ML20205Q026

Application for Amends to Licenses DPR-42 & DPR-60, Relocating Shutdown Margin Requirements from TS to COLR

ML20205Q026
Person / Time
Site:	Prairie Island
Issue date:	04/12/1999
From:	Sorensen J NORTHERN STATES POWER CO.
To:
Shared Package
ML20205Q023	List: ML20205Q019 ML20205Q026 ML20205Q035
References
NUDOCS 9904210066
Download: ML20205Q026 (8)

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UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLANT DOCKET NO. 50-282 {

50-306 License Amendment Request Dated April 12,1999 Relocation of Shutdown Margin Requirements to the Core Operating Limits Report Northern States Power Company, a Minnesota corporation, with this letter is submitting information to support a requested license amendment.

This letter contains no restricted or other defense information.

l NORTHERN STATES POWER COMPANY BY

/ del P. Sorense'n Site General Manager Prairie Island Nuclear Generating Plant On this /c/d day of AMAd /999 before me a notary public in and for said County, perso6 ally appeared Joel P. Sorensen, Site General Manager, Prairie Island Nuclear Generating Plant; and being first duly sworn acknowledged that he is authorized to execute this document on behalf of Northern States Power Company, that he knows the contents thereof, and that to the best of his knowledge, information, and belief the statements made in it are true and that it is not interposed for delay.

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.3 EXHIBIT A PRAIRIE ISLAND NUCLEAR GENERATING STATION License Amendment Request dated April 12,1999 Evaluation of Proposed Changes to the Tchnical Specifications ,

Appendix A of Operating Licenses DPR-42 and DPR-60 Pursuant to 10 CFR Part 50, Sections 50.59 and 50.90, the holders of Operating Licenses DPR-42 and DPR-60 hereby propose the following changes to the Technical Specifications contained in Appendix A of the Facility Operating Licenses:

BACKGROUND As part of the Prairie Island Nuclear Generating Plant (PINGP) Updated Safety Analysis Report (USAR) review and update pioject, a transient scenario was identified which could potentially place the plant in an unanalyzed condition. The current Chemical and Volume Control System (CVCS) Malfunction analysis in the USAR, Section 14, evaluates the effects from an inadvedent boron dilution in refueling, start-up and power (manual and automatic rod control) operation. The USAR review concluded that the plant is within the design basis as described in the I analyses for these plant conditions. However, per plant Technical Specifications other plant operating conditions are allowed which could be more limiting from a boron dilution analysis perspective. This condition was reported in LER 1-97-12 dated November 7,1997. Administrative controls were implemented to specify higher shutdown margins than specified in the plant Technical Specifications for these other plant conditions to ensure that the analyses in the USAR are bounding.

Consistent with the guidance in NRC Administrative Letter 98-10 "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," this License Amendment Request proposes changes to the Technical Specifications which will ensure that the analyses in the USAR remain bounding. This is being done through the following methods: (1) the shutdown margin requirements are being relocated to the Core Operating Limits Repod (COLR), and (2) the shutdown margin requirements in the COLR will be calculated using methods developed to provide sufficient shutdown margin for postulated dilution accidents for all plant conditions.

The shutdown margin limits being incorporated into the COLR will be developed utilizing methodology described in NSPNAD-8102-P, Revision 7, " Prairie Island Nuclear Power Plant Reload Safety Evaluation Methods For Application to PI Units."

NSPNAD-8102-P, Revision 7, was submitted for NRC review and approval on January 29,1999. That methodology will establish the minimum required shutdown 1

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' limits will ensure that a complete loss of shutdown margin will not occur for at least twenty-four minutes from initiation of the dilution. Pending approval of this License Amendment Request and the new methodology, the USAR will be updated to include analyses for all operating modes.

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! PROPOSED CHANGES In order to relocate shutdown margin requirements to the COLR and ensure that the Technical Specification requirements are consistent with the USAR dilution analysis, several Technical Specification sections require changes. Brief descriptions of the proposed changes are provided below. The specific wording changes to the Technical Specifications are provided in Exhibits B and C. A sample of a portion of the Prairie Island COLR incorporating the shutdown margin limitations developed using the methodology in NSPNAD-8102-P, Revision 7, is provided as Exhibit D.

Table TS.1-1. Operational Modes A reference to the COLR is being incorporated to specify additional shutdown margin requirements for MODE 6 operation. The proposed change will ensure that the most restrictive shutdown margin requirement will be invoked during MODE 6 operation.

TS.3.10.1.A. Control Rod and Power Distribution Limits - Specification The proposed changes incorporate a reference to the COLR for shutdown margin requirements and eliminate the reference to Figure TS.3.10-1. A sample of a portion of the Prairie Island COLR incorporating the shutdown margin limitations is provided as Exhibit D.

TS.3.10.D.3. Rod Insertion Limits The proposed changes relocate the shutdown margin requirements from Figure TS 3.10-1 to the COLR.

Fiaure TS.3.10-1 Reauired Shutdown Marain vs Reactor Boron Concentration The proposed changes delete this figure. The COLR will specify the shutdown margin requirements as shown in Exhibit D. Therefore, this figure will no longer be applicable.

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TS.6.7.A.6. Core Operatina Limits Report Specification 6.7.A.6.a is being revised to add shutdown margin as an operating limit ;

specified in the COLR. No change to Specification 6.7A.6.b is required because a '

reference to the " latest approved version" of the NSP Topical Report NSPNAD-8102-P is already included in Specification 6.7.A.6.b.

License Amendment 141 was issued by the NRC on December 7,1998. That  ;

License Amendment revised the Administrative Controls section of the Technical Specifications. Because of the amount of effort necessary to fully implement the

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j changes resulting from License Amendment 141, fullimplementation of the changes j is not required until September 1,1999. During the interim period, the NRC '

requested that NSP submit two sets of Technical Specification pages for any pages affected in future amendments by the issuance of License Amendment 141. The Technical Specification pages should reflect the conditions before and after full implementation of License Amendment 141 so that the correct Technical pages may be issued in any future amendments. In response to that request, Exhibits E and F contain a revision to Technical Specification page TS.6.0-13. Page TS.6.0-13 was issued with License Amendment 141, and it has been revised to reflect the changes to Section 6.7.A.6.a proposed by this License Amendment Request. l l

B.3.8. Refuelina and Fuel Handlina The Bases for Section 3.8 are being revised in accordance with the Technical Specification changes described above. The changes to the bases are shown in Exhibit B.

B.3.10.A. Control Rod and Power Distribution Limits Bases The Bases for Section 3.10.A are being revised in accordance with the Technical Specification changes described above. A paragraph is also being added to support Technical Specification 3.10.A.2. This paragraph is intended to clarify the bases for the 15 minutes allowed to initiate boration if shutdown margin is less than the applicable limit. The proposed bases for the 15 minute action statement is consistent with that provided in the Improved Standard Technical Specifications (NUREG-1431).

The changes to the Bases are shown in Exhibit B.

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JUSTIFICATION OF CHANGES The proposed changes to Table TS.1-1 invoke an additional third criteria for shutdown margin in order to ensure that adequate shutdown margin is maintained during MODE 6 operation.

This License Amendment Request proposes to relocate the shutdown margin requirements from the Technical Specifications to the COLR. Generic Letter 88-16, dated October 4,1988, was issued to encourage licensees to prepare changes to Technical Specifications related to cycle-specific parameters. The generic letter provided guidance for the relocation of certain cycle-dependent core operating limits from the Technical Specifications. This would allow changes to the values of tnese cycle-dependent core operating limits without prior NRC approval, provided the NRC-approved methodology for the calculations is followed. Shutdown margin was not one of the parameters included in Generic Letter 88-16 that could be relocated to the COLR. However, Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-9, Revision 1, proposed the relocation of shutdown margin requirements from the Technical Specifications to the COLR. That TSTF traveler was approved by the NRC on September 18,1996.

The shutdown margin limits being incorporated into the COLR will be developed utilizing the methodology described in NSP topical report NSPNAD-8102-P, Revision 7. That revision to NSPNAD-8102-P was submitted for NRC review and approval on January 29,1999. That methodology will establish the minimum required shutdown margin for a dilution accident during Modes 3,4,5 and 6.

SAFETY EVALUATION i

The proposed changes to the Prairie Island Technical Specifications relocate the shutdown margin requirements to the COLR.

The shutdown margin requirements being incorporated into the COLR will utilize the methodology submitted by NSPNAD-8102-P, Revision 7, " Prairie Island Nuclear Power Plant Reload Safety Evaluation Methods For Application to PI Units" dated January,1999. NSPNAD-8102-P, Revision 7, was submitted to the NRC for review and approval on January 29,1999. That methodology will establish the minimum required shutdown margin for a dilution accident during Modes 3,4,5 and 6 and will ensure that a complete loss of shutdown margin will not occur for at least twenty-four minutes from initiation of the dilution as specified in the Prairie Island USAR.

The relocation of the shutdown margin requirements to the COLR is an administrative change which has no impact upon plant operation or safety. No safety-related equipment, safety function, or plant operations will be altered as result of the proposed changes. The current Technical Specification shutdown margin 4

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l requirements and the interim additional administrative controls will be maintained and followed until the NRC approves the new methodology.

The proposed changes to Table TS.1-1 which invoke an additional third criteria for l shutdown margin will ensure that adequate shutdown margin is maintained during i MODE 6 operation.

In conclusion, Northern States Power Company believes there is reasonable

assurance that the health and safety of the public will not be adversely affected by the proposed Technical Specification changes.

DETERMINATION OF SIGNIFICANT HAZARDS CONSIDERATIONS The proposed changes to the Prairie Island Operating Licenses have been evaluated to determine whether they constitute a significant hazards consideration l as required by 10 CFR 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below:

i 1. The proposed amendment will not involve a sianificant increase in the probability or conseauences of an accident previousiv evaluated.

The proposed changes do not affect any system that is a contributor to initiating events for previously evaluated design basis accidents. The proposed changes do not involve any system changes or modifications. No systems or equipment will be operated in a new manner as a result of the proposed changes.

Therefore, the proposed changes do not involve a significant increase in the probability of an accident previously evaluated.

l Relocation of the shutdown margin requirements to the COLR is an administrative change. The shutdown margin requirements being incorporated into the COLR will be developed using NRC approved methodology. That methodology will establish the minimum required shutdown margin for a dilution accident during Modes 3,4,5 and 6 and will ensure that a complete loss of shutdown margin will not occur for at least twenty-four minutes from initiation of the dilution as specified in the Prairie Island USAR. Therefore, the relocation of the shutdown margin requirements to the COLR will not result in any increase in the consequences of an accident previously evaluated.

The proposed changes to Table TS.1-1 invoke an additional third criteria for shutdown margin during MODE 6. This proposed change involves an additional restriction designed to ensure that shutdown margin is maintained during MODE 6 operation, and as such will not result in any increase in the consequences of

[.. an accident previously evaluated.

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1 Therefore, based on the conclusions of the above analysis, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The, proposed amendment will not create the possibility of a new or different kind l of aocident from any accident previously analyzed.

The proposed changes do not alter the design or function of any plant l component and do not install any new or different equipment. The proposed  !

changes do not alter the operation of any plant component in a manner which could lead to a new or different kind of accident. Therefore the possibillty of a new or different kind of accident from those previously analyzed has not been created.

3. The proposed amendment will not involve a sianificant reduction in the marain of  !

safety.

Relocation of the shutdown margin requirements to the COLR is an administrative change. The shutdown margin requirements being incorporated into the COLR will be developed using NRC approved methodology. That methodology wiil establish the minimum required shutdown margin for a dilution accident during Modes 3,4,5 and 6 and will ensure that a complete loss of shutdown margin will not occur for at least twenty-four minutes from initiation of the dilution as .specified in the Prairie Island USAR. Therefore, the relocation of the shutdown margin requirernents to the COLR will not reduce the margin of safety because it has no effect on any safety analyses assumptions.

The proposed changes to Table TS.1-1 invoke an additional third criteria for l

shutdown margin during MODE 6. This proposed change involves an additional restriction designed to enhance plant safety by ensuring that shutdown margin is maintained during MODE 6 operation. The imposition of more restrictive requirements either has no effect on or increases the margin of plant safety. The change maintains requirements within the safety analyses and licensing basis.

Therefore, the proposed changes to Table TS.1-1 do not involve a significant reduction in the margin of safety.

Therefore, based on the conclusions of the above analysis, the proposed changes do not involve a significant reduction in the margin of safety.

Considering the above evaluation and pursuant to 10CFR50.91, Northern States Power Company has determined that operation of the Prairie Island Nuclear Generating Plant in accordance with the proposed license amendment request does not involve a significant hazards consideration as defined by Nuclear Regulatory Commission regulations in 10CFR50.92.

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ENVIRONMENTAL ASSESSMENT Northern States Pcwer Company has evaluated the proposed changes and determined that:

1. The changes do not involve a significant hazards consideration,

2. The changes do not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and

3. The changes do not involve a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR51.22(b), an environmental assessment of the proposed changes is not required.

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