L-PI-14-034, License Amendment Request (LAR) to Revise Technical Specification (TS) 3.3.3, Event Monitoring (EM) Instrumentation, and Additional Conditions Related to Alternative Source Term License Amendment Implementation

License Amendment Request (LAR) to Revise Technical Specification (TS) 3.3.3, Event Monitoring (EM) Instrumentation, and Additional Conditions Related to Alternative Source Term License Amendment Implementation

ML14349A749
Person / Time
Site:	Prairie Island
Issue date:	12/11/2014
From:	Davison K Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-14-034
Download: ML14349A749 (35)

Text

(l Xcel Energy L-PI-14-034 DEC 11 2014 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 Renewed License Nos. DPR-42 and DPR-60 License Amendment Request (LAR) to Revise Technical Specification (TS) 3.3.3, "Event Monitoring (EM) Instrumentation", and Additional Conditions Related to Alternative Source Term License Amendment Implementation Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), hereby requests an amendment to revise Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, TS 3.3.3 to add Steam Generator Water Level- Narrow Range Instruments to Table 3.3.3-1; revise Renewed Operating License Appendix B, "Additional Conditions," for each unit related to implementation of the Alternative Source Term (AST) License Amendments 206 (Unit

1) and 193 (Unit 2) (LA-206/193); and remove two AST Additional Conditions for each unit that have been fulfilled. NSPM evaluated the changes proposed in this LARin accordance with 10 CFR 50.92 and concluded that they involve no significant hazards consideration.

The enclosure to this letter, "Evaluation of the Proposed Changes," contains the licensee's evaluation of the proposed changes.

NSPM requests approval of this LAR within one calendar year of the submittal date.

Upon NRC approval NSPM requests implementation within 90 days. In accordance with 10 CFR 50.91, NSPM*is notifying the State of Minnesota of this LAR by transmitting a copy of this letter and enclosure to the designated State Official.

If there are any questions or if additional information is needed, please contact Mr. Dale Vincent, P.E., at 651-267-1736.

1717 Wakonade Drive East

• Welch, Minnesota 55089-9642 Telephone: 651.388.1121

Document Control Desk Page 2 Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.

I declare und~_.P.enalty of J?erjury that the foregoing is true and correct.

Executed on Ut.C 1 1 20g

fl~ ~~(~

Kevin Davison Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company- Minnesota Enclosures (1) cc: Administrator, Region Ill, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota

ENCLOSURE Evaluation of the Proposed Changes License Amendment Request (LAR) to Revise Technical Specification (TS) 3.3.3, "Event Monitoring (EM) Instrumentation", and Additional Conditions Related to Alternative Source Term License Amendment Implementation

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 Proposed Changes

2.2 Background

3. TECHNICAL EVALUATION

4. REGULATORY SAFETY ANALYSIS 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration Determination 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1. Additional Condition and Technical Specification Pages (Markup)

2. Technical Specification Bases Pages (Markup)

3. Additional Condition and Technical Specification Pages (Retyped)

Page 1 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions

1.

SUMMARY

DESCRIPTION This evaluation supports a request to amend Renewed Operating Licenses DPR-42 and DRP-60 for Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, respectively.

Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), hereby requests an amendment to revise PINGP TS 3.3.3 to add Steam Generator Water Level- Narrow Range Instruments (SGNR) to Table 3.3.3-1; revise Renewed Operating License Appendix B, "Additional Conditions," for each unit related to implementation of the Alternative Source Term (AST) license amendments 206 (Unit 1) and 193 (Unit 2) (LA-206/193); and remove two AST Additional Conditions for each unit that have been fulfilled. NSPM evaluated the changes proposed in this LAR in accordance with 10 CFR 50.92 and concluded that they involve no significant hazards consideration.

NSPM determined that the absence of the SGNR instruments from TS Table 3.3.3-1 is a non-conservative TS in accordance with the guidance of Administrative Letter (AL) 98-10 (ML031110108), "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety." The SGNR instruments are part of the reactor trip system and monitored under the reactor trip system TS, thus plant safety is maintained utilizing the current instruments. NSPM submits this LAR to resolve a non-conservative TS.

The licensing actions proposed in this LAR resolve AST implementation issues and allow AST LA-206/193 to be fully implemented. Currently, as an interim measure, NSPM has administratively restored selected TS operating requirements and surveillances which were removed by AST LA-206/193.

2. DETAILED DESCRIPTION 2.1 Proposed Changes A brief description of the associated proposed TS and Appendix B Additional Condition changes is provided below along with a discussion of the justification for each change.

The specific wording changes to the TS and Appendix B Additional Conditions are provided in Attachments 1 and 3 to this enclosure.

TS 3.3.3, "Event Monitoring", Table 3.3.3-1 Event Monitoring Instrumentation, new Function 17: This LAR proposes to add SGNR instruments to the event monitoring instrumentation TS. Two Notes are included to specify when the SGNR instruments will meet Regulatory Guide 1.97, Revision 2 (RG 1.97) guidance. This change is acceptable because it conforms TS Table 3.3.3-1 to the guidance to include Type A and Category 1 instrumentation as defined in RG 1.97 and requires SGNR water level instrumentation to be upgraded to meet RG 1.97 guidance for Type A, Category 1 instrumentation.

Page 2 of 17

Enclosure Revise TS Table 3.3.3-1 and AST Additional Conditio ns NSPM Unit 1 Appendix 8 Additional Condition, last condition listed on page 8-3:

This LAR proposes to revise this license condition to make an exception for implementation of the SGNR instrumentation requirements within 90 days after RSG installation. This change is acceptable because implementation requirements for the SGNR instruments are appropriately addressed in proposed changes toTS Table 3.3.3-1.

Unit 2 Appendix 8 Additional Condition, last condition listed on page 8-3:

This LAR proposes to revise this license condition to make an exception for implementation of the SGNR instrumentation requirements within 90 days after RSG installation. This change is acceptable because implementation requirements for the SGNR instruments are appropriately addressed in proposed changes toTS Table 3.3.3-1.

Unit 1 Appendix 8 Additional Condition, conditions listed on page 8-4: This LAR proposes to remove both Additional Conditions and delete page B-4.

This change is acceptable because these conditions have been fulfilled and these Additional Conditions no longer serve any purpose.

Unit 2 Appendix 8 Additional Condition, conditions listed on page 8-4: This LAR proposes to remove both Additional Conditions and delete page B-4.

This change is acceptable because these conditions have been fulfilled and these Additional Conditions no longer serve any purpose.

Although Bases changes are not a part of this LAR, Attachment 2 to this enclosure includes marked up TS 3.3.3 Bases pages for information. The TS Bases changes are directly related to the proposed TS changes.

In summary, these changes are acceptable because they assure TS limiting conditions for operation are provided which meet NRC guidance; plant instrumentatio n meets applicable regulatory guidance; AST implementation requirements are clarified and they make administrative changes to remove requirements that have been fulfilled.

2.2 Background During NRC review of a PINGP LAR (ML093160583) to adopt alternative source term (AST) methodologies, NSPM identified that the SGNR instrumentation is credited for monitoring of a steam generator tube rupture (SGTR) design basis accide nt in the plant emergency operating procedures. The NRC authorized AST methodologie s in LA-206/193 and associated TS changes by amendment dated January 22, 2013 (ML112521289). LA-206/193 also included license conditions in the Renew ed Operating License Appendix B, "Additional Conditions" and implementatio n

requirements in the license amendment with respect to SGNR instrum entation.

Specifically, LA-206/193 included Implementation Requirement 4.(1) which stated, "Prior to implementation of the Alternative Source Term license amend ment, NSPM will Page 3 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions revise the Prairie Island Nuclear Generating Plant design and licensing bases to indicate that the Steam Generator Water Level- Narrow Range Instruments are required to meet Regulatory Guide 1.97, Revision 2 requirements." Thus, implementation of AST became dependent on addressing SGNR instrumentation within the plant licensing basis.

NSPM tentatively concluded during the NRC review of the AST LAR that SGNR instrumentation should be classified as RG 1.97 Type A, Category 1 instrumentation.

Since PINGP TS 3.3.3, "Event Monitoring (EM) Instrumentation", Table 3.3.3-1, lists RG 1.97 Type A or Category 1 event monitoring instrumentation, this TS would require addition of this instrumentation.

(Note, the PINGP-specific term "event monitoring instrumentation" applies to instrumentation that is used for monitoring purposes on accident mitigating systems and components before, during, and after accidents. This instrumentation is the same as the equipment commonly known in the industry and Standard Technical Specifications (for example, NUREG-1431 TS 3.3.3) as "post-accident monitoring instrumentation".)

Early in the implementation of the AST amendments, LA-206/193, NSPM anticipated that the SGNR implementation requirements would be met with the current qualifications of the installed SGNR instrumentation and submittal of an LAR to add SGNR instrumentation toTS Table 3.3.3-1. As the AST Additional Condition implementation date (90 days after completion of the outage in which the Unit 2 replacement steam generators were installed) approached, NSPM determined that compliance with Implementation Requirement 4.(1) could not be achieved at that time.

NSPM has subsequently decided that the best resolution to assure compliance with RG 1.97 guidance for the SGNR instrumentation is to designate this function as Type A, Category 1 instrumentation and replacement of SGNR instrumentation loop components which currently do not meet the guidance for Type A, Category 1 variables.

This LAR proposes to separate SGNR compliance with RG 1.97 from AST implementation by revising the AST implementation Additional Conditions to take exception to Implementation Requirement 4.(1) and revising the TS to include SGNR in Table 3.3.3-1 with notes specifying when the SGNR instruments will meet RG 1.97 guidance. This LAR also proposes administrative changes to remove AST implementation Additional Conditions which have been fulfilled and no longer serve any purpose.

NSPM requests approval of this LAR within one calendar year of the submittal date.

Upon NRC approval NSPM requests implementation of the TS and Additional Conditions within 90 days. As proposed in new Table 3.3.3-1 Notes, equipment modifications for safety-related upgrades to the instrumentation will be completed for Unit 1 operation in cycle 1R30 and for Unit 2 operation in cycle 2R30. Upon NRC approval, AST LA-206/193 implementation compliance will be restored and the interim administrative pre-AST LA-206/193 TS measures will be terminated.

Page 4 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions NRC AL 98-10 (ML031110108) provides guidance for correction of facility TS when they are found to contain non-conservative requirements. The NRC staff expressed their expectation in AL 98-10 that, following imposition of administrative controls, an amendment to the TS will be submitted in a timely fashion. Contrary to the guidance of NUREG-1431, PINGP TS do not include SGNR instruments in TS Table 3.3.3-1. Since the SGNR instruments are also part of the reactor trip system TS controls are accomplished by virtue of the current reactor trip system surveillances. This LAR proposes TS revisions which require appropriate actions and schedules for resolving the SGNR non-conservative TS.

With the changes proposed in this LAR, the plant will continue to operate safely and the health and welfare of the public is protected.

3. TECHNICAL EVALUATION PINGP is a two unit plant located on the right bank of the Mississippi River approximately six miles northwest of the city of Red Wing, Minnesota. The facility is owned and operated by Northern States Power Company, a Minnesota corporation (NSPM). Each unit at PINGP employs a two-loop pressurized water reactor designed and supplied by Westinghouse Electric Corporation. The initial PINGP application for a Construction Permit and Operating License was submitted to the Atomic Energy Commission (AEC) in April 1967. The Final Safety Analysis Report (FSAR) was submitted for application of an Operating License in January 1971. Unit 1 began commercial operation in December 1973, and Unit 2 began commercial operation in December 1974.

The PINGP was designed and constructed to comply with the licensee's understanding of the intent of the AEC General Design Criteria (GDC) for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. PINGP was not licensed to NUREG-0800, "Standard Review Plan (SRP)."

Steam Generator Water Level - Narrow Range Instrumentation There are three channels of SG Water Level - Narrow Range (SGNR) instrumentation on each SG and each channel has separate indication displayed in the control room.

SGNR instrumentation provides a protection function within the reactor protection system as required by TS 3.3.1 and therefore the instrumentation loop from the sensing line through the transmitter are safety-related.

The SGNR instruments provide the primary means of identification of a ruptured steam generator by indication of an unexpected increase in any SGNR channel level.

Immediately following identification of the ruptured SG, operators manually isolate the ruptured SG. As such, SGNR level provides the primary information required to permit the control room operators to take the specified manual control actions.

Page 5 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions The indication is on the non-safety related side of the loop. The indicator power supply is safety related and will be available during a loss of offsite power. Also the plant Emergency Response Computer System (ERGS) provides backup indications for SGNR water level. ERGS is powered by an uninterruptible power supply and redundant power source to network switches and remote multiplexing units.

Current requirements, basis and limitations During NRC review of an LAR to adopt AST methodology, the SGNR instrumentation was identified as instrumentation which is credited as the primary indication for identification of a ruptured steam generator. This use would require it to be classified as Type A, Category 1 instrumentation under RG 1.97, Revision 2, and included in TS Table 3.3.3-1. LA-206/193 issued on January 22,2013 (ML112521289) included Implementation Requirement 4.(1) with respect to the SGNR instrumentation which states, "Prior to implementation of the Alternative Source Term license amendment, NSPM will revise the Prairie Island Nuclear Generating Plant design and licensing bases to indicate that the Steam Generator Water Level -Narrow Range Instruments are required to meet Regulatory Guide 1.97, Revision 2 requirements." Since this was part of the license amendment implementation requirements, this also fell under the requirements of the AST implementation Appendix B Additional Condition which required, "The Alternative Source Term (AST) License Amendments 206/193 will be implemented after installation of the Unit 2 Replacement Steam Generators (RSGs)."

The implementation date for this Additional Condition was, "Within 90 days after completion of the outage in which the Unit 2 RSGs are installed."

NSPM determined that literal compliance with Implementation Requirement 4.(1), with the instrument function designated as RG 1.97 Type A, Category 1, requires portions of the SGNR instrumentation to be replaced with qualified equipment. Design, procurement, manufacturing and installation of qualified equipment could not have been performed within the implementation date of 90 days after the outage in which the Unit 2 RSG were installed (March 27, 2014).

Proposed Changes NSPM proposes to revise the Unit 1 Additional Condition for AST implementation, the last Additional Condition listed on Appendix B page B-3, to state, 'The Alternative Source Term (AST) License Amendments 206/193, with the exception of Implementation Requirement 4. (1) for Steam Generator Water Level- Narrow Range Instruments, will be implemented within 90 days after installation of the Unit 2 Replacement Steam Generators (RSGs)." This proposed change will separate SGNR implementation requirements from AST implementation requirements and enable AST implementation requirements to be fully met. Likewise for Unit 2, this LAR proposes to revise the Unit 2 Additional Condition for AST implementation, the last Additional Condition listed on Appendix B page B-3, to state, "The Alternative Source Term (AST)

License Amendments 206/193, with the exception of Steam Generator Water Level -

Narrow Range Instrument requirements, will be implemented within 90 days after Page 6 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions installation of the Unit 2 Replacement Steam Generators (RSGs)." The Implementation Date for these Additional Conditions is revised to, "Effective immediately upon issuance of the amendment".

Since this LAR proposes Additional Condition revisions which exclude SGNR from AST implementation, this LAR also proposes to revise TS Table 3.3.3-1, "Event Monitoring Instrumentation", to include the Steam Generator Water Level (Narrow Range) as a new Function 17. Two new Table Notes (d) and (e) are included which specify that the instrumentation for Unit 1 will meet RG 1.97 Type A and Category 1 guidance no later than operating cycle 30 and Unit 2 no later than operating cycle 30.

As an administrative change, this LAR also proposes to remove two Additional Conditions for each unit related toAST implementation as follows. Appendix B for both units include an Additional Condition stating, "NSPM will provide the NRC written notification when Unit 2 RSG installation is complete and AST License Amendment implementation has commenced", with an Implementation Date of, "Within 30 days after completion of the outage in which the Unit 2 RSGs are installed". Appendix B for both units also include an Additional Condition stating, "Implement a physical plant modification or procedure modification that will ensure the 121 Laundry Fan exhaust flow path is not a potential source of post-accident radioactive release through the Auxiliary Building Ventilation Exhaust stack" with an Implementation Date of, "Within 90 days after completion of the outage in which the Unit 2 RSGs are installed."

Technical Basis for Changes During NRC review of the AST LAR (ML112521289), SGNR instruments were identified as instrumentation that provides information required by the control room operators during accident situations, but these instruments had not been classified as RG 1.97 instruments in the PINGP design or licensing basis. Furthermore, since these instruments have been classified as RG 1.97 Type A, Category 1 instruments, then they should be included in TS Table 3.3.3-1 to meet the guidance of NUREG-1431 forTS contents. This lack of RG 1.97 classification was a condition which existed prior to submittal of the AST LAR, that is, lack of classification pre-existed and was not created by the AST LAR. Therefore this LAR proposes to separate the SGNR RG 1.97 classification issue from AST implementation. Separation would be accomplished by revising the AST implementation Additional Condition for each unit to exclude RG 1.97 classification requirements, LA-206/193 Implementation Requirement 4.(1 ), from implementation of AST amendments LA-206/193. NRC issuance of the proposed revised AST implementation Additional Conditions will clarify the status of AST amendments LA-206/193 and bring closure to their implementation activities.

In lieu of AST Implementation Requirement 4.(1) and the associated AST implementation Additional Condition, this LAR proposes to add SGNR instrumentation toTS Table 3.3.3-1 as Function 17 with Notes (d) and (e) which specify the time at which the instruments will fully meet RG 1.97 guidance for Type A and Category 1 instruments. The proposed date for Unit 1 is no later than operating cycle 30 Page 7 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions (scheduled to commence Fall of 2016) and for Unit 2 is no later than operating cycle 30 (scheduled to commence Fall of 2017). With the planned modifications, the PINGP SGNR instrumentation will meet NRC expectations for post-accident monitoring instrumentation classification, design and qualification.

These proposed dates in TS Table 3.3.3-1 Notes (d) and (e) allow time to procure and install SGNR instrumentation which is fully qualified to meet RG 1.97, Revision 2, Type A, Category 1 guidance. The upgrades to the SGNR instruments require modifications to the plant that will be disruptive to plant operations and therefore these modifications are targeted to be performed during scheduled plant refueling outages designated by the plant operating cycle which they precede, that is, refueling outages 1R30 and 2R30 for Units 1 and 2 respectively. Due to the complexities, cost and plant configuration impacts of these modifications, they will be implemented as formal projects to which project and work planning standards apply. The project and work planning standards include project milestones for work to be performed within each scheduled refueling outage. Outages 1R30 and 2R30 were selected as the bounding implementation dates for these modifications in consideration of the ability to successfully complete the modifications in these outages.

NSPM project administration procedures include a fast-track process which can be implemented at project initiation when the standard project management process does not support established project milestones, refueling outage readiness milestones or work completion commitment dates. The goal of this process is to recover projects to the point where standard milestones will apply. NSPM is applying the fast-track process to the Unit 1 modifications to assure that the 1R30 completion date will be met. Another Unit 2 scheduled refueling outage, 2R29, occurs prior to 2R30. Currently NSPM is targeting implementation of the Unit 2 modification for refueling outage 2R29 through application of the fast-track process, but this schedule will be abandoned if it becomes impractical to meet. There are many challenges to implementing the Unit 2 modification during outage 2R29 including bypassing the project study phase, standard project milestones, and 2R29 outage specific milestones. Due to the limited available time until commencement of 2R29, the fast-track process likely cannot recover the SGNR instrumentation project milestones to meet the 2R29 outage milestones. The efforts to implement the Unit 2 SGNR instrumentation modification during 2R29 will likely not be successful and the modification will more likely be completed by the TS proposed implementation date of 2R30.

As described in the AST LAR (ML093160583), the radiological dose analysis for an SGTR event includes a key assumption that the affected steam generator will not overfill and the ruptured SG can be isolated within 30 minutes of an SGTR initiation.

Thus, the analysis only considered steam releases carrying radioactive material for the radiological dose analysis. Water releases have a significantly greater concentration of radioactive material when compared with that of steam releases and will result in worse radiological releases. If SG overfill were allowed to occur, the secondary side of the SG would fill and water may enter the steam lines, resulting in an unanalyzed condition. In this case, the radiological dose analysis for the SGTR event would become invalid.

Page 8 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions The basis for classification of SGNR level instrument indication as a RG 1.97 Type A variable is its use in Emergency Operating Procedure (EOP), "Steam Generator Tube Rupture," which is used by the plant operators to make a timely determination of which SG has ruptured to preclude overfilling of the SG during a SGTR accident.

As discussed in an NSPM letter dated December 8, 2011 (ML113430091 ), all of the instruments utilized for SGTR mitigation in the PINGP specific EOPs are currently classified as RG 1.97, Revision 2, instrumentation in the PINGP Updated Safety Analysis Report (USAR), except for SGNR. Based on a review of the specific mitigation function that the instrument provides, the SGNR level instrumentation has conservatively been classified in accordance with RG 1.97, Revision 2 as Type A, Category 1.

NSPM, within the corrective action program, has determined with reasonable assurance that the SGNR instrumentation has adequate design, qualification, and surveillance tests to ensure that it will perform its specific post-accident monitoring function associated with identifying the ruptured steam generator for the SGTR event. However, full qualification is being pursued within the schedule described in the proposed Notes toTS Table 3.3.3-1.

In the interim, until the SGNR instrumentation is modified, the plant can safely operate based on the capability of the currently installed instrumentation. Type A variables are to meet RG 1.97 Category 1 design and qualification guidance for seismic and environmental qualification, single failure criterion, utilization of emergency standby power, immediately accessible display, continuous readout, and recording of display.

Qualification applies to the complete instrumentation channel from sensor to display where the display is a direct-indicating meter or recording device. In consideration of the RG 1.97 guidance, the currently installed SGNR instrumentation qualification was evaluated with respect to this guidance.

With respect to instrument quality, the channels are installed as part of the reactor protection system and are qualified from the transmitter to the electrical isolator, located in the control room. The non-safety related (NSR) portion of the channel extends from the isolator to the control board indication. The NSR indicators are the same model used in other augmented quality (AQ) or safety related (SR) applications in the plant.

The NSR model has the same construction and installation quality, and is installed in similar locations to the AQ/SR indicators of the same model. The NSR indicators are expected to perform similar to the AQ/SR indicators. A review of the calibration history of the indicators, for both units, back to 2009 found the indicators met their calibration tolerance over this period. Based upon the installation of the channels as part of the reactor protection system, the limited length of the NSR portion, the use of the same model indicator in AQ/SR applications, and the calibration history of the indicators there is reasonable expectation that the indication would be available.

Page 9 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions During a SGTR, containment pressure, temperature, humidity and chemistry continue to be a mild environment. That is, there is no release to the containment atmosphere during this event that would change the environment from that of normal operation. The SGTR could result in an elevated radiation dose to in-containment instruments, the level transmitters, from the RCS fluid collecting in the secondary side of the ruptured SG.

The vault walls provide shielding for the transmitter from the activity levels in the secondary side of the SG, and the required operating time for the transmitter during a SGTR is long enough for the operator to identify the ruptured SG. Thus, the total integrated exposure to the transmitter will be low compared to the normal operating integrated exposure. Therefore, while the current environmental installation does not meet the guidance of RG 1.97 there is reasonable assurance that the instrumentation is not located where adverse environmental conditions would affect its ability to provide control room indication during a SGTR.

The SGNR level indicators are seismically mounted on the control boards and installed to seismic "two over one" criteria (NSR components whose failure could result in damage to SR components). The NSR indicators are the same model used in other seismically qualified AQ/SR applications. The NSR indicators are expected to perform similar to the AQ/SR indicators. Also, SGNR level indication is available through multiple indicators in the control room. Since multiple SGNR channels are available, additional indication locations exist in the control room, and the installed SGNR indicator model is the same used in other seismically qualified applications there is reasonable assurance indication will be available after a seismic event.

There are three narrow range level loops per generator. These loops are installed as part of the Reactor Trip System (RTS); the indication portion of the loops are NSR.

Multiple indication is available in the control room for each level instrument loop. Loss of a single instrument loop would still provide the operators with two loops of indication.

The channels are periodically tested as part of the RTS surveillance requirements, therefore loss of an indication would be quickly recognized. Thus from a single failure perspective, there is reasonable assurance that indication would be available to operations during a SGTR.

SGNR level instrument loops are installed as part of the RTS system. While the indication portion of the loops are NSR, the loops are powered from instrument inverters that are powered from a safety related power supply that will be available during a loss of offsite power, and the power supply to the inverters is battery backed, therefore there is reasonable assurance that indication will be available.

SGNR level indication is available on individual indicators located on the control board.

Additionally, the median channel is displayed on the SG level recorders. These indications are continuously available for operations with additional information available on emergency response computer system (ERGS).

Page 10 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions No qualified recording capabilities for the SGNR level indication exist in the control room. There are two alternate recording instruments available (ERGS and SG level recorders). Additionally, ERGS was initially a credited trend recorder used for the SG wide range level which was originally credited to avoid overfilling the SGs following a SGTR. Therefore based upon past practice and multiple SGNR trend options there is reasonable assurance that trending will be available.

In conclusion, an examination of the current installed SGNR level instrumentation against the guidance for Regulatory Guide 1.97 for Type A, Category 1 variables demonstrates there is reasonable assurance that SGNR level indication would be available during a SGTR event.

TS Table 3.3.3-1 lists variables identified by unit specific RG 1.97 analyses as Type A, Category 1 instruments in accordance with the guidance of NUREG-1431. SGNR instrumentation has been classified as RG 1.97 Type A, Category 1 instrumentation and is required to be listed in TS Table 3.3.3-1 to place the appropriate TS controls on this instrumentation.

This LAR proposes to remove two AST implementation Additional Conditions for each unit which have been fulfilled. The license Appendix B Additional Conditions for each unit includes an Additional Condition which states, "NSPM will provide the NRC written notification when Unit 2 RSG installation is complete and AST License Amendment implementation has commenced." By letter dated January 13, 2014 (ML14014A056),

NSPM notified the NRC that Unit 2 RSG installation was complete and AST implementation had commenced, thus this Additional Condition has been fulfilled and can be administratively removed. The license Appendix B Additional Conditions for each unit includes an Additional Condition which states, "Implement a physical plant modification or procedure modification that will ensure the 121 Laundry Fan exhaust flow path is not a potential source of post-accident radioactive release through the Auxiliary Building Ventilation Exhaust stack." A physical modification was completed March 24, 2014 to prevent post-accident radioactive releases through the 121 Laundry Fan, thus this Additional Condition has been fulfilled and can be administratively removed. These proposed changes are administrative and do not have any technical impact on plant operations.

Conclusions This LAR requests revisions to: 1) TS 3.3.3, "Event Monitoring (EM) Instrumentation";

and 2) the Alternative Source Term license amendment implementation Additional Conditions to exclude Steam Generator Water Level - Narrow Range Instrument implementation requirements. These revisions will allow closure of Alternative Source Term license amendment implementation and termination of interim administrative measures. As an administrative matter, this license amendment request also proposes to remove two Alternative Source Term license amendment implementation license Additional Conditions for each unit which have been fulfilled. Operation of the Prairie Island Nuclear Generating Plant with these proposed changes will continue to protect Page 11 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions the health and safety of the public through improved plant instrumentation and Technical Specification controls on this instrumentation.

4. REGULATORY SAFETY ANALYSIS 4.1 Applicable Regulatory Requirements/Criteria Title 10 Code of Federal Regulations 50.36, "Technical specifications":

(c) Technical specifications will include items in the following categories:

2) Limiting conditions for operation. (i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

With the changes proposed in this license amendment request, the Technical Specifications will continue to specify limiting conditions for operation which assure safe operation, maintenance and testing of the plant. Thus with the changes proposed in this license amendment request, the requirements of Title 10 CFR 50.36 continue to be met.

Title 10 Code of Federal Regulations 50.67, "Accident Source Term":

(b) Requirements. (1) A licensee who seeks to revise its current accident source term in design basis radiological consequence analyses shall apply for a license amendment under§ 50.90. The application shall contain an evaluation of the consequences of applicable design basis accidents previously analyzed in the safety analysis report. (footnote omitted)

The NRC January 22, 2013, safety evaluation (ML112521289) for Prairie Island Nuclear Generating Plant license amendments 206 and 193, for Units 1 and 2 respectively, concluded that the requirements of 10 CFR 50.67 were met with implementation of Technical Specification changes, Appendix B Additional Conditions and license amendment implementation requirements. With the Technical Specification and license Additional Condition changes proposed in this license amendment request, the implementation requirements for license amendments 206 and 193 will be complete.

Thus with the changes proposed in this license amendment request, the requirements of Title 10 CFR 50.67 will be met.

Regulatory Guide 1.97, Revision 2, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident":

Regulatory Guide 1.97 provides methods acceptable to the NRC staff for complying with Page 12 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions the regulations to provide instrumentation to monitor plant variables and systems during and following an accident. This regulatory guide provides guidance for classification of instrumentation credited for monitoring design basis accidents and associated qualification of the instrumentation. The Steam Generator Water Level - Narrow Range Instruments have been classified under the guidance of Regulatory Guide 1.97 as Type A, Category 1 instrumentation. This license amendment request proposes to revise Technical Specification 3.3.3, "Event Monitoring (EM) Instrumentation", to require full compliance with this regulatory guide for this instrumentation for Unit 1 by Operating Cycle 30 and for Unit 2 by Operating Cycle 30. With the changes proposed in this license amendment request, the plant will comply with this regulatory guide for this instrumentation.

NUREG-1431. Revision 4, "Standard Technical Specifications, Westinghouse Plants":

NUREG-1431 provides format and content guidance for Technical Specifications for Westinghouse plants. The current NRC-approved version of NUREG-1431, Revision 4, provides the following content guidance:

Table 3.3.3-1 provides a list of variables typical of those identified by the unit specific Regulatory Guide 1.97 analyses. Table 3.3.3-1 in unit specific Technical Specifications (TS) shall list all Type A and Category 1 variables identified by the unit specific Regulatory Guide 1.97 analyses, as amended by the NRC's Safety Evaluation Report (SER).

The Steam Generator Water Level- Narrow Range Instruments have been classified under the guidance of Regulatory Guide 1.97 as Type A, Category 1 instrumentation.

This license amendment request proposes to revise Technical Specification 3.3.3, "Event Monitoring (EM) Instrumentation", to require full compliance with this regulatory guide for this instrumentation for Unit 1 by Operating Cycle 30 and for Unit 2 by Operating Cycle 30. Therefore, with the changes proposed in this license amendment, the Technical Specifications will conform to the content and guidance of NUREG-1431 which assure safe operation of the plant.

4.2 Precedent Precedent for NRC approval of changes to post-accident monitoring Technical Specification requirement is provided in a letter dated April 25, 2002 (ADAMS Accession No. ML020090379) in which the NRC issued an amendment for Indian Point Nuclear Generating Unit No. 3 to revise the post-accident monitoring instrumentation Technical Specifications. The amendment revised the Post Accident Monitoring Instrumentation Technical Specifications to ensure the licensee commitments to Regulatory Guide 1.97 were properly reflected and to correctly reflect the design of the plant.

Page 13 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions 4.3 Significant Hazards Consideration Determination Northern States Power Company, a Minnesota Corporation (NSPM), doing business as Xcel Energy, proposes to amend the facility operating licenses of Prairie Island Nuclear Generating Plants (PINGP) Units 1 and 2. The purpose of this amendment is to modify the PINGP Technical Specifications (TS) to add Steam Generator Water Level- Narrow Range (SGNR) instruments to the list of event monitoring instrumentation; revise license Additional Conditions to exclude Steam Generator Water Level - Narrow Range instrument implementation requirements from Alternative Source Term license amendment implementation; and remove Alternative Source Term license amendment implementation license Additional Conditions which have been fulfilled.

NSPM evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92(c),

"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 license amendment request proposes to add Steam Generator Water Level (narrow range) Instrumentation to Technical Specification Event Monitoring Instrumentation; revise license Additional Conditions to exclude Steam Generator Water Level (narrow range) Instrument implementation requirements from Alternative Source Term license amendment implementation; and remove Alternative Source Term amendment implementation Additional Conditions which have been fulfilled.

The Steam Generator Water Level (narrow range) Instrumentation is not an accident initiator and therefore addition of this instrumentation to the Technical Specifications does not increase the probability of an accident. Addition of this instrumentation to the Technical Specifications will bring it under the controls and testing requirements of the Technical Specifications. The proposed change will not increase the consequences of previously-evaluated accidents because the inclusion of these instruments in the technical specification improves their reliability to perform during a postulated accident. Therefore, the proposed Technical Specification changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The Alternative Source Term license amendment was previously analyzed and approved for implementation. The proposed Additional Condition revision to exclude Steam Generator Water Level (narrow range) Instrumentation implementation requirements from Alternative Source Term license amendment implementation clarifies implementation requirements and allows completion of implementation activities. Since the Alternative Source Term amendment was Page 14 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions previously approved, this change does not increase the probability or consequences of a previously evaluated accident.

Removal of license Additional Conditions which have been fulfilled is an administrative change and thus this change does not increase the probability or consequences of a previously evaluated accident.

The proposed changes do 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 accident previously evaluated?

Response: No The license amendment request proposes to add Steam Generator Water Level (narrow range) Instrumentation to Technical Specification Event Monitoring Instrumentation; revise license Additional Conditions to exclude Steam Generator Water Level (narrow range) Instrument implementation requirements from Alternative Source Term license amendment implementation; and remove Alternative Source Term amendment implementation Additional Conditions which have been fulfilled.

The proposed Technical Specification changes and Additional Condition changes and the resulting instrument upgrades do not create new failure modes or mechanisms and do not change plant conditions from which some new material interaction may create a new or different type of accident. Thus, the Technical Specification and license Additional Condition changes do not create new failure modes or mechanisms, nor do they generate new accident precursors.

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

The proposed removal of fulfilled Additional Conditions is an administrative change and thus does not create the possibility of a new or different kind of accident.

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

Response: No The license amendment request proposes to add Steam Generator Water Level (narrow range) Instrumentation to Technical Specification Event Monitoring Instrumentation; revise license Additional Conditions to exclude Steam Generator Water Level (narrow range) Instrument implementation requirements from Alternative Source Term license amendment implementation; and remove Page 15 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions Alternative Source Term amendment implementation Additional Conditions which have been fulfilled.

Addition of this instrumentation to the Technical Specifications will bring it under the controls and testing requirements of the Technical Specifications. The proposed change will not increase the consequences of previously evaluated accidents because instrument upgrade and the inclusion of these instruments in the Technical Specifications improves their reliability to perform during a postulated accident. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

The Alternative Source Term license amendment was previously analyzed and approved for implementation. The proposed Additional Condition revision to exclude Steam Generator Water Level (narrow range) Instrumentation implementation requirements from Alternative Source Term license amendment implementation clarifies implementation requirements and allows completion of implementation activities. Since the Alternative Source Term was previously approved, the changes proposed in this license amendment do not involve a significant reduction in a margin of safety.

The proposed removal of fulfilled Additional Conditions is administrative in nature and thus does not involve a significant reduction in a margin of safety.

Based on the above, NSPM concludes that the proposed amendment does not involve a 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.

4.4 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 Commission's 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.

5. ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment 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 amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR Page 16 of 17

Enclosure NSPM Revise TS Table 3.3.3-1 and AST Additional Conditions 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 amendment.

6. REFERENCES None Page 17 of 17

ENCLOSURE,ATTACHMENT1 Additional Condition and Technical Specification Pages (Markup)

Additional Condition DPR-42 pages:

8-3 8-3 (page carry over) 8-4 Additional Condition DPR-60 pages:

8-3 8-3 (page carry over) 8-4 Technical Specification Page:

3.3.3-6 7 pages follow

APPENDIX B ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. DPR-42 Amendment Implementation Number Additional Conditions Date 158 The schedule for performing Surveillance Requirements October 31, (SRs) that are new or revised in Amendment No. 158 shall 2002 be as follows:

For SRs that are new in this amendment, the first performance is due at the end of the first surveillance interval, which begins on the date of implementation of this amendment.

For SRs that existed prior to this amendment, whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

For SRs that existed prior to this amendment, whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to the implementation of this amendment.

158 The licensee is authorized to relocate certain Technical October 31, Specification requirements previously included in 2002 Appendix A to licensee-controlled documents, as described in Table LR, "Less Restrictive Changes- Relocated Details," and Table R, "Relocated Specifications," atta.ched to the NRC staff's safety evaluation dated July 26, 2002.

Those requirements shall be relocated to the appropriate documents no later than October 31, 2002.

The Alternative Source Term (AST) License Amendments Effective 206/193, with the exception of Implementation Requirement immediately

4. (1) for Steam Generator Water Level- Narrow Range upon issuance Instruments. will be implemented within 90 days after of the installation of the Unit 2 Replacement Steam Generators amendmentWit (RSGs). hin 90 days after completion of the outage in

'A'hich the Unit 2 B-3 Amendment No. ;we

RSGs are installed B-3 Amendment No. 200

APPENDIX B ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. DPR-42 Amendment Implementation Number Additional Conditions Date

---

2-00 NSPM will provide the NRC written notification 'Nhen Unit 2 VVithin 30 days RSG installation is complete and AST License Amendment after completion implementation has commenced. of the outage in which the Unit 2 RSGs are installed Implement a physical plant modification or procedure Within 90 days modification that 'Nill ensure the 121 Laundry Fan exhaust after completion flow path is not a potential source of post accident of the outage in radioactive release through the Auxiliary Building 'Nhich the Unit 2 Ventilation Exhaust stacl(. RSGs are installed B4 Amendment No. 206

APPENDIX 8 ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. DPR-60 Amendment Implementation Number Additional Conditions Date 149 The schedule for performing Surveillance Requirements October 31, (SRs) that are new or revised in Amendment No. 149 shall 2002 be as follows:

For SRs that are new in this amendment, the first performance is due at the end of the first surveillance interval, which begins on the date of implementation of this amendment.

For SRs that existed prior to this amendment, whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

For SRs that existed prior to this amendment, whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to the implementation of this amendment.

149 The licensee is authorized to relocate certain Technical October 31, Specification requirements previously included in 2002 Appendix A to licensee-controlled documents, as described in Table LR, "Less Restrictive Changes- Relocated Details," and Table R, "Relocated Specifications," attached to the NRC staff's safety evaluation dated July 26, 2002.

Those requirements shall be relocated to the appropriate documents no later than October 31, 2002.

The Alternative Source Term License Amendments Effective 206/193, with the exception of Implementation Requirement immediately

4. (1) for Steam Generator Water Level- Narrow Range upon issuance Instruments, will be implemented within 90 days after of the installation of the Unit 2 Replacement Steam Generators amendmentWJ.t (RSGs). hin 90 days after oompletion of the outage in 8-3 Amendment No. ~

Correoted by letter dated February 20, 2013

'Nhich the Unit 2 RSGs are installed 8-3 Amendment No. ~

Corrected by letter dated February 20, 2013

APPENDIX B ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. DPR-60 Amendment Implementation Number Additional Conditions Date 193 NSPM will provide the NRC written notification 'l.'hen Unit 2 \"/ithin 30 days RSG installation is complete and AST License Amendment after oompletion implementation has commenced. of the outage in vvhioh the Unit 2 RSGs are installed 193 Implement a physical plant modification or procedure Within 90 days modification that will ensure the 121 Laundry Fan exhaust after completion flmv path is not a potential source of post aocident of the outage in radioactive release through the Auxiliary Building whioh the Unit 2 Ventilation Exhaust staol<. RSGs are installed 84 Amendment No. 193

EM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 1)

Event Monitoring Instrumentation CONDITION REFERENCED FROM FUNCTION REQUIRED REQUIRED ACTION CHANNELS G.l

1. Power Range Neutron Flux (Logarithmic Scale) 2 H

2. Source Range Neutron Flux (Logmithmic Scale) 2 H

3. Reactor Coolant System (RCS) Hot Leg Temperature 2 H

4. RCS Cold Leg Temperature 2 H

5. RCS Pressure (Wide Range) 2 H

6. Reactor Vessel Water Level 2

7. Containment Sump Water Level (Wide Range) 2 H

8. Containment Pressure (Wide Range) 2 H

9. Penetration Flow Path Automatic Containment 2 per penetration flow H Isolation Valve Position path(a)(b)

10. Containment Area Radiation (High Range) 2

11. Notused

12. Pressurizer Level 2 H

13. Steam Generator Water Level (Wide Range) 2 per steam generator H

14. Condensate Storage Tank Level 2 H

15. Core Exit Temperature 4 per quadrant(c) H

16. Refueling Water Storage Tank Level 2 H

17. Steam Generator Water Level (Narrow Range) (d)(e) 2 per steam generator H (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel.

(c) A channel consists of one core exit thermocouple (CET).

(d) Unit I instmments will comply with Regulatory Guide 1.97, Type A. Category I guidance no later than Unit I Cycle 30.

(e) Unit 2 instruments will comply with Regulatory Guide 1.97. Type A. Category I guidance no later than Unit 2 Cycle 30.

Prairie Island Unit 1- Amendment No . .f..3.& +/-@

Units 1 and 2 3.3.3-6 Unit 2- Amendment No. M9 .f-§.4.

ENCLOSURE,ATTACHMENT2 Technical Specification Bases Pages (Markup)

B 3.3.3-9 B 3.3.3-12 B 3.3.3-13 3 pages follow

EM Instrumentation B 3.3.3 BASES LCO 10. Containment Area Radiation (High Range) (continued) invoke site emergency plans. Containment radiation level is used to determine if a LOCA with core damage has occurred.

11. Not Used

12. Pressurizer Level Pressurizer Level is used to determine whether to terminate SI, if still in progress, or to reinitiate SI if it has been stopped.

Knowledge of pressurizer water level is also used to verify the unit conditions necessary to establish natural circulation in the RCS and to verify that the unit is maintained in a safe shutdown condition.

13. Steam Generator Water Level (Wide Range)

SG Water Level is provided to monitor operation of decay heat removal via the SGs. A+he Category I indication of SG level is the wide range level instrumentation. The wide range level covers a span of 0% to 100% between the lower tubesheet and the separator.

The LCO requires two channels of indication in the control room to be OPERABLE for each SG (Wide Range). Each SG is treated separately and each SG indication is considered a separate function. Therefore, separate Condition entry is allowed for each SG indication.

SG Water Level (Wide Range) is used to:

Prairie Island Unit 1 - Revision m I Units 1 and 2 B 3.3.3-9 Unit 2 - Revision +8-

EM Instrumentation B 3.3.3 BASES LCO 15. Core Exit Temperature (continued)

CETNumber CET Location 9 D-5 10 D-7 12 E-4 13 E-6 14 E-10 16 F-7 18 G-4 19 G-6 22 H-5 23 H-9 28 1-4 29 1-8 30 1-10 32 J-6 33 J-8 34 J-9 These required thermocouples ensure a single failure will not disable the ability to determine the radial temperature gradient.

16. Refueling Water Storage Tank (RWST) Level The RWST Level is a Category I, Type A variable provided for verifying a water source to the ECCS and Containment Spray, determining the time for initiation of recirculation following a LOCA, and event diagnosis.

17. Steam Generator Water Level (Narrow Range)

Steam Generator Narrow Range level instrumentation is categorized as a Category L Type A. vatiable provided as the primary indication used to identify the ruptured Steam Generator to preclude overfill in a Steam Generator Tube Rupture event.

Prairie Island Unit 1 - Revision -+/--161 Units 1 and 2 B 3.3.3-12 Unit 2 - Revision -+/--16

EM Instrumentation B 3.3.3 BASES LCO 17. Steam Generator Water Level (Narrow Range) (continued)

The LCO requires two channels of indication in the control room to be OPERABLE for each SG (Narrow Range). Each SG is treated separately. and each SG indication is considered a separate function. Therefore. separate Condition entry is allowed for each SG indication.

APPliCABILITY The EM instrumentation LCO is applicable in MODES 1 and 2.

These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. In MODES 3, 4, 5, and 6, unit conditions are such that the likelihood of an event that would require EM instrumentation is low; therefore, the EM instrumentation is not required to be OPERABLE in these MODES.

ACTIONS A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.3-1.

The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

Condition A applies when one or more Functions have one required channel that is inoperable. Required Action A.1 requires restoring the inoperable channel to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel, the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring EM instrumentation during this interval.

A Note has been added stating that Condition A is not applicable to the CETs. The CETs are controlled under Conditions B, E, and F Prairie Island Unit 1 - Revision +/-+e I Units 1 and 2 B 3.3.3-13 Unit 2- Revision +/-+e

ENCLOSURE,ATTACHMENT3 Additional Condition and Technical Specification Pages (Retyped)

Additional Condition DPR-42 pages:

B-3 Additional Condition DPR-60 pages:

B-3 Technical Specification Page:

3.3.3-6 3 pages follow

Unit 1 APPENDIX 8 ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. DPR-42 Amendment Implementation Number Additional Conditions Date 158 The schedule for performing Surveillance Requirements October 31, (SRs) that are new or revised in Amendment No. 158 shall 2002 be as follows:

For SRs that are new in this amendment, the first performance is due at the end of the first surveillance interval, which begins on the date of implementation of this amendment.

For SRs that existed prior to this amendment, whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

For SRs that existed prior to this amendment, whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to the implementation of this amendment.

158 The licensee is authorized to relocate certain Technical October 31, Specification requirements previously included in 2002 Appendix A to licensee-controlled documents, as described in Table LR, "Less Restrictive Changes- Relocated Details," and Table R, "Relocated Specifications," attached to the NRC staff's safety evaluation dated July 26, 2002.

Those requirements shall be relocated to the appropriate documents no later than October 31, 2002.

XXX The Alternative Source Term (AST) License Amendments Effective 206/193, with the exception of Implementation Requirement immediately

4. (1) for Steam Generator Water Level- Narrow Range upon issuance Instruments, will be implemented within 90 days after of the installation of the Unit 2 Replacement Steam Generators amendment (RSGs).

8-3 Amendment No.

Unit 2 APPENDIX 8 ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. DPR-60 Amendment Implementation Number Additional Conditions Date 149 The schedule for performing Surveillance Requirements October 31, (SRs) that are new or revised in Amendment No. 149 shall 2002 be as follows:

For SRs that are new in this amendment, the first performance is due at the end of the first surveillance interval, which begins on the date of implementation of this amendment.

For SRs that existed prior to this amendment, whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

For SRs that existed prior to this amendment, whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to the implementation of this amendment.

149 The licensee is authorized to relocate certain Technical October 31, Specification requirements previously included in 2002 Appendix A to licensee-controlled documents, as described in Table LR, "Less Restrictive Changes- Relocated Details," and Table R, "Relocated Specifications," attached to the NRC staff's safety evaluation dated July 26, 2002.

Those requirements shall be relocated to the appropriate documents no later than October 31, 2002.

XXX The Alternative Source Term License Amendments Effective 206/193, with the exception of Implementation Requirement immediately

4. (1) for Steam Generator Water Level- Narrow Range upon issuance Instruments, will be implemented within 90 days after of the installation of the Unit 2 Replacement Steam Generators amendment (RSGs).

B-3 Amendment No.

EM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 1)

Event Monitoring Instrumentation CONDITION REFERENCED FROM FUNCTION REQUIRED REQUIRED ACTION CHANNELS G.l

1. Power Range Neutron Flux (Logarithmic Scale) 2 H

2. Source Range Neutron Flux (Logarithmic Scale) 2 H

3. Reactor Coolant System (RCS) Hot Leg Temperature 2 H

4. RCS Cold Leg Temperature 2 H

5. RCS Pressure (Wide Range) 2 H

6. Reactor Vessel Water Level 2

7. Containment Sump Water Level (Wide Range) 2 H

8. Containment Pressure (Wide Range) 2 H

9. Penetration Flow 'Path Automatic Containment 2 per penetration flow H Isolation Valve Position path(a)(b)

10. Containment Area Radiation (High Range) 2

11. Not used

12. Pressurizer Level 2 H

13. Steam Generator Water Level (Wide Range) 2 per steam generator H

14. Condensate Storage Tank Level 2 H

15. Core Exit Temperature 4 per quadrant(c) H

16. Refueling Water Storage Tank Level 2 H

17. Steam Generator Water Level (Narrow Range) (d)(e) 2 per steam generator H (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel.

(c) A channel consists of one core exit thermocouple (CET).

(d) Unit 1 instruments will comply with Regulatory Guide 1.97, Type A, Category 1 guidance no later than Unit 1 Cycle 30.

(e) Unit 2 instruments will comply with Regulatory Guide 1.97, Type A, Category 1 guidance no later than Unit 2 Cycle 30.

Prairie Island Unit 1 -Amendment No. B-&-!-@

Units 1 and 2 3.3.3-6 Unit 2- Amendment No. -149 +M