ML19268A042
| ML19268A042 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 09/26/2019 |
| From: | Xcel Energy |
| To: | Office of Nuclear Reactor Regulation |
| Kuntz R | |
| References | |
| Download: ML19268A042 (17) | |
Text
Prairie Island Nuclear Generating Plant Pre-Application Meeting License Amendment Request Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b September 26, 2019
- Describe future license amendment request
- Scope of the request
- Variations from TSTF-505
- Schedule Meeting Agenda 2
Scope of the Request 3
- Based on TSTF-505, Revision 2, and NEI 06-09, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines
- Applicable in Modes 1 and 2
- No loss of function consistent with template
- New TS 5.5 program called the Risk Informed Completion Time Program
- Precedent approved and under review considered
- Differences in Condition/RA wording
- PINGP TS are based on Revision 1 of NUREG-1431, Standard Technical Specifications Westinghouse Plants
- Administrative changes
- TS formatting changes
- Re-typed/clean TS pages not included Variations 4
- Condition not in TSTF-505
- TS 3.3.1.L.1 - for one or both channel(s) inoperable on one bus, place channel(s) in trip
- Bus undervoltage and underfrequency reactor trip function
- 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> CT front stop
- Function is modeled in PRA
- RICT added to RA consistent with TSTF-505 changes TS 3.3.1 - Reactor Trip System (RTS)
Instrumentation 5
- Condition not in TSTF-505
- TS 3.3.2.I.1 - for one or both channel(s) inoperable on one bus, place channel(s) in trip
- Bus undervoltage AFW start function
- 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> CT front stop
- Function is modeled in PRA
- RICT added to RA consistent with TSTF-505 changes TS 3.3.2 - Engineered Safety Feature System (ESFAS) Instrumentation 6
- PINGP has two trains of Containment Cooling and both trains are required to be operable by TS LCO 3.6.5.
- Conditions not in TSTF-505
- TS 3.6.5.C.1 - one or both containment cooling FCU(s) in one train inoperable, restore containment cooling FCU(s) to OPERABLE status
- TS 3.6.5.D.2 - one containment cooling FCU in each train inoperable, restore all FCUs to OPERABLE status
- 7 day CT front stops
- FCUs are not modeled in PRA
- Analysis has shown FCUs are not required to prevent a Large Early Release
- RICT added to RAs consistent with TSTF-505 changes TS 3.6.5 - Containment Spray and Cooling Systems 7
- TS 3.7.1 LCO requires PINGP to have five MSSVs per steam generator operable or the unit is required to shut down
- Condition not in TSTF-505
- TS 3.7.1.A.1 - for one MSSV inoperable, restore inoperable MSSV to OPERABLE status
- 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CT front stop
- RICT added to RAs consistent with TSTF-505 changes TS 3.7.1 - Main Steam Safety Valves (MSSVs) 8
- CL is a shared system between PINGP units. TS 3.7.8 LCO requires PINGP to have two CL trains OPERABLE or both units are required to shut down
- Conditions not in TSTF-505
- TS 3.7.8.A.1 - for no safeguards CL pumps OPERABLE for one train, restore one safeguards CL pump to OPERABLE status
- Remove NOTE 3 which limits the Condition existing for greater than 7 days in any consecutive 30 day period
- 7 day CT front stop
- TS 3.7.8.B.3 - for one CL supply header inoperable, restore CL supply header to OPERABLE status
- 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT front stop
- CL System modeled in PRA
- RICT added to RAs consistent with TSTF-505 changes TS 3.7.8 - Cooling Water (CL) System 9
- Internal Events including Internal Flooding
- RG 1.200 peer reviewed
- Appendix X to NEI 05-04 finding closure review complete
- One open F&O related to Abeyance RCP seal
- Fire
- RG 1.200 peer reviewed
- Appendix X to NEI 05-04 finding closure review complete
- No open Fire PRA F&Os
- Fire PRA reflects future state of the as-built/as-operated plant following NFPA 805 modifications
- RICT Program will not be used until modifications are complete on both units and PRA models updated PRA Technical Adequacy 10
- Seismic
- NRC staff assessment of PINGP seismic (ML15341A162):
- Seismic hazard bounded by existing design-basis SSE,
- Therefore, seismic risk evaluation not merited
- Seismic penalty will be applied to all RICTs based on current seismic hazard for CDF & LERF
- Other External Hazards
- Bounding analysis concludes that other external hazards can be screened out from calculations in the RICT Program PRA Technical Adequacy (continued) 11
- A Real-Time Risk Model similar to existing Maintenance Rule a(4)
Configuration Risk Management Program
- Uses EPRI Phoenix Risk Analysis Software
- Incorporates RICT/RMAT calculation features
- Incorporates seismic penalty factor RICT Program Real-Time Risk Model 12
Impact of Ongoing NRC/Industry Risk-Informed Activities 13
- Development of an alternative to the administrative TS addressing use of newly developed PRA methods
- Intend to supplement PINGP application if becomes available while PINGP application is under review
- Projected submission in November 2019 with a requested issuance of December 2020
- Request an implementation period of 180 days Schedule 14
- CDF - Core Damage Frequency
- CT - Completion Time
- CRMP - Configuration Risk Management Program
- F&O - Facts and Observations
- FCU - Fan Coil Unit
- LAR - License Amendment Request
- LCO - Limiting Condition of Operation
- NEI - Nuclear Energy Institute
- PINGP - Prairie Island Nuclear Generating Plant
- RA - Required Action
- RCP - Reactor Coolant Pump
- RFO - Refueling Outage
- RICT - Risk Informed Completion Time
- RMA - Risk Management
- RMAT - Risk Management Action Time
- SE - Safety Evaluation
- TS - Technical Specification