L-MT-07-046, License Amendment Request: Application for Technical Specification Change TSTF-477, Add Action for Two Inoperable Control Room Air Conditioning Subsystems to the Technical Specifications Using the Consolidated Line Item Improvement Proce

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License Amendment Request: Application for Technical Specification Change TSTF-477, Add Action for Two Inoperable Control Room Air Conditioning Subsystems to the Technical Specifications Using the Consolidated Line Item Improvement Process
ML072610596
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 09/17/2007
From: O'Connor T
Nuclear Management Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-07-046
Download: ML072610596 (16)
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Text

Monticello Nuclear Generatina Plant Committed to Nuclear Excellence Operated by Nuclear Management Company, LLC September 17,2007 L-MT-07-046 10 CFR 50.90 TSTF-477 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 Renewed Operating License No. DPR-22 License Amendment Request: Application for Technical Specification Change TSTF-477, Add Action for Two Inoperable Control Room Air Conditioning Subsystems to the Technical Specifications Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90 the Nuclear Management Company, LLC (NMC) is requesting an amendment to the Technical Specifications (TS) for the Monticello Nuclear Generating Plant (MNGP). The proposed amendment would revise the TS by adding an action statement for two inoperable Control Room air conditioning subsystems.

Enclosure 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing TS pages marked-up to show the proposed change. Enclosure 3 provides the retyped TS pages showing the proposed changes. Enclosure 4 provides draft TS Bases pages (for information) showing the associated bases changes in accordance with 10 CFR 50.36(a).

NMC requests approval of the proposed license amendment in accordance with the normal timeframe for processing Technical Specification Task Force (TSTF) Improved Standard TS travelers, with an implementation period of 90 days following issuance.

Summaw of Commitments This letter makes no new commitment or any changes to existing commitments.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Minnesota Official.

2807 West County Road 75 Monticello, Minnesota 55362-9637 Telephone: 763.295.5151 a Fax: 763.295.1454

Document Control Desk Page 2 I declare undgr penalty of p,erjury that the foregoing is true and correct.

lear Generating Plant Enclosures (4) cc: Administrator, Region Ill, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce

ENCLOSURE I DESCRIPTION OF CHANGE AND ASSESSMENT ADD ACTION FOR TWO INOPERABLE CONTROL ROOM AIR CONDITIONING SUBSYSTEMS TO THE TECHNICAL SPECIFICATIONS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

1.0 DESCRIPTION

The proposed amendment would modify the Monticello Nuclear Generating Plant (MNGP) Technical Specifications (TS) by adding an Action Statement to the Limiting Condition for Operation (LCO) for Specification 3.7.5, "Control Room Ventilation System." Proposed Action B will allow a finite time (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) to restore one Control Room ventilation subsystem to operable status, when both ventilation subsystems are inoperable, provided the Control Room temperature is verified to be less than 90°F once every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

The proposed changes are consistent with the Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF) Improved Standard Technical Specifications Change Traveler, TSTF-477, Revision 3 (Reference 1). A notice of availability of this TS improvement was published in the Federal Register on March 26, 2007 (Reference 2), as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of TSTF-477 and Published Safety Evaluation The Nuclear Management Company, LLC (NMC) has reviewed TSTF-477, Revision 3, and the NRC model safety evaluation previously published in the Federal Register on December 18, 2006 (Reference 3). NMC has concluded that the information in TSTF-477, as well as the safety evaluation prepared by the NRC staff are applicable to the MNGP and justify this amendment for the incorporation of the changes to the MNGP TS.

2.2 Optional Changes and Variations The NMC is not proposing any variations or deviations from the TS changes or TS Bases changes described in TSTF-477, Revision 3, or the NRC model safety evaluation dated December 18, 2006, with the exception of the control room air conditioning system / subsystem names.

TSTF-477, Revision 3, refers to the 'control room air conditioning (AC) system1and the

'control room AC subsystems'. The corresponding nomenclature at the MNGP are the

'control room ventilation system1and the 'control room ventilation subsystems1and this naming convention has been followed herein.

Page 1 of 3

ENCLOSURE I

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination The NMC has reviewed the proposed No Significant Hazards Consideration (NSHC) determination published in the Federal Register on December 18, 2006, as part of the CLIIP. The NMC has concluded that the proposed NSHC determination presented in this Federal Register notice is applicable to the MNGP and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on March 26, 2007, for this TS improvement, plant-specific verifications were performed as follows. TSTF-477, Revision 3, is applicable to all licensees of General Electric Boiling Water Reactors who have adopted or will adopt in conjunction with the change, the TS requirements for a TS bases control program consistent with the TS Bases Control Program described in Section 5.5 of the Standard Technical Specifications (STS). The MNGP is a BWRl3 with TS that do not currently provide an action other than entering LC0 3.0.3 for two inoperable Control Room ventilation subsystems. The NMC has reviewed TSTF-477, Revision 3, and the NRC model SE published in the Federal Register on December 18, 2006 and determined that the information and conclusions therein are applicable to the MNGP and justify incorporation of these proposed changes to the MNGP TS. The NMC has proposed TS Bases changes consistent with TSTF-477, Revision 3, which provide guidance and details on how to implement the new requirements. Finally, a bases control program is included in MNGP Specification 5.5.9, "Technical Specifications (TS) Bases Control Program," that is consistent with Section 5.5 of the STS.

4.0 ENVIRONMENTAL EVALUATION The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment adopting TSTF-477, Revision 3, involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that TSTF-477, Revision 3, involves no significant hazards considerations, and there has been no public comment on the finding in Federal Register Notice 71 FR 75774. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(~)(9).Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

Page 2 of 3

ENCLOSURE I

5.0 REFERENCES

1. Technical Specification Task Force, Improved Standard Technical Specifications Change Traveler, TSTF-477, Revision 3, "Add Action for Two lnoperable Control Room AC Subsystems."
2. Federal Register Notice, Nuclear Regulatory Commission, "Notice of Availability Concerning Technical Specification lmprovement to Add an Action Statement for Two lnoperable Control Room Air Conditioning Subsystems to the Technical Specifications Using the Consolidated Line Item lmprovement Process,"

published on March 26, 2007 (72 FR 14143).

3. Federal Register Notice, Nuclear Regulatory Commission, "Notice of Opportunity to Comment on Model Safety Evaluation and Model License Amendment Request on Technical Specification lmprovement Regarding Adding an Action Statement for Two lnoperable Control Room Air Conditioning Subsystems,"

published on December 18,2006 (71 FR 75774).

Page 3 of 3

ENCLOSURE 2 MONTICELLO NUCLEAR GENERATING PLANT ADD AN ACTION FOR TWO INOPERABLE CONTROL ROOM AIR CONDITIONING SUBSYSTEMS TO THE TECHNICAL SPECIFICATIONS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

(2 pages follow)

Control Room Ventilation System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Control Room Ventilation System L C 0 3.7.5 Two control room ventilation subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION I REQUIRED ACTION 1 COMPLETION TIME A. One control room A. 1 Restore control room 30 days ventilation subsystem ventilation subsystem to inoperable. OPERABLE status.

B. Two control room B. 1 Verify control room area Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ventilation subsystems temperature < 90°F.

inoperable.

B.2 Restore one control room 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ventilation subsystem to OPERABLE status.

BC. equired Action and Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a s s o c i a t e d Completion Time of Condition A not met in MODE 1, or 3. @ Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

@equired Action and .................... NOTE-------------------

associated Completion LC0 3.0.3 is not applicable.

Time of Condition A not ................................................

met during movement of recently irradiated fuel 6D.1 Place OPERABLE control room ventilation subsystem Immediately I assemblies in the secondary containment in operation.

or during OPDRVs.

OR Monticello Amendment No. +%+I48 I-

Control Room Ventilation System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME Suspend movement of lmmediately recently irradiated fuel assemblies in the secondary containment.

1 AND nitiate action to suspend Immediately OPDRVs.

.................... NOTE-------------------

L C 0 3.0.3 is not applicable.

Action and associated Com~letionTime of E.l Suspend movement of lmmediately recently irradiated fuel assemblies in the recently irradiated fuel secondary containment.

assemblies in the secondary containment or during OPDRVs.

E.2 Initiate actions to suspend lmmediately OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 Verify each control room ventilation subsystem has 24 months the capability to remove the assumed heat load.

Monticello Amendment No. 4-45, 148, -

ENCLOSURE 3 MONTICELLO NUCLEAR GENERATING PLANT ADD AN ACTION FOR TWO INOPERABLE CONTROL ROOM AIR CONDITIONING SUBSYSTEMS TO THE TECHNICAL SPECIFICATIONS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS PROPOSED RETYPED TECHNICAL SPECIFICATION CHANGES (2 pages follow)

Control Room Ventilation System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Control Room Ventilation System L C 0 3.7.5 Two control room ventilation subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control room A. 1 Restore control room 30 days ventilation subsystem ventilation subsystem to inoperable. OPERABLE status.

B. Two control room B.1 Verify control room area Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ventilation subsystems temperature < 90°F.

inoperable.

8.2 Restore one control room 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ventilation subsystem to OPERABLE status.

C. Required Action and C.l Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A or B A M not met in MODE 1, 2, or 3. C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Required Action and .................... NOTE-------------------

associated Completion L C 0 3.0.3 is not applicable.

Time of Condition A not met during movement of recently irradiated fuel D.l Place OPERABLE control Immediately assemblies in the room ventilation subsystem secondary containment in operation.

or during OPDRVs.

Monticello 3.7.5-1 Amendment No. 146, ?48,-

Control Room Ventilation System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.2.1 Suspend movement of lmmediately recently irradiated fuel assemblies in the secondary containment.

D.2.2 Initiate action to suspend lmmediately OPDRVs.

E. Required Action and .................... NOTE-------------------

associated Completion LC0 3.0.3 is not applicable.

Time of Condition B not ................................................

met during movement of recently irradiated fuel E.l Suspend movement of lmmediately assemblies in the recently irradiated fuel secondary containment assemblies in the or during OPDRVs. secondary containment.

E.2 lnitiate actions to suspend 1 lmmediately 1 OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE I FREQUENCY SR 3.7.5.1 Verify each control room ventilation subsystem has 24 months the capability to remove the assumed heat load.

Monticello Amendment No. 443+48 I -

ENCLOSURE 4 MONTICELLO NUCLEAR GENERATING PLANT ADD AN ACTION FOR TWO INOPERABLE CONTROL ROOM AIR CONDITIONING SUBSYSTEMS TO THE TECHNICAL SPECIFICATIONS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS RETYPED DRAFT TECHNICAL SPECIFICATION BASES PAGES (4 pages follow)

Control Room Ventilation System B.3.7.5 B 3.7 PLANT SYSTEMS B 3.7.5 Control Room Ventilation System BASES BACKGROUND The Control Room Ventilation System provides temperature control for the control room boundary following isolation of the control room. The control room boundary includes the main control room and portions of the first and second floors of the Emergency Filtration Train (EFT) building.

The Control Room Ventilation System consists of two independent, redundant subsystems that provide cooling and heating of recirculated control room boundary and outside air. Each subsystem consists of heating coils (not required for OPERABILITY), cooling coils, fans, compressors, ductwork, dampers, and instrumentation and controls to provide for control room boundary temperature control.

The Control Room Ventilation System is designed to provide a controlled environment under both normal and accident conditions. A single subsystem provides the required temperature control to maintain a suitable control room boundary environment for a sustained occupancy of 10 persons. The system is designed to maintain the control room boundary at 78°F during the summer and 72°F in the winter. The maximum design condition in the control room and most of the EFT is 104°F. The Control Room Ventilation System operation in maintaining the control room boundary temperature is discussed in USAR, Section 6.7 (Ref. 1).

APPLICABLE The design basis of the Control Room Ventilation System is to maintain SAFETY the control room boundary temperature for a 30 day continuous occupancy.

ANALYSES The Control Room Ventilation System components are arranged in redundant safety related subsystems. During emergency operation, the Control Room Ventilation System maintains a habitable environment and ensures the OPERABILITY of components in the control room boundary.

A single failure of a component of the Control Room Ventilation System, assuming a loss of offsite power, does not impair the ability of the system to perform its design function. Redundant detectors and controls are provided for control room boundary temperature control. The Control Room Ventilation System is designed in accordance with Seismic Category I requirements. The Control Room Ventilation System is capable of removing sensible and latent heat loads from the control room boundary, including consideration of equipment heat loads and personnel occupancy requirements to ensure equipment OPERABILITY.

The Control Room Ventilation System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Monticello Revision No. -

Control Room Ventilation System B.3.7.5 BASES Two independent and redundant subsystems of the Control Room Ventilation System are required to be OPERABLE to ensure that at least one is available, assuming a single failure disables the other subsystem.

Total system failure could result in the equipment operating temperature exceeding limits.

The Control Room Ventilation System is considered OPERABLE when the individual components necessary to maintain the control room boundary temperature are OPERABLE in both subsystems. These components include the cooling coils, fans, compressors, ductwork, dampers, and associated instrumentation and controls.

APPLICABILITY In MODE I,2, or 3, the Control Room Ventilation System must be OPERABLE to ensure that the control room boundary temperature will not exceed equipment OPERABILITY limits following control room isolation.

In MODES 4 and 5, the probability and consequences of a Design Basis Accident are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the Control Room Ventilation System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:

a. During operations with a potential for draining the reactor vessel (OPDRVs); and
b. During movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, the Control Room Ventilation System is only required to be OPERABLE during fuel handling involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

ACTIONS With one control room ventilation subsystem inoperable, the inoperable control room ventilation subsystem must be restored to OPERABLE status within 30 days. With the unit in this condition, the remaining OPERABLE control room ventilation subsystem is adequate to perform the control room boundary air conditioning function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in loss of the control room boundary air conditioning function. The 30 day Completion Time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining subsystem can provide the required protection, and the availability of alternate safety and nonsafety cooling methods.

Monticello Revision No. -

Control Room Ventilation System B.3.7.5 BASES If both control room ventilation subsystems are inoperable, the Control Room Ventilation System may not be capable of performing its intended function. Therefore, the control room area temperature is required to be monitored to ensure that temperature is being maintained low enough that equipment in the control room is not adversely affected. With the control room temperature being maintained within the temperature limit, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to restore a control room ventilation subsystem to OPERABLE status. This Completion time is reasonable considering that the control room temperature is being maintained within limits and the low probability of an event occurring requiring control room isolation.

In MODE 1 2, or 3, if the inoperable control room ventilation 9

subsyste s) cannot be restored to OPERABLE status within the associated ompletion Time, the unit must be placed in a MODE that minimizes risk. To achieve this status, the unit must be placed in at least I

MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

The Required Actions of ~ondition@are modified by a Note indicating that L C 0 3.0.3 does not apply. If moving recently irradiated fuel assemblies, although not feasible, while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if Required Action A. 1 cannot be completed within the required Completion Time, the OPERABLE control room ventilation subsystem may be placed immediately in operation.

This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent actuation will occur, and that any active failure will be readily detected.

An alternative to Required ~ c t i o n a i to s immediately suspend activities I that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk.

Monticello B 3.7.5-3 Revision No. -

Control Room Ventilation System 8.3.7.5 BASES ACTIONS (continued)

If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

E . l and E.2 The Required Actions of Condition E are modified by a Note indicating that L C 0 3.0.3 does not apply. If moving recently irradiated fuel assemblies, although not feasible, while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not a sufficient reason to require a reactor shutdown.

otential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk.

If applicable, handling of recently irradiated fuel in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

SURVEILLANCE SR 3.7.5.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control room boundary heat load assumed in the safety analyses. The SR consists of a combination of testing and calculation.

The 24 month Frequency is appropriate since significant degradation of the Control Room Ventilation System is not expected over this time period.

REFERENCES 1. USAR, Section 6.7 Monticello B 3.7.5-4 Revision No. -

~~ ~~~ ~-~

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