ML091050619

License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26

ML091050619
Person / Time
Site:	Monticello, Prairie Island
Issue date:	04/15/2009
From:	Salamon G Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-XE-09-006, TSTF-511, Rev. 0
Download: ML091050619 (18)

Text

Xcel Enerc/ya A

April 15, 2009 414 Nicollet Mall - MP4 Minneapolis, MN 55401 L-XE-09-006 10 CFR 50.90 U.S. Nuclear Regulatory C80mmission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Monticello Nuclear Generating Plant Units 1 and 2 Docket 50-263 Dockets 50-282, 50-306 Renewed License No. DPR-22 License Nos. DPR-42 and DPR-60 License Amendment Request for Adoption of TSTF-511, Rev. 0, "Eliminate Working Hour Restrictions From TS 5.2.2 To Support Compliance With 10 CFR Part 26" In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Northern States Power, a Minnesota corporation (NSPM) is submitting requests for amendments to the Technical Specifications (TS) for Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP) and Monticello Nuclear Generating Plant (MNGP).

The proposed amendment would delete those portions of TS superseded by 10 CFR Part 26, Subpart I. This change is consistent with tlhe Nuclear Regulatory Commission (NRC) approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-511, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26", except that a minor difference in TS 5.2.2 paragraph lettering is proposed. The availability of this TS improvement was announced in the Federal Register on December 30,2008 (73 FR 79923) as part of the consiolidated line item improvement process (CLIIP). provides an evaluation of the proposed change. Enclosure 2 provides the existing TS pages marked up to show the proposed change for PINGP. Enclosure 3 provides the existing TS piages marked up to show the proposed change for MNGP. provides the proposed TS changes in ffinal typed format for PINGP. provides the proposed TS changes in final typed format for MNGP.

NSPM requests approval of the proposed license amendments by September 1,2009, to support implementation of TS changes concurre~nt with implementation of the new 10 CFR 26, Subpart I requirements by October 1, i!009. In accordance with 10 CFR 50.91, a copy of this applic:ation, with attachments, is being provided to the designated Minnesota Official.

Document Control Desk Page 2 If you should have any questions regarding this suk~mittal, please contact Mr. Dale Vincent, P.E., at 851-388-1 121.

Summaw of Commitments This letter contains no revi!;ions to existing commitments. This letter contains the following new commitment:

Removal of the plant-specific TS requiremenlts will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements. This commitment will be completed no later than (October 1, 2009.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on April 15, 200E1.

Gabor Salamon Director, Nuclear Licensing and Emergency Prepar~edness Northern States Power Col-npany - Minnesota Enclosures (5) cc:

Administrator, Region Ill, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC Project Manager, MNGP, USNRC Resident Inspector, MNGP, USNRC State of Minnesota

ENCLOSURE Evaluation of the Proposed Changes License Amendment Relquest (LAR) for Adoption of TSTFdl I, Rev. 0, "Eliminate Working Hour Restrictions From TS 5.2.2 To Support Compliance With 10 CFR Part 26"

1.

DESCRIPTION

2.

PROPOSED CHANGE

3.

BACKGROUND

4.

TECHNICAL ANALYSIS

5.

REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Determination 5.2 Applicable Regulatory Requirements1Crii:eria

6.

ENVIRONMENTAL CONSIDERATION

7.

REFERENCES Page 1 of 6 TSTF-511 NSPM

1.

DESCRIPTION The proposed amendment would delete those portions of the Technical Specifications (TS) superseded by 10 CFR Part 26, Subpart I. This change is consistent with Nuclear Regulatory Commission (NIRC) approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-511, "Eliminate Working Hour Restrictions from TS 5.2.2: to Support Compliance with 10 CFR Part 26." Minor differences between the proposed plant specific TS changes, and the changes proposed by TSTF-511 are listed in Section 2.0. The availability of this TS improvement was announced in the Federal Register on December 30,2008 (73 FR 79923) as part of the consolidated line item improvement process (CLIIP).

2.

PROPOSED CHANGE Consistent with the NRC approved Revision 0 of TSTF-511, the proposed TS changes delete those portions of TI; superseded by 10 CFR Part 26, Subpart I. This application is being made in accordance with the CLIIP. North~ern States Power, a Minnesota company (NSPM) is proposing variations or deviations from the TS changes described in TSTF-511, Revision 0, or the NRC staffs model safety evaluation (SE) published on December 30, 2008 (73 FR 79923) as part of the CLllP Notice of Availability. NSPM proposes to retain TS 5.2.2 paragraph (d.) as "Not Used" and retain the current lettering for paragraphs (e.) and (f.) in the TS for both the Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP) and the Monticello Nuclear Generating Plant (MNGP).

3.

BACKGROUND The NRC issued a Federal Register notice (73 FR '16966, March 31, 2008) of the issuance of a final rule that amended 10 CFR Part 26. The revised regulations in 10 CFR Part 26, Subpart I supersede working hour restrictions contained in paragraph (d.)

of TS 5.2.2. The background for this application is adequately addressed by the NRC Notice of Availability published on December 30, 2008 (73 FR 79923).

4.

TECHNICAL ANALYSIS NSPM has reviewed the SIE published on December 30,2008 (73 FR 79923) as part of the CLllP Notice of Availability. NSPM has conclucled that the technical justifications presented in the SE prepared by the NRC staff are applicable to PINGP and MNGP.

10 CFR Part 26, Subpart I, supersedes existing worker fatigue guidance. 10 CFR Part 26, Subpart I, distinguishes between work hour con~trols and fatigue management and strengthens the requireme~nts for both. Under the new rule, work hour restrictions include not only work hour limitations for rolling 24-lhour, 48-hour, and 7-day periods, Page 2 of 6 TSTF-511 NSPM but also include a required minimum break between work periods and varying required minimum days off. Additionally, Subpart I confines the use of waivers (deviations from restrictions) to situations where overtime is necessary to mitigate or prevent a condition adverse to safety or necessary to maintain the security of the facility. Subpart I also strengthens reporting requirements. Finally, the new rule's work hour control scope includes certain operating and maintenance personnel, as well as individuals directing those operating and maintenance personnel, healtti physics and chemistry personnel who are a part of the on-site emergency response organization minimum shift complement, the fire brigade member who is responsible for understanding the effects of fire and fire suppressant:^ on safe shutdown capisbility, and certain security personnel.

The proposed change removes working hour limits imposed in the Technical Specifications in order to support compliance with 'I0 CFR Part 26, Subpart I. Work hour controls and fatigue management requiremen,ts have been incorporated into the NRC's regulations; therefore, it is unnecessary to have work hour control requirements in the Technical Specifications.

Removal of the Technical Specification requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I, requirements, even if the Technical Specification change is implemented prior to the October 1, 2009 deadline.

Along with this LAR, NSPI1S has submitted a commitment to comply with 10 CFR Part 26 concurrently with the irr~plementation of the Technical Specification change.

5.0 REGULATORY SAFE'W ANALYSIS 5.1 No Significant Hazards; Determination Northern States Power, a Minnesota corporation (NSPM) has reviewed the no significant hazards determination published on December 30, 2008 (73 FR 79923) as part of the CLllP Notice of Availability. NSPM has concluded that the determination presented in the notice is applicable to PlNGP and MNGP. NSPM has evaluated the proposed changes to the 1-S using the criteria in 1C) CFR 50.92 and has determined that the proposed changes do not involve a significant tiazards consideration. An analysis of the issue of no significa~nt hazards consideration is presented below:

Criterion 1 : The Proposed Change Does Not Involve a Significant Increase in the Probability or Conseque~nces of an Accident Previously Evaluated The proposed change removes Technical Slpecification restrictions on working hours for personnel who perform safety related functions. The Technical Specification restrictions are superseded by the worker fatigue requirements in 10 CFR Part 26. Rt2moval of the Technical Specification requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I, requiremlents. The proposed change does not impact the physical Page 3 of 6 TSTF-511 NSPM configuration or function of plant structures, !systems, or components (SSCs) or the manner in which1 SSCs are operated, maintained, modified, tested, or inspected. Worker fatigue is not an initiator ref any accident previously evaluated. Worker tfatigue is not an assump'tion in the consequence mitigation of any accident previously evaluated. Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Criterion 2: The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident From Any Accident Previously Evaluated The proposed change removes Technical Specification restrictions on working hours for personnel who perform safety related functions. The Technical Specification restricitions are superseded by the worker fatigue requirements in 10 CFR Part 26. Working hours will continue to be controlled in accordance with NRC requirements. The new rule allows for deviations from controls to mitigate or prevent a condition adverse to safety or as necessary to maintain the security of the facility. This ensures that the new rule will not unnecessarily restrict working hours and thereby create the possiblility of a new or different kind of accident from any accident previously evaluated.

The proposed change does not alter the plant configuration, require new plant equipment to be installed, alter accident analysis assumptions, add any initiators, or effect the functio~i of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected.

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

Criterion 3: The Proposed Change Does Not Involve a Significant Reduction in a Margin of Safety The proposed change removes Technical Slpecification restrictions on working hours for personnel who perform safety related functions. The Technical Specification restrictions are superseded by the worker fatigue requirements in 10 CFR Part 26. The proposed change does not involve any physical changes to plant or alter the manner in which plant systems are operated, maintained, modified, tested, or inspected. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by this change. The proposed change will not result in plant operation in a configuration outside the design basis. The proposed change does not adversely affect systems that respond to safely shutdown the plant and to maintain the plant in a safe shutdown condi1:ion.

Page 4 of 6 TSTF-511 NSPM Removal of plant-specific Technical Specification administrative requirements will not reduce a margin of safety because the requirements in 10 CFR Part 26 are adequate to ensure that worker fatigue is managed.

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

Based on the above, North~ern States Power, a Minnesota corporation, 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.

5.2 Applicable Regulatory IRequirementsICriteria A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of A\\~ailability published on December 30,2008 (73 FR 79923). NSPM has reviewed the INRC staffs model SE published on December 30, 2008 (73 FR 79923) as part of the CLllP Notice of Availability and concluded that the regulatory evaluation section is ;applicable to PlNGP and MNGP.

The proposed change eliminates the plant-specific Technical Specification administrative controls on working hours. The Technical Specification guidance has been superseded by 10 CFzR Part 26.

10 CFR Part 26, Subpart I, "Managing Fatigue," contains requirements for managing worker fatigue at operating nuclear power plants.

10 CFR 50.36 provides, arnong other things, the regulatory requirements for the content in the Administrative Controls section of the Technical Specifications. The inclusion of requirements to control working hours and manage fatigue is not required to be in the Administrative Controls by 10 CFR Part 50.36. Because the requirement to control working hours and manage fatigue is provided in 10 CFR Part 26, Subpart I, it is unnecessary for the Technical Specifications to contain similar controls.

6.

ENVIRONMENTAL CONSIDERATION NSPM has reviewed the environmental evaluation included in the safety evaluation (SE) published on December 30, 2008 (73 FR 799:23) as part of the CLllP Notice of Availability. NSPM has concluded that the staffs findings presented in that evaluation are applicable to PlNGP and MNGP. The proposed amendment changes recordkeeping, reporting, or administrative procedures. Accordingly, the amendment meets the eligibility criteria for categorical exclusior\\ set forth in 10 CFR 51.22(~)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

Page 5 of 6 TSTF-5 1 1 NSPM

7.

REFERENCES

1.

Federal Register Notice, Final Rule 10 CFR Part 26 published on March 31, 2008.

2.

TSTF-511, Revision 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26."

3.

Federal Regilster Notice, Notice of Availability published on December 30, 2008 (73 FR 79923).

Page 6 of 6

ENCLOSURE 2 Prairie Island Nuclear Generating Plant Technical Specification Pa~ges (Markup) 2 pages follow

Organization 5.2 Organization (continued) 5.2.2 Plant Staff The plant staff organization shall include the following:

a. An operator to perform non-licensed duties shall be assigned to each reactor containing he1 and one additional operator to perform non-licensed duties shall be assigned when either or both reactors are operating in MODES l,2, 3, or 4.

b. Shift crew composition may be less than the minimum requirement of 10 CITR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

c. An individual qualified in radiation protection procedures shall be on site when fuel is in a reactor. 'The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provitle for unexpected absence, provided immediate action is taken to fill the required position.

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Prairie Island Units 1 and 2 Unit 1 - Amendment No. 448 5.O-3 Unit 2 - Amendment No. 4-49

Organization 5.2 Organization 5.2.2 Plant Staff (continued)

e. The o'perations manager or assistant operations manager shall hold an SRO license. In addition, the duty shift manager shall hold an SRO license.

f.

In MODES 1,2,3, and 4, the shift technical advisor shall provide advisory technical support to tlhe unit operations shift crew in the areas of the:rrnal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shifit.

Prairie Island Units 1 and 2 Unit 1 - Amendment No. 43-8 444 5.0-4 Unit 2 - Amendment No. 4-49 474

ENCLOSURE 3 Monticello Nuclear Generating Plant Technical Specification Plage (Markup) 1 page follows;

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

c.

A radiation protection technician shiall be on site when fuel is in the reactor.

The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

d.

Not Useti---

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e.

The opel-ations manager shall hold a Senior Operator license or shall formerly have held a Senior Operatlor license. If the operations manager does not hold a Senior Operator license, another member of plant management shall hold a Senior Operator license and shall be assigned to the plant operations group on a long term basis (approximately 2 years).

This individual shall not be assigned to a rotating shift.

f.

An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

Monticello Amendment No. 4-46

ENCLOSURE 4 Pra.irie Island Nuclear Generating Plant Teclhnical Specification Pa'ges (Retyped) 2 pages follo~/

Organization 5.2 5.2 Organization ('continued) 5.2.2 Plant Staff The plant staff organization shall include the following:

a. An operator to perform non-licensed duties shall be assigned to each reactor containing fuel and one additional operator to perform non-licensed duties shall be assigned when either or both reactors are operating in MODES 1, 2, 3, or 4.

b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2:.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the sh,ift crew composition to within the minimum requirements.

c. An individual qualified in radiation protection procedures shall be on site when fuel is in a reactor. The position may be vacant for not more than ;! hours, in order to provide for unexpected absence, provided immediate action is taken to fill1 the required position.

d. Not Used.

Prairie Island Units 1 and 2 Unit 1 - Amendment No. 4%

5.O-3 Unit 2 - Amendment No. 4-49

Organization 5.2 5.2 Organization 5.2.2 Plant Stafif (continued)

e. The operations manager or assistant operations manager shall hold an SRO llicense. In addition, the duty shift manager shall hold an SRO license.

f.

In MODES 1,2, 3, and 4, the slhift technical advisor shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shiff..

Prairie Island Units 1 and 2 Unit 1 - Amendment No. 4% 4-84 5.0-4 Unit 2 - Amendment No. 4-49 474

ENCLOSURE 45 Monticello Nuclear Generating Plant Technical Specification Page (Retyped) 1 page follows

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

c.

A radiation protection technician shall be on site when fuel is in the reactor.

The posi1:ion may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

d.

Not Usecl.

e.

The operations manager shall hold (a Senior Operator license or shall formerly have held a Senior Operator license. If the operations manager does not hold a Senior Operator license, another member of plant managernent shall hold a Senior Operator license and shall be assigned to the plant operations group on a long term basis (approximately 2 years).

This individual shall not be assigned to a rotating shift.

f.

An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

Monticello Amendment No. 44-6