L-PI-24-044, Application to Revise Technical Specifications to Adopt TSTF-591, Revise Risk Informed Completion Time (RICT) Program
| ML24297A403 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/21/2024 |
| From: | Conboy T Northern States Power Co, Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-PI-24-044 | |
| Download: ML24297A403 (1) | |
Text
1717 Wakonade Drive Welch, MN 55089 October 21, 2024 L-PI-24-044 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 Application to Revise Technical Specifications to Adopt TSTF-591, "Revise Risk Informed Completion Time (RICT) Program" Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), is submitting a request for an amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2.
NSPM requests adoption of TSTF-591, "Revise Risk Informed Completion Time (RICT)
Program," which is an approved change to the Standard Technical Specifications (STS), into the PINGP, Units 1 and 2 TS. TSTF-591 revises the TS Section 5.5 Program, "Risk Informed Completion Time Program," to reference Regulatory Guide 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of newly developed methods used to calculate a RICT.
The enclosure provides a description and assessment of the proposed changes. Attachment 1 to the enclosure provides the existing PINGP TS pages marked to show the proposed changes. Attachment 2 to the enclosure provides revised (clean) TS pages. The proposed change does not affect the PINGP TS Bases.
NSPM requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within six months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 90 days.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Minnesota official.
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.
Document Control Desk L-Pl-24-044 Page 2 Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.
I declare under penalty of perjury, that the foregoing is true and correct.
Executed on ----------
Thomas A. Conboy Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota
Enclosure:
Description and Assessment Attachments:
- 1. Proposed Technical Specification Changes (Mark-Up)
- 2. Revised Technical Specification Pages cc:
Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota October 21, 2024.
Page 1 of 4 ENCLOSURE PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 Description and Assessment
1.0 DESCRIPTION
Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), requests adoption of TSTF-591, "Revise Risk Informed Completion Time (RICT) Program," which is an approved change to the Standard Technical Specifications (STS), into the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, Technical Specifications (TS). TSTF-591 revises the TS Section 5.5 Program, "Risk Informed Completion Time Program," to reference Regulatory Guide 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of newly developed methods used to calculate a RICT.
2.0 ASSESSMENT
2.1 Applicability of Safety Evaluation NSPM has reviewed the safety evaluation for TSTF-591 provided to the Technical Specifications Task Force in a letter dated September 21, 2023. This review included the NRC staffs evaluation, as well as the information provided in TSTF-591. NSPM has concluded that the justifications presented in TSTF-591 and the safety evaluation prepared by the NRC staff are applicable to PINGP, Units 1 and 2, and justify this amendment for the incorporation of the changes to the PINGP TS.
2.2 Variations The PINGP TS utilize different numbering than the STS on which TSTF-591 was based.
Specifically, PINGP TS 5.5.18 is the Risk Informed Completion Time section where the Risk Informed Completion Time section in TSTF-591 is numbered 5.5.20. Also, the new RICT Program Upgrade Report section will be PINGP TS 5.6.9, where this new section is numbered 5.6.8 in TSTF-591. These differences are administrative and do not affect the applicability of TSTF-591 to the PINGP TS.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), requests adoption of TSTF-591, "Revise Risk Informed Completion Time
L-PI-24-044 NSPM Enclosure Page 2 of 4 (RICT) Program," which is an approved change to the Standard Technical Specifications (STS), into the PINGP, Units 1 and 2, Technical Specifications (TS). TSTF-591 revises the TS Section 5.5 Program, "Risk Informed Completion Time Program," to reference Regulatory Guide 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of newly developed methods used to calculate a RICT.
NSPM has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
- 1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change updates the standard for maintaining and updating Probabilistic Risk Assessment (PRA) models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed method is used.
The proposed change does not involve a significant increase in the probability of an accident previously evaluated because the change involves no change to the plant or its modes of operation. The proposed change does not increase the consequences of an accident because the design-basis mitigation function of the affected systems is not changed and the consequences of an accident during the extended Risk Informed Completion Time are no different from those during the existing Completion Time. The submittal of information-only reports has no effect on the initiators or consequences of any accidents previously evaluated.
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 updates the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed method is used.
L-PI-24-044 NSPM Enclosure Page 3 of 4 The proposed change does not change a design function or method of operation of the plant. The proposed change does not involve a physical alteration of the plant (no new or different kind of equipment will be installed).
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed change involve a significant reduction a margin of safety?
Response: No The proposed change updates the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed method is used.
The proposed change supports the extension of Completion Times provided risk is assessed and managed in accordance with the NRC-approved RICT Program. The proposed change does not alter any design basis or safety limits. The proposed change affects the standard used to maintain the PRA models used in the RICT Program by changing from one NRC-approved standard to a later NRC-approved version and requiring submittal of an information-only report. The RICT Program will continue to assure that adequate margins of safety are maintained.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, NSPM concludes that the proposed change presents no 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.
3.2 Conclusion 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.
4.0 ENVIRONMENTAL CONSIDERATION
A review 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,
L-PI-24-044 NSPM Enclosure Page 4 of 4 the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents 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.
ENCLOSURE, ATTACHMENT 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 Application to Revise Technical Specifications to Adopt TSTF-591, Revise Risk Informed Completion Time (RICT) Program TECHNICAL SPECIFICATION PAGES (Markup)
(2 pages follow)
Programs and Manuals 5.5 Prairie Island Unit 1 - Amendment No. 239 Units 1 and 2 5.5-21 Unit 2 - Amendment No. 227 5.5 Programs and Manuals 5.5.18 Risk Informed Completion Time Program (continued)
- 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.
- e. The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods used to support this license amendment, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.
- e.
A RICT calculation must include the following hazard groups: Internal Events PRA (including Internal Flooding), Fire PRA, and Seismic Penalty Factor. Changes to these means of assessing hazard groups require prior NRC approval.
- f.
The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities.
- g.
A report shall be submitted in accordance with Specification 5.6.9 before a newly developed method is used to calculate a RICT.
Reporting Requirements 5.6 Prairie Island Units 1 and 2 5.6-9 Unit 1 +/- Amendment No. 243 Unit 2 +/- Amendment No. 231 5.6 Reporting Requirements (continued) 5.6.8 Steam Generator Tube Inspection Report (continued) d.
An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results; e.
The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG; and f.
The results of any SG secondary side inspections.
5.6.8 EM Report When a report is required by Condition C or I of LCO 3.3.3, "Event Monitoring (EM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.
5.6.9 Risk Informed Completion Time (RICT) Program Update Report A report describing newly developed methods and their implementation must be submitted following a probabilistic risk assessment (PRA) upgrade associated with newly developed methods and prior to first use of those methods to calculate a RICT. This report shall include:
- a.
The PRA models upgraded to include newly developed methods;
- b.
A description of the acceptability of the newly developed methods consistent with Section 5.2 of PWROG-19027-NP, Revision 2, Newly Developed Method Requirements and Peer Review;
- c.
Any open findings from the peer review of the implementation of the newly developed methods and how those findings were dispositioned; and
- d.
All changes to key assumptions related to newly developed methods or their implementation.
ENCLOSURE, ATTACHMENT 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 Application to Revise Technical Specifications to Adopt TSTF-591, Revise Risk Informed Completion Time (RICT) Program TECHNICAL SPECIFICATION PAGES (Re-typed)
(2 pages follow)
Programs and Manuals 5.5 Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 5.5-21 Unit 2 - Amendment No. YYY 5.5 Programs and Manuals 5.5.18 Risk Informed Completion Time Program (continued)
- 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.
- e.
A RICT calculation must include the following hazard groups Internal Events PRA (including Internal Flooding), Fire PRA, and Seismic Penalty Factor. Changes to these means of assessing hazard groups require prior NRC approval.
- f.
The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities.
- g.
A report shall be submitted in accordance with Specification 5.6.9 before a newly developed method is used to calculate a RICT.
Reporting Requirements 5.6 Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 5.6-9 Unit 2 - Amendment No. YYY 5.6 Reporting Requirements (continued) 5.6.8 EM Report When a report is required by Condition C or I of LCO 3.3.3, "Event Monitoring (EM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.
5.6.9 Risk Informed Completion Time (RICT) Program Update Report A report describing newly developed methods and their implementation must be submitted following a probabilistic risk assessment (PRA) upgrade associated with newly developed methods and prior to first use of those methods to calculate a RICT. This report shall include:
- a.
The PRA models upgraded to include newly developed methods;
- b.
A description of the acceptability of the newly developed methods consistent with Section 5.2 of PWROG-19027-NP, Revision 2, Newly Developed Method Requirements and Peer Review;
- c.
Any open findings from the peer review of the implementation of the newly developed methods and how those findings were dispositioned; and
- d.
All changes to key assumptions related to newly developed methods or their implementation.