ML20057D308

Slides Potential License Amendment to Remove Note from LCO 3.4.12 and LCO 3.4.13

ML20057D308
Person / Time
Site:	Prairie Island
Issue date:	02/18/2020
From:	Robert Kuntz Nuclear Management Co
To:	Division of Operating Reactor Licensing
Kuntz R
References
Download: ML20057D308 (8)

Text

Prairie Island Amendment to Remove Note from LCO 3.4.12 and LCO 3.4.13 2.18.2020

Agenda

• Opening Remarks

• Background - LTOP LCO 3.4.12 and LCO 3.4.13 Note 1

• Proposed Changes

• Closing Remarks 2

Opening Remarks

• The purpose of this meeting is to discuss proposed License Amendment for Prairie Island Nuclear Generating Plant (PINGP) Units 1 and 2

• The LAR will clarify requirements for operating Safety Injection (SI) pumps for testing or other evolutions when in the Mode or Other Specified Condition of Applicability of LCO 3.4.12 or LCO 3.4.13

• The proposed change is intended to align the PINGP TS with the underlying LTOP analysis and eliminate redundancy 3

Background

• Note 1 of LCO 3.4.12 and LCO 3.4.13 reads:

Both safety injection (SI) pumps may be run for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> while conducting SI system testing provided there is a steam or gas bubble in the pressurizer, the reactor vessel head is on, and at least one isolation valve between the SI pump and the RCS is shut.

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Background (cont.)

• The precursor to the Note was introduced to the PINGP custom TS (CTS) with Amendments 38 and 32 in 1979 to provide for running both SI pumps for testing

• In the conversion to ITS, the Note was included to incorporate the CTS provisions for SI testing

• After 2011 NSPM changed SI testing practice from running both trains concurrently to running one train at a time

• In 2019 NSPM implemented a STRIDE under the SFCP that changes SI testing frequency such that only one train is tested each refueling outage 5

Background (cont.)

• Specifically, Note 1 includes three constraints in order to operate two SI pumps for testing or other evolutions:

• Pressurizer bubble - Intended to provide a surge volume to provide additional time to react to a postulated event. The associated analysis does not credit a pressurizer bubble

• Vessel head on - Redundant to modes of applicability. No protection against LTOP

• Isolation valve closed - redundant to the LCO requirement 6

Proposed Changes

• Eliminate Note 1 from LCO 3.4.12 and LCO 3.4.13 7