L-PI-09-128, Supplement to License Amendment Request (LAR) to Revise Technical Specifications in Accordance with TSTF-448, Revision 3 - Control Room Habitability

Supplement to License Amendment Request (LAR) to Revise Technical Specifications in Accordance with TSTF-448, Revision 3 - Control Room Habitability

ML093560134
Person / Time
Site:	Prairie Island
Issue date:	12/21/2009
From:	Schimmel M Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-09-128, TAC ME1605, TAC ME1606, TSTF-448, Rev 3
Download: ML093560134 (15)

Text

DEC 2 1 2009 L-PI-09-128 10 CFR 50.90 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Supplement to License Amendment Request (LAR) to Revise Technical Specifications in Accordance with TSTF-448, Revision 3 - Control Room Habitabilitv (Tac Nos.

ME1605 and ME16061

References:

1. Letter from Northern States Power Company, a Minnesota corporation (NSPM) to the Nuclear Regulatory Commission (NRC), "License Amendment Request (LAR) to Revise Technical Specifications in Accordance with TSTF-448, Revision 3 - Control Room Habitability," dated June 24, 2009, ADAMS Accession Number ML091760988.

2. Prairie Island Nuclear Generating Plant, Units 1 and 2 Request for Additional Information Related to License Amendment Request to Revise Technical Specification in Accordance with TSTF-448, Revision 3 - Control Room Habitability (TAC Nos.

ME1605 and ME1606), dated November 17,2009, ADAMS Accession Number ML093130076.

In Reference 1, NSPM, doing business as Xcel Energy, submitted an LAR for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, to revise Technical Specifications in accordance with TSTF-448, Revision 3 - Control Room Habitability. In Reference 2, NRC Staff requested additional information to support their review of Reference 1. The Enclosure 1 to this letter provides the responses to the NRC Staff requests for additional information. NSPM submits this supplement in accordance with the provisions of 10 CFR 50.90.

The supplemental information provided in this letter does not impact the conclusions of the Determination of No Significant Hazards Consideration and Environmental Assessment presented in the June 24,2009 submittal.

1717 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1 121

Document Control Desk Page 2 In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this LAR supplement 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 Mr. Dale Vincent, P.E., at 651-388-1121.

Summaw of Commitments This letter contains no new commitments and no revisions to existing commitments I declare under enal @ ~ r j u r that y the foregoing is true and correct.

Executed on D C 2 fl2L.k Mark A. Schimmel Site Vice President Prairie Island Nuclear Generating Plant, Units 1 and 2 Northern States Power Company - Minnesota Enclosures (1) cc: Administrator, Region Ill, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota

Enclosure 1 Nuclear Regulatory Commission (NRC) Request for Additional Information (RAI)

I. In order to be consistent with TSTF-448, the title of the "Control Room Habitability Program" in TS [Technical Specifications] section 5.5.16 of your submittal should be "Control Room Envelope Habitability Program. " Please update your submittal to include this change.

Northern States Power Company, a Minnesota corporation (NSPM) Response

1. The title of TS 5.5.16 has been revised to "Control Room Envelope Habitability Program." Attachments 1 and 2 provide the revised TS pages.

NRC RAI

2. On page 3 of 6 of your submittal concerning Section 5.5.18.d (5.5.16.d of your submittal), you stated that in lieu of the pressure test, NSPM proposes a PlNGP Surveillance Requirement (SR) that will require a leakage test of outside air intake and boundary exhaust dampers. You also stated that the damper leakage SR would be included in the CRE [Control Room Envelope] Program as 5.5.16, sub-item (d), and that the addition of this SR will require the damper test to be performed at least once per operating cycle. The NRC staff believes that limiting a SR to outside air intake and boundary exhaust dampers is not consistent with the intent of TSTF-448, Rev. 3, Section 5.5.18.d.

To address this issue, other licensees have developed licensee-controlled programs that verify the integrity of the CRE boundary. Such a licensee-controlled program may or may not include intake and exhaust dampers; the inclusion or exclusion of such dampers would be determined by the developer of the program. Therefore, in order to be in compliance with the intent of Section 5.5.18.dJPlNGP should develop a program that includes a method to collect data that will serve as input to a periodic assessment of the CRE boundary. This position is supported by the technical analysis section of TSTF-448 Revision 3, page 8, where an explanation of the basis for paragraph (d) is provided.

NSPM Response

2. NSPM conducts preventative maintenance (PM) and surveillance activities which give assurance that the boundary is maintained in a manner that would provide protection for the operators. These requirements are currently controlled under other plant programs, but would be included as appropriate in the new Control Room Envelope Habitability Program. Any criteria that are not met while performing these activities would be documented and resolved in accordance with the NSPM Corrective Action Program (CAP). Appropriate actions would be identified and implemented to restore the degraded conditions and access impact Page 1 of 3

NSPM on the CRE boundary. The information captured by the CAP would be used in future periodic assessments of the CRE. These processes ensure that the PlNGP CRE boundary can perform its safety function comparable to performing a pressurization test and trending the test data. NSPM has revised TS 5.5.16.d to be consistent with the intent of TSTF-448, Rev. 3. Attachments 1 and 2 provide the revised license and TS pages to reflect this change.

NRC RAI In TSTF-448, Revision 3, the CRE Habitability Program TS Section 5.5.18.e (5.5.16.e of PINGPfs submittal) states that the quantitative limits on unfiltered air inleakage into the CRE shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph (c).

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

PlNGP elected to omit the last sentence that states, "Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis. " As stated in your June 24, 2009, letter, you provided information by letter dated December 9, 2003 (ADAMS Accession No. ML033500298), indicating that the PlNGP licensing basis does not assume limiting CR unfiltered in-leakage during these events. It is the NRC staff position that this is not consistent with the intent of the omitted sentence. The staff understands that there are no specific limits on hazardous chemicals and smoke. Nevertheless, the inclusion of the omitted sentence assures that licensees will abide by the licensing basis requirement for this issue. It does not change the licensing basis. Therefore, the staff is requesting that PlNGP update the submittal to include the omitted sentence.

NSPM Response

3. TS 5.5.16.e has been revised to include the omitted sentence. Attachments 1 and 2 provide the revised TS pages.

NRC RAI

4. When section 5.5.16.d is updated in accordance this request, Section 5.5.16.f should also be updated to reflect the change is section 5.5.16.d.

NSPM Response

4. TS 5.5.16.f has been revised to reflect the change in section 5.5.16.d.

Attachments 1 and 2 provide the revised TS pages.

Page 2 of 3

NSPM Other In addition to the RAI responses, per discussion with the NRC, NSPM is providing the PlNGP Unit 1 and Unit 2 license pages to reflect the license condition to support implementation of the proposed TS changes. Attachments 1 and 2 provide the revised license pages.

Attachments

1. License and Technical Specification Pages (Markup)

2. License and Technical Specification Pages (Clean)

Page 3 of 3

ATTACHMENT 1 to ENCLOSURE License and Technical Specification Pages (Markup)

Unit 1 License Page 5 Unit 2 License Page 5 5.0-30 5.0-31 4 pages follow

(7) Upon implementation of Amendment No. -_=adoptingTSTF-448, Revision 3. the dejermination of control room envelope (CRE) unfilteredair in-leakaae as required

&-SR 3 7.10.5, in accordance with TS 5.5.16 c (i). the assessment of CRE hab~tabilrtyas required by TS 5.5.16.c (ii), and assessing the CRE boundarv as rgqulred by Specification 5.5 16.d. shall be cons~deredmet Followinq im&lem_entation.

a Theirst p e r f o r m a n c e o f 10 5. In accordance w ~ t hSrsec~f~cation 5 5 16 c (iL shall b ~ m t b n t h e s ~ e ~ ~frequency fied of 6 years, plus the 18 month allowance of SR zx 3 0 g~measuredfrom December3. 2004. the date of the most recent successful t- r-a---s e -~ test1

~ s as- ~ t h December e 18: 2006 letter ~nresponse t_o Generis Letter 2003-01. or w~thlnthe next 18 months ~fthe time per~odslnce the most recent sue-cessful tracer gas test is greater than 6 years b Thef~rst-pmansofther>ermd~cassessment_ofCRE

- -- -- hab~tab~llty!

Spec~fica-5 5 16 cl_li), shall be 3 vears, plus the 9 month allowance-_of SR 3 0 2: as measured from December 3 M 3 0 4the , date ofthe most recent successful tracer gas test, as stated in the December 18, 2006 letter Inresponse to Gener~cLetter 2QL.B-01. or wzhin the next 9 months ~fthe time per~odsince the most recent successful tracer gas test IS greater than 3 vears

2. D. This license is effective as of the date of issuance and shall expire at midnight August 9, 2013.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by Roger S Boyd A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:

1. Appendix A - Technical Specifications

2. Appendix B - Additional Conditions Date of Issuance: April 5, 1974 Unit 1 Amendment No. 4-64

-(7) Upon implementat~onof Amendment No adopting TSTF-448. Revision 3, the

&eterrnlnatron of control room envelope (CRE) unf~lteredair rn-leakaae as reauired by- SR 3 7 10.5: in accordance w~thTS 5 5.16 c (I), the assessment of CRE hatxiab~lityas requrred by TS 5 5 16.c (11).and assessing the CRE boundary as requ~redby Specrficatron 5 5 16 d: shall be csns~deredmet Following rmplementation

a. Tke frrst performance of SR 3 7 10 5: in accordance with Spec~ftcatlon5 5.16.c (IL shall be withln the spec~f~ed frequency of 6 years! plus the 18 month allowance of SR 302 *, measured from December 3. 2004, the date of the most recent successful Facer gas test. as stated In the December 18. 2006 letter in response to Gener~c Letter 2003-81: or with~nthe next 18 months if the time period since the most recent sUccess~ultracer gasJg2t IS greater than 6 years b__Theflrst performance of the periodic assessment of CRE hab~tab~litv! Specifrcat~on 5 5 16 c (11).shall be 3 years, plus the 9 month allowance of SR 3 0.2: as measured fr*an~ecember3. 2004, the date of the most recent successful tracer aas test. as stated In the December 18: 2006 letter in response to Generic Letter 2003-01, or within the next 9 months ~fthe hme period suce the most recent successful tracer gas te-st isgreater than 3jears

2. D. This license is effective as of the date of issuance and shall expire at midnight October 29, 2014.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by A. Giambusso A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:

1. Appendix A - Technical Specifications

2. Appendix B - Additional Conditions Date of Issuance: October 29, 1974 Unit 2 Amendment No. 4-52

Programs and Manuals 5.5 Programs and Manuals (continued) 5 5.16 Cl'ntrol lic)c)111Envelope Habitability P r o g r m AC'ontrol t<oon~ - -Enyelope

- (CREJ 1 Iabitabilit P~ogri1111 shall be established kvith

--- - iltl OPERABLE Cc>ntrolRoom Special --Ventilation

- System (._C_RVS),

cR11 occupants can ccxltrol the reactor safelv under i ~ o r n ~conditic7ns al and

~--n a i n l -n & i ~ ~ ~ ' t . ~ i t-i o n f i ~ \ ~ g a ~ - i - ~ & g @ & a z a r d c rLU chemical

- - -- - release, or a smoke challenge. 'I'he programg-shalI ensure t h g gdcyYuate-- radiation protection isyrovided to permit access anci occur-cnc~of the CRE undcr design basis accident (DBA) concliticm without person&

recc&~yra.~iation exposures in excessof 5 rem whole body or its cquivi11e11tto anv part oS the bod)? or 5 rcm total effective dose equivalent

[17EDEl, as applicable. for the ciuration of the accident. The program shall include the Sollowing clcments:

tl-_ -'l'he__definition

_____ of the CRf'- and the CKI: b o u n d a ~ .

b. Uquirements -- Ihcrnaintaining the CRIi boundary in its desim c(~n$tkim~s incluc~it~g~confguration coiltrol and preventive n~itinteixincc.

c. _ Ucquire~nentsfor (i) determining the unfiltered air in-leakage past the

-CKE

- \boundar~

into

-- the CRE

-- in accordance nit11 the testing methods and at the -Freg~~encies

- - -- in Sections C. 1 and C.2 of Regulatory

--- specified ---

i d . e n s t r t i n o r 0 1 Roorn Enyelope Integrity at Nuclear Power-Reactors,' Revision 0, May 2003, and (ii) assessing C:RE.!xt&bility at the Frecluencies specified in Sections C. 1 and (2.2 of Kier:L11ittnry

-- Guide

- P I . 197. Revision 0.

e p cS. Liccnsec controlled progranls that ~ ~ ibel lusccl to verify the intcgritj of' the C_KEbounciary. Conditions that generate relevant information from t h o ~ r o g r a m will

-- s be entered into the corrective action process and shall betrended and used as part-of the periodic -- assessments of the CflE boutida~:.

Prairie Island Unit 1 - Amendment No. 43-84-77 Units 1 and 2 5.0-30 Unit 2 - Amendment No. 4-49 4-67

Programs and Manuals 5.5 5.5 Programs and Manuals e.

7 Ills quantitative lii~~th~unti&e~regir in-leakage into the CRE.Jhag 7

limits sl~allbe stated in -a 111anneEo allow direct comparison to the unfilterecl in-legkgge ~neasyedbv the testing desgibed in paragraph c.

I'he unfiltereci a& in-leakaielkit

- . - for radiolc3gical challenges is tlie in-lealii~gejl~)~t-rate

- ass~~lned

- - in the licensin-&is

- i111asis _of DL3A consequences.

- IJnfiltered air inlealcage lin~its for ha7ardous chemicals m u s l u t h a t e m r e of CRE

-..-- - occupants to these 11il~ards

--. 1% i l l b x

>\,ithi11the assumptions of the licensing basis.

f. _Ihc_provisionsof SI< 3U , are ap~licablcto the Frcqucncics for assessin0 CKE

&--= habitabili-nd

--=- -------

dgterrninill,~

. CKE unfiltered in-leakage as wuid buaragraph C.

Prairie Island Unit 1 - Amendment No. 448 47-7 llnits 1 and 2 5.0-3 1 Unit 2 - Amendment No. 4 4 4-67

ATTACHMENT 2 to ENCLOSURE License and Technical Specification Pages (Clean)

Unit 1 License Page 5 Unit 2 License Page 5 5.0-30 5.0-31 4 pages follow

(7) Upon implementation of Amendment No. adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air in-leakage as required by SR 3.7.10.5, in accordance with TS 5.5.16.c (i), the assessment of CRE habitability as required by TS 5.5.16.c (ii), and assessing the CRE boundary as required by Specification 5.5.16.d, shall be considered met. Following implementation:

a. The first performance of SR 3.7.10.5, in accordance with Specification 5.5.16.c (i),

shall be within the specified frequency of 6 years, plus the 18 month allowance of SR 3.0.2, as measured from December 3, 2004, the date of the most recent successful tracer gas test, as stated in the December 18, 2006 letter in response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

b. The first performance of the periodic assessment of CRE habitability, Specification 5.5.16.c (ii), shall be 3 years, plus the 9 month allowance of SR 3.0.2, as measured from December 3, 2004, the date of the most recent successful tracer gas test, as stated in the December 18, 2006 letter in response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

2. D. This license is effective as of the date of issuance and shall expire at midnight August 9, 2013.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by Roger S Boyd A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:

1. Appendix A - Technical Specifications

2. Appendix B - Additional Conditions Date of Issuance: April 5, 1974 Unit 1 Amendment No.

(7) Upon implementation of Amendment No. adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air in-leakage as required by SR 3.7.10.5, in accordance with TS 5.5.16.c (i), the assessment of CRE habitability as required by TS 5.5.16.c (ii), and assessing the CRE boundary as required by Specification 5.5.16.d, shall be considered met. Following implementation:

a. The first performance of SR 3.7.10.5, in accordance with Specification 5.5.16.c (i),

shall be within the specified frequency of 6 years, plus the 18 month allowance of SR 3.0.2, as measured from December 3, 2004, the date of the most recent successful tracer gas test, as stated in the December 18, 2006 letter in response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

b. The first performance of the periodic assessment of CRE habitability, Specification 5.5.16.c (ii), shall be 3 years, plus the 9 month allowance of SR 3.0.2, as measured from December 3, 2004, the date of the most recent successful tracer gas test, as stated in the December 18, 2006 letter in response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

2. D. This license is effective as of the date of issuance and shall expire at midnight October 29, 2014.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by A. Giambusso A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:

1. Appendix A - Technical Specifications

2. Appendix B - Additional Conditions Date of Issuance: October 29, 1974 Unit 2 Amendment No.

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.16 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Special Ventilation System (CRSVS),

CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body, or 5 rem total effective dose equivalent (TEDE), as applicable, for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.

b. Requirements for maintaining the CRE boundary in its design conditions including configuration control and preventive maintenance.

c. Requirements for (i) determining the unfiltered air in-leakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C. 1 and C.2 of Regulatory Guide 1.197, Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

d. Licensee controlled programs that will be used to verifjl the integrity of the CRE boundary. Conditions that generate relevant information from those programs will be entered into the corrective action process and shall be trended and used as part of the periodic assessments of the CRE boundary.

Prairie Island Unit 1 - Amendment No. 4-58477 Units 1 and 2 5 .O-30 Unit 2 - Amendment No. 449 1-63

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.

Prairie Island Unit 1 - Amendment No. 44-84-77 Units 1 and 2 5.0-3 1 Unit 2 - Amendment No. W 467