L-MT-12-077, License Amendment Request: Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities

License Amendment Request: Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities

ML12346A010
Person / Time
Site:	Monticello
Issue date:	12/06/2012
From:	Schimmel M Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-12-077, TSTF-484, Rev. 0
Download: ML12346A010 (21)

Text

U XcelEnergy Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 December 6, 2012 L-MT-12-077 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 Renewed Facility Operating License No. DPR-22 License Amendment Request: Adoption of Technical Specifications Task Force (TSTF)

Traveler TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities" Pursuant to 10 CFR 50.90, Northern States Power Company - Minnesota (NSPM),

doing business as Xcel Energy, Inc., proposes to revise Monticello Nuclear Generating Plant (MNGP) Technical Specifications (TS) 3.10.1, "Inservice Leak and Hydrostatic Testing Operation". The proposed changes would revise Limiting Condition for Operation (LCO) 3.10.1 and the associated TS Bases to expand its scope to include provisions for temperature excursions greater than 212°F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4.

This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of this TS improvement was announced in the FederalRegister published on October 27, 2006

[71 FR 63050] as part of the Consolidated Line Item Improvement Process (CLIIP). provides a description of the proposed changes and includes the technical evaluation and associated no significant hazards determination and environmental evaluation. Enclosure 2 provides a marked-up copy of the existing TS pages showing the proposed changes. Enclosure 3 provides a marked-up copy of the TS Bases pages showing the proposed changes. The proposed Bases changes are provided for information only.

A,-

Document Control Desk L-MT-12-077 Page 2 of 2 NSPM requests approval of this proposed license amendment request by December 15, 2013 with the amendment being implemented within 120 days of NRC approval.

In accordance with 10 CFR 50.91(a)(1), the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission.

The MNGP Plant Operations Review Committee has reviewed this application. In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Minnesota Official.

This license amendment request has been evaluated and has no impact on the pending Extended Power Uprate and Maximum Extended Load Line Limit Analysis Plus (MELLLA+) license amendment requests currently under NRC review.

Should you have questions regarding this letter, please contact Mr. Richard Loeffler at (763) 295-1247.

Summary of Commitments This letter proposes no new commitments and does not revise any existing commitments.

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

Executed on December 2012.

Mark A. Schimmel Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (3) cc: Administrator, Region Ill, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce

ENCLOSURE 1 MONTICELLO NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)

TRAVELER TSTF-484, REVISION 0, "USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES" DESCRIPTION OF CHANGES (6 pages follow)

TABLE OF CONTENTS SECTION TITLE PAGE

1.0 DESCRIPTION

1

2.0 PROPOSED CHANGE

S 1

3.0 BACKGROUND

2

4.0 TECHNICAL ANALYSIS

2

5.0 REGULATORY ANALYSIS

2 5.1 No Significant Hazards Determination 2 5.2 Applicable Regulatory Requirements 3 6.0 ENVIRONMENTAL EVALUATION 5

7.0 REFERENCES

5

L-MT-12-077 Page 1 of 5 DESCRIPTION OF CHANGES ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)

TRAVELER TSTF-484, REVISION 0, "USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES"

1.0 DESCRIPTION

Pursuant to 10 CFR 50.90, Northern States Power Company - Minnesota (NSPM),

doing business as Xcel Energy, Inc., proposes to revise Monticello Nuclear Generating Plant (MNGP) Technical Specification (TS) Limiting Condition for Operation (LCO) 3.10.1, "Inservice Leak and Hydrostatic Testing Operation," and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 212'F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in MODE 4.

This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities" (Reference 1). The availability of the model safety evaluation for this TS improvement was announced in the FederalRegister on October 27, 2006, (71 FR 63050) as part of the Consolidated Line Item Improvement Process (CLIIP) (Reference 2).

2.0 PROPOSED CHANGE

S Consistent with the NRC approved Revision 0 of TSTF-484, the proposed TS changes include a revised TS 3.10.1, "Inservice Leak and Hydrostatic Testing Operation."

Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF-484, Revision 0 is an integral part of implementing this TS amendment. Adoption of the TS Bases changes associated with TSTF-484, Revision 0, will be incorporated in accordance with MNGP Specification 5.5.9, "Technical Specification (TS) Bases Control Program" following approval of a license amendment. A mark-up of the proposed TS changes is provided in Enclosure 2. provides a marked-up copy of the TS Bases pages showing the proposed changes.

This application is being made in accordance with the CLIIP. NSPM is not proposing variations or deviations from the TS changes described in TSTF-484, Revision 0, or the NRC staff's model safety evaluation (SE) published in the FederalRegister on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

L-MT-12-077 Page 2 of 5 It is noted that the current MNGP TS LCO 3.10.1 varies slightly from the NUREG-1433, Revision 4, Standard Technical Specification, General Electric BWR/4 Plants. MNGP TS 3.10.1 limits the specific activity of the reactor coolant during inservice leak and hydrostatic testing. MNGP has maintained the reactor coolant specific activity limit consistent with current TS LCO 3.10.1.(1) This variation does not constitute a technical difference from the conclusions of the NRC staffs model Safety Evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability that would preclude MNGP from adopting the provisions of TSTF-484, Rev. 0.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability of Model Safety Evaluation on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1 published on October 27, 2006, (71 FR 63050) (Reference 2).

4.0 TECHNICAL ANALYSIS

NSPM has reviewed the model SE published in the FederalRegister on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability of the Model Safety Evaluation. NSPM has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to MNGP and therefore justify this amendment for the incorporation of the proposed changes to the MNGP TS.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Determination In accordance with the requirements of 10 CFR 50.90, Northern States Power Company - Minnesota (NSPM), doing business as Xcel Energy, Inc., requests an amendment to facility Renewed Operating License DPR-22, for the Monticello Nuclear Generating Plant (MNGP). The proposed changes revise Technical Specification (TS) Limiting Condition for Operation (LCO) 3.10.1, "Inservice Leak and Hydrostatic Testing Operation," and the associated Bases.

NSPM has reviewed the no significant hazards determination published on August 21, 2006 (71 FR 48561) (Reference 3) as part of the CLIIP Notice for Comment. NSPM has concluded that the determination presented in the notice is applicable to MNGP and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

1. MNGP Amendment 107, a precursor to TSTF-484, included a reactor coolant specific activity limit. See the Reference section in TSTF-484.

L-MT-12-077 Page 3 of 5 5.2 Applicable Regulatory Requirements A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on October 27, 2006 (71 FR 63050). NSPM has reviewed the NRC staffs model SE referenced in the CLIIP Notice of Availability and concluded that the regulatory requirements section is applicable to MNGP.

• 10 CFR 50.36, Technical Specifications 10 CFR 50.36 "Technical Specifications," provides the regulatory requirements for the content required in the TS. As stated in 10 CFR 50.36, the TS include Limiting Conditions for Operation (LCO) and Surveillance Requirements (SR) to assure that the LCOs are met. The proposed changes to the TS LCOs and SRs for inservice leakage and hydrostatic testing, and scram time testing will continue to meet the requirements of 10 CFR 50.36.

The TSTF-484, Rev. 0 Traveler and model Safety Evaluation discuss the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (GDC). MNGP was designed largely before the publishing of the 70 General Design Criteria (GDC) for Nuclear Power Plant Construction Permits proposed by the Atomic Energy Commission (AEC) for public comment in July 1967, and constructed prior to the 1971 publication of the 10 CFR 50, Appendix A, GDC. As such, MNGP was not licensed to the Appendix A, GDC.

The MNGP USAR, Section 1.2, lists the Principal Design Criteria (PDC) for the design, construction and operation of the plant. MNGP USAR Appendix E provides a plant comparative evaluation to the 70 proposed AEC design criteria.

It was concluded that the plant conforms to the intent of the GDC. The applicable GDC and PDC are discussed below.

• PDC 1.2.2- Reactor Core

e. The reactor core is designed so that control rod action, with the maximum worth control rod fully withdrawn and unavailable for use, is capable of bringing the reactor core subcritical and maintaining it so from any power level in the operating cycle.

L-MT-12-077 Page 4 of 5

f. Redundant backup reactivity shutdown capability is provided independent of normal reactivity provisions. This system has the capability, with adequate margin, to shut down the reactor from any power level in the operating cycle.

The applicable 70 Draft AEC General Design Criteria (AEC-GDC) are:

" Criterion 6 - Reactor Core Design (Category A)

The reactor core shall be designed to function throughout its design lifetime, without exceeding acceptable fuel damage limits which have been stipulated and justified. The core design, together with reliable process and decay heat removal systems, shall provide for this capability under all expected conditions of normal operation with appropriate margins for uncertainties and for transient situations which can be anticipated, including the effects of the loss of power to recirculation pumps, tripping out of a turbine generator set, isolation of the reactor from its primary heat sink, and loss of off-site power.

" Criterion 27 - Redundancy of Reactivity Control (Cateqory A)

At least two independent reactivity control systems, preferable of different principles, shall be provided.

" Criterion 28 - Reactivity Hot Shutdown Capability (Cate-qory A)

At least two of the reactivity control systems provided shall independently be capable of making and holding the core subcritical from any hot standby or hot operating condition, including those resulting from power changes, sufficiently fast to prevent exceeding acceptable fuel damage limits.

As discussed in the model Safety Evaluation for TSTF-484, Rev. 0 (71 FR 63050), 10 CFR 50, Appendix A, Criterion 10 states that the reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences. The scram reactivity used in design basis accidents (DBA) and transient analyses is based on an assumed control rod scram time. This modification to LCO 3.10.1 does not alter the means of compliance with Criterion 10 of Appendix A to 10 CFR 50.

NSPM has evaluated the proposed changes against the applicable regulatory requirements and acceptance criteria. The proposed TS changes will continue to assure that the design requirements and acceptance criteria for MNGP are met.

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

L-MT-12-077 Page 5 of 5 proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL EVALUATION NSPM has reviewed the environmental evaluation included in the safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

NSPM has concluded that the staff's findings presented in that evaluation are applicable to MNGP and the evaluation is hereby incorporated by reference for this application.

7.0 REFERENCES

1. NRC approved Revision 0 to Technical Specification Task Force (TSTF)

Improved Standard Technical Specification Change Traveler, TSTF- 484, "Use of TS 3.10.1 for Scram Time Testing Activities".

2. Federal Register Notice published on October 27, 2006 [71 FR 63050], NRC Notice of Availability of Model Safety Evaluation on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1, Inservice Leak and Hydrostatic Testing Operation Using the Consolidated Line Item Improvement Process.

3. Federal Register Notice published on August 21, 2006 [71 FR 48561], Notice of Opportunity To Comment on Model Safety Evaluation on Technical Specification Improvement To Modify Requirements Regarding LCO 3.10.1, Inservice Leak and Hydrostatic Testing Operation Using the Consolidated Line Item Improvement Process.

ENCLOSURE2 MONTICELLO NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)

TRAVELER TSTF-484, REVISION 0, "USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES" MARKED-UP TECHNICAL SPECIFICATION PAGES (3 pages follow)

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The aiverage reactor coolant temperature specified in Table 1.1-1 for MODIE 4 may be changed to "NA," and operation considered not to be in MODIE 3; and the requirements of LCO 3.4.8, "Residual Heat Removal (RHR ) Shutdown Cooling System - Cold Shutdown," may be suspended, to allc VALE&NT 1131 and- the follwn OD3LGsaemt

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation,"

Functions 1, 3, and 4 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)";

and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 212 0 F.

reactor coolant temperature > 212'F provided the specific activity of the reactor coolant is *0.02 ltCi/gm DOSE EQUIVALENT 1-131:

" For performance of an inservice leak or hydrostatic test,

• As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or

• As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:

Monticello 3.10.1-1 Amendment No. 146

Inservice Leak and Hydrostatic Testing Operation 3.10.1 ACTIONS K Irv*iTr-

---

I f.-I----------------------------------------

Separate Condition entry is allowed for each requirement of the LCO.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more of the LCO A.1 --- ---------------- N E-------TE -----

requirements not met. Required Actions to be in MODE 4 include reducing average reactor coolant temperature to < 212 0 F.

Enter the applicable Immediately No Changes Condition of the affected for LCO.

Information OR A.2.1 Suspend activities that Immediately could increase the average reactor coolant temperature or pressure.

AND A.2.2 Reduce average reactor 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coolant temperature to

< 212 0 F.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.1.1 Perform the applicable SRs for the required According to the MODE 3 LCOs. applicable SRs Monticello 3.10.1-2 Amendment No. 146

Inservice Leak and Hydrostatic Testing Operation 3.10.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.1.2 Verify reactor coolant DOSE EQUIVALENT 1-131 Once within specific activity is _<0.02 ý0Ci/gm. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to increasing average reactor coolant temperature

> 212OF No Changes for Information Monticello 3.10.1-3 Amendment No. 146

ENCLOSURE 3 MONTICELLO NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)

TRAVELER TSTF-484, REVISION 0, "USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES" MARKED-UP TECHNICAL SPECIFICATION BASES PAGES (7 pages follow)

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 212°F (normally corresponding to MODE 3).4 Inservice hydrostatic testing and system leakage pressure tests required by Section Xl of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Recirculation pump operation and a water solid RPV are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LCO 3.4.9, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits." These limits are conservatively based on the fracture toughness of the reactor vessel, takin into account anticipated vessel neutron fluence. may INSERT2 With increased reactor vessel fluence ov r ine, the minimum allowab e vessel temperature increases at a give pressure. Periodic updates to the RPV P/T limit curves are performe as necessary, based upon the t results of analyses of irradiated surve' ance specimens removed from the vessel. Hydrostatic and leak testing , ventualll be required with7 minimum reactor coolant temperatures > 212 0 F.

Tho hudroctatic tPct rcaurc ' nre no nressurce to not less than nominal Replace with ,#

INSERT 3. operatingprcure assoclated with nremal system operation

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^ ^ I IIIr%4 S 't5 J*U*I fluence, the minimum allowable verose! temnporaturo according to LCO 3.4.0 ma icraet>2420F.

APPLICABLE Allowing the reactor to be considered in MODE 4 during hydro-,tatiG O*

SAFETY leak-testing, when the reactor coolant temperature is > 212°F, efectively--

ANALYSES provides an exception to MODE 3 requirements, including OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems. Since the hydro.tatic or leak tests are performed nearly water solid, at low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent increase in coolant activity above the LCO 3.4.6, "RCS Specific Activity," limits are Monticello B 3.10.1-1 Revision No. 0

Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities" Insert 1 (Bases 3.10.1, Background) or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 212'F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 212°F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown,"

during MODE 4 operation.

Insert 2 (Bases 3.10.1. Background)

However, even with required minimum reactor coolant temperatures < 212 0 F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

Insert 3 (Bases 3.10.1, Background)

The hydrostatic and/or RCS system leakage tests requires increasing pressure to approximately 1000 psig. Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor steam dome pressure > 800 psig.

Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.

Insert 4 (Bases 3.10.1, Applicable Safety Analyses) during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test,

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE SAFETY ANALYSES (continued) minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. Furthermore, the specific activity of the reactor coolant is assumed to be < 0.02 jiCi/gm DOSE EQUIVALENT 1-131. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.

In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2, "ECCS -

Shutdown," would be more than adequate to keep the core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred.

For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the reactor coolant specific activity limit and secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.

As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) apply.

Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.

LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation at reactor coolant temperatures > 212*F can be in accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures > 212°F, performance of inservice leak and hydrostatic testing would also necessitate the inoperability of some subsystems normally required to be OPERABLE when > 212°F.

INSERT 5 Monticello B 3.10.1-2 Revision No. 0

Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities" Insert 5 (Bases 3.10.1, LCO)

Additionally, even with required minimum reactor coolant temperatures < 212 0 F, RCS temperatures may drift above 212TF during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing. While this Special Operations LCO is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LCO (continued)

If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs, the reactor coolant specific activity limit, and the specified MODE 3 LCOs must be met. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown." The additional requirements for the reactor coolant specific activity limit and the secondary containment LCOs to be met will provide sufficient protection for operations at reactor coolant temperatures

> 212°F for the purpose of performing eithe an inservice leak or INSERT 6 hydrostatic test. v This LCO allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable I IE;U ran, Eak mnc U I I I*;I l I1*;I

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thi ,p~tilNSERT 7 The MODE 4 requirements may o*nly be modified for the performance of APPLICABILITY inservice leak or hydrostatic test'o that these operations can be considered as in MODE 4, even though the reactor coolant temperature is

> 212°F. The additional requirements for the reactor coolant specific activity limit as well as the secondary containment LCOs to be met according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur. Operations in all other MODES are unaffected by this LCO.

ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LCO not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.

Revision No. 0 B 3.10.1-3 Monticello Monticello B 3.10.1-3 Revision No. 0

Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities" Insert 6 (Bases 3.10.1, LCO)

, and for control rod scram testing initiated in conjunction with an inservice leak or hydrostatic test.

Insert 7 (Bases 3.10.1, APPLICABILITY)

, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test,

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES ACTIONS (continued)

A._1 If an LCO specified in LCO 3.10.1 is not met, the ACTIONS applicable to the stated requirements are entered immediately and complied with.

Required Action A.1 has been modified by a Note that clarifies the intent of another LCO's Required Action to be in MODE 4 includes reducing the average reactor coolant temperature to < 212 0 F.

A.2.1 and A.2.2 Required Action A.2.1 and Required Action A.2.2 are alternate Required Actions that can be taken instead of Required Action A. 1 to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operation LCO's Applicability. Activities that could further No Changes increase reactor coolant temperature or pressure are suspended for immediately, in accordance with Required Action A.2.1, and the reactor Information coolant temperature is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2.2 is based on engineering judgment and provides sufficient time to reduce the average reactor coolant temperature from the highest expected value to < 212°F with normal cooldown procedures. The Completion Time is also consistent with the time provided in LCO 3.0.3 to reach MODE 4 from MODE 3.

SURVEILLANCE SR 3.10.1.1 REQUIREMENTS The LCOs made applicable are required to have their Surveillances met to establish that this LCO is being met. A discussion of the applicable SRs is provided in their respective Bases.

SR 3.10.1.2 This Surveillance is performed to ensure the reactor coolant specific activity is within limit. The Frequency is based on ensuring the reactor coolant specific activity is within the limit prior to increasing average reactor coolant temperature above the MODE 3 limit (i.e., 212 0 F).

REFERENCES 1. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI.

2. USAR, Section 14.7.3.

Monticello B 3.10.1-4 Revision No. 0