L-MT-14-023, Maximum Extended Load Line Limit Analysis Plus: Technical Specification Clarifications

Maximum Extended Load Line Limit Analysis Plus: Technical Specification Clarifications

ML14057A526
Person / Time
Site:	Monticello
Issue date:	02/24/2014
From:	Fili K Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-14-023, TAC ME3145
Download: ML14057A526 (14)

Text

XcelEnergy Monticello Nuclear Generating Plant 2807 W County Rd 75 Monticello, MN 55362 February 24, 2014 L-MT-14-023 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22

Subject:

Maximum Extended Load Line Limit Analysis Plus: Technical Specification Clarifications (TAC ME3145)

References:

1) Letter from T J O'Connor (NSPM), to Document Control Desk (NRC),

"License Amendment Request: Maximum Extended Load Line Limit Analysis Plus," L-MT-1 0-003, dated January 21, 2010. (ADAMS Accession No. MLI100280558)

In Reference 1, Northern States Power Company, a Minnesota corporation (NSPM),

doing business as Xcel Energy, requested approval of an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications (TS). The proposed change would allow operation in the expanded Maximum Extended Load Line Limit Analysis Plus (MELLLA+) domain.

On February 19, 2014, the NRC staff requested that NSPM provide clarifications to the proposed MELLLA+ TS. The clarifications involve:

1. Administrative Clarifications - Clarify TS numbering based on the TS numbering convention, TS language and recent amendments to the TS.

2. Improved Coordination Between TS 3.3.1.1.1 and TS 5.6.6 - Clarify the reporting timeframe to provide a required report to the NRC for an inoperable Oscillation Power Range Monitor (OPRM) in TS 3.3.1.1.1 and TS 5.6.6 as proposed in Enclosure 1 of this letter.

The purpose of this letter is to provide the NRC with clarifications to the proposed TS provided in Reference 1.

Al o(

Document Control Desk Page 2 Enclosure I to this letter provides a description of the proposed changes and a justification for the proposed changes. provides a markup to the proposed TS page for MELLLA+ indicating the clarifications to the previously proposed TS changes. provides final TS pages for MELLLA+ including these changes.

The clarifying information provided herein does not change the conclusions of the No Significant Hazards Consideration and the Environmental Consideration evaluations provided in Reference I for the MELLLA+ license amendment request.

In accordance with 10 CFR 50.91 (b), a copy of this application supplement, without enclosures is being provided to the designated Minnesota Official.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

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

Executed on: February-_, 2014 IKaren D. Fili Site Vice-President Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (3) cc: Regional Administrator, Region Ill, USNRC (w/o enclosures)

Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC (w/o enclosures)

Minnesota Department of Commerce (w/o enclosures)

L-MT-14-023 ENCLOSURE 1 Clarification of Maximum Extended Load Line Limit Analysis Plus Proposed Technical Specifications 1.0 Summary Description In Reference 1, Northern States Power Company, a Minnesota corporation (NSPM),

doing business as Xcel Energy, requested approval of an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications (TS). The proposed change would allow operation in the expanded Maximum Extended Load Line Limit Analysis Plus (MELLLA+) domain.

On February 19, 2014 the NRC staff requested that NSPM provide clarifications to the proposed MELLLA+ TS provided in Reference 1. The proposed clarifications include:

1. Administrative Clarifications - Clarify TS numbering based on TS numbering convention, TS language and recent amendments to the TS.

2. Improved Coordination Between TS 3.3.1.1.1 and TS 5.6.6 - Clarify the reporting timeframe to provide a required report to the NRC for an inoperable Oscillation Power Range Monitor (OPRM) in proposed TS 3.3.1.1.1 and proposed TS 5.6.6.

This is considered an administrative clarification.

2.0

Background:

In Reference 1, NSPM provided proposed TS changes to implement MELLLA+

based on conformance to the NRC approved topical reports. The proposed changes herein would clarify these proposed TS by revising the following: TS numbering; language convention; recent amendments to the TS; and removing redundancy for the 90-day timeframe for a TS 5.6.5 report in TS 3.3.1.1.1.

3.0 Detailed Description 3.1 Administrative Clarifications The proposed TS administrative clarifications are:

• renumber proposed TS 3.3.1.1.1 Required Action "1.2.1" to "1.2."

• renumber proposed TS 3.3.1.1.1 Required Action "1.2.2" to "1.3."

• renumber TS "5.6.5" as referenced in TS 3.3.1.1.1 Required Action 1.2.2 to "5.6.6."

Page 1 of 5

L-MT-14-023

• renumber proposed TS "5.6.5" to "5.6.6."

3.2 Coordination of TS 3.3.1.1.1 and TS 5.6.6 The proposed TS change would change the Completion Time associated with TS 3.3.1.1 .1, Required Action 1.2.2 (renumbered above to 1.3) from "90 days" to "Immediately." Further, TS 5.6.5 (renumbered above to 5.6.6) would be changed as follows:

From:

"When a report is required by CONDITION I of LCO 3.3.1.1, "ReactorProtective System (RPS) Instrumentation,"a reportshall be submitted within 90 days of entering CONDITION I."

To:

"When a report is required by Condition I of LCO 3.3.1.1, "ReactorProtection System (RPS) Instrumentation," a reportshall be submitted within the following 90 days."

See Enclosure 2 for a markup of these TS pages.

4.0 Evaluation 4.1 Administrative Clarification

-the proposed renumbering clarifications are administrative in nature as they do not change any TS requirements previously proposed or modify the order or scope of any proposed TS. The clarifications have been made to change the numbering system of the proposed TS to that which more closely follows the current TS convention.

The change in numbering for TS 5.6.5 to TS 5.6.6 is necessary due to a recent TS amendment 172, that included TS 5.6.5 to describe the Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR). Therefore, the proposed TS 5.6.5 is being renumbered to 5.6.6.

Page 2 of 5

L-MT-14-023 4.2 Coordination of TS 3.3.1.1.1 and TS 5.6.6 The proposed changes are administrative in nature as they do not change any TS requirements previously proposed or modify the order or scope of any proposed TS.

The purpose of these proposed changes is to improve the coordination and remove the redundancy between TS 3.3.1.1.1 and TS 5.6.6. Further, the proposed clarifications are administrative in nature as they clarify the proposed format and language to be consistent with current TS format and language.

The clarification to TS 3.3.1.1.1, Condition 1.2.2 (renumbered to 1.3) from "90 days" to "Immediately" is necessary so that the redundant 90 days in TS 5.6.5 (renumbered to 5.6.6) is not considered an additional 90 days (i.e., for a total of 180 days) to provide the required report concerning OPRM inoperability. This clarification restores the original intent of the proposed TS that when the OPRM is made or found inoperable (subject to other limitations and criteria in TS 3.3.1.1) a report shall be submitted in accordance with TS 5.6.6 within 90 days. This clarification is consistent with comparable reporting language in TS 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," Conditions B and F.

Other clarifications are made to a sentence in TS 5.6.5 (renumbered to 5.6.6) to improve readability and for consistency with TS language convention. In TS 5.6.6 the following sentence is proposed to be changed:

From:

"When a reportis requiredby CONDITION I of LCO 3.3.1.1, "ReactorProtective System (RPS) Instrumentation," a reportshall be submitted within 90 days of entering CONDITION I."

To:

"When a reportis requiredby Condition I of LCO 3.3.1.1, "ReactorProtection System (RPS) Instrumentation,"a report shall be submitted within the following 90 days."

The changes in this sentence were made to remove redundancy, correct terminology and align the language for the report generation requirement to be consistent with the format and language for similar requirements (e.g. TS 5.6.4, "Post Accident Monitoring Report"). This clarification does not affect the frequency, requirements, or contents of the OPRM Report and is considered an administrative clarification.

Page 3 of 5

L-MT-14-023 4.3 Conclusion The proposed changes are administrative in nature as they do not change any TS requirements previously proposed or modify the order or scope of any proposed TS.

The changes proposed are made to align with the current TS numbering system and align to the current TS convention, format, and language and provide numbering changes that are based on recently approved amendments to the MNGP TS.

5.0 Regulatory Analysis 5.1 No Significant Hazards Determination Since the clarifications described above are administrative in nature and no technical changes to the MELLLA+ design and licensing bases are proposed, the No Significant Hazards Determination provided in Reference 1 remains unchanged.

Therefore, NSPM has determined that operation of the facility in accordance with the proposed clarifications does not involve a significant hazards consideration as defined in 10 CFR 50.92(c), in that it does not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

5.2 Applicable Regulatory Requirements Since the clarifications described above are administrative in nature and no technical changes to the MELLLA+ design and licensing bases are proposed, the applicable regulatory requirements provided in Reference 1 remain unchanged.

NSPM has evaluated the proposed clarifications against the applicable regulatory requirements and acceptance criteria provided in the MELLLA+ License Amendment Request (LAR) (Reference 1) and determined that the clarifications do not affect the conclusion that MELLLA+ is consistent with the applicable regulatory criteria described in the MELLLA+ LAR. Based on this rationale, there is reasonable assurance that the health and safety of the public, following approval of this change, is unaffected.

6.0 Environmental Evaluation Since the clarifications described above are administrative in nature and no technical changes to the MELLLA+ design and licensing bases are proposed, the Environmental Evaluation provided in Reference 1 remains unchanged.

Page 4 of 5

L-MT-14-023 Therefore, NSPM has determined that the proposed clarifications would not revise a requirement with respect to installation or use of a facility or component located within the restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement.

The proposed MELLLA+ amendment in Reference I does not involve (i) a significant hazards consideration, or (ii) authorize a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) result in a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed MELLLA+ amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, NSPM concludes that pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment. The proposed clarifications do not alter the environmental assessment performed in support of the MELLLA+ LAR.

7.0 References

1. Letter from T J O'Connor (NSPM), to Document Control Desk (NRC), "License Amendment Request: Maximum Extended Load Line Limit Analysis Plus," L-MT-10-003, dated January 21, 2010. (ADAMS Accession No. ML100280558)

Page 5 of 5

L-MT-14-023 ENCLOSURE 2 CLARIFICATION TO MAXIMUM EXTENDED LOAD LINE LIMIT ANALYSIS PLUS MARKED-UP TECHNICAL SPECIFICATION PAGES 3.3.1.1-3 5.6-3 2 pages follow

I. As required by I.l Initiate action to Required Action D.1 implement the Manual *h-eoImmediatelv and referenced in BSP Regions defined Table 3.3.1.1-1. in the COLR--ternate rnzthed te dzteet an~d suppress thzrir..l AND I.2-.4 Implement the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Automated BSP Scram Region using the modified APRM Simulated Thermal Power - High scram setpoints defined in the COLR. Ilmmediately I.4-4 Initiate action in accordance with Specification 5.6.&..

J. Required Action and J.l Initiate action to Immediately associated Completion implement the Manual BSP Time of Condition I not Regions defined in the met. COLR.

AND J.2 Reduce operation to below 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> the BSP Boundary defined in the COLR.

AND J.3 NOTE---------- 120 days LCO 3.0.4 is not applicable Restore required channel to OPERABLE I

I xK. Required Action and 4K.l Reduce THERMAL POWER 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> associated Completion to <20% RTP. I Time of condition 4--j not met.

13..11-

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.4 Post Accident Monitoring Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

/--M:l i6,, OPIRM Repor j-ond~tion Rat 2 the fo lowingo e ProtetionJ When a report is required by I of LCO 3.3.1.1. "React 1GNT',,

System (RPS) Instrumentation." a report shall be submitted within 90 days ef-iet- CO.'DT',O;" I. The report shall outline the preplanned means to provide backup stability protection, the cause of the inoperability, and the plans and schedule for restoring the required instrumentation channels to OPERABLE status.

5.6-3 Amendment No. 44~, 159 Monticello 5.6-3 Amendment No. 446, 159

L-MT-14-023 ENCLOSURE 3 CLARIFICATION TO MAXIMUM EXTENDED LOAD LINE LIMIT ANALYSIS PLUS FINAL TECHNICAL SPECIFICATION PAGES 3.3.1.1-3 5.6-3 2 pages follow

RPS Instrumentation 3.3.1.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME As required by Required 1.1 Initiate action to implement Immediately Action D.1 and the Manual BSP Regions referenced in defined in the COLR.

Table 3.3.1.1-1.

AND 1.2 Implement the Automated 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> BSP Scram Region using the modified APRM Simulated Thermal Power -

High scram setpoints defined in the COLR.

AND 1.3 Initiate action in accordance Immediately with Specification 5.6.6.

J. Required Action and J.1 Initiate action to implement Immediately associated Completion the Manual BSP Regions Time of Condition I not defined in the COLR.

met.

AND J.2 Reduce operation to below 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> the BSP Boundary defined in the COLR.

AND J.3 --------- NOTE ----------------

LCO 3.0.4 is not applicable Restore required channel to 120 days OPERABLE.

K. Required Action and K.1 Reduce THERMAL 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> associated Completion POWER to < 20% RTP.

Time of Condition J not met.

Monticello 3.3.1.1-3 Amendment No. 446,-4-59, 180

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.4 Post Accident Monitoring Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.5 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

a. RCS pressure and temperature limits for heatup, cooldown, low temperature operation, criticality, and hydrostatic testing as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:

1. Limiting Conditions for Operation Section 3.4.9, "RCS Pressure and Temperature (P/T) Limits"

2. Surveillance Requirements Section 3.4.9, "RCS Pressure and Temperature (P/T) Limits"

b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1. SIR-05-044-A, "Pressure-Temperature Limits Report Methodology for Boiling Water Reactors," Revision 0, dated April 2007.

c. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplements thereto.

5.6.6 OPRM Report When a report is required by Condition I of LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," a report shall be submitted within the following 90 days. The report shall outline the preplanned means to provide backup stability protection, the cause of the inoperability, and the plans and schedule for restoring the required instrumentation channels to OPERABLE status.

Monticello 5.6-3 Amendment No. 146, 159, 172, 180

QF-0212, Revision 4 (FP-SC-RSI-04) Page 1 of 1

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