ML090300705)

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS PRAIRIE ISLAND NUCLEAR GENERATING PLANT AUDIT PERFORMED FROM September 9-11,2014 Commitment No. Description of Commitment Implementation Status 01168385-06 By the end of the third quarter of 2009 for Unit 2,and end of Closed. (U2) second quarter 201 0 for Unit 1 NSPM will develop and (U2) Revised by L-PI-09-012, dated January implement interim surveillance measures in owner-controlled 30, 2009 (ADAMS Accessions No. 01168385-07 documents (until implementation of Reference 3, Enclosure ML090300705) and track with 01168385-14 (U1) Section B, Commitment 2 activities is complete) to periodically Refer to 01168385-14 for status of verify the piping is sufficiently full such that its functional commitment.

requirements are maintained. (U1) The commitment is a revision of commitment 1 of L-PI-08-088, dated October 14, 2008. (ADAMS Accession No.ML082880483) and previously tracked with 01155174-01.

The following documents were revised to incorporate this commitment (01168385-07):

• TP 1468, "Unit 1 GL-08-01 inspections"

• PMID 6359-18 with a quarterly frequency All the actions associated with this commitment are complete.

01168385-12 An extent of condition review of flow element and orifices Closed. (U1) -considering lessons learned from evaluating the voids in the RHR pump miniflow lines, completed January 24, 2009, An extent of condition review was conducted 01168385-13 identified additional locations to evaluate.

The corrective identifying orifices in the RHR, Sl, and CS (U2) actions (that is, walkdowns) for this extent of condition systems. Susceptible locations into and review will be completed for the Units 1 and 2 locations outside outside containment were documented and containment in the second quarter of 2009. The Units 1 and 2 UT's conducted under WO 380828 and WO locations inside containment will be completed consistent with 387086. accessibility no later than 1 R26 in 2009 and 2R26 in 2010, respectively All the actions associated with this commitment are complete.

Attachment I ' Commitment NSPM Letter No. Subject No. Description of Commitment Implementation Status L-PI-09-102, dated Supplemental 01155174-07 Procedures or work instructions will be written to dynamically Closed. September 28, to Responses vent portions of the RHR and Sl systems that are currently 2009 (ADAMS to Generic vented in association with check valve testing. NSPM will state in The commitment is a revision of commitment Accessions No. Letter (GL) the purpose that such venting is being performed.

NSPM will 6 of L-PI-08-088, dated October 14, 2008. ML092730109) 2008-01 ensure that these procedures and work instructions will be (ADAMS Accession No.ML082880483) and scheduled appropriately as a post-maintenance verification for previously tracked with 01155174-06.

activities in an outage that may introduce voids into the systems. The following documents were revised to incorporate this commitment:

• SP 2466, "Dynamic Flush of RHR System (GL 2008-01 )"

• SP 1029A, "SI Check Valve Test (Head Off) Part A."

• SP 20292A, "SI Check Valve Test (Head Off) Part A."

• SP 1092D, "Safety Injection Check Valve Test (Head On) Part D." All the actions associated with this commitment are complete.

01168385-14 By the end of fourth quarter 2009 for Unit 2 and end of second Closed. (U2) quarter 2010 for Unit 1, NSPM will develop and implement interim surveillance measures in owner-controlled documents The commitment is a revision of commitment (until implementation of Reference 3, Enclosure Section B, 1 of L-PI-09-012, dated January 30, 2009 Commitment 2 activities is complete) to periodically verify the (ADAMS Accessions No. ML090300705) and piping is sufficiently full such that its functional requirements are previously tracked as 01168385-06; which maintained.

revised commitment 1 of L-PI-08-088, dated October 14, 2008. (ADAMS Accession No.ML082880483) and previously tracked with 01155174-01.

The following documents were revised to incorporate this commitment (01168385-14):

• TP 2468, "Unit 2 GL-08-01 inspections"

• PMID 6786-14 with a quarterly frequency All the actions associated with this commitment are complete. Commitment NSPM Letter No. Subject No. Description of Commitment Implementation Status L-PI-09-125, dated LAR for 01207012-01 In the course of the core reload process approved for use at Open. November 24, Optimized PINGP, and prior to first loading of Optimized ZIRLOŽ, 2009 (ADAMS ZIRLOŽ Westinghouse will be programmatically required to evaluate the Targeted for completion in 2015 Accession No. effects of Optimized ZIRLOTM on PINGP core performance and ML093280883) accident analysis.

To satisfy NRC Safety Evaluation (SE) for Optimized ZIRLOŽ, NSPM will confirm that core reload safety evaluations satisfy conditions and limitations 3, 4, 5, 8, and 10 of the NRC SE for Optimized ZIRLOŽ. Continuous, until the contingency requirements of the conditions and limitations have been satisfied.

01207012-02 To satisfy NRC SE for Optimized Z IRLOŽ, NSPM will confirm Open. that Westinghouse provides additional confirmatory data associated with Lead Test Assembly (L TA) programs at other facilities prior to operation with Optimized Zl RLO TM fuel rod Targeted for completion in 2015 cladding.

This commitment relates to conditions and limitations 6 and 7 of the NRC SE for Optimized ZIRLOŽ. Continuous, until the L TA data up through the fuel burnup limit applicable for PINGP has been provided to the NRC. L-PI-11-099, dated Response to 01316908-01 NSPM will revise the Prairie Island Nuclear Generating Plant Closed. The license condition approved in December 8, 2011 RAis design and licensing bases to include that the Steam Generator LAR dated January 22, 2013 (ADAMS (ADAMS Regarding water level -narrow range instruments are required to meet accession No.ML 112521289) supersedes accession No. Regulatory regulatory guide 1.97, Revision 2 requirements.

This commitment regulatory commitment.

ML113430091)

Guide 1.97 will be completed prior to implementation of the Alternative Source lnstrurnentatio Term license amendment.

Action currently being tracked with 01441944-n. 01 Commitment NSPM Letter No. Subject No. Description of Commitment Implementation Status L-PI-12-013, dated Response to 0132669-01 Implement a plant modification that will enter either block Closed. The license condition proposed in L-February 24, 2012 RAis [P12001A]

the 121 Laundry Fan exhaust flow path permanently or Pl-12-082 dated September 13, 2012 (ADAMS Regarding will otherwise remove the 121 Laundry fan exhaust path as a (ADAMS accession No. ML 12258A057) and accession No. Adoption of potential source of post-accident radioactive release approved in LAR dated January 22, 2013 ML 12058A069)

Alternate through the Auxiliary Building Ventilation Exhaust Stack. (ADAMS accession No.ML 112521289)

Source Term supersedes regulatory commitment.

0132669-02 Implement an administrative control to require Auxiliary Closed. The commitment was incorporated

[P12002A]

Building Special Ventilation Zone boundary integrity during in the following document:

movement of heavy loads over an open reactor vessel containing irradiated fuel assemblies when the containment USAR Section 12, Revision 33P atmosphere is open to the outside (as described in USAR 12.2.12).

All the actions associated with this commitment are complete.

L-PI-12-089, dated NFPA805 01355866-01 NSPM will implement procedure changes, process updates, and Open. NSPM submitted the LAR by letter September 28, [P12023A]

training of affected personnel as identified in AttachmentS, Table dated September 28,2012 (ADAMS 2012 (ADAMS S-3, of TR within the later six months after NRC approval, or six Accession No. ML 12278A405).

LAR is accession No. months after a refueling outage if in progress at the time of NRC pending NRC approval ML 12278A405) approval.

01355866-02 NSPM will provide a supplement to the NFPA 805 LAR no later Closed. NSPM submitted the LAR [P12023A]

than November 15, 2012, to provide the final findings and supplement by letter dated November 8, 2012 observations with dispositions elated to the Internal Flooding (ADAMS Accession No. ML 12314A144) with PRA peer review. final information regarding peer review of the Internal Flooding PRA. All the actions associated with this commitment are complete.

L-PI-10-104, dated RAI Response 01263702-02 Northern States Power Company, a Minnesota corporations, will Closed. October 20, 2010 Associated develop dynamic electrical model for the Prairie Island Nuclear (ADAMS with Exigent Generating Plant Unit 1 emergency diesel generators by A dynamic electrical model was developed Accession No. LAR to Modify December 15, 2011 per EC 17737. Calculations were performed ML 102930575)

TSSR to verify and validate the response of EDGs 3.8.1.10 during transient conditions.

All the actions associated with this commitment are complete.

--*-- Commitment NSPM Letter No. Subject No. Description of Commitment Implementation Status L-PI-11-024, dated Supplement 1 01284353-01 The Updated Safety Analysis Report will be updated to include Closed. The commitment was incorporated in March 15, 2011 toLAR [P11001A]

the description of existing and new Unit 1 battery chargers, as the following document: (ADAMS concerning applicable, within 6 months following completion of the Unit 1 Accession No. Battery 2011 refueling outage. USAR Section 8, Revision 28 ML 11 0750198) Charger Replacement All the actions associated with this commitment are complete.

L-PI-11-057, dated Request for 01292172-01 NSPM will submit the License Amendment Request (LAR) Closed. NSPM submitted the LAR by letter June 22, 2011 Extension of implementing 10 CFR 50.48(c) for Prairie Island Nuclear dated September 28, 2012 (ADAMS (ADAMS Enforcement Generating Plant no later than September 30, 2012. Accession No. ML 12278A405).

Accession No. Discretion and ML 111740866)

Commitment All the actions associated with this to Submit Date commitment are complete.

for10CFR 50.48(c) LAR L-PI-11-069, dated 60-Day 01296934-01 NSPM will include a requirement for continuing training on Closed. The commitment was incorporated in July 11, 2011 Response to [P11003A]

Extensive Damage Mitigation Guidelines (EDMG) in the PINGP the following document: (ADAMS NRC Bulletin training program for the Emergency Response Organization Accession No. 2011-01' (ERO) qualified decision makers by January 13, 2012. P7400 Rev 24, Emergency Plan (Training ML 111930159)

Mitigating Program) [Completed January 13, 2012] Strategies All the actions associated with this commitment are complete.

L-PI-11-075, dated Spent Fuel 01298553-01 In conjunction with implementation of the proposed Technical Closed. The commitment was incorporated in August 19, 2011 Criticality

[P1107A] Specifications (TS), procedures will be revised to require the following document: (ADAMS positive controls for the movement of all fissile material Accession No. in the Spent Fuel Pool (including Consolidated Rod Storage 05.3, "Movement of Non-Fuel Hardware in the ML 11236A133)

Canister (CRSC), Fuel Rod Storage Canister (FRSC), and Spent Fuel Pool" Failed Fuel Pin Basket (FFPB)) and all non-fuel material (including fuel assembly cages and dummy fuel assemblies)

All the actions associated with this placed into a storage rack. These positive controls will be commitment are complete.

comparable to those used for fuel assemblies (e.g., Fuel Transfer Log). The procedure revisions will include a post-campaign validation of all the affected Spent Fuel Pool (SFP) locations, whether fresh fuel is involved in the campaign or not. --- Commitment NSPM Letter No. Subject No. Description of Commitment Implementation Status 01298553-02 In conjunction with implementation of the proposed TS, Closed. The commitment was incorporated in [P1108A] procedures will be revised to require an assessment of a the following document:

fuel assembly's cumulative exposure to rodded power operation in the core prior to moving that fuel assembly

• D5.2, "Reactor Refueling Operations" into the SFP storage racks. If an assembly experiences

• SWE NE-22, "ShuffleWorks Fuel more than 1 gigawatt day per metric ton uranium Movement Planning System (GWd/MTU) of core average rodded operation, the assembly shall either be treated as Fuel Category 1 or All the actions associated with this evaluated to determine which Fuel Category is appropriate commitment are complete.

for safe storage of the assembly.

01298553-03 In conjunction with implementation of the proposed TS, an Closed. [P1109A] assessment of existing spent fuel inventory will be performed to ensure cumulative exposure to rodded Assessment has been performed.

No operation for any assembly does not exceed 1 GWd!MTU. previous cycles at Prairie Island have If an assembly experienced more than 1 GWd/MTU of exceeded the 1 GWd/MTU limit of rodded core average rodded operation, the assembly shall either operations.

be treated as Fuel Category 1 or evaluated to determine which Fuel Category is appropriate for safe storage of the All the actions associated with this assembly.

commitment are complete.

L-PI-11-070, dated 01299474-01 Within 180 days after approval of the LBB LAR, NSPM will Closed. The commitment was incorporated in August 9, 2011 [P11004A]

implement procedural guidance to allow plant operators to the following documents: (ADAMS approximate the quantity of RCS leakage based on containment Accession No. sump A pump operating frequency or containment particulate

• SP 1001AA/2001AA, "Daily Reactor ML 112220099) radiation monitor indications.

Coolant System Leakage Test"

• SP 1001A/2001A, "RCS Leakage Test Manual Method"

• SP 1001AAA/2001AAA, "RCS Leakage Investigation"

• C4 7041 , "Alarm Response Procedure

-ERGS"

• PINGP 1180, "Operator Round Sheet"

• Training conducted All the actions associated with this commitment are complete.

---

* Commitment NSPM Letter No. Subject No. Description of Commitment Implementation Status 01299474-02 Within 180 days after approval of the LBB LAR, NSPM will Closed. [P11005A]

provide indications and alarms on the plant Emergency Response Computer System that will alert plant operators to

• Engineering calculations were completed potential RCS leakage based on containment particulate per EC 14541 radiation monitor indications.

• ERGS alarm activations were completed underWO 431911 (U1) and WO 431921 (U2)

• C4 7041, "Alarm Response Procedure

-ERGS" updated All the actions associated with this commitment are complete.

01299474-03 Within 180 days after approval of the LBB LAR, NSPM will Closed. The commitment was incorporated in [P11006A]

implement procedural guidance to clarify operator actions in the following documents:

response to indications of potential RCS leakage based on containment sump A pump run time indications or containment

• SP 1001AA/2001AA, "Daily Reactor particulate radiation monitor indications.

Coolant System Leakage Test"

• SP 1001A/2001A, "RCS Leakage Test Manual Method"

• SP 1001AAA/2001AAA, "RCS Leakage Investigation"

• C4 7041, "Alarm Response Procedure

-ERGS"

• PINGP 1180, "Operator Round Sheet"

• Training conducted All the actions associated with this commitment are complete.

L-PI-13-044, dated Provide a 01381444-01 NSPM commits to provide a supplement to the NFPA 805 LAR Closed. NSPM submitted the LAR May 3, 2013 supplement to [P13003A]

with revised Fire PRA results by May 1, 2014. supplement by letter dated April 30, 2014 (ADAMS the NFPA 805 (ADAMS Accession No. ML 14125A106).

LAR Accession No. LAR is pending NRC approval ML13126A115)

- Commitment NSPM Letter No. Subject No. Description of Commitment Implementation Status L-PI-10-052, dated Issue 01236136-01 Cycle-specific BEACON calibrations performed before Closed. The commitment was incorporated in June 14, 2010 Procedure for startup and at beginning-of-cycle conditions will ensure the following procedure: (ADAMS BEACON-that power peaking uncertainties provide 95% probability Accession No. TSM upper tolerance limits at the 95% confidence level. These Maintenance Procedure D37, "BEACON-TSM ML 101650544)

Calibration calibrations are to be performed using the Westinghouse Calibration During Initial Cycle Startup." Work methodology.

Until these calibrations are complete, more Package performed D37 during 1 R28. conservative default uncertainties will be applied. The calibrations will be documented and retained as records All the actions associated with this commitment are complete.

Response to Additional 01252160-01 Northern States Power will establish the following policy: Closed. New tracking number used for Generic Ltr 82-12 Information transferring commitment from legacy system. & NUREG-0737, Related to (1) Overtime will be limited for all nuclear plant staff personnel Previously tracked with COM 1 0-03. dated November lmplementatio who perform safety related functions (e.g., licensed SROs, 16, 1982 (ADAMS n of NRC licensed ROs, health physicists, auxiliary operators, and key Commitment was made associated with the Accession No. Guidelines for maintenance personnel) so that total work time does not exceed response to NRC Generic Letter 82-12. 10 ML 112991042)

Working Hours 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, CFR Part 26 Subpart I (73 FR 16966, March nor 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> in any seven-day period. Individuals will not be 31, 2008), supersedes existing worker fatigue required to work more than 15 consecutive days without 2 guidance.

consecutive days off. Letter L-XI-09-006, dated April 15, 2009 (2) Exceptions to the above limitations shall only be granted after (ADAMS Accession No. ML091050619) has review and approval of each individual situation on a case basis Technical Specification changes resulting by the Plant Manager or his designee.

During plant emergencies from the rule. the Emergency Director, who is normally the Plant Manager, All the actions associated with this shall have exception authority.

commitment are complete.

(3) STA and SEC on-site rest time periods shall not be considered as hours worked when determining the total work time for which the above limitations apply -- Commitment NSPM Letter No. Subject No. Description of Commitment Implementation Status LER 2-92-02, Interruption of 01252160-02 Emergency plan procedures for RHR interruption events were Closed. New tracking number used for dated February One Train of clarified.

transferring commitment from legacy system. 24, 1992. RHR During Previously tracked with COM 10-04. I I Reported by letter Unit2 RCS I I dated March 25, Draining The following documents were revised to 1992 (ADAMS Operation incorporate this commitment:

Accession No.

• F3-2, Rev 14 ML113111394)

• PINGP 579, Rev 47

• PINGP 580, Rev 51 All the actions associated with this commitment are complete.

LER 1-97-02, Relief 01259886-01 Original Commitment: "Each future examination with limitations Closed. New tracking number used for dated February Requests for will be documented to quantify the extent of limitation and relief transferring commitment from legacy system. 19, 1997. lSI will be requested.

Relief will be submitted with the outage Previously tracked with COM 66021-1. Reported by letter examinations summary report [due 90 days after each outage] for each limited dated March 21 , examination." Corrective actions described in commitment 1997 not required for compliance with 10 CFR Commitment was revised by Commitment Change 06-04 (GAR 50.55(a).

01 045247) such that relief requests for limited examinations arc 50.59 Evaluation Summary Report submitted to be submitted within 12 months after the associated outage. by L-PI-07-074, dated December 10, 2007 (ADAMS Accession No. ML073440325).

All the actions associated with this commitment are complete.

NRC letter dated Fire-related 01348431-01 Fire-rated dampers (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or equivalent) will be installed in all Closed. New tracking number used for September 6, Dampers return ventilation ducts that penetrate the boundaries of the transferring commitment from legacy system. 1979 (ADAMS room. Previously tracked with COM 78647. Accession No. ML022170670)

L-PI-07-011, dated February 15, 2007 (ADAMS Accession No. ML070590196) notified NRC of deletion of commitment.

All the actions associated with this commitment are complete. Commitment NSPM Letter No. Subject No. Description of Commitment Implementation Status L-PI-12-080, dated Response to 0 1350093-0 1 The JOG PV Program classifies each MOV into one of four Closed. The commitment was incorporated September 24, GL 96-05 [P12020A]

classes: Class A, B, C, or D. Class A, B, and C valves are in the following programs:

2012 (ADAMS included within the scope of the JOG MOV PV Program and Accession No. Class D valves are not. As such, the JOG PV Program will not be

• H5, "Motor Operated Valve Program" ML 12269A 166 implemented for the Class D valve population which consists of

• Calculation program (MIDAS) for MSIV the Main Steam Isolation Valve (MSIV) Bypass Motor Valves Bypass MOVs. (MVs) (MV-32045, MV-32047, MV-32048 and MV-32050)

• WO 459748, "Disassemble and Inspect MV-32047 for MOV Program" All the actions associated with this commitment are complete 01350086-01 The JOG Periodic Verification (PV) Program will be used in Closed. The commitment was incorporated

[P12019A]

accordance with JOG document MPR-2524-A for those valves in the following programs:

that have been categorized as JOG Class A, B, or C for those valves currently in the PINGP GL 89-10 196-05 MOV program.

• H5, "Motor Operated Valve Program"

• Calculation program (MIDAS) for MSIV Bypass MOVs.

• WO 459748, "Disassemble and Inspect MV-32047 for MOV Program" All the actions associated with this commitment are complete L-PI-12-108, dated Seismic 01361825-01 NSPM will complete the Seismic Walkdowns of the inaccessible Open. November 26, Aspects of [P12027B]

components listed in Appendix D, "Plan for Future Seismic 2012 (ADAMS Recommendat Walkdown of Inaccessible Equipment," of the enclosure.

Due Action due Fall2014 Accession No. ion 2.3 (Unit 1) Date Refueling Outage (RFO) 1 R30 ML 12334A495)

Note: FP-R-LIC-24 does not address when Revised by L-PI-13-07, dated September 12, 2013 (ADAMS NRC initiates or requests a change to a Accession No. ML 13259A028):

regulatory commitment. (AIR No 01444011)

NSPM will complete the Seismic Walkdowns of the inaccessible components listed in the enclosure of this letter. Due Date Refueling Outage (RFO) 1 R29 _L._ ---*-- Commitment NSPM Letter No. Subject No. Description of Commitment Implementation Status 01361825-02 NSPM will provide an updated seismic walkdown report with the Open. [P12028C]

results of the walkdowns of the inaccessible components.

Due Date: 60 days following the end of RFO 1 R30 Action due Winter 2015 Revised by L-PI-13-07, dated September 12, 2013 (ADAMS Note: FP-R-LIC-24 does not address when Accession No. ML 13259A028):

NRC initiates or requests a change to a NSPM will provide an updated seismic walkdown report with the regulatory commitment. (AIR No 01444011) results of the walkdowns of the inaccessible components.

Due Date: 60 days following the end of RFO 1 R29. L-PI-12-109, dated Seismic 01361842-01 NSPM will complete the Seismic Walkdowns of the inaccessible Closed. November 26, Aspects of [P12029C]

components listed in Appendix D, "Plan for Future Seismic 2012 (ADAMS Recommendat Walkdown of Inaccessible Equipment," of the enclosure.

Due Response provided in L-PI-14-020, dated Accession No. ion 2.3 (Unit 2) Date: Refueling Outage (RFO) 2R29 March 4, 2014 (ADAMS Accession No. ML 12334A470)

ML 14069A027)

Revised by L-PI-13-82, dated September 12, 2013 (ADAMS Note: FP-R-LIC-24 does not address when Accession No. ML 13259A027):

NSPM will complete the Seismic Walkdowns of the inaccessible NRC initiates or requests a change to a components listed in the enclosure of this letter. Due Date regulatory commitment. (AIR No 01444011)

Refueling Outage (RFO) 2R28 01361842-02 NSPM will provide an updated seismic walkdown report with the Closed. [P12030C]

results of the walkdowns of the inaccessible components.

Due Date: 60 days following the end of RFO 2R29 Response provided in L-PI-14-020, dated March 4, 2014 (ADAMS Accession No. Revised by L-PI-13-82, dated September 12, 2013 (ADAMS ML 14069A027)

Accession No. ML 13259A027):

Note: FP-R-LIC-24 does not address when NSPM will provide an updated seismic walkdown report with the results of the walkdowns of the inaccessible components.

Due NRC initiates or requests a change to a Date: 60 days following the end of RFO 2R28 regulatory commitment. (AIR No 01444011)

K. Davison The NRC staff appreciates the resources that were made available by your staff for performing the audit. If you have any questions, please contact me at (301) 415-2855 or via e-mail at Scott.Wall@nrc.gov.

Docket Nos. 50-282 and 50-306

Enclosure:

Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL3-1 R/F RidsAcrsAcnw_MaiiCTR Resource RidsNrrDorllpl3-1 Resource RidsNrrPMPrairielsland Resource RidsNrrLAMHenderson Resource RidsOgcRp Resource RidsRgn3MaiiCenter Resource TOrf, TA/DORL ADAMS Accession No* ML 14258A377

.. Sincerely, IRA/ Scott P. Wall, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/LPL3-1/BC NRR/LPL3-1/PM NAME SWall MHenderson DPelton SWall DATE 09/15/14 09/23/14 09/25/14 09/25/14 OFFICIAL RECORD COPY