L-PI-21-029, Exigent License Amendment Request to Revise Technical Specification 3.7.8 to Allow a One-Time Extension of the Completion Time of Required Action B.1

Exigent License Amendment Request to Revise Technical Specification 3.7.8 to Allow a One-Time Extension of the Completion Time of Required Action B.1

ML21281A017
Person / Time
Site:	Prairie Island
Issue date:	10/07/2021
From:	Domingos C Northern States Power Company, Minnesota, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-21-029
Download: ML21281A017 (23)

Text

1717 Wakonade Drive Welch, MN 55089 October 7, 2021 L-PI-21-029 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Units 1 and 2 Docket Nos. 50-282 and 50-306 Renewed Facility Operating License Nos. DPR-42 and DPR-60 Exigent License Amendment Request to Revise Technical Specification 3.7.8 to Allow a One-Time Extension of the Completion Time of Required Action B.1 Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), hereby requests an exigent amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP). The one-time exigent license amendment supports a contingency for the planned work to replace PINGP cooling water (CL) system supply header piping. NSPM is replacing sections of both trains of the PINGP CL system supply header because of suspected microbiologically induced corrosion (MIC). The PINGP CL system supply headers run through the concrete floor and cannot be inspected directly. However, MIC has been identified via non-destructive examination (NDE) in accessible sections of the CL system supply header; therefore, NSPM believes it is prudent to replace supply header piping on both trains of the CL system. This piping replacement is a complex maintenance activity and requires isolating the header to be replaced resulting in the entry into TS 3.7.8, Condition B, for both units because CL is a shared system. In the final phases of the detailed work planning process, NSPM has identified that a contingency plan is needed for use on either train of header in the event that the isolation valve does not provide an acceptable isolation to allow header replacements.

This contingency plan will include expanding the isolation boundary temporarily, installing a blind flange on the leaking isolation valve, and then restoring the original isolation boundary.

The temporary expansion of the isolation boundary results in the inoperability of the motor-driven cooling pump (MDCLP) during which time Units 1 and 2 will no longer meet Required Action B.1 of TS 3.7.8 to verify operability of the MDCLP within the Completion Time of four hours. NSPM estimates, based on detailed planning, that the time needed to install the blind flange is up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> with a similar estimate of time needed to remove the flange. Therefore, NSPM proposes a one-time change to the Completion Time for TS 3.7.8, Required Action B.1 of up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to install or remove a blind flange on the isolation valve for either header, if needed.

Document Control Desk Page 2 The enclosure provides NSPM's evaluation of the proposed change. Attachment 1 to the enclosure provides the marked-up PINGP TS pages. Attachment 2 to the enclosure provides re-typed copies of the PINGP TS pages. Attachment 3 to the enclosure provides the marked-up PINGP TS Bases pages, which are being provided for information only.

NSPM has evaluated the changes proposed in this License Amendment Request in accordance with 10 CFR 50.92 and concluded that they involve no significant hazards consideration. In accordance with 10 CFR 50.91 (b)(1 ), a copy of this application, with the enclosure, is being provided to the designated Minnesota official.

NSPM requests approval of the proposed amendment by November 24, 2021 in support of work to be conducted beginning November 28, 2021, and will remain in effect until December 28, 2021.

If there are any questions or if additional information is required, please contact Mr. Jeff Kivi at (612) 330-5788 or Jeffrey.L.Kivi@XcelEnergy.com.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

I declare under pe alty of perjury, that the foregoing is true and correct.

Executed on rµ_1,µ-----

Ql, P Doming.._o_.s..__

Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc:

Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota

Page 1 of 12 ENCLOSURE PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 Evaluation of the Proposed Change Exigent License Amendment Request to Revise Technical Specification 3.7.8 to Extend the Completion Time of Required Action B.1 on a One-Time Basis 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for Proposed Change 2.4 Exigent Circumstances 2.5 Description of Proposed Change

3.0 TECHNICAL EVALUATION

3.1 Safety Impact of Allowance for One Time Extended Completion Time 3.2 Risk Insights

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Determination 4.3 Conclusions

6.0 REFERENCES

ATTACHMENTS:

1. Technical Specification Pages (Markup)

2. Technical Specification Pages (Retyped)

3. Technical Specification Bases Pages (Markup - for information only)

L-PI-21-029 NSPM Enclosure Page 2 of 12 License Amendment Request to Revise Technical Specification 3.7.8 to Eliminate Required Action B.1 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), hereby requests an exigent amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP). The one-time exigent license amendment supports a contingency for the planned work to replace PINGP cooling water (CL) system supply header piping. NSPM is replacing sections of both trains of the PINGP CL system supply header because of suspected microbiologically induced corrosion (MIC). The PINGP CL system supply headers run through the concrete floor and cannot be inspected directly. However, MIC has been identified via non-destructive examination (NDE) in accessible sections of the CL system supply header; therefore, NSPM believes it is prudent to replace supply header piping on both trains of the CL system. This piping replacement is a complex maintenance activity and requires isolating the header to be replaced resulting in the entry into TS 3.7.8, Condition B, for both units because CL is a shared system. In the final phases of the detailed work planning process, NSPM has identified that a contingency plan is needed for use on either train of header in the event that the isolation valve does not provide an acceptable isolation to allow header replacements.

This contingency plan will include expanding the isolation boundary temporarily, installing a blind flange on the leaking isolation valve, and then restoring the original isolation boundary.

The temporary expansion of the isolation boundary results in the inoperability of the motor-driven cooling pump (MDCLP) during which time Units 1 and 2 will no longer meet Required Action B.1 of TS 3.7.8 to verify operability of the MDCLP within the Completion Time of four hours. NSPM estimates, based on detailed planning, that the time needed to install the blind flange is up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> with a similar estimate of time needed to remove the flange. Therefore, NSPM proposes a one-time change to the Completion Time for TS 3.7.8, Required Action B.1 of up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to install or remove a blind flange on the isolation valve for either header, if needed.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The CL System is a shared system common to both units. The CL System provides a heat sink for the removal of process and operating heat from safety related components during a Design Basis Accident (DBA) or transient. During normal operation, and a normal shutdown, the CL System also provides this function for various safety related and nonsafety related components. The safety related function is covered by this LCO.

L-PI-21-029 NSPM Enclosure Page 3 of 12 The CL System consists of a common CL pump discharge header for the five CL pumps (2 nonsafeguards horizontal pumps, 2 safeguards diesel driven vertical pumps, 1 motor-driven vertical pump that can be designated as safeguards or nonsafeguards) that directs flow into two separate, 100% capacity, CL headers. Each header then supplies loops in the turbine and auxiliary buildings and containments for the two units.

Each safeguards CL train consists of:

a. One 100% capacity vertical safeguards pump (12 or 121 for Train A; 22 or 121 for Train B);

b. A header; and

c. Piping, valving, instrumentation and controls.

The vertical motor driven CL pump (MDCLP) may be directed to supply either CL header when aligned in its safeguards mode of operation. In this case, the MDCLP may replace a vertical diesel driven pump on either train.

A single safeguards CL pump can provide sufficient cooling in one unit during the injection and recirculation phases of a postulated loss of coolant accident plus sufficient cooling to maintain the second unit in a safe shutdown condition.

Both the Train A and Train B CL header has its own dedicated diesel driven CL pump to supply the associated trains safeguards components after being automatically started upon receipt of a safety injection or header low pressure signal. The MDCLP may also be aligned for safeguards mode as a redundant pump to supply either Train A or Train B safeguards components with the MDCLP powered by the associated Train A or Train B Unit 2 safeguards 4kV bus.

Principal post-accident heat loads supplied by the CL System include Unit 1 diesel generators, control room chillers, component cooling (CC) heat exchangers, containment fan coil units, and the nonsafeguards instrument air compressors.

2.2 Current Technical Specification Requirements TS 3.7.8 Condition B is entered if one Cooling Water (CL) header is inoperable. Required Action B.1 is to verify vertical motor driven CL pump OPERABLE with a Completion Time (CT) of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Required Action B.2 is to verify the opposite train diesel driven CL pump is operable with a CT of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Required Action B.3 is to restore CL supply header to operable status with a CT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time (RICT)

Program of TS 5.5.18.

L-PI-21-029 NSPM Enclosure Page 4 of 12 2.3 Reason for Proposed Change 2.3.1 PINGP CL Header Replacement Project NSPM is proactively replacing sections of the PINGP CL supply header piping where a portion of the header is embedded in concrete and cannot be subjected to non-destructive examination (NDE). NSPM believes that timely replacement is prudent because NDE of CL header sections near the inaccessible section show that microbiologically induced corrosion (MIC) has occurred in the header piping. The planned project will replace the affected header sections in order to improve reliability of the CL system as the ultimate heat sink for PINGP Units 1 and 2.

2.3.2 Contingency in the Event That the CL Isolation Boundary Needs to be Extended If the planned isolation valve is found to leak by excessively, a contingency plan has been developed to temporarily expand the isolation boundary to allow installation of a blind flange as an alternate isolation boundary. The intermediate step of establishing this new isolation boundary will require additional valve closures that result in inoperability of the MDCLP for up to an estimated 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> while the blind flange is installed as the isolation boundary. After the flange is installed, the isolation boundary will be reduced restoring the MDCLP to operable thereby meeting Required Action B.1. An additional 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of MDCLP inoperability will be required in order to remove the blind flange as part of system restoration following completion of header replacement. This contingency could potentially be needed for both trains of header.

2.3.4 CL Header Replacement Project Schedule The current schedule is to replace the CL supply header piping at power in the period between November 28, 2021, and December 28, 2021. This period was chosen as a time when CL demand is low.

2.4 Exigent Circumstances During the last phase of detailed planning, NSPM recognized the need for a contingency in the event that the isolation valve were to have excessive leakage. As described in the preceding section, the contingency to support isolation of the affected header is the installation/removal of a blind flange which requires MDCLP to be inoperable longer than the four hour CT for TS 3.7.8, Required Action B.1. NSPM evaluated the following options for this contingency:

Exigent license amendment to allow a one-time extended CT of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for TS 3.7.8, Required Action B.1, if needed to install or remove a blind flange on the isolation valve.

Backing out of the scheduled and planned header replacement and reschedule after completing a license amendment via the normal regulatory review process for the one-time extended CT.

Going into a dual-unit shutdown in order to complete the header replacement activities.

Requesting emergency licensing action if the contingency is needed.

L-PI-21-029 NSPM Enclosure Page 5 of 12 NSPM determined the exigent license amendment was the appropriate approach. The option of backing out and waiting for a license amendment under the normal review process unduly delays the header replacement especially in light of the uncertainty of MIC growth. The dual-unit outage option adds to the complexity and overall risk of the maintenance activity due to having to manage two units in outage with a single operable CL train without a corresponding safety benefit. An emergency licensing action allows less time for regulatory review and public comment than an exigent amendment.

NSPM initiated dialog with the NRC on the proposed change and is making a good faith effort to submit this license amendment request in a timely manner following identification of the need for the temporary expanded isolation boundary contingency. Accordingly, NSPM requests this amendment be processed under exigent circumstances pursuant to 10 CFR 50.91(a)(6).

Consistent with the Statement of Considerations accompanying the issuance of 10 CFR 50.91(a)(6), the proposed one-time extended CT for the blind flange contingency supports timely improvement of CL system reliability and, thus, results in a net increase in safety or reliability (51 Federal Register 7756, March 6, 1986). The Staff implementing guidance expresses a preference for a license amendment, if possible, over NOED. See NRC Enforcement Manual Appendix F, Section 1.4. In this case, the proposed exigent license amendment process appropriately balances opportunity to improve public safety and reliability with public participation in the NRCs license amendment process.

2.5 Description of Proposed Change NSPM proposes one-time change to TS 3.7.8 Required Action B.1 CT to up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, as needed, for installation or removal of a blind flange on either header. The period for this one-time TS allowance would be during the CL header replacement project which will be conducted between November 28, 2021, and December 28, 2021.

L-PI-21-029 NSPM Enclosure Page 6 of 12 TS 3.7.8, Condition B would be changed to add a footnote to the CT for Required Action B.1:

CONDITION REQUIRED ACTION COMPLETION TIME B. One CL supply header inoperable.

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NOTES---------------

1.

Unit 1 enter applicable Conditions and Required Actions of LCO 3.8.1, AC Sources-MODES 1, 2, 3, and 4, for emergency diesel generator made inoperable by CL System.

2.

Both units enter applicable Conditions and Required Actions of LCO 3.4.6, RCS Loops-MODE 4, for residual heat removal loops made inoperable by CL System.

B.1 Verify vertical motor driven CL pump OPERABLE.

AND 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s*

• As a contingency to support an adequate isolation boundary, the vertical motor driven CL pump is allowed to remain inoperable for up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to support blind flange installation and for up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to support the blind flange removal during the time frame of 11/28/2021 through 12/28/2021 to Support the A and B train CL Supply Header piping replacement project.

3.0 TECHNICAL EVALUATION

3.1 Safety Impact of Allowance for One Time Extended Completion Time The proposed change allows one-time change to the CT for TS 3.7.8, Required Action B.1, of up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> as needed to install or remove a blind flange on the isolation boundary needed

L-PI-21-029 NSPM Enclosure Page 7 of 12 to replace CL system header piping. The proposed change has a low safety impact because the redundant header will remain operable with the MDCLP inoperable because the diesel driven CL pump associated with the operable CL header will remain operable. This single diesel driven CL pump can provide sufficient cooling in one unit during the injection and recirculation phases of a postulated loss of coolant accident plus sufficient cooling to maintain the second unit in a safe shutdown condition. There is no impact to the safety analysis described in the USAR.

3.2 Risk Insights PINGP has implemented TSTF-505, Provide Risk-Informed Extended Completion Times -

RITSTF Initiative 4b. (Reference 1) As such, the risk of the proposed change to TS 3.7.8, Required Action B.1, will be managed because NSPM will apply the Risk Informed Completion Time (RICT) Program to the Completion Time for TS 3.7.8, Required Action B.3. Required Action B.3 requires restoring the CL supply header to operable status with a Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the RICT Program. The RICT applied to Required Action B.3 will necessarily include the configuration with the MDCLP inoperable and, as such, the risk involved with having one CL supply header and the MDCLP inoperable will be managed in accordance with the RICT Program during the period that the extended Completion Time is in effect.

Risk mitigation actions (RMAs) will target the success of the redundant or diverse systems, structures and components (SSCs) and, if possible, reduce the frequency of initiating events which call upon affected SSCs (CL and the systems it supports). RMAs include:

Protecting equipment, such as opposite train residual heat removal, safety injection, and containment spray pumps, containment fan coils, auxiliary feedwater pumps, component cooling water pumps, Unit 1 diesel generators (Unit 2 diesel generators do not rely on CL), opposite train diesel driven CL pump, and instrument and air compressors.

Deferring maintenance and testing activities that could generate an initiating event that could challenge the operable SSCs.

Establishing compensatory action, shift brief, or standing order that focuses on actions operators will take in response to an initiating event if an associated operable SSC fails.

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria 4.1.1 10 CFR 50.36 10 CFR 50.36, Technical Specifications, defines the content required in licensee TS.

Specifically, 10 CFR 50.36(c)(2)(i) requires that the TS include limiting conditions for operation that are the lowest functional capability or performance levels of equipment required for safe

L-PI-21-029 NSPM Enclosure Page 8 of 12 operation of the facility. The CL System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). The proposed changes will allow a one-time change to TS 3.7.8 Required Action B.1 to extend the CT. Based on this evaluation, the proposed extended CT continues to support compliance to 10 CFR 50.36(c)(2).

4.1.2 Principal Design Criteria PINGP was not licensed to the 10 CFR 50, Appendix A, General Design Criteria (GDC).

PINGP was designed and constructed to comply with NSPs understanding of the intent of the AEC General Design Criteria for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. Since the construction of the plant was significantly completed prior to the issuance of the February 20, 1971, 10CFR50, Appendix A GDC, the plant was not reanalyzed and the Final Safety Analysis Report (FSAR) was not revised to reflect these later criteria.

However, the AEC Safety Evaluation Report acknowledged that the AEC staff assessed the plant, as described in the FSAR, against the Appendix A design criteria and...are satisfied that the plant design generally conforms to the intent of these criteria.

Criterion 4 - Sharing of Systems Reactor facilities shall not share systems or components unless it is shown safety is not impaired by the sharing.

The PINGP CL System includes a ring header which is shared by Units 1 and 2 and can be isolated automatically to provide two redundant independent sources of cooling water for all essential services. One-half of essential services for each Unit is supplied from each side of the isolable loop. Each side of the loop is designed to supply the needs for all essential services for both Units. Thus, failure of one side of the loop still provides for the operation of all equipment required for the safe shutdown of both Units.

The proposed change to add an allowance for a longer Completion Time for TS 3.7.8, Required Action B.1, in support of CL header piping replacement has no impact on the ability of the remaining diesel driven cooling water pump to support the remaining CL header and to support both PINGP Units as required. Therefore, PINGP conformance to Criterion 4 is unaffected by the proposed changes.

Criterion 37 - Engineered Safety Features Basis for Design Engineered safety features shall be provided in the facility to back up the safety provided by the core design, the reactor coolant pressure boundary, and their protection systems. As a minimum, such engineered safety features shall be designed to cope with any size reactor coolant pressure boundary break up to and including the circumferential rupture of any pipe in that boundary assuming unobstructed discharge from both ends.

The CL system is a supporting system for the Engineered Safety Features and is designed in accordance with Criterion 37.

L-PI-21-029 NSPM Enclosure Page 9 of 12 The proposed change to add an allowance for a longer Completion Time for TS 3.7.8, Required Action B.1, in support of CL header piping replacement has no impact on the permanent physical configuration, design, or function the CL system. Even with the MDCLP isolated for the extended period, the remaining CL header still supported by an operable DDCLP. Therefore, PINGP conformance to Criterion 37 is unaffected by the proposed changes.

Criterion 41 - Engineered Safety Features Performance Capability Engineered safety features such as emergency core cooling and containment heat removal systems shall provide sufficient performance capability to accommodate partial loss of installed capacity and still fulfill the required safety function. As a minimum, each engineered safety feature shall provide this required safety function assuming a failure of a single active component.

The PINGP CL system has sufficient redundancy and duplication incorporated into its design to insure it will perform its function adequately even with the loss of a single active component.

The proposed change to add an allowance for a longer Completion Time for TS 3.7.8, Required Action B.1, in support of CL header piping replacement has no impact on the permanent physical configuration, design, or function the CL system. Even with the MDCLP isolated for the extended period, the remaining CL header still supported by an operable DDCLP. Therefore, PINGP conformance to Criterion 41 is unaffected by the proposed changes.

Criterion 52 - Containment Heat Removal System Where active heat removal systems are needed under accident conditions to prevent exceeding containment design pressure, at least two systems, preferably of different principles, each with full capacity, shall be provided.

The PINGP CL system provides cooling flow to the containment Fan Coil Units (FCUs). The containment FCUs serve as part of one of two independent containment heat removal systems.

The proposed change to add an allowance for a longer Completion Time for TS 3.7.8, Required Action B.1, in support of CL header piping replacement has no impact on the permanent physical configuration, design, or function the CL system. Even with the MDCLP isolated for the extended period, the remaining CL header still supported by an operable DDCLP. Therefore, PINGP conformance to Criterion 52 is unaffected by the proposed changes.

4.2 No Significant Hazards Consideration Determination In accordance with the requirements of 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), requests a one-time amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating

L-PI-21-029 NSPM Enclosure Page 10 of 12 Plant (PINGP), Units 1 and 2, Renewed Facility Operating License Nos. DPR-42 and DPR-60.

The proposed change revises TS 3.7.8 to extend the Completion Time of Required Action B.1 on a one-time basis to support contingency plans. This one-time change supports planned work to replace PINGP Cooling Water (CL) system header piping in the event unexpected leakage of isolation valve(s) requires expansion of the isolation boundary. In order to install a blind flange to obtain an adequate isolation. The extended Completion Time is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to install or remove the blind flange.

NSPM has evaluated the proposed amendment against the standards in 10 CFR 50.92 and has determined that the operation of the PINGP in accordance with the proposed amendment presents no significant hazards. NSPMs evaluation against each of the criteria in 10 CFR 50.92 follows.

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The CL system is not an initiator of any accident previously evaluated. As a result, the probability of an accident previously evaluated is not increased by the allowance to extend the Completion Time of Required Action B.1 if needed for installation or removal of a blind flange. The consequences of an accident during the proposed extended Required Action B.1 Completion Time are no different than the consequences of an accident during the existing 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time. The MDCLP provides a source of cooling water to the operable CL header. However, the operable header is also served by the associated diesel driven cooling water pump (DDCLP) and that CL header remains operable even if the MDCLP is inoperable, so the extended time will not significantly increase consequences of any of the accidents that CL mitigates.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change will not permanently alter the design or function of the CL system.

The proposed change provides an allowance for the MDCLP to be valved out of service and inoperable longer than the TS 3.7.8 Required Action B.1 Completion Time of four hours. Up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> will be required for the purpose of installing a blind flange if the leakage across the valve supporting the planned isolation is found to be too high.

Similarly, up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> will be required for the purpose of removing the blind flange.

L-PI-21-029 NSPM Enclosure Page 11 of 12 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change extends the Completion Time of Required Action B.1 of TS 3.7.8.

Required Action B.1 verifies operability of the MDCLP. The MDCLP provides a source of cooling water to the operable header. However, the operable header is also served by the associated DDCLP and that CL header remains operable even if the MDCLP is inoperable.

Therefore, the proposed change does not result in a significant reduction in a margin of safety.

Based on the above evaluation, NSPM concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and accordingly, a finding of no significant hazards consideration is justified.

4.3 Conclusions In conclusion, based on the considerations discussed above, (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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

NSPM has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

L-PI-21-029 NSPM Enclosure Page 12 of 12

6.0 REFERENCES

1. NRC letter to NSPM, Prairie Island Nuclear Generating Plant, Units 1 and 2 - Issuance of Amendment Nos. 235 and 223 re: Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b (EPID L-2019-LLA-0283) (NRC ADAMS Accession No. ML20346A020)

ENCLOSURE, ATTACHMENT 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 License Amendment Request to Revise Technical Specification 3.7.8 to Eliminate Required Action B.1 TECHNICAL SPECIFICATION PAGES (Markup)

(2 page follows)

CL System 3.7.8 Prairie Island Units 1 and 2 3.7.8-2 Unit 1 - Amendment No. 235 Unit 2 - Amendment No. 223 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.1 Restore one safeguards CL pump to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. One CL supply header inoperable.

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NOTES---------------

1.

Unit 1 enter applicable Conditions and Required Actions of LCO 3.8.1, AC Sources-MODES 1, 2, 3, and 4, for emergency diesel generator made inoperable by CL System.

2.

Both units enter applicable Conditions and Required Actions of LCO 3.4.6, RCS Loops-MODE 4, for residual heat removal loops made inoperable by CL System.

B.1 Verify vertical motor driven CL pump OPERABLE.

AND 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Insert A

Insert A

• As a contingency and if needed to support an adequate isolation boundary, the vertical motor driven CL pump is allowed to remain inoperable for up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to support blind flange installation and for up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to support the blind flange removal during the time frame of 11/28/2021 through 12/28/2021 to Support the A and B train CL Supply Header piping replacement project.

ENCLOSURE, ATTACHMENT 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 License Amendment Request to Revise Technical Specification 3.7.8 to Eliminate Required Action B.1 TECHNICAL SPECIFICATION PAGES (Re-typed)

(1 page follows)

CL System 3.7.8 Prairie Island Unit 1 - Amendment No. TBD Units 1 and 2 3.7.8-2 Unit 2 - Amendment No. TBD ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.1 Restore one safeguards CL pump to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. One CL supply header inoperable.

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NOTES---------------

1.

Unit 1 enter applicable Conditions and Required Actions of LCO 3.8.1, AC Sources-MODES 1, 2, 3, and 4, for emergency diesel generator made inoperable by CL System.

2.

Both units enter applicable Conditions and Required Actions of LCO 3.4.6, RCS Loops-MODE 4, for residual heat removal loops made inoperable by CL System.

B.1 Verify vertical motor driven CL pump OPERABLE.

AND 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s*

• As a contingency and if needed to support an adequate isolation boundary, the vertical motor driven CL pump is allowed to remain inoperable for up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to support blind flange installation and for up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to support the blind flange removal during the time frame of 11/28/2021 through 12/28/2021 to Support the A and B train CL Supply Header piping replacement project.

ENCLOSURE, ATTACHMENT 3 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 License Amendment Request to Revise Technical Specification 3.7.8 to Eliminate Required Action B.1 TECHNICAL SPECIFICATION BASES PAGES (Marked-Up)

(Provided for Information Only)

(3 pages follow)

CL System B 3.7.8 Prairie Island Units 1 and 2 B 3.7.8-9 Revision 250 BASES ACTIONS B.1, B.2 and B.3 (continued)

If one CL supply header is inoperable, action must be taken to verify the vertical motor driven CL pump and the opposite train diesel driven CL pump are OPERABLE within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and restore the inoperable CL header to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program Verification of vertical motor driven CL pump OPERABILITY does not require the pump to be aligned and may be performed by administrative means. Verification of the opposite train diesel driven CL pump may be performed by administrative means.

Completion of the CL pump surveillance tests is not required.

Conditions may occur in the CL System piping, valves, or instrumentation downstream of the supply header (e.g., closed or failed valves, failed piping, or instrumentation in a return header) that can result in the supply header being considered inoperable. In such cases, Condition B and related Required Actions shall apply.

In this Condition, the remaining OPERABLE CL header is adequate to perform the heat removal function. However, the overall redundancy is reduced because only a single CL train remains OPERABLE.

Required Action B.1 ensures that the vertical motor driven 121 CL pump may be used to provide redundancy for the safeguards CL pump on the OPERABLE header. Required Action B.3 assures adequate system reliability is maintained.

Required Actions B.1, B.2, and B.3 are modified by two Notes.

The first Note indicates that the applicable Conditions and Required Actions of LCO 3.8.1, AC Sources-Operating, should be entered for Unit 1 since an inoperable CL train results in an inoperable emergency diesel generator.

CL System B 3.7.8 Prairie Island Units 1 and 2 B 3.7.8-10 Revision 250 BASES ACTIONS B.1, B.2 and B.3 (continued)

The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6, RCS Loops-MODE 4, should be entered if an inoperable CL train results in an inoperable decay heat removal train. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

The 4 and 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Times are based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this time period. In addition, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time for Required Actions B.1 and B.2 is within the time period anticipated to verify OPERABILITY of the required CL pump by administrative means.

C.1 and C.2 If at least one safeguards CL pump for a train or a CL supply header cannot be restored to OPERABLE status within the associated Completion Time, the units must be placed in a MODE in which the LCO does not apply. To achieve this status the units must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.1 This Condition is modified by a note indicating that separate Condition entry is allowed for each stored diesel driven CL pump fuel oil supply. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable stored diesel driven CL pump fuel oil supply. Complying Insert A

Insert A An extended Completion Time is provided on a one-time basis for Required Action B.1 if it is needed. The extended Completion Time is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and supports installation and removal of a blind flange (36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for each evolution) if it becomes necessary to install a blind flange in support of creating an adequate isolation for CL supply header replacement work during the time frame of 11/28/2021 to 12/28/2021.