L-PI-25-006, Units, 1 and 2, Application to Revise Technical Specifications to Adopt TSTF-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in Actuated Positions
| ML25071A416 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/12/2025 |
| From: | Conboy T Nuclear Management Co, Xcel Energy |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-PI-25-006 | |
| Download: ML25071A416 (1) | |
Text
1717 Wakonade Drive Welch, MN 55089 March 12, 2025 L-PI-25-006 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-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position 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-541, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position," which is an approved change to the Standard Technical Specifications (STS), into the PINGP Units 1 and 2 Technical Specifications (TS). The proposed amendment modifies certain TS Surveillance Requirements (SRs) by adding exceptions to consider the SR met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position, in order to consider the SR met.
Securing the automatic damper in the actuated position may affect the operability of the system or any supported systems. The associated Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function).
The enclosure provides a description and assessment of the proposed changes. Enclosure provides the existing TS pages marked up to show the proposed changes.
Enclosure Attachment 2 provides revised (clean) TS pages. Enclosure Attachment 3 provides existing TS Bases pages marked to show the proposed changes for information only.
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 NRC acceptance. 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.
fl Xcel Energy
Document Control Desk L-Pl-25-006 Page 2 Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.
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Site Vice President, Prairie Isla enerating Plant Northern States Power Campa Enclosure cc:
Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota
Page 1 of 5 ENCLOSURE LICENSE AMENDMENT REQUEST APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-541, ADD EXCEPTIONS TO SURVEILLANCE REQUIREMENTS FOR VALVES AND DAMPERS LOCKED IN THE ACTUATED POSITION
1.0 DESCRIPTION
Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM) requests adoption of TSTF-541, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position," 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). The proposed amendment modifies the TS Surveillance Requirements (SRs) by adding exceptions to consider the SR met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position, in order to consider the SR met. Securing the automatic damper in the actuated position may affect the operability of the system or of any supported systems. The associated Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function). The following SRs are affected by the proposed change.
TS 3.6.9, Shield Building Ventilation System (SBSVS)"
TS 3.7.10, "Control Room Special Ventilation System (CRSVS),"
TS 3.7.12, "Auxiliary Building Special Ventilation System (ABSVS),"
While the proposed exceptions permit automatic valves and dampers that are locked, sealed, or otherwise secured in the actuated position to be excluded from the SR in order to consider the SR met, the proposed changes will not permit a system that is made inoperable by locking, sealing, or otherwise securing an automatic damper in the actuated position to be considered operable. As stated in the SR 3.0.1 Bases:
"Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:
- a. The systems or components are known to be inoperable, although still meeting the SRs."
L-PI-25-006 NSPM Enclosure Page 2 of 5
2.0 ASSESSMENT
2.1 Applicability of Safety Evaluation NSPM has reviewed the safety evaluation for TSTF-541 provided to the Technical Specifications Task Force in a letter dated December 10, 2019. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-541. NSPM has concluded that the justifications presented in TSTF-541 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.
NSPM acknowledges that under the proposed change, the affected valves and dampers may be excluded from the SR when locked, sealed or otherwise secured in the actuated position.
However, if the safety analysis assumes movement from the actuated position following an event, or the system is rendered inoperable by locking, sealing, or otherwise securing the damper in the actuated position, then the system cannot perform its specified safety function and is inoperable regardless of whether the SR is met.
NSPM acknowledges for components for which the SR allowance can be utilized, the SR must be verified to have been met within its required Frequency after removing the damper from the locked, sealed or otherwise secured status. If the SR exception is utilized to not test the actuation of a damper and the specified Frequency of the SR is exceeded without testing the component, the SR must be performed on the component when it is returned to service in order to meet the SR.
2.2 Variations NSPM is proposing the following variations from the TS changes described in TSTF-541 or the applicable parts of the NRC staffs safety evaluation:
The PINGP TS utilize different titles than the Standard Technical Specifications (STS) on which TSTF-541 was based. Specifically, PINGP TS 3.6.9 is equivalent to STS 3.6.13 and is titled, Shield Building Ventilation System, TS 3.7.10 is equivalent to STS 3.7.10 and is titled, "Control Room Special Ventilation System (CRSVS)," and TS 3.7.12 is equivalent to STS 3.7.12 and is titled, "Auxiliary Building Special Ventilation System (ABSVS)." These differences are administrative and do not affect the applicability of TSTF-541 to the PINGP TS.
The PINGP TS do not include the following TS that are included in TSTF-541:
TS 3.6.11, "Iodine Cleanup System (ICS) (Atmospheric and Subatmospheric),"
TS 3.7.13, "Fuel Building Air Cleanup System (FBACS),"
TS 3.7.14, "Penetration Room Exhaust Air Cleanup System (PREACS)"
L-PI-25-006 NSPM Enclosure Page 3 of 5 The PINGP Technical Specifications contain a Surveillance Frequency Control Program.
Therefore, the Frequency for the affected SRs is "In accordance with the Surveillance Frequency Control Program." This has no effect on the applicability of the proposed change.
2.3 Licensee Verifications NSPM confirms that existing administrative processes, such as the Corrective Action Program, Operability Determination process, the maintenance, design control, configuration control, and operating procedures, etc., will be used to assess the operability of the system or of any supported systems when utilizing the SR allowances, which includes consideration of whether movement of the affected valves or dampers following an event is assumed in the safety analysis.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination NSPM requests adoption of TSTF-541, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position," which is an approved change to the Standard Technical Specifications (STS), into the PINGP Units 1 and 2 Technical Specifications (TS). The proposed amendment modifies the TS Surveillance Requirements (SRs) by adding exceptions to consider the SR met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position, in order to consider the SR met.
Securing the automatic damper in the actuated position may affect the operability of the system or of any supported systems. The associated Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function).
NSPM has evaluated whether or not 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 amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change revises SRs by adding exceptions excluding from actuation and isolation time testing those valves and dampers that are locked, sealed or otherwise secured in the actuated position. The performance or lack of performance of SRs is not an initiator of any accident previously evaluated. As a result, the proposed change has no effect on the probability of any accident previously evaluated. The proposed change excludes performance of portions of certain SRs, but the SSC must still be capable of performing the safety functions assumed in the accident analysis. Otherwise, the SSC is
L-PI-25-006 NSPM Enclosure Page 4 of 5 inoperable, and the associated TS Actions are followed. As a result, the SSCs continue to perform their mitigating functions and the consequences of any accident previously evaluated are not affected.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change revises SRs by adding exceptions excluding from actuation and isolation time testing those valves and dampers that are locked, sealed or otherwise secured in the actuated position. The proposed change will not change the design function or operability requirements of the affected SSCs. The SSC must still be capable of performing the safety functions assumed in the accident analysis or the SSC is inoperable, and the associated TS Actions are followed. The proposed change does not create any credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.
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 amendment involve a significant reduction in a margin of safety?
Response: No The proposed change revises SRs by adding exceptions excluding from actuation and isolation time testing those valves and dampers that are locked, sealed or otherwise secured in the actuated position. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis assumptions and acceptance criteria are not affected by this change.
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.
L-PI-25-006 NSPM Enclosure Page 5 of 5 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
The proposed change 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 change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or 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 change 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 change.
ENCLOSURE, ATTACHMENT 1 LICENSE AMENDMENT REQUEST APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-541, ADD EXCEPTIONS TO SURVEILLANCE REQUIREMENTS FOR VALVES AND DAMPERS LOCKED IN THE ACTUATED POSITION TECHNICAL SPECIFICATION PAGES (MARKUP)
(3 Pages Follow)
SBVS 3.6.9 Prairie Island Unit 1 - Amendment No. 226 Units 1 and 2 3.6.9-2 Unit 2 - Amendment No. 214 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.9.2 Perform required SBVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.6.9.3 Verify each SBVS train actuates on an actual or simulated actuation signal.
In accordance with the Surveillance Frequency Control Program SR 3.6.9.4 Verify SBVS isolation dampers actuate on an actual or simulated signal.
In accordance with the Surveillance Frequency Control Program
, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
CRSVS 3.7.10 Prairie Island Unit 1 - Amendment No. 226 Units 1 and 2 3.7.10-4 Unit 2 - Amendment No. 214 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CRSVS train > 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.2 Perform required CRSVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with VFTP SR 3.7.10.3 Verify each CRSVS train actuates on an actual or simulated actuation signal.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.4 Verify each CRSVS train in the Emergency Mode delivers 3600 to 4400 cfm through the associated CRSVS filters.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.5 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
In accordance with the Control Room Habitability Program
, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
ABSVS 3.7.12 Prairie Island Unit 1 - Amendment No. 226 Units 1 and 2 3.7.12-3 Unit 2 - Amendment No. 214 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.12.2 Perform required ABSVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.12.3 Verify each ABSVS train can produce a negative pressure within 20 minutes after initiation.
In accordance with the Surveillance Frequency Control Program SR 3.7.12.4 Verify each ABSVS train actuates on an actual or simulated actuation signal.
In accordance with the Surveillance Frequency Control Program
, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
ENCLOSURE, ATTACHMENT 2 LICENSE AMENDMENT REQUEST APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-541, ADD EXCEPTIONS TO SURVEILLANCE REQUIREMENTS FOR VALVES AND DAMPERS LOCKED IN THE ACTUATED POSITION TECHNICAL SPECIFICATION PAGES (RE-TYPED)
(3 Pages Follow)
SBVS 3.6.9 Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 3.6.9-2 Unit 2 - Amendment No. YYY SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.9.2 Perform required SBVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.6.9.3 Verify each SBVS train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.6.9.4 Verify SBVS isolation dampers actuate on an actual or simulated signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program
CRSVS 3.7.10 Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 3.7.10-4 Unit 2 - Amendment No. YYY SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CRSVS train > 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.2 Perform required CRSVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with VFTP SR 3.7.10.3 Verify each CRSVS train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.4 Verify each CRSVS train in the Emergency Mode delivers 3600 to 4400 cfm through the associated CRSVS filters.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.5 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
In accordance with the Control Room Habitability Program
ABSVS 3.7.12 Prairie Island Unit 1 - Amendment No. XXX Units 1 and 2 3.7.12-3 Unit 2 - Amendment No. YYY SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.12.2 Perform required ABSVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.12.3 Verify each ABSVS train can produce a negative pressure within 20 minutes after initiation.
In accordance with the Surveillance Frequency Control Program SR 3.7.12.4 Verify each ABSVS train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program
ENCLOSURE, ATTACHMENT 3 LICENSE AMENDMENT REQUEST APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-541, ADD EXCEPTIONS TO SURVEILLANCE REQUIREMENTS FOR VALVES AND DAMPERS LOCKED IN THE ACTUATED POSITION FOR INFORMATION ONLY (4 Pages Follow)
SBVS B 3.6.9 Prairie Island Units 1 and 2 B 3.6.9-5 Revision 242 BASES SURVEILLANCE SR 3.6.9.2 REQUIREMENTS (continued)
This SR verifies that the required SBVS filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).
The VFTP includes testing HEPA filter performance and minimum system flow rate. Specific test frequencies and additional information are discussed in detail in the VFTP.
SR 3.6.9.3 The automatic startup ensures that each SBVS train responds properly.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.6.9.4 The SBVS isolation dampers are tested to verify OPERABILITY.
The dampers are in the closed position during normal plant operation and must reposition for accident operation to draw air through the filters.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
Insert
CRSVS B 3.7.10 Prairie Island Units 1 and 2 B 3.7.10-9 Revision 242 BASES SURVEILLANCE SR 3.7.10.3 REQUIREMENTS (continued)
The CRSVS may be actuated by either a safety injection signal or a high radiation signal. This SR verifies that each CRSVS train starts and operates on an actual or simulated safety injection actuation signal and verifies each CRSVS train starts and operates on an actual or simulated high radiation signal.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.7.10.4 This SR verifies proper functioning of the CRSVS in the Emergency Mode (Ref. 1). During operation, in the Emergency Mode, the CRSVS train is designed to provide 4000 + 10% cfm through the PAC filter unit.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.7.10.5 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air in-leakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.
The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem whole body or its equivalent to any part of the body or 5 rem TEDE, as applicable, and the CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air in-leakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air in-leakage is greater than Insert
ABSVS B 3.7.12 Prairie Island Units 1 and 2 B 3.7.12-8 Revision 267 BASES SURVEILLANCE SR 3.7.12.3 (continued)
REQUIREMENTS The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.7.12.4 The ABSVS initiates on a safety injection signal, high radiation signal or manual actuation. This SR verifies that each ABSVS train starts and operates on an actual or simulated safety injection actuation signal, high radiation signal, or on manual initiation. The high radiation actuation signal is only required during movement of irradiated fuel assemblies.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
- 1. USAR, Appendix G.
- 2. USAR, Section 10.3.
- 3. USAR, Section 14.
- 4. USAR, Section 6.7.
- 5. 10 CFR 50.67.
- 6. NSPM licensing submittal dated February 24, 2012, "Response to Request for Additional Information (RAI) Associated with Adoption of the Alternative Source Term (AST) Methodology."
Insert
INSERT The SR excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured.
Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency.