ML20198L221
| ML20198L221 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/07/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20198L214 | List: |
| References | |
| NUDOCS 9901040106 | |
| Download: ML20198L221 (17) | |
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NUCLEAR REGULATORY COMMISSION g,
WASHINGTON, D.C. 20eWHW01 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.141 TO FACILITY OPERATING LICENSE NO. DPR-42 AND AMENDMENT NO.132 TO FACILITY OPERATION LICENSE NO. DPR-60 NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLANT. UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306
1.0 INTRODUCTION
By letter dated December 14,1995, as supplemented on Ncvember 25,1996, April 10, September 4, and December 29,1097, January 8, March 2, June 11, August 12, and October 30,1998, Northern States Power Company, (NSP or the licensee), requested amendments to the Technical Specifications (TS) appended to Facility Operating License Nos.
DPR-42 and DPR-60 for the Prairie Island Nuclear Generating Plant, Units 1 and 2, respectively.
The proposed changes would modify Section 6.0 by removing or relocating requirements that are adequately controlled by existing regulations other than 10 CFR 50.36 and the TS.
i GJidance on the proposed changes was developed by the NRC and provided in the Standard Technical Specifications (STS) for Westinghouse Plants, NUREG-1431, and Administrative Letter 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance," issued on December 12,1995.
The November 25,1996, April 10, September 4, and December 29,1997, January 8, March 2, June 11, August 12, and October 30,1998, submittals provided additional clarifying information, revised implementation dates, and updated TS pages. This information was within the scope of the onginal Federal Register notice and did not change the staff's initial proposed no significant hazards considerations determination.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state TS to be include (t as part of the license. The Commission's regulatory requirements related to the content of TS are set forth in Title 10, Code of Federal Regulations (CFR), Section 50.36. That regulation requires that the TS include items in five specific categories, including (1) safety liraits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs);
(4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.
9901040106 981207 PDR ADOCK 05000282 c
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The Commission amended 10 CFR 50.36 (60 FR 36593, July 19,1995), and codified four criteria to be used in determining whether a particular matter is required to be included in an LCO, as follows: (1) Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; or (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. LCOs and related requirements that fall within or satisfy any of the criteria in the regulation must be retained in the TS, while those requirements that do not fall within or satisfy these criteria may be relocated to licensee-controlled documents. White the criteria specifically apply to LCOs, in adopting the revision to the rule the Commission noted that the staff had used the intent of these criteria to identify the optimum set of administrative controls in the TS (60 FR 36957).
The regulation at 10 CFR 50.36 states that Administrative Controls "are the provisions rela. ting to organization and management, proctdures, recordkeeping, review and audit, and reporting necessary to assure safe operation of the facility in a safe manner." The specific content of the administrative controls section of the TS is,.therefore, that information that the Commission deems essential for the safe operation of the facility that is not already adequately covered by other regulations. Accordingly, the staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(5), and that are not otherwise necessary for operation of the facility in a safe manner, can be removed from administrative controls.
3.0 EVALUATION The following discussions detail the staff's conclusions regarding the removal or relocation of selected administrative controls from the Prairie Island Nuclear Generating Plant TS. The changes were reviewed in accordance with the guidance provided in, or planned for, the STS, NUREG-1431. In addition, these changes were reviewed in accordance with the guidance provided in Administrative Letter 95-06.
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License amendment requests should describe the relocation of each selected requirement to a i
particular licensee-controlled document or program (e.g., the final safety analysis report (FSAR) or the quality assurance (QA) plan). The description should also address the submittal of the revised documents to the NRC in accordance with the applicable regulation (e.g.,10 CFR 50.71(e)). In the amendment request, the licensee should clearly describe the program it will 1
use to control changes to relocated requirements (e.g.,10 CFR 50.59 or 50.54(q)). Control of l
the relocated requhements in accordance with the applicabis regulation ensures that NRC l
review and approval will be proposed for changes exceeding the statcd regulatory threshold (e.g., an unreviewed safety question or a decrease in effectiveness). Elimination of reporting requirements that are recommended for relocation or removal from the TS can be proposed if i
they are not required by 10 CFR 50.72,10 CFR 50.73 or other regulations, i
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3-3.1 Table of Contents The proposed changes to the Table of Contents reflect the deletion of TS.3.1.E and TE.4.4.D and the bases associaied with each specification, reformatting of Section 6, and excluding the bases citations.
The proposed changes to the Table of Contents are administrative only and reflect the proposed changes discussed in this safety evaluation (SE). The removal of the Bases Table of Contents reflects that the bases are controlled separately and are not part of the TS. This is consistent with the STS. Some minor pagination errors on page TS-viii were identified by the staff and corrected after telephone discussion with D. Vincent (NSP) on September 17,1998.
Therefore, the proposed changes to the Table of Contents are acceptable to the staff.
3.2 Maximum Coolant Activity Reort TS 3.1.D.4, Maximum Coolant Activity, currently requires annual reporting requirements in accordance with TS 6.7.A.1.c. The proposed change deletes this reference to annual reporting requirements, since the licensee proposes to delete TS 6.7.A.1.c. The deletion of TS 6.7.A.1.c is discussed in Section 3.17 below. The Maximum Coolant Activity Report is not required to be in the TS under the criteria of 10 CFR 50.36(c)(2)(ii).
The proposed change to TS 3.1.D.4 is administrative only and ensures consistency with the proposed changes to TS 6.7.A.1.c. This change is therefore acceptable to the staff.
3.3 Chemistry The licensee proposes to delete TS 3.1.E, ' Maximum Reactor Coolant Oxygen, Chloiide and Fluoride Concentration," in its entirety. TS 3.1.E provides limits on che,T.ial concentrations in the reactor coolant system (RCS) to protect plant equipment and the pressure boundary. The RCS chemistry limits for maximum reactor coolant oxygen, chloride, and fluoride concentration shall be relocated to the Updated Safety Analysis Report (USAR) by the next USAR update, but no later than June 1,1999. This relocation requirement has been included as a condition in Appendix B to the licenses.
The reactor coolant water chemistry limits on particular chemical properties of the primary coolant, and surveillance practices to monitor those properties, ensure that degradation of the reactor coolant pressure boundary and equipment is not exacerbated by poor chemistry conditions. However, degradation of the reactor coolant pressure boundary is a long-term process, and there are other more direct means to monitor and correct the degradation of the reactor pressure boundary and RCS equipment that are controlled by regulations and TS; for example, in-service inspection conducted in accordance with 10 CFR 50.55a, and primary coolant leakage limits. On this basis, the staff has concluded that the reactor coolant chemistry limits are not required to be in the TS to protect public health and safety and may be relocated to licensee procedures and included in the USAR. The TS is deleted, consistent with STS, since it does not meet the criteria of 10 CFR 50.36(c)(2)(ii) for inclusion in the TS. The staff finds this change acceptable.
. 3.4 Minimum Freauencies for Samolino Tests This proposed change deletes item 7, 'RCS Chemistry," in Table TS.4.1-28, ' Minimum Frequencies for Sampling Tests," to ensure consistency with the change to TS 3.1.E.,
" Maximum Reactor Coolant Oxygen, Chloride and Fluoride Concentration." The licensee proposed removal of the footnote associated with the
- at the bottom of the page.
The staff determined that the footnote should be retained since it is applicable to another entry on the table. The proposed change to Table TS.4.1-28 to delete the entry for RCS Chemistry (CL, F,02) is administrative only and ensures consistency with the deletion of TS.3.1.E as discussed in Section 3.3 of this SE. Table TS 4.1-28, item 7, does not meet the criteria of 10 CFR 50.30(c)(2)(ii) for inclusion in the TS. Therefore, the staff finds this deletion acceptable.
3.5 Residual Heat Removal (RHm System TS 4.4.D, "RHR System," currently requires portions of the RHR system external to the isolation valves at the containment be hydrostatically tested for leakage during each refueling shutdown, visually inspected for leakage, quantifying leakage to ensure that the maximum leakage at 350 psig does not exceed 2 gallons per hour, completing repairs if the leakage limit is exceeded, and shutting down and depressurizing the unit if repairs are not completed within 7 days. The licensee proposes to delete this TS and encompass the requirements in the program referenced in proposed TS 6.5.B, " Primary Coolant Sources Outside Containment."
The details of TS SR 4.4.D on RHR system leakage limits can be deleted because the limits are encompassed in the proposed Administrative Controls Section TS 6.5.B. This change is consistent with STS. TS 4.4.D does not meet the criteria of 10 CFR 50.36(c)(2)(ii) for inclusion in the TS. Accordingly, the TS change is acceptable.
3.6 Samolina of Diesel FuelOo Currently, TS 4.6, " Periodic Testing of Emergency Power System," Section A, " Diesel Generators," item 1.c, requires that at least once a month, for each diesel generator, a sample of diesel fuel from the fuel storage tank is verified to be within the acceptable limits specified in Table 1 of American Society for Testing and Materials (ASTM) D975-77 when checked for viscosity, water, and sediment. The licensee proposes to delete this TS and relocate requirements similar to the STS to proposed TS Section 6.5.K, " Diesel Fuel Oil Testing Program." This relocation requirement has been included as a condition in Appendix B to the licenses. The program shallinclude sampling and testing requirements, and acceptance criteria, all in accordance with the limits specified in Table 1 of ASTM D975-77 when checked for viscosity, water, and sediment. Acceptability of new fuel oil shall be dotermined prior to addition to the safeguards storage tanks. Testing of diesel fuel oil stored in safeguards storage tanks shall be performed at least every 31 days. The provisions of TS 4.0 are applicable to the diesel fuel oil testing programs surveillance frequencies.
The proposed change is consistent with STS for the inclusion of a program for diesel fuel oil testing and is acceptable. Until fuel oil TS are proposed to meet the LCOs and SRs in accordance with the STS, the SRs in the current TS are proposed for deletion and incorporated as additional information in the proposed fu,el oil testing program administrative controls.
. i 3.7 Emeraency Procedures TS 5.1, " Design Features," currently states that TS 6.5.A.7 requires an emergency procedure that necessitates plant shutdown for flood water levels above +692 feet mean sea level (MSL) at the plant site. The emergency procedures will assure the proper erection of flood protection panels and assure an orderly shutdown of the plant and prctection of safety-related facilities.
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This procedure must provide for progressive action levels to prevent the possibility of unsafe plant operation and must include requirements for periodic inspection of flood protection measures. Additionally, emergency procedures prepared in accordance with TS 6.5.A.7 must define actions required for earthquakes, including plant shutdown and inspection if an j
operational basis earthquake is measured at the site.
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i The licensee proposes to delete the description of emergency procedures for floods and
' earthquakes and the criteria for plant shutdown in response to these events since the proposed changes to TS 6.4, " Procedures," requires written procedures shall be established, j
implemented, and maintained covering applicable procedures in Regulatory Guide (RG) 1.33,
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" Quality Assurance Program Requirements," Revision 2, Appendix A, February 1978.
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The details of Design Features TS 5.1 on the emergency procedures for floods and earthquakes can be deleted because the requirements are encompassed in the Administrative Controls Section 6.4 of the TS. This change results in comparable restrictions. The flood level that 3
requires action to be taken to shut down the plant shall be included in the USAR by the next USAR update, but no later than June 1,1999. Accordingly, the staff finds the changes to be j
acceptable.
1 3.8 Resoonsibilities i
j The current title of TS Section 6.1, " Organization,"is being changed to " Responsibility." The first paragraph of the current TS Section 6.1 is revised to conform with STS with the following exceptions. The title " plant manager"is used instead of Plant Superintendent since it is the title currently in use at Prairie Island for the position with overall responsibility. The capitalization on the title " plant manager" has been changed to lower case to indicate that this is a generic title associated with the responsibilities rather than a plant-specific title. These changes are administrative and consistent with the licensee's organization. Therefore, they are acceptable to the staff.
The second paragraph of Section 6.1, added in conformance with STS, provides further description of the plant manager's responsibilities and is acceptable to the staff.
The third paragraph of Section 6.1, added in conformance with STS, provides requirements for the control room command function and is acceptable to the staff.
The content of the Administrative Controls TS 6.1 is editorially updated to reflect current position titles and enhanced with additionalinformation on the plant manager's responsibilities and the control room command function. These TS changes are administrative, are consistent with the improved STS and the licensee's organization, and are acceptable.
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6-3.9 Oraanization - Onsite and Offsite Oroanizations I
Current TS 6.1, " Organization," that includes the following sections:
TS 6.1.A plant manager function, TS 6.1.B Onsite and Offsite Organizations, TS 6.1.C Plam Staff, TS 6.1.D plant staff qualifications, and TS 6.1.E administrative procedures (shift coverage, overtime control),
is proposed to be relocated to TS 6.2, " Organization." TS 6.2 consists of TS 6.2.A, "Onsite and j
Offsite Organization," and TS 6.2.B, ' Plant Staff," to conform with the organization of the STS.
Section 6.2 conforms in content with STS with the following exceptions that are evaluated as
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When both units are collectively under consideration, " plant" had been substituted for " unit."
i This clarifies the TS and is acceptable, Throughout the proposed changes, generic titles describing responsibilities are used. The j
intent of these changes is to allow the licensee to make specific title changes by providing updates to the USAR. Proposed TS 6.2.A.1 states, "the plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall i
be documented in the Updated Safety Analysis Report." The intent of this statement it, to allow i
the licensee to make title changes and provide appropriate documentation in the USAR. This i
provision also applies to the corporate officer position identified in Specification 6.2.A.3.
l Incorporation of organizational titles in the USAR is acceptable to the staff, in that changes are adequately controlled by 10 CFR 50.54(a)(3).
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The current TS 6.2.B.1 takes exception to 10 CFR 50.54 in that, when one unit is operating and j
the other unit is not operating, only two licensed reactor operators are required on site (in i
addition to two senior reactor operators.) Prairie Island proposes to deleto the second senten ;e i.
of TS 6.2.B.1 and thereby clarity conformance with tho requ!rements of 10 CFR 50.54. This j
change is acceptable.
i The content of proposed TS 6.2 is editorially updated to reflect current position titles and terminology. The requirements related to crew con.,msition can be deleted from TS 6.2, because these requirements are adequately addressed in 10 CFR 50.54(k), (I), and (m). The regulations describe the minimum shift composition for operating modes, as well as for cold shutdown and refueling. These requirements are described in the administrative instructions implementing 10 CFR 50.54 and in the Emergency Plan. The staff concludes that the shift j
staffing requirements in 10 CFR 50.54, in conjunction with the organizational responsibilities and authorities retained in the administrative controls, provide adequate control over the plant staffing requirements. These TS changes are consistent with the STS and are acceptable.
The proposed TS 6.2.B.5 will take the place of current TS 6.1.E, which will be deleted. Prairie
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Island currently uses a staff overtime control program that was reviewed and approved by NRC Safety Evaluation under cover letter dated March 17,1983 from D. Vassallo (NRC) to D. Musoif (NSP) and License Amendments 105/98. The wording of proposed TS 6.2.B.5 is consistent l
with one of the STS options and is acceptable.
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3.10 Review and Audit j
The licensee proposes that the review and audit functions associated with the Safety Audit Committee (SAC) and the Operations Committee (OC) specified in existing TS 6.2 be relocated from the TS to the Operational Quality Assurance Plan (OOAP) such that future changes could i
be made pursuant to 10 CFR 50.54(a). Section 13.4, " Operational Review", of NUREG-0800,
- the ' Standard Review Plan" (SRP), provides the acceptance criteria used by the staff to evaluate TS provisions related to the plant staff review of operational activities performed by j
licensee organizational units fulfilling the review and audit function. This acceptance criteria is i
based on meeting the relevant requirements of 10 CFR 50.40(b) as it relates to the licensee being technically qualified to engage in licensed activities, and of Appendix B to 10 CFR Part 50 as it relates to the review and audit functions required by the licensee's OA program.
j Therefore, TS provisions associated with the review and audit function satisfy the criteria in both Section 50.36(c)(5), and Appendix B to 10 CFR Part 50. These provisions do not satisfy
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the criteria for inclusion in TS of 10 CFR 50.36 (c)(2)(ii) and can be relocated to the licensee's O/. program description, consistent with NRC Administrative Letter 95-06. Additionally, the l
following considerations support relocating these items from the TS:
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The licensee has proposed that the Prairie Island SAC function, membership, i
qualifications, meeting frequency, quorum, responsibilities, authority, arid records j
provisions be relocated, verbatim, to Section 21.0, " Prairie Island SAC," of Revision 20 to the OOAP. Subsequent changes associated with SAC requirements will be controlled 3
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effectively under 10 CFR 50.54(a).
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The licensee has proposed that the Prairie Island OC membership, meeting frequency, i
quorum, responsibilities, authority, records, and procedures provisions be relocated, i
verbatim, to Section 22.0, " Prairie Island OC," of Revision 20 to the OQAP. Subsequent changes associated with OC requirements will be controlled effectively under 10 CFR 50.54(a).
This approach is consistent with NRC Administrative Letter 95 06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12,1995, that provides guidance for relocating TS administrative requirements. This approach would j
also result in an equivalent level of regulatory authority while providing for an acceptable i
change control process under the provisions of 10 CFR 50.54 (a)(3). On this basis, the staff has concluded that the review and audit functions identified above are not required to be included in the TS to protect public health and safety and may be relocated to the OQAP.
j 3.11 Spfcial Review and Audit 4
l The licensee proposes to relocate the provisions in the existing TS 6.3, "Special Inspections l
and Auods," to the Fire Protection Program. TS 6.3 requires an annualinspection and audit by qualified personnel and a triennial inspection and audit performed by a qualified fire protection consultant. The licensee will incorporate a 2-year limit on performance-based audit schedules in accordance with American National Standards Institute (ANSI) N 18.7, which is committed to in the licensee's OOAP, and retains the existing frequency for audits of the fire protection program on a fixed basis in accordance with Generic Letter (GL) 88-12, " Removal of Fire Protection Requirements from Technical Specifications." The relocation provides adequate j
controls in accordance with 10 CFR 50.54(a) and is acceptable to the staff.
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3.12. Plant Staff Qualifications Proposed TS 6.3, " Plant Staff Qualifications," is being added to more closely conform with STS.
TS 6.3 includes current TS 6.1.d with one revision. The revision includes current plant practice that personnel performing the function of shift technical advisor (STA) shall maintain an active senior reactor operator license. Prairie Island will continue to commit to RG 1.8," Qualification and Training of Personnel for Nuclear Power Plams," Revision 1, September 1975 and ANSI N18.1-1971 that is a;so endorsed by the regulatory guide, as stated in the licensee's OQAP.
This relocation results in identical restrictions.
The staff finds the change requiring the STA to have a senior reactor operator license acceptable since this is a desirable requirement for those performing the STA function. The staff finds the rewording included in the September 4,1997, submittal acceptable since the wording now conforms with the most recent STS wording. Accordingly, the TS change is administrative and acceptable.
3.13 Safetv Limit Violation TS Section 6.4, " Safety Limit Violation," was previously relocated to TS 2.2 by Amendment Nos.
123/116, issued May 21,1996, and is not addressed by these amendments.
I 3.14 Procedures The licensee proposes to relocate portions of current TS 6.5 to TS 6.4, " Plant Operating i
Procedures," to conform to Section 5.4, " Procedures" of NUREG-1431, Revision 1. The proposed TS 6.4 includes the following sections:
6.4 Procedures, 6.4.A Procedures required by RG 1.33, Rev 2, Appendix A, j
6.4.B EOPs [ emergency operating procedures) per NUREG 0737 and NUREG-0737 Supplement 1,
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6.4.C Quality control for effluent and environmental monitorir.g, 6.4.D Fire protection program implementation, and 6.4.E All programs specified in TS 6.5.
The information in TS 6.4.A inemdes the following procedures that are acceptable to the staff in accordance with RG 1.33, Revision 2, Appendix A as follows:
Current TS 6.5.A.1 is addressed by RG 1.33, Rev. 2, Appendix A, Section 3, Procedures for Startup, Operation, and Shutdown of Safety-Related PWR (Pressurized Water Reactor) System.
Current TS 6.5 A.2 is addressed by RG 1.33, Appendix A, Section 2, General Plant Operating Procedures, Items k and I and Section 6, Procedures for Combating Emergencies and Other Significant Events, item x.
Current TS 6.5.A.3 is addressed by RG 1.33, Rev. 2, Appendix A, Section 2, General Plant Operating Procedures, item c; Section 5, Procedures for Abnormal, Offnormal, or 4
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Alarm Conditions; and Section 6. Procedures for Combating Emergencies and Other Significant Events.
Current TS 6.5.A.4 is addressed by RG 1.33, Rev. 2, Appendix A, Section 8, Procedures for Control of Measuring and. Test Equipment and for Surveillance Tests, Procedures, and Calibrations, item B.
Current TS 6.5.A-6 is addressed by RG 1.33, Rev. 2, Appendix A, Section 6, Procedures for Combating Emergencies and Other Significant Events, item w. The requirement to shut down the plant if the flood level reaches 692 feet above MSL will be relocated to the USAR.
Current TS 6.5.B is addressed by RG 1.33, Rev. 2, Appendix A, Section 7, Procedures for Control of Radioactivity, item 7, and the requirements of 10 CFR Part 20.
Current TS 6.5.C, ' Maintenance and Test," is generally included in RG 1.33, but the specific list will be relocated to the OOAP.
i Current TS 6.5.A.5 and TS 6.5.B.3 will be relocated to the Emergency Plan, since the requirement for written procedures that implement the Emer0ency Plan are specified in 10 CFR J
50.54(q) and (t), and 10 CFR Part 50, Appendix E, Section V; the airborne iodine measurement j
program is embodied in the Emergency Plan; and changes to the Emergency Plan are controlled by 10 CFR 50.54(q) and 50.4. This relocation is consistent with STS and is acceptable to the staff.
Current TS 6.5.A 8 and TS 6.5.D were relocated by TS Amendment Nos.122/115, issued January 24,1996.
By letter dated April 4,1996, NSP submitted a supplement further clarifying its previous submittals. The revisions included TS 6.4.8 concerning the requirements for EOPs that now includes the base document NUREG-0!'37 in addition to NUREG 0737, Supplement 1. The staff finds this acceptable sin:;e the wording now conforms to STS.
The licensee proposes to revise current TS 6.5, " Plant Operating Procedures," to conform to Section 5.4, " Procedures" of NUREG-1431, Revision 1. The revised section, TS 6.4,
" Procedures," would include only procedural requirements for activities addressed in NUREG-1431, and all other procedure-related provisions currently in TS 6.5 would be relocated, verbatim, to the OOAP, Section 7.3, " Procedures." The relocation provides adequate controls in accordance with 10 CFR 50.54(a), and is acceptable to the staff.
TS 6.5 requirements related to the plant Emergency Plan would continue to be controlled through 10 CFR 50.54(q) and 50.54(t) in accordance with GL 93-07, " Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans." Additionally, the licensee proposed that TS 6.5.C, " Temporary Cnanges to Procedures," be relocated, verbatim, to the OOAP, Section 8.4.4, " Prairie Island Procedure Control." Therefore, subsequent changes to these provisions would be controlled pursuant to 10 CFR 50.54(a).
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f Based on the above, the staff concludes that the proposed TS 6.4 would conform to the format and content of NUREG 1431, Revision 1, and that procedural requirements currently in TS 6.5, but not addressed in STS, could be relocated as previously described to either the OOAP or the Emergency Han. Therefore the staff finda this change acceptable.
^ 3.15 Proarams and Manuals J
Proposed TS Section 6.5, Programs and Manuals, includes the following:
i 6.5.A This section consists of current TS 6.5.E, "Offsite Dose Calculation Manual."
l 6.5.B Current TS 6.5.B.2, " Primary Coolant Sources Outside Containment," is relocat ' l to this section. This section also encompasses current TS 4.4.D, i
" Residual Heat Removal Tests."
l 6.5.C Current TS 6.5.B.3 and TS 6.5.B.4, " Post Accident Sampling," are relocated to this section.
6.5.D Current TS 6.5.H, " Radioactive Effluent Controls Program," is relocated to this section.
6.5.E Current TS 6.6.B.8, " Component Cyclic or Transient Limit," is relocated to this section.
6.5.F Current TS 6.5.F " Security," is being deleted since the program is covered by 10 CFR 50.54(p)(1) and 10 CFR 73.55. The licensee proposes reserving this section for future use.
6.5.G Current TS 6.5.G, " Temporary Changes to Procedures," is being deleted from the TS and included in the OOAP. The licensee proposes reserving this section for future use. The relocation provides adequate controls in accordance with 10 CFR 50.B4(a), and is acceptable to the staff.
6.5.H Current TS 6.5.H. " Radioactive Effluent Controls Program," is being relocated to 6.5.0. The licensee proposes to reserve this section for the Steam Generator Tube Surveilfunce Program that currently is included in TS 4.12.
6.5.1 The licensee proposes to reserve this section for the ventilation filter testing program that is currently covered in TS 4.4,4.14, and TS 4.15.
6.5.J ~
This section will consist of the current TS 6.5.1, " Explosive Gas and Storage Tank Radioactivity Monitoring Program."
6.5.K The Diesel Fuel Oil Testing Program will be relocated from current TS 4.6.A.1.c 6.5.L TS Bases Control Program is new.
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a f i 6.5.M Containment Leakage Rate Testing Program is relocated from current l
TS.6.5.J l
i Proposed TS 6.5.A, TS 6.5.B, TS 6.5.C, TS 6.5.D, TS 6.5.E TS 6.5.J, TS 6.6.K, and TS 6.5.M j
are relocations of exhting requirements and are acceptable to the staff. The licensee proposes a correction to the quantity of radioactivity contained in each gas storage tank from 78,000 to i
78,800 curies. This change corrects a typographical error introduced in TS 6.5.1.2 during Amendment Nos.122/115, issued January 24,1996, and is acceptable to the staff.
i The licensee proposed to relocate the requirements for both the review and approval process in 4
TS 6.8.2, and the temporary change process for procedures in TS 6.8.3, to the OOAP. The relocation provides adequate controls in accordance with 10 CFR 50.54(a), and is acceptable to
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the staff. The revised TS will include a specific requirement that written procedures be established, implemented, and maintained, and a requirement for procedure control is j
mandated by 10 CFR Part 50, Appendix B, Criterion 11 and Criterion V. ANSI N18.7-1976, an i
NRC staff-endorsed document used in the development of many licensee QA plans, also contains specific provisions related ta procedures. The licensee has incorporated certain j
provisions of ANSI N18.71976 and ANSI N45.2-1971 in the OOAP, as stated in OOAP Section l
1.3, ae a means to comply with 10 CFR Part 50, Appendix B. ANSI N18.7-1976, Section 5.2.2 discws procedure adherence. This section clearly states that procedures shall be followed, j
and the requirements for use of procedures shall be prescribed in writing. ANSI N18.7-1976
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also discusses temporary changes to procedures and requires review and approval of procedures to be defined. ANSI N18.7-1976, Section 5.2.15, describes the review, approval, and control of procedures. This section states that the licensee's OOAP is to provide measures to control and coordinate the approval and issuance of documents, including changes thereto, j
that prescribe all activities affecting quality. The section further states that each procedure shall be reviewed and approved prior to initial use. The required reviews are alco described. ANSI j
N45.21971, Section 6, also prescribes procedural controls for activities affecting quality, i
The provisions in the OQAP implement 10 CFR Part 50, Appendix B, Criteria V and VI, pertaining to the control of documents such as instructions, procedures, and drawings, l
including changes thereto. The procedure review and approval functions currently in TS define an administrative framework to ensure that document are reviewed for adequacy and approved for release by authorized personnel. The required control of these processes in 10 l
CFR Part 50, Appendix B, Criteria V and VI and the revised OOAP is considered to be redundant and functionally equivalent to the provisions currently in TS. The stati has l
determined that the procedure review and approval functions are adequately addressed by 10 CFR Part 50, Appendix B, and the related OQAP changes. Based upon the relocation of the l
procedure review provisions to the OOAP, it is not necessary to include redundant or additional i
requirements in the TS administrative controls.
1 The licensee will continue to implement an OQAP in accordance with the requirements of l
10 CFR Part 50, Appendix B, Criteria V and VI, that requires appropriate controls for the review j
and approval of procedure changes. The staff concludes that these regulatory requirements provide sufficient control of these provisions and removing them from the TS is acceptable.
Future changes to the review and approval process for procedure changes can be adequately controlled under 10 CFR 50.54(a).
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i The licensee proposes to add TS 6.5.L. " Technical Specifications Bases Control Program," that
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generally follows the guidance of STS and is acceptable to the staff. In TS 6.5.L.1, the licensee proposes to correct a typographical error. The phrase, " Bases or the [TS)..." should read,
- Bases of the [TS)..." The correction is editorial and is acceptable to the staff.
o j
3.16 Plant Ooeratina Records a
j The licensee proposes to relocate, verbatim, the record retention requirements in TS 6.6, ' Plant i
Operating Records," to OQAP Section 19.12, " Prairie is!and Operating Records," in accordance with Administrative Letter 95-06. Once relocated to the OQAP, these record retention requirements are adequately addressed by 10 CFR 50.54(a). In addition to specific record retention commitmente in the OOAP, the licensee relies upon its OOAP commitments to ANSI l
N18.7-1976, ' Administrative Controls and Quality Assurance for the Operational Phase of j
Nuclear Power Plants," and ANSI N45.2.9-1974, " Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants," (as endorsed by
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RG 1.88, " Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance l,
Records," Revision 2) to satisfy the regulatory requirements of 10 CFR Part 50, Appendix B,
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Criterion XVil," Quality Assurance Records."
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Since current TS 6.6 is being relocated, the licensee proposes to delete the specification in its entirety based on duplication of OOAP commitments and the requirements of 10 CFR Part 20, Subpart L, and 10 CFR 50.71. This relocation is consistent with STS.
i i
4 The licensee proposed that the requirements for record retention in TS 6.10 be relocated j
because they are adequately addressed by the OOAP. The provisions in the OOAP implement 10 CFR Part 50, Appendix B, Criterion XVil pertaining to the maintenance of records related to I
J activities affecting quality. The required controls related to record retention specified in various regulations and the provision incorporated into the OOAP are considered to be redundant to the requirements currently in TS. The staff has determined that record retention requirements are adequately addressed by 10 CFR Part 50, Appendix B, Criterion XVll and the related OOAP commitments. Based upon the relocation of the record retention provisions to the OOAP, it is not necessary to include redundtnt or additbnal requirements in the TS administrative controls.
The relocation provides adequate controls in accordance with 10 CFR 50.54(a) and is acceptable to the staff.
The staff concludes that the regulatory requirements under 10 CFR Part 50, Appendix B, provide sufficient control of the plant records, and sufficient regulatory controls exist for future changes to the program pursuant to 10 CFR 50.54(a). In addition, other regulations such as j
10 CFR Part 20, Subpart L, and 10 CFR 50.71 require the setention of certain records related to operation of the nuclear plant. The staff concludes that these regulatcry requirements provide sufficient control of these recordkeeping provisions and removing them from the TS is acceptable.
3.17 Reportina Reauirements Proposed Section 6.6, Reporting Requirements, will include current TS Section 6.7 as detailed in the following evaluation. The evaluation discusses those Saction 6.7 requirements that are relocated, deleted, and not provided in accordance with STS.
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13-I The STS Administrative Controls specifies Section 5.6," Reporting Requirements." The licensee proposes the following sections under TS 6.6, " Reporting Requirements:"
A. Occupational Exposure Report, 3;
B. Annual Rodiological Environmental Monitoring Report, C. Radioactive Effluent Report, D. Monthly Operating Report, E. Core Operating Limits Report (COLR),
F. Pressure and Temperature Limit Report.
The licensee proposes to relocate current TS 6.7.A.1.a " Occupational Exposure Report," and 4
its associated footnote and to revise the section to correspond to STS and include the section i
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as proposed TS 6.6.A.
The licensee proposes to relocate current TS 6.7.A.1.b," Report of Safety and Relief Valve 4[
Failures and Challenges," to the proposed TS 6.6.D, " Monthly Operating Report."
i The licensee proposes to relocate current TS 6.7.C.1, " Annual Radiological Environmental l
Monitoring Report," to proposed TS 6.6.B. The proposed TS 6.6.S includes a clarification to the i
word 6ng of the distance from one reactor to the sample location. The proposed wording is from "the site" to the sampling locations. As explained in the submittal, the center of the reactor site which is less than 200 feet from the centerline of either reactor will be used. The licensee also proposes to elirninate the word "all" from "a map of all sampling locations," since the wording is superfluous, 3
i Current TS 6.7.A.4, " Radioactive Effluent Report," is proposed to be relocated to TS 6.6.C.
j
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The licensee proposes to relocate current TS 6.7.D, "Special Reports," to proposed TS 6.6.D,
" Monthly Operating Report." An incorrect reference regarding whom to submit the report is corrected.
Current TS 6.7.A.6, " Core Operating Limits Report," is proposed to be relocated to TS 6.6.E.
The relocation of current TS 6.7.A.1.a 6.7.A.1.b,6.7.C.1,6.7.A.4,6.7.D and 6.7.A.6 to proposed TS 6.6.A 6.6.B,6.0.0,6.6.D, and 6.6.E is administrative and the corrections made j
are acceptable.
The licensee proposes to delete the following reports included in current TS 6.7:
t Current TS 6.7.A.1.c, " Primary Coolant lodine Spike Report," is deleted because the report is unnecessary. The original purpose of the report was to provide to the NRC baseline data on core iodine levels in the commercial nuclear industry for use in l'
postulating accident lodine releases. With the maturing of the industry, this data is well established and this report is unnecessary, in addition, serious degradation of a fission i
product barrier is required to be reported by 10 CFR 50.73. The deletion of this report is
~
administrative and does not affect plant operation.
Current TS 6.7.A.2, Startup Reports, is deleted because the report is unnecessary.
Startup Reports, as required by TS 6.7.A.2, are required when an operating license is e
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received, plant power level is increased by license amendment, fuel of a different design or manufacturer is installed, or modifications are performed which significantly alter the i
nuclear, thermal, or hydraulic performance of the plant. All of these plant changes are l
accompanied by specific NRC authorization, and requirement for a report would appropriately be addressed in the concomitant TS or license condition. The Startup
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Report is not required to ensure safe plant operation. The approved 10 CFR Part 50, j
Appendix B, QA Plan, and FSAR startup testing program provide assurance that the affected activities are adequately performed and that appropriate corrective actions, if required, are taken.
4 Current TS 6.7.A.5, Annual Summaries of Meteorological Data, is being deleted, consistant with STS.
Current TS 6.7.D, Special Reports, is being deleted, consistent with STS.
l
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Over the last several years, there were several initiatives to reduce unnecessary administrative 1
burdens associated with reporting requirements, while retaining an appropriate level of publicly i
accessible information flow. The staff has concluded that the reports are unnecessary because tha information is duplicated in other required reports, such as reports required by the Offsite Dose Calculation Manual, Radioactive Effluent Controls Program, and Radiological Environment Monitoring Program, or the reports are not required for the safe operation of the plant. In addition, tne notification requirements in 10 CFR 50.72 and 50.73 for plant conditions
]
that may be safety significant or warrant emergency response address these matters.
Accordingly, the staff has concluded that the Primary Coolant lodine Spike Report, Startup Reports, Annual Summaries of Meteorological Data, and Special Reports are unnecessuy because the information is duplicated in other required reports or the information is not required for the safe operation of the plant.
l TS 6.7.C.3, Other Environmental Reports, is not required for safe operation of the plant and is j
deleted consistent with STS.
l The licensee proposes that the requirement in TS 6.7.B that the Commission be notified of all reportable events, be deleted from the TS on the basis that this requiremant is adequately addressed in the regulations. Requirements are provided in 10 CFR 50.73(a)(2) for the licensee to submit a Licensee Event Report (LER) for all reportable events specified in 10 CFR 50.73. The staff concludes that these reporting requirements are sufficient and removing the duplicative reporting requirements from the TS is acceptable.
Reports included by STS, but not included in this subinittal are:
l Proposed TS 6.6 does not include an EDG [ emergency diesel generator) failure report
]
since this requirement is not included in current TS.
Proposed TS 6.6 does not include provision for reporting of Post Accident Monitoring Instrumentation failures because reporting requirements are included in current TS 3.15.
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' i Proposed TS 6.6 does not Jnclude a steam generator tube inspection report requirement since current TS 4.12, " Steam Generator Tube Surveillance," Item E, " Reports," is being retained.
4 l
Since there is no proposed change to the current TS, no discussion is required. However, to meet the format of the STS, proposed changes to address these reporting requirements are expected when revisions to TS Sections 3/4 are submitted.
3.18 Hiah Radiation Area Current TS 6.5.B.1 is relocated to proposed TS 6.7, High Radiation Areas, consistent with the format of the STS administrative controls section. The licensee proposes to add to TS 6.7.A "or equal to' to the definition of high radiation area as follows: 'each high radiation area, as defined in 10 CFR Part 20, in which the intensity of radiation is greater than 100 mrem /hr but less than or equal to 1000 mrem /hr...." Similarly, the licensee proposes to delete 'or equal to" prior to 1000 mr/hr from TS 6.7.B so that it reads as follows: " areas with radiation levels greater than 1000 mrem /hr...."
The proposed changes are editorial and reflect the wording in the STS. The staff finds the changes acceptable.
3.19 Chemistry Bases The licensee proposes to delete the current TS Bares,3.1.E. " Reactor Coolant System Maximum Coolant Oxygen, Chloride, and Fluoride Concentration," since LCO 3.1.E is being deleted.
The proposed deletion of TS Bases,3.1.E is administrative only and is consistent with the deletion of TS.3.1.E as discussed in Section 3.3. The staff finds the proposed change acceptable.
3.20 RHR System Bases The licensee proposes to delete the Bases for current TS 4.4.0, ' Residual Heat Removal System," since TS 4.4.D is being deleted. The provisions of TS 4.4.D are to be relocated to proposed TS 6.5.B.
As discussed in Section 3.5, the staff found the proposed change to TS 4.4.D to be acceptable.
The deletion of TS Bases 4.4.D provides consistency with the proposed changes. Accordingly, the TS change is administrative and acceptable to the staff.
3.21 Summarv The staff has evaluated the relocation of some of those administrative controls to the OQAP.
Based on this evaluation, the staff has concluded that (1) the proposed Prairie island TS 6.4,
' Procedures," conforms to the format and content specified in NUREG-1431, Revision 1, and to the requirements of 10 CFR 50.36(c)(5); (2) the proposed relocation of OA related administrative control provisions (Section 6.2, " Review and Audit," Subsection C, " Temporary Changes to Procedures," of Section 6.5, " Plant Operating Procedures,' and Section 6.6, ' Plant
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\\ Operating Records") from the TS to the OQAP satisfies Administrative Letter 95-06 p*ovisions and 10 CFR 50.36 requirements and, once relocated to the OOAP and controlled puraant to 10 CFR 50.54(a), constitute the bases for the licensee's continued compliance with the requirements of Appendix B to 10 CFR Part 50; and (3) Revision 20 to the OQAP, dated July 14,1997, continues to comply with the criteria of Appendix B to 10 CFR Part 50 in
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accordance with NUREG-0800 (SRP Sections 13.4 and 17.2).
In conclusion, the existing TS requirements relating to administrative controls that have been deleted or relocated are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act and are governed by other regulations such as 10 CFR 50.4,50.47, 50.48,50.54,50.72,50.73, Part 50 Appendix A, Part 50 Appendix B, Part 50 Appendix E, Part 20, Part 55, or 73.55. Thus, the relocated provisions do not meet the intent of the four criteria described in the Commission's Final Policy Statement and included in 10 CFR 50.36(c)(2). In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.59,50.54(a),
(k), (I), (m), (p), (q), and (t) and 73.55 to control future changes to the relocated provisions.
Accordingly, the staff has concluded that these requirements may be relocated from the TS to the above specified documents. Finally, the staff concludes that the administrative controls requirements remaining in the TS satisfy the license content specified in 10 CFR 50.36(c)(5).
4.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendments. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
Tne amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that these amendments involve no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued proposed findings that the amendments involve no significant hazards consideration and there has been no public comment on such findings (61 FR 28618). The amendments also change recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10). Pursuant to 10 CFR 51.22(b),
no environmental impact statement er environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussert 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, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: T. Tjader J. Peralta C. Goodman Date: December 7,1998
a-w t
R. O. Anderson December 7, 1998 A copy of our related Safety Evaluation is also enclosed. The notice of issuance will be included in the Commission's biweekly Federa/ Register notice.
Sincerely, ORIGINAL SIGNED BY Carl F. Lyon, Project Manager Project Directorate lll-1 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306 1
Enclosures:
- 1. Amendment No. 141 to DPR-42 i
- 2. Amendment No. 132 to DPR-60
- 3. Safety Evaluation cc w/ encl:
See next page QlSTRIBUTj_QN:
Docket File (50-282, 50-306)
PUBLIC PDill-1 Reading i
E. Adensam C. Jamerson T.J. Kim (2)
C.F. Lyon OGC l
G. Hill (4) 1 W. Beckner i
T. Tjader J. Peralta C. Goodman ACRS B. Burgess, Rill SEDB (TLH3)
DOCUMENT NAME: G:\\WPDOCS\\Pl95130.AMD
- SEE PREVIOUS CONCURRENCE To receive a copy of this document, indicate in the box C= Copy w/o attachment / enclosure E= Copy with attachment / enclosure N = No co)y OFFICE PM:PD31 E
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BC:EMCB BC:HQMB BC:DRCH FLyon:db [
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NAME
- JStrosnider
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DATE 11/13 /98 11/ A /98 11/16/98 g 03/12/98 11/25/97 12/16/97 OG hk PD:PD31 b
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