ML20238C696

Application for Amends to Licenses DPR-42 & DPR-60,revising Tech Spec Page 5.1-2 Re Flood Protection Measures Periodic Drills

ML20238C696
Person / Time
Site:	Prairie Island
Issue date:	12/18/1987
From:	Musolf D NORTHERN STATES POWER CO.
To:
Shared Package
ML20238C692	List: ML20238C690 ML20238C696 ML20238C701
References
NUDOCS 8712310166
Download: ML20238C696 (7)

Text

• UNITED STATES NUCLEAR REGUIATORY COMMISSION NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLANT DOCKET NO. 50-282 50-306 REQUEST FOR AMENDMENT TO OPERATING LICENSE DPR-42 & DPR-60 LICENSE AMENDMENT REQUEST DATED December 18, 1987 Northern States Power Company, a Minnesota corporation, requests authorization for changes to Appendix A of the Prairie Island Operating License as shown on the attachments labeled Exhibits A, B, and C. Exhibit A describes the proposed changes, describes the reasons for the changes, and contains a significant hazards eval-uation. Exhibits B and C are copies of the Prairie Island Technical Specifications incorporating the proposed changes. Exhibit D is a copy of the Prairie Island Flood Procedure, AB-4.

This letter contains no restricted or other defense information.

NORTHERN STATES POWER COMPANY By

• l David Musolf A Manager-Nuclear Support Services i

On this /[ day of h e /sv lbefore me a notary public in and for said County, personal y appeared David Musolf, Manag-er-Nuclear Support Services, and being first duly sworn acknowl-edged that he is authorized to execute this document on behalf of ]

l Northern States Power Company, that he knows the contents there-of, and that to the best of his knowledge, information, and be-lief the statements made in it are true and that is is not inter-posed for delay.

ee::.v:::.v:::::- :::- :- :. . .::- 1 JUDY L KLAPPERICK i

NOTARY PUBLIC--MINN(NTA 4 ANOKA COUNTY )

My Commmen Emres Sept 29,1991 n :.::::::::::v::.v:::::::::::: ::e l 8712310166 871218 PDR ADOCK 05000282 P DCD

EXHIBIT A Prairie Island Nuclear Generating Plant License Amendment Recuest Dated December 18. 1987 l

Evaluation of Proposed Changes to the Technical Specifications Appendix A of l Operating License DPR-42 and DPR-60 1

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 Appendix A, Technical Specifications:

Flood Protection Measures. Periodic Drills _ . _

l Proposed Chances (TS 5.1)

Change the words which read, "

.. will include requirements for periodic drills to test flood protection measures, such as erecting flood protection panels ", to read " . will include requirements for periodic inspection of flood protection measures.".

Reason for Chanpe _

The current Technical Specification requirement for periodic drills to test flood protection measures, such as erecting flood prctection panels, is impractical. The majority of the actions called for by the Prairie Island Flood Procedure, AB-4 (Exhibit D), are basic and routine actions for plant personnel such as surveillance of equipment, operating water control gates, and racking open electrical breakers. The only actions called for which are not typical operations carried out by plant personnel regularly is sandbagging and installation of the main building and screen house " bulkheads" as called for in items 4.H.8 and 4.H.9 of the Flood Procedure. Sandbagging is considered a basic task not requiring drills. Installation of bulkheads is the only action not considered to be routine or basic.

However, the operation of installing the bulkheads is an extremely simple procedure. Figures 1 and 2 show illustrations of typical rolling and lifting flood protection panels. As can be seen from the illustrations, the basic operation of the bulkheads requires only unbolting the doors from their storage positions, rolling or lifting them (Sto place, and bolting them into position. In addition to the basic operation of installing the bulkheads, some of the panels require that obstructions be removed. These obstructions include items such as miscellaneous non-safety related conduit and piping, door handles and asphalt ramps leading to some external doors. The operations required to remove these obstructions are basic tasks frequently performed at any industrial facility.

A-1

. I

. EXHIBIT A >

Installing the bulkheads is not something that is required to be done on 1 l

a moments notice. Long range advisories and three-day forecasts of river stage and crest are supplied by the National Weather Service for Gage stations on the Mississippi River and its major tributaries. Advisory and forecast reports are released over the Minneapolis-St. Paul local weather teletype circuit and received directly at a teletype station in the NSP system dispatch center. The means to readily interpret these projections for specific locations between gage stations was developed in cooperation with the Army Corps of Engineers. Advance planning and preliminary arrangements for operation during floods is based on the advisory reports of flood potential. Implementation of flood procedures is based on the three-day forecasts of flood stage and actual flood stage at the plant site. Therefore, the minimum time the plant would have to accomplish the installation of the 14-flood protection panels is three days.

In lieu of the requirement for periodic drills, periodic inspection of l the flood protection measures would be performed. This would be accomplished by developing and implementing a detailed procedure which would list each bulkhead individually and provide step by step actions .j necessary to install that bulkhead. This would include any obstructions which need to be removed. This procedure would then be revised annually to reflect any changes made in the vicinity of the doors to be protected ,

which would affect bulkhead installation. This procedure would {

l coordinate the actions of the plant personnel necessary to facilitate l installation of the bulkheads and would preclude the need for periodic 3 drills.

Safety Evaluation and Determination of Significant Hazards Considerations The proposed change to the Operating License has been evaluated to \

1 determine whether it constitutes a significant hazards consideration as '

required by 10 CFR Part 50, Section 50.91 using standards provided in Section 50.92. This analysis is provided below:

1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

l The operation of the Prairie Island Nuclear Generating Plant under

) flood conditions has been analyzed. A summary of these analyses is included in Chapter 2 of the Updated Safety Analysis Report (USAR).

The USAR states, "The Prairie Island plant is designed for normal operation to a flood stage elevation of 698 feet. Since the 1,000 year recurrence flood level is 693.5 feet, it is highly improbable that any extraordinary flood procedures will have to be implemented during the life of the plant." It goes on to state, "In the event l that three-day forecasts project a crest in excess of 695.0, i bulkheads, which are stored onsite, will be installed to close all l

openings in the flood protection walls and sandbag barriers will be constructed around the substation control house. Otherwise normal A-2 l

J

. EXHIBIT A operation will continue to a stage elevation of approximately 698.0."

Even though, the USAR concludes that the bulkheads do not need to be installed until predictions exceeding the 695' elevation are received and normal operation can continue until the 698' elevation, the flood I procedure, AB-4 calls for bulkhead installation of the bulkheads to be started at a predicted level of 692' and the Technical Specifications (TS.6.5.A.6) require plant shutdown for water levels at the site higher that 692' elevation.

Because the actions necessary to accomplish installation are basic skills commonly practiced, drills are not necessary to train plant personnel to respond to a flood situation. The preparation of a detailed procedure outlining the steps necessary to install each individual bulkhead and its review annually following inspection of the bulkheads will improve ability of plant personnel to respond to a flood situation, In addition, while the USAR allows for actions to be initiated at predicted levels of 695' and 698', the procedure for implementation and Technical Specifications call for action at a predicted level of 692 feet. For these reasons, the proposed amendment will 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 f different kind of accident from any accident previously analyzed. 3 No physical change is being made to the plant or its flood j projections devices. The flood level which triggers installation of '

the bulkheads, the amount of time from initiation to when installation is necessary and the complexity of the installation has not changed. For these reasons, the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.

3. The proposed amendment will not involve a significant reduction in the margin of safety.

The operation of the Prairie Island Nuclear Generating Plant under flood conditions has been analyzed. A summary of these analyses is included in Chapter 2 of the Updated Safety Analysis Report (USAR).

The USAR states, "In the event that three-day forecasts project a crest in excess of 695.0, bulkheads, which are stored onsite, will be installed to close all openings in the flood protection walls and sandbag barriers will be constructed around the substation control house. The statement contained in the USAR that the bulkheads will be installed in the event of flood levels over the 695.0 elevation continues to be valid. For this reason, the proposed amendment does not reduce the margin of safety.

The commission has provided guidance (March 6, 1986 Federal Register) concerning the application of the standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists by A-3

'}

u______________-________________________ _____ _ _ - . -- - - - -

4 EXHIBIT A providing certain examples of amendments that will likely be found to involve no significant hazards considerations. The changes to the Prairie Island Technical Specifications proposed in this amendment request are equivalent to NRC example (vi), because they involve changes ]

which either may result in some change in the probability or consequences of a previously analyzed accident or may change in some way a safety ,

margin, but where the results of the change are clearly within all 1 acceptance criteria. Based on this guidance and the reason discussed I j above, we have concluded that the proposed changes do not involve a significant hazards consideration.

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