ML20133N209

Conformance to Reg Guide 1.97,Prairie Island Nuclear Generating Plant,Units 1 & 2

ML20133N209
Person / Time
Site:	Prairie Island
Issue date:	08/31/1985
From:	Udy A EG&G IDAHO, INC.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20133N190	List: ML20133N186 ML20133N202 ML20133N209
References
CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, TAC-51122, TAC-51123, NUDOCS 8510280451
Download: ML20133N209 (21)

Text

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4 CONFORMANCE TO REGULATORY GUIDE 1.97 PRAIRIE ISLAND NUCLEAR GEhERATING PLANT, UNIT NOS. 1 AND 2 A. L. Udy Published August 1985 EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the l

U.S. Nuclear Regulatory Comission l Washington, D.C. 20555

Under DOE Contract No. DE-AC07-761001570 l FIN No. A6483 i

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8510280451 051018 PDR ADOCK 05000282 PDR y

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t ABSTRACT This EG&G Idano, Inc., report provices a review of the Prairie Island Nuclear Generating Plant, Unit hos. I and 2, submittals for Regulatory Guide 1.97, and ioentifies areas of nonconformance. Any exception to the guidelines is evaluated and those areas where sufficient basis for acceptaoility is not provideo are identified.

i FOREWORD This report is supplied as part of the " Program for Evaluating Licensee / Applicant Conformance to RG 1.97,'" being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation.

l- Division of Systems Integration, by EG&G Idaho, Inc., NRC Licensing Support

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i The U.S. Nuclear Regulatory Commission funded the work under l authorization B&R 20-19-10-11-3.

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l Docket Nos. 50-282 ana 50-306 TAC Nos. 51122 and 51123 11 l

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5 CONTENTS A8STRACT...........................................................'... ii FOREWORD .............................................................. ii

1. INTRODUCTION ..................................................... l-j 2. REVIEW REQUIREMENTS .............................~................. 2

3. EVALUATION ....................................................... 4 3.1 Acherence to Regu latory Gu ide 1.97 . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.2 Ty p e A V a r i a o l e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 l' 3.3 Except ions to Regul atory Gu id e 1.97 . . . . . . . . . . . . . . . . . . . . . . . . 4

. 4. CONCLUSIONS ...................................................... 17

5. REFERENCES ....................................................... 18 4

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CONFORMANCE TO REGULATORY GUIDE 1.97 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT NOS. 1 AND 2 -

1. INTRODUCTION On Decemcer 17, 1982, Generic Letter No. 82-33 (Reference 1) was issueo by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses and hoicers of construction permits. This letter incluoed aeditional clarification regarding Regulatory Guide 1.97, Revis-ion 2 (Reference 2), relating to the requirements for emergency response capacility. These requirenents have been puolishec as Supplement I to NUREG-0737, "THI Action Plan Requirements" (Reference 3).

Northern States Power Company, the licensee for the Prairie Island Nuclear Generating Plant, provided a response to the generic letter on April 15,1983 (Reference 4). On .Septemaer 15, 1983, the response (Reference 5) to the Regulatory Guide 1.97 portion of Generic Letter No. 82-33 (Section 6.2) was provided. Aoditional information was provided on January 18, 1985 (Reference 6) ar.d on June 6, 1985 (Reference 7).

This report provides an evaluation of these submittals.

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2. REVIEW REQUIREMENTS Section o.2 of fiUREG-0737, Supplement No.1, sets forth the doCunentation to De submitted in a report to the NRC describing how the licensee complies with Regulatory Guide 1.97 as applied to energency ~

response facilities. The submittal should incluoe coc' umentation that provides tne following information for each variable shown in the -

applicaule table of Regulatory Guide 1.97. .

1. Instrument range N

2. Environmental qualification > ,

3. Seismic qualification ',, .

4. Quality assurance

5. Redundance and sensor location

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6. Power supply

7. Location of oisplay

8. Schedule of installation or upgrade Furthernare, the suomittal should identify deviations frcm the regulatory -

guide and provide supporting justification or alternatives.

Subsequent to the issuance of the generic letter, the NRC helo regional meetings in February and March 1983, to answer licensee and applicant questions and concerns regarding the NRC policy on this subject. .

At these meetings, it was noted that the NRC review would only address exceptions taken to Regulatory Guioe 1.97. Furthermore, where licensees or applicants explicitly state that instrument systems conform to the -

regulatory guide, it was noted that no further staff review would be i

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necessary . Therefore, this repcrt only addresses exceptions to Regulatory Guice 1.97. The following evaluation is an audit of the licensee's sucmittals based on the review policy described in the fiRC regional meetings.

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4 3.' EVALUATION Tne licensee proviceu a response to the NRC Generic Letter 82-33 on , , .

April 15, 1983. An additional submittal of September 15, 1983, described the licensee's position on post-accident monitoring instrumentation.

Adaitional information was provided on January 18, 1985 and on June 6, 1985. This evaluation is baseo on these submittals. .

i 3.1 Aoherence to Regulatory Guide 1.97 Reference 5 states that "the schedule for completing implementation of all the kegulatory Guide 1.97 requirements was agreed to in a June 24, 1983 meeting." Therefore, it is concluced that the licensee has provided an explicit' commitment of conformance to Regulatory Guide 1.97, except as .

noted in Section 3.3.

3.2 Type A Variables

, Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., those variables that provide information required to perm'it the control room operator to take specific manually contrciled safety actions.+

The licensee classifies the following instrumentation as Type A.

I 1. Reactor coolant system pressure I

• i 2. Refueling water storage tank level. .

This instrumentation meets the Category I reconnendations consistent with the requirements for Type A variaoles.

3.3 Exceptions to Regulatory Guide 1.97 ~

i The licensee identified the following exceptions to the requirements of Regulatory Guide 1.97.

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n 3.3.1 Incomolete Qualification of Catecory 2 Instrumentation 1

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i The following lists Category 2 variables for which the licensee does not have environmentally qualifiec instrumentation.

o Containment effluent racioactivity--noble gases from identifieo release points o Effluent ricioactivity--noble gas effluent from condenser air ejector exhaust i

o Containment effluent radioactivity--noble gases from icentified release' points o Effluent radioactivity--noble gases (inside buildings or areas where penetrations and hatches are locatec) o Resioual neat removal system flow o Rasidual heat removal heat exchanger outlet temperature o Accumulator isolation valve position (sensor)

o Accumulator isolation valve position (status lights) -

o Boric acid charging flow '

o Primary system safety relief valve position o Pressurizer heater status J

o Safety / relief valve status

o Auxiliary feedwater flow o Heat removal by the containaent fan ' heat removal system t

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o Containment atmosphere temperature o Makeup flow-in

! o Letcown flow-out -

o Volume control tank level o Component cooling water temperature to engineereo safety feature system components o Component cooling water flow to engineered safety feature system .

'l o Emergency ventilation damper position ,

o Status of standby power and other energy sources important to safety o Air header pressure o Reactor shield building annulus--noble gases and vent flow rate

! o Condenser air removal system exhaust--noble gases and vent flow rate o Vent from steam generator safety relief valves--noble gases and ~

vent flow rate, duration and mass of steam Environmental qualification has been clarifieo by the Environmental Qualification Rule,10 CFR 50.49. The licensee states, in Reference 6, that the environmental qualification of this post-accident monitoring .

instrumentation will be addressed as part of the 10 CFR 50.49 review

. program. We find this commitment acceptable.

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3.3.2 Reactor Coolant System Soluole Boron Concentration Regulatory Guice 1.97 recommends instrumentation for tnis variable with a range from 0 to 6000 parts per million. The licensee has provided instrumentation for this variable with a range from 0 to 3000 parts per million. Tne licensee's justification for this ceviation from the recommendeo range is tnat the supplieo range is considered acequate, and that the normal cold shutdown concentration is 2000 parts per million.

The licensee also indicates that the sample is taken from the letdown line, which is isolatea on certain containment isolations. When this

- continuous monitor is not available, the post-accident sampling system provides the neeced information.

The licensee deviates from Regulatory Guide 1.97 with respect to post-accident sampling capability. This deviation goes beyond the scope of this review and is being adoressed by the NRC as part of their review of NUREG-0737, item II .B.3.

3.3.3 Reactor Coolant System told Leg Water Temoerature Reactor Coolant System Hot Leg Water Temoerature Regulatory Guide 1.97, Revision 2, specifies a range of 50 to 750 F for these variaoles. The instrumentation provided for these variables has ,

a range from 50 to 700*F. Since Revision 3 of Regulatory Guide 1.97 (Reference 8) lists the range as 50 to 700*F for these variables, we find tnat this is acceptable.

3.3.4 Radiation Level in Circulatino Primary Coolant Regulatory Guide 1.97 recommends instrumentation for this variable for the detection of a breach. The licensee has provided radiation monitoring on the letdown line. The letdown line, however, is isolated during an accident. The licensee also has a post-accident sampling system which provices the capability to cetermine primary coolant activity.

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Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable. -

3.3.5 Effluent Radioactivity--Noble Gas Effluent from Condenser Air Ejector Exhaust Regulatory Guide 1.97 reccmmenas a range of 10-6 to.10'0 uCi/cc -

for tnis variable. The licensee has proviced instrumentation with a range of 10~4 to 10+2 uCi/cc for this variable. The licensee notes that

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the air ejector exhaust is routed to the shield building exhaust, which is 4 monitored by instrumentation that incluaes the recommended range. Based on ,

this, ano since the regulatory guide does not require this variable when the effluent is dischargea through a common plant vent, we find that this instrumentation is ac'ceptable.

3.3.6 Containment Hydrogen Concentration Regulatory Guide 1.97 recommends instrumentation for this variable

- with a range of 0 to 10 percent, and capable of operating from 10 psia to maximum design pressure. The licensee has instrumentation for this variable that meets the range requirements. The deviation identifieo by tne licensee is that the sensor has not been tested from 10 psia to normal atmospheric pressure. It has been environmentally qualified to the requirements of 10 CFR 50.49. The licensee is performing qualification 7

testing, as outlined in Reference 6, to show that th'e sensors are capable of operating at subatmospheric pressures (10 psia).

l 3.3.7 Containment Effluent Radioactivity-Noble Gases from Identified Release Points l

Regulatory Guiae 1.97 recommends instrumentation for this variable with a range from 10"6 to 10 2 uCi/cc. The licensee's instrumentation for this variable has a range from 10~4 to 10 N uCi/cc. They state, in 8

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Refert:nce 6, that this instrumentation refers to the shield builoing vents, wnich ure tne only accident release point for either unit. .

The licensee states that the instrumentation will respono to

-5 1 x 10 uCi/cc, and that releases of less magnituoe than this are below technical specification limits with no significant release taking -

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place. Releases relateo to an accioent would be above this. level. The -

licensee also notes that grab samples are taken routinely, and tnis is the l alternate method of obtaining information for this variable. The minimum sensitivity for the grab sample is 1 x 10-8 uC i/cc .

- Based on the licensee's justification, we find that the range supplied is adequate.

3.3.8 Radiation Exposure Rate I

Regulatory Guide 1.97 recommends instrumentation for this variable

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with a range of 10 to 10 R/hr. The licensee did not provice information on the instrunentation for this variable in Reference 5. The

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licensee notes, in Reference 6, that a study of post-accident plant radiation levels has Deen completed, and as a result, approximately 6

30 instruments covering the recommenced range of 10-I to 104 R/hr would be installed. We find this committment satisfactory.

3.3.9 Effluent Radioactivity--hoble Gases Inside Buildings or Areas Where Penetrations and Hatches are located Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 10-6 to 103 uCi/cc. The licensee has provided instrumentation r

for this variable with a range of 10 to 104 uCi/cc. The licensee states, in Reference 6, that this instrumentation refers to the shield building vents, which are the only accident release points for either unit.

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The licensee states that the instrumentation will respond to 1 x 10-5 uCi/cc, and that releases of less magnitude than this are below technical specification limits with no significant release in taking -

place. Releases related to an accident would be above this level. The licensee also notes that grab samples are taken routinely, and this is the alternate method of obtaining information for this variable. The minimum .

sensitivity for the grao sample is 1 x 10~0 uCi/cc. ,

Based on the licensee's justifica' tion, we find that the range supplied is adequate.

3.3.10 Residual Heat Removal Heat Exchanger Outlet Temperature ,

Revision 2 of kegulatory Guide 1.97 recommends instrumentation for this variable with a range of 32 to 350*F to monitor system operation.

r Revision 3 of R,egulatory Guide 1.97 raised the lower limit of the range from 32*F to 40*F. The licensee has provided instrumentation for this variaole with a range of 100 to 400'F.

The Prairie Island Operation Manual (Reference 9), Section B15-1.3.2 and 6 states that the cesign outlet temperature is 133.5*F. This temperature is maintained by a control room operated flow control valve that bypasses a portion of.the reactor coolant around the heat exchanger.

Thus, tne outlet temperature will be above the minimum range of the

! instrumentation and the indication will remain on scale. Therefore,'we .

find that tnis deviation from the reconinended range is acceptable.

3.3.11 Accumulator Tank Level and Pressure Regulatory Guide 1.97 recommends Category 2 instrumentation for this variaole with a range of 10 to 90 percent volume. The licensee has .

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• provided pressure instrumentation that meets the recounendations of the regulatory guice and Category 3 level instrumentation that indicates 0 to 100 percent. However, 0 percent is equal to 1235.25 cubic feet of the accumulator volume of 2000 cubic feet. The 100 percent indication 10

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corresponcs to 1295 cubic feet. The licensee states that this information is used to verify that the water volume required by technica'l ,

specifications is maintained before an accident. Prcper operation of the -

accumulator curing an accident is ooserved by the operator by observing the accumulator tank pressure oecrease with the reactor coolant system pressure and oy verifying the level instrumentation is off scale. .

The accumulators are passive oevices. Their discharge into the reactor coolant system (RCS) is actuated solely by a decrease in RCS ,

pressure. We find that the instrumentation supplied for this variable is adequate to determine that the accumulators have discharged. Therefore,

. the range of this instrumentation is acceptable for this variable.

3.3.12 Reactor Coolant Pump Status Regulatory Guide 1.97 recommends monitoring the motor current for this variable. The licensee has proviced both motor circuit breaker status and kilowatt usage (0 to o000 kw). Tht. power used by a reactor coolant pump is a direct relation to the pump current. Therefore, we find that measuring the reactor coolant pump power ratner than current is acceptaDie.

3.3.13 Pressurizer Level

' Regulatory Guide 1.97 recomends instrumentation for this variable ,

with a range covering from the top to the bottom of the vessel. The instrumentation provided for this variable does n'ot inaicate tne volume in the hemispherical ends of the vessel. The level indication is provided for tne cylinorical partion of the pressurizer. We find that this deviation is ac .;ept able .

3.3.14 Pressurizer Heater Status I

Regulatory Guide 1.97 recommends Categury 2 instrumentation to monitor the heater current to determine the operating status of the pressurizer heaters. The licensee has supplied comercial grace ON/0FF inoication for each of five heater banks. The licensee, in Reference 7, also commits to install instrumentation to monitor the power used by the pressurizer heater 11 ~

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banks that are supplied power by essential power. This power indication is a direct relation to the current drawn by these heaters, and will assist tne operator in maintaining the load on the diesel generators within the ,

aiesel generator rating.

Based on our review and judgement, we find this deviation of measuring heater input power rather than current acceptable, because the heater power.

has a known relation to the heater current.

3.3.15 Quench Tank Temperature Regulatory Guide 1.97 recommenos instrumantation for this variable with a range of 50 to 750"F. The licensee is providing instrunentation for ~

the variable with a range of 0 to 350*F (Reference 7). The licensee Justifies this ceviation by noting that the range is consistent with the maximum containment temperature, as the pressurizer relief tank has a rupture disc that relieves to the containment atmosphere.

Section B4-l.3.5 of Reference 9 states that the pressurizer relief tank has a full capacity rupture disc that relieves pressure at 85 psig.

Saturated steam at this pressure has a temperature of 328*F. Thus, under accident conditions, this instrumentation will not go off-scale.

The range covers the anticipated requirements for normal operation, anticipated operational occurrences and accident conditions. This range '

relates to the tank rupture disc relief pressure of,85 psig that limits the temperature of the tank contents to saturated steam conditions under 350*F. Thus, we find that this deviation from the regulatory guide is acceptable.

3.3.16- Steam Generator Level .

• Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. As such, redundant instrumentation channels are required. The licensee nas provioed one channel of Category 1 instrumentation for each ,

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e stehm generator, ano a second channel that is Category I except in the area of environmental qualification.

The licensee states in Reference 7, that the non-qualifleo instrumentation will be replaced with fully qualified instrumentation. We fina this ccamitteent acceptable.

3.3.17 Auxiliary Feedwater Flow Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 110 percent of design flow. The licensee identified,

- in Reference 5, instrumentation to monitor the auxiliary feedwater flow witn a range from 0 to 200 gpm. Each auxiliary feedwater pump has a rated flow of 200 gpm. In Reference 6, the licensee states that the instrumentation will be reranged to O to 250 gpm. We find this committment to meet the regulatory guide recommendation acceptable.

3.3.18 Condensate Storage Tank Water Level

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Regulatory Guice 1.97 reccmmends redundant, seismically qualified instrumentation for this variable. The licensee is proposing an additional channel for eacn cf the two tanks, so that each control rocm can monitor the level in either unit's tank. Therefore, sufficient redundancy is innerent in the licensee's proposal. The existing channels are not ,

seismically qualified. The licensee states, in Reference 6, that both the existing and the new instrumentation will be seismically qualified. We fina this acceptaDie.

3.3.19 Containment Spray Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this

, variable with a range of 0 to 110 percent of design flow to monitor the operation of the containment spray system. The licensee does not have flow monitoring instrumentation for this variable.

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J The licensee utilitizes the following alternate instrumentation in the l cuntrol room to monitor the operation of the containment spray syste,m. ,

o Refueling water storage tank level 1 -

. o Caustic additive standpipe level 1

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o Containment spray pump on/off status I i f

o, Containment spray system valve position i 1 i

o Residual heat removal (RHR) heat exchanger inlet temperature .

j o RHR heat exchanger outlet temperature 1

i The alternate instrumentation provided by the licenset is acequate to

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monitor this variaole. Therefore, we find tnis deviation acceptable.

j ,_ 3.3.20 Centainment Sump Water Temperature

! Regulatory Guide 1.97 recommends instrumentation for this variable l with a range of 50 to 250*F to monitor operation of this containment l cooling system. The licensee does not have instrumentation for this l

variable. Their justification for this oeviation is that this function is .

! provided by the residual heat removal temperatures.

The Prairie Islard station has temperature indication fcr residual o

heat removal (RHR) heat exchanger outlet. Temperature indication for the RHR heat exchanger' inlet is being added.

l The RHR heat exchanger inlet temperature will De the sare as the sump l ,

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• temperature when the sump is the water source for the RHR system. We find l this alternative instrumentation acceptable.

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3.3.21 High Level Radioactive Liquid Tank Level Regulatory Guide 1.97 recommends monitoring this variable in the .

control room; the licensee does not monitor this variable in the control room. As Justification for this deviation, the licensee states that waste processing is done locally. Section 6.2(g) of NUREG-0737 Supplement No. I makes allowance for oisplays in locations other than control room control panels. Therefore, we find this deviation acceptable.

3.3.22 Raoicactive Gas Holdup Tank Pressure Regulatory Guide 1.97 recommends monitoring this variable with Category 3 instrumentation with a range of 0 to 150 percent of design pressure to incicate storage capacity. The licensee indicates that the

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waste gas holdup tanks are controlled locally in the auxiliary building, whicn is accessible following an accident. The range is 0 to 150 psig (the design pressure of the tanks). Section 6.2(g) of hUREG-0737, Supplement No.1, makes allowance for displays in locations other th'in control room control panels. We find the local instrumentation accept ele. The waste gas compressors cannot pressurize the radioactive gas holdup tanks beyond 100 psig. Therefore, we find the range of 0 to 150 psig acceptable.

3.3.23 Reactor Shield Building Annulus--Noble Gas Raciation Level ano Flow Rate Regulatory Guide 1.97 recommends instrumentation for this variable witn a range of 10'0 to 10#uCi/cc. The licensee has instrumentation for this variable with a range of 10-4 to 104 uCi/cc. The licensee inoicates that this vent is the common release point for each unit.

The licensee states that the instrumentation will responc to 1 x 10-5 uCi/cc, and that releases of less magnitude than this are below technical specification limits with no significant release taking place. Releases related to an accident would be above this level. The 15

licensee also notes that grat samples are taken routinely, ano this is the alternate raethoc of oDtaining information for this variable. The minimum sensitivity for the grab samples is 1 x 10' uCi/cc. ,

2 Based on the licensee's justification, we find that th'e range supplied is adequate. -

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! 3.3.24 Radiation Exposure Meters Revision 2 of Regulatory Guide 1.97 recomner.ds instrumentation for this variable. The licensee has not provided instrumentation for this 3

variable, citing Revision 3 of the regulatory guide. Revision 3 of Regulatory Guide 1.97 (Reference 6) does not recommend this variable.

Therefore, the licensee deviation from Revision 2 for this variable is acceptable.

3.3.25 Plant and Environs Radiation I

Regulatory Guide 1.97 recommends portable instrumentation for this

'" variable. The licensee has provided instrumentation for this variable that meets the recommenoations of the regulatory guide, except the

! instrumentation for beta particles nas a range identified in Reference 5 i

that goes up to 50 rads /hr, whereas the regulatory guide recommends a range of up to 10 4rads /hr.

I Reference 6 states that an additional portable ' instrument is onsite 4

that has an upper range limit of 1.99 x 10 R/hr beta. This meets the regulatory guide recommendations.

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4. CONCLUSIONS Based on our review, we find that the licensee either conforms to or is justified in deviating from the guidance of Regulatory Guide 1.97.

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I i 5. REFERENCES l

l 4 1. NRC letter, D. G. Eisennut to all Licensees of Operating Reactors,

• i Applicants for Operating Licenses, and Holoers of Construction

, Permits, "Supplenent No. I to NUREG-0737--Requirements for Emergency j kesponse Capaoility (Generic Letter No. 82-33)," December 17, 1982. .

' 2. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess -

Plant and Environs Concitions During ano Following an Accioent, Regulatory Guide 1.97, Revision 2 U.S. Nuclear Regulatory Commission (NRC), Office of Standaros Developaent, Decenter 1980.

! 3. Clarification of TMI Action Plan Recuirements, Recuirements for Emergency Response Capability, NUREG-0737 Supplenent No.1, NRC, Office of tiuclear Reactor Regulation, January 1983.

i 4. Northern States Power Company letter, D. Musolf to Director, Office of

! Nuclear Reactor Regulation, NRC, " Supplement 1 to NUREG-0737-Response to Generic Letter 82-33," April 15,1983. .

5. Northern States Power Comoany letter, D. Musolf to Director, Office of y

Nuclear Reactor Regulation, NRC, "NUREG-0737 Supplement 1-Generic l

Letter 82-33, Regulatory Guide 1.97-Application to Emergency Response i

Facilities," September 15, 1983.

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6. Northern States Power Company letter, D. Musolf to Director, Office of huclear Reactor Regulation, NRC, " Additional Information Related to Conformance with Regulatory Guide 1.97, Revision 2," January 18, 1985.

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7. fiorthern States Pcwer Company letter, D. Musolf to Director, Office of Nuclear Reactor Regulation, NkC, "Aoditional Information Related to I,

Conformance with Regulatory Guide 1.97, Revision 2," June 6,1985.

l 8. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess

! P lant ano Environs Conditions curing ano Following an Accioent,

! Regulatory Guide 1.97, Revision 3, hRC, Of fice of feuclear Regulatory .

Research, May 1983.

9. Prairie Island Operations Manual, Prairie Island Training Center, j

horthern States Power Company.

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