ML20203F069
| ML20203F069 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 07/15/1986 |
| From: | Musolf D NORTHERN STATES POWER CO. |
| To: | |
| Shared Package | |
| ML20203F055 | List: |
| References | |
| TAC-62137, TAC-62138, NUDOCS 8607300090 | |
| Download: ML20203F069 (16) | |
Text
o o 'o UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket No. 50-282 50-306 REQUEST FOR AMENDMENT TO OPERATING LICENSE NOS. DPR-42 & DPR-60 License Amendment Request Dated July 15, 1986 Northern States Power Company, a Minnesota corporation, requests authorization for changes to the Technical Specifications as shown on the attachments labeled Exhibit C. Exhibit A is the Evaluation of Proposed Changes to the Technical Specifications. Exhibit B is the Proposed Changes Marked Up on Existing Techni-cal Specification Pages. Exhibit C is the Revised Technical Specification Changes. Exhibits D and E contain information supporting the requested changes.
This letter contains no restricted or other defense information.
NORTHERN STATES POWER COMPANY By M kw 4 David Musolf Manager-NuclearSupportServices}
On this /I M day of /J44./.1 - , //[4 before me a notary public in and l
for said County, personal}f apq{/ared David Musolf, Manager - Nuclear Support Services, and being first duly sworn acknowledged that he is authorized to execute this document on behalf of Northern States Power Company, that he knows the contents thereof and that to the best of his knowledge, information and belief, the statements made in it are true and that it is not interposed for delay.
8607300090 860715 PDR ADOCK 05000282 p PDR db '
d
- m e:- .:::::.- .:: :::...:,
ll, g.g DODY A. BROSE ll . os idOTARY PUDLIC - MINNESOTA lU ll HENNEPIN COUNTY i
- My Commission Dpires Dec. 26,1989 ;
':^^..: ::::::^^~..^.::~~ ::::::::^:::
Exhibit A Prairie Island Nuclear Generating Plant License Amendment Request Dated July 15, 1986 Evaluation of Proposed Changes 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 Licenses DPR-42 and DPR-60 hereby propose the following changes to Appendix A, Technical Specifications:
- 1. Heatup and Cooldown Specification Changes
- a. Heatup/Cooldown Curve Revision Proposed Change Replace Figures TS.3.1-1 and TS.3.1-2 with the revised figures included in Exhibit B.
' Reason For Change The exi' sting reactor coolant system heatup and cooldown curves are only valid for ten effective full power years (EFPY) of plant operation. Prairie Island Unit 1 (lead unit) is expected to reach 10 EFPY by early October, 1986. The revised curves are being submitted to provide reactor coolant system heatup and cooldown limitations valid to 15 EFPY.
Safety Evaluation and Determination of Significant Hazards Considerations The proposed change to the Operating License has been evaluated to determine whether it constitutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed heatup and cooldown curves were calculated using the i techniques described in the Summary Technical Report of Analysis of Capsule R from the Prairie Island Unit 1 Reactor Vessel Radiation Surveillance Program submitted to the Commission by letter dated April 25, 1986, and conform to the requirements of 10 CFR Part 50, Appendix G. The curves are based on an RTNDT (reference nil-ductility temperature) equivalent to 15 EFPY and are in all cases more restrictive than the existing curves.
Because the proposed heatup and cooldown curves conform to the i requirements of 10 CFR Part 50, Appendix G, and are more A-1
P__, e restrictive than the existing curves, they will provide adequate margins of safety for the reactor coolant system pressure boundary during any condition of normal operation, including anticipated operational occurrences and system hydrostatic tests to which the pressure boundary msy be subjected to during the 15 EFFY service period and will not result in a significant increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibility oS a new or different kind of accident from any accident previously analyzed.
The proposed heatup and cooldown limitations involve only the recalculation of the existing curves to reflect the reactor vessel fluence anticipated for 15 EFPY, and as such no different type of accident is created. No safety analyses are affected.
The accident analyses presented in the Updated Safety Analysis Report remain bounding.
- 3. The proposed amendment will not involve a significant reduction in the margin of safety.
Because the proposed heatup and cooldown curves conform to the requirements of 10 CFR Part 50, Appendix G they will provide a margin of safety for the reactor coolant system pressure boundary equivalent to that found in the existing curves. There will be no reduction in the margin of safety.
The Commission has prpvided guidance (March 6,1986 Federal Register) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists by providing certain examples of amendments that will likely be found to involve no significant hazards considerations. The changes to the Prairie Island yechnical Specifications proposed in this amendment request are equivalent to NRC example (ii), because they involve changes that constitute an additional limitations, restrictions or controls not presently included in the Technical Specifications.
Based on this guidance and the reasons discussed above, we have concluded that the proposed heatup and cooldown curve revisions do not involve a significant hazards consideration.
- b. Change to Section 3.1.B.1 Proposed Change Delete "for the first full power service period" from paragraph 3.1.B.1 on page TS.3.1-4 Reason For Change The existing reactor coolant system heatup and cooldown curves are being replaced by curves valid te 15 EFPY. The reference in paragraph 3.1.B.1 to the first full power service period will no longer be valid. The phrase is being deleted rather than updated because such guidance on the applicability of the heatup and cooldown A-2
9 ,o curves is not neces.sary in Section 3.1.B.1 since the revised curves are clearly marked with respect to the applicable period of allowed operation.
Safety Evaluation and Determination of Significant Hazards Considerations The proposed change to the Operating License has been evaluated to determine whether it constitutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The phrase being deleted only provided guidance on the allowed period of operation for the heatup and cooldown curves, information which is also provided on the heatup and cooldown curves. Its deletion will have no impact on plant operation and as such will not result in any increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.
As stated above, the phrase being deleted cnly involves guidance with respect to the applicability of the heatup and cooldown curves. This information will still be provided on the revised heatup and cooldown curves and as such no different type of accident is created. No safety analyses are affected. The accident analyses presented in the Updated Safety Analysis Report remain bounding.
- 3. The proposed amendment will not involve a significant reduction in the margin of safety.
Because the guidance on the applicability of the heatup and cooldown curves being deleted from Section 3.1.B.1 will still be provided on the revised curves, there will be no effect on the '
plant's margin of safety.
The Commission has provided guidance (March 6,1986 Federal Register) l concerning the application of the standards in 10 CFR 50.92 for l determining whether a significant hazards consideration exists by providing certain examples of amendments that will likely be found to involve no significant hazards considerations. The change to the Prairie Island Technical Specifications proposed in this amendment request is equivalent to NRC example (i), because it involves a purely administrative change to Technical Specification:.: Based on this guidance and the reasons discussed above, we have ecncluded that the proposed change does not involve a significant hazards consideration, s
e i A-3 .
- c. Heatup/Cooldown Limitations Bases Changes Proposed Change The bases to Technical Specification Section 3.1.B are being modified as shown on pages TS.3.1-7 and TS.3.1-8 in Exhibit B. Pages TS.3.1- 2A, 3, 3A, 4, 5, and 6 have been renumbered to pages TS.3.1-3 through 8 to accommodate the revised bases.
Reason For Change The Bases to Section 3.1.3, as presently written, are overly detailed and difficult to understand, and do not accurately reflect the analyses used in the development of the new heatup and cooldown curves. They have been rewritten to eliminate the inaccuracies and to simplify the description of the heatup and cooldown curve development to a level more appropriate for the Technical Specifications.
A reference to the USAR has been added and a detailed discussion of the development of the heatup and cooldown curves will be incorporated into the USAR as part of the next revision. Additional information related to the bases for the criticality limits and the ASME Code Section XI Inservice Test Limits has also been added.
Safety Evaluation and Determination of Significant Hazards Considerations The proposed change to the Operating License has been evaluated to determine whether it constitutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in SectLon 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes involve only the modification of the bases for the heatup and cooldown curves. They do not modify any operating limits and will have no impact on plant operation, and as such will not result in any increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.
As stated above, the proposed change only involves the modification of the bases for the heatup and cooldown curves, plant operation is not affected. Thus, no different type of accident is created. No safety analyses are affected. The accident analyses presented in the Updated Safety Analysis Report remain bounding.
- 3. The proposed amendment will not involve a significant reduction in the margin of safety.
Because the proposed changes correct inaccuracies in the heatup and cooldown curve bases and make them more understandable to the A-4
9 ,,
f.
individuals.using them, there will be no reduction in the plant's margin of safety.
The Commission has provided guidance (March 6,1986 Federal Register) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists by providing certain examples of amendments that will likely be found to involve no significant hazards considerations. The change to the Prairie Island Technical Specifications proposed in this amendment request is equivalent to NRC example (1), because it involves a purely administrative change to Technical Specifications. Based on this guidance and the reasons discussed above, we have concluded that the proposed modification to the bases for the heatup and cooldown curves does not involve a significant hazards consideration.
- d. Removal of Tables and Figures Proposed Change Delete Table TS .3.1 - 1, Table TS .3.1 - 2, Figure TS.3.1-3 and Figure TS.3.1-4 and delete the references to these tables and figures in the bases for Section 3.1.B and on pages TS-ix and TS-x.
Renumber Table TS.3.1-5 to be Table TS.3.1-3. Change references to this table on pages TS-x, TS.3.1-ll, 12 and 13.
Reason For Change .
The data provided in the tables and figures being deleted is used in the development of the heatup and cooldown curves. They are not operating limits, and have no impact on day to day plant operation and as such should be deleted from the Technical Specifications.
Tables TS.3.1-1 and TS.3.1-2 contain unirradiated reactor vessel toughness data which is more appropriate for the USAR than the Technical Specifications. These tables are being incorporated into the to the USAR as part of Revision 4 which will be distributed in July 1986.
Figure TS.3.1-3, which is a set of curves showing the effect of fluence and copper content on the shift of RTNDT, is no longer valid and has been replaced by Figure 1 of Regulatory Guide 1.99, Revision 1 in the development of the heatup and cooldown curves. Figure TS.3.1-3 is being deleted.
Figure TS.3.1-4, which shows the fast neutron fluence cs a function of full power service life, is no longer valid. The curves shown on Figure TS.3.1-4 were updated as part of the recent analysis of Unit 1 Surveillance Capsule R. The updated curves, which were utilized in the development of the heatup and cooldown curves, are provided in Figure A-2 of the capsule analysis summary technical report
. referenced in item 1.a above. Like the tables discussed ab,ve, Figure TS.3.1-4 does not contain information pertinent to daily plant operation, it only contains data used in the development of the heatup and cooldown curves, which is more appropriately contained in 1
A-5 l
9 9 the USAR. Figure TS.3.1-4 is being deleted and Figure A-2 from the Unit 1 Surveillance Capsule R analysis technical summary report is being incorporated into the USAR as part of Revision 4.
Safety Evaluation and Determination of Significant Hazards Considerations The proposed chcnge to the Operating License has been evaluated to determine whether it constitutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes involve the deletion of data utilized in the development of heatup and cooldown curves which is provided for information only and as such should not be located in the Technical Specifications. Deletion of this material will not impact any operating limits or affect daily plant operation and therefore will not result in any increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.
As stated above, the proposed changes will not impact any operating limits or the daily operation of the plant. Thus, no differene type of accident is created. No safety analyses are affected. The accident analyses presented in the Updated Safety Analysis Report remain bounding.
- 3. The proposed amendment will not involve a significant reduction in the margin of safety.
As stated above, the material being deleted is provided only for information and has no impact on the day to day safe operation of the plant. The Technical Specifications will be simplified and improved, and thus plant safety enhanced, by the removal of this unnecessary material. There will be no reduction in the plant's margin of safety.
The Commission has provided guidance (March 6,1986 Federal Register) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists by providing certain examples of amendments that will likely be found to involve no significant hazards considerations. The change to the Prairie Island Technical Specifications proposed in this amendment request is equivalent to NRC example (1), because it involves a purely administrative change to Technical Specifications. Based on this guidance and the reasons discussed above, we have concluded that the proposed change does not involve a significant hazards consideration.
A-6
! /
j
- 2. Radiation Environmental Monitoring Program Changes
- a. Correction of Table References Proposed Changes In Specification TS.4.10.A.4 on page TS.4.10-1, change the references to Table 3.12-2 and Table 4.10-2 to Table TS.4.10-3.
Reason for Changes This changes corrects two table numbers.
Safety Evaluation and Determination of Significant Hazards Considerations The proposed change to the Operating License has been evaluated to determine whether it constitutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change corrects incorrect references and as such will not result in any increase in the probability or consequences of an accident previously evaluated. .
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.
The proposed change corrects incorrect references and as such no different type of accident is created. No safety analyses are affected.
- 3. The proposed amendment will not involve a significant reduction in the margin of safety.
Since this change corrects incorrect references, there will be no reduction in the margin of safety.
The Commission has provided guidance (March 6,1986 Federal Register) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists by providing certain examples of amendments that will likely be found to involve no significant hazards considerations. The changes to the Prairie Island Technical Specifications proposed in this amendment request are equivalent to NRC example (1), because they involve purely administrative changes to the Technical Specifications.
For the reasons discussed above, we have concluded that the proposed changes do not involve a sir 3nificant hazards consideration.
A-7
O s
- b. Corn Environmental Sampling Proposed Changes Change the sampling requirements for corn in Section 4.c, of Table TS.4.10-1 (page 4 of 4) per the attached Exhibit B. Rather than requiring annual sampling of corn from the " highest D/Q farm and one from 10-20 miles" sampling will be required annually from "any field that is irrigated by water into which liquid plant wastes have been discharged." This sampling will be done by methods outlined in the ODCM. The draft ODCM change is attached as Exhibit D.
Reason for Changes The initial environmental Radiation Sampling Program at Prairie Island specified sampling of agricultural crops taken from river water irrigated fields located downstream from the plant discharge.
Corn was the crop frequently grown on fields irrigated with water pumped from the Mississippi River. Over a period of time, a uniform process of deep well irrigation has been developed in the area and the use of river water for this purpose has been discontinued. The collection of corn samples is no longer a valid monitor to determine the impact of liquid releases of radioactive material into the river.
When the radiological environmental technical specifications were revised to conform to 10 CFR Part 50 Appendix I, and 40 CFR Part 190 on October 21, 1982, corn samples were erroneously carried over in the program by Northern States Power, with a high D/Q location .
specified for sampling. The land use census specified in the Technical, Specifications does not identify high D/Q corn locations.
The proposed changes are designed to resolve this conflict.
Safety Evaluation and Determination of Significant Hazards Considerations The proposed change to the Operating License has been evaluated to determine whether it constitutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The intent of this requirement was to monitor for effects of plant radioactive waste discharges on crops irrigated with river water. The proposed requirement will meet the intent of the original requirement, and as such will not result in any increase in the probability or consequences of an accident previously ;
evaluated.
l
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.
The proposed requirement will meet the intent of the original requirement and as such no different type of accident is created.
No safety analyses are affected.
A-8
- /
- 3. The. proposed amendment will not involve a significant reduction in the margin of safety.
This change only affects the Environmental Monitoring Program and as such will have no effect in the margin of safety. {
For the reasons discussed above and because similar changes were ,
approved for the Monticel'a Nuclear Generating Plant (See NRC Safety l Evaluation Report dated 3/13/86), we have concluded that the proposed l changes do not involve a significant hazards consideration. l
- c. Iodine Environmental Monitoring Proposed Changes Change Table TS.4.10-2 (Pages 1 and 2 of 2) so that it specifies that the lower limit of detection of Iodine-131 only applies when I-131 analysis is specified.
Change Footnote "e" of Table TS.4.10-2 (Page 2 of 2) to specify for which isotopes the lower limit of detection must be used when " gamma isotopic analysis" is specified.
Reason for Changes These changes will clarify the conditions when the lower limits of detection identified in Table TS.4.10-2 apply. ,
Safety Evaluation and Determination of Significant Hazards Considerations The proposed change to the Operating License has been evaluated to determine whether it cons-itutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.
l These changes clarify that the LLD limits for I-131 apply only to l analyses that specifically state I-131 analysis is required.
These changes affect the Environmental Monitoring Program and as such will not result in any increase in'the probability or
( consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previousiv analyzed.
These changes involve clarifications to the Environmental Monitoring Program and as such no different type of accident is created. No safety analyses are affected.
A-9
o ,.
I
- 3. The proposed amendment will not involve a significant reduction in the margin of safety.
This change involves clarifications to the Environmental Monitoring Program and as such will have no effect in the margin of safety.
The Commission has provided guidance (March 6,1986 Federal Re5i ster) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists by providing certain examples of amendments that will likely be found to involve no significant hazards considerations. The changes to the Prairie Island Technical Specifications proposed in this amendment
- request are equivalent to NRC example (i), because they involve purely administrative changes to the Technical Specifications.
For the reasons discussed above and because similar changes were approved for the Monticello Nuclear Generating Plant (See NRC Safety Evaluation Report dated 3/13/86), we have concluded that the proposed changes do not involve a significant hazards consideration.
- d. Sample Location i
1 Proposed Changes l Replace "8-20 miles distance and in the least prevalent wind direction" of Specification 1 in Table TS.4.10-1 (Page 1 of 4) with 1 "specified in the ODCM."
Reason for Changes The control location is identified in the ODCM, Figure 5.1-1, location 4. Location 4 is approximately 12 miles northwest of the plant. The prevailing wind direction is from the northwest.
Therefore, the current sample location meets the requirements. We -
have more than 10 years of data from the present control location and
, believe the location of the control sampling location should be
- consistent with past sampling and not dependent upon prevailing wind
{ direction which could change slightly from year to year.
Safety Evaluation and Determination of Significant Hazards Considerations Tha proposed change to the Operating License has been evaluated to
. determine whether it constitutes 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:
i
- 1. The proposed amendment will not involve a significant increase
{ in the probability or consequences of an accident previously evaluated.
This change only affects the Environmental Monitoring Program and 7
as such will not result in any increase in the probability or consequences of an accident previously evaluated.
l f A-10 I
, ,-,,..m., , , , - , . . - .--,-,,.~e.-,-- , ,-m..m.- .
-me - _ --..y--,,_,,my,,, , - ,- ,y--r,_y ,-w.,- , , , , - - - , , , - -yr--,-.-,, ,.q,~..
o ,
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.
This change only affects the Environmental Monitoring Program and as such no different type of accident is created. No safety analyses are affected.
3
- 3. The proposed amendment will not involve a si8 nificant reduction in i the margin of safety.
This change only affects the Environmental Monitoring Program and as such will have no effect in the margin of safety.
For the reasons discussed above, we have concluded that the proposed changes do not involve a significant hazards consideration.
- 3. Section-5 Changes Proposed Changes Change Section-5.5 as shown in Exhibit B.
Change "AEC" to "NRC" on pages: TS.5.1-1 and TS.5.4-1.
t Add a period to "6.5 A.7" to read "6.5.A.7" on page TS.S.1-2.
Change "accuated" to " actuated" on page TS.S.4-1.
- Change the format of the references to consistent with changes made in
- the License Amendment Request date March 17, 1986. Change the references to the FSAR to the appropriate section of the USAR.
Reason for Changes The changes to Section 5.5 reflect changes associated with implementation of 10 CFR Part 50, Appendix I and methods currently 4
used to process radioactive waste. References to the Code of Federal Regulations in the first paragraph were also updated.
The rest of the changes to Section 5.0 are administrative changes designed to be consistent with changes made to Section 2.0, 3.0 and 4.0 in the March 17, 1986 License Amendment Request.
Safety Evaluation and Determination of Significant Hazards Considerations The proposed change to the Operating License has been evaluated to determine whether it constitutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes update the Technical Specifications Design A-ll
r 1-Features Section, Section : 5.0, to reflect the actual radioactive waste system configuration and incorporate other administrative changes and as such will not result in a significant increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.
j The . proposed changes update Section 5.0, a section of the Technical Specifications which provides a general description of the plant and its systems, and as such no different type of accident is created. No safety analyses are affected. The accident analyses presented in the Updated Safety Analysis Report remain bounding.
- 3. The proposed amendment will not involve a significant reduction in
- the margin of safety.
Since the proposed changes update Section 5.0, a section of the Technical Specifications which provides a general description of the plant and its systems, there will be no reduction in the margin of safety.
The Commission has provided guidance (March 6,1986 Federal Register) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists by providing certain examples of amendments that will likely be found to 1nvolve no significant hazards considerations. The changes to the Prairie Island Technical Specifications proposed in this amendment request are equivalent to NRC example (i), because they involve purely administrative changes to Technical Specifications.
i For the reasons discussed above, we have concluded that the proposed changes do not involve a significant hazards consideration.
- 4. Security Plan Implementing Procedures Review 4
Proposed Changes l Modify Technical Specification Pages TS-vii, TS .6.2 - 6, T.S.6.5-1 and T.S.6.5-4 as shown in Exhibit B, to clarify that Operations Committee review of non-safety related Security Plan implementing procedures which govern work activities exclusively applicable to or performed by the guards is not required.
Reason for Change The current Technical Specifications require the Operations Committee to review all Security Plan implementing procedures, which includes non-safety related procedures written to cover details of guard force functions. Operations Committee review of such procedures is not necessary and should not be required.
A-12
- s Safety Evaluation and Determination of Significant Hazards Considerations The proposed change to the Operating Licens*e has been evaluated to determine whether ir constitutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change is intended to clarify the requirements for Operations Committee review of Security Plan implementing procedures. Only the requirements for Operations Committee review of non-safety related procedures associated with activities performed exclusively by security personnel are affected, plant operation will not be affected by the proposed changes. Therefore the proposed change will not result in any increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.
As stated above, only the requirements for Operations Committee review of non-safety related procedures associated with activities performed exclusively by security personnel are affected by the proposed change. Plant operation will not be affected and as such no different type of accident is created.
No safety analyses are affected.- The accident analyses presented in the Updated Safety Analysis Report remain bounding.
- 3. The proposed amendment will not involve a significant reduction in the margin of safety.
The proposed change will eliminate the requirement for Operations Committee review of non-safety related procedures associated with activities performed exclusively by security personnel and will result in more effective use the Operation Committee's time, thereby enhancing plant safety. There will be no reduction in the plant's margin of safety as a result of the proposed change.
The Commission has provided guidance (March 6,1986 Federal Register) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists by providing certain examples of amendments that will likely be found to involve no significant hazards considerations. The change to the Prairie Island Technical Specifications proposed in this amendment request is equivalent to NRC example (i), because it involves a purely administrative change to Technical Specifications.
Based on this guidance and the reasons discussed above, and because similar changes were approved for the Monticello Nuclear Generating Plant in an NRC Safety Evaluation Report dated August 15, 19"4, we have concluded that the proposed change does not involve a significant hazards consideration.
A-13
_ = _ -_ -
I
- 5. Section 6 Changes Proposed Changes Replace the addressee and the address of the Monthly Operating Report in Section 6.7.A.3 (Pages TS.6.7-2) to:
Director, Office of Resource Management U S Nuclear Regulatory Commission Washington, DC 20555 Delete Section 6.8 on page TS.6.8-1 and the reference to Section 6.8 on page TS-viii. Delete the record keeping requirements for Environmental Qualification records in Section 6.6.B.ll on page 6.6-2.
Reason for Changes i The current addressee is incorrect. This amendment proposes the current address.
Recent changes to 10 CFR 50, Section 50.49 specify the requirements for environmental qualification of electric equipment important to safety. Deletion of this section will eliminate duplicate requirements concerning environmental qualification of electrical equipment. Section 50.49 specifies the record keeping requirements for environmental qualification records. Therefore, there is no need to specify them in the Technical Specifics.tions.
Safety Evaluation and Determination of Significant Hazards Considerations I The proposed change to the Operating License has been evaluated to determine whether it constitutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below:
- 1. The proposed amendment will not involve a significant increase
- in the probability or consequences of an accident previously evaluated.
These changes are administrative in nature and will not result in any increase in the probability or consequences of an . accident previously evaluated.
- 2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.
These changes are administrative in nature and as such no different type of accident is created. No safety analyses are affected.
4 l
l A-14 l
e o
- 3. The proposed amendment will not involve a significant reduction in the margin of safety.
Since these changes are administrative in nature, there will be no reduction in the margin of safety.
The Commission has provided guidance (March 6,1986 Federal Register) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists by providing certain examples of amendments that will likely be found to involve no significant hazards considerations. The changes to the Prairie Island Technical Specifications proposed in this amendment request are equivalent to NRC example (i), because they involve purely administrative changes to the Technical Specifications.
For the reasons discussed above, we have concluded that the proposed changes do not involve a significant hazards consideration.
e 4
(
t l
A-15
, - ._. - _ _ _ . - . . _ _ - - . - . . . - -