Text

Issuance of Amendments Technical Specification 3.8.7 Inverters-Operating
	ML17130A716
Person / Time
Site:	Prairie Island
Issue date:	06/20/2017
From:	Robert Kuntz; Plant Licensing Branch III
To:	Northard S; Northern States Power Company, Minnesota
	Kuntz R, DORL/LPLIII, 415-3733
References
	CAC MF8319, CAC MF8320
	Download: ML17130A716 (17)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 20, 2017 Mr. Scott D. Northard 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 1AND2 -

ISSUANCE OF AMENDMENTS RE: TECHNICAL SPECIFICATION 3.8.7 "INVERTERS-OPERATING" (CAC NOS. MF8319 AND MF8320)

Dear Mr. Northard:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 219 to Renewed Facility Operating License No. DPR-42 and Amendment No. 206 to Renewed Facility Operating License No. DPR-60 for the Prairie Island Nuclear Generating Plant, Units 1 and 2, respectively. The amendments consist of changes to the technical specifications (TSs) in response to your application dated August 31, 2016, as supplemented by letter dated February 16, 2017.

The amendments revise TS 3.8. 7 by removing the site-specific Required Actions and associated Completion Times, thus reverting to the standard TS language contained in NUREG-1431, "Standard Technical Specifications: Westinghouse Plants."

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.

S.inc.erely'. -- .* . -7***

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// ~- I Licen~iBranch R _K izdnior Project Manager Plant Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306

Enclosures:

1. Amendment No. 219 to DPR-42

2. Amendment No. 206 to DPR-60

3. Safety Evaluation cc w/encls: 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. 219 License No. DPR-42

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

A. The application for amendment by Northern States Power Company, a Minnesota Corporation (NSPM, the licensee), dated August 31, 2016, as supplemented by letter dated February 16, 2017, 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 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:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 219, are hereby incorporated in the renewed operating license. NSPM shall operate the facility in accordance with the Technical Specifications.

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

FOR THE NUCLEAR REGULATORY COMMISSION

()J 9u_

David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: June 20, 2017

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. 206 License No. DPR-60

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

A. The application for amendment by Northern States Power Company, a Minnesota Corporation (NSPM, the licensee), dated August 31, 2016, as supplemented by letter dated February 16, 2017, 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 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.

Enclosure 2

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:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 206, are hereby incorporated in the renewed operating license. NSPM shall operate the facility in accordance with the Technical Specifications.

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

FOR THE NUCLEAR REGULATORY COMMISSION Q~na9~ief~~

Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: June 20, 2017

ATTACHMENT TO LICENSE AMENDMENT NOS. 219 AND 206 RENEWED FACILITY OPERATING LICENSE NOS. DPR-42 AND DPR-60 PRAIRIE ISLAND NUCLEAR GENERATING PLANT DOCKET NOS. 50-282 AND 50-306 Replace the following pages of the Renewed Facility Operating License Nos. DPR-42 and DPR-60 with the attached revised pages. The changed areas are identified by a marginal line.

REMOVE INSERT Page 3 Page 3 Page 3 Page 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.8.7-1 3.8.7-1 3.8.7-2 3.8.7-2 3.8.7-3

(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. 219, 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. 219

(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 purposes 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. 206, 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. 206

Inverters-Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS

3. 8. 7 Inverters-Operating LCO 3.8.7 Four Reactor Protection Instrument AC inverters shall be OPERABLE.

APPLICABILlTY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Reactor Protection A.I ------------NOTE------------

Instrument AC inverter Enter the applicable inoperable. Conditions and Required Actions ofLCO 3.8.9, "Distribution Systems -

Operating" with any Reactor Protection Instrument AC panel de-energized.

Restore Reactor Protection 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Instrument AC inverter to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Prairie Island Unit I - Amendment No. §-8, 219 Units 1and2 3.8.7-1 Unit 2 - Amendment No. +49, 206

Inverters-Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8. 7.1 Verify correct inverter voltage and alignment to 7 days required Reactor Protection Instrument AC panels.

Prairie Island Unit 1 - Amendment No. ~' 219 Units 1and2 3.8.7-2 Unit 2 - Amendment No. -l-49, 206

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 219 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-42 AND AMENDMENT NO. 206 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

By application dated August 31, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16244A493), as supplemented by letter dated February 16, 2017 (ADAMS Accession No. ML17047A687), Northern States Power Company, a Minnesota Corporation (the licensee), requested changes to the technical specifications (TSs) for Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2. The supplemental letter dated February 16, 2017, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on October 25, 2016 (81 FR 73436).

The proposed changes would revise the TS 3.8.7, "Inverters - Operating," to remove a non-conservatism by adopting the NUREG-1431, "Standard Technical Specifications [STS]:

Westinghouse Plants," language for TS 3.8.7. Specifically, the proposed changes would delete the plant-specific Required Actions (RAs) and Completion Times (CTs) for inoperable inverter(s), and would add the RA and associated CT for one inoperable inverter consistent with the improved STS.

2.0 REGULATORY EVALUATION

Title 1O of the Code of Federal Regulations (10 CFR) Part 50.36, "Technical specifications,"

requires, in part, that the operating license of a nuclear production facility include TSs.

10 CFR 56.36(c)(2) requires that the TS include limiting conditions for operation (LCOs) that 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."

Enclosure 3

According to PINGP updated safety analysis report (USAR), Section 8.1, "Summary," the following criteria of the Proposed General Design Criteria (PGDC) for Nuclear Power Plant Construction Permits, published by the Atomic Energy Commission in July 11, 1967, are applicable to PINGP:

Criterion 24, "Emergency Power for Protection Systems," which states: "In the event of loss of all offsite power, sufficient alternate sources of power shall be provided to permit the required functioning of the protection systems."

Criterion 39, "Emergency Power for Engineered Safety Features," which states: "An emergency power source shall be provided and designed with adequate independency, redundancy, capacity, and testability to permit the functioning of the engineered safety features and protection systems required to avoid undue risk to the health and safety of the public. This power source shall provide this capacity assuming a failure of a single active component."

NUREG-1431, Revision 4, "Standard Technical Specifications: Westinghouse Plants," contains the Improved Standard Technical Specification (ISTS) for Westinghouse plants. The ISTS were developed based on the criteria in the Final Commission Policy Statement on TSs Improvements for Nuclear Power Reactors, dated July 22, 1993, which was subsequently codified by changes to Section 36 of Part 50 of 10 CFR 50.36 (60 FR 36953).

Regulatory Guide (RG) 1.93, Revision 1, "Availability of Electric Power Sources," states: "If the available inverters are one less than the LCO, power operation may continue for a period that should not exceed the 24-hour time period specified in the standard technical specifications. If the affected inverter is restored within this time period, unrestricted operation may resume. If not, the licensee should shut down the plant in accordance with plant-specific technical specifications."

3.0 TECHNICAL EVALUATION

3.1 Background According to PINGP, USAR, Section 8.6, "Instrumentation and Control AC [alternating current]

Power Supply Systems," each PINGP unit has four reactor protection instrument (RPI) AC inverters (hereafter inverters). Each inverter supplies a corresponding RPI AC panel that is dedicated to one Reactor Protection and Nuclear Instrumentation System channel. Each inverter has an associated rectifier that allows the inverter to be fed from an AC source with instantaneous non-interrupted transfer to the direct current (DC) system if there is a loss of rectifier or AC supply. The power supplied to an RPI AC panel is provided by the uninterruptible power supply which includes an automatic static transfer switch in addition to the inverter. The automatic transfer switch transfers the RPI AC panel load from the inverter, if it fails, to the AC source through a bypass breaker.

Each PINGP unit also includes a minimum interruptible bus, denoted as Panel 117 for Unit 1 and Panel 217 for Unit 2, which is fed from a 480-volt (V)-AC safeguards bus via a safeguards motor control center.

Section 3.1 of the license amendment request (LAR) states that the inverters are the preferred source of power for the RPI AC panels because of the stability and reliability they achieve. The

inverters ensure the availability of uninterruptible AC power for the instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated design-basis accident (OBA).

Section 3.2 of the LAR states that Panels 117 and 217, which can be aligned to any of the four RPI AC panels on the associated unit, were downgraded from safety-related to nonsafety- related in 2010. The downgrade of the Panels 117 and 217 eliminates the justification for considering these panels reliable to remain functional during a postulated OBA.

PINGP TS 3.8.7 provides the actions to be implemented when an inverter is inoperable. The current TS 3.8.7 Action A (Condition A with associated RAs and CTs) provides no requirement for restoring the inoperable inverter and, as such, allows the RPI AC panel to be powered from either the inverter bypass source or the nonsafety-related Panel 117 (217) indefinitely. Without a requirement to restore the preferred power source (i.e., inverter) for the affected RPI AC panel to operable status, the licensee determined that the current TS 3.8. 7 Action A is non-conservative. In accordance with the U.S. Nuclear Regulatory Commission (NRC or Commission) Administrative Letter 98-10, "Oispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," LAR, Section 1.0 states that administrative controls have been implemented to require a plant shutdown after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation with a RPI bus powered via the nonsafety-related Panels 117 and 217. To resolve this non-conservatism, the licensee proposes to revise TS 3.8.7 consistent with NUREG-1431.

3.2 Staff Evaluation The LAR proposes to revise TS 3.8.7 by (1) modifying current Action A to adopt the NUREG-1431 TS 3.8.7 RA and CT for one inoperable inverter; (2) deleting current Action B for two inoperable inverters; and (3) renumbering current Action C which applies when Condition A and its associated RA and CT are not met. The LCO 3.8.7 and its applicability remain unchanged. The NRC staff evaluation of the proposed changes is provided in the following sections.

TS 3. 8. 7, Action A PINGP TS 3.8.7 Action A would be revised by: (1) deleting current RAs A.1 and A.2 and associated CTs, and (2) adding a new RA A.1 and associated CT for restoring one inoperable inverter.

The proposed revised RA A.1 would require the inverter to be restored to operable status with an associated completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . RA A.1 would also include a note that would require entry into the applicable conditions and RAs of TS LCO 3.8.9 with any RPI AC panel de-energized. TS 3.8.9 Condition C applies when an RPI AC panel is inoperable (de-energized), and associated RA C.1 requires the RPI AC panel to be restored to operable status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The Bases of TS 3.8.9 state that the RPI AC panels are operable when (1) they are energized to their proper voltages to ensure necessary power to the appropriate engineered safety feature (ESF) systems, and (2) they ensure the redundancy incorporated into the design of the ESF is not defeated.

Currently, TS 3.8.9 allows Panels 117 and 217 to be used as power supplies for restoring the RPI panels to operable status. However, LAR, Section 2.2, states that a lack of train separation for the safety-related equipment exists when the non-safety-related Panel 117 (217) is aligned to the safety-related RPI AC panel 112 or 114 (212 or 214). In the request for additional

information (RAI) dated January 18, 2017 (ADAMS Accession No. ML17018A427), the NRC staff requested a description of how independence/redundancy is maintained between the safety-related equipment when the RPI AC panels are being fed from the Panel 117 or 217, as allowed by TS 3.8.9. In its response provided by letter dated February 16, 2017, the licensee clarified that the independence/ redundancy is not preserved when the nonsafety-related Panel 117 or 217 is being used to power an RPI AC panel. The licensee also stated that Panels 117 and 217 cannot be used to meet the TS LCOs 3.8.7 and 3.8.9; and this fact will be reflected in the revised Bases for TS 3.8.7 and 3.8.9. The licensee further explained that Panels 117 and 217 will be used as power supplies for the RPI AC panels during maintenance and during the LCOs while actions are being taken to return the RPI AC panels to service. The NRC staff finds that, since the nonsafety-related Panels 117 and 217 cannot restore the inoperable RPI AC panels within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months as required by TS 3.8.9 Action C, the use of the Panels 117 and 217 in any case during plant operation is limited to less than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and controlled by TS 3.8.9 Action C. Therefore, the NRC staff has no further concerns with the use of the nonsafety-related Panels 117 and 217 since these panels will not be used to meet the requirements of TS 3.8.7 and 3.8.9.

In the February 16, 2017, response letter, the licensee also stated that the inverter bypass sources remain the safety-related backup sources for the RPI AC panels. When an inverter is inoperable, the inverter bypass source will restore the RPI AC panel to operable status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , as required by TS LCO 3.8.9 Action C. This is consistent with the PINGP current licensing bases. The NRC staff finds that maintaining the RPI AC panels in an operable status will allow sufficient time to fix the inverter and return it to service. In addition, the proposed new RA A.1 including the note is consistent with NUREG-1431. Therefore, the NRC staff finds the proposed new RA A.1 for an inoperable inverter acceptable because the safety-related inverter bypass sources are capable of maintaining the RPI AC panels operable and the new RA A.1 is consistent with NUREG-1431.

The licensee proposes a 24-hour CT for restoring the inoperable inverter (RA A.1 ). In the LAR, the licensee states that the proposed 24-hour CT is adopted from NUREG-1431, Revision 4.

According to NUREG-1431, "the 24-hour limit is based upon engineering judgment, taking into consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the inverter inoperability." In addition, RG 1.93, Revision 1, "Availability of Electric Power Sources," recommends power operation to be limited to the 24-hour time period specified in the NUREG-1431 if one inverter is inoperable. Since the proposed 24-hour CT and its associated RA A.1 are consistent with NUREG-1431 and RG 1.93, the NRC staff finds the proposed 24-hour CT for an inoperable inverter acceptable.

The licensee also proposes deleting the current RA A.1 and RA A.2 from the TS 3.8.7. The current TS 3.8.7 RA A.1 requires verifying that the RPI AC panel with inoperable inverter is powered from Panel 117 (217) within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . In letter dated February 16, 2017, in response to an NRC staff RAI regarding the use of nonsafety-related Panel 117(217), the licensee clarified that the nonsafety-related Panels 117 and 217 will no longer be used to meet the TS LCOs 3.8.7 and 3.8.9. Since the Panels 117 and 217 cannot be used to meet the TS LCOs, the staff finds the elimination of current RA A.1 with its associated CT from the TS acceptable.

Current TS 3.8. 7 RA A.2 requires verifying that the RPI AC panel with inoperable inverter is powered from its inverter bypass source within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This action is accomplished by the note in new RA A.1 when, as directed by the note, TS LCO 3.8.9 Action C is entered to restore the de-energized RPI AC panel to operable status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months using the inverter bypass source.

Since current RA A.2 with associated CT will be completed by new RA A.1, the NRC staff finds the elimination of current RA A.2 with its associated CT from the TS acceptable.

In summary, the licensee revised TS 3.8.7 Action A for an inoperable inverter by adding new RA and CT and deleting the current RAs with associated CTs. The NRC staff finds the new RA A.1 and associated CT acceptable because they are consistent with NUREG-1431, RG 1.93, and the current PINGP licensing bases. The NRC staff also finds the elimination of the two current TS 3.8.7 RAs with associated CTs acceptable since one RA is no longer required and the other RA will be satisfied by new RA A.1. Therefore, the NRC staff concludes that the proposed change to TS 3.8.7 Action A is acceptable since the change results in a revised TS 3.8.7 that conforms to NUREG-1431 and continues to provide acceptable remedial actions as required by 10 CFR 50.36(c)(2).

TS 3. 8. 7, Current Action B The LAR proposes deleting RAs 8.1, 8.2, and 8.3, and the associated CTs.

The LAR proposes deleting current Action 8 for two inoperable inverters from the TS 3.8.7.

LAR, Section 3.3, states that an immediate entry into LCO 3.0.3 would be required for two or more inoperable inverters. PINGP TS LCO 3.0.3 requires a unit shutdown when a TS LCO is not met and the specific condition of the unit in Modes 1, 2, 3, and 4 is not addressed by the associated actions. Since no action is proposed for the condition of two or more inoperable inverters, the NRC staff finds TS LCO 3.0.3 appropriate for this condition. In addition, the entry into LCO 3.0.3 for two or more inoperable inverters is consistent with the action recommended by NUREG-1431 when more than one inverter is inoperable. Therefore, the staff concludes that the elimination of current Action 8 related to two inoperable inverters is acceptable because the change results in a revised TS 3.8.7 that conforms to NUREG-1431 and continues to provide acceptable remedial actions as required by 10 CFR 50.36(c)(2).

TS 3. 8. 7, Current Action C The LAR proposes to renumber current Action C as Action 8 with the proposed deletion of the current Action 8 as discussed above. Since the action statements of renumbered Action 8 have not changed, the NRC staff finds that the renumbering of Action C as Action 8 is editorial in nature. In addition, the renumbered Action 8 is consistent with NUREG-1431. Therefore, the NRC staff concludes that the renumbering of Action C is acceptable since the change results in a revised TS 3.8.7 that conforms to NUREG-1431 and continues to provide acceptable remedial actions as required by 10 CFR 50.36(c)(2).

TS Page 3.8. 7-3 The proposed revision to the TS 3.8.7 requirements moved the text from TS page 3.8.7-3 to TS page 3.8.7-2 and therefore TS page 3.8.7-3 is deleted. This is an administrative change to the TSs and therefore acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendments an May 9, 2017. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. 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 a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (81 FR 73436, dated October 25, 2016). 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 the amendments.

6.0 CONCLUSION

The Commission 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 Contributor: Adakou Foli, NRR Date of issuance: June 20, 2017

ML17130A716 *memo date **via e-mail OFFICE DORL/LPL3/PM DORL/LPL3/LA DE/EEEB/ BC* DE/El CB/BC NAME RKuntz SRohrer JZimmerman MWaters DATE 05/11/17 05/11/17 04/20/17 05/31/17 OGC NLO subject OFFICE DSS/STSB/BC** DORL/LPL3/BC DORL/LPL3-1/PM to edits**

NAME JWhitman(A) RNorwood DWrona RKuntz DATE 05/26/17 06/16/17 06/20/17 06/20/17

v t e Letter Sequence Approval
CAC:MF8319, (Approved, Closed) CAC:MF8320, (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers 16 February 2017 Results Approval Other:
MONTHYEAR2016-09-20 [Table View]

ML17130A716

Text

SUBJECT:

Dear Mr. Northard:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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