Text

Application for License Amendment to Implement 24-Month Operating Cycle
	ML21218A093
Person / Time
Site:	Prairie Island
Issue date:	08/06/2021
From:	Domingos C; Northern States Power Company, Minnesota, Xcel Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-PI-21-016
	Download: ML21218A093 (78)
	v • d • e

~ Xcel Energy*

RESPONSIBL E BY NATUR E 1717 Wakonade Drive Welch, MN 55089 August 6, 2021 L-PI-21-016 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Units 1 and 2 Docket Nos. 50-282 and 50-306 Renewed Facility Operating License Nos. DPR-42 and DPR-60 Application for License Amendment to Implement 24-Month Operating Cycle

References:

1. Technical Specification Task Force (TSTF) Improved Standard Technical Specification Traveler TSTF-299, Revision 0, Administrative Controls Program 5.5.2.b Test Interval and Exception, dated November 12, 1998 (ML040620202)

2. NRC Generic Letter (GL) 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, dated April 2, 1991 (ML013100215)

Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), is submitting a request for approval for changes to the Prairie Island Nuclear Generating Plant (PINGP) licensing basis to implement a 24-month operating cycle for PINGP Units 1 and 2 and corresponding changes to the PINGP Technical Specifications (TS). The corresponding TS changes in support of the change in the maximum surveillance intervals from 24 months to 30 months includes a change to one TS Allowable Value and changes to TS 5.5.2 and TS 5.5.17. The proposed change to TS 5.5.2 will implement TSTF-299 (Reference 1), which clarifies the intent of refueling cycle intervals with respect to the system leak test requirements to 24 months plus the allowance of TS Surveillance Requirement (SR) 3.0.2. The proposed change to TS 5.5.17 documents the use of NRC GL 91-04 (Reference 2) to increase the SR intervals in lieu of the TS program. provides a description and assessment of the proposed changes. Attachment 1 to provides the existing TS pages marked up to show the proposed changes. to Enclosure 1 provides revised (clean) TS pages. Enclosure 2 provides an evaluation in accordance with the guidance of NRC Generic Letter 91-04. Table 1 of Enclosure 2 describes the instrumentation to which the proposed change applies. Enclosure 3 provides a summary of the PINGP engineering guidance for instrument drift analysis.

Document Control Desk Page 2 Approval of the proposed amendment is requested by August 22, 2022, in support of the Unit 2 refueling outage scheduled to begin in October of 2022. Once approved, the amendment shall be implemented within 30 days.

In accordance with 10 CFR 50.91 (b)(1 }, a copy of this application, with the enclosures, is being provided to the designated Minnesota Official.

Please contact Mr. Jeff Kivi at (612) 330-5788 or Jeffrey.L.Kivi@xcelenergy.com if there are any questions or if additional information is needed.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

nalty of perjury, that the foregoing is true and correct.

Christopher . Domingos Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (3) cc: Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island , USNRC State of Minnesota

ENCLOSURE 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT License Amendment Request Application for License Amendment to Implement 24-Month Operating Cycle 1.0

SUMMARY

DESCRIPTION ............................................................................................ 2

2.0 BACKGROUND

.............................................................................................................. 2 3.0 DETAILED DESCRIPTION ............................................................................................. 3 3.1 Surveillance Interval Changes for 24-Month Fuel Cycle ...................................... 3 3.2 TS Allowable Values ............................................................................................ 5 3.3 TS 5.5 Programs and Manuals............................................................................. 5 3.4 Reason for the Proposed Changes ...................................................................... 6 3.5 Description of the Proposed TS Changes ............................................................ 6

4.0 TECHNICAL EVALUATION

............................................................................................ 7 4.1 Generic Letter 91-04 Change Evaluation ............................................................. 7 4.2 Variations from NRC Generic Letter 91-04........................................................... 8 4.3 Non-Calibration Changes ..................................................................................... 9 4.4 Calibration Changes ........................................................................................... 11 4.5 Allowable Value Changes .................................................................................. 14 4.6 TSTF-299 ........................................................................................................... 15

5.0 REGULATORY EVALUATION

..................................................................................... 15 5.1 Applicable Regulatory Requirements/Criteria..................................................... 16 5.2 Precedents ......................................................................................................... 17 5.3 No Significant Hazard Consideration Analysis ................................................... 18 5.4 Conclusions........................................................................................................ 21 6.0 ENVIRONMENTAL EVALUATION ............................................................................... 21

7.0 REFERENCES

............................................................................................................. 21 ATTACHMENTS

1. TECHNICAL SPECIFICATIONS PAGES (Markup)

2. TECHNICAL SPECIFICATIONS PAGES (Clean Pages)

L-PI-21-016 NSPM License Amendment Request Application for License Amendment to Implement 24-Month Operating Cycle 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), is submitting a request for approval for changes to the Prairie Island Nuclear Generating Plant (PINGP) licensing basis to implement a 24-month operating cycle for PINGP Units 1 and 2 and corresponding changes to the PINGP Technical Specifications (TS). The corresponding TS changes in support of the change in the maximum surveillance intervals from 24 months to 30 months includes a change to one TS Allowable Value and changes to TS 5.5.2 and TS 5.5.17. The proposed change to TS 5.5.2 will implement TSTF-299 (Reference 1), which clarifies the intent of refueling cycle intervals with respect to the system leak test requirements to 24 months plus the allowance of TS Surveillance Requirement (SR) 3.0.2. The proposed change to TS 5.5.17 documents the use of NRC GL 91-04 (Reference 2) to increase the SR intervals in lieu of the TS program.

2.0 BACKGROUND

In 2002, PINGP Units 1 and 2 license amendments 158 and 149 (Reference 2) adopted improved standard TS (ITS). Although it was the intent of the ITS conversion LAR to include a 24-month fuel cycle extension, not all evaluations to justify moving the Frequencies to 24 months were completed. Therefore, NSPM justified the extension of these TS SR Frequencies to a maximum of 24 months in the ITS conversion LAR submittals and proposed a restriction within TS SR 3.0.2 on the 1.25 Frequency extension (referred to as grace) to all 24-month Frequencies. Any exceptions to the restriction were technically justified and noted in the individual SRs Frequency.

With the adoption of TS Task Force Traveler TSTF-425 in 2019 (Reference 3), TS SR 3.0.2 was updated to align with the NUREG-1431 TS SR 3.0.2 and removed the restriction from TS SR 3.0.2. The restriction was relocated with the specific 24-month Frequencies under the surveillance frequency control program (SFCP) defined by TS. The limitation on grace was relocated from TS SR 3.0.2 to the Surveillance Test Interval (STI) document. Thus, at this time, the PINGP STI states, Unless noted otherwise, TS SR 3.0.2 does not apply to the SRs in Table 2.1 that have a Frequency of 24 months.

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L-PI-21-016 NSPM 3.0 DETAILED DESCRIPTION 3.1 Surveillance Interval Changes for 24-Month Fuel Cycle The following SRs with 24-month intervals in the PI STI have limitations on application of grace and will be revised to allow grace of up to six months or 30 months total:

TS 3.3.1, Reactor Trip System (RTS) Instrumentation SR 3.3.1.10 Perform CHANNEL CALIBRATION SR 3.3.1.11 Perform CHANNEL CALIBRATION SR 3.3.1.12 Perform CHANNEL CALIBRATION SR 3.3.1.13 Perform COT SR 3.3.1.14 Perform TADOT TS 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation SR 3.3.2.6 Perform CHANNEL CALIBRATION SR 3.3.2.7 Perform MASTER RELAY TEST TS 3.3.3, Event Monitoring (EM) Instrumentation SR 3.3.3.2 Perform CHANNEL CALIBRATION TS 3.3.6, Control Room Special Ventilation System (CRSVS) Actuation Instrumentation SR 3.3.6.3 Perform TADOT SR 3.3.6.4 Perform CHANNEL CALIBRATION TS 3.4.1, RCS Pressure, Temperature, and Flow - Departure from Nucleate Boiling (DNB) Limit SR 3.4.1.3 Verify RCS total flow rate is within the limit specified in the COLR TS 3.4.9, Pressurizer SR 3.4.9.2 Verify capacity of each required group of pressurizer heaters is 100 kW SR 3.4.9.3 Verify required pressurizer heaters are capable of being powered from an emergency power supply TS 3.4.11, Pressurizer Power Operated Relief Valves (PORVs)

SR 3.4.11.2 Perform a complete cycle of each Power Operated Relief Valve (PORV)

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L-PI-21-016 NSPM TS 3.4.12, Low Temperature Overpressure Protection (LTOP) - Reactor Coolant System Cold Leg Temperature (RCSPT) > Safety Injection (SI) Pump Disable Temperature SR 3.4.12.5 Perform CHANNEL CALIBRATION for each OPPS actuation channel TS 3.4.13, Low Temperature Overpressure Protection (LTOP) - Reactor Coolant System Cold Leg Temperature (RCSPT) Safety Injection (SI) Pump Disable Temperature SR 3.4.13.6 Perform CHANNEL CALIBRATION for each OPPS actuation channel TS 3.4.16, RCS Leakage Detection Instrumentation SR 3.4.16.3 Perform CHANNEL CALIBRATION of the required containment sump monitor SR 3.4.16.4 Perform CHANNEL CALIBRATION of the required containment radionuclide monitor TS 3.5.2, ECCS - Operating SR 3.5.2.9 Verify each ECCS throttle valve listed in SR 3.5.2.9 is in the correct position SR 3.5.2.10 Verify, by visual inspection, each ECCS train containment sump suction inlet is not restricted by debris and the suction inlet strainers show no evidence of structural distress or abnormal corrosion TS 3.6.5, Containment Spray and Cooling Systems SR 3.6.5.4 Verify cooling water flow rate to each containment fan coil unit is 900 gpm TS 3.6.8, Vacuum Breaker System SR 3.6.8.2 Perform CHANNEL CALIBRATION TS 3.7.3, Main Feedwater Regulation Valves (MFRVs) and MFRV Bypass Valves SR 3.7.3.2 Verify each Main Feedwater Regulation Valve (MFRV) and MFRV bypass valve actuates to the isolation position on an actual or simulated actuation signal Page 4 of 22

L-PI-21-016 NSPM TS 3.7.4, Steam Generator (SG) Power Operated Relief Valves (PORVs)

SR 3.7.4.2 Verify one complete manual cycle of each SG PORV block valve TS 3.7.10, Control Room Special Ventilation System (CRSVS)

SR 3.7.10.4 Verify each CRSVS train in the Emergency Mode delivers 3600 to 4400 cfm through the associated CRSVS filters TS 3.8.1, AC Sources - Operating SR 3.8.1.11 Verify on an actual or simulated loss of offsite power that the DG auto-starts from standby condition TS 3.9.3, Nuclear Instrumentation SR 3.9.3.2 Perform CHANNEL CALIBRATION of required channels 3.2 TS Allowable Values In accordance with the guidance of Generic Letter 91-04, for calibration interval extensions, a comparison of the projected drift errors over the extended calibration interval was made with the values of drift used in the setpoint evaluations. The setpoint evaluations conducted in support of the proposed change in the maximum surveillance interval identified one TS Allowable Value that needs to be changed. No change to the safety analysis (i.e., analytical limit or other design basis assumption) is required to support the Allowable Value change. The following Allowable Value is proposed to change in support of a maximum surveillance interval of 30 months:

TS Table 3.3.2-1 Function 1e, Safety Injection - Steam Line Low Pressure The Allowable Value is revised from 500 psig to 505 psig.

3.3 TS 5.5 Programs and Manuals The following TS 5.5 program changes are requested in support of the amendment.

TS 5.5.2, Primary Coolant Sources Outside Containment The program shall include the following:

b. Integrated leak test requirements for each system at refueling cycle intervals or less.

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L-PI-21-016 NSPM TS 5.5.2 refers to, refueling cycle intervals or less. Therefore, NSPM proposes to adopt TSTF-299 (Reference 4) to change TS 5.5.2 to clarify that the interval is 24 months and that SR 3.0.2 is applicable to TS 5.5.2.

TS 5.5.17, Surveillance Frequency Control Program (SFCP)

This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

The SRs that are within the scope of this request are all in the PINGP STI which is governed by TS 5.5.17, thus, this proposed amendment to allow for longer surveillance intervals using the deterministic methods of Generic Letter 91-04 is addressed in TS 5.5.17 as an exception to use of the SFCP.

3.4 Reason for the Proposed Changes The proposed change applies to SRs that are in the PINGP STI with Frequency of 24 months where allowance of TS SR 3.0.2 may not be applied. That is, for the applicable SRs the current maximum surveillance interval is 24 months, which limits the scheduling of refueling outages to minimize their impact on peak summer generation.

3.5 Description of the Proposed TS Changes The proposed changes to PINGP TS are shown below with deletions struck through and additions underlined.

TS 3.3.2, Table 3.3.2-1, Function 1e, Safety Injection - Steam Line Low Pressure.

Allowable Value 500 505(b) psig 5.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practical. The systems include portions of the Residual Heat Removal and Safety Injection Systems. The program shall include the following:

a. Preventive maintenance and periodic visual inspection requirements; and Page 6 of 22

L-PI-21-016 NSPM

b. Integrated leak test requirements for each system at refueling cycle intervals or less least once per 24 months.

The provisions of SR 3.0.2 are applicable.

5.5.17 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

c. The 24-Month Fuel Cycle related Surveillance Requirement Frequency changes approved by the NRC in Units 1 and 2 License Amendments XXX/YYY were not subject to provision b. Subsequent changes are subject to the Surveillance Frequency Control Program.

cd. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

4.0 TECHNICAL EVALUATION

4.1 Generic Letter 91-04 Change Evaluation NRC GL 91-04 provides generic guidance for evaluating SR interval changes to accommodate a 24-month fuel cycle for two broad SR classifications:

Non-Calibration SRs Calibration SRs Applying the standard TS SR 3.0.2 allowance to extend a SR interval to 1.25 times the interval, the GL 91-04 guidance changes the maximum SR interval to 30 months (24 months times 1.25).

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L-PI-21-016 NSPM NSPM used this guidance to evaluate extending the maximum surveillance interval from 24 months to 30 months. NSPM further broke down the evaluation of Calibration SRs into those with setpoints and TS Allowable Values and those without setpoints and TS Allowable Values.

GL-91-04 defines three evaluation steps for Non-Calibration SR interval changes, and seven steps are defined for calibration SR interval changes. This section describes the approach used by NSPM to address these steps for each proposed SR with 24-month frequency to which NSPM proposes an allowance for grace of 1.25 on the SR frequency. The approach taken by NSPM is consistent with that used to support previous 24-month fuel cycle license amendments including Fermi and Robinson.

Historical SR test data and associated maintenance records were reviewed for both Non-Calibration and Calibration changes to evaluate whether there is any adverse effect on safety.

The licensing basis (Updated Safety Analysis Report and commitments) was reviewed for functions associated with the subject SR intervals.

The impact of instrument drift was evaluated for the proposed calibration SR interval changes.

As a result of the drift evaluation, PINGP instrumentation setpoint and uncertainty calculations will be revised, as necessary, to reflect the proposed calibration SR interval changes. The evaluation also resulted in one proposed change to a TS Allowable Value. Further, calibration information is affected for some instrumentation. The affected calibration surveillance procedures will be revised as part of implementation, prior to the first application of grace to SRs with 24-month frequency.

The results of Non-Calibration and Calibration change reviews support the conclusion that the effect on plant safety associated with the proposed allowance for a maximum surveillance interval of 1.25 times the Frequency for SRs with a frequency of 24 months and increase the maximum interval to 30 months, if any, is small.

4.2 Variations from NRC Generic Letter 91-04 NSPM has two variations from the typical NRC GL 91-04 submittal. The first variation relates to the presumed fuel cycle length and the second variation relates to which SRs Frequencies will be changed by the proposed amendment. These variations did not affect the evaluation of the proposed change.

Variation 1. NRC GL 91-04 presumes that plants are changing from an 18-month to a 24-month Frequency. With the inclusion of TS SR 3.0.2 allowance for a maximum surveillance interval of 1.25 times the Frequency, GL 91-04 typically evaluates a maximum interval change from 22.5 months (18 months plus 4.5 months grace) to 30 months (24 months plus 6 months grace). The change for PINGP will be from 24-month intervals (no grace allowed) to 30 months (24 months plus 6 months grace).

Variation 2. The limitation on applying TS SR 3.0.2 grace applies only to SRs in the PINGP STI with a Frequency of 24 months. SRs with a Frequency of 24 months that are Page 8 of 22

L-PI-21-016 NSPM in the TS, but not in the STI, are already allowed grace by TS SR 3.0.2 as the limitation on grace was relocated to the PINGP STI document as part of the TSTF-425 license amendment (Reference 3). SRs in the STI with Frequency other than 24 months have no limitation on applying TS SR 3.0.2.

4.3 Non-Calibration Changes GL 91-04 identifies three steps to evaluate Non-Calibration changes:

STEP 1: Licensees should evaluate the effect on safety of an increase in 18-month surveillance intervals to accommodate a 24-month fuel cycle. This evaluation should support a conclusion that the effect on safety is small.

EVALUATION Each proposed Non-Calibration SR interval change has been evaluated with respect to the effect on plant safety. The methodology utilized to justify the conclusion that changing the SR interval to allow a grace of 1.25 for SRs with 24-month frequency has a minimal effect on safety, is based on whether the associated function/feature is:

1. Tested on a more frequent basis during the operating cycle by other plant programs;

2. Designed to have redundant counterparts or be single failure proof; or

3. Highly reliable.

A summary of the evaluation of the effect on safety for each proposed Non-Calibration SR interval change is presented in Enclosure 2.

STEP 2: Licensees should confirm that historical plant maintenance and surveillance data support this conclusion.

EVALUATION The SR test history of the affected SRs has been evaluated. This evaluation consisted of a review of available SR test results and associated maintenance records going back to at least 2010 and back to 1999 in some cases. With the allowance of using grace of 1.25 times the interval for SRs with frequency of 24 months, there will be a longer period between each SR performance. If a failure that results in the loss of the associated safety function should occur during the operating cycle, and would only be detected by the performance of the 24-month TS SR without allowance for grace, then the increase in the SR testing interval could reduce the associated function availability.

In addition to evaluating these SR failures, potential common failures of similar components tested by different SRs were also evaluated. This additional evaluation determined whether there is evidence of repetitive failures among similar plant Page 9 of 22

L-PI-21-016 NSPM components. These common component failures have been further evaluated to determine if there was an impact on plant reliability.

The evaluation documented in Enclosure 2 determined that current plant programs are adequate to ensure system reliability. SR failures that are discussed in Enclosure 2 exclude failures that:

1. Did not impact a TS safety function or TS operability;

2. Are detectable by required testing performed more frequently than the SR being extended; or

3. The cause can be attributed to an associated event such as a preventative maintenance task, human error, previous modification, or previously existing design deficiency; or that were subsequently re-performed successfully with no intervening corrective maintenance (e.g., plant conditions or malfunctioning measurement and test equipment may have caused aborting the test performance).

These types of failures are not related to potential unavailability due to SR interval extension and were therefore not further evaluated. This review of SR test history validates the conclusion that the impact, if any, on system availability will be minimal as a result of the change to allow applying grace to SRs with a 24-month SR interval.

Specific SR test failures and justification for this conclusion are discussed in Enclosure 2.

STEP 3: Licensees should confirm that assumptions in the plant licensing basis would not be invalidated on the basis of performing any surveillance at the bounding SR interval limit provided to accommodate a 24-month fuel cycle.

EVALUATION The impact of the proposed SR changes was reviewed to confirm that assumptions in the plant licensing basis would not be invalidated. In general, SR intervals are not discussed in the descriptions of functions in the plant licensing basis. A review of the PINGP Updated Safety Analysis (USAR) and PINGP commitments identified that no assumptions in the plant licensing basis that would be invalidated by the proposed bounding SR interval changes. Any necessary conforming changes will be made during implementation of the license amendment as required by 10 CFR 50.71(e), or permitted by 10 CFR 50.59.

If the proposed SR interval changes were to lead to degrading performance, NSPM would address such degradation as a routine part of Maintenance Rule Program evaluations or, in some cases, evaluations conducted under the surveillance frequency control program (SFCP). Systems and functions included in the scope of the Maintenance Rule are monitored under the Maintenance Rule program. Component and/or train level monitoring is required for high risk SSCs associated with surveillance frequencies that have been extended using the SFCP. If component and/or train Page 10 of 22

L-PI-21-016 NSPM monitoring is not already performed as part of the Maintenance Rule performance monitoring for SSCs affected by a SFCP surveillance frequency change, additional monitoring is required under the NSPM SFCP.

GL 91-04 states that licensees need not quantify the effect of the change in surveillance intervals on the availability of individual systems or components.

The proposed changes increase the bounding SR interval limit from 24 to 30 months (a maximum of 30 months including the 25% extension afforded by TS SR 3.0.2 where applicable) for the non-calibration SRs evaluated in Enclosure 2. The evaluations provided for each of these changes support the conclusion that: the effect of these changes on plant safety, if any is small; that the changes do not invalidate any assumption in the plant licensing basis; and that the impact, if any, on system availability is minimal. The surveillance failure analysis review of the Prairie Island Units 1 and 2 SR performance history that supports this conclusion is summarized for each SR in Enclosure 2.

4.4 Calibration Changes GL 91-04 identifies seven steps for the evaluation of instrumentation Calibration changes.

STEP 1: Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval.

EVALUATION Historically, As-Found tolerances used in Surveillance Procedures at Prairie Island have been based on instrument accuracy. As required by plant procedures, out of tolerance conditions detected during performance of Surveillance Procedures are entered into the Corrective Action Program (CAP) for evaluation and trending. This ensures identification of occurrences of instruments found outside of their Allowable Value and instruments whose performance is not as anticipated by the setpoint analysis. When an instrument under surveillance is found to have exceeded the As-Found tolerance (i.e., acceptable limits) provided in the Surveillance Procedures, a CAP report is initiated and referenced/attached to the Work Order and an operability analysis is performed to determine if the out of tolerance condition has challenged the operability of the loop.

The difference between As-Found and As-Left data collected during performance of surveillance procedures represents the combined effects of instrument reference accuracy, calibration error, time dependent error and normal radiation effects. Statistical analysis was performed for all instruments which perform a SR function on the As-Found and As-Left data from surveillance procedures to determine a statistical drift value that is representative of data collected since 1999 or since when the instrument Page 11 of 22

L-PI-21-016 NSPM was replaced. The statistically determined drift was extrapolated for a surveillance interval of 30 months (24 months plus 25%).

A Summary Technical Specification Trip Setpoint Calculation was developed using the 30-month extrapolated drift values to determine the impact on loop uncertainty, Nominal Trip Setpoint and Allowable Value for all instrumentation providing Safety Related functions. Results of the Summary Technical Specification Trip Setpoint Calculation demonstrated whether or not existing Allowable Value and Nominal Trip Setpoint are conservative assuming a 30-month surveillance interval. The Summary Technical Specification Trip Setpoint Calculation also assessed the availability of margin between the actual plant setting and Nominal Trip Setpoint as well as ensuring that the existing as-found setting tolerance specified in Surveillance Procedures does not challenge the Allowable Value from Technical Specifications. The Summary Technical Specification Trip Setpoint Calculation identified one instance where the Allowable Value will need to be revised to support an extension of the surveillance interval to 30 months.

STEP 2: Confirm that the values of drift for each instrument type (make, model, and range) and application have been determined with a high probability and a high degree of confidence. Provide a summary of the methodology and assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data.

EVALUATION A listing of the lead instrument make, model, and range affected by this submittal is provided in Table 1 of Enclosure 2. The effect of longer calibration intervals on the TS instrumentation was evaluated by performing an instrument drift study. In performing the drift study, the recorded channel calibration data for associated instruments was obtained from records going back to at least 2010 and back to 1999 in some cases.

This historical calibration data was analyzed to determine a statistically valid representation of instrument drift.

The methodology used to perform the drift analysis is consistent with the methodology utilized by other utilities requesting transition to a 24-month fuel cycle. The PINGP methodology is based on EPRI TR-103335, Revision 2, Guidelines for Instrument Calibration Extension/Reduction Programs. A summary of the methodology is provided in Enclosure 3.

STEP 3: Confirm that the magnitude of instrument drift has been determined with a high probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument type (make, model number, and range) and application that performs a safety function. Provide a list of the channels by TS section that identifies these instrument applications.

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L-PI-21-016 NSPM EVALUATION In accordance with the methodology described in Enclosure 3, the magnitude of instrument drift has been determined with a high probability and a high degree of confidence (typically 95/95) for a bounding calibration interval of 30 months for each instrument make, model, and range. For instruments not in service long enough to establish a projected drift value, or where an insufficient number of calibrations have been performed to utilize the statistical methods (i.e., fewer than 30 calibrations for any given group of instruments), the proposed allowance to apply 1.25 grace to SRs with frequency of 24 months is based on justification obtained from analysis using the method presented in Enclosure 3. The list of affected channels by TS section, including instrument make, model, and range, is provided in Table 1 of Enclosure 2.

STEP 4: Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analysis. If this results in revised setpoints to accommodate larger drift errors, provide proposed TS changes to update trip setpoints. If the drift errors result in revised safety analysis to support existing setpoints, provide a summary of the updated analysis conclusions to confirm that safety limits and safety analysis assumptions are not exceeded.

EVALUATION The projected 30-month drift values were compared to the design allowances as calculated in the associated instrument setpoint analyses documented in a Summary Technical Specification Trip Setpoint Calculation. The Summary Technical Specification Trip Setpoint Calculation identified one instance where the Allowable Value will need to be revised to support an extension of the surveillance interval to a maximum of 30 months including the 25% extension afforded by TS SR 3.0.2 where applicable.

The individual setpoint calculations will be revised using the PINGP setpoint methodology. The affected calibration surveillance procedures will be revised as part of implementation, prior to implementing the allowance to apply grace of 1.25 to SRs with frequency of 24 months.

STEP 5: Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to effect a safe shutdown with the associated instrumentation.

EVALUATION Enclosure 2 discusses the evaluation of impact of drift on instrument setpoint and uncertainty calculations associated with allowing a grace of 1.25 to SRs with frequency of 24 months. This evaluation includes instrumentation used for safe shutdown. The revised setpoint and uncertainty calculations change calibration information if needed to accommodate allowing a grace of 1.25 to SRs with frequency of 24 months. The Page 13 of 22

L-PI-21-016 NSPM changes in calibration information provide assurance that the instrumentation will perform with the required accuracy to effect a safe shutdown. The calibration information is implemented through plant calibration procedures. The affected calibration surveillance procedures will be revised as part of implementation, prior to the first application of grace to SRs in the PINGP STI with frequency of 24 months.

STEP 6: Confirm that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant SR procedures for channel checks, channel functional tests, and channel calibrations.

EVALUATION As discussed above, the revised setpoint and uncertainty calculations will result in changes to calibration information which are implemented through plant calibration procedures. The affected calibration surveillance procedures will be revised as part of implementation, prior to the first application of grace to SRs in the PINGP STI with frequency of 24 months. Existing plant processes ensure that the conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for channel checks, channel functional tests and channel calibrations.

STEP 7: Provide a summary description of the program for monitoring and assessing the effects of increased calibration surveillance intervals on instrument drift and its effect on safety.

EVALUATION Instruments with TS calibration SR intervals of up to 30 months will be monitored and trended in accordance with station procedures including recording of as-found and as-left calibration data. As required by plant procedures, out of tolerance conditions are entered into the corrective action program and are evaluated and trended. This approach will identify occurrences of instruments found outside of their allowable value and instruments whose performance is not as assumed in the drift or setpoint analysis.

When the as found conditions are outside the As-Found tolerance (i.e., acceptable limits), an evaluation will be performed in accordance with the station corrective action program to evaluate the effect, if any, on plant safety.

4.5 Allowable Value Changes The supporting setpoint evaluations were developed in accordance with PINGP instrument setpoint and drift analysis methodologies, which are based, in part, upon Regulatory Guide (RG) 1.105, Revision 2, and Instrument Society of America (ISA) Standard 67.04-1988.

Additional discussion is provided in 5.1.3, below.

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L-PI-21-016 NSPM These evaluations assessed the instrument uncertainties, setpoint, and allowable value for the affected function. The allowable values were determined in a manner suitable to establish limits for their application. As such, the revised allowable values ensure that sufficient margins are maintained in the applicable safety analyses to confirm the affected instruments are capable of performing their intended design function.

4.6 TSTF-299 NSPM has reviewed TSTF-299 (Reference 4) with regard to PINGP Units 1 and 2 and concluded that implementation would continue to provide adequate safety because the change is administrative in nature. In Reference 5, the NRC acknowledged their approval of TSTF-299, Revision 0, which is applicable to NUREG-1431. The revised wording is a voluntary administrative change to the TS that does not alter the design basis of the plant.

The revised TS 5.5.2.b will require system leak testing at least once per 24 months. However, a refueling cycle interval may be longer than 24 months. Incorporating the allowance to apply a 25 percent frequency extension, as provided in SR 3.0.2, to the system leak test requirements allows flexibility in scheduling that is inherent in the current requirement of at refueling cycle intervals or less. The applicability of SR 3.0.2 must be explicitly stated in TS 5.5.2.

The fixed testing frequency of at least once every 24 months is more precise than the current frequency of at refueling cycle intervals or less and is consistent with similar requirements in the PINGP TS and the Standard Technical Specifications. Adopting this more precise terminology is a clarification of the test frequency that matches the proposed changes in this license amendment request. The proposed TS change implementing TSTF-299 is administrative in nature.

Extending the test frequency by 25 percent is consistent with the test extension permitted in the Standard Technical Specifications. The 25 percent test frequency extension provides flexibility that supports consistent scheduling of refueling outages.

5.0 REGULATORY EVALUATION

The proposed change involves allowance of a grace of 1.25 on the frequency of SRs with a frequency of 24 months. The proposed changes are based on the guidance provided by NRC GL 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, dated April 2, 1991 (ML013100215). The guidance provided by GL 91-04 has been used as the basis for all 24-month fuel cycle SR interval license amendments requested and approved since April 2, 1991.

NSPM has evaluated the proposed change and supporting information provided by this submittal relative to the GL 91-04 guidance. NSPM has concluded the proposed change and supporting information are consistent with and satisfy the guidance provided by GL 91-04.

Page 15 of 22

L-PI-21-016 NSPM NSPM has further evaluated the proposed allowable value change to determine whether applicable regulations and requirements continue to be met.

In addition, NSPM has evaluated the proposed change with respect to the applicable regulatory requirements discussed below. NSPM has concluded that the proposed change does not impact conformance with regulatory requirements.

5.1 Applicable Regulatory Requirements/Criteria 5.1.1 10 CFR 50.36 10 CFR 50.36, Technical Specifications, defines the content required in licensee TS.

Specifically, 10 CFR 50.36(c)(3) requires that the TS include SR requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The proposed changes will allow the application of grace of 1.25 (consistent with PINGP TS SR 3.0.2) to SRs with a frequency of 24 months. No SRs are eliminated by the proposed changes. The proposed changes have been evaluated using the guidance provided by GL 91-04.

Based on this evaluation, the proposed SR interval changes continue to support compliance 10 CFR 50.36(c)(3).

5.1.2 Principal Design Criteria PINGP was not licensed to the 10 CFR 50, Appendix A, General Design Criteria (GDC) and was designed and constructed to comply with NSPMs understanding of the intent of the AEC General Design Criteria for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. Since the construction of the plant was significantly completed prior to the issuance of the February 20, 1971, 10CFR50, Appendix A GDC, the plant was not reanalyzed and the Final Safety Analysis Report (FSAR) was not revised to reflect these later criteria. However, the AEC Safety Evaluation Report acknowledged that the AEC staff assessed the plant, as described in the FSAR, against the Appendix A design criteria and ... are satisfied that the plant design generally conforms to the intent of these criteria.

Criterion 19, Protection Systems Reliability Protection systems shall be designed for high functional reliability and in-service testability commensurate with the safety functions to be performed.

The proposed changes to SR intervals have no impact on the physical configuration, design, function, or capability to test protection systems. Therefore, PINGP conformance to Criterion 19 is unaffected by the proposed changes.

Criterion 38, Reliability and Testability of Engineered Safety Features All engineered safety features shall be designed to provide high functional reliability and ready testability. In determining the suitability of a facility for proposed site, the degree Page 16 of 22

L-PI-21-016 NSPM of reliance upon and acceptance of the inherent and engineered safety afforded by the systems, including engineered safety features, will be influenced by the known and the demonstrated performance capability and reliability of the systems, and by the extent to which the operability of such systems can be tested and inspected where appropriate during the life of the plant.

The proposed changes to SR intervals have no impact on the physical configuration, design, function, or capability to test engineered safety features. Therefore, PINGP conformance to Criterion 38 is unaffected by the proposed changes.

Criterion 39, Emergency Power for Engineered Safety Features Alternate power systems shall be provided and designed with adequate independency, redundancy, capacity, and testability to permit the functioning required of the engineered safety features. As a minimum, the onsite power system and the offsite power system shall each, independently, provide this capacity assuming a failure of a single active component in each power system.

The proposed changes to SR intervals have no impact on the physical configuration, design, function, or capability to test emergency power systems. Therefore, PINGP conformance to Criterion 39 is unaffected by the proposed changes.

5.1.3 Codes and Standards The new allowable value has been determined in accordance with the guidance provided in the PINGP drift analysis and setpoint methodologies, which are based, in part, upon RG 1.105, Revision 2, and ISA 67.04-1988. The use of RG 1.105, Revision 2, and ISA 67.04-1988 (referred to as ISA 67.04-1987) was addressed in detail in the PINGP ITS submittal and the NRC safety evaluation for the associated amendments.

(Reference 2)

These evaluations determine the instrument uncertainties, setpoints, and allowable values for the affected functions. The allowable values have been determined in a manner suitable to establish limits for their application. As such, the revised allowable value ensures that sufficient margins are maintained in the applicable safety analyses to confirm the affected instrument is capable of performing its intended design function.

NSPM has determined that the proposed change does not require any exemptions or relief from regulatory requirements, other than the TS.

5.2 Precedents NRC GL 91-04 provides generic guidance for evaluating SR interval changes from 18 to 24 months. GL 91-04 identifies specific considerations to be addressed in applications to extend SR intervals to 24 months (including grace of up to 1.25 times the interval or 30 months). The methodology and approach taken by NSPM in addressing the GL 91-04 considerations is Page 17 of 22

L-PI-21-016 NSPM consistent with that used to support previous similar license amendments. Recent precedents include:

Fermi 2, Amendment No. 218, dated February 24, 2021 (ML20358A155)

Robinson 2, Amendment No. 258, dated May 25, 2018 (ML18115A150)

TSTF-299 (Reference 4) provides for clarifying and adding flexibility to the testing requirements in TS 5.5.2.b. Reference 5 documents the NRC approval of TSTF-299. A recent precedent for adopting TSTF-299 is Browns Ferry Units 1, 2, and 3 Amendment Nos. 301, 325, and 285, dated November 8, 2017 (ML17277A207).

5.3 No Significant Hazard Consideration Analysis Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), is submitting a request for approval for a change to the Prairie Island Nuclear Generating Plant (PINGP) licensing basis to implement a 24-month fuel cycle for PINGP Units 1 and 2. The proposed Technical Specifications (TS) change supports removing the restriction against applying the grace of TS Surveillance Requirement (SR) 3.0.2 to SRs in the PINGP Surveillance Test Interval (STI) document that have a Frequency of 24 months by utilizing the approach contained within Generic Letter 91-04 in lieu of the approach allowed by TS 5.5.17. In effect, this changes the maximum surveillance interval for this set of SRs from 24 months to 30 months. As a result of the analysis supporting the change, one change to a TS Allowable Value was identified.

The proposed TSTF-299, Administrative Controls Program 5.5.2.b Test Interval and Exception, administrative change revises TS 5.5.2, Primary Coolant Sources Outside Containment, to clarify the intent of refueling cycle intervals to be 24 months with the ability to apply the 25 percent allowance of SR 3.0.2.

NSPM has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change supports removing the restriction against applying the grace of TS SR 3.0.2 to SRs in the PINGP STI that have a Frequency of 24 months and changes the maximum surveillance interval for this set of SRs from 24 months to 30 months. The proposed change does not physically alter the plant or its operation. The changes in calibration tolerances assure that the instrumentation continues to function as assumed in the accident analyses. The proposed change does not degrade the performance of, or increase the challenges to, any safety systems assumed to function in the accident Page 18 of 22

L-PI-21-016 NSPM analysis. The proposed change does not impact the usefulness of the SR and testing requirements in evaluating the operability of required systems and components, or the way in which the SRs are performed. In addition, the SR intervals are not considered to be an initiator of any analyzed accident, nor do the SR interval changes introduce any new accident initiators. Therefore, the proposed change does not involve a significant increase in the probability of an accident previously evaluated.

The proposed change does not affect the performance of any equipment credited to mitigate the radiological consequences of an accident. Evaluation of the proposed change demonstrated that the availability of credited equipment is not significantly affected because of other more frequent testing that is performed, the availability of redundant systems and equipment, and the high reliability of the equipment. Historical review of SR test results and associated maintenance records did not find evidence of failures that would invalidate the above conclusions.

One change to an Allowable Value has been developed in accordance with PINGP methodologies discussed above, to ensure that the design and safety analysis limits are satisfied. The methodologies used for the development of the Allowable Value ensures the affected instrumentation remains capable of mitigating design basis events as described in the safety analyses and that the results and radiological consequences described in the safety analyses remain bounding.

The proposed change to adopt TSTF-299 affects only the interval at which system leak tests are performed, not the effectiveness of the system leak test requirements.

Revising the system leak test requirements from at refueling cycle intervals or less to at least once per 24 months is considered to be an administrative change because PINGP Units 1 and 2 will operate on 24-month fuel cycles with approval of the proposed change. Incorporation of the allowance to extend the 24-month interval by 25 percent, as allowed by SR 3.0.2, does not significantly degrade the reliability that results from performing the TS 5.5.2.b leak tests at the currently specified test interval.

Test intervals are not considered as initiators of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased by the proposed change. TS 5.5.2 continues to require the performance of periodic system leak tests. Therefore, accident analysis assumptions will still be verified. As a result, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?

Response: No Page 19 of 22

L-PI-21-016 NSPM The proposed change supports removing the restriction against applying the grace of TS SR 3.0.2 to SRs in the PINGP STI that have a Frequency of 24 months and this changes the maximum surveillance interval for this set of SRs from 24 months to 30 months. One Allowable Value is changed to support the interval increase. No analytical limits are changed. The proposed change does not physically alter the plant or its operation or result in installed equipment being operated in a different manner. The changes in calibration tolerances assure that the instrumentation continues to function as assumed in the accident analyses. The proposed change does not degrade the performance of, or increase the challenges to, any safety systems assumed to function in the accident analysis. Therefore, the proposed change does not introduce any failure mechanisms of a different type than those previously evaluated.

The proposed TSTF-299 adoption affects only the interval at which system leak tests are performed and does not alter the design or physical configuration of the plant. No changes are being made to PINGP Units 1 and 2 that would introduce any new accident causal mechanisms.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change supports removing the restriction against applying the grace of TS SR 3.0.2 to SRs in the PINGP STI that have a Frequency of 24 months and changes the maximum surveillance interval for this set of SRs from 24 months to 30 months. The evaluation of the historical SR test data concludes the proposed SR interval changes will have little, if any, impact on system availability. Performance of other more frequent testing, the existence of redundant systems and equipment, and overall system reliability supports this conclusion. The proposed change does not physically alter the plant or the performance of functions assumed in accident analyses. Existing margin between plant operating conditions and setpoints is not affected by the proposed change. The proposed change to one TS instrumentation Allowable Value is the result of application of the NSPM setpoint methodology using plant specific drift values. The revised Allowable Value more accurately reflects total instrumentation loop accuracy including drift while continuing to protect any assumed analytical limit. The proposed change does not result in any hardware changes or in any changes to the analytical limits assumed in accident analyses. Existing operating margin between plant conditions and actual plant setpoints is not significantly reduced due to these changes.

The proposed change does not significantly impact any safety analysis assumptions or results.

The proposed change to adopt TSTF-299 does not change the design or function of plant equipment and does not significantly reduce the level of assurance that any plant Page 20 of 22

L-PI-21-016 NSPM equipment will be available to perform its function. The proposed change provides operational flexibility without significantly affecting plant operation.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, NSPM concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

7.0 REFERENCES

1. NRC Generic Letter 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, dated April 2, 1991. (NRC ADAMS Accession No. ML013100215)

2. Letter from the NRC to Nuclear Management Company, Prairie Island Nuclear Generating Plant, Units 1 and 2 - Issuance of Amendments Re: Conversion to Improved Technical Specifications, dated July 26, 2002. (NRC ADAMS Accession No. ML022070654)

3. Letter from the NRC to NSPM, Prairie Island Nuclear Generating Plant, Units 1 and 2 -

Issuance of Amendments Re: Adoption of TSTF-425, Revision 3, Relocation of Page 21 of 22

L-PI-21-016 NSPM Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B, (NRC ADAMS Accession No. ML19045A480)

4. Technical Specification Task Force (TSTF) Improved Standard Technical Specification Traveler TSTF-299, Revision 0, Administrative Controls Program 5.5.2.b Test Interval and Exception, dated November 12, 1998 (ML040620202)

5. Letter from the NRC to Nuclear Energy Institute (NEI), TSTF Status Report - October 2000, dated October 31, 2000 (ML003765449)

Page 22 of 22

ENCLOSURE 1, ATTACHMENT 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 License Amendment Request Application for License Amendment to Implement 24-Month Operating Cycle TECHNICAL SPECIFICATIONS PAGES (Markup)

(3 Pages Follow)

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 1 of 4)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE

1. Safety Injection

a. Manual 1, 2, 3, 4 2 B SR 3.3.2.5 NA Initiation

b. Automatic 1, 2, 3, 4 2 trains C SR 3.3.2.2 NA Actuation Relay SR 3.3.2.8 Logic

c. High 1, 2, 3 3 D SR 3.3.2.1 < 4.0 psig Containment SR 3.3.2.3 Pressure SR 3.3.2.6

d. Pressurizer Low 1, 2, 3(a) 3 D SR 3.3.2.1 > 1760 psig Pressure SR 3.3.2.3 SR 3.3.2.6

e. Steam Line Low 1, 2, 3(a) 3 per steam D SR 3.3.2.1 > 500(b) psig Pressure line SR 3.3.2.3 SR 3.3.2.6 505

2. Containment Spray

a. Manual Initiation 1, 2, 3, 4 2 B SR 3.3.2.4 NA

b. Automatic 1, 2, 3, 4 2 trains C SR 3.3.2.2 NA Actuation SR 3.3.2.8 Relay Logic (a) Pressurizer Pressure > 2000 psig.

(b) Time constants used in the lead/lag controller are t1 > 12 seconds and t2 < 2 seconds.

Prairie Island Unit 1 - Amendment No. 235 Units 1 and 2 3.3.2-10 Unit 2 - Amendment No. 223

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.1 Offsite Dose Calculation Manual (ODCM) (continued)

c. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed. The date (i.e., month and year) the change was implemented shall be indicated.

5.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practical. The systems include portions of the Residual Heat Removal and Safety Injection Systems. The program shall include the following:

a. Preventive maintenance and periodic visual inspection requirements; and

b. Integrated leak test requirements for each system at refueling cycle intervals or less.

The provisions of SR 3.0.2 are applicable.

5.5.3 Post Accident Sampling least once per 24 months.

This program provides controls that ensure the capability to obtain and analyze reactor coolant, radioactive gases, and particulates in plant gaseous effluents and containment atmosphere samples under accident conditions.

The program shall include the following:

a. Training of personnel;

b. Procedures for sampling and analysis; and

c. Provisions for maintenance of sampling and analysis equipment.

Prairie Island Unit 1 - Amendment No. 158 Units 1 and 2 5.0-8 Unit 2 - Amendment No. 149

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 Control Room Envelope Habitability Program (continued)

e. The quantitative limits on unfiltered air in-leakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered in-leakage measured by the testing described in paragraph c.

The unfiltered air in-leakage limit for radiological challenges is the in-leakage flow rate assumed in the licensing basis analysis of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions of the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability and determining CRE unfiltered in-leakage as required by paragraph c.

5.5.17 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are d applicable to the Frequencies established in the Surveillance Frequency Control Program.

c. The 24-Month Fuel Cycle related Surveillance Requirement Frequency changes approved by the NRC in Units 1 and 2 License Amendments XXX/

YYY were not subject to provision b. Subsequent changes are subject to the Surveillance Frequency Control Program.

Prairie Island Unit 1 - Amendment No. 235 Units 1 and 2 5.0-29 Unit 2 - Amendment No. 223

ENCLOSURE 1, ATTACHMENT 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 License Amendment Request Application for License Amendment to Implement 24-Month Operating Cycle TECHNICAL SPECIFICATIONS PAGES (Clean Pages)

(3 Pages Follow)

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 1 of 4)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE

1. Safety Injection

a. Manual 1, 2, 3, 4 2 B SR 3.3.2.5 NA Initiation

b. Automatic 1, 2, 3, 4 2 trains C SR 3.3.2.2 NA Actuation Relay SR 3.3.2.8 Logic

c. High 1, 2, 3 3 D SR 3.3.2.1 < 4.0 psig Containment SR 3.3.2.3 Pressure SR 3.3.2.6

d. Pressurizer Low 1, 2, 3(a) 3 D SR 3.3.2.1 > 1760 psig Pressure SR 3.3.2.3 SR 3.3.2.6

e. Steam Line Low 1, 2, 3(a) 3 per steam D SR 3.3.2.1 > 505(b) psig Pressure line SR 3.3.2.3 SR 3.3.2.6

2. Containment Spray

a. Manual Initiation 1, 2, 3, 4 2 B SR 3.3.2.4 NA

b. Automatic 1, 2, 3, 4 2 trains C SR 3.3.2.2 NA Actuation SR 3.3.2.8 Relay Logic (a) Pressurizer Pressure > 2000 psig.

(b) Time constants used in the lead/lag controller are t1 > 12 seconds and t2 < 2 seconds.

Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 3.3.2-10 Unit 2 - Amendment No. YYY

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.1 Offsite Dose Calculation Manual (ODCM) (continued)

c. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed. The date (i.e., month and year) the change was implemented shall be indicated.

5.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practical. The systems include portions of the Residual Heat Removal and Safety Injection Systems. The program shall include the following:

a. Preventive maintenance and periodic visual inspection requirements; and

b. Integrated leak test requirements for each system at least once per 24 months.

The provisions of SR 3.0.2 are applicable.

5.5.3 Post Accident Sampling This program provides controls that ensure the capability to obtain and analyze reactor coolant, radioactive gases, and particulates in plant gaseous effluents and containment atmosphere samples under accident conditions.

The program shall include the following:

a. Training of personnel;

b. Procedures for sampling and analysis; and Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 5.0-8 Unit 2 - Amendment No. YYY