L-PI-19-006, Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements

Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements

ML19029B311
Person / Time
Site:	Prairie Island
Issue date:	01/29/2019
From:	Sharp S Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-19-006
Download: ML19029B311 (18)

Text

1717 Wakonade Drive Welch, MN 55089 fl Xcel Energy*

RESPONSIBLE BY NATURE 800.895.4999 xcelenergy.com January 29, 2019 L-PI-19-006 10 CFR 50.90 10 CFR 50.91(a)(5)

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Unit 2 Docket No. 50-306 Renewed Facility Operating License No. DPR-60 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), hereby requests a one-time amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP) Unit 2.

The proposed change to TS 3.8.1 Condition E would extend the Completion Time for two diesel generators inoperable for Unit 2 from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during periods when outside air temperatures fall below -30 degrees F from January 29, 2019 through January 31, 2019, which is below the intake air temperature limit specified by the diesel generator vendor (SACM).

NSPM has evaluated the changes proposed in this license amendment request (LAR) in accordance with 10 CFR 50.92 and concluded that they involved no significant hazards consideration. In accordance with 10 CFR 50.91(b)(1), a copy of this application, with the enclosure, is being provided to the designated Minnesota Official.

Due to the inability to anticipate the extreme weather that is being forecast for PINGP, NSPM requests this LAR be processed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of receipt as an emergency LAR in accordance with 10 CFR 50.91(a)(5).

The Enclosure provides NSPMs evaluation of the proposed change, marked up and clean (retyped) copies of the applicable TS page.

Document Control Desk Page 2 If there are any questions or if additional information is needed , please contact Mr. Leonard Sueper at (612) 330-6917.

Summary of Commitments NSPM commits to putting in place and maintaining the compensatory measures described in Section 3.5 of the enclosure for the period of time when the one-time extension will be in E v-2*2019 effect.

I declare under penalty of perjury, that the foregoing is true and correct.

---Site Scott Sharp Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region 111, USNRC Project Manager, Prairie Island , USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota

ENCLOSURE PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 Evaluation of the Proposed Change Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY ANALYSIS

4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA 4.2 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

4.3 CONCLUSION

S

6.0 REFERENCES

ATTACHMENTS:

1. Technical Specification Pages (Markup)

2. Technical Specification Pages (Retyped)

Page 1 of 12

L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), requests an amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP) Unit 2. The proposed change to TS 3.8.1 Condition E would extend the Completion Time (CT) associated with two diesel generators (DGs) inoperable for Unit 2 from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from January 29 through January 31, 2019. The National Weather Service has forecast the ambient temperatures in the vicinity of PINGP may at times fall below -30 degrees F during this period, which is below the intake air temperature limit specified by the diesel generator vendor (SACM). NSPM asks this change be approved as an emergency license amendment in accordance with 10 CFR 50.91(a)(5).

2.0 DETAILED DESCRIPTION 2.1 PRAIRIE ISLAND EMERGENCY DIESEL GENERATORS The Unit 2 Emergency DGs consist of two tandem-drive units (gensets) manufactured by Societe Alsacienne de Constructions Mecaniques de Mulhouse (SACM), each rated at 5400 KW continuous (8760 hr basis), 0.8 power factor, 1200 rpm, 4160V, 3-phase, 60 Hertz. The gensets are radiator cooled independent of the plant cooling water system.

Each Emergency DG is automatically started by either of the following events:

a. Undervoltage, which envelopes loss of voltage, including a loss of offsite power (LOOP), or degraded voltage on the associated 4160 Volt buses. Automatic starting of the Emergency DGs is initiated by a modified 2-out-of-4 voltage relay scheme on each 4160 Volt bus to which the DG is to be connected.

b. Initiation of a Safety Injection (SI) signal (both of the affected Units DGs start on this signal).

Loading on the DGs is analyzed for a worst case condition as represented by a SI signal coincident with a LOOP. However, a small break loss of coolant accident (LOCA) that was sufficient to initiate automatic SI action would represent the same inrush KVA load on the DG. If the break is so small that automatic SI is not initiated, manual action would be required as soon as the operator is aware of the break. Manual action would represent loads less than or equal to that analyzed in the calculations.

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L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements The Unit 2 DGs meet the requirements of Reg. Guide 1.9, Revision 2, except portions of the 1984 Edition of IEEE 387 were implemented in the factory testing instead of the 1977 revision (NSP letter to NRC, September 9, 1989).

The air intake temperatures of the Unit 2 SACM DGs are limited to -30 degrees F to 103 degrees F. Conversely, the Unit 1 DGs were manufactured by Fairbanks Morse and draw combustion air from a protected area within the Service Building.

Station Blackout A Station Blackout (SBO) exists when there is a LOOP and concurrent loss of both of a units DGs sources. An SBO is assumed to occur on only one Unit of a two unit site, in accordance with Reg. Guide 1.155. Prairie Island meets the SBO rule of 10 CFR 50.63 (June 21, 1988) and the related guidance of Reg. Guide 1.155 (August, 1988). Prairie Island is classified as a four hour plant (four hour SBO duration) based on criteria contained in Reg. Guide 1.155 and NUMARC-8700. In accordance with Reg. Guide 1.155 and NUMARC-8700, it has been demonstrated by testing that alternate AC (AAC) from the non-SBO units DG is available and the interconnecting bus ties can be manually closed within ten minutes of the realization that an SBO condition exists to provide power to the required loads on the SBO unit . Analysis has shown that the AAC has sufficient capacity to supply the required loads for the non-SBO unit plus the required loads of the SBO unit for the required four hour SBO duration and that adequate condensate inventory is available to provide decay heat removal for the four hour SBO duration. Additional coping analyses for other plant systems are not required for the SBO unit per Reg. Guide 1.155 and NUMARC-8700 due to the alignment of AAC to the SBO unit within ten minutes of the realization that an SBO condition exists.

DG Loading criteria:

Because of the low probability of either an SBO or DBA occurring, the simultaneous occurrence of a DBA and SBO is not credible. NUMARC 8700 provides the loading criteria for a DG in the non-SBO unit cross-tied to the SBO unit and requires the DG to carry: (1) the loss of off-site power safe shutdown loads on the non-SBO unit, and (2) the SBO loads on the SBO unit for the required coping duration. Reference NUMARC 8700 Appendix J Question and Answer B.3.

2.2 CURRENT TECHNICAL SPECIFICATION REQUIREMENTS TS 3.8.1 Limiting Condition for Operation (LCO) for Unit 2 requires two paths between the offsite transmission grid and the onsite 4 kV Safeguards Distribution System and two DGs capable of supplying the onsite 4 kV Safeguards Distribution System be OPERABLE in MODES 1, 2, 3 and 4.

Page 3 of 12

L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements The REQUIRED ACTION for TS 3.8.1 LCO CONDITION E when two DGs are INOPERABLE is to restore one DG to OPERABLE status within a Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. If CONDITION E is not met, CONDITION F requires the unit be placed in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

2.3 REASON FOR PROPOSED CHANGE This emergency license amendment request (LAR) is being requested to avoid an unnecessary transient as a result of an unanticipated extreme cold weather pattern. The National Weather Service has forecast the ambient temperatures in the vicinity of PINGP may periodically drop below the -30 degree F minimum intake air temperature limits of the PINGP Unit 2 DGs, as specified by SACM, from January 29 through January 31, 2019. While both Unit 2 DGs will remain in a standby mode, their ability to perform their safety function cannot be assured.

2.4 PROPOSED CHANGE

This LAR proposes to add a footnote modifying the current CT associated with LIMITING CONDITION OF OPERATION (LCO) 3.8.1 CONDITION E:

CONDITION REQUIRED ACTION COMPLETION TIME E. Two DGs inoperable E.1 Restore one DG to 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s*

OPERABLE status.

The footnote will state: *A one-time change increased the Completion Time to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Unit 2 during the period from January 29 through January 31, 2019. This change was approved via an emergency license amendment.

3.0 TECHNICAL EVALUATION

3.1 COMPLIANCE WITH CURRENT REGULATIONS AND COMMITMENTS The DGs comply with the applicable General Design Criteria (GDCs) (see Section 4.0 for additional information). The proposed change only affects the TS CT and does not involve a change to the design or method of operation of the Unit 2 DGs. Conformance to the GDC criteria is not altered by the proposed change.

The regulatory requirements related to the contents of TS are contained in 10 CFR 50.36. Pursuant to 10 CFR 50.36, TS are required to contain (1) safety limits, limiting safety system settings, and limiting control settings, (2) limiting conditions for operation (LCO), (3) surveillance requirements, (4) design features, and (5) administrative controls.

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L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements The regulations in 10 CFR 50.36(c)(2) state that the LCOs are the lowest functional capability or performance level of equipment required for safe operation of the facility and when LCOs are not met, the licensee shall shut down the reactor or follow any remedial actions permitted by the TS until the LCO can be met.

This proposed revision to the Technical Specifications (TS) provides the plant-specific review that supports a finding of continued adequate protection of public health and safety. Although it is less restrictive than the current TS requirement, it still affords adequate assurance of safety when judged against the current regulatory standards. The proposed one-time change in the CT for TS condition 3.8.1.E for Unit 2 DGs associated with limiting conditions for operation is proposed in accordance with 10 CFR 50.90. The detailed technical evaluation is provided in Sections 3.2 through 3.6.

There are no other license conditions or orders applicable to this proposed change.

3.2 DEFENSE IN DEPTH The impact of the proposed one-time change in the CT for TS LCO 3.8.1 Condition E for Unit 2 DGs was evaluated and is consistent with the defense-in-depth philosophy and also ensures the adequate protection of the public health and safety.

PINGPs normal administrative controls will be used during the extended CT which includes protecting opposite unit systems and support systems. Compensatory measures above and beyond those required by plant procedure will be employed as further risk management actions. However, no credit for these measures were taken in the probabilistic risk assessment (PRA) performed for the proposed CT extension.

The following plant features support the defense in depth of the plants design:

Unit 1 DGs Defense in depth is primarily maintained by the TS requirement for operability of the Unit 1 DGs. Each DG, as a backup to the normal standby AC power supply, is capable of sequentially starting and supplying the power requirements of one of the redundant sets of engineered safety features for its Unit. In addition, in the event of a SBO condition, each DG is capable of sequentially starting and supplying the power requirements of the hot shutdown loads for its unit, as well as the essential loads of the blacked out unit, through the use of manual bus tie breakers interconnecting the 4160V buses. The limited increase in unavailability for the proposed one-time change in CT for TS LCO 3.8.1 Condition E does not significantly change the balance among the defense in depth principles over prevention of core damage, prevention of containment failure, and consequence mitigation.

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L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements Redundancy of Offsite Sources There are five transmission lines that connect PINGP to the transmission system. There are four possible paths each between the offsite transmission system and the Unit 1 and Unit 2 safeguard 4160V buses. Each path is capable of providing the required power to shutdown the reactor and maintain it in a shutdown condition.

Auxilliary Feedwater System (AFW)

Both PINGP Units 1 and 2 have a steam-driven and motor-driven AFW pump. However, a cross-connection between the discharge lines of the motor-driven pumps provide flexibility during emergencies.

Cooling Water System The PINGP Cooling Water System has been designed to provide redundant cooling water supplies with isolation valves to auxiliary feedwater pumps, Unit 1 DGs, air compressors, component cooling water heat exchangers, containment fan-coil units, and the Auxiliary Building unit coolers. Normal operation utilizes two horizontal pumps with the vertical motor-driven pump as a standby. Two vertical diesel driven pumps are provided for emergency operation. The diesel driven pumps are used whenever an engineered safety features sequence is initiated, when discharge header pressure drops below its setpoint, or on a LOOP.

FLEX Equipment PINGP has implemented a FLEX program that meets the requirements of NEI 12-06.

The FLEX equipment is capable of operating to -40 degrees F. The FLEX generators have the ability to repower selected 480V motor control centers and the FLEX pumps are capable of injecting into the steam generators.

3.3 SUFFICIENT SAFETY MARGINS The proposed one-time change in the CT for TS condition 3.8.1.E does not conflict with existing codes and standards applicable to PINGP. There are no codes or standards that place a limit on the CT for emergency AC power sources. There is no change in plant configuration associated with the proposed changes. The same configuration conditions exist for the extended CT as is currently allowed for a CT of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The safety analysis acceptance criteria would continue to be met during the extended CT. The Required Actions associated with the requested change will continue to assure adequate safety margins are preserved for maintaining the DGs and offsite power sources.

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L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements 3.4 PRA RISK INSIGHTS The change in risk associated with the one-time increase in the CT for LCO 3.8.1 Condition E has been evaluated for both PINGP units against the acceptance criteria in Inspection Manual Chapter- 0410, which is less than or equal to an ICCDP of 5E-7 and an ICLERP of 5E-8.

Although PINGP is requesting a one-time extension of the TS LCO 3.8.1 Condition E CT from 2 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the change in incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP) were evaluated assuming both Unit 2 DGs are inoperable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using the zero-maintenance PRA model. The results are as follows:

ICCDP (24 Hours) ICLERP (24 Hours)

Unit 2 LCO 3.8.1 CONDITION 2.55E-08 (Unit 1) 7.12E-11 (Unit 1)

E Completion Time Extension 2.10E-07 (Unit 2) 3.20E-08 (Unit 2)

The dominant risk contributors resulting from this evaluation are as follows:

Unit 1: The dominant ICCDP contributors are LOOP events which are designated in the Transient Event Tree as sequence TR1-017 (SBO event). These are LOOP events in which the reactor is subcritical, power-operated relief valves (PORV)s are not challenged or do not stick open. The Unit 1 EDGs fail to supply power to at least one 4kV safeguards bus. The reactor coolant pump (RCP) seals remain intact and the turbine driven Auxiliary Feedwater (AFW) pump runs until the batteries deplete. With the Unit 2 DGs (D5 or D6) unavailable for 4kV safeguards bus cross-tie and early offsite power recovery failed (within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />), AC power is not recovered prior to battery depletion which results in core damage.

Dominant ICLERP contributors are LOOP events with random failure of the Unit 1 EDGs and the failure to perform 4kV safeguards bus cross-tie due to unavailability of the D5/D6 (sequences TR1-017). This results in a SBO event and core damage. A pre-existing containment leak results in a release.

Unit 2: The dominant ICCDP contributors include Steam Generator Tube Rupture (SGTR), LOCA and Main Feedwater/Steam Line Break (MFLB) events followed by consequential LOOP. These events are considered to be a SBO because with both D5 and D6 failed, no power is available to the Unit 2 safeguards buses to power necessary mitigation equipment and the event will go directly to core damage. The cross-tie capability to the Unit 1 EDGs is available but was not included in the PRA modeled for Page 7 of 12

L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements these scenarios since detail recovery timing assessment was not available at the time this version of the PRA model was completed.

Other dominant Unit 2 ICCDP contributors are LOOP events which are designated in the Transient Event Tree as sequence TR1-020. These are LOOP events in which the reactor is subcritical, PORVs are not challenged or do not stick open. The operators successfully cross-tie the Unit 1 EDGs to at least one Unit 2 - 4kV safeguards bus. The RCP seals remain intact. However, the turbine driven AFW pump fails to operate requiring operators to initiate feed and bleed. Due to the limited capacity of the Unit 1 EDGs, high head recirculation operation requires restoration of offsite power or Unit 2 EDGs. AC power is not recovered prior to high head recirculation which results in core damage.

Dominant ICLERP contributors include SGTR, LOCA and MFLB events followed by consequential LOOP. These events are considered to be a SBO because with both D5 and D6 failed, no power is available to the Unit 2 safeguards buses to power necessary mitigation equipment and the event will go directly to core damage. As mentioned in the ICCDP cutset review, the cross-tie capability to the Unit 1 EDGs is available but was not included in the PRA modeled for these scenarios since detail recovery timing assessment was not available at the time this version of the PRA model was completed.

A release occurs due to a pre-existing containment leak, containment failure or a direct containment bypass event in the case of the SGTR.

3.5 COMPENSATORY MEASURES The following compensatory measures will be put in place for the duration of the extended LCO 3.8.1 Condition E CT when two DGs are rendered inoperable:

1. The Unit 1 and Unit 2 AC Power Supply Systems will be protected including Unit 1 and Unit 2 DGs, Unit 1 and Unit 2 4KV safeguards buses and the Station Substation/Switchyard.

2. The Unit 1 and Unit 2 AFW pumps will be protected.

3. The on-shift operation crew will review procedures related to grid conditions and LOOP scenarios, including manual voltage restoration of 4KV switchgear from opposite unit DG.

4. The on-shift operation crew will review procedures related to AFW pump unit cross tie alignment and loss of Heat Sink.

5. Non-essential switchyard and transformer yard activities will be deferred.

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L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements

6. Non-essential surveillances or other maintenance activities on other risk significant equipment, such as the DGs, the ECCS systems, and the AFW system will be deferred.

7. The 12 and 22 Diesel Driven Cooling Water pumps will be protected.

3.6 CONFIGURATION RISK MANAGEMENT PROGRAM Plant procedures implement PINGPs configuration risk management control program.

The basis for PINGPs configuration risk management control program is Maintenance Rule Section 10 CFR 50.65(a)(4). The maintenance rule (MR) requires that licensees perform risk assessments before maintenance activities are performed on SSCs and manage the increase in risk resulting from the planned activities.

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria Title 10 Code of Federal Regulations 50.36, "Technical specifications":

(c) Technical specifications will include items in the following categories:

(2) Limiting conditions for operation. (i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

When a limiting condition for operation of any process step in the system of a fuel reprocessing plant is not met, the licensee shall shut down that part of the operation or follow any remedial action permitted by the technical specifications until the condition can be met. In the case of a nuclear reactor not licensed under

§ 50.21(b) or § 50.22 of this part or fuel reprocessing plant, the licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence. The licensee shall retain the record of the results of each review until the Commission terminates the license for the nuclear reactor or the fuel reprocessing plant. In the case of nuclear power reactors licensed under § 50.21(b) or § 50.22, the licensee shall notify the Commission if required by § 50.72 and shall submit a Licensee Event Report to the Commission as required by § 50.73. In this case, licensees shall retain records associated with preparation of a Licensee Event Report for a period of three years following Page 9 of 12

L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements issuance of the report. For events which do not require a Licensee Event Report, the licensee shall retain each record as required by the technical specifications.

General Design Criteria The construction of the Prairie Island Nuclear Generating Plant was significantly complete prior to issuance of 10 CFR 50, Appendix A, General Design Criteria. The Prairie Island Nuclear Generating Plant was designed and constructed to comply with the Atomic Energy Commission General Design Criteria as proposed on July 10, 1967, (AEC GDC) as described in the plant Updated Safety Analysis Report. AEC GDC proposed Criterion 39 provides design guidance for the operating capability of alternate power systems.

Criterion 39 - Emergency Power For Engineered Safety Features Alternate power systems shall be provided and designed with adequate independency, redundancy, capacity, and testability to permit the functioning required of the engineered safety features. As a minimum, the onsite power system and the offsite power system shall each, independently, provide this capacity assuming a failure of a single active component in each power system.

Thus with the changes proposed in this license amendment request, the requirements of AEC GDC 39 continue to be met and the plant Technical Specifications will continue to provide the basis for safe plant operation.

4.2 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION In accordance with the requirements of 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, d/b/a Xcel Energy (hereafter NSPM), requests an amendment to the Technical Specifications (TS) for the Prairie Island Nuclear Generating Plant (PINGP), Unit 2, Renewed Facility Operating License No. DPR-60. The proposed amendment would extend the CT for LCO 3.8.1 CONDITION E on a one-time basis due to the potential for extreme low ambient temperatures.

NSPM has evaluated the proposed amendment against the standards in 10 CFR 50.92 and has determined that the operation of the PINGP in accordance with the proposed amendment presents no significant hazards. NSPMs evaluation against each of the criteria in 10 CFR 50.92 follows.

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L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The requested action is a one-time extension to the CT of TS LCO 3.8.1 Condition E, two DGs inoperable. Extending the CT does not constitute a precursor to an accident and does not affect the probability of an accident. Therefore, the proposed extension of the CT in this license amendment request (LAR) does not increase the probability of an accident.

The consequences of extending the CT was evaluated and determined to be within the acceptable range allowed by Inspection Manual Chapter 0410. Additionally the compensatory measures that will be put in place provide defense in depth. No new failure modes have been introduced because of this action and the consequences remain consistent with previously evaluated accidents.

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 previously evaluated?

Response: No The proposed amendment does not involve a physical alteration of any SSC or a change in the way any SSC is operated. The proposed amendment does not involve operation of any SSCs in a manner or configuration different from those previously recognized or evaluated. No new failure mechanisms will be introduced by the one-time CT extension being requested.

Therefore, the proposed change does not create the possibility of a new or different kind of accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The overall risk of extending the LCO 3.8.1 Condition E CT from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Unit 2 is minimal and within the limits specified in Inspection Manual Chapter 0410.

Extending the CT does not involve a significant increase in the consequences of an accident. Extending the CT does not involve a change in a methodology used to Page 11 of 12

L-PI-19-006 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements evaluate consequences of an accident. Extending the CT does not involve a change in any operating procedure or process.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluation, NSPM concludes that the proposed amendment does not involve a 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.

4.3 CONCLUSION

S 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.

5.0 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, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent 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.

6.0 REFERENCES

1. NRC Inspection Manual Chapter 0410, "Notices of Enforcement Discretion Page 12 of 12

ENCLOSURE, ATTACHMENT 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements TECHNICAL SPECIFICATION PAGES (Markup)

(1 page follows)

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two DGs inoperable. E.1 Restore one DG to 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s*

OPERABLE status.

F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, B, AND C, D, or E not met.

F.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G. Two DGs inoperable and G.1 Enter LCO 3.0.3. Immediately one or more paths inoperable.

OR One DG inoperable and two paths inoperable.

• A one-time change increased the Completion Time to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Unit 2 during the period from January 29 through January 31, 2019. This change was approved via an emergency license amendment.

Prairie Island Unit 1 - Amendment No. 158, 167 Units 1 and 2 3.8.1-5 _ 157XXX Unit 2 - Amendment No. 149, - f1

ENCLOSURE, ATTACHMENT 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 Emergency License Amendment Request Regarding One-Time Extension for Technical Specification Completion Time Requirements TECHNICAL SPECIFICATION PAGES (Retyped)

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AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two DGs inoperable. E.1 Restore one DG to 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s*

OPERABLE status.

F. Required Action and F.1 Bein MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, B, AND C, D, or E not met.

F.2 Bein MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G. Two DGs inoperable and G.l Enter LCO 3.0.3. Immediately one or more paths inoperable.

OR One DG inoperable and two paths inoperable.

• A one-time change increased the Completion Time to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Unit 2 during the period from January 29 through January 31, 2019. This change was approved via an emergency license amendment.

Prairie Island Unit 1 -Amendment No. -l-38, 167 Units 1 and 2 3.8.1-5 Unit 2 - Amendment No. XXX