ML20070E266

Application for Amends to Licenses DPR-42 & DPR-60,revising Tech Specs 3.4.A to Incorporate Action Statement for Inoperability of One Steam Generator PORV & Revise Bases for Tech Spec Section 3.4

ML20070E266
Person / Time
Site:	Prairie Island
Issue date:	02/26/1991
From:	NORTHERN STATES POWER CO.
To:
Shared Package
ML20070E264	List: ML20070E261 ML20070E266 ML20070E269
References
NUDOCS 9103050312
Download: ML20070E266 (4)

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l Exhibit A l l

l Prairie Island Nuclear Generating Plant  !

License Amendment Request Dated February 26, 1991 Evaluation of Proposed Changes to the Technical Specifications Appendix A of Operating License DPR-42 and DPR 60 Pursuant to 10 CPR Part 50, Sections 50.59 and 50.90, the holders of Operating Licenses DPR-42 and DPR 60 heretv propose the following changes to Appendix A, Technical Specifications:

Proposed Changes Revise specification 3-4.A as shown on page TS,3,4 1 in Exhibit B to incorporate an action statement for the inoperability of one steam generator power operated relief valve, Revisc-the bases for Technical _ Specification Section 3.4 as shown on page B,3,4-1 in Exhibit B, Renson For Chances License amendments 91 and 84 to the Prairie Island facility operating licenses, approved October 27, 1989 incorporated a large upgrade into the Prairie Island Technical Specifications, Included in that upgrade was a completely rewritten Section 3,4, " Steam and Power Conversion System".

Prior to amendments 91 and 84, Sectiv.. 3.4 included the following specification for the steam generator safety and power operated relief valves:

"A. A reactor shall not be heated-above 350* F unless the following conditions are satisfied:  :

1, S a fe ty and Relief Vnives

a. Rated relief capacity of ten steam system safety valves is available for that reactor, except duriug testing.

b. - Both steam generator power operated relief valves for that reactor are operable."

Prior to amendments 91 and 84, Specification 3.4.B provided the following action statement for Specification 3,4,A 1:

"B. If, during startup operation or power operation, any of the conditions of Specification 3.4. A, except as noted below for 2.a, 2.b or 4 cannot be-met, startup operations shall be discontinued and if operability cannot be restored within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the affected reactor shall be placed in the cold shutdown condition using normal operating procedures."

9103050312 910226 PDR ADOCK 05000282 P PDR

Exhibit A Page 2 of 3 l

During the preparation of the rewrite of Section 3.4, which was approved by amendments 91 and 84, the action statements provided for the steam generator safety and power operated relief valves were unintentionally not included in the revision to Section 3.4. As a result, the current Prairie Island Technical Specification does not provide action statements for the steam generator safety and power operated relief valves beyond the standard one hour to prepare for shutdown and six hours to reach hot shutdown.

The proposed changes to Section 3.4, shown in Exhibit B, incorporate an action statement for the steam generator power operated relief valves back into the Prairie Island Technical Specifications. The proposed action statemeat allows one steam generator power operated relief valve to be inoperable for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

This is similar to the old statement described above, which allowed both steam generator power operated relief valves to be inoperable for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

No action statement for the steam generator safety relief valves is being proposed at this time. An appropriate action statement for the safety relief valves is under evaluation and will be submitted as part of a future license amendment request.

The bases for Technical Specification 3.4 are being revised to better describe the bases of the steam generator power operated relief valve specification and to provide guidance on the operability of the steam generator power operated relief valves.

Safety Evaluation and Determination of Sirnificant Hazards Considerations The proposed changes to the Operating License have been evaluated to determine whether they constitute a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92.

This analysis is provided below:

1. The proposed amendment will not involve a significant increase in the probability or consecuences of an accident previousiv evaluated.

The proposed amendment incorporates an action statement into Technical Specification Section 3.4 that is similar to the action statement previously included in Section 3.4 for the stcam generator power operated relief valves. However, the proposed action statement is more restrictive than the action statement that was inadvertently deleted. The allowed out of service time is the same as the previous action statement, but the proposed action statement only allows one steam generator power operated relief valve to be out of service for the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period. The previous action strtement implied that both steam generator power operated relief valves could be inoperaole for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Therefore, because the proposed action statement is more restrictive than the action statement previorsly included in the Technical Specifications, the proposed changes will no- involv' a significant increase in the probability or consequences of an accident previously evaluated.

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hhibit A Page 3 of 3

2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident oreviousiv nnalyzed.

There are no new failure modes or mechanisms associated with the proposed changes. The proposed changes do not involve any modification in the operational limits or physical design of the involved systems. The change merely it corporates an action statement for the steam generator power operated relief valves which is more restrictive than an action statement that was previously included in the Prairie Island Technical Specifications.

As discussed above, the proposed changes do not result in any significant change in the configuration of the plant, equipment design or equipment use nor do they require any change in the accident analysis methodology.

Therefore, no different type of accident is created. No safety analyses are affected. The_ accident analyses presented in the Updated Safety Analysis Report remain bounding.

3. The proposed amendment will not involve a significant reduction in the marr_in of safety.

The proposed ~ changes do not involve a reduction in any Technical Specification margin of safety. The change is incorporating an action statement-for the steam generator power operated relief valves which is more restrictive than an action statement that was previously included in the Prairie Island Technical Specifications. Therefore, the proposed changes will not result in any reduction in the plant's margin of safety.

The Commission has provided guidance concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists by providing certain examples of amendments that will likely be found to involve no significant hazards considerations. These examples'were published in the Federal Register on March 6, 1986.

The changes to the Prairie Island Technical Specifications proposed above are equivalent to_NRC example (vi), because they involve changes which either may result in some-increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margia, but where the'results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan.

Based on this guidance and the reasons-discussed above, we have concluded that the proposed changes do not involve a significant hazards consideration.

Environmental Assessment This license amendment request does not change effluent types or total effluent amounts nor does it involve an increase in power level. Therefore, this change will not result in any significant environmental impact.

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. Exhibit B Prairic Island Nuclear Generating Plant

' License Amendment Request Dated February 26, 1991 Proposed Changes Marked Up -

On Existing Technical Specification Pages '

Exhibit B consists of existing Technical Specification pages with the preposed changes written on those pages. The existing pages affected by this License Amradment Request are listed below:

TS.3.4 1 B.3.4 1 4

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