ML20096D679
| ML20096D679 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 05/07/1992 |
| From: | Parker T NORTHERN STATES POWER CO. |
| To: | |
| Shared Package | |
| ML20096D632 | List: |
| References | |
| GL-91-08, GL-91-8, NUDOCS 9205180190 | |
| Download: ML20096D679 (12) | |
Text
._ . - - . - . -- . _ . - . - . - . - - - - - . . - . - . - - . - . - - . - . . .
+
1 UNITED STATES NUCLEAR REGU1ATORY COMMISSION l
NORTMERN STATES POWER COMPANY PRAIRIE IS1AND NUCLEAR GENERATING PLANT DOCKET NO. 50 282 50 306 REQUEST 00R AMENDMENT TO OPERATING LICENSES DPR 42 6 DPR-60 LICENSE AMENDMENT REQUEST DATED May 7, 1992 !
Northern States Power Company, r. Minuemota corporation, requests authorir.ation for changes to Appendix A of the Prairie Island Operating License as shown on the i attachments labeled Fxhibits A, B, and C. Exhibit A describes the proposed changes, reasons for the changes, and a significant hazards evaNation. Exhibits B and C ara copies of the Prairic Island Technical Specificati~nc. incorperating th proposed, changes.
This letter contains no restricted or other detense information.
NORTHERN STA (S 'Op 'OMPANY
/
By fNWhdhW Thomas M Parker Manager Nuclent Support S rvices on this 'Nday of 7New / # 2 before me a notary public in and for said County, personally appeared Thomas M Parker, Manager Nuclear Suprart Services, and being first duly sworn acknowledgcd that he is authorized te execute this document on behalf of Northern States Power Company, that he knows the contents thereof, and that to the best of his knowledr,e, information, and butief the statements made in it are true and that it is not interposed for delay.
,v)</ s.:nwNX
/ / ,/
- ...
- ==:.=:= = : -
( 5 JUDYL KLAPPERICK f NOTARY PUBUC-WINNESOTA ANOKACOUN1Y i
6 4 Wy Commhaion Es
&:x-xx:xxx=pkol Sept =NNN:==:: 29,1997m P
9205180190 DR 920507 p ADOCK 05000282 PDR
Exhibit A Prairie Island Nuclear Cencrating Plant License Awendtoent Request Dated May 7, 1902 Evaluation of Proposed Charges to the Technical Specifications Appendix A of Operating License DPR 42 and DPR 60 Pursuant to 10 CFR Part 50, Sections 50.59 and 50.90, the holders of Operating Licensen DPR 42 and DPR 60 hereby propose the following changes to Appendix A, Technical Specifications:
- 1. Relocatloc of -Containment Penet rat ton List Backtround This license amendment request proposes the relocation of the Prairie Island Technical Specilication containment Fenetration List into plant procedures in accordance with the gule '.cc provided in Generic Letter 91 08, " Removal of Component Lists From 'w.hnical Specifications".
The Containment Peretration List in the Prairie Islar.d Technical Specification Section 4.4 will be relocated into plant procedures that are ,
subject to the change control provisions for plant procedures in the Administrative Controls Section of the Technical Specifications. The removal of the Containment Penetration List from-Technical Specifs.4tions
- will permit -administrative- control- of -changes-to this list without processing a license amendment. Any change to the Containment Penetration List once it is incorporated in the plant procedures will be subject to tho' requirements specified in the Administrative' Controls Section of the Technical Specifications on changes to plant procedures. The change control provisions.of the Technical Specifi. cations will provide an adequate means to contro1L changes to the Contalament Penetration List.
The removal of the Containment Penetration List-from the Prairic Island Technical Specifications per the guidance .descrit;d in Generic Letter 91-08 provides an' acceptable alternative to identifying every containment penetration by.its. plant identification number in the Technical Specification Containment Pet.etration List. The. removal of the Containment Penetration List is acceptable-because it-does not alter-existing Technical Specification' requirements or those components.to which they' apply.
l l
t ;
e ,
fahlbit A
- Page 2 of 11 Pronosed Channes and Reasons for Chante ;
The proposed changes to the Prairie Island lechnical Specifications being impicmented in response to Generic Letter 91-08 are described below, and the specific wording chanr,es to Technical Specifications are shown in !
Exhibits B and C. ;
A. Proposed ch,a.wres to Technten1 Specification List of Tables The reference to Table 1S.4./. 1, " Unit 1 and Unit 2 Penetration .
Designation for leakage Tests", is being deleted in response to the !
deletion of the table from the Technical Specifications, -
B. Proposed channes to Technical Specificajlon Section 1.0 Item 2 is ;eing deleted from the definition of containment Integrity in Section-l',0. -The reference to Table TS.4.4 1 will no 1 Lager be appropriate following deletion of the table. The $quirernent for the installation of-blind flanges required by Table TS.4.4 1 is being deleted because it is redundant to the requirement in item 1.b of the Containment Intecrity definition which states thet all penetrations are either closed by manual valves, blind flanges or deactivated automatic '
valves, f
C. Proposed cht.nres to Technical Specification Section 3.6.C The references to Table TS.4.4 1 being deleted trom Sections 3.6,C.2 and 3.6.C.3 in response to the deletion of the table trom the Technical Specifications.
D. Proposed channes to Technical Specification Section 4.4.A
.The references to Table Ts.4.4 1 bning deleted frotn Sections 4.4.A.2.
4.4, A,4.a and 4.4. A.4 b in response to the deletion of the table from the Technical Specifications. The term "contaitunent system integrity" is.being changed to " CONTAINMENT INTEGRITY" in Section 4.4.A,2 to be consistent with the current terminology in Section 1.0 ano the policy for capitalizing all defined terms. The acronym "ABSVZ" is being spelled out in Sections 4.4.A.4.a and 4.4.A,4,b for clarity and consistency _with Sections 4,4.A 5 and 4.4,A,6.
D. Proposed Relocat ion of Technical _,f t.ecif tention Table TS.4.4-1 As discussed above, per'the guidance in Generic Letter 91 08,. Table TS,4,4-1, " Unit 1 and Unit 2 Penetration Designation for Leakage Tests", is being relocated into plant procedurer that are subject to the change control provisions for plant procedures in the Administrative Controls Stetton of the Prairie Island Technical
-Specificatirns.
_ .. . _ _ _ _ c. - . ~ ~ . _ - - - -= -- - - - -
fahlbit A '
i Page 3 of 11 License Amendment No. 62, dated February 23, 1983 revised the Prairie Island Technical Speci.fications to conform to the requirements of Appendix J to 10 CFR Part 50. Notes 1, 2 and 5 of Table TS.4.4 1 were incorporated into the Prairic Island Technical Speelrications by License Amendment No. 62 to provide clarifications and exemptions to the Type B and C testing requf rements of Appendix J to 10 CPR Part 50.
Notes 1, 2 and 5 of Table 75.4.4 1 are being incorporated into Technical Specification Section 4,4.A.2 so that the applicability of the Appendix J testing requirements remains clearly defined in the i Technical Specifications. k'h il e the reference of these notes to specific containment. penetrations is being relocated out of the Technical Specifications with Table TS.4.4 1,.we consider the specific clarifications and exemptions incorporated into Table TS.4.4 1 by License Amendment 62 still binding. The reference of Notes 1, 2 and 5 to the specific containment penetrations will be maintainnd in the Prairie Island Updated Safety Analysis Report, Note 3 of Table T5.4.4 1, which defines terms utilized in Table TS.4.4-1, is not being retained in the Technical Specifications because it is an integral part of the Table and serves no useful purpose in the Technical Specificatior.s once the table is relocated.
Note 4'of Table TS.4.4 1, which describes which penetrations have blank flanges, is not being retained in the Technical Specifications because of its reference to specific penetration numbers. The information provided by Note 4 will be relocated with Table TS.4.4 1 to the plant procedures and the Prairie Island Updated Fafety Analysis Report.
Note 6 of Table TS 4.4 1 is being deleted, it provides luformation which is also provided by Section 3.6.D.2.b of the Technical Specifications.
Safety Evalunt ion and Det ,.rminat ion of Si nni ficant Hazards Con dderations t
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 urobability or consaquences of an accident ureviousiv evaluated.
Relocation of the Containment Penetration List to plant procedures is consistent with the Euidance in Generic Letter 91-08, it does not alter existing Technical Specification requirements or those components to l which they apply. Any change to the Containment Penetration List, once l it is incorporated in the plant procedures, wi!1 be subject to the requirements specified in the Administrative Controls Section of the -
Technical Specifications on changes to plant procedures. The procedure change control provisions of the Technical Specifications will provide an adequate means to control changes to the Containment Penetration List.
l
[Ahlbit A Page 4 of 11 Therefore, becaose the retuoval of the Contairuoent Penetration List from the Prairie Island Technical Specifications does not alter existing ,
Technical Specification requirements and because changes to the Containment Penetration Lis' will be controlled per the Administrative Controls Section of the Technical Specifications, the proposed changes will not significantly affect the probability or consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibilit.y of a new or different kind of accident from any. accident nreviousiv analyzed. l There are no new failure modes or mechanisms associated with the '
proposed changes. The proposed changes do not involve any modification in operational limits. Only the list of containment penetrations is being removed from Technical Specifications.
The proposed changes are consistent with the fiRC Staff guidance provided by Generic Letter 91-06, " Removal of Component Lists From Technical Specifications". The !!RC Stat f concluded in Generic Lett.or 90-09, that the removal of component. lists from the Technical Specifications per the guidance described in Generic Letter 91 08 provides an acceptable alternative to identifyin6 every component by ,
its plant identificat. ion number in the Technical Specifications because the removal of the lists does not alter existing Technical Specification requirements or those components to which they apply.
Since the proposed chrnges conform with the guidance in Generic Letter 91-08, and because the removal of the Contaitunent Penetration List from the Prairie Island Technical Specifications does not alter existing Technical Specification requirements et those components to which they apply, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated, and the I
accident analyses presented in the Updated Safety Analysis Report will remain bounding.
- 3. The proposed amendment will not involve a significant reduction in the marr.in of safety.
Relocation of the Containment Penetration List to plant procedures is consistent with the guidance in Generic Letter 91 08, it does not alter existing Technical Specification requirements or those con >ponents to which they apply. Any change to the Containment Penetration List, once l It is incorporated in the plant procedures, will be subject to the requirement.s specified in the Administrative controls Section of the Technical Specifications on changes to plant procedures. The procedure change control prcvisions of the Technical Specifications will provide an adequate means-to control changes to the Containment Penetration List.
. - . - - - . - . - . - - . . . . _ . . - - . .- . , , - . _ - . . . . . . - - ~ . -
tahlbit A 49e $ of 11 Therciore, because the removal of the cor ainment Penetration List from the Prairie Island Technical Specifications does not alter existing Technical Specification requirements and because changen to the Containment Penetration List vill be controlled per the Ad:ninistrative Controls Section of the Technical Specifications, the proposed changes will not result in any reduction in the plant's margin of safety.
Based on the evaluation described above, and pursuant to 10 CFR Part 50, Section 50.91, Northern States Power Company has deterrnined that operation of the Prairie Island Nuclear Generating Plant in accordance with the proposed license aruendruent request does not involve any significant hazards considerations as defined by !!RC regulations in 10 CPR Part 50, Section 50.92 Envi ronmeMal As *;e mment This license amendment request does not ebange effluent types or total effluent amounts nor does it involve an increase in power level. Therefore, this chang will not result in any significant environmental impact.
-- - - _ - - - - - - - - - - - - - - - _ _ - - . - - - - - . _ . ~ . -- . - . -
i a
tahlbit A Page 6 of 11
- 2. Fon Automatic Containment Isolation Valve Applicability Backrround .
I This license amendment request proposes changes to Prairie Island ,
Technical Specification Section 3.6.C which will clarify when the non- I automatic containment isolation valves are required to be operable and '
what actions are te be taken in response to the inoperability of a non-automatic containment isolation valve. ,
[Iponsed Chances and Rensons for [hanne I The existing wording in Technical Specification Section 3.6,C.1 does not specify when the non automatic containment isolation valves are required to be operable and does not specifically refer to the containment isolation valve accion statements in Section 3.6.C.3. It is not clear per the existing wording in Sections 3.6.C.1 and 3.6.C.3 that the action statements in Section 3.6.C.3 apply to the nor. automatic containment isolation valves.
Section 3.6.C.1 is being revised, as shown in Exhibit B, to specify that the non automatic containment isolation valves be operable whenever containment inte ;rity is required and to refer to the action statements in Section 3.6.L.a. The changes made to Section 3.6.C.3 in response to removal of Table TS.4.4 1 make it clear that the specified acti>n staterents apply to all containment isolation valves, both automatic and non automatic.
The praposed changes will clearly define when the non automatic containment isolation valves are required to be operable and what actions are to be taken if they are found to be inoperable. They will aid in the >
compliance with Technical Specification requirements and will thus enhance ,
plant safety.
The specific wording changes to the Prairic Island Technical ,
Specifications proposed by this License Amendment Request are shown in i Exhibitt. B and C.
Safety Evaluation and Determination of Sirnificant llazards Considerations i . -
l '.
- 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
t
- 1. The proposed- amendment will not sinvolve a significant increase in the probability or conscauences of an accident previousiv eval"ated.
.The. proposed chenges clearly defino when-the non-automatic containment- i isolation valves are required to be operable and clarify that the action-statements in Section 3.6.C aise apply to non-automatic l conta' ament isolation valves. The clarification of Section 3~.6.C apnlicability will ensure that the non-auto- 4c containment isolation valves are maintained operabic when require i o maintain plant safety.
l
_ . - ~ . . - - - - - - - - - - - . - - - -- - ~ ~ -
? .
(xhibit A Page 7 of 11 The clarification that the action statements in Section 3.6.C.3 are applicable te non-automatic contaiteent isolacion valves will ensure that appropriate action is takeri in response to the inoperability of a non-automati contaitunent isolation valve. The etual actions, specified by the Technical Specifications, to be taken in response to an inoperable contaliment isolation valve, either non automatic or automatic ate not affected by the proposed changes.
Therefore, the proposed changes will not significantly affect 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 nreviousiv analv: ed.
There are no new failure .wles or rocchanisms associated with the proposed changes. The proposed changes do not involve any modification in operational limits. Tbc proposed changes only clarify that the action statements in Section 3.6.C also apply to non automatic
_ containment isolation valves. The actual actions to be taken in response to an inoperable contairment isolation valve, either non-automatic or automatic are not affected by the proposed changes.
Therefore, the proposed changes do not create the possibility of a new .
or different kind of accident from any previously evaluated, and the l accident analyses presented in tho Updated Safety Analysis Report will remain bounding.
- 3. The proposed amendment will not involve a significant reduction in the u rrin of sefety.
The proposed changes' clearly define when the non-automatic containment isolation valven are required to be operabic and clarify that the action statements in Section 3.6.C also apply to non-automatic containment isolation valves. The clarification of Section 3.6.C applicability will ensure that thn non-automatic contalrnent isolation valves are maintained operable when required to maintain plant safety.
The clarification that the action statements in Section 3.6.C.3 are applicabic to non-ntomatic containment isolation valves will reduce the chances that inappropriate action is taken in response to the inoperability_of a non automatic containment isolation valve. The actual actions, specified by the Technical Specifications, to be taken in response to an inoperable containment isolation valve, either non-automatic or automatic are not affected by the proposed changes.
The proposed changes more clearly define when the non automatic containment isolation valves are required to be operable and what actions'are to be taken if they are found to be inoperabic and will aid in the compliance with Technical Specification requirements and sill thus increase the plant's margin to safety. Therefore, the proposed changes will not result in any reduction in the plant's margin of safety.
_ __. . _ _ _ _ _ _ _ . _ _ _ _ . _ _ . _ . . ~ . _ _ . . _ . _ , . _ _ _ _ _ . _ _ _ . _ _ . _ . ._.. . . _ __-._ . _ . _ . ,
s;
' l tahlbit A 1 4
- Pepe 8 of 11 l Based on the evaluation described above. and pursuant to 10 CFR Part 50,
-Section 50.91, Northern States Power company has determined that operation of the Prairie Island Nuclear Generating Plant in accordance with the proposed license amendment request does not involve any significant hazards considerations as defined by NRC regulations in 10 CPR Part 50, Section 50.92.
f_nvironmental 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 impoet. ,
l l
L 1
l I
l s
w ..m-e.--e=' ,.-.w*-.-~si - sw. .,--, s- - , . vsm,,e,e-ie..-.,r.-- e s. w.- . . - mi.+-+.,em. . ,e..--,cy +,.---v.r+,r_'wca,6+, r , &, . - -u , - . - . -w-~yn-yy--
fahlbit A Page 9 of D 3, Deletion of Condensate Supp1v Cross Connect Valve Backcround Specification 3.4.B.1.g currently specifies that condensate cross connect valves C 41 1 and C 41 2 be blocked and tagged open. A reliability study of the Prairic Island auxiliary fetdwater system was completed in April 1986. That ro11 ability study concluded that the reliability of the auxiliary feedwater system could be improved if valve C-41-1 was removed from the condensate supply to the auxiliary feedwater pumps and replaced with a spool piece (see Figure 1).
Valve C 41 1 was subsequently remove 3 and replaced with a spool piece.
llowever, due to an oversight, the valve was removed and replaced with a spool picen before it was removed from the Technical Specifications.
Valve C 41-1 was originally included ln the Technical Specifications to protect against inadvertent closure of the valve which would adversely affect the condensate supply to the auxiliary feedwater pumps. When it was identified that the valve had been removed without modli'ying the Technical Specifications, it was concluded that the spool piece performed the samo function as a blocked and tagged open valve and that the use of the spool ploce met the intent of the Technical Specification 3.4.b.1.g.
Based on t! iiliability study discussed above, the use of the spool piece in place of one blocked and tagged valve improves the reliability of the auxiliary feedwater system and results in a plar,t configuration with a larger margin of safety than is previded by the current Technical Specification requirements in Section 3.4.B,1.g.
proposed channes and Reasons for Chante, Th!s license amendment request proposes the deletion of condensate cross connect valve C-41 1 from Prairie island Technical Specification Section 3.4.B.1.g._ The proposed changes are being made to bring the Prairie Island Technical Specifications into agreement with the actual plant configuration. The specific wording changes to the Prairic Island Technical Specifications proposed by this License Amendment Request are shown in Exhibits E and C.
Sa fe ty Evaluation and Determination of S!rnificant 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 provid d in Netion 50.92. This analysis is provided be?.ow:
- 1. The proposed amendment will not involve a significant increase in
! the probability or consequeJ)ces of an accident previousiv evaluated.
l The spool piece which replaced valve C-41-1 performs the same function I as a blocked and tagged open valve and meets cl.e intent of the l
Technical Specification 3.4.B.1.g. Based on the auxiliary feedwater system reliability study, discussed above, the use of the spool piece in place of the blocked and tagged valve C-41-1 results in a plant l'
1
. n. '
Exhibit A Page 10 of 11 configuration with less chance of the condensate supply to the auxiliary feedwater punps being blocked by the inadvertent closing of a valve and thus improves the reliability of the aux.111ary feedwater system.
Therefore, because the proposed changes improve the reliability of the auxiliary feedwater system nnd do not change the intent of the current Technical Specifications, there is no increase in the probability or l consequences of an accident previously evaluated. l l
- 2. The proposed amendment will not create the possibility of a new or '
different kind of accident from any accident previousiv analyzed.,,
There are no new fcilure modes or mechanisms associated with the ;
proposed changes. The replacement of a blocked and tagged open valve !
with a spool piece actually eliminates a poscible failure mechanism which could adversely affect auxiliary feedwater system operation. The proposed changes do not involve any modification in operational limits.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated, and the accident analyses presented in the Updated S?fety Analysis Report will remain bounding.
- 3. The proposed amendment will not involve a significant reduction in the marnin of safety. _,
I The spool piece which replaced valva 0 41 1 performs the same function as a blocked and tagged open valve. The use of the spool piece meets
-the intent of the Technical Specification 3.4.B.I.g. Based on the auxiliery feedwater system reliability study discussed above, t.he use of the spool piece in place of the blocked and tagged valve C-41 1 results !n a plant configuration with less chance of the condensate t
i supply to the auxiliary faedwater pumps beinn blocked by the inadvertent closing of a valve .and thus improves the reliability of the auxiliary feedwater svstem and increases the plants margin of safety.
Therefore, the proposed changes will not result in any reduction in the plant's margin of safety.
i Based on the evaluation described above, and pursuant to 10 CFR Part 50, Section 50.91, Northern States Power Company has determined thu operation of the Prairie Island Nuclear Generating Plant in accordance with the i proposed license amendment request does not involve any significant i hazards considerations as defined by NRC regulations in 10 CFR Part 50.
Section 50.92.
Environmental Assessment This license amendment request does Tot 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.
1.
- ,w w-m w w. , , ,w.co ,-, . - - - ,,.-,-.y-, ,---w--w - y- w -y- ...,,.,-e--y
>> r II; , ! [ ;lj;f ,!I 7l) : : !.t( jl[
1\ ,4 ! !
EI SE5 >Q =
^
t e
a s
2e g n e t d arks in n ot on a UCST e r i
n ye l
b rt r
u el niwp aa 'j f
Tv ixer id n j
/ e 2rueu /c 2DAFP e
^ -
i P
E A1ll' l i
Y A. .
l o
o p
S m
e t
s 4 y El21 r 11 A,
T_.
S y r p e p l
r ye 1 t u o rt a aS t
o niwp a E w el R d e Mvid ixe m U G
et e a 1
2D*.FP rueu 2 I F s
- F n ye M1C 4 r :e a n i o l C i
x u
4 A X _1 r
m A.
T___
r ye o rt nia wa p t
o el Mvixeid m 2rueu 1 DAFP 4
) -
X en -C' r
l l
62
+
[$
i ye b rt r nelia awp u
1 Tvrueui ixed m 1 DAFP t
e a
s I
n e g e
a s t d rk inn ot i o a UCST
. ,4 ' i} . i i ' i