ML20085C997
| ML20085C997 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/04/1991 |
| From: | Parker T NORTHERN STATES POWER CO. |
| To: | |
| Shared Package | |
| ML20085C994 | List: |
| References | |
| RTR-NUREG-0612, RTR-NUREG-612 NUDOCS 9110150180 | |
| Download: ML20085C997 (11) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHERN STATES POVER COMPANY PRAIRIE IS!AND NUCLEAR GENERATING PIANT DOCKET No. 50 282 50 306 REQUEST FOR AMENDMENT as OPERATING LICENSES DPR 42 & DPR 60 LICENSE AMENDMENT REQUEST DATED October 4, 1991 Northern States Power Company, a Minnesota corporation, requests authorization for changes to Appendix A of the Prairie Island Operating License as shown on the attachmenis labeled Exhibits A, B, and C, Exhibit A describes the proposed changes, reasons for the changes, and a significant hazards evaluation. Exhibits B and C are copies of the Prairie Island Technical Specifications incorporating the proposed changes.
This letter contains no restricted or other defense information.
R ;0MPANY NORTHERN SJ/t S j
/ /
B.b .homas
)fd MdParker _
Manager Nuclear Support Services b l-On this_ ' day of County, personally appeared &
as M Thom$[bef ore me aSupport notary public in and fo Parker, Manager Nuclear Services, and being first duly sworn acknowledged that he is authorized to execute this document on behalf of Northern States Power Company, that he knows the contents thereof, and that to the best of his knowledge, information, and belief the statements made in it are . . and that it is not interposed for delay, l
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HLhNIPIN CDUNTY My Commruca Lt;sts Sept 24, lk) a w :::::::::::: :::::::::::::::: = n 9110150100 911004 PDR ADOCK 05000202 P FDR
- 4.
- Exhibit A Prairie Island Nuclear Generating Plant
- License Amendment Request Dated October 4,1991 Evaluation of Proposed Changes to the Technical Specifications Appendix A of Operating License DPR 42 and DPR 60 Pursuant to 10 CFR Part 50, beetions 50.59 and 50.90. -the holders of Operating Licenses DPR 42 and DPR 60 hereby propose the following changes to Appendix A.
Technical Specifications:
1, AUXILIARY BUILDING CRANE UPGRADE BACKGROUND AND JUSTIFICATION FOR CHANCES In an application dated August 31, 1990, Northern States Power Company applied for a license to construct and operate a Dry Cask Independent Spent Fuel Storage Installation to be located ou the Prairie Island Site. The license was requested for the storage of spent fuel from the Prairie Island Nuclear Generating Plant in Transnuclear TN 40 storage casks.
Ilowever; because of the height of the TN-40 storage casks, it is not practical to'use an impact limiter or crash pad, as prescribed by Technical Specification 3,8.B.1.b,2, during the handling and loading of those casks, Therefore, Northern States Power has. contracted with Ederer Incorporated to modify the auxiliary building crane in accordance with the single-failure-proof criteria of Section 5,1,6 and Appendix C of NUREG 0612. This modification consists of replacement of the existing bridge trolley with an Ederer-designed-trolley and associated hoists. The upgrade of the auxiliary building crane to a single-failure proof design is scheduled to be completed in 1992.
f This. upgrade to the auxiliary building crane is being made to provide a handling system for handling heavy loads in the spent fuel pool area that satisfies the single failure proof guidelines of Section 5.1.6 of NUREG-0612, and thus eliminate tr. ed to analyze the effects of drops of heavy loads per the evaluation ca itsr.a of-Section 5.1 of NUREG 0612, Because the installation of a single t'al'ure proof handling system eliminates the need for.a cask drop analysis, i s Technical Specification restrictions designed to mitigate-the effects of a cask drop are no longer required.
The Technical Specification changes described below eliminate the cask handling restrictions imposed by License Amendments 74 arn! 67, and replace them with requirements for the use of a single failure-proof handling system in the handling of spent fuel casks. The changes include the addition of requirements in Section 5,6 requiring the use of a single-failure-proof handling system for handling spent fuel casks and now surveillance requirements on lif ting devices to be used for handling heavy loads by the auxiliary building crane over safe shutdown equipment or spent fuel in the spent fuel pool.
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, t tahlbit A Page 2 of 10 SINGLE PAILURE PROOP llANDLINC SYSTEM DESIGj Section 5.1.1 of NUREO.0612 provides seven general guidelines for handling heavy loads that ceuld be brought in proximity to or over safe shutdown equipment or irradiated fuel in the spent fuel pool area. The seven guidelines are intended to assure reliable operation of the handling systems, and to the extent practical, minimize the movement of heavy loads over irradiated fuel. Controls satisfying the guidelines of Section 5.1.1 of NUREG-0612 were implemented at prairie Island as described in our original. response to NUREC 0612. Those controls remai in place.
Section 5.1.6 of NUREG 0612 imposes additional guidelines, - beyond the seven general Buidelines of Section 5. L 1, when the alternative of upgrading the handling system to be single failure ptoof is chosen. Those !
additional guidelines are addressed below: .
(1) Liftine Device.gl (a) Special Liftine Devices Except as noted below, all special lif ting devices to be utilized with the auxiliary building crane in the handling of heavy loads over safe shutdcwn equipment or spen'. fuel in the spent fuel pool will be designed to meet the requirements of ANSI N14.01978, "St andard For Special Lif ting Devices for Shipping Containers Weighing 10,000 Pounds or More For Nucitar Materials", as
- outlined in guideline (1)(a) of Section 5.1.6 of NUREG 0612. A description of the special liiting de vices to % utilized in handling the TN 40 spent fuel storage casks and an evaluation of how their design meets the requirements of ANSI N14.6 and guideline (1)(a) of Section 5.1.6 will be provided for NRC Staff review when complete.
Due t.o onsite crane limitations, we will be unable to comply with the 150% special lift device load test requireacnts of ANSI ;.14.6 1978. Any special lifting device load testing performed per ANSI N14.6 will be performed at the 125% level.
(b) Other Lif tlym Deviqcs - Administrative controls will be established which will assure that lif ting devices not specifically designed and that are to be used with the auxiliary building crane for handling of heavy loads over safe shutdown equipment or spent fuel in the spent fual pool will meet the requirements of guideline (1)(h) of Section 5.1.6 of NUREG 0612.
(2) New Cranes:
As sected above, Northern States Power has contracted with Ederer incorporated to upgrade the Prairie Island auxiliary building crano to a single failure proof design. The main hoist of the upgraded auxiliary butiding crane will be a single-failure-proof design based -
on a maximum critical load of 125 tons which will comply with the single-failure proof criteria of Section 5.1.6 and Appendix C of NUREC 0612 to the extent possible. Any exceptions to the requirement.s of Section 5.1 6 and Appendix C of NUREC 0612 that may >
be necessary due to the constraints of upgrading an existing crane, '
will be described and justified as part of the plant specific design inforration which will be provided for NRC Staff review when complete.
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fahlbit A Pope 3 of 10 Idcrer Incorporated has published Revision 3, Amendment 3, to Generic l Licensing Topical Report EDR 1(P).A, "fderer Nuclear Safety Related Extra Safety and Monitoring (X SAM) Cranes", dated October 8, 1982, i The report describes the design and testing of the single failure proof features which are included in Ederer's X SAM cranes intended for handling spent fuel casks and other safety related loads in a nuclear power plant. NRC Staff approval of the report was documented in a :
Safety Evaluation transmitted by NRC letter dated August 26, 1983. ;
The Appendix B and Appendix C Supplements to Topical Report EDR 1 will be provided for NRC Staff review when complete. The Appendix B supplement to Topical kepott EDR 1 will provide a summary of plant '
specific crane dar.a supplied by Ederer Incorporated for the Prairie Island auxiliary building crane. The Appendix-C supplement to Topical ,
Report EDR-1 will provide a summary of plant specific data supplied by I Northern States Power for the Prairio Island auxiliary building crane modifications. r i
A plant specific seismic analysis will be completed, which v?41 ;
demonstrate that the auxiliary building crano, as modified, '.11 retain the design load during a seismic event equal to a safe shutdown earthquake. The completed analysis will be available upon request. -
(3) Interfacinr_ Lift Points !
Administrative controls will be established which will assure that all interfacing lift points, such as lifting lugs or trunnions, for heavy :
loads to be hanoted by the auxiliary building crane over safe shutdown equipment or spent fuel in the spent fuel pool, will meet tha requirements of guideline (3)(a) or (3)(b) of Section 5.1.6 of COREG-0612, unless the effects of a drop of the particular load have been evaluated end shown-to-satisfy the evaluation criteria of Section 5.1 of NUREG 0612.
The TN 40 spent fuel storage cask lift point system is a non redundant system consisting of two trunnions welded to the cask body gamma shleiding. The TN 40 trunnions are. designed to meet the requirements of Et;SI 14.6-1986 and to not exceed the minimum ultimate strength of the trunnion material under vertical lift loadings of ten times the ;
maximum weight of a fully loaded cask, The TN 40 trunnions meet the requirements of guideline (3)(b) of Section 5.1.6 of NUREG 0612. The detailed design of the TN 40 trunnions is being evaluated as part of the review of the Prairie Island Independent Spent Fuel Storage ;
Installation license application.
FROPOSED TECHNICAL,,,fPECIFICATLQF CHANCES AND REASSNS FOR CHANGES
-A. Proposed Chanc_es to Technical Spfsification Section 3.8.B.1 Because heavy loads will be handled over the spent fuel pool by a sin &l e-failure-proof handling system, a cack drop in the spent fuel pool will no longer need to be considered. The Technical Specification restrictions contained in Section 3,8.B,1.b and 3.8.B.1.d will not be i
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[xhibit A Foge 4 of 10 necessary to prevent or mitigate the consequences of a cask drop accident. Therefore, Technical Specifica*1on Sectiono 3.8.B.1.b and 3.8.B.1.d and their associated bases are being deleted in their entirety.
A new paragraph is being incorporated into the bases for Section J.8 B which discusses the elimination of the Technical Specification restrictions related to cask handling and which states that spent fuel casks will be handled with a single-failure-proof handling system.
B. Et e rd Changes to Technical Specification Section 3.8.B As described above, all restrictions on crane operation are being climinated from Soction 3.8.B as a result of the upgrading of the auxiliary buildP g crane to a single-f ailure-proof design. Therefore, references to "es au3 operations" and " crane operations with loads o"er spent fuel (inside the spent fuel pool enclosure)" are being deleted from the heading to Section 3.8.B and from paragraphs 3.8.B.1 and 3.8,B.2.
C. Proposed New Technical Specification Section 4.19 The auxiliary building crane is being modified to conform with the single failure proof requirements of Section 5.1.6 of NUREG 0612, and will be designed to not allow a load drop as a result of any single failure. As the slings end special lifting devices are, by their uacure, an integral part of the locd bearing path, their surveillance is nGeessary to ensure against a load drop as a result of deficient rigging. Therefore, a new surveillance requirement, Section 4.19 and its associated bases, are being incorporated as shown in Exhibit B.
Tne new Section 4.19 will specify surveillance requirements for special lif ting devices and slings used in conjunction with the auxiliary building crane for handling heavy loads over safe shutdown equipment or spent fuel in the spent fuci pool.
D. Protiosed Changes to Technical Spettication Section 5.6 h
As discussed above, a cask drop accident in the spent fuel pool will no longer need to be considered following the upgrade of the auxiliary building crane to a single-failure proof design. Therefore, references to the spect fuel cask drop analysis and cask drop mitigation design features are being removed from Technical Specif -tion Section 5.6.
A new paragraph is being incorporated into Section 5.6.C which states that spent fuel casks will be handled by a single-failure-proof handling system and which briefly discusses the upgrade of the auxiliary building crane to a single-failure-proof design, l
tahibit A Pege 5 of 10 i
SLFETY EVALL%IlQtLMLDfJEElilRAIl0LOL.SIGhlf1CMLIMAEDLEONSIDERAT10NS The proposed changes to the Opeeng 1.icense n been evaluated to determine whether they constitute a significaw c ards consideration as required by 10 CFR Part 50, _cetion 50.91 using m e standards provided in Section 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase in the probabilitv or conseauences of an accident previous 1v evaluat ed.
The proposed amendment climinates Technical Specification restrictions on cask handling that are designed to prevent or mitigate the consequences of a cask drop accident. However, in place of these existing restrictions on cask handling, the probability of a cask drop in the spent fuel pool is being significantly reduced by the upgrade of the auxiliary building crane to a single-failure proof design in l accordance with the requirements of NUREG-0612.
linile the elimination of the Technical Specf.fic* tion restrictions on cask handling could have a significant offect <,n the consequences of a cask drop accident, the use of a single-failure-proof handling system will essentially eliminate the possibility of cask drop event and thus the consequences of a cask drop event are of little concern. This conclusion it rupported by the guidance in Section 5 of NUREG-0612 uhich r.pecifically allows the use of a single-failure proof handling system in place of the ability to withstand a load drop accident.
Therefore, the use of a single failure proof handling system for the handling of spent funi casks. and removal of the current Technical Specification restrictions on cask handling will not iavolve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibility of a new or different kind of accideat from any accident previously analyzed.
The proposed amendment eliminates Technical Specification restcietions on cask handling that are dealgned to prevent or mitigate the consequences of the previously analyzed cask drop accident. The upgrade of the auxiliary building crane to a single-failure-proof .
design and the handling of speat fuel casks with a single-failure-proof he.ndling system will essentially eliminate the possibility of the previously analyzed cask drop accident.
There are no new failure modes or mechanisms associated with the proposed changes. The single-failure-proof handling system to be used in cask handling will be in compliance with all applicable regulatory requirements and will provide a significantly more reliable system for handling heavy loads than the current auxiliary building crane can provide.
Therefore, no different type of accident is created. No additional safety analyses are necessary. The accident analys % presented in the Updated Safety Analysis Report remain bounding.
Exhibit A Page 6 cf 10
- 3. The proposed amendment will not involve a significant reduction in the margin of safety.
While the elimination of the Technical Specification restrictions on cask handling could have a significant effect on the consequences of a cask drop accident, the use of a single failure-proof handling system will essentially eliminate the possibility of cask drop event. This significant reduction in the probability of a cask drop event will resu S; an increase in the plant's margin of safety.
The use of a single failure proof handling system which meets the requirements of NUREG-0612 ensures that the probability of a load drop is sufficiently small such that the activity release from a fuel handling accident assumed in the safety analyses will not be affected.
The use of a single-failure-proof handling system for the handling of spent fuel casks and removal of the current Technictl Specification restrictions on cask handling will not result in a reduction in any Technical Specification margin of safety. This conclusion is supported by the guidance in Section 5 of NUREG-0612 which specifically allows the use of a single-failure proof handling systee in place of the ability to withstand a load drop accident.
Theretore, the proposed changas will not result in any reduction in the plant's margin of safety.
The Conrission 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 not directly equivalent to any of the NRC exampics published in the Federal Register. The closest example ic (vi), ch concerns changes which eithet may result in some increase to t5 , . bility or consequences of a previously-analyzed accident or may ret s se.e way a safety margin, but where the results of the change ;i, riy within all acceptable criteria with rerpect to the system .: component specified in the Standard Review Plan. The results of the proposed license amendment are c1carly within all acceptable criteria specified in the Standard Review Plan. The proposed amendment differs from example (vi) in that the addition of a single failure-proof crane will not result in an increase the probability or consequences of ac-idents er reduce the margin of safety.
The proposed changes have less pstential for creating a significant hazard than an amendment which would conform with example (vi) because, as stated above, they will not result in an increase the probability or contequences of accidents or reduce the margin of safety. Therefore, we have concluded that the proposed changes do not involve a significant hazards consideration.
d 4 iAhlblt A Fage 7 of 10 Q{VEONMENTAL i.SS?jijidffil Thiti license amembnent request does tiot chang,e cfiluent types or total effluent amounts nor dons it involvo an increase in power Icvel.
Therefore, this change will not result in any significant environmental impact.
Exhibit A Page 8 of 10
- 2. INDEPENDENT SPENT FUEL STORAGFa INSTALIATION RElATED CHANGES.
W'csGROUND AND JUSTIFICATIoE.JRPJ1ANGES As discussed above, Northern States Power Company has applied for a license to construct and operate a Dry Cask Independent Spent Fuel Storage Installation to be located on the Prairie Island Site, The license was requested for the storage of spent fuel from the Prairie Island Nuclear
< Generating Plant in Transnuclear TN-40 storage casks. Several changes to the Prairie Island Technical Specifications are required to accommodare the Prairie Island Independent Spent Fuel Storage Installation and the storage of fuel in spent fuel storage casks.
PROPOSED TECHNICAL SPECIFICATION CHANCES A"i REASONS FOR CHANGES A. Pronosed New Technical Specification 3.8.B.1.c The criticality analysis for the flooded Transnuclear TN-40 spant fuel storage cask assumes that the cask contains water borated to 1800 ppm.
The 1800 ppm will ensure that k,,, for the spent fuel cask, including statistical uncertainties, will be less than or equal to 0.95 for all postulated arrangements of fuel within the cask. New Specification 3.8.B.1.c and its associated bases are being incorporated to ensure that the spent fuel pool is maintained at 1800 ppm anytime a cask containing fuel is located in the spent fuei pool. This will ensure cask suberiticality during the loading process.
B. Proposed Changes to Technical Specification 3.8.Bml The current action statement for Specification 3.8.B.1 (Specification 3.8.B.2) does not provide an adequate response if the requirements of the new Specification 3.8.B.1.c cannot be met. It the spent fuel pool boron concentration is found to be less than 1800 ppm, with a cask containing fuel in the spent fuel pool, suspension of fuel handling operations is not an tdequate response. Action must be taken to increase the spent fuel pool boron concentration.
Action statement 3.d.B.2 has been revised to specify that if the conditions in 3.8.B.1 cannot be met, then actions must he initiated to re-establish compliance with the requirements of 3.8.B.1. In the case of the boron concentration found to be less than 1800 ppm, the action would be to increase the boron concentration above the limit.
[ C. Pronosed Channes to Technical Snecification Table TS.4.1-2B In order to ensure that the boron concentration limits of new Specification 3.8.B.1.c are met anytime a cask containing fuel is located in the spent fuel pool, the existing surveillance requirements for spent fuel pool boron in Table TS.4.1-2B have been revised. A new Note 7 has been incorporated into Table TS.4.1-2B (page 2 of 2). Note 7 specifies that the minimum boron concentration from Specification 3.8 B.1.b shall be verified by chemical analysis weekly while a spent fuel cask containing fuel is located in the spent fuel pool. A reference to Note 7 has been added to the spent fuel pool boron surveillance requirement in Table TS.4.1-2B (Item 13 on page 1 of 2).
4 4 tahlbit A PmDe 9 of 10 D. ProposesLQLepges to Technical Speciftf fttion Section 5.6. A A discussion of the bar.es for the 1800 ppm spent fuel pool boron requirements and the TN 40 spent fuel storage cask criticality analysis have been added to Section 5.6.A E. Proposed _Changej to Technical Specification Section 5.6.C The third paragraph of Section 5.6.C has been revir,ed, as shown in Exhibit B, to incorporate the option of storing of spent fuel in the Prairie Island Independent Spent Fuel Storage Installation.
F, Proposed Channe to Technical Sor.tifjrntion Section 5.6.D The term " shipping" cask has been revised to the more general term
" spent fuel" cask in Specification 5.6.D to accommodate the use of either shipping or storage casks in the spent fuel pool.
SAFETY EVALUATION AND DETERMINATION OF SIGNIFICANT llAZARDS CONSIDJlRATIONS 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 conitauences of an occident . previous 1v evalunted.
The Tectnical Specification changes proposed by this portion of the License Amendment Request are required to accommodate the Prairie Island Independent Spent Fuel Storage Installation and the storage of fuel in spent fuel storage casks.
Because the preposed changes are either administrative in nature or constitute additional restrictions not presently in the Technical Specifications, the proposed changes will not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously annivzed.
There are no new failure modes or mechanisms associated with the proposed changet.. The proposed changes do not involve any modification in the operational limits or physical design of the involved systems.
The change merely incorporates Technical Specification changes required to accommodate the Prairie Island Independent Spent Fuel Storage Installation and the storage of fuel in spent fuel storage casks.
The boron concentration limitations imposed by the proposed changes are consistent with the restrictions currently in the Technical Specifications to mitigate the consequences of a cask drop. Spent fuel pool boron concentration is normally maintained above the 1800 ppm limit. This new Technical Specification requirement will have no effect on plant operations.
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Echibit A Pige 100f 10 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. L 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
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marcin of safety. __
3ecause the proposed changes are either administrative in nature or
=
constitute additional restrictions not presently in the Technical- l Specifications, the proposed changes d not involve a reduction in any l Technical Specification margin of safety. l l The additional restrictions imposed by the new spent fuel pool boron concentration requirements will ensure that k , for the spent fuel j cask, including statistical uncertainties', wil,l be less than or equal l
- to 0.95 for all postulated arrangements of fuel within the cask.
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. Therefore, the proposed-changes will not result in any reduction in the l i plant's margin of safety, i The Commission has provided guidance concerning the application of the standards _in 10 CFR 50.92 for determining whether a significant hazards i 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 examples (1) or (ii), because they are= purely administrative changes or because they involve changes that constitute
'i . additional limitations, restrictione or controls not presently included in the Technical Specifications, 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 rmounts nor does it involve an increase in power level.
Therefore, this change will not result in-any significant environmental impact.