ML20129E534
| ML20129E534 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 06/25/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20129E525 | List: |
| References | |
| GL-83-43, NUDOCS 8507160842 | |
| Download: ML20129E534 (7) | |
Text
k UNITED STATES
[
g NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
.....l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.73 AND 66 TO FACILITY OPERATING LICENSE NOS. DPR-42 AND DPR-60 NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-282 AND 50-306 Introduction By letter dated July 11, 1984 as supplemented April 26, 1985, Northern States Power Company (NSP), the licensee, requested amendments to Facility Operating License Nos. DPR-42 and DPR-60 for the Prairie Island Nuclear Generating Plant Unit Nos. I and 2 (PINGP). The requested amendments proposed changes to the Technical Specifications (TS) in the following areas:
1.
TS 1-1, (and throughout sections of TSs) - Administrative changes dealing with reporting requirements as defined in Generic Letter (GL) 83-43 and 10 CFR 50.73 l
2.
TS i thru TS viii - Administrative changes revising the Table of Contents, detailing additional listings that result in easy access for locating items in the TS.
3.
TS 1.P.3, TS 3.6.A.4 and TS 3.8.A.4 - A change in the 2000 PPM Boron requirements to achieve consistency with the standard technical specification requirements for the reactor coolant system during various refooling conditions.
4.
TS 4.110 - An administrative change involving the deletion of the reference to TS section 6.7 for the reporting requirements related to the radioactive source leakage test.
5.
TS 6.1-1 table - An addition to the TS is proposed to meet a new requirement of 10 CFR 50.54(m)(2) for having one Senior Reactor Operator (SRO) in the control room at all times when the reactor is i
above cold shutdown.
6.
TS 3.12-1 table and TS 4.13 The proposed changes implement the recommendation of Generic Letter 84-13 dealing with the deletion of the detailed listing of the safety related snubbers.
7.
TS 3.3B1c - The proposed change is administrative in nature and is related to the minimum volume and concentration of the sodium hydroxide spray additive tank.
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4 d 8.
TS 3.9 The proposed change modifies the requirement for measuring the plant discharge flow rate which would make continuous flow rate measurement unnecessary.
9.
TS 3.9-2 table, TS 4.17-1 table - The proposed change involves the deletion of utnecessary tests of the radioactive effluent monitoring instrumentation.
- 10. TS 4.10-1 table - The proposed change involves minor wording changes regarding the radiation environmental monitoring program sample collection and analysis to achieve consistency with the Standard Technical Specifications for PWRs (NUREG '?473 Revision 2).
- 11. TS 6.2 and Figure TS 6.1 The proposed change is administrative in nature in that it involves a title change of the Director of Nuclear Generation.
By letter dated January 21, 1985, the licensee withdrew the portion of the license arendment request associated with new peaking factor limits for the Exxon fuel assemblies. The revised peaking factor limits will not be needed for the current cycles for both units.
In addition, these peaking factor limits which are applicable to EXXON fuel would not be needed for future cycles since the licensee is scheduled to change fuel vendors starting with cycle 11 on both units. On this basis, the staff stopped the review of this change and the technical specifications are not amended to reflect this item.
Discussion and Evaluation 1.
TS 1-1 (and throughout applicable section of TS Reporting Requirements By Genaric Letter 83-43, we requested all licensees and applicants to implement changes to the technical specifications (TS) to reflect the requirement of 10 CFR 50.73:
"Since paragraph (g) of Section 50.73 specifically states that 'the requirements contained in this section replace all existing requirements for licensees to report " Reportable Occurrences" as defined in individual plant Technical Specifications,' the reporting requirements incorporated into the " Administrative Controls" section of your facility's technical specifications may require modification."
The licensee responded to our request by submitting the proposed changes to the TS to reflect the new requirements of 10 CFR 50.73. The licensee, using model technical specifications as guidance, added a definition for
" Reportable Events", changed the phrases " reportable occurrence report,"
" prompt notification with written followup" and other similar phrases. The staff has reviewed the licensee's proposed changes and finds that the proposed changes agree with the guidance given in GL 83-43. On this basis, we find the proposed changes to the reporting requirements acceptable.
2.
TS i thru TS viii Table of Contents The licensee proposed to change the Table of Contents of the TS, giving a more detailed breakdown of the various sections. We agree with the licensee that the detailed listing of these items would make it easier to locate the various sub.ie::i.s throughout the body of the TS.
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This change is administrative in nature and has no effect on the limiting conditions of operation, the surveillance or the administrative requirements. On this basis, the staff concludes that there will be no reduction in the level of plant safety and therefore, the changes are acceptable.
3.
TS 3.6 and TS 3.8 Refueling Boron Concentration The licensee has requested that the limit on boron concentration of 2000 ppm during refueling operations be deleted. The current TS specific limits of 2000 ppm boron and a shutdown margin of 10% ak/k.
In order to eliminate any confusion as to which limit must be observed, the licensee proposed the deletion of the 2000 ppm boron concentration limit. By the letter dated April 26, 1985, the licensee confirmed that the boron concentration corresponding to a shutdown margin of 10% ak/k is calculated as part of the reload analysis and is stated in the Startup and Operations Report and in the plant procedures. The licensee's objective of this change is to achieve consistency throughout the TS to assure that the shutdown margin requirement is not misinterpreted.
The Standard Technical Specifications permit the more restrictive of the 2000 ppm boron or a shutdown margin of 5% a k/k to exist during refueling operations. The boron concentration necessary to ensure a shutdown margin of 10% 6 k/k is equivalent to 2000 ppm boron concentration and therefore specifying either value in the technical specification will in no way reduce the safety margin during refueling operation for which the specification applies. The 5%ak/k has been included in the proposed change to cover rare occasions when the 2000 ppm boron concentration would not be adequate to maintain the 10% ak/k.
The licensee's proposed change is inconsistent in regard to the 2000 PPM boron an 5% ak/k limits specified in the Standard Technical Specifications.
Therefore, the licensee's proposed change was modified to eliminate this l
inconsistency. The modifications to the proposed change were discussed with and agreed to by the licensee. The staff concludes the proposed change as modified adequately meets the intent of the Standard Technical Specification requirements and eliminstes the potential of misinterpretation of the shutdown margin requirements in the TS.
In addition, the proposed change adequately protects against inadvertent criticality during refueling operations. On this basis, the staff finds the proposed change will not reduce the level of plant safety and thus finds it acceptable.
, 4.
TS 4.11 Radioactive Source Leakaae Test The licensee proposes to delete the reference to TS section TS 6.7
" reporting requirements" in describing the reporting requirements for source leak test results. This proposed change is administrative in nature and does in no way change the reporting requirement for source <
leak test results.
A review of section 6.7 by the staff shows that the requirement of this section does not apply nor does it give any applicable guidance related to reporting the results of source leak tests. A misspelled word appearing in the basis (i.e., ingest 4n) also has been corrected. Based on the above, the proposed change dealing with the deletion of the reference to section TS 6.7 will not reduce or affect the level of plant safety and therefore is acceptable.
s 5.
TS 6.1-1 table-Senior Reactor Operator (SR0) Requirements The licensee proposed a change to Table TS 6.1-1 regarding the minimum shift crew composition to assure agreement with 10 CFR 50.54(m)(2) that became effective January 1, 1984. Specifically, the licensee e
proposes to add a note to the table specifying that one SR0 shall be in the control room at all times when one or both reactors are above cold shutdown. This added requirement is merely having the TS agree l
with requirements of 10 CFR 50.54 and is an additional limiting condition of operation that increases the level of plant safety. On this basis, the staff finds the proposed change acceptable.
6.
TS 3.12-1 Deletion of Snubber table By letter dated October 28, 1981, the Commission issued Amendment Nos.
50 and 44 to Facility Operating License Nos. DPR-42 and DPR-60 that put in place the Hydraulic Snubber technical specifications. The TS were revised to incorporate the surveillance requirements as requested by our Generic Letter dated November 20, 1980. Generic Letter 84-13 dated May 3, 1984, transmitted Revision 1 of the Surveillance Requirements of the Generic Letter dated November 20, 1980, and allowed the deletion of the tabular listing of safety related snubbers provided the snubber TS is modified to specify which snubbers are required to be operable. The licensee's proposed change includes all safety related snubbers to be operable when the reactor is above cold shutdown. The safety related snubbers include all snubbers necessary to insure that the structural integrity of the reactor coolant system and all other safety related systems are maintained during and following a seismic event or other events initiating dynamic loads.
Based on the above and our review of the licensee's proposed change, the licensee has adequately specified which snubbers are required to be operable and meets the intent of Generic letter 84-13.
In addition, the licensee is required to maintain plant records containing a record of the service life, installation date and maintenance history for each snubber. On this basis, the proposed change is acceptable.
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7.
TS 3.3B1C Spray Additive tank volume / concentration requirements By letter dated September 1,1983 the Commission issued Amendments Nos. 65 and 59 permitting the lowering of the Sodium Hydroxide (NaOH) concentration in the spray additive tanks of the containment spray system from 30% by weight to a range of 9% to 11% by weight, inclusive. The licensee's analysis showed that, under certain accident scenarios, the electrical equipment inside containment could be subjected to an unacceptable pH environment (i.e., pH > 10.5) if the 30% by weight Na0H concentration is maintained in the spray additive tanks. Amendment Nos. 65 and 59 to the TS still permitted the 30% by weight Na0H concentration to exist in spray additive tanks until the tanks were modified to accept the larger volume of solution for the lower Na0H concentration range (i.e., 9% to 11% by weight). This proposed change is administrative in nature in that it deletes the 30% by weight.
Na0H concentration from the TS which is no longer necessary or required since the modifications to the spray additive tanks are now completed. Thus, the proposed TS change would have a single requirement for the Na0H concentration in the spray additive tanks that has been found acceptable in Amendment Nos. 65 and 59. On this basis, the staff finds the proposed deletion of 30% by weight Na0H concentration is acceptable.
8.
TS 3.9-1 table-Discharge Canal Flow 9.
TS 3.9-2 table, TS 4.17-1 and TS 4.17-2 Radioactive Effluent Monitoring Instrumentation Requirements
- 10. TS 4.10-1 table-Radiation Environmental Monitoring Program Sample Collection and analysis Items 8, 9 and 10 are proposed changes that modify requirements related to the Radiological Effluent Technical Specifications (RETS) that were issued by the Commission on October 21, 1982 as Amendment Nos. 59 and 53. The items address the following areas:
a.
Item 8 is related to a clarification of the measurement of the plant discharge flow rate frequency (i.e., continuous vs daily).
b.
Item 9 is related to deleting unnecessary testing of Radiation Effluent Monitoring instrumentation; and; c.
Item 10 deals with minor wording changes to achieve consistency with the Standard Technical Specifications for PWRs (NUREG-0473, Revision 2).
All of these changes in items 8, 9 and 10 were reviewed by the staff.
The staff finds that the modifications proposed therein meet the
0 intent of the NRC staff's RETS for PWRs, NUREG-0473 Revision 2, (February 1, 1980). The changes proposed in these items will not remove or relax any existing requirements related to the probability or consequences of accidents previously considered and do not involve a significant hazards consideration.
In addition, the proposed changes will not remove or relax any existing requirements needed to provide reasonable assurance that the health and safety of the public r will not be endangered by operation in the proposed manner. On this, basis, the staff finds the proposed changes acceptable.
- 11. TS 6.1-1 table, TS 6.2 and TS 6.7 title change The licensee proposed the title of " Director of Nuclear Generation" be changed to "Vice President Nuclear Generation. The administrative sections of the TS reflect the change by modifying the title of the Director of Nuclear Generation to Vice President Nuclear Generation.
The title change would make the title appearing in the TS agree with the title existing in the actual plant organization. This change is administrative in nature and has no effect on the management function, authority or responsibility of the position identified throughout the administrative sections of the TS. On this basis, the staff concludes that the change will not reduce the level of plant safety and, therefore, is acceptable.
Environmental Consideration The part of the amendment dealing with clarifications and elimination of unnecessary testing in the radiation environmental monitoring program technical specifications involves an administrative change. Accordingly, this part of the amendment meets the eligibility criteria for categorical exclusion sct forth in 10 CFR 51.22(c)(10). The remaining parts of the amendments involve a' change in the installation or use of a facility l
component located within the restricted area or a change to a surveillance requirement. The staff has detemined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that these amendments involve no significant hazards consideration and there has been no public coment on such finding. Accordingly, the remaining parts of forth in 10 CFR 51.22(c)(9)gibility criteria for categorical exclusion setPursuant to 10 the amendments meet the eli l
impact statement or environmental assessment need be prepared in connection l
with the issuance of these amendments.
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, Conclusion We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Conmission's regulations, and the issuance of the amendments will not be inimical to the common defense.and security or to the health and safety of the public.
Date: June 25, 1985 Principal Contributors:
D. C. Di Ianni M. Chatterton W. Meinke C. Willis i
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