Text

Issuance of Amendments TSTF-439 Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO
	ML19128A133
Person / Time
Site:	Prairie Island
Issue date:	06/06/2019
From:	Robert Kuntz; Plant Licensing Branch III
To:	Sharp S; Northern States Power Co
	Kuntz R, NRR/DORL/LPL3,, 415-3733
References
	EPID L-2018-LLA-0178
	Download: ML19128A133 (43)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 6, 2019 Mr. Scott Sharp 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 AMENDMENTS RE: TSTF-439 "ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO" (EPID L-2018-LLA-0178)

Dear Mr. Sharp:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 227.to Renewed Facility Operating License No. DPR-42 and Amendment No. 215 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 June 26, 2018.

The amendments revise TS 1.3, "Completion Times" Example 1.3-3, TS 3.6.5, "Containment Spray and Cooling Systems," TS 3.7.5, "Auxiliary Feedwater (AFW) System," TS 3.7.8, "Cooling Water (CL) System," TS 3.8.1, "AC Sources - Operating," and TS 3.8.9, "Distribution Systems -

Operating" by eliminating the second completion time in accordance with Technical Specifications Task Force (TSTF)-439, Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [limiting condition for operation]."

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.

. ~*enior Project Manager KWll'fb~

Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306

Enclosures:

1. Amendment No. 227 to DPR-42

2. Amendment No. 215 to DPR-60

3. Safety Evaluation cc: 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. 227 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 June 26, 2018, 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 i r 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:

Enclosure 1

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 227, 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.

CLEAR REGULATORY COMMISSION Lisa M. Regner, Acting Chief Plant Licensing Branch 111 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 6, 2 o1 9

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. 215 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 June 26, 2018, 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 d~fense 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:

Enclosure 2

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 215, 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.

LEAR REGULATORY COMMISSION Lisa M. Regner, Acting Chief Plant Licensing Branch 111 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 6 , 2 o1 9

ATTACHMENT TO LICENSE AMENDMENT NOS. 227 AND 215 RENEWED FACILITY OPERATING LICENSE NOS. DPR-42 AND DPR-60 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 1.3-3 1.3-3 1.3-7 1.3-7 1.3-8 1.3-8 1.3-9 1.3-9 1.3-10 1.3-10 1.3-11 1.3-11 1.3-12 1.3-12 1.3-13 1.3-13 1.3-14 1.3-14 1.3-15 1.3-15 1.3-16 3.6.5-1 3.6.5-1 3.6.5-2 3.6.5-2 3.7.5-2 3.7.5-2 3.7.8-2 3.7.8-2 3.7.8-3 3.7.8-3 3.7.8-4 3.7.8-4 3.8.1-1 3.8.1-1 3.8.1-2 3.8.1-2 3.8.1-3 3.8.1-3 3.8.1-4 3.8.1-4 3.8.1-5 3.8.1-5 3.8.1-6 3.8.1-6 3.8.1-7 3.8.1-7 3.8.1-8 3.8.1-8 3.8.1-9 3.8.1-9 3.8.1-10 3.8.9-1 3.8.9-1 3.8.9-2 3.8.9-2 3.8.9-3

(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. 227, 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. 227

(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. 215, 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. 215

Completion Times 1.3 1.3 Completion Times DESCRIPTION The above Completion Time extension does not apply to a (continued) Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ,"

where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " An I*

example of a modified "time zero" with the Completion Time expressed as "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months " is illustrated in Example 1.3-6, Condition A. In this example, the Completion Time may not be extended.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 1.3-3 Unit 2-Amendment No. 215

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.l Restore Function X 7 days Function X train to train OPERABLE status.

inoperable.

B. One B.l Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function Y train to train OPERABLE status.

inoperable.

C. One C.l Restore Function X 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function X train to train OPERABLE status.

inoperable.

OR AND C.2 Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months One train to Function Y OPERABLE status.

train inoperable.

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 1.3-7 Unit 2 -Amendment No. 215

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions Band Care exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A).

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 1.3-8 Unit 2-Amendment No. 215

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-4

( continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.I Restore valve(s) to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months valves OPERABLE inoperable. status.

B. Required B.l Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated AND Completion Time not B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months met.

A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per valve basis. Declaring subsequent valves inoperable, while Condition A is still in effect, does not trigger the tracking of separate Completion Times.

Once one of the valves has been restored to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first valve was declared inoperable. The Completion Time may be extended if the valve restored to OPERABLE status was the first inoperable valve. The Condition A Completion Time may be extended for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provided this does not result in any subsequent valve being inoperable for> 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 1.3-9 Unit 2 -Amendment No. 215

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-4 (continued)

If the Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (plus the extension) expires while one or more valves are still inoperable, Condition B is entered.

EXAMPLE 1.3-5 ACTIONS

NOTE-------------------------------------

Separate Condition entry is allowed for each inoperable valve.

CONDITION REQU1RED ACTION COMPLETION TIME A. One or more A.l Restore valve to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months valves OPERABLE inoperable. status.

B. Required B.l Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated AND Completion Time not B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months met.

The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 1.3-10 Unit 2-Amendment No. 215

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-5 (continued)

The Note allows Condition A to be entered separately for each inoperable valve, and Completion Times tracked on a per valve basis. When a valve is declared inoperable, Condition A is entered and its Completion Time starts. If subsequent valves are declared inoperable, Condition A is entered for each valve and separate Completion Times start and are tracked for each valve.

If the Completion Time associated with a valve in Condition A expires, Condition B is entered for that valve. If the Completion Times associated with subsequent valves in Condition A expire,

~ondition B is entered separately for each valve and separate Completion Times start and are tracked for each valve. If a valve that caused entry into Condition B is restored to OPERABLE status, Condition B is exited for that valve.

Since the Note in this example allows multiple Condition entry and tracking of separate Completion Times, Completion Time extensions do not apply.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 1.3-11 Unit 2 -Amendment No. 215

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-6 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel A.1 Perform Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable. SR3.x.x.x.

OR A.2 Reduce 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months THERMAL POWER to

50% RTP.

B. Required B.l Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated Completion Time not met.

Entry into Condition A offers a choice between Required Action A.1 or A.2. Required Action A.1 has a "once per" Completion Time, which qualifies for the 25% extension, per SR 3.0.2, to each performance after the initial performance. The initial 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval of Required Action A.1 begins when Condition A is entered and the initial performance of Required Action A.1 must be complete within the first 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval. If Required Action A. l is followed, and the Required Action is not met within the Completion Time (plus the extension allowed by SR 3.0.2), Condition Bis entered. If Required Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 1.3-12 Unit 2-Amendment No. 215

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-6 (continued)

Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is not met, Condition B is entered.

If after entry into Condition B, Required Action A. l or A.2 is met, Condition B is exited and operation may then continue in Condition A.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 1.3-13 Unit 2-Amendment No. 215

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-7 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.I Verify affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months subsystem subsystem isolated.

inoperable. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Restore subsystem 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to OPERABLE status.

B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated AND Completion Time not B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months met.

Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time begins at the time the Condition is entered and each "Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter" interval begins upon performance of Required Action A.1.

Prairie Island Unit 1 -Amendment No. 227 Units 1 and 2 1.3-14 Unit 2 -Amendment No. 215

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-7 (continued)

If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or any subsequent 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval from the previous performance (plus the extension allowed by SR 3.0.2), Condition Bis entered. The Completion Time clock for Condition A does not stop after Condition B is entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may continue i_n accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired.

IMMEDIA1E When "Immediately" is used as a Completion Time, the Required COMPLETION Action should be pursued without delay and in a controlled manner.

TIME Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 1.3-15 Unit 2 -Amendment No. 215

Containment Spray and Cooling Systems 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Spray and Cooling Systems LCO 3.6.5 Two containment spray trains and two containment cooling trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.I Restore containment spray 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable. train 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 of Condition A not AND met.

B.2 Be in MODE 5. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months C. One or both containment C.l Restore containment 7 days cooling fan coil unit(s) cooling FCU(s) to (FCU) in one train OPERABLE status.

inoperable.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 3.6.5-1 Unit 2 -Amendment No. 215

Containment Spray and Cooling Systems 3.6.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One containment cooling D.1 Initiate action to isolate Immediately FCU in each train both inoperable FCUs.

inoperable.

AND D.2 Restore all FCUs to 7 days OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months '

associated Completion Time of Condition C or D AND not met.

E.2 Bein MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Prairie Island Unit 1 -Amendment No. 227 Units 1 and 2 3.6.5-2 Unit 2 - Amendment No. 215

AFW System 3.7.5 ACTIONS

NOTE:-------------------------------------------------

LCO 3.0.4.b is not applicable.

CONDITION REQUIRED ACTION COMPLE:TION TIME:

A. One steam supply to A.1 Restore affected equipment 7 days turbine driven AFW to OPE:RABLE: status.

pump inoperable. I .

OR

NOTE:-----------

Only applicable if MODE:

2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE: 3 following refueling.

B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable in MODE: 1, 2, OPE:RABLE: status.

or 3 for reasons other than Condition A.

Prairie Island Unit 1 -Amendment No. 227 Units 1 and 2 3.7.5-2 Unit 2-Amendment No. 215

CL System 3.7.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.1 .Restore one safeguards CL 7 days pump to OPERABLE status.

B. One CL supply header -----------------NOTES----------------

inoperable. 1. Unit 1 enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-MODES 1, 2, 3, and 4," for emergency diesel generator made inoperable by CL System.

2. Both units enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4," for residual heat removal loops made inoperable by CL System.

B.l Verify vertical motor driven 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months CL pump OPERABLE.

AND B.2 Verify opposite train diesel 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months driven CL pump OPERABLE.

AND B.3 Restore CL supply header to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 3.7.8-2 Unit 2 -Amendment No. 215

CL System 3.7.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.l 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 C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. -----------NOTE------------ D.1 Restore fuel oil supply to ~ 7 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Separate Condition entry days.

is allowed for each stored diesel driven CL pump fuel oil supply.

One or both stored diesel driven CL pump fuel oil supply(s) < 7 days and

~ 6 days.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 3.7.8-3 Unit 2 -Amendment No, 215

CL System 3.7.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. -----------NOTE------------ E.1 Declare associated diesel Immediately Separate Condition entry driven CL pump inoperable.

is allowed for each stored diesel driven CL pump fuel oil supply.

One or both stored diesel driven CL pump fuel oil supply(s)

< 6 days.

Required Action and associated Completion Time of Condition D not met.

Prairie Island Unit 1 -Amendment No. 227 Units 1 and 2 3.7.8-4 Unit 2 -Amendment No. 215

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two paths between the offsite transmission grid and the onsite 4 kV

Safeguards Distribution System; and

b. Two diesel generators (DGs) capable of supplying the onsite 4 kV Safeguards Distribution System.

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

ACTIONS

NOTE--------------------------------------------------

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required path A.l Perform SR3.8.l.l for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE path.

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Restore path to 7 days OPERABLE status.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 3.8.1-1 Unit 2 -Amendment No. 215

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One DG inoperable. B.l Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months paths.

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required feature( s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the discovery of inoperable DG inoperable Condition B when its required concurrent with redundant feature(s) is inoperability of inoperable. redundant required feature(s)

AND B.3 .1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DG is not inoperable due to common cause failure.

B.3.2 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE DG.

AND B .4 Restore DG to 14 days OPERABLE status.

Prairie Island Unit 1 -Amendment No. 227 Units 1 and 2 3.8.1-2 Unit 2 -Amendment No. 215

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two paths inoperable. C.1 Declare required feature( s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from inoperable when its discovery of redundant required Condition C feature(s) is inoperable. concurrent with inoperability of redundant required features AND C.2 Restore one path to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

D. One path inoperable. -----------------NOTE----------------

Enter applicable Conditions and AND Required Actions of LCO 3.8.9, "Distribution Systems-One DG inoperable. Operating," when Condition Dis entered with no AC power source to either train.

D.l Restore path to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

OR D.2 Restore DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2. 3.8.1-3 Unit 2 -Amendment No. 215

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two DGs inoperable. E.1 Restore one DG to 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months s*

OPERABLE status.

F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A, B, AND C, D, or E not met.

F.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G. Two DGs inoperable and G.l Enter LCO 3.0.3. Immediately one or more paths inoperable.

OR One DG inoperable and two paths inoperable.

A one-time change increased the Completion Time to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Unit 2 during the period from January 29 through January 31 , 2019. This change was approved via an emergency license amendment Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 3.8.1 -4 Unit 2 - Amendment No. 215

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power In accordance with availability for each required path. the Surveillance Frequency Control Program SR 3 .8.1.2 ----------------------------NOTES--------------------------

1. Performance of SR 3 .8.1.6 satisfies this SR.

2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

3. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR in consideration of manufacturer's recommendations. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.6 must be met.

Verify each DG starts from standby conditions and In accordance with achieves steady state voltage:::. 4084 V and the Surveillance

_::: 4400 V, and frequency:::. 59.5 Hz and_::: 60.5 Hz. Frequency Control Program Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 3.8.1-5 Unit 2 -Amendment No. 215

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3 .8.1'.3 ---------------------------NOTES---------------------------

1. DG loadings may include gradual loading in consideration of manufacturer's recommendations.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.6.

Verify each DG is synchronized and loaded and In accordance with operates for ~ 60 minutes at a load: the Surveillance Frequency Control

a. Unit l; ~ 2500 kW; and Program

b. Unit 2; ~ 5100 kW and~ 5300 kW.

SR 3.8.1.4 Verify fuel oil level above lower limit switch in each In accordance with day tank. the Surveillance Frequency Control Program SR 3.8.1.5 Verify the fuel oil transfer system operates to transfer In accordance with fuel oil from storage tank to the day tank. the Surveillance Frequency Control Program Prairie Island Unit 1 -Amendment No. 227 Units 1 and 2 3.8.1-6 Unit 2 -Amendment No. 215

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3 .8.1.6 ----------------------------NOTE---------------------------

All DG starts may be preceded by an engine prelube period.

Verify each DG starts from standby condition and In accordance with achieves: the Surveillance Frequency Control

a. In.:::: 10 seconds, voltage 2:. 3740 V and Program frequency 2:_ 58.8 Hz; and

b. Steady state voltage 2:_ 4084 V and.:::: 4400 V, and frequency 2:_ 59.5 Hz and.:::: 60.5 Hz.

SR 3.8.1.7 Verify each DG does not trip during and following a In accordance with load *rejection of: the Surveillance Frequency Control

1. Unit 1 2:_ 650 kW; and Program

2. Unit 2 2:. 860 kW.

SR 3.8.1.8 Verify each DG's automatic trips are bypassed on an In accordance with actual or simulated safety injection signal except: the Surveillance Frequency Control

a. Engine overspeed; Program

b. Generator differential current; and

c. Ground fault (Unit 1 only).

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 3.8.1-7 Unit 2 -Amendment No. 215

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3. 8.1. 9 ----------------------------NOTES--------------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. If performed with DG synchronized with offsite power, it shall be performed at a power factor

_:: 0.85. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG operates for 2:_ 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: In accordance with the Surveillance

a. For 2:_ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded: Frequency Control Program Unit 1 2:_ 2832 kW, and

_::3000kW Unit 2 2:_ 5400 kW, and

_:: 5940 kW; and

b. For the remaining hours of the test loaded:

Unit 1 2:_ 2500 kW, and Unit 2 2:_ 4860 kW; and

c. Achieves steady state voltage 2:_ 4084 V and_:: 4400 V; and frequency 2::. 59.5 Hz and_:: 60.5 Hz.

Prairie Island Unit 1 -Amendment No. 227 Units 1 and 2 3.8.1-8 Unit 2 -Amendment No. 215

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3. 8.1.10 ----------------------------NOTES--------------------------

1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.

3. 12 Battery Charger not required to be energized in SR 3. 8.1.10( c) until completion of this SR during Unit 1 2011 refueling outage.*

Verify on an actual or simulated loss of offsite power In accordance with signal in conjunction with an actual or simulated the Surveillance safety injection actuation signal: Frequency Control Program

a. De-energization of emergency buses;

b. Load shedding from emergency buses; and

c. DG auto-starts from standby condition and energizes emergency loads in :S 60 seconds.

SR 3 .8.1.11 ----------------------------NOTE----------------------------

All DG starts may be preceded by an engine prelube period.

Verify on an actual or simulated loss of offsite power In accordance with signal that the DG auto-starts from standby condition. the Surveillance Frequency Control Program

A modification will be installed during or prior to the Unit 1 2011 refueling outage to assure the 12 Battery Charger is automatically powered from its normal bus within 60 seconds. Compliance with this SR will be demonstrated after implementation of the modification.

Prairie Island Unit 1 -Amendment No. 227 Units 1 and 2 3.8.1-9 Unit 2 -Amendment No. 215

Distribution Systems-Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems-Operating LCO 3.8.9 Train A and Train B safeguards AC and DC, and Reactor Protection Instrument AC electrical power distribution subsystems shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more safeguards -----------------NOTE----------------

AC electrical power Enter applicable Conditions and distribution subsystems Required Actions of LCO 3.8.4, inoperable. "DC Sources - Operating," for DC trains made inoperable by inoperable power distribution subsystems.

A.I Restore safeguards AC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power distribution subsystems to OPERABLE status.

B. One or more safeguards B.1 Restore safeguards DC 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months DC electrical power electrical power distribution subsystems distribution subsystems to inoperable. OPERABLE status.

Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 3.8.9-1 Unit 2 -Amendment No. 215

Distribution Systems-Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One Reactor Protection C.1 Restore Reactor Protection 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Instrument AC panel Instrument AC panel to inoperable. OPERABLE status.

D. Required Action and D.l 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 D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Two trains with E.1 Enter LCO 3.0.3. Immediately inoperable distribution subsystems that result in a loss of safety function.

OR Two or more Reactor Protection Instrument AC panels inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker and switch alignments and In accordance with voltage to safeguards AC, DC, and Reactor the Surveillance Protection Instrument AC electrical power Frequency Control distribution subsystems. Program Prairie Island Unit 1 - Amendment No. 227 Units 1 and 2 3.8.9-2 Unit 2-Amendment No. 215

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 227 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-42 AND AMENDMENT NO. 215 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 June 26, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18177A450), Northern States Power Company, a Minnesota Corporation (the licensee), requested changes to the technical specifications (TSs) for Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP).

The proposed changes would revise TS 1.3, "Completion Times" Example 1.3-3, TS 3.6.5, "Containment Spray and Cooling Systems," TS 3.7.5, "Auxiliary Feedwater (AFW) System," TS 3.7.8, "Cooling Water (CL) System," TS 3.8.1, "AC Sources - Operating," and TS 3.8.9, "Distribution Systems - Operating" by eliminating the second completion time in accordance with Technical Specifications Task Fort:e (TSTF)-439, Revision 2, "Eliminate Second -

Completion Times Limiting Time from Discovery of Failure to Meet an LCO [limiting condition for operation]."

2.0 REGULATORY EVALUATION

2. 1 System Description 2.1.1 Completion Times The completion time (CT) is the amount of time allowed for completing a required action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an action condition unless otherwise specified, provided the unit is in a mode or specified condition stated in the applicability of the LCO. Required actions must be completed prior to the expiration of the specified CT. An action condition remains in effect and the required actions apply until the condition no longer exists or the unit is not within the LCO applicability.

Enclosure 3

The description section of the licensee's TS 1.3, CT, states that once a condition has been entered, subsequent trains, subsystems, components or variables expressed in the condition, discovered to be inoperable or not within limits, will not result in separate entry into the condition, unless specifically stated. The required actions of the condition continue to apply to each additional failure, with CTs based on initial entry into the condition .

Additional secondary CTs, such as limits on the period of time from discovery of the failure to meet the LCOs discussed above, were specified to prevent repeated entry and exit from alternating TS required actions.

2.1.2 Containment Spray and Cooling System The containment spray and containment cooling systems provide containment atmosphere cooling to limit post-accident pressure and temperature in containment to less than the design values. Reduction of containment pressure and the iodine removal capability of the spray reduces the release of fission product radioactivity from containment to the environment, in the event of a design basis accident (DBA), to within limits. PINGP's TS LCO 3.6.5, "Containment Spray and Cooling Systems," required actions A.1 , C.1 , and D.2, have a second CT of 10 days from discovery of failure to meet the LCO.

2.1.3 Auxiliary Feedwater System The AFW system automatically supplies feedwater to the steam generators to remove decay heat from the reactor coolant system upon the loss of normal feedwater supply. PINGP's TS LCO 3.7.5, "Auxiliary Feedwater (AFW) System, " required actions A.1 and B.1, have a second CT of 1O days from discovery of failure to meet the LCO.

2.1.4 Cooling Water System The CL system is a shared system common to both units. The CL system provides a heat sink for the removal of process and operating heat from safety-related components during a DBA or transient. During normal operation, and a normal shutdown, the CL system also provides this function for various safety-related and nonsafety-related components. The safety-related function is covered by PINGP's TS LCO 3.7.8. TS LCO 3.7.8, "CL System ," required actions A.1 anctB.3: have a secorid CT of 1O days from discovery of failu re to meet the [CO. Required action D.1 has a second CT of 9 days from discovery of failure to meet the LCO.

2.1 .5 AC Sources - Operating The unit 4 kV (kilovolt) safeguards distribution system AC (alternating current) sources consist of the offsite power sources and the onsite standby power sources (Train A and Train B diesel generators (DGs)). PINGP's TS LCO 3.8.1, "AC Sources - Operating ," required actions A.2 and B.4, have a second CT of 21 days from discovery of failure to meet the LCO.

2.1.6 Distribution Systems - Operating The onsite safeguards AC and DC electrical power distribution systems are divided by train into two redundant and independent electrical power distribution subsystems. PINGP's TS LCO 3.8.9, "Distribution Systems - Operating," required actions A.1, B.1, and C.1, have a second CT of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet the LCO.

2.2 Proposed TS Changes The licensee proposed to delete the following statement from PINGP's TS 1.3:

Example 1.3-3 illustrates one use of this type of Completion Time.

The 10-day Completion Time specified for Condition A and 8 in Example 1.3-3 may not be extended.

In addition, in Example 1.3-3, the licensee proposed to delete the "AND 10 days from discovery of failure to meet the LCO" from the CT of Condition A and Condition 8.

Also, the licensee proposed to delete the following statement from PING P's TS 1.3:

The Completion Times of Conditions A and 8 are modified by a logical connector, with a separate 10-day Completion measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, 8 and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock." In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.

The licensee proposed to replace the paragraph above with the following statement:

It is possible to alternate between Conditions A, 8, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall eni ure-that the Completion Times for those Conditions are'"hot 1nappropriately extended.

The licensee's proposed change also deletes the second CT associated with the following TS LCOs required actions:

TS 3.6.5, "Containment Spray and Cooling Systems," required actions A.1, C.1, and 0.2

TS 3.7.5, "Auxiliary Feedwater (AFW) System," required actions A.1 and 8 .1

TS 3.7.8, "Cooling Water (CL) System," required actions A.1, 8.3, and 0.1

TS 3.8.1, "AC Sources-Operating," required actions A.2 and B.4

TS 3.8.9, "Distribution* Systems-Operating," required actions A.1 , B.1, and C.1

2.3 Regulatory Requirements and Guidance Documents The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the proposed changes to eliminate TS second CTs against the criteria in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36 and the precedent established in NUREG-1431, "Standard Technical Specifications [STS], Westinghouse Plants," Revision 4. Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TS as part of the license.

These TS are derived from the plant safety analyses. In 10 CFR 50.36, the NRC established its regulatory requirements related to the content of the TS, which include: (1) safety limits, limiting safety systems settings and control settings, (2) LCOs, (3) surveillance requirements, (4) design features, and (5) administrative controls.

In NUREG-1431, a second CT (henceforth referred to as "second CT") was included in the STS for certain required actions to establish a limit on the maximum time allowed for any combination of conditions that would result in a single continuous failure to meet the LCO.

These CTs are joined by an "AND" logical connector to the condition-specific CT and state "X days from discovery of failure to meet the LCO" (where "X" varies by specification). The intent of the second CT was to preclude entry into and out of the actions for an indefinite period of time without meeting the LCO. The second CT provides a limit on the amount of time the LCO would not be met for various combinations of conditions. TSTF-439, Revision 2, deletes these second CTs from the affected STS required actions.

In regulation 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" and specifically, 10 CFR 50.65(a}(1 ), requires each licensee to monitor the performance or condition of structures, systems, and components (SSCs) against licensee-established goals in a manner sufficient to provide reasonable assurance that the SSCs are capable of fulfilling their intended functions. These goals shall be established commensurate with safety and, where practical, take into account industrywide operating experience. When the performance or condition of a SSC does not meet established goals, appropriate corrective action shall be taken. The effectiveness of these performance and condition monitoring activities, and associated goals and preventive maintenance activities, are evaluated at least every refueling cycle, not to exceed 24 months, per 10 CFR 50.65(a)(3). The goals shall be established "frommensurate wifh safety and, where practical, take into account industry-wide operating experience.

By letter dated June 20, 2005 (ADAMS Accession No. ML051860296), the TSTF submitted a proposed change, TSTF-439, Revision 2, to the improved STS. The proposed TSTF- 439, Revision 2, was approved by the NRC in a letter dated January 11, 2006 (ADAMS Accession No. ML060120272).

3.0 TECHNICAL EVALUATION

The license amendment request (LAR) stated the following regarding the 10 CFR 50.65, referred to as the Maintenance Rule (MR):

Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. Risk assessments at PINGP are conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the

Effectiveness of Maintenance at Nuclear Power Plants". Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to:

plan and conduct other activities in a manner that controls overall risk,

increase risk awareness by shift and management personnel,

reduce the duration of the condition,

minimize the magnitude of risk increases through the establishment of backup success paths or compensatory measures,

and determine that the proposed maintenance is acceptable.

The comprehensive program provides much greater assurance of safe plant operation than the second Completion Times in the TS.

In addition, the LAR stated the following regarding performance indicators:

NEI [Nuclear Energy Institute] 99-02, "Regulatory Assessment Performance Indicator Guideline", describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (ROP). The NRC noted endorsement of NEI 99-02 in RIS 2001 -11, "Voluntary Submission of Performance Indicator Data". NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone. NEI 99-02 specifically addresses the emergency AC power systems, the auxiliary feedwater system, and the cooling water support system. Extended unavailability due to multiple entries into the ACTIONS would affect the NRC's evaluation of the licensee's performance under the ROP.

The LAR state2_ th~ ~ollowing reg_arding administrative controls:

In addition to these programs, a requirement is added to Section 1.3 of the TS to require administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls should consider plant risk and shall limit the maximum contiguous time of failing to meet the LCO. This TS requirement, when considered with the regulatory processes discussed above, provides an equivalent level of plant safety without the unnecessary complication of the TS by second Completion Times on some Specifications.

Prior to the promulgation of 10 CFR 50.65, TSs were the primary requirements governing operations, including what equipment must normally be in service, how long equipment can be out of service, compensatory actions, and surveillance testing to demonstrate equipment readiness. The goal of TSs is to provide adequate assurance of the availability and reliability of equipment needed to prevent, and if necessary mitigate, accidents and transients. The MR supports this same goal by requiring a comprehensive process for performance and condition monitoring activities. As required by 10 CFR 50.65, the licensee assesses and manages the

inoperable equipment; however, the rule also considers all inoperable risk-significant equipment. Under the TSs, the CT for one system within an LCO is not generally affected by inoperable equipment in another LCO. However, the second CT influenced the CT for one system based on the condition of another system, but only if the two systems were required by the same LCO. Plant-specific MR programs implement risk-based configuration management programs that augment the deterministic CTs in the TSs. The performance and condition monitoring activities required by 10 CFR 50.65 identify poor maintenance practices that would result from multiple entries into the actions of the TSs which would contribute to unacceptable unavailability of these SSCs.

The NRC staff finds the proposed changes to PINGP's TS 1.3 acceptable because administrative control requirements were added in Example 1.3-3 of PINGP's TSs to limit the maximum time allowed for any combination of conditions that result in a single contiguous occurrence of failing to meet the LCO and ensuring CTs are not inappropriately extended. In addition, the licensee's MR program requires the licensee to monitor the performance or conditions of SSCs in a manner sufficient to provide reasonable assurance that SSCs can fulfill their specified safety functions and thus prevent indefinite operation without restoration of the systems.

The LAR proposed change deletes the second CT associated with the following TS LCOs required actions: TS 3.6.5, A.1, C.1 , and D.2; TS 3.7.5, A.1 and 8.1; TS 3.7.8, A.1, 8.3, and D.1; TS 3.8.1, A.2 and 8.4; and, TS 3.8.9, A.1, 8.1, and C.1. These additional secondary CTs were specified for these instances to prevent repeated entry and exit from alternating TS required actions. Administrative controls will replace second CTs as described in the LAR. The NRC staff finds the proposed deletion of second CTs listed above acceptable because multiple, continuous entries into TS conditions, without meeting the LCO, will be adequately controlled by: (1) the licensee's administrative controls, (2) the configuration risk management programs as implemented to meet the requirements of the MR to assess and manage risk and performance indicators, and (3) the requirements of Section 1.3 of the TS, "Completion Times."

In addition, the NRC staff finds the MR provides adequate assurance against inappropriate use of combinations of TS conditions that result in a single contiguous occurrence of failing to meet the LCO. Accordingly, consistent with TSTF-439, Revision 2, the NRC staff finds the proposed changes to PINGP TSs to be acceptable.

4.0 STATE Cb NSULTATION -

In accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendments on May 8, 2019. 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 or change the surveillance requirements. The 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 (83 FR 40351 ). 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: Caroline E. Tilton, NRR Date of issuance: June 6 , 2 o1 9

ML19128A133

memo dated ** via e-mail OFFICE DORL/LPL3/PM DORL/LPL3/LA DSS/STSB/BC NAME RKuntz SRohrer VCusomano PSnyder* for DATE 5/9/19 . 5 /9/19 4/11/19 OFFICE OGC DORL/LPL3/BC/A DORL/LPL3/PM AGhosh** NLO NAME LRegner RKuntz w/comments DATE 5/23/19 6/5/19 6/6/19

v t e Letter Sequence Approval
EPID:L-2018-LLA-0178, TSTF-439 (Approved, Closed)
Initiation Request Acceptance Supplement Administration Questions Answers Results Approval Other:
MONTHYEAR2018-07-20 [Table View]

ML19128A133

Text

SUBJECT:

Dear Mr. Sharp:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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