ML15264A209

Issuance of Amendment Nos. 216 and 204 Regarding Revisions to Technical Specification 3.3.3 and Renewed Facility Operating License

ML15264A209
Person / Time
Site:	Prairie Island
Issue date:	11/30/2015
From:	Beltz T Plant Licensing Branch III
To:	Davison K Northern States Power Co, Xcel Energy
Beltz T
References
TAC MF5415, TAC MF5416
Download: ML15264A209 (25)

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Mr. Kevin K. Davison Site Vice President Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota 1717 Wakonade Drive East Welch, MN 55089

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 -

ISSUANCE OF LICENSE AMENDMENTS REGARDING REVISION TO TECHNICAL SPECIFICATION (TS) 3.3.3 AND THE RENEWED FACILITY OPERATING LICENSE RELATED TO IMPLEMENTATION OF ALTERNATE SOURCE TERM (AST) (CAC NOS. MF5415 AND MF5416)

Dear Mr. Davison:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment Nos. 216 and 204 to Renewed Facility Operating License Nos. DPR-42 and DPR-60 for the Prairie Island Nuclear Generating Plant (Prairie Island), Units 1 and 2, respectively, in response to your application dated December 11, 2014. The amendments revise TS 3.3.3, "Event Monitoring (EM) Instrumentation," to add steam generator water level - narrow range instruments to Table 3.3.3-1, and to revise Appendix B, Additional Conditions, of the Renewed Facility Operating License, to support AST implementation at Prairie Island, Units 1 and 2.

A copy of our related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306

Enclosures:

1. Amendment No. 216 to DPR-42

2. Amendment No. 204 to DPR-60

3. Safety Evaluation cc: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER COMPANY - MINNESOTA DOCKET NO. 50-282 PRAIRIE ISLAND NUCLEAR GENERATING PLANT. UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 216 Renewed License No. DPR-42

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Northern States Power Company - Minnesota (NSPM, the licensee), dated December 11, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-42 is hereby amended to read as follows:

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 216, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

Enclosure 1

3. This license amendment is effective as its date of issuance and shall be implemented within 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

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Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-42 and Technical Specifications Date of Issuance: November 30, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 216 RENEWED FACILITY OPERATING LICENSE NO. DPR-42 DOCKET NO. 50-282 Replace the following pages of Renewed Facility Operating License No. DPR-42 with the attached revised pages. The change areas are identified by a marginal line.

REMOVE INSERT Replace the following page of Appendix B, Additional Conditions, of Renewed Facility Operating License No. DPR-42 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT B-3 B-3 B-4 Replace the following page of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

REMOVE INSERT 3.3.3-6 3.3.3-6

(3) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, NSPM to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility; (6) Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to transfer byproduct materials from other job sites owned by NSPM for the purpose of volume reduction and decontamination.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level NSPM is authorized to operate the facility at steady state reactor core power levels not in excess of 1677 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 216, are hereby incorporated in the renewed operating license.

NSPM shall operate the facility in accordance with the Technical Specifications.

(3) Physical Protection NSPM shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Renewed Operating License No. DPR-42 Amendment No. 216

Safeguards Information protected under 10 CFR 73.21, is entitled: "Prairie Island Nuclear Generating Plant Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program," submitted by letters dated October 18, 2006, and January 10, 2007, and as supplemented by letters dated March 18 and June 2, 2011, and approved by NRC Safety Evaluation dated August 16, 2011.

NSPM shall fully implement and maintain in effect all provisions of the Commission-approved Northern States Power Company - Minnesota (NSPM)

Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NSPM CSP was approved by License Amendment No. 202 and supplemented by License Amendment No. 212.

(4) Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire protection program as described and referenced in the Updated Safety Analysis Report for the Prairie Island Nuclear Generating Plant, Units 1 and 2, and as approved in Safety Evaluation Reports dated February 14, 1978, September 6, 1979, April 21, 1980, December 29, 1980, July 28, 1981, October 27, 1989, and October 6, 1995, subject to the following provision:

NSPM may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(5) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 216, are hereby incorporated into this license. NSPM shall operate the facility in accordance with the Additional Conditions.

(6) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel Renewed Operating License No. DPR-42 Amendment No. 216

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," attached to the NRC staffs safety evaluation dated July 26, 2002.

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

216 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).

B-3 Amendment No. 216

EM Instrumentation 3.3.3 Table 3.3.3-1(page1 of 1)

Event Monitoring Instrumentation CONDITION REFERENCED FROM FUNCTION REQUIRED REQUIRED ACTION CHANNELS G.l I. 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 quadranlc) 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. -lfil. 216 Units 1and2 3.3.3-6 Unit 2 - Amendment No. +§4 204

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER COMPANY - MINNESOTA DOCKET NO. 50-306 PRAIRIE ISLAND NUCLEAR GENERATING PLANT. UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 204 Renewed License No. DPR-60

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Northern States Power Company - Minnesota (NSPM, the licensee), dated December 11, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-60 is hereby amended to read as follows:

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 204, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

Enclosure 2

3. This license amendment is effective as its date of issuance and shall be implemented within 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION David L. Pelton, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-60 and Technical Specifications Date of Issuance: November 30, 201 5

ATTACHMENT TO LICENSE AMENDMENT NO. 204 RENEWED FACILITY OPERATING LICENSE NO. DPR-60 DOCKET NO. 50-306 Replace the following pages of Renewed Facility Operating License No. DPR-60 with the attached revised pages. The change areas are identified by a marginal line.

REMOVE INSERT Replace the following page of Appendix B, Additional Conditions, of Renewed Facility Operating License No. DPR-60 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT B-3 8-3 B-4 Replace the following page of Appendix A, Technical Specifications, with the attached revised pages. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3.3.3-6 3.3.3-6

(3) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, NSPM to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility; (6) Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to transfer byproduct materials from other job sites owned by NSPM for the purpose of volume reduction and decontamination.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level NSPM is authorized to operate the facility at steady state reactor core power levels not in excess of 1677 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 204, are hereby incorporated in the renewed operating license.

NSPM shall operate the facility in accordance with the Technical Specifications.

(3) Physical Protection NSPM shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Renewed Operating License No. DPR-60 Amendment No. 204

Safeguards Information protected under 10 CFR 73.21, is entitled: "Prairie Island Nuclear Generating Plant Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, submitted by letters dated October 18, 2006 and January 10, 2007, and as supplemented by letters dated March 18 and June 2, 2011, and approved by NRC Safety Evaluation dated August 16, 2011.

NSPM shall fully implement and maintain in effect all provisions of the Commission-approved Northern States Power Company- Minnesota (NSPM)

Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NSPM CSP was approved by License Amendment No. 189 and supplemented by License Amendment No. 200.

(4) Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire protection program as described and referenced in the Updated Safety Analysis Report for the Prairie Island Nuclear Generating Plant, Units 1 and 2, and as approved in Safety Evaluation Reports dated February 14, 1978, September 6, 1979, April 21, 1980, December 29, 1980, July 28, 1981, October 27, 1989, and October 6, 1995, subject to the following provision:

NSPM may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(5) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 204, are hereby incorporated into this license. NSPM shall operate the facility in accordance with the Additional Conditions.

(6) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures Renewed Operating License No. DPR-60 Amendment No. 204

APPENDIX B 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 staffs safety evaluation dated July 26, 2002.

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

204 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. 204

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.1

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)

IO. 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 ofone core exit thermocouple (CET).

(d) Unit I instruments will comply with Regulatory Guide 1.97, Type A, Category 1 guidance no later than Unit 1Cycle30.

(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.~ 216 Units 1and2 3.3.3-6 Unit 2 - Amendment No. !M 204

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 216 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-42 AND AMENDMENT NO. 204 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-60 NORTHERN STATES POWER COMPANY-MINNESOTA PRAIRIE ISLAND NUCLEAR GENERATING PLANT. UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306

1.0 INTRODUCTION

1.1 Background By letter dated October 27, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093160583), as supplemented by letters dated June 22, 2011, August 9, 2011, and December 8, 2011 (ADAMS Accession Nos. ML111740145, ML112220098 and ML113430091, respectively), Northern States Power Company - Minnesota (NSPM, the licensee), doing business as Xcel Energy, submitted a license amendment request (LAR) to change the technical specifications (TS) to support adoption of an Alternate Source Term (AST) methodology for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2.

On January 22, 2013, the U.S. Nuclear Regulatory Commission (NRC) issued Amendment Nos. 206 and 193 (ADAMS Accession No. ML112521289) to Renewed Facility Operating License Nos. DPR-42 and DPR-60 for PINGP, Units 1 and 2, respectively. The amendments modified the PINGP TSs and licensing basis to support adoption of the AST methodology. The approved amendments stated that, with the exception of the steam generator water level -

narrow range (SGNR) instrumentation, all principal instruments required for steam generator tube rupture (SGTR) mitigation are fully qualified. Additionally, the amendments stated that once the licensee qualifies the SGNR instrumentation to meet the criteria of Regulatory Guide (RG) 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Revision 2, then all the primary instrumentation listed in Table 1 of the licensee's letter dated December 8, 2011, will be adequate for SGTR mitigation and will comply with the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50.36.

Enclosure 3

The approved AST amendments included the following implementation requirement:

Prior to implementation of the Alternate 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.

In addition, the amendments added the following license conditions to TS Appendix B, "Additional Conditions":

• The Alternative Source (AST) License Amendments 206/193 will be implemented after installation of the Unit 2 Replacement Steam Generators (RSGs).

• NSPM will provide the NRC written notification when Unit 2 RSG installation is complete and AST License Amendment implementation has commenced.

• 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 stack.

1.2 License Amendment Request On December 11, 2014 (ADAMS Accession No. ML14349A749), NSPM submitted a license amendment request (LAR) to revise the technical specifications (TSs) and Renewed Facility Operating Licenses at PINGP, Units 1 and 2. The proposed changes would revise TS 3.3.3, "Event Monitoring (EM) Instrumentation," to add the steam generator water level - narrow range (SGNR) instruments to Table 3.3.3-1, and to revise Appendix B, "Additional Conditions," of the Renewed Operation Licenses, to support implementation of the AST at PINGP.

The licensee indicates in the LAR that it was unable to implement the requirement to meet the RG 1.97 requirements for the SGNR instruments. Consequently, the licensee was unable to implement the Additional Conditions for implementing Amendment Nos. 206 and 193 after installation of the Unit 2 RSGs within the implementation date of 90 days after completion of the outage in which the Unit 2 RSGs were installed.

The LAR proposes to separate SGNR compliance with RG 1.97 from AST implementation by:

• Adding SGNR instruments to Table 3.3.3-1, "Event Monitoring Instrumentation".

• Adding two notes to Table 3.3.3-1 specifying when the SGNR instruments will meet RG 1.97 guidance.

• Modifying a license condition in TS Appendix B, "Additional Conditions," to make an exception for implementation of the SGNR instrumentation requirements within 90 days after RSG installation.

Additionally, the LAR proposes to remove two of the Additional Conditions specified in TS Appendix B which have been fulfilled.

2.0 REGULATORY EVALUATION

The NRC staff reviewed the proposed TS changes in Section 1.0 against the regulatory requirements and guidance listed in Sections 2.1 and 2.2 of this report to ensure that there is reasonable assurance that the systems and components affected by the proposed TS changes will perform their safety functions.

2.1 Regulatory Requirements:

The staff considered the following regulatory requirements:

10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," establishes the fundamental regulatory requirements. Specifically, Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50 provides criteria for the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to safety.

In 10 CFR 50.36, "Technical Specifications," the Commission established its regulatory requirements related to the contents of the TS. Specifically, 10 CFR 50.36 states that "each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section."

10 CFR 50.36( c)(3) states, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

The staff reviewed the adequacy of the SGNR instrumentation used for SGTR mitigations against these requirements to ensure that there is reasonable assurance that the instrumentation will perform its required safety functions.

2.2 Regulatory Guidance:

The staff considered the regulatory guidance provided in RG 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Asses Plant and Environs Conditions During and Following an Accident," Revision 2. Clause 1.3.1 in this RG stipulates the Design and Qualification Criteria for Category 1 instrumentation. Table 2 in RG 1.97 lists the suggested Category for Pressurized Water Reactor plant instrumentation.

3.0 TECHNICAL EVALUATION

3.1 Background During the NRC staff's review of the LAR to adopt the AST methodology (ADAMS Accession

No. ML112521289), the SGNR instruments were identified as instrumentation providing information required by the control room operators during accident situations and credited as the primary indication for identification of a steam generator tube rupture. Therefore, this function is required to be classified as a Type A, Category 1, instrument under RG 1.97, Revision 2, and included in TS Table 3.3.3-1. However, the SGNR instruments had not been classified as RG 1.97 instruments in the PINGP design or licensing basis. This lack of RG 1.97 classification was a condition that existed prior to the AST LAR.

In Amendment Nos. 206 and 193 for PINGP, Units 1 and 2, the NRC staff found that the licensee's corrective action program identified that the SGNR instruments should be qualified to RG 1.97. The licensee initiated actions to fully demonstrate and document that the SGNR instruments will comply with the correct RG 1.97 classification.

As previously discussed in Section 1.1, Implementation Requirement 4.1) included in Amendments 206/193 stated the following:

Prior to implementation of the Alternate 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.

To comply with the RG 1.97 guidance for the SGNR instruments, the licensee decided to designate this function as Type A, Category 1, instrumentation and replace the SGNR instrumentation loop components to bring them into compliance with these requirements.

However, in its December 11, 2014, application, the licensee stated that design, procurement, manufacturing and installation of qualified equipment could not be performed within the implementation date of 90 days after the outage in which the Unit 2 RSG were installed. By not completing this implementation requirement, the licensee was unable to fulfill the Additional Condition that requires AST License Amendments 206/193 be implemented after installation of the Unit 2 RSGs. Therefore, the licensee proposes to separate SGNR compliance with RG 1.97 from the AST implementation Additional Condition.

3.2 NRC Staff Evaluation 3.2.1 Addition of SGNR Instruments to Table 3.3.3-1, "Event Monitoring Instrumentation" The licensee proposes to revise TS Table 3.3.3-1, "Event Monitoring Instrumentation", to include the SGNR instruments as a new Function 17 which is required to comply with RG 1.97.

The licensee proposes to add Notes (d) and (e) to Function 17 to specify the time at which the SGNR instruments will meet the RG 1.97 guidance for Type A and Category 1 instruments. The notes are as follows:

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

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

The Unit 1 Cycle 30 outage (scheduled to commence fall of 2016) and the Unit 2 Cycle 30 outage (scheduled to commence fall of 2017) were selected by the licensee to allow time for procuring and installing SGNR instrumentation which is fully qualified to meet the Type A, Category 1 guidance as specified in RG 1.97, Revision 2.

The licensee also evaluated the currently installed SGNR instrumentation against the RG 1.97 guidance to ensure that it will perform its specific post-accident monitoring function for a SGTR event, until the SGNR instrumentation is modified to comply with RG 1.97.

RG 1.97, Clause 1.3.1, "Design and Qualification Criteria - Category 1," specifies the design and qualification requirements as it applies to Category 1 accident-monitoring instrumentation.

Category 1 instrumentation provides the most stringent requirements for those key plant variables important for accomplishing specific safety functions.

RG 1.97, Clause 1.3.1. a., contains instrumentation qualification criteria for accident-monitoring instrumentation. The qualification criteria applies to the complete instrumentation channel from sensor to display, where the display is a direct-indicating meter or recording device.

The licensee states that during a SGTR, the containment pressure, temperature, humidity and chemistry continue to be a mild environment. 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 licensee states that in this situation 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. Regarding seismic qualification, the SGNR level indicators are seismically mounted on the control boards and installed to seismic "two over one" criteria (non-safety related components whose failure could result in damage to safety-related components).

The licensee states the non-safety related indicators are the same model used in other seismically qualified augmented quality or safety-related applications. Finally, the SGNR level indication is available through multiple indicators in the control room.

The NRC staff finds that the currently installed SGNR instrumentation is adequately qualified to remain capable of providing tube rupture indication during a SGTR event until the SGNR instrumentation is modified to fully comply with RG 1.97.

RG 1.97, Clause 1.3.1, b., contains single failure criteria for accident-monitoring instrumentation. No single failure within either the accident-monitoring instrumentation, its auxiliary supporting features, or its power sources concurrent with the failures that are a condition or result of a specific accident should prevent operators from being presented information necessary for them to determine the safety status of the plant and bring the plant to and maintain it in a safe condition.

The licensee states there are three SGNR level loops per steam generator which are installed as part of the Reactor Trip System (RTS) and multiple indications are available in the control room for each level instrument loop, and that the loss of a single instrument loop would still provide plant operators with two loops of level indication. The licensee further states the channels are periodically tested as part of the RTS surveillance requirements, which allows for identifying the loss of an indication.

The NRC staff finds that the currently installed SGNR instrumentation indication would continue to be available to operations upon the loss of one indication until the SGNR instrumentation is modified to fully comply with RG 1.97, RG 1.97, Clause 1.3.1, c., contains criteria for emergency power sources. It provides that instrumentation should be energized from station standby power sources and backed up by batteries where momentary interruption is not tolerable.

The licensee states the SGNR level instrument 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. Additionally, the power supply to the inverters is battery backed.

The NRC staff finds that the currently installed SGNR instrumentation is adequately energized by emergency power sources until the SGNR instrumentation is modified to fully comply with RG 1.97.

RG 1.97, Clause 1.3.1, d., contains criteria related to instrument availability such that the instrument channel should be available prior to an accident, and RG 1.97, Clause 1.3.1, f.,

contains criteria for continuous indication such that the entire level range is provided coverage.

The licensee states the SGNR level indication is available on individual indicators located on the control board, while the median channel is displayed on the steam generator level recorders.

These indications are continuously available for supporting plant operation with additional information available on the emergency response computer system (ERGS).

The NRC staff finds that the currently installed SGNR instrumentation is available prior to an accident and capable of providing continuous indication, such that the range required to be monitored is provided coverage, until the SGNR instrumentation is modified to fully comply with RG 1.97.

RG 1.97, Clause 1.3.1, e., provides quality assurance criteria for accident-monitoring instrumentation.

The licensee states that the SGNR channels are installed as part of the RTS and are qualified from the transmitter to the electrical isolator, which is located in the control room. The non-safety related portion of the channel extends from the isolator to the control board indication. The non-safety related indicators are the same model used in other augmented quality or safety-related applications in the plant. Additionally, the licensee states that a review of the calibration history (both units back to 2009) of the indicators found the indicators met their calibration tolerance over this period.

The NRC staff finds that the quality assurance criteria for the currently installed SGNR instrumentation provides reasonable assurance for ensuring accident monitoring capability is maintained for providing indication of a tube rupture during a SGTR event until the SGNR instrumentation is modified to fully comply with RG 1.97. All other principal instruments required for SGTR mitigation are fully qualified for SGTR mitigation.

RG 1.97, Clause 1.3.1, g., contains criteria for recording of instrument readout information. The licensee states that although no qualified recording capabilities for the SGNR level indication exist in the control room, there are two alternate recording instruments available (ERCS and SG level recorders). The ERCS 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.

The NRC staff finds that the currently installed SGNR instrumentation will continue to be capable of recording readout information until the SGNR instrumentation is modified to comply with RG 1.97.

Summary Based on the above, the NRC staff finds the licensee has adequately evaluated the currently installed SGNR level instrumentation against RG 1.97, and that until the SGNR instrumentation is modified to comply with RG 1.97, the currently installed SGNR instrumentation is capable of providing tube rupture indication during a SGTR event. The staff also finds the addition of Function 17, SGNR instrumentation, and notes (d) and (e) to TS Table 3.3.3-1 to be acceptable.

3.2.2 Modification of License Condition in TS Appendix B, "Additional Conditions" License amendments 206/193 include a SGNR instrumentation Implementation Requirement which states that "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 for Unit 1 and Unit 2 which required that "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."

In order to separate the SGNR implementation requirements from the AST implementation requirements, the licensee proposes to revise this Additional Condition for Unit 1 and Unit 2 to state the following:

The Alternative Source Term 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).

The implementation date for these Additional Conditions is revised to, "Effective immediately upon issuance of the amendment."

Summary Based on the above, the NRC staff finds that SGNR instrumentation compliance with RG 1.97

will be tracked by the new TS Table 3.3.3-1 Function 17, Notes (d) and (e), by removing SGNR compliance with RG 1.97 from the Appendix B Additional Condition is acceptable. The proposed Appendix B Additional Condition change separates SGNR compliance with RG 1.97 from AST implementation, and thus enables AST implementation requirements to be met.

3.2.3 Removal of Two License Conditions in TS Appendix B, "Additional Conditions" The licensee proposes to remove two AST implementation Additional Conditions, for each unit, which have been fulfilled. The first Additional Condition for each unit states that "NSPM will provide the NRC written notification when Unit 2 RSG installation is complete and AST License Amendment implementation has commenced", with an associated implementation date of "Within 30 days after completion of the outage in which the Unit 2 RSGs are installed."

By letter dated January 13, 2014 (ADAMS Accession No. ML14014A056), NSPM notified the NRC that Unit 2 RSG installation was complete and AST implementation had commenced. The NRC staff finds that this Additional Condition has been fulfilled and can be administratively removed.

The second Additional Condition for each unit states to "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 9 days after completion of the outage in which the Unit 2 RSGs are installed."

Summary The licensee states that a physical modification was completed on March 24, 2014, to prevent post-accident radioactive releases through the 121 Laundry Fan. Therefore, the NRC staff finds this Additional Condition has been fulfilled and can be administratively removed.

3.3 Conclusion The NRC staff evaluated the licensee's justifications for the proposed administrative TS changes specified in Section 1.0 of this safety evaluation. The staff finds the proposed TS changes to separate SGNR compliance with RG 1.97 from AST implementation to be acceptable. The staff also finds the proposed removal of two fulfilled Additional Conditions to be acceptable.

Although the currently installed SGNR instrumentation fails to fully meet the guidance provided in RG 1.97, the NRC staff finds that continued operation under these temporary circumstances is acceptable. After the licensee qualifies the SGNR instrumentation to fully meet the criteria of RG 1.97, all the primary instrumentation listed in Table 1 of the December 8, 2011, letter, will be adequate for SGTR mitigation and be in compliance with the requirements of 10 CFR 50.36.

Based on the above, the NRC staff concludes that the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendment on November 17, 2015. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the use of facility components located within the restricted area as defined in 10 CFR Part 20 or changes surveillance requirements.

The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding as published in the Federal Register on April 14, 2015 (80 FR 20023). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

6.0 CONCLUSION

The NRC staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Samir Darbali, NRR Date: November 30, 2015

ML15264A209

• concurrence via memorandum dated October 1, 2015 OFFICE NRR/DORL/LPLlll-1/PM NRR/DORL/LPLlll-1/LA NRR/DE/EICB/BC NRR/DSS/STSB/BC NAME TBeltz MHenderson MWaters

• RElliott DATE 10/14/2015 10/19/2015 10/01/2015 11/04/2015 OFFICE OGC (NLO) NRR/DORL/LPLlll-1/BC NRR/DORL/LPLlll-1 /PM NAME BMizuno DPelton TBeltz DATE 11/16/2015 11/30/2015 11/30/2015