ML20086N368
| ML20086N368 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 07/17/1995 |
| From: | Wadley M NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20086N370 | List: |
| References | |
| RTR-NUREG-1431 GL-89-01, GL-89-1, NUDOCS 9507250185 | |
| Download: ML20086N368 (17) | |
Text
Northem States Power Company Prairie island Nuclear Gorerating Plant 1717 Wakonade Dr. East Welch, Minnesota 55089 July 17, 1995 10 CFR Part 50 Section 50.90 U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 License Amendment Request Dated July 17, 1995 Radiological Effluent Technical Specifications Conformance To Standard Technical Specifications and Generic Letter 89-01 Attached is a request for change to the Technical Specifications, Appendix A of the Operating Licenses, for the Prairie Island Nuclear Generating Plant.
This request is submitted in accordance with the provisions of 10 CFR Part 50, Section 50.90. The requested amendment will revise the Prairie Island Radiological Effluent Technical Specifications and other Sections relating to radiological controls to conform to NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Revision 1, and Generic Letter 89-01,
" Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program".
Exhibit A contains a description of the proposed changes, the reasons for requesting the changes, and the supporting safety evaluation and significant hazards determination. Exhibit B contains current Prairie" Island Technical Specification pages marked up to show the proposed changes. Exhibit C contains the revised Prairie Island Technical Specification pages. Exhibit D contains marked up pages of comparable Standard Technical Specification Administrative Controls pages.
Generic Letter 89-01 stipulates, "A complete and legible copy of the revised ODCM should be forwarded with the amendment request for NRC use as a reference." The Prairie Island ODCM is in the final stages of revision and will be forwarded to the NRC by separate cover letter in a few weeks. ;
250097 9507250185 950717 PDR ADOCK 05000282
)
l 1 P PDR s.
USNRC July 17, 1995 Page 2 To assure a smooth transition to the proposed Technical Specifications, we f request that the implementation period be extended to 120 days upon issuance of this proposed amendment.
l Please consider this License Amendment Request as a Cost Beneficial Licensing ;
Action (CBIA) item in that these amendments may reduce Northern States Power Company costs by more than $100,000 over the life of the plant and deal with- ]
changes which improve plant safety or have low safety significance. !
If you have any questions related to this License Amendment Request please contact myself or Dale Vincent at 612-388-6758 X4107. !
l s
M. D. Wadley Plant Manager Prairie Island Nuclear Generating Plant t c: Regional Administrator-III, NRC j NRR Project Manager, NRC Senior Resident Inspector, NRC State of Minnesota Attn: Kris Sanda J E Silberg k
Attachments:
Affidavit Exhibit A - Description of Proposed Changes, the Reasons for Requesting the Changes, and the supporting Safety Evaluation and Significant Hazards Determination Exhibit B - Technical Specification Marked Up Pages Exhibit C - Revised Technical Specification Pages Exhibit D - Standard Technical Specification Marked Up Pages
UNITED STATES NUCLEAR REGUIATORY COMMISSION NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PIANT DOCKET NO. 50-282 50-306 REQUEST FOR AMENDMENT TO OPERATING LICENSES DPR-42 & DPR-60 LICENSE AMENDMENT REQUEST DATED July 17, 1995 Northern States Power Company, a Minnesota corporation, requests authorization for changes to the Prairie Island Operating License, Appendix A as shown on the attachments labeled Exhibits A, B, C, and D. Exhibit A describes the proposed changes, reasons for the changes, and the supporting safety evaluation and significant hazards determination. Exhibit B contains current Prairie Island Technical Specification pages marked up to show the proposed changes. Exhibit C contains the revised Technical Specification pages. Exhibit D contains Standard Technical Specification pages marked up to show how the proposed amendments compare, i
This letter contains no restricted or other defense information.
NORTHERN STATES POWER COMPANY M h6(
By cu D-/
M. 'D. Wadley Plant Manager Prairie Island uclear Generating Plant Onthis/7 y of , /f before me a notary public in and for said County,personallyappearpM'D.Wadley,PlantManager,PrairieIsland Nuclear Generating Plant, 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 true and that i it is not interposed for delay.
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LICENSE AMENDMENT REQUEST DATED July 17, 1995 Radiological Effluent Technical Specifications Conformance To Standard Technical Specifications and Generic Letter 89-01 EXHIBIT A Description of the Proposed Changes, The Reasons for Requesting the Changes, and the Supporting Safety Evaluation /Significant Hazards Determination Pursuant to 10 CFR Part 50, Sections 50.59 and 50.90, the holders of Operating Licenses DPR-42 and DPR-60 hereby propose the following changes to the Facility Operating Licenses and Appendix A, Technical Specifications:
Backaround By letter dated January 31, 1989, the Nuclear Regulatory Commission issued Generic Letter 89-01, " Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of Radiological Effluent Technical Specifications to the Offsite Dose Calculation Manual (ODCM) or to the Process Control Program (PCP)", and encouraged licensees to propose changes to their Technical Specifications consistent with the guidance provided in the Generic Letter. Subsequently, NUREG-1431,
" Standard Technical Specifications, Westinghouse Plants", was issued in September 1992 and Revision 1 was issued in April 1995.
This document is the result of extensive technical meetings between the Nuclear Regulatory Commission and the industry. The Standard Technical Specifications provide more recent guidance on preferred Technical Specifications implementation of Radiological Effluent Technical Specifications. This license amendment request proposes changes consistent with the recommendations of Generic Letter 89-01 and the guidance contained in the Standard Technical Specifications, Revision 1. Differencca between these two documents are addressed in the Procosed Chances and Reasons for Chances as well as differences between the proposed amendments and the Standard Technical Specifications.
The proposed changes add new programmatic requirements governing radioactive effluents, radiological environmental monitoring, explosive gas monitoring, radioactive storage tank limitations and solid radioactive wastes to the Administrative Controls Section of the Technical Specifications. Existing Technical Page 1
l Specifications containing procedural details on radioactive wastes and associated reporting requirements are being relocated to the Offsite Dose Calculation Manual (ODCM) or the Process Control Program (PCP) as appropriate. In laddition, other changes are proposed to other portions of the Technical Specifications to accommodate the incorporation of Generic Letter 89-01 and the Standard Technical Specifications.
Implementation of this license amendment request will simplify the Radiological Effluent Technical Specifications, meet the regulatory requirements for radioactive effluents and radiological monitoring, and implement a line-item improvement to the Technical Specifications consistent with the Commission's Interim Policy Statement on Technical Specifications Improvements.
Proposed Chances and Reasons for Chances The proposed changes to Prairie Island Operating License Appendix A, Technical Specifications are described below, and the specific wording changes are shown in Exhibits B and C. Additionally, Exhibit D includes the appropriate sections from the Administrative Controls Section of the Standard Technical f Specifications, Revision 1, marked up to demonstrate how the proposed Prairie Island Section 6 Technical Specifications compare.
The proposed Prairie Island amendments generally differ from the Standard Technical Specifications, Revision 1, in that Prairie Island intends to continue to operate within the requirements of the "old" 10CFR20 requirements. Generic Letter and Standard g Technical Specification references to 10CFR20 have been modified to "10CFR20.1 - 20.601" or to a specific Part 20 paragraph to make it clear that the "old" 10CFR20 limitations are invoked. By letter dated June 30, 1993, from Thomas E. Murley, then Director, Office of Nuclear Reactor Regulation, to Thomas E. Tipton, the Nuclear Regulatory Commission responded to an industry inquiry on continued use of Appendix B to 10CFR20.1 - 20.601 after promulgation of a new Part 20. In that letter the Nuclear Regulatory Commission stated, After careful review of your position and other relevant ,
l factors, we have determined that is it acceptable to the staff for licensees to retain their existing level of effluent control as implementing the ALARA requirement after January 1, 1994, without submitting individual 1 requests for amending their technical specifications to I comply with new 10CFR20.1101(b). l I
" . we are preparing a Generic The letter goes on to say, . . '
Letter to provide model Technical Specification wording to ensure Page 2 4
conformance with the revised Part 20 requirements." and, "The model changes for Technical Specifications that will be in the Generic Letter are intended to eliminate possible confusion or improper implementation of revised Part 20 requirements."
As of the submittal date of this license amendment request, Northern States Power Company is not in receipt of a Generic Letter with guidance on implementation of the "new" Part 20. j Absent such guidance arm based on the Nuclear Regulatory I l Commission position set forth in the above quoted June 30, 1993 letter, this license amendment proposes to continue the radiological effluent controls program in accordance with the requirements of the "old" Part 20, that is, 10CFR20.1 - 20.601, and its Appendices until such time as a Generic Letter on this subject is issued and appropriate Technical Specification changes are submitted and approved.
Revision 1 of the Standard Technical Specifications has totally eliminated the records retention section. Thus, following this lead, the record retention requirements of Generic Letter 89-01 have not been implemented in this license amendment request.
Prairie Island maintains records in accordance with the requirements of ANSI N45.2.9 and the provisions included in each /
procedure, program and manual.
- 1. TABLE OF CONTENTS: Revise to reflect the deletion of Technical Specification Sections 3.9, 4.10, 4.11, 4.17, 5.5, Bases 3.9, 4.10, 4.11 4.17 and associated Tables and Figures.
Revise to include new Subsections and correct the spelling of
" Security" in Section 6.5.
Justification: Table of Contents revised to reflect the 4 requested relocation of the Radiological Effluent Technical Specifications and other proposed changes.
Correction of " Security" is an administrative change to correct a typographical error.
- 2. DEFINITIONS: Delete the definitions of Gaseous Radwaste Treatment System, Members of the Public, Offsite Dose Calculation Manual, Frocess Control Program, Purge-Purging, Site Boundary, Solidification, Unrestricted Area, Ventilation Exhaust Treatment System and Venting.
Justification: In conformance with Standard Technical Specifications the substance of the definition of Offsite Dose Calculation Manual has been relocated to Section 6.5.
The other definitions listed above, relating to Radiological Effluent Technical Specifications, have been relocated to the Offsite Dose Calculation Manual or Process Control Program in accordance with Generic Letter 89-01 and Standard Technical Specifications guidance.
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- 3. LIMITING CONDITIONS FOR OPERATION. Section 3.9. Radioactive Effluents: Delete Section 3.9 in its entirety.
Justification: In conformance with the guidance of Standard Technical Specifications the contents of Section 3.9 have been relocated to the Offsite Dose Calculation Manual or Process Control Program as appropriate with additional programmatic controls delineated in the Administrative Controls Section of the Technical Specifications, Section 6.5.
Generic Letter 89-01 defined some requirements which should be retained as requirements in the existing plant Technical Specifications: (1) the figures defining the boundary for effluents; (2) existing plant Technical Specifications for explosive gas monitoring instrumentation; and (3) limitations on the quantity of radioactivity in liquid and gaseous holdup or storage tanks.
These items have all been addressed in accordance with the more recent guidance provided by the Standard Technical Specifications. The figures defining the boundary for effluents have been relocated to the Offsite Dose /
Calculation Manual. Explosive gas monitoring requirements I and limitations on the quantity of radioactivity in liquid and gaseous holdup or storage tanks have been relocated to Section 6.5 in the form of programmatic controls for a new licensee controlled administrative program. The specific plant requirements have been incorporated into the Offsite Dose Calculation Manual.
- 4. EURVEILLANCE REOUIREMENTS. Section 4.10. Radiation Environmental Monitorina Proaram: Delete Section 4.10 in its entirety.
Justification: In conformance with Generic Letter 89-01 and Standard Technical Specifications the contents of Section 4.10 have been relocated to the Offsite Dose Calculation Manual or Process Control Program as appropriate. The radiation environmental monitoring activities will continue under the provisions of these licensee controlled documents. Also, proposed programmatic controls delineated in the Administrative controls Section ,
of the Technical Specifications, Section 6.5, require changes to the Offsite Dose Calculation Manual to be i submitted to the NRC for review, thus maintaining NRC input to the radiation environmental monitoring l activities. ;
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- 5. SURVEILLANCE REOUIREMENTS, Section 4.11, Radioactive Source Leakace Test: Delete Section 4.11 in its entirety.
Justification: In conformance with the guidance of Standard Technical Specifications this request for amendment proposes to relocate the requirements of this section to a licensee controlled program. If Prairie Island were to convert its Technical Specifications to the Standard Technical Specifications, the conversion process would require this section to be relocated to a licensee controlled program. The same controls and benefits can be realized through this license amendment request by establishing a Prairie Island program and deleting this section from Technical Specifications.
As a matter of law, radioactive source leakage testing shall comply with 10CFR30 regardless of whether specific requirements are delineated in the Technical Specifications. Furthermore, the requirements in 10CFR30 are sufficiently prescriptive that there is no need for further specification as part of the operating license.
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- 6. SURVEILLANCE REOUIREMENTS. Section 4.17. Radioactive Effluents Surveillance: Delete Section 4.17 in its entirety. i Justification: In conformance with Generic Letter 89-01 )
and the Standard Technical Specifications the contents of {
Section 4.17 have been relocated to the Offsite Dose Calculation Manual or Process Control Program as appropriate with additional programmatic controls delineated in the Administrative Controls Section of the Technical Specifications, Section 6.5.
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- 7. DESIGN FEATURES, Section 5.5, Radioactive Waste Systems: l Delete Section 5.5 in its entirety.
Justification:_ Section 5.5 is impacted by the changes proposed by this proposed amendment and also needs to be updated to reflect current plant radwaste management I practices. Since revision is required, this amendment, in conformance with Standard Technical Specifications, proposes to delete this section in its entirety. On September 20, 1994, the Nuclear Regulatory Commission ,
published in Federal Register Vol. 59, No. 181, proposed !
rules for defining the scope of Technical Specifications. l The proposed criteria for specifications apply to Limiting I Conditions for Operation. However the following discussion was included: ;
At the time the criteria were developed, the industry did not wish to address administrative controls and design features in the effort to Page 5
i improve the Standard Technical Specifications. H Later, however, both the industry and the Nuclear Regulatory Commission staff realized that it would !
be beneficial to include upgraded administrative controls and design features in the improved Standard Technical Specifications, and these were .
handled separately from the application of the !
criteria to the Limiting condition for Operations. ,
l From this discussion it is clear that the Nuclear Regulatory Commission and industry consciously framed the design features sections of the Standard Technical Specifications with the features that should be included and deleted those features which are no longer important ;
to Technical Specifications. Therefore, the Standard l Technical Specifications is appropriate guidance for i deletion of this section from the Prairie Island Technical l Specifications. If Prairie Island were to convert its Technical Specifications to the Standard Technical Specifications, the conversion program would require this section to be deleted. The same benefits can be realized through this license amendment request by deleting this section from the Prairie Island Technical Specifications at this time.
- 8. ADMINISTRATIVE CONTROLS. SECTION 6.5, PLANT OPERATING PROCEDURES. Subsections B. D, E and new Subsections H and I:
Revise wording for requirements as shown in Exhibits B and C.
lustification:
Subsection B Subsection B, Paragraph 1 applies to control of high l radiation areas in the plant. The requested changes in requirements will generally conform the Prairie Island Technical Specifications to the Standard Technical i Specifications and allow full use of recent advances in j radiation protection technology. Specifically, the Standard !
Technical Specification requirements allow electronic J personnel dosimetry features as sufficient protection for ,
personnel in high radiation areas. j l
Substantive changes from the Standard Technical Specifications include (Refer to Exhibit D pages 5.0-24 and .
i 25):
6.5.B.1.a.(3) The radiation protection manager shall define the frequency of radiation surveillance for these activities, j the option of relying upon an RWP has been deleted. This is j more restrictive than the Standard Technical Specifications and thus should be acceptable.
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6.5.B.1.a(4) The option of employing direct or remote continuous surveillance (electronic surveillance) was deleted from paragraph 6.5.B.1.b and inserted into paragraph 6.5.B.1.a as item (4). This paragraph has also been broadened to explicitly allow use of radiation monitoring devices that continuously transmit dose rate and cumulative dose to a remote receiver. Relocation af this paragraph allows use of these technologies in the lower intensity radiation areas as well as the higher intensity radiation areas. Broader use of these technologies enable Prairie Island to reduce occupational radiation exposure.
6.5.B.1.b The position title has been changed to " Shift Supervisor" to be consistent with Prairie Island position titles.
Subsection D In conformance with the Standard Technical Specifications, Revision 1, Subsection D has been deleted. The Process Control Program will continue to be maintained under the existing Prairie Island program. This program ensures compliance with 10CFR20, 10CFR61 and 10CFR71 which regulate the processing and packaging of solid radioactive wastes. Since the Process Control Program compliance is already mandated by existing regulations, it is acceptable to relocate this program to plant procedures under licensee control where it will be available onsite for inspection and audit by the NRC.
Subsection E In conformance with Generic Letter 89-01 and the Standard Technical Specifications, Subsection E has been revised to include the new programmatic controls associated with relocation of the Radiological Effluent Technical Specification Limiting Conditions for Operation and Surveillance Requirements from Technical Specifications to the Offsite Dose Calculation Manual.
Generic Letter 89-01 also specifies requirements for retention of records associated with changes made to the Offsite Dose Calculation Manual and Process Control Program, however the more recent guidance of Standard Technical 4 Specifications, Revision 1, does not include specifications l for any record retention. Consistent with this recent l guidance this proposed amendment does not include specifications for retention of Offsite dose Calculation Manual and Process Control Program records. This is justified on the basis that NSP is committed to ANSI N45.2.9-1974, Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants, and these r
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s documents specify their own record retention requirements which are subject to inspection and audit by the NRC.
Furthermore, if Prairie Island were to convert Technical Specifications Chapter 6 to conform to the Standard Technical Specifications, the section on records retention would likely be removed since record retention is not an appropriate subject for Technical Specifications.
Substantive departures from Standard Technical Specifications for this section are as follows (Refer to Exhibit D pages 5.0-7 and 5.0-8):
6.5.E.1.b. Reference is made to 10CFR20.106 which is consistent with the general intent to continue to operate 3 to the "old" Part 20 as discussed above. l 1
6.5.E.2. The proposed wording is consistent with existing Prairie Island Technical Specification Requirements and plant practice.
6.5.E.3 Delete " Release" to be consistent with the Prairie Island report title. The requirements for marking changes on each page have been revised to more clearly reflect Prairie Island standard practice.
Subsection H Subsection H, Radiological Effluent Controls Program, is a new subsection which generally follows the guidance f provided by Generic Letter 89-01 and Standard Technical Specifications.
Substantive departures from Standard Technical Specifications !
for this section are as follows (Refer to Exhibit D pages 5.0-8, 9 and 10):
6.5.H, Introductory Paragraph This paragraph was split to insert an other paragraph which provides clarification, taken from the BASES of the current Prairie Island Technical Specifications, on equal allocation of liquid and gaseous releases from each unit. The liquid radwaste treatment system, waste gas treatment system, containment purge release vent, and spent fuel pool vent are shared by both units. Experience has shown that contributions from both units are released from each auxiliary building vent.
For these reasons, it is not practical to allocate releases to any specific unit. Therefore, all releases will be allocated equally in determining conformance to the design objectives of 10CFR50, Appendix I.
6.5.H.2 and 3 Reference to "old" Part 20 as previously discussed.
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6.5.H.4, 8 and 9 "each unit" has been replaced with "the site". The currently approved Prairie Island Technical Specification limits are based on releases from two units.
4 6.5.H.5 Replace "31 days" with " monthly" to be consistent with existing Prairie Island Technical Specification phraseology.
6.5.H.6 The current Prairie Island specific dose limits have been retained as limitations on the capability and use of effluent treatment systems. The current plant Technical Specification limits which are retained provide I more clarity to plant personnel and are within the i 10CFR50, Appendix I limits imposed in Generic Letter 89-01 f and the Standard Technical Specifications.
6.5.H.7 Reference to "old" Part 20 as previously discussed.
Subsection I Subsection I, Explosive Gas and Storage Tank Radioactivity Monitoring Program, is a new subsection established in conformance with the guidance provided by Standard Technical l Specifications. Generic Letter 89-01 defined some l specifications for which the existing specification
} requirements should be retained, including requirements for I explosive gas mixtures, liquid holdup tank contents and gaseous holdup tank contents. However, more recent Nuclear Regulatory Commission and industry guidance provided by the Standard Technical Specifications indicates that establishment of an administrative controls program is a more
! appropriate format for these requirements.
Substantive departures from Standard Technical Specifications for this section are as follows (Refer to Exhibit D pages 5.0-14 and 5.0-15):
6.5.I, Introductory Paragraph Reference to "offgas treatment system" is deleted since Prairie Island does not have an offgas system. Reference to methodologies for determining gaseous and liquid storage limits have been deleted because this section defines specific limits taken from the current Prairie Island Technical Specifications which have been previously approved by the NRC.
6.5.I.1 The existing approved Prairie Island Technical Specification limits for oxygen concentrations will be retained in this program. Therefore, this Specification places requirements on limiting oxygen in the waste gas systems. This will enable the plant to continue to operate Page 9
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I with the existing instrumentation and will preserve plant personnel familiarity with the applicable limits. The limits currently specified are appropriate for the system design criteria, accordingly the phrase regarding withstanding hydrogen explosions is not required.
6.5.I.2 and 3 Reference to "offgas treatment system" is deleted since Prairio Island does not have an offgas system. The Standard Technical Specifications limit tank radioactive contents by specific individual exposure limits for gas storage tanks or reference to 10CFR20 for liquid storage tanks. The Standard Technical Specifications then go on to define methodology for determining the allowed storage quantities based on the specified limits. This requested amendment proposes the limits extant in the current Prairie Island Technical Specifications which have been previously approved by the NRC. Use of specific defined limits is a much more straight forward and less confusing method of presenting Technical Specifications limits. Also these current Technical Specifications limits are presently familiar to plant personnel and are within the exposure limits and 10CFR20 limits presented in Standard Technical Specifications.
6.5.I.4 Specification TS 4.0 contains requirements comparable to SR 3.0.2 and SR 3.0.3 to the extent they are available in Prairie Island Technical Specifications.
- 9. ADMINISTRATIVE CONTROLS. Section 6.7. Reportina Recuirements.
A.4: Revise wording for Radioactive Effluent Report as shown in exhibits B and C.
Justification: The proposed specifications for the Radioactive Effluent Report conform to the guidelines of Generic Letter 89-01 except that the report is annual in lieu of semiannual consistent with changes to 10CFR50.36a and a recently approved amendment to the Prairie Island Technical Specifications. These reporting requirements are more general than the current Prairie Island Technical Specifications and relocate the specific report requirements to the Offsite Dose Calculation Manual and cite the applicable report guidelines in 10CFR50.36a and 10CFR50, Appendix I.
This report specification also conforms to the guidelines of the Standard Technical Specifications (Refer to Exhibit D page 5.0-19) with the following exceptionn:
The report title has been simplified by deletion of the word " Release".
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" unit" has been replaced with " plant" since Prairie Island is a two unit site.
Wording was added specifically relating the report to the previous calendar year.
The proposed report submittal date is May 15 each year.
This date is proposed to coincide with the proposed May 15 submittal date of the Annual Radiological Environmental Monitoring Report. May 15 is only two weeks later than the current Prairie Island specification of May 1. Submittal dates significantly earlier in the calendar year do not allow sufficient time to analyze all of the data for the report.
Reference to the Process Control Program has been deleted since the Prairie Island Process Control Program dccs not contain any guidance applicable to the Radioactive Effluent Report.
- 10. ADMINISTRATIVE CONTROLS, Section 6.7. Renortina Reauirements, C.1: Revise wording for the Annual Radiological Environmental Monitoring Report as shown in exhibits B and C. I Justification: The proposed specifications for the Annual Radiological Environmental Monitoring Report conform to the guidelines of Generic Letter 89-01 for the Annual Radiological Envi" nmental Operating Report. These reporting requirements are more general than the current Prairie Island Technical Specifications and cite the applicable report guidelines in 10CFR50, Appendix I. The specific report requirements are relocated to the Offsite Dose Calculation Manual. Consistent with this philosophy, the more prescriptive second paragraph in the Standard Technical Specifications has not been included in these requested amendments.
This report specification conforms to the guidelines of the Standard Technical Specifications (Refer to Exhibit D page 5.0-18 and 5.0-19) with the following exceptions:
The word " Operating" in the report title has been replaced with " Monitoring" to be consistent with current Prairie Island Technical Specification terminology.
" unit" has been replaced with " site" since Prairie Island is a two unit plant.
Consistent with Generic Letter 89-01 guidance, the second paragraph has been deleted. Specific report requirements '
are delineated in the Offsite Dose Calculation Manual Page 11
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which is subject to NRC audit and inspection and do not need to be repeated in the Technical Specifications.
- 11. BASES, Sections 3.9, 4.10, 4.11 and 4.17: Delete these sections in their entirety.
Justification: Since the sections which these BASES support have been deleted, the BASES themselves are no longer relevant and should be deleted.
' Safety Evaluation The proposed changes to the Prairie Island Technical Specifications will implement the recommendations contained in Generic Letter 89-01 and the guidance provided by the Standard ,
l Technical Specifications. The proposed changes add new programmatic requirements governing radioactive effluents, radiological environmental monitoring, solid radioactive wastes, explosive gas monitoring and storage tank radioactivity limitations. Existing Technical Specifications containing procedural details on radioactive effluents, radiological environmental monitoring, radioactive source leakage testing, explosive gas monitoring, storage tank radioactive content j limits, solid radioactive wastes and associated reporting I requirements are being relocated to the Offsite Dose Calculation Manual, Process Control Program or other new licensee controlled programs as appropriate. In addition, changes are proposed to other portions of the Technical Specifications to accommodate the incorporation of Generic Letter 89-01 and the subject relevant portions of the Standard Technical Specifications.
The level of radiological control will not be reduced by the proposed changes to the Technical Specifications since compliance i with applicable regulatory requirements governing radioactive I effluents, radioactive sources and radiological environmental monitoring, including 10CFR20.106, 40CFR190, 10CFR30, l 10CFR50.36a, and 10CFR50, Appendix A will continue to be maintained. The proposed changes will allow for the relocation of procedural details from the Technical Specifications to the Offsite Dose Calculation Manual, Process Control Program or other new licensee controlled programs as appropriate. Accordingly, future changes to these procedural details will be controlled by the controls for changes to the programs included in the proposed changes to the Administrative Controls Sections of the Technical Specifications. These procedural details have been included in l l
conformance with the recommendations of Generic Letter 89-01 and the guidance of the Standard Technical Specifications.
Determination of Sianificant Hazards considerations l
The proposed changes to the Operating License have been evaluated to determine whether they constitute a significant hazards Page 12
i 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 consequences of an accident previously evaluated The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed changes are administrative in nature and alter only the format and location of programmatic controls and procedural details relative to radioactive effluents, radiological environmental monitoring, radioactive source leakage testing, solid radioactive wastes, and associated reporting requirements. Existing Technical Specifications containing procedural details on radioactive effluents, radiological environmental monitoring, radioactive source leakage testing, explosive gas monitoring, storage tank radioactive content limits, solid radioactive wastes and associated reporting requirements are being relocated to the Offsite Dose Calculation Manual, Process Control Program or other new programs as appropriate. Compliance with applicable regulatory requirements will continue to be maintained. In addition, the proposed changes do not alter the conditions or assumptions in any of the previous accident analyses. Since the previous accident analyses remain bounding, the radiological consequences previously evaluated are not adversely affected by the proposed changes.
Therefore, the probability or consequences of an accident previously evaluated are not affected by any of the proposed amendments.
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident oreviously analyzed The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed changes do not involve any change to the configuration or method of operation of any plant equipment. Accordingly, no new failure modes have been defined for any plant system or component i important to safety nor has any new limiting single i failure been identified as a result of the proposed )
changes. Also, there will be no change in types or l increase in the amounts of any effluents released offsite, j Therefore, the possibility of a new or different kind of l accident from any accident previously evaluated would not be created.
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- 3. The proposed amendment will not involve a significant t reduction in the marain of safety i
The proposed changes do not involve a significant reduction in a margin of safety. The proposed changes do not involve any actual change in the methodology used in the control of radioactive effluents, radioactive sources, solid radioactive wastes, or radiological environmental monitoring. These changes are considered administrative in nature and provide >
for the relocation of procedural details outside of the !'
technical specifications but add appropriate administrative controls to provide continued assurance of compliance to applicable regulatory requirements. These proposed changes :
also comply with the guidance contained in Generic Letter 89- !
01 and the Standard Technical Specifications. [
Therefore, it can be concluded a significant reduction in the margin of safety would not be involved.
Based on the evaluation described above, and pursuant to 10 CFR Part 50, Section 50.91, Northern States Power Company has determined that operation the Prairie Island Nuclear Generating Plant in accordance with the proposed license. amendment request i does not involve any significant hazards considerations as defined by Nuclear Regulatory Commission regulations in 10 CFR Part 50, Section 50.92.
Environmental Assessment Northern States Power Company has evaluated the proposed changes and determined that:
- 1. The changes do not involve a significant hazards consideration, or
- 2. The changes do not involve a significant change in the types or significant increase in the amounts of any effluents that j may be released offsite, or
- 3. The changes do not involve a significant increase in i individual or cumulative occupational radiation exposure. l Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR Part 51 Section 51.22 (c) (9) . Therefore, pursuant to 10 CFR Part 51 Section 51.22(b), an environmental assessment of the proposed changes is i not required.
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