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| ==References:== | | ==References:== |
| : 1. NSPM letter, J.P. Sorensen to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, L-PI-12-089, dated September 28, 2012, ADAMS Accession No. ML 12278A405. | | : 1. NSPM letter, J.P. Sorensen to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, L-PI-12-089, dated September 28, 2012, ADAMS Accession No. ML12278A405. |
| : 2. NSPM letter, S. Sharp to NRC Document Control Desk, Supplement to License Amendment Request to Adopt NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactors, L-PI-14-045, dated April 30, 2014 (ADAMS Nos. ML 14125A106 and ML 14125A149). | | : 2. NSPM letter, S. Sharp to NRC Document Control Desk, Supplement to License Amendment Request to Adopt NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactors, L-PI-14-045, dated April 30, 2014 (ADAMS Nos. ML14125A106 and ML14125A149). |
| : 3. NRC email, T. Beltz to S. Chesnutt, Prairie Island Nuclear Generating Plant, Units 1 and 2 -NFPA 805 Requests for Additional Information and Response Timeline (TAG Nos. ME9734 and ME9735), dated March 30, 2015 (ADAMS Accession No. ML 15089A157). | | : 3. NRC email, T. Beltz to S. Chesnutt, Prairie Island Nuclear Generating Plant, Units 1 and 2 -NFPA 805 Requests for Additional Information and Response Timeline (TAG Nos. ME9734 and ME9735), dated March 30, 2015 (ADAMS Accession No. ML15089A157). |
| : 4. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors -Response to Request for Additional Information, L-PI-15-041, dated May 28,2015 (ADAMS No. ML 15153A018). | | : 4. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors -Response to Request for Additional Information, L-PI-15-041, dated May 28,2015 (ADAMS No. ML15153A018). |
| : 5. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors -Response to Request for Additional Information-90-Day Responses, L-PI-15-052, dated June 19,2015 (ADAMS No. ML 15174A139). | | : 5. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors -Response to Request for Additional Information-90-Day Responses, L-PI-15-052, dated June 19,2015 (ADAMS No. ML15174A139). |
| Document Control Desk Page 2 6. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors -Response to Final Request for Additional Information (PRA-Second Round), L-PI-15-059, dated October 22, 2015 (ADAMS No. ML 15296A259). | | Document Control Desk Page 2 6. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors -Response to Final Request for Additional Information (PRA-Second Round), L-PI-15-059, dated October 22, 2015 (ADAMS No. ML15296A259). |
| : 7. NRC email, T. Beltz to A. Hazel hoff, Prairie Island Nuclear Generating Requests for Additional Information (AFPB) re: LAR to Adopt NFPA 805 (TAG Nos. ME9734 and ME9735), dated January 8, 2016. In Reference 1, the Northern States Power Company, a Minnesota Corporation (NSPM) doing business as Xcel Energy requested approval from the Nuclear Regulatory Commission (NRC) to transition the fire protection licensing basis for the Prairie Island Nuclear Generating Plant (PINGP) to 10 CFR 50.48(c), National Fire Protection Association Standard 805 (NFPA 805). Supplemental information was provided in letters dated November 8, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12314A144) and December 18, 2012 (ADAMS Accession No. ML 12354A464). | | : 7. NRC email, T. Beltz to A. Hazel hoff, Prairie Island Nuclear Generating Requests for Additional Information (AFPB) re: LAR to Adopt NFPA 805 (TAG Nos. ME9734 and ME9735), dated January 8, 2016. In Reference 1, the Northern States Power Company, a Minnesota Corporation (NSPM) doing business as Xcel Energy requested approval from the Nuclear Regulatory Commission (NRC) to transition the fire protection licensing basis for the Prairie Island Nuclear Generating Plant (PINGP) to 10 CFR 50.48(c), National Fire Protection Association Standard 805 (NFPA 805). Supplemental information was provided in letters dated November 8, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12314A144) and December 18, 2012 (ADAMS Accession No. ML12354A464). |
| In Reference 2, NSPM submitted a revised Fire Probabilistic Risk Assessment (PRA) in a supplement to the subject License Amendment Request (LAR). In Reference 3, the NRC staff provided requests for additional information (RAis) regarding this request and also provided a timeline and due dates for submitting responses within 60, 90, or 120 days after an on-site Audit that was conducted March 23-25, 2015. NSPM letter dated May 28, 2015 (Reference | | In Reference 2, NSPM submitted a revised Fire Probabilistic Risk Assessment (PRA) in a supplement to the subject License Amendment Request (LAR). In Reference 3, the NRC staff provided requests for additional information (RAis) regarding this request and also provided a timeline and due dates for submitting responses within 60, 90, or 120 days after an on-site Audit that was conducted March 23-25, 2015. NSPM letter dated May 28, 2015 (Reference |
| : 4) provided responses to the 60-day RAis and one of the 90-day RAis (Fire Protection Engineering RAI 03). NSPM letter dated June 19, 2015 (Reference | | : 4) provided responses to the 60-day RAis and one of the 90-day RAis (Fire Protection Engineering RAI 03). NSPM letter dated June 19, 2015 (Reference |
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| Document Control Desk Page 3 Summary of Commitments This letter contains no new commitments and makes no revisions to any existing commitments. | | Document Control Desk Page 3 Summary of Commitments This letter contains no new commitments and makes no revisions to any existing commitments. |
| I declare under penalty of perjury that the foregoing is true and correct. Executed on January 20, 2016. | | I declare under penalty of perjury that the foregoing is true and correct. Executed on January 20, 2016. |
| Kevin Davison Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company -Minnesota Enclosure (1) cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota L-PI-16-004 Enclosure NSPM Response to Requests for Additional Information (RAis) Regarding the License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805 at Prairie Island Nuclear Generating Plant Units 1 and 2 NRC Request Fire Protection Engineering (FPE) RAI 07 In a letter dated October 22, 2015 (ADAMS Accession No. ML 15296A259), the licensee submitted a new LAR Attachment L, Approval Request 4, which involved using a based method to comply with NFPA 805 Section 3. 3. 5. 1 for the installation of wiring above suspended ceilings in several areas of the plant. a. In Part 1 of the approval request under safety margins and defense in depth, the licensee stated, ''The introduction of the non-rated and non-enclosed wiring routed above these suspended ceilings does not impact fire protection defense-in-depth. | | Kevin Davison Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company -Minnesota Enclosure (1) cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota L-PI-16-004 Enclosure NSPM Response to Requests for Additional Information (RAis) Regarding the License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805 at Prairie Island Nuclear Generating Plant Units 1 and 2 NRC Request Fire Protection Engineering (FPE) RAI 07 In a letter dated October 22, 2015 (ADAMS Accession No. ML15296A259), the licensee submitted a new LAR Attachment L, Approval Request 4, which involved using a based method to comply with NFPA 805 Section 3. 3. 5. 1 for the installation of wiring above suspended ceilings in several areas of the plant. a. In Part 1 of the approval request under safety margins and defense in depth, the licensee stated, ''The introduction of the non-rated and non-enclosed wiring routed above these suspended ceilings does not impact fire protection defense-in-depth. |
| The wiring located above the ceilings does not compromise administrative fire prevention controls, and does not challenge automatic fire detection and suppression functions, manual fire suppression functions, or post-fire safe shutdown capability." Please provide a technical basis how each of the three echelons of fire protection defense-in-depth is or is not impacted by the wiring above the suspended ceiling in each of the areas of the plant. NSPM Response FPE RAI 07 a. The technical basis for each of the three echelons of fire protection defense-in-depth is provided below. Echelon 1 Preventing fires from starting (e.g., combustible/hot work controls) | | The wiring located above the ceilings does not compromise administrative fire prevention controls, and does not challenge automatic fire detection and suppression functions, manual fire suppression functions, or post-fire safe shutdown capability." Please provide a technical basis how each of the three echelons of fire protection defense-in-depth is or is not impacted by the wiring above the suspended ceiling in each of the areas of the plant. NSPM Response FPE RAI 07 a. The technical basis for each of the three echelons of fire protection defense-in-depth is provided below. Echelon 1 Preventing fires from starting (e.g., combustible/hot work controls) |
| The cables in the Fire Areas noted in Approval Request 4 are low voltage video/communication/data cables or low voltage power cable (below 480 VAC) which are not susceptible to self-ignition. | | The cables in the Fire Areas noted in Approval Request 4 are low voltage video/communication/data cables or low voltage power cable (below 480 VAC) which are not susceptible to self-ignition. |
Letter Sequence Response to RAI |
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MONTHYEARL-PI-12-102, Supplement to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Submittal of Lnternal Flooding Peer Review Final Results and Revised Total Plant Risk Values2012-11-0808 November 2012 Supplement to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Submittal of Lnternal Flooding Peer Review Final Results and Revised Total Plant Risk Values Project stage: Supplement ML12335A1832012-11-29029 November 2012 11/29/12 E-mail, Acceptance Review Questions Regarding NFPA 805 License Amendment Request Project stage: Acceptance Review L-PI-12-117, Supplement to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Acceptance Review Questions2012-12-18018 December 2012 Supplement to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Acceptance Review Questions Project stage: Supplement L-PI-13-044, Commitment to Submit a Supplement to the PINGP NFPA 805 License Amendment Request2013-05-0303 May 2013 Commitment to Submit a Supplement to the PINGP NFPA 805 License Amendment Request Project stage: Supplement ML13282A5382013-10-0909 October 2013 Status of Review of National Fire Protection Association Standard 805 Application Project stage: Approval L-PI-13-093, NFPA 805 License Amendment Request- Milestone Schedule for Submittal of Supplement2013-10-17017 October 2013 NFPA 805 License Amendment Request- Milestone Schedule for Submittal of Supplement Project stage: Supplement ML15062A1502015-03-0303 March 2015 NRR E-mail Capture - Prairie Island Nuclear Plant, Units 1 and 2 - NFPA 805 Pre-Audit Draft Requests for Additional Information Project stage: Draft RAI ML15089A1572015-03-30030 March 2015 NRR E-mail Capture - Prairie Island Nuclear Generating Plant, Units 1 and 2 - NFPA 805 Requests for Additional Information and Response Timeline Project stage: RAI L-PI-15-041, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information2015-05-28028 May 2015 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information Project stage: Response to RAI L-PI-15-052, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information - 90-Day Responses2015-06-19019 June 2015 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information - 90-Day Responses Project stage: Response to RAI ML15243A4092015-08-28028 August 2015 NRR E-mail Capture - Prairie Island Nuclear Generating Plant - Final Requests for Additional Information (Second Round) from Apla LAR to Adopt NFPA 805 Project stage: RAI ML15243A4102015-08-28028 August 2015 NRR E-mail Capture - Prairie Island Nuclear Generating Plant - Final Requests for Additional Information (Fire Modeling - Second Round) LAR to Adopt NFPA 805 Project stage: RAI L-PI-15-059, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Information (PRA-Second Round)2015-10-22022 October 2015 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Information (PRA-Second Round) Project stage: Request L-PI-16-004, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors- Response to Request for Additional Information2016-01-20020 January 2016 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors- Response to Request for Additional Information Project stage: Response to RAI L-PI-16-005, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information2016-05-24024 May 2016 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information Project stage: Response to RAI 2015-10-22
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Category:Letter type:L
MONTHYEARL-PI-24-036, – Preparation and Scheduling of Operator Licensing Examinations2024-06-28028 June 2024 – Preparation and Scheduling of Operator Licensing Examinations L-PI-24-031, Independent Spent Fuel Storage Installation, Supplement to License Amendment Request to Revise Independent Spent Fuel Storage Installation (ISFSI) License Conditions 23(a), 24(A)(2), and 24(B)(2)2024-06-0505 June 2024 Independent Spent Fuel Storage Installation, Supplement to License Amendment Request to Revise Independent Spent Fuel Storage Installation (ISFSI) License Conditions 23(a), 24(A)(2), and 24(B)(2) L-PI-24-014, License Amendment Request to Revise the Technical Specification Definition of Reactor Trip System (RTS) Response Time and Apply Response Time Testing to RTS Trip Functions with Time Delay Assumption2024-06-0303 June 2024 License Amendment Request to Revise the Technical Specification Definition of Reactor Trip System (RTS) Response Time and Apply Response Time Testing to RTS Trip Functions with Time Delay Assumption L-PI-24-030, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3.8.12024-05-22022 May 2024 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3.8.1 L-PI-24-012, Independent Spent Fuel Storage Installation - License Amendment Request: Revise Independent Spent Fuel Storage Installation (ISFSI) License Conditions 23(a), 24(A)(2), and 24(B)(2)2024-04-0202 April 2024 Independent Spent Fuel Storage Installation - License Amendment Request: Revise Independent Spent Fuel Storage Installation (ISFSI) License Conditions 23(a), 24(A)(2), and 24(B)(2) L-PI-23-034, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3.7.8, Cooling Water (Cl) System,2024-01-0202 January 2024 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3.7.8, Cooling Water (Cl) System, L-PI-23-035, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Section 5.6.6, Reactor Coolant System (RCS) Pressure and Temperature Limits Report2023-12-20020 December 2023 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Section 5.6.6, Reactor Coolant System (RCS) Pressure and Temperature Limits Report L-PI-23-033, Supplement to License Amendment Request to Revise Technical Specification 3.8.1, Surveillance Requirement 3.8.1.2, Note 32023-12-0505 December 2023 Supplement to License Amendment Request to Revise Technical Specification 3.8.1, Surveillance Requirement 3.8.1.2, Note 3 L-PI-23-025, License Amendment Request to Revise Technical Specification 3.8.1, Surveillance Requirement 3.8.1.2, Note 32023-09-28028 September 2023 License Amendment Request to Revise Technical Specification 3.8.1, Surveillance Requirement 3.8.1.2, Note 3 L-PI-23-023, Baffle Former Bolts Alternate Aging Management Strategy2023-09-11011 September 2023 Baffle Former Bolts Alternate Aging Management Strategy L-PI-23-018, License Amendment Request to Revise ISFSI Technical Specification 4.4 to Allow Use of a Code Alternative to ASME Code, NB-5130, Examination of Weld Edge Preparation Surfaces, for the TN-40HT2023-07-14014 July 2023 License Amendment Request to Revise ISFSI Technical Specification 4.4 to Allow Use of a Code Alternative to ASME Code, NB-5130, Examination of Weld Edge Preparation Surfaces, for the TN-40HT L-PI-23-006, License Amendment Request to Revise Technical Specification 3.7.8 Required Actions2023-06-22022 June 2023 License Amendment Request to Revise Technical Specification 3.7.8 Required Actions L-PI-23-016, 2022 10 CFR 50.46 LOCA Annual Report2023-06-14014 June 2023 2022 10 CFR 50.46 LOCA Annual Report L-PI-23-010, Annual Report of Individual Monitoring2023-04-27027 April 2023 Annual Report of Individual Monitoring L-PI-23-007, Supplement to Application to Revise Technical Specification Section 5.6.6, Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)2023-03-28028 March 2023 Supplement to Application to Revise Technical Specification Section 5.6.6, Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR) L-PI-23-005, CFR 50.55a Requests Nos. 1-RR-5-15 and 2-RR-5-15, Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv)2023-03-0303 March 2023 CFR 50.55a Requests Nos. 1-RR-5-15 and 2-RR-5-15, Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv) L-PI-23-001, Day Steam Generator Tube Inspection Report2023-01-30030 January 2023 Day Steam Generator Tube Inspection Report L-PI-22-047, Resubmittal of Prairie Island Nuclear Generating Plant (PINGP) 2018 Unit 1 180-Day Steam Generator Tube Inspection Report2022-12-21021 December 2022 Resubmittal of Prairie Island Nuclear Generating Plant (PINGP) 2018 Unit 1 180-Day Steam Generator Tube Inspection Report L-PI-22-020, Application to Revise Technical Specification Section 5.6.6, Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)2022-12-0202 December 2022 Application to Revise Technical Specification Section 5.6.6, Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR) L-PI-22-040, Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections2022-10-0606 October 2022 Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections L-PI-22-037, Updated Approach for Prairie Island Unit 1 and Unit 2 Baffle Former Bolts2022-09-20020 September 2022 Updated Approach for Prairie Island Unit 1 and Unit 2 Baffle Former Bolts L-PI-22-032, CFR 50.46 LOCA Annual Report2022-06-16016 June 2022 CFR 50.46 LOCA Annual Report L-PI-22-033, Response to Request for Additional Information Prairie Island Nuclear Generating Plant, Units 1 and 2, Amendment to Adopt 24-Month Operating Cycles2022-06-10010 June 2022 Response to Request for Additional Information Prairie Island Nuclear Generating Plant, Units 1 and 2, Amendment to Adopt 24-Month Operating Cycles L-PI-22-003, Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections2022-06-0707 June 2022 Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections L-PI-22-024, Supplement to Application for License Amendment to Implement 24-Month Operating Cycle2022-03-0707 March 2022 Supplement to Application for License Amendment to Implement 24-Month Operating Cycle L-PI-21-047, Response to Request for Additional Information 24-Month Cycle Amendment Prairie Island Nuclear Generating Plant, Units 1 and 22021-12-0707 December 2021 Response to Request for Additional Information 24-Month Cycle Amendment Prairie Island Nuclear Generating Plant, Units 1 and 2 L-PI-21-045, Response to Request for Additional Information Cooling Water System License Amendment Request2021-11-0404 November 2021 Response to Request for Additional Information Cooling Water System License Amendment Request L-PI-21-029, Exigent License Amendment Request to Revise Technical Specification 3.7.8 to Allow a One-Time Extension of the Completion Time of Required Action B.12021-10-0707 October 2021 Exigent License Amendment Request to Revise Technical Specification 3.7.8 to Allow a One-Time Extension of the Completion Time of Required Action B.1 L-PI-21-006, License Amendment Request to Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation, to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions2021-10-0202 October 2021 License Amendment Request to Revise Technical Specification 3.3.1, Reactor Trip System (RTS) Instrumentation, to Incorporate Installed Bypass Test Capability for the Power Range RTS Functions L-PI-21-032, Response to Request for Additional Information Amendment Request to Adopt TSTF-471 and 571-T for Prairie Island2021-09-30030 September 2021 Response to Request for Additional Information Amendment Request to Adopt TSTF-471 and 571-T for Prairie Island L-PI-21-016, Application for License Amendment to Implement 24-Month Operating Cycle2021-08-0606 August 2021 Application for License Amendment to Implement 24-Month Operating Cycle L-PI-21-027, 2020 10 CFR 50.46 LOCA Annual Report2021-06-28028 June 2021 2020 10 CFR 50.46 LOCA Annual Report L-PI-21-023, Independent Spent Fuel Storage Installation - 2020 Annual Radiological Environmental Monitoring Program Report2021-05-14014 May 2021 Independent Spent Fuel Storage Installation - 2020 Annual Radiological Environmental Monitoring Program Report L-PI-21-007, Application to Revise Technical Specifications to Adopt TSTF-471, Eliminate Use of the Term Core Alterations in Actions and Notes2021-04-19019 April 2021 Application to Revise Technical Specifications to Adopt TSTF-471, Eliminate Use of the Term Core Alterations in Actions and Notes L-PI-20-050, Request for a One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements, Due to COVID-19 Pandemic2020-10-0707 October 2020 Request for a One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements, Due to COVID-19 Pandemic L-PI-20-051, Supplement to Application to Revise Technical Specifications to Adopt TSTF-547, Clarification of Rod Position Requirements2020-09-28028 September 2020 Supplement to Application to Revise Technical Specifications to Adopt TSTF-547, Clarification of Rod Position Requirements L-PI-20-026, Response to Request for Additional Information: License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiativ2020-09-0101 September 2020 Response to Request for Additional Information: License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 L-PI-20-035, = Request for Revision to Reactor Vessel Material Surveillance Capsule Removal Schedule2020-07-28028 July 2020 = Request for Revision to Reactor Vessel Material Surveillance Capsule Removal Schedule L-PI-20-023, Independent Spent Fuel Storage Installation, Response to Request for Additional Information: License Amendment Request to Expand the Storage Capacity of the Independent Spent Fuel Storage Installation (ISFSI)2020-06-10010 June 2020 Independent Spent Fuel Storage Installation, Response to Request for Additional Information: License Amendment Request to Expand the Storage Capacity of the Independent Spent Fuel Storage Installation (ISFSI) L-PI-20-014, Supplement to License Amendment Request: Expand the Storage Capacity of the Independent Spent Fuel Storage Installation (ISFSI2020-04-29029 April 2020 Supplement to License Amendment Request: Expand the Storage Capacity of the Independent Spent Fuel Storage Installation (ISFSI L-PI-20-004, License Amendment Request to Revise Technical Specifications (TS) to Remove Note I from Limiting Condition for Operating (LCO) 3.4.12 and LCO 3.4.132020-03-30030 March 2020 License Amendment Request to Revise Technical Specifications (TS) to Remove Note I from Limiting Condition for Operating (LCO) 3.4.12 and LCO 3.4.13 L-PI-20-001, License Amendment Request to Address Issues Identified in Westinghouse Nuclear Safety Advisory Letter NSAL-09-5, Revision 1, and NSAL-15-12020-01-29029 January 2020 License Amendment Request to Address Issues Identified in Westinghouse Nuclear Safety Advisory Letter NSAL-09-5, Revision 1, and NSAL-15-1 L-PI-19-041, Application to Revise Technical Specifications to Adopt TSTF-547, Clarification of Rod Position Requirements2019-12-23023 December 2019 Application to Revise Technical Specifications to Adopt TSTF-547, Clarification of Rod Position Requirements L-PI-19-031, License Amendment Request: Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2019-12-16016 December 2019 License Amendment Request: Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b L-PI-19-040, License Amendment Request: Revise Technical Specification 5.5.14 to Permanently Extend Containment Leakage Rate Test Frequency2019-10-0707 October 2019 License Amendment Request: Revise Technical Specification 5.5.14 to Permanently Extend Containment Leakage Rate Test Frequency L-PI-19-038, Submittal of Revised Pressure and Temperature Limits Report2019-09-19019 September 2019 Submittal of Revised Pressure and Temperature Limits Report L-PI-19-037, Response to Request for Additional Information: 10 CFR 50.55a Requests Nos. 1-RR-5-10 and 2-RR-5-10, Proposed Alternative to Reactor Vessel Inservice Inspection (ISI) Intervals2019-09-16016 September 2019 Response to Request for Additional Information: 10 CFR 50.55a Requests Nos. 1-RR-5-10 and 2-RR-5-10, Proposed Alternative to Reactor Vessel Inservice Inspection (ISI) Intervals L-PI-19-025, Request to Approve Site-Specific Probabilistic Risk Assessment (PRA) Model for Flowserve N-Seal Abeyance Seal and Dynamic Testing for the Prairie Island Nuclear Generating Plant (PINGP)2019-08-27027 August 2019 Request to Approve Site-Specific Probabilistic Risk Assessment (PRA) Model for Flowserve N-Seal Abeyance Seal and Dynamic Testing for the Prairie Island Nuclear Generating Plant (PINGP) L-PI-19-029, Supplement to Response to Request for Additional Information: Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components For...2019-08-0505 August 2019 Supplement to Response to Request for Additional Information: Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components For... L-PI-19-002, 10 CFR 50.55a Requests Nos. 1-RR-5-10 and 2-RR-5-10, Proposed Alternative to Reactor Vessel Inservice Inspection (ISI) Intervals for Prairie Island, Unit 1 and Unit 22019-06-13013 June 2019 10 CFR 50.55a Requests Nos. 1-RR-5-10 and 2-RR-5-10, Proposed Alternative to Reactor Vessel Inservice Inspection (ISI) Intervals for Prairie Island, Unit 1 and Unit 2 2024-06-05
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARL-PI-24-030, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3.8.12024-05-22022 May 2024 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3.8.1 L-PI-23-034, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3.7.8, Cooling Water (Cl) System,2024-01-0202 January 2024 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3.7.8, Cooling Water (Cl) System, L-PI-23-035, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Section 5.6.6, Reactor Coolant System (RCS) Pressure and Temperature Limits Report2023-12-20020 December 2023 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Section 5.6.6, Reactor Coolant System (RCS) Pressure and Temperature Limits Report L-PI-23-033, Supplement to License Amendment Request to Revise Technical Specification 3.8.1, Surveillance Requirement 3.8.1.2, Note 32023-12-0505 December 2023 Supplement to License Amendment Request to Revise Technical Specification 3.8.1, Surveillance Requirement 3.8.1.2, Note 3 ML23262B0372023-09-19019 September 2023 Response to NRC Request for Additional Information Regarding the 2023 Monticello and Prairie Island Plant Decommissioning Funding Status Reports L-PI-22-034, Response to RAI, Alternative RR-08 Related to Pressure Isolation Valve Monitoring and Testing2022-07-14014 July 2022 Response to RAI, Alternative RR-08 Related to Pressure Isolation Valve Monitoring and Testing L-PI-22-033, Response to Request for Additional Information Prairie Island Nuclear Generating Plant, Units 1 and 2, Amendment to Adopt 24-Month Operating Cycles2022-06-10010 June 2022 Response to Request for Additional Information Prairie Island Nuclear Generating Plant, Units 1 and 2, Amendment to Adopt 24-Month Operating Cycles ML22161A9152022-06-10010 June 2022 and Prairie Island Nuclear Generating Plant, Units 1 and 2 - Response to a Request for Additional Information Xcel Energy Amendment Request to Create a Common Emergency Plan and Emergency Operations. L-PI-21-047, Response to Request for Additional Information 24-Month Cycle Amendment Prairie Island Nuclear Generating Plant, Units 1 and 22021-12-0707 December 2021 Response to Request for Additional Information 24-Month Cycle Amendment Prairie Island Nuclear Generating Plant, Units 1 and 2 L-PI-21-045, Response to Request for Additional Information Cooling Water System License Amendment Request2021-11-0404 November 2021 Response to Request for Additional Information Cooling Water System License Amendment Request L-PI-21-032, Response to Request for Additional Information Amendment Request to Adopt TSTF-471 and 571-T for Prairie Island2021-09-30030 September 2021 Response to Request for Additional Information Amendment Request to Adopt TSTF-471 and 571-T for Prairie Island L-PI-20-026, Response to Request for Additional Information: License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiativ2020-09-0101 September 2020 Response to Request for Additional Information: License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 L-PI-20-023, Independent Spent Fuel Storage Installation, Response to Request for Additional Information: License Amendment Request to Expand the Storage Capacity of the Independent Spent Fuel Storage Installation (ISFSI)2020-06-10010 June 2020 Independent Spent Fuel Storage Installation, Response to Request for Additional Information: License Amendment Request to Expand the Storage Capacity of the Independent Spent Fuel Storage Installation (ISFSI) ML20045E8942020-02-14014 February 2020 Response to a Request for Additional Information for Proposed 10 CFR 50.55a(z)(2) Alternatives to Utilize ASME Code Case N-786-3, Alternative Requirements for Sleeve Reinforcement of Class 2 and 3 Moderate-Energy Carbon Steel Piping, and AS ML20127J0002019-11-0707 November 2019 Xcel Reply to PIIC Expansion Application L-PI-19-037, Response to Request for Additional Information: 10 CFR 50.55a Requests Nos. 1-RR-5-10 and 2-RR-5-10, Proposed Alternative to Reactor Vessel Inservice Inspection (ISI) Intervals2019-09-16016 September 2019 Response to Request for Additional Information: 10 CFR 50.55a Requests Nos. 1-RR-5-10 and 2-RR-5-10, Proposed Alternative to Reactor Vessel Inservice Inspection (ISI) Intervals L-PI-19-029, Supplement to Response to Request for Additional Information: Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components For...2019-08-0505 August 2019 Supplement to Response to Request for Additional Information: Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components For... L-PI-19-014, Response to Request for Additional Information: Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2019-04-29029 April 2019 Response to Request for Additional Information: Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors L-PI-18-063, Response to Request for Additional Information: Revise License Condition Associated with Implementation of NFPA 8052018-12-0606 December 2018 Response to Request for Additional Information: Revise License Condition Associated with Implementation of NFPA 805 L-PI-18-051, Response to Request for Additional Information: Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program2018-09-17017 September 2018 Response to Request for Additional Information: Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program L-PI-18-038, Supplement to License Amendment Request to Revise License Condition Associated with Implementation of NFPA 8052018-07-10010 July 2018 Supplement to License Amendment Request to Revise License Condition Associated with Implementation of NFPA 805 ML18131A2232018-05-11011 May 2018 Prairie and Monticello - Response to Request for Additional Information Regarding Proposed Alternative to Utilize Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Di L-PI-17-042, Response to Request for Additional Information Regarding License Amendment Request to Revise the NDE Inspection Interval for Special Lifting Devices2017-11-0606 November 2017 Response to Request for Additional Information Regarding License Amendment Request to Revise the NDE Inspection Interval for Special Lifting Devices ML17279A1212017-10-0404 October 2017 Enclosure 2 to L-PI-17-041, Westinghouse-Prepared RAI Responses CE-17-3, Rev. 1, Attachment 2 and Enclosure 3, Marked-Up Technical Specification Page 4.0-7 L-PI-17-035, License Amendment Request to Revise the Emergency Action Level (EAL) Scheme - Supplement and Response to Requests for Additional Information2017-09-27027 September 2017 License Amendment Request to Revise the Emergency Action Level (EAL) Scheme - Supplement and Response to Requests for Additional Information L-PI-17-032, Response to Request for Additional Information Regarding License Amendment Request to Revise Emergency Plan Staff Augmentation Response Times2017-09-20020 September 2017 Response to Request for Additional Information Regarding License Amendment Request to Revise Emergency Plan Staff Augmentation Response Times L-PI-17-007, Response to Request for Additional Information on License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors2017-03-0606 March 2017 Response to Request for Additional Information on License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors L-PI-17-002, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3.8.7 to Remove Non-Conservative Required Action2017-02-16016 February 2017 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 3.8.7 to Remove Non-Conservative Required Action L-PI-16-100, Response to NRC Request for Information - License Amendment Request for Spent Fuel Pool Criticality Technical Specification Changes2017-02-16016 February 2017 Response to NRC Request for Information - License Amendment Request for Spent Fuel Pool Criticality Technical Specification Changes L-PI-16-090, Response to Request for Additional Information on License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors2016-12-14014 December 2016 Response to Request for Additional Information on License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors ML16351A2102016-12-13013 December 2016 External Flooding Assessment Focused Evaluation. (Redacted) ML16288A0972016-10-14014 October 2016 and Monticello - Response to Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools ML16279A4792016-09-29029 September 2016 Flood Hazard Reevaluation Report - Response to Requested Information L-PI-16-076, Supplement to the Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 2, Flood Hazard Reevaluation Report2016-09-29029 September 2016 Supplement to the Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 2, Flood Hazard Reevaluation Report L-PI-16-067, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors- Response to Request for Additional Information2016-08-17017 August 2016 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors- Response to Request for Additional Information L-PI-16-063, Seventh Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events2016-08-17017 August 2016 Seventh Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events L-PI-16-005, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information2016-05-24024 May 2016 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information L-PI-16-040, Supplement to License Amendment Request for Spent Fuel Pool Criticality Technical Specification Changes: Westinghouse-Prepared Response to RAI, CE-16-237, Attachment 2 (Enclosure 4)2016-05-23023 May 2016 Supplement to License Amendment Request for Spent Fuel Pool Criticality Technical Specification Changes: Westinghouse-Prepared Response to RAI, CE-16-237, Attachment 2 (Enclosure 4) ML16144A8062016-05-23023 May 2016 Supplement to License Amendment Request for Spent Fuel Pool Criticality Technical Specification Changes: Response to RAI-2 (Enclosure 1) & Marked-Up Technical Specification Page (Enclosure 2) ML16133A0412016-05-0909 May 2016 Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 2, Flood Hazard Reevaluation Report L-08-001, Response to Requests for Additional Information - License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Revision 2, Using the Consolidated..2016-04-14014 April 2016 Response to Requests for Additional Information - License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Revision 2, Using the Consolidated.. L-PI-16-029, Response to Requests for Additional Information - License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Revision 2,,Using the Consolidated..2016-03-31031 March 2016 Response to Requests for Additional Information - License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Revision 2,,Using the Consolidated.. L-PI-16-004, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors- Response to Request for Additional Information2016-01-20020 January 2016 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors- Response to Request for Additional Information L-PI-16-001, Enclosure 2: Responses to Open and Pending Items from the NRC Audit Report2016-01-14014 January 2016 Enclosure 2: Responses to Open and Pending Items from the NRC Audit Report L-PI-15-105, License Amendment Request (LAR) to Revise Technical Specifications (TS) to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process - Response to Request..2015-12-30030 December 2015 License Amendment Request (LAR) to Revise Technical Specifications (TS) to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process - Response to Request.. L-PI-15-052, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information - 90-Day Responses2015-06-19019 June 2015 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information - 90-Day Responses L-PI-14-113, Updated Final Response to NRC Request for Information Per 10CFR50.54(f) Re Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident2015-01-16016 January 2015 Updated Final Response to NRC Request for Information Per 10CFR50.54(f) Re Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident 2024-05-22
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(l Xcel Energy* January 20, 2016 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 Prairie Island Nuclear Generating Plant 1717 Wakonade Drive East Welch, MN 55089 L-PI-16-004 10 CFR 50.90 10 CFR 50.48(c) License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors-Response to Request for Additional Information (TAC Nos. ME9734 and ME9735)
References:
- 1. NSPM letter, J.P. Sorensen to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, L-PI-12-089, dated September 28, 2012, ADAMS Accession No. ML12278A405.
- 2. NSPM letter, S. Sharp to NRC Document Control Desk, Supplement to License Amendment Request to Adopt NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactors, L-PI-14-045, dated April 30, 2014 (ADAMS Nos. ML14125A106 and ML14125A149).
- 3. NRC email, T. Beltz to S. Chesnutt, Prairie Island Nuclear Generating Plant, Units 1 and 2 -NFPA 805 Requests for Additional Information and Response Timeline (TAG Nos. ME9734 and ME9735), dated March 30, 2015 (ADAMS Accession No. ML15089A157).
- 4. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors -Response to Request for Additional Information, L-PI-15-041, dated May 28,2015 (ADAMS No. ML15153A018).
- 5. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors -Response to Request for Additional Information-90-Day Responses, L-PI-15-052, dated June 19,2015 (ADAMS No. ML15174A139).
Document Control Desk Page 2 6. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors -Response to Final Request for Additional Information (PRA-Second Round), L-PI-15-059, dated October 22, 2015 (ADAMS No. ML15296A259).
- 7. NRC email, T. Beltz to A. Hazel hoff, Prairie Island Nuclear Generating Requests for Additional Information (AFPB) re: LAR to Adopt NFPA 805 (TAG Nos. ME9734 and ME9735), dated January 8, 2016. In Reference 1, the Northern States Power Company, a Minnesota Corporation (NSPM) doing business as Xcel Energy requested approval from the Nuclear Regulatory Commission (NRC) to transition the fire protection licensing basis for the Prairie Island Nuclear Generating Plant (PINGP) to 10 CFR 50.48(c), National Fire Protection Association Standard 805 (NFPA 805). Supplemental information was provided in letters dated November 8, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12314A144) and December 18, 2012 (ADAMS Accession No. ML12354A464).
In Reference 2, NSPM submitted a revised Fire Probabilistic Risk Assessment (PRA) in a supplement to the subject License Amendment Request (LAR). In Reference 3, the NRC staff provided requests for additional information (RAis) regarding this request and also provided a timeline and due dates for submitting responses within 60, 90, or 120 days after an on-site Audit that was conducted March 23-25, 2015. NSPM letter dated May 28, 2015 (Reference
- 4) provided responses to the 60-day RAis and one of the 90-day RAis (Fire Protection Engineering RAI 03). NSPM letter dated June 19, 2015 (Reference
- 5) provided responses to the remaining 90-day RAis. NSPM letter dated October 22, 2015 (Reference
- 6) provided responses to second round RAis and included an Attachment L request, "Approval Request 4 -Wiring Above Suspended Ceilings." In Reference 7, the NRC staff provided RAison this Attachment L request. Enclosure 1 to this letter provides NSPM's responses to these RAis, which are due by January 29, 2016. This letter is submitted in accordance with 10 CFR 50.90. The additional information provided in this letter does not impact the conclusions of the No Significant Hazards Evaluation or Environmental Considerations Evaluation presented in Reference
- 2. In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this additional information by transmitting a copy of this letter to the designated State Official.
If there are any questions or if additional information is needed, please contact Gene Eckholt at 651-267-1742.
Document Control Desk Page 3 Summary of Commitments This letter contains no new commitments and makes no revisions to any existing commitments.
I declare under penalty of perjury that the foregoing is true and correct. Executed on January 20, 2016.
Kevin Davison Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company -Minnesota Enclosure (1) cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota L-PI-16-004 Enclosure NSPM Response to Requests for Additional Information (RAis) Regarding the License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805 at Prairie Island Nuclear Generating Plant Units 1 and 2 NRC Request Fire Protection Engineering (FPE) RAI 07 In a letter dated October 22, 2015 (ADAMS Accession No. ML15296A259), the licensee submitted a new LAR Attachment L, Approval Request 4, which involved using a based method to comply with NFPA 805 Section 3. 3. 5. 1 for the installation of wiring above suspended ceilings in several areas of the plant. a. In Part 1 of the approval request under safety margins and defense in depth, the licensee stated, The introduction of the non-rated and non-enclosed wiring routed above these suspended ceilings does not impact fire protection defense-in-depth.
The wiring located above the ceilings does not compromise administrative fire prevention controls, and does not challenge automatic fire detection and suppression functions, manual fire suppression functions, or post-fire safe shutdown capability." Please provide a technical basis how each of the three echelons of fire protection defense-in-depth is or is not impacted by the wiring above the suspended ceiling in each of the areas of the plant. NSPM Response FPE RAI 07 a. The technical basis for each of the three echelons of fire protection defense-in-depth is provided below. Echelon 1 Preventing fires from starting (e.g., combustible/hot work controls)
The cables in the Fire Areas noted in Approval Request 4 are low voltage video/communication/data cables or low voltage power cable (below 480 VAC) which are not susceptible to self-ignition.
Self-ignited cable fires are screened from consideration for all locations in the plant based on the evaluation documented in the Engineering Change Package 20695 (EC 20695) -Determination of Thermoplastic and Thermoset Cable Types at PINGP. The guidance in NUREG-1805 section 7.3, states that "It is common practice to consider only self-ignited cable fires to occur in power cable trays since they carry enough electrical energy for ignition.
Control, instrumentation, data cables, etc. typically do not carry enough electrical energy for ignition." Additionally, with respect to low voltage power cables, EC 20695 determined that all plant routed thermoplastic cables, and cables with unknown jacket or insulation type were used exclusively in low energy applications (e.g., data, instrumentation, control, low voltage power, etc.); and therefore, based upon the results of the evaluation, and consistent with the guidance in NUREG/CR-6850 and NUREG-1805, it was concluded that no areas in the plant need to postulate self-ignited cable fires. In addition, administrative controls such as combustible controls and hot work controls are not affected.
Page 1 of 3 L-PI-16-004 Enclosure NSPM This preserves Defense-In-Depth (DID) Echelon 1. Echelon 2 Detecting fires quickly and extinguishing those that occur, thereby limiting damage (e.g., fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans) The following fire areas, which were identified in Approval Request 4, have portable fire extinguishers, hose stations, and pre-fire plans that are available for manual firefighting activities by the site fire brigade. This provides assurance that if a fire were to occur the damage from the fire would be limited.
- Fire Area 8 Lunch Room, Unit 1, 715' in Southeast corner
- Fire Area 8 Locker Room, Unit 2, 715' in Northwest corner
- Fire Area 83 SAS and Operations Lounge
- Fire Area 94 Computer Room In addition, the SAS (Part of Fire Area 83) is continually manned providing early notification and the potential use of a fire extinguisher as early extinguishment prior to brigade arrival. This preserves DID Echelon 2. Echelon 3 Providing adequate level of fire protection for structures, systems and components important to safety so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed (e.g., fire barriers, fire rated cable, success path remains free of fire damage, recovery actions) The use of the non-plenum rated cables routed above the suspended ceilings does not prevent essential safety functions from being performed.
The quantity of combustibles associated with the non-rated cabling is considered insignificant with regard to combustible loading in the affected areas. The non-plenum rated cabling does not compromise manual fire suppression functions, or the nuclear safety capability assessment.
This does not impact the ability to achieve and maintain safe and stable conditions.
This preserves DID Echelon 3. NRC Request FPE RAI 07 b. In Part 1 of the approval request, the licensee stated that plant procedures will be revised to ensure that future wiring installation above the suspended ceilings discussed in Part 1 will meet NFPA 805 Section 3.3.5.1, and added Implementation Item 68 in LAR AttachmentS, Table S-3. Please clarify whether Implementation Item 68 will include the administrative control for all suspended ceilings, including the suspended ceiling described in Part 2 of the approval request. Page 2 of 3 L-PI-16-004 Enclosure NSPM Response FPE RAI 07 NSPM b. Implementation Item 68 will include administrative controls for power block areas with suspended ceilings.
An updated Attachment S will be provided with the final PRA RAI 03 submittal.
NRC Request FPE RAI 07 c. In Part 2 of the approval request, the licensee stated that Fire Area 8, Locker Room, Unit 1, 715' in the southeast corner has several cable trays with multiple types and voltages, ranging from free-air runs of low voltage data/communications and lighting cables to open trays containing 120 VAG [volts alternating current] and 4 kV [kilovolt]
power cables above the suspended ceiling. In its discussion of safety margin and depth, the licensee stated, "The introduction of the non-rated and non-enclosed wiring routed above the suspended ceiling in this fire area location does not impact fire protection defense-in-depth.
The wiring located above the ceilings does not compromise administrative fire prevention controls, and does not challenge automatic fire detection and suppression functions, manual fire suppression functions, or post-fire safe shutdown capability." However, the licensee does not discuss the fire hazards associated with the 120 VAG and 4 kV power cables located in open trays and the basis for not challenging the fire protection systems. Please provide a clear technical basis for concluding that the fire hazards, including potential ignition sources, that are associated with the power cables above the suspended ceiling in Fire Area 8, Locker Room, Unit 1, 715' in the southeast corner, do not impact the three elements of defense-in-depth.
Include with the technical basis a specific discussion on how each of the three echelons of fire protection defense-in-depth is or is not impacted by the wiring above the suspended ceiling in Fire Area 8, Locker Room, Unit 1, 715' in the southeast corner. NSPM Response FPE RAI 07 c. NSPM withdraws Part 2 of the Attachment L Request, "Approval Request 4 -Wiring Above Suspended Ceilings," submitted per letter dated October 22, 2015. Attachment S, Table S-2, will be revised to add a modification to bring Fire Area 8 Locker Room, Unit 1, 715' in the southeast corner into compliance with NFPA 805, Section 3.3.5.1. An updated Attachment S will be provided with the final PRA RAI 03 submittal.
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