Letter Sequence Response to RAI |
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TAC:MD4095, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed) |
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Category:Letter type:L
MONTHYEARL-MT-23-054, Subsequent License Renewal Application Supplement 82024-01-11011 January 2024
Subsequent License Renewal Application Supplement 8
L-MT-23-047, License Amendment Request: Revision to the MNGP Pressure Temperature Limits Report to Change the Neutron Fluence Methodology and Incorporate New Surveillance Capsule Data2023-12-29029 December 2023
License Amendment Request: Revision to the MNGP Pressure Temperature Limits Report to Change the Neutron Fluence Methodology and Incorporate New Surveillance Capsule Data
L-MT-23-056, Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 Part 22023-12-18018 December 2023
Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 Part 2
L-MT-23-042, 2023 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.462023-12-11011 December 2023
2023 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.46
L-MT-23-052, Subsequent License Renewal Application Supplement 72023-11-30030 November 2023
Subsequent License Renewal Application Supplement 7
L-MT-23-051, Update to the Technical Specification Bases2023-11-28028 November 2023
Update to the Technical Specification Bases
L-MT-23-049, Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 12023-11-21021 November 2023
Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1
L-MT-23-043, 10 CFR 50.55a(z)(1) Request Regarding OMN-17, Revision 1. VR-092023-11-13013 November 2023
10 CFR 50.55a(z)(1) Request Regarding OMN-17, Revision 1. VR-09
L-MT-23-038, License Amendment Request to Revise Monticello Technical Specification Surveillance Requirement 3.8.6.62023-11-10010 November 2023
License Amendment Request to Revise Monticello Technical Specification Surveillance Requirement 3.8.6.6
L-MT-23-046, Subsequent License Renewal Application Response to Request for Additional Information Round 2 - Set 12023-11-0909 November 2023
Subsequent License Renewal Application Response to Request for Additional Information Round 2 - Set 1
L-MT-23-041, Subsequent License Renewal Application Response to Request for Confirmation of Information Set 22023-10-0303 October 2023
Subsequent License Renewal Application Response to Request for Confirmation of Information Set 2
L-MT-23-037, Subsequent License Renewal Application Response to Request for Additional Information Set 32023-09-22022 September 2023
Subsequent License Renewal Application Response to Request for Additional Information Set 3
L-MT-23-036, Subsequent License Renewal Application Response to Request for Additional Information Set 2 and Supplement 62023-09-0505 September 2023
Subsequent License Renewal Application Response to Request for Additional Information Set 2 and Supplement 6
L-MT-23-035, Subsequent License Renewal Application Supplement 52023-08-28028 August 2023
Subsequent License Renewal Application Supplement 5
L-MT-23-034, Subsequent License Renewal Application Response to Request for Additional Information Set 12023-08-15015 August 2023
Subsequent License Renewal Application Response to Request for Additional Information Set 1
L-MT-23-028, 2023 Refueling Outage 90-Day Inservice Inspection (ISI) Summary Report2023-07-31031 July 2023
2023 Refueling Outage 90-Day Inservice Inspection (ISI) Summary Report
L-MT-23-032, 10 CFR 50.55a(z)(2) Request Regarding MO-2397, VR-112023-07-31031 July 2023
10 CFR 50.55a(z)(2) Request Regarding MO-2397, VR-11
L-MT-23-031, Subsequent License Renewal Application Supplement 4 and Responses to Request for Confirmation of Information - Set 12023-07-18018 July 2023
Subsequent License Renewal Application Supplement 4 and Responses to Request for Confirmation of Information - Set 1
L-MT-23-030, Subsequent License Renewal Application Supplement 32023-07-0404 July 2023
Subsequent License Renewal Application Supplement 3
L-MT-23-025, Subsequent License Renewal Application Supplement 22023-06-26026 June 2023
Subsequent License Renewal Application Supplement 2
L-MT-23-019, Submittal of 2022 Annual Radiological Environmental Operating Report2023-05-10010 May 2023
Submittal of 2022 Annual Radiological Environmental Operating Report
L-MT-23-020, Submittal of 2022 Annual Radioactive Effluent Release Report2023-05-10010 May 2023
Submittal of 2022 Annual Radioactive Effluent Release Report
L-MT-23-021, Core Operating Limits Report (COLR) for the Monticello Nuclear Generating Plant for Cycle 322023-05-0202 May 2023
Core Operating Limits Report (COLR) for the Monticello Nuclear Generating Plant for Cycle 32
L-MT-23-017, 2022 Annual Report of Individual Monitoring for the Monticello Nuclear Generating Plant (MNGP)2023-04-18018 April 2023
2022 Annual Report of Individual Monitoring for the Monticello Nuclear Generating Plant (MNGP)
L-MT-23-010, Subsequent License Renewal Application Supplement 12023-04-0303 April 2023
Subsequent License Renewal Application Supplement 1
L-MT-23-013, Core Operating Limits Report (COLR) for Cycle 31, Revision 32023-03-28028 March 2023
Core Operating Limits Report (COLR) for Cycle 31, Revision 3
L-MT-23-012, Core Operating Limits Report (COLR) for Monticello Nuclear Generating Plant Cycle 31, Revision 22023-03-17017 March 2023
Core Operating Limits Report (COLR) for Monticello Nuclear Generating Plant Cycle 31, Revision 2
L-MT-23-008, 10CFR50.55a Request to Use Later Edition of ASME Section XI for ISI Code of Record (RR-003)2023-02-0707 February 2023
10CFR50.55a Request to Use Later Edition of ASME Section XI for ISI Code of Record (RR-003)
L-MT-23-004, CFR 50.55a Request RR-001, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI for the Monticello Third Interval Containment Inservice Inspection Program2023-01-23023 January 2023
CFR 50.55a Request RR-001, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI for the Monticello Third Interval Containment Inservice Inspection Program
L-MT-23-005, Response to the NRC Request for Additional Information Regarding the 50.55a Request Pr 08, HPCI Pump Quarterly Testing (EPID Number L-2022-LLR-0088)2023-01-0606 January 2023
Response to the NRC Request for Additional Information Regarding the 50.55a Request Pr 08, HPCI Pump Quarterly Testing (EPID Number L-2022-LLR-0088)
L-MT-22-049, Industry Groundwater Protection Initiative Special Report2022-12-15015 December 2022
Industry Groundwater Protection Initiative Special Report
L-MT-22-052, L-MT-22-052 Monticello Nuclear Generating Plant 10 CFR 50.55a Request No. Pr 08, Request for HPCI Pump Quarterly Alternative2022-12-15015 December 2022
L-MT-22-052 Monticello Nuclear Generating Plant 10 CFR 50.55a Request No. Pr 08, Request for HPCI Pump Quarterly Alternative
L-MT-22-046, 2022 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.462022-12-13013 December 2022
2022 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.46
L-MT-22-048, Update to the Monticello Technical Specification Bases2022-11-28028 November 2022
Update to the Monticello Technical Specification Bases
L-MT-22-047, Withdrawal of Request for Relief from ASME OM Code for the Sixth Inservice Testing Interval2022-11-10010 November 2022
Withdrawal of Request for Relief from ASME OM Code for the Sixth Inservice Testing Interval
L-MT-22-045, Letter Submitting Post-Exam Package2022-11-0404 November 2022
Letter Submitting Post-Exam Package
L-MT-22-030, Sixth Interval Inservice Testing (1ST) Plan2022-09-0606 September 2022
Sixth Interval Inservice Testing (1ST) Plan
L-MT-22-037, Supplement to 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval, Alternative VR-10, Excess Flow Check Valve Testing Frequency2022-08-29029 August 2022
Supplement to 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval, Alternative VR-10, Excess Flow Check Valve Testing Frequency
L-MT-22-007, Response to Request for Additional Information for the Monticello Nuclear Generating Plant Alternative Request VR-08 (EPID: L-MT-22-007)2022-07-22022 July 2022
Response to Request for Additional Information for the Monticello Nuclear Generating Plant Alternative Request VR-08 (EPID: L-MT-22-007)
L-MT-22-026, Changes to the Emergency Plan2022-07-19019 July 2022
Changes to the Emergency Plan
L-MT-22-024, Response to a Request for Additional Information for the Monticello Nuclear Generating Plant Related to the Amendment to Adopt Advanced Framatome Methodologies2022-06-0606 June 2022
Response to a Request for Additional Information for the Monticello Nuclear Generating Plant Related to the Amendment to Adopt Advanced Framatome Methodologies
L-MT-22-022, Response to a Request for Additional Information: Monticello Alternative VR-10, Excess Flow Check Valve Testing Frequency2022-05-25025 May 2022
Response to a Request for Additional Information: Monticello Alternative VR-10, Excess Flow Check Valve Testing Frequency
L-MT-22-017, 2021 Annual Radiological Environmental Operating Report2022-05-11011 May 2022
2021 Annual Radiological Environmental Operating Report
L-MT-22-018, 2021 Annual Radioactive Effluent Release Report2022-05-11011 May 2022
2021 Annual Radioactive Effluent Release Report
L-MT-22-016, 2021 Annual Report of Individual Monitoring2022-04-28028 April 2022
2021 Annual Report of Individual Monitoring
L-MT-22-019, Withdrawal of Requests for Relief from ASME OM Code for the Sixth Inservice Testing Interval2022-04-18018 April 2022
Withdrawal of Requests for Relief from ASME OM Code for the Sixth Inservice Testing Interval
L-MT-22-010, License Amendment Request to Revise Technical Specification 3.6.1.8 Residual Heat Removal (RHR) Drywell Spray Header and Nozzle Surveillance Frequency2022-03-18018 March 2022
License Amendment Request to Revise Technical Specification 3.6.1.8 Residual Heat Removal (RHR) Drywell Spray Header and Nozzle Surveillance Frequency
L-MT-22-012, Special Report for the Bypass of the Offgas Treatment Storage System2022-03-15015 March 2022
Special Report for the Bypass of the Offgas Treatment Storage System
L-MT-22-008, 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval Alternative Related to Excess Flow Check Valve Testing Frequency (L-MT-22-008)2022-03-0707 March 2022
10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval Alternative Related to Excess Flow Check Valve Testing Frequency (L-MT-22-008)
L-MT-22-006, 10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval OMN-26 (L-MT-22-006)2022-02-18018 February 2022
10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval OMN-26 (L-MT-22-006)
2024-01-11
[Table view] |
Text
N Committed to Nuclear Monticello Nuclear Generatina Plant Operated by Nuclear Management Company, LLC May 25,2007 L-MT-07-034 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 License No. DPR-22 Response to Request for Additional Information to Revise TS Surveillance Requirement 3.5.1.3 to Correct the Alternate Nitroqen System Pressure (TAC No. MD4095)
Reference:
NMC letter to NRC, "License Amendment Request to Revise Technical Specification Surveillance Requirement 3.5.1.3 to Correct the Alternate Nitrogen System Pressure," (L-MT-07-014), dated January 30, 2007.
On January 30,2007, the Nuclear Management Company, LLC (NMC) submitted a request to revise the Alternate Nitrogen System pressure in Surveillance Requirement 3.5.1.3.b of the Monticello Nuclear Generating Plant Technical Specifications. On April 17, 2007, the U.S. Nuclear Regulatory Commission requested additional information during a teleconference on the basis for the proposed change. Enclosure 1 provides the requested information.
This letter makes no new commitments or changes to any existing commitments, In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Minnesota official.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on M a y d 2 , 2 0 0 7 .
Site Vice President, Monticello Nuclear Generating Plant Nuclear Management Company, LLC Enclosure cc: Administrator, Region Ill, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce 2807 West County Road 75 e Monticello, Minnesota 55362-9637 Telephone: 763.295.5151 e Fax: 763.295.1454
ENCLOSURE *I Introduction On April 17, 2007, the U.S. Nuclear Regulatory Commission (NRC) requested the Nuclear Management Company, LLC (NMC) to provide a summary description of the Alternate Nitrogen System design and the system's integration with the Automatic Depressurization System (ADS). This request for information was based on a proposed license amendment request (LAR) (Reference I ) to correct the value specified for the Alternate Nitrogen System supply pressure to the ADS in Surveillance Requirement (SR) 3.5.1.3.b from > 220 psig to 1 4 1 0 psig.
Alternate Nitrogen System Description The Alternate Nitrogen System was designed as a long-term, safety-related backup to the normal non-safety related pneumatic supplies (the lnstrument Air and lnstrument Nitrogen Systems). The Alternate Nitrogen System consists of two separate safety-related subsystems supplied from separate nitrogen bottle racks in the Turbine Building. Manifold pressure is maintained greater than or equal to 41 0 psig to maintain Alternate Nitrogen System operability. The Alternate Nitrogen System supplies the following major components:
- 1. Primary Containment and Atmospheric Control System Purge and Vent Valve T-ring seals
- 2. Reactor Building to Torus Vacuum Breaker T-ring seals and actuators
- 3. Inboard Main Steam Isolation Valve actuators
- 4. Hard Pipe Vent System Isolation Valves and rupture disc
- 5. Various functions of the Safety Relief Valves (SRVs), summarized below.
The Alternate Nitrogen System was installed to assure SRV actuation for the ADS, Low-Low Set (LLS), alternate shutdown, and manual depressurization functions during all applicable design basis events. Alternate Nitrogen System supply was assigned to six of the eight SRVs (between the two subsystems) to provide a safety-related backup to support the functions listed below (two SRVs are served by accumulators).
Three SRVs (RV-2-71A, C and D) are assigned to the ADS.
0 Three SRVs (RV-2-71E, G and H) are assigned to the LLS.
0 FourSRVs(RV-2-71B,E,FandH)satisfytheNUREG-0737,ltemll.K.3.28 commitment to provide a 100-day air supply to ensure long term ECCS capability.
Alternate Nitrogen System and the ADS Interrelationship SR 3.5.1.3.b was added during the Improved Standard Technical Specification (ITS) conversion to describe the Alternate Nitrogen System pneumatic supply pressure requirement to the portion of the ADS served by the system. Since the proposed LAR pertains only to correcting an incorrect value in the Technical Specifications (TS) for the Page 1 of 3
ENCLOSURE I Alternate Nitrogen System pneumatic supply pressure to the ADS, the following technical discussion refers only to the relationship between the ADS and the Alternate Nitrogen System.
As indicated previously, three of the eight SRVs are assigned to the ADS function. The ADS is an automatic actuation logic system which provides a backup to the High Pressure Coolant Injection (HPCI) System during a loss of coolant accident (LOCA) by depressurizing the reactor vessel to permit low pressure Emergency Core Cooling System (ECCS) injection. Two of the three ADS valves are normally supplied by the non-safety related lnstrument Nitrogen System. Each ADS valve has a different safety-related backup nitrogen supply, described below.
RV-2-71A (Alternate Nitrogen Subsystem A)
RV-2-71C (Alternate Nitrogen Subsystem B)
ITS Conversion Discussion The ITS NUREG for the BWRl4 plant design (NUREG-1433) (Reference 2) includes a surveillance requirement, SR 3.5.1.3, to verify every 31 days that the supply pressure to the ADS is greater then or equal to a specified value. This SR was not included in the previous Monticello Nuclear Generating Plant (MNGP) custom TS.
Each ADS valve has a different safety-related pneumatic backup source at the MNGP (i.e., Alternate Nitrogen Subsystem A, Alternate Nitrogen Subsystem B, or the accumulator bank in the Drywell). Therefore, it was necessary to modify SR 3.5.1.3 as part of the ITS conversion to reflect the different safety-related, back-up, pneumatic supplies. However, during the ITS conversion the wrong value for the Alternate Nitrogen System pressure (220 psig) was chosen from a calculation and specified in SR 3.5.1.3.b as the required pressure. SR 3.5.1.3 currently reads:
Verify ADS pneumatic pressure is as follows for each required ADS pneumatic supply:
- a. SRV Accumulator Bank header pressure > 88.3 psig; and
- b. Alternate Nitrogen System pressure is > 220 psig.
It was later identified that the wrong value (220 psig) had been specified as the required Alternate Nitrogen System pressure. The Alternate Nitrogen System pressure should actually have been stated as 2 41 0 psig in the surveillance requirement.
- 1. The safety-related pneumatic supply to ADS SRV RV-2-71D is provided by a bank of four accumulators located in the Drywell (charged by the lnstrument Nitrogen or lnstrument Air Systems).
Page 2 of 3
ENCLOSURE I On January 30,2007, the NMC submitted a LAR for the MNGP (Reference I ) to revise the Alternate Nitrogen System pressure in SR 3.5.1.3.b to the correct value of 1 4 1 0 psig. The NMC has determined that the current MNGP TS value of 220 psig for the Alternate Nitrogen System pressure is non-conservative and that the guidance of NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," applies. In the interim until this TS change is approved, the NMC has implemented administrative controls to maintain the Alternate Nitrogen System supply pressure at 1 4 1 0 psig.
REFERENCES
- 1. NMC letter to NRC, "License Amendment Request to Revise Technical Specification Surveillance Requirement 3.5.1.3 to Correct the Alternate Nitrogen System Pressure," (L-MT-07-014), dated January 30, 2007.
- 2. NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWRI4," Revision 3.1, dated December 1, 2005.
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