Text

License Amendment Request: Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process
	ML15196A576
Person / Time
Site:	Monticello
Issue date:	07/15/2015
From:	Gardner P; Xcel Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-MT-15-048, TAC MD7847
	Download: ML15196A576 (55)
	v • d • e

Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 July 15, 2015 L-MT-15-048 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 Facility Operating License No. DPR-22 License Amendment Request: Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process

References:

1) NSPM to NRC, Nine-month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," letter L-MT-08-063, dated October 14, 2008 (TAC No. MD7847)

2) NSPM to NRC, Revise Commitment Date to Submit License Amendment Request for Adoption of TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, letter L-MT-14-065, dated July 8, 2014

3) NSPM to NRC, Revise Commitment Date to Submit License Amendment Request for Adoption of TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, letter L-MT-15-009, dated January 14, 2015 Pursuant to 10 CFR 50.90, Northern States Power Company - Minnesota (NSPM),

doing business as Xcel Energy, Inc., is submitting a request for an amendment to the Technical Specifications (TS) for the Monticello Nuclear Generating Plant (MNGP).

The proposed amendment would modify the TS requirements to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." NSPM committed to submit this proposed change in Reference 1 and revised the commitment due date in Reference 2 and 3.

Document Control Desk L-MT-15-048 Page 2 of 2 provides a description and assessment of the proposed changes. provides the existing TS pages marked up to show the proposed changes. provides the existing TS Bases pages marked up to show the proposed changes. Changes to the existing TS Bases, consistent with the technical and regulatory analyses, will be implemented under the Technical Specification Bases Control Program. They are provided in Enclosure 3 for information only.

NSPM requests approval of this proposed license amendment request by July 26, 2016, with the amendment being implemented prior to startup from the 2017 Refueling Outage.

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.

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

Summary of Commitments This letter closes the following commitment made in Reference 3.

NSPM will evaluate the Technical Specification changes in the Technical Specification Task Force (TSTF) Traveler related to gas accumulation within the ECCS [Emergency Core Cooling Systems] for applicability to the MNGP and submit a license amendment request, adjusted, as needed, to account for the MNGP plant-specific design and licensing basis, by July 15, 2015.

This letter does not propose any new commitments and does not revise any existing commitments.

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

Executed on July iQ015.

~~~

Peter A. Gardner Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company- Minnesota

Enclosures:

(3) cc: Administrator, Region Ill, USNRC Resident Inspector, Monticello, USNRC Project Manager, Monticello, USNRC Minnesota Department of Commerce

ENCLOSURE 1 MONTICELLO NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-523, GENERIC LETTER 2008-01 MANAGING GAS ACCUMULATION, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS DESCRIPTION AND ASSESSMENT OF CHANGES (9 pages follow)

L-MT-15-048 Table of Contents Page 1 of 1 TABLE OF CONTENTS SECTION TITLE PAGE

1.0 DESCRIPTION

1 2.0 ASSESSMENT 1 2.1 Applicability of the Published Safety Evaluation 1 2.2 Optional Changes and Variations 1

3.0 REGULATORY ANALYSIS

3 3.1 No Significant Hazards Consideration Determination 3 3.2 Applicable Regulatory Requirements 5 4.0 ENVIRONMENTAL EVALUATION 8

L-MT-15-048 Page 1 of 8 REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-523, GENERIC LETTER 2008-01 MANAGING GAS ACCUMULATION, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

1.0 DESCRIPTION

The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification. The changes are being made to address the concerns discussed in Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems.

The proposed amendment is consistent with TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation.

2.0 ASSESSMENT 2.1 Applicability of the Published Safety Evaluation Northern States Power Company - Minnesota (NSPM) has reviewed the model safety evaluation dated January 15, 2014, as part of the Federal Register Notice of Availability (NOA). This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-523. As described in the subsequent paragraphs, NSPM has concluded that the justifications presented in the TSTF-523 proposal and the model safety evaluation prepared by the NRC staff are applicable to the Monticello Nuclear Generating Plant (MNGP) and justify this amendment for the incorporation of the changes into the MNGP Technical Specifications (TSs).

2.2 Optional Changes and Variations NSPM is proposing the following variations from the TS changes described in the TSTF-523, Revision 2, or the applicable parts of the NRC staffs model safety evaluation dated January 15, 2014.

Table 1 provides a description of the proposed changes and variations from TSTF-523.

These differences are administrative, with two exceptions: first, to revise Surveillance Requirement (SR) 3.5.1.1 to remove the qualifier that this SR only pertains to low pressure ECCS injection/spray subsystems, and second, add an additional MNGP specification to maintain internal consistency within the MNGP TS. These changes do not affect the applicability of TSTF-523, Revision 2, to the MNGP TS.

L-MT-15-048 Enclosure 1 Page 2 of 8 Table 1 - Comparison Between NUREG-1433 and MNGP Specifications NUREG-1433 TS - TSTF-523 Mark-up MNGP Equivalent Technical Specifications Notes - Discussion of NUREG-1433 MNGP Equivalent Differences Between Specification SRs Affected Spec. MNGP SRs TSTF-523 and MNGP TS Title (BWR/4) Title RHR cut in permissive 3.4.8, Residual Heat pressure is referred to as Removal (RHR) Add new Add new 3.4.7(1) the RHR shutdown Shutdown Cooling SR 3.4.8.2 SR 3.4.7.2(1) cooling supply isolation System - Hot Shutdown interlock.

3.4.9, RHR Shutdown Add new Add new Cooling System - Cold 3.4.8(1)

SR 3.4.9.2 SR 3.4.8.2(1)

Shutdown Revise SR 3.5.1.1 to remove words low 3.5.1, ECCS [Emergency Revise Revise SR 3.5.1.1 pressure. The SR now Core Cooling Systems] - 3.5.1 SR 3.5.1.1 and and SR 3.5.1.2 also applies to the High Operating SR 3.5.1.2 Pressure Coolant Injection (HPCI) System.

Revise Revise SR 3.5.2.3 3.5.2, ECCS - Shutdown 3.5.2 SR 3.5.2.2(1) and and SR 3.5.2.4 SR 3.5.2.3(1)

Revise New SR 3.5.3.5 added at 3.5.3, RCIC [Reactor Revise SR 3.5.3.1 SR 3.5.3.1 and end of SR listing.

Core Isolation Cooling] 3.5.3 and SR 3.5.3.2 add new Corresponds to SR 3.5.3.1 System SR 3.5.3.5(1) in NUREG-1433.

3.6.2.3, RHR Suppression Add new Add new New SR 3.6.2.3.3 added at 3.6.2.3 Pool Cooling SR 3.6.2.3.2 SR 3.6.2.3.3(1) end of SR listing.

3.6.2.4, RHR Suppression Add new MNGP TS do not include N/A N/A Pool Spray SR 3.6.2.4.2 this specification.

A similar function, Spec.

3.6.1.8, RHR Drywell Spray, is included in the Add new 3.6.1.8(1) MNGP TS. New SR 3.6.1.8.3(1)

SR 3.6.1.8.3 aligns with SR 3.6.2.4.2. This new SR added at end of SR listing.

3.9.8, RHR - High Water Add new Add new 3.9.7(1)

Level SR 3.9.8.2 SR 3.9.7.2(1) 3.9.9, RHR - Low Water Add new Add new 3.9.8(1)

Level SR 3.9.9.2 SR 3.9.8.2(1)

Note (1): The corresponding MNGP specification number or specific SR number are different from those specified in the BWR/4 Standard Technical Specifications (STS)

NUREG-1433 that is marked-up in TSTF-523 for the same or similar specification.

L-MT-15-048 Page 3 of 8 The MNGP TS utilizes different numbering than the Standard Technical Specifications on which TSTF-523 was based. Also, the MNGP TS do not have some of the existing SRs revised by TSTF-523. These differences do not affect the applicability of TSTF-523 to the MNGP TS.

For those case(s) where an existing surveillance requirement is not being modified and insertion of a new surveillance requirement would result in renumbering of the following surveillance requirements in a specification, NSPM proposes to instead add a new surveillance requirement at the end of the existing surveillance requirements listing for the specification. This avoids a large administrative impact requiring the renumbering of the existing TS surveillance requirements, the revising of the associated surveillance procedures, and revising other plant operating procedures that refer to these surveillance requirements.

SR 3.5.1.1 in Specification 3.5.1, ECCS [Emergency Core Cooling Systems] -

Operating, currently pertains only to the low pressure ECCS injection/spray subsystems. To align this surveillance with TSTF-523, it is proposed to remove the words low pressure from the surveillance requirement so that it will also pertain to the high pressure High Pressure Coolant Injection (HPCI) System. This change is consistent with the intent and aligns the MNGP specification to align with NUREG-1433, which is the basis from which TSTF-523 was developed.

The MNGP TS do not include Specification 3.6.2.4, RHR [Residual Heat Removal]

Suppression Pool Spray that is contained in NUREG-1433. However, the MNGP TS do include another RHR specification for a similar application, Specification 3.6.1.8, RHR Drywell Spray. NSPM proposes to add a new surveillance requirement to Specification 3.6.1.8 due to the similarity of functions, and for consistency, considering the RHR System has surveillance requirements specified in several other specifications.

All of these changes are in accordance with the guidance and the intent of addressing gas accumulation issues as outlined in TSTF-523, Revision 2, and hence, acceptable.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination NSPM requests adoption of TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," which is an approved change to the standard technical specifications (STS), into the MNGP TS. The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

L-MT-15-048 Page 4 of 8 NSPM has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, as discussed below:

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

Response: No.

The proposed change revises or adds Surveillance Requirement(s) (SRs) that require verification that the Emergency Core Cooling Systems (ECCS), the Residual Heat Removal (RHR) System / Shutdown Cooling (SDC) System, the Containment Spray (CS) System, and the Reactor Core Isolation Cooling (RCIC) System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. Gas accumulation in the subject systems is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The proposed SRs ensure that the subject systems continue to be capable to perform their assumed safety function and are not rendered inoperable due to gas accumulation. Thus, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change revises or adds SRs that require verification that the ECCS, the RHR / SDC System, the CS System, and the RCIC System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the proposed change does not impose any new or different requirements that could initiate an accident. The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions.

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

L-MT-15-048 Page 5 of 8

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

Response: No.

The proposed change revises or adds SRs that require verification that the ECCS, the RHR / SDC System, the CS System, and the RCIC System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change clarifies requirements for management of gas accumulation in order to ensure the subject systems are capable of performing their assumed safety functions. The proposed SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis are protected.

The proposed change does not adversely affect any current plant safety margins or the reliability of the equipment assumed in the safety analysis.

Therefore, there are no changes being made to any safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

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

Based on the above, NSPM concludes that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Applicable Regulatory Requirements General Design Criteria (GDC)

MNGP was designed largely before the publishing of the 70 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 Updated Safety Analysis Report (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. GDCs and PDCs directly associated with the ECCS, the RHR and SDC System, the CS System, and the RCIC System are presented below.

L-MT-15-048 Page 6 of 8 PDC 1.2.3 - Reactor Core Cooling

b. Heat removal systems are provided to remove decay heat generated in the reactor core under circumstances wherein the normal operational heat removal systems become inoperative. The capacity of such systems is adequate to prevent fuel clad damage.

c. Redundant heat removal systems are provided to preserve reactor core heat transfer geometry following various postulated design basis loss-of-coolant accidents.

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

Criterion 37 - Engineered Safety Features Basis for Design (Category A)

Engineered safety features shall be provided in the facility to back up the safety provided by the core design, the reactor coolant pressure boundary, and their protection systems. As a minimum, such engineered safety features shall be designed to cope with any size reactor pressure boundary break up to and including the circumferential rupture of any pipe in that boundary assuming unobstructed discharge from both ends.

Criterion 44 - Emergency Core Cooling System Capability (Category A)

At least two emergency core cooling systems, preferably of different design principles, each with a capability for accomplishing abundant emergency core cooling, shall be provided. Each emergency core cooling system and the core shall be designed to prevent fuel and clad damage that would interfere with the emergency core cooling function and to limit the clad metal-water reaction to negligible amounts of all sizes of breaks in the reactor coolant pressure boundary, including the double-ended rupture of the largest pipe.

The performance of each emergency core cooling system shall be evaluated conservatively in each area of uncertainty. The systems shall not share active components and shall not share other features or components unless it can be demonstrated that (a) the capability of the shared feature or components to perform its required function can be readily ascertained during reactor operation, (b) failure of the shared feature or component does not initiate a loss-of-coolant accident, and (c) capability of the shared feature or component to perform its required function is not impaired by the effects of a loss-of-coolant accident and is not lost during the entire period this function is required following the accident.

L-MT-15-048 Page 7 of 8 10 CFR 50, Appendix A, General Design Criteria Criterion 33Reactor coolant makeup. A system to supply reactor coolant makeup for protection against small breaks in the reactor coolant pressure boundary shall be provided. The system safety function shall be to assure that specified acceptable fuel design limits are not exceeded as a result of reactor coolant loss due to leakage from the reactor coolant pressure boundary and rupture of small piping or other small components which are part of the boundary. The system shall be designed to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished using the piping, pumps, and valves used to maintain coolant inventory during normal reactor operation.

Criterion 34Residual heat removal. A system to remove residual heat shall be provided. The system safety function shall be to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.

Suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

Criterion 35Emergency core cooling. A system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.

Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

NSPM has evaluated the proposed changes against the applicable regulatory requirements and acceptance criteria. The technical analysis concludes that 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, (i) there is reasonable assurance that the health and safety of the public

L-MT-15-048 Page 8 of 8 will not be endangered by operation in the proposed manner, (ii) such activities will be conducted in compliance with the Commissions regulations, and (iii) 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.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

ENCLOSURE 2 MONTICELLO NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-523, GENERIC LETTER 2008-01 MANAGING GAS ACCUMULATION, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS MARKED-UP TECHNICAL SPECIFICATION PAGES (9 pages follow)

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.7.2 -------------------------------NOTE------------------------------ 31 days Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than the RHR shutdown cooling supply isolation interlock.

Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.4.7-3 Amendment No. ___

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2 Monitor reactor coolant Once per hour temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR shutdown cooling subsystem or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months recirculation pump is operating.

SR 3.4.8.2 Verify RHR shutdown cooling subsystem locations 31 days susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.4.8-2 Amendment No. 146, ___

ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each low pressure ECCS injection/spray 31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve locations susceptible to gas accumulation are sufficiently filled with water.

SR 3.5.1.2 -------------------------------NOTE------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS injection/spray subsystem 31 days manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.1.3 Verify ADS pneumatic pressure is as follows for 31 days each required ADS pneumatic supply:

a. S/RV Accumulator Bank header pressure 88.3 psig; and

b. Alternate Nitrogen System pressure is 410 psig.

SR 3.5.1.4 -------------------------------NOTE------------------------------

Only required to be met in MODE 1.

Verify the RHR System intertie return line isolation 31 days valves are closed.

SR 3.5.1.5 Verify correct breaker alignment to the LPCI swing 31 days bus.

SR 3.5.1.6 Verify each recirculation pump discharge valve In accordance cycles through one complete cycle of full travel or is with the Inservice de-energized in the closed position. Testing Program Monticello 3.5.1-5 Amendment No. 146, 155, 162, ___

ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for each required ECCS injection/spray 31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve locations susceptible to gas accumulation are sufficiently filled with water.

SR 3.5.2.3 -------------------------------NOTE------------------------------

Not required to be met for system vent flow paths opened under administrative control.

31 days Verify each required ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.4 Verify each required ECCS pump develops the In accordance specified flow rate against a system head with the Inservice corresponding to the specified reactor to Testing Program containment pressure.

System Head Corresponding to a Reactor to No. of Containment System Flow Rate Pumps Pressure of Core Spray 2835 gpm 1 130 psi LPCI 3870 gpm 1 20 psi SR 3.5.2.5 -------------------------------NOTE------------------------------

Vessel injection/spray may be excluded.

Verify each required ECCS injection/spray 24 months subsystem actuates on an actual or simulated automatic initiation signal.

Monticello 3.5.2-3 Amendment No. 146, 167, ___

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 -------------------------------NOTE------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each RCIC System manual, power operated, 31 days and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.3.2 -------------------------------NOTE------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 1025.3 psig and In accordance 950 psig, the RCIC pump can develop a flow rate with the Inservice 400 gpm against a system head corresponding to Testing Program reactor pressure.

SR 3.5.3.3 -------------------------------NOTE------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 165 psig, the RCIC 24 months pump can develop a flow rate 400 gpm against a system head corresponding to reactor pressure.

SR 3.5.3.4 -------------------------------NOTE------------------------------

Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or 24 months simulated automatic initiation signal.

SR 3.5.3.5 Verify the RCIC System locations susceptible to gas 31 days accumulation are sufficiently filled with water.

Monticello 3.5.3-2 Amendment No. 146, ___

RHR Drywell Spray 3.6.1.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.8.2 Verify each drywell spray header and nozzle is 10 years unobstructed.

SR 3.6.1.8.3 Verify RHR drywell spray subsystem locations 31 days susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.6.1.8-2 Amendment No. 146, ___

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.2.3.2 Verify each required RHR pump develops a flow In accordance rate > 3870 gpm through the associated heat with the Inservice exchanger while operating in the suppression pool Testing Program cooling mode.

SR 3.6.2.3.3 Verify RHR suppression pool cooling subsystem 31 days locations susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.6.2.3-2 Amendment No. 146, ___

RHR - High Water Level 3.9.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.3 Initiate action to restore one Immediately standby gas treatment subsystem to OPERABLE status.

AND B.4 Initiate action to restore Immediately isolation capability in each required secondary containment penetration flow path not isolated.

C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery cooling subsystem in circulation by an alternate of no reactor coolant operation. method. circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify one RHR shutdown cooling subsystem is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months operating.

SR 3.9.7.2 Verify required RHR shutdown cooling subsystem 31 days locations susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.9.7-2 Amendment No. 146, ___

RHR - Low Water Level 3.9.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.3 Initiate action to restore Immediately isolation capability in each required secondary containment penetration flow path not isolated.

C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery cooling subsystem in circulation by an alternate of no reactor coolant operation. method. circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one RHR shutdown cooling subsystem is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months operating.

SR 3.9.8.2 Verify RHR shutdown cooling subsystem locations 31 days susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.9.8-2 Amendment No. 146, ___

ENCLOSURE 3 MONTICELLO NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-523, GENERIC LETTER 2008-01 MANAGING GAS ACCUMULATION, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS MARKED-UP TECHNICAL SPECIFICATION BASES PAGES (32 pages follow)

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown BASES BACKGROUND Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant. This decay heat must be removed to reduce the temperature of the reactor coolant to 212°F in preparation for performing Refueling or Cold Shutdown maintenance operations, or for keeping the reactor in the Hot Shutdown condition.

The two redundant, manually controlled shutdown cooling subsystems of the RHR System provide decay heat removal. Each loop consists of two motor driven pumps, a heat exchanger, and associated piping and valves.

Both loops have a common suction from the same recirculation loop. Each pump discharges the reactor coolant, after circulation through the respective heat exchanger, to the reactor via either recirculation loop. The RHR heat exchangers transfer heat to the RHR Service Water System (LCO 3.7.1, "Residual Heat Removal Service Water (RHRSW) System").

APPLICABLE Decay heat removal by operation of the RHR System in the shutdown SAFETY cooling mode is not required for mitigation of any event or accident ANALYSES evaluated in the safety analyses. Decay heat removal is, however, an important safety function that must be accomplished or core damage could result. The RHR Shutdown Cooling System satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO Two RHR shutdown cooling subsystems are required to be OPERABLE, and when no recirculation pump is in operation, one shutdown cooling subsystem must be in operation. An OPERABLE RHR shutdown cooling subsystem consists of one OPERABLE RHR pump, one heat exchanger, and the associated piping and valves. The two subsystems have a common suction source and are allowed to have a common heat exchanger and common discharge piping. Thus, to meet the LCO, both pumps in one loop or one pump in each of the two loops must be OPERABLE. Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems. Each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 3, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy.

Operation of one subsystem can maintain or reduce the reactor coolant temperature as required. To ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

Monticello B 3.4.7-1 Revision No. ___

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES ACTIONS (continued)

Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR subsystem in the control room.

This Surveillance is modified by a Note allowing sufficient time to align the RHR System for shutdown cooling operation after clearing the pressure interlock that isolates the system, or for placing a recirculation pump in operation. The Note takes exception to the requirements of the Surveillance being met (i.e., forced coolant circulation is not required for this initial 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period), which also allows entry into the Applicability of this Specification in accordance with SR 3.0.4 since the Surveillance will not be "not met" at the time of entry into the Applicability.

SR 3.4.7.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Monticello B 3.4.7-4 Revision No. ___

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES SURVEILLANCE REQUIREMENTS (continued)

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

This SR is modified by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam dome pressure is less than the RHR shutdown cooling supply isolation interlock. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering the Applicability.

Monticello B 3.4.7-5 Revision No. ___

RHR Shutdown Cooling System - Hot Shutdown B 3.4.7 BASES SURVEILLANCE REQUIREMENTS (continued)

The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Shutdown Cooling System piping and the procedural controls governing system operation.

REFERENCES 1. Amendment No. XXX, Monticello Nuclear Generating Plant -

Issuance of Amendment to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Month Day, Year.

(ADAMS Accession No. MLxxxxxxxx)

Monticello B 3.4.7 Last Revision No. ___

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES LCO (continued) subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required. To ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

Note 1 permits both RHR shutdown cooling subsystems and recirculation pumps to be removed from operation for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. Note 2 allows one RHR shutdown cooling subsystem to be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillance tests.

These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation can be low enough and the heatup rate slow enough to allow some changes to the RHR subsystems or other operations requiring RHR flow interruption and loss of redundancy.

APPLICABILITY In MODE 4, the RHR Shutdown Cooling System must be OPERABLE and one RHR shutdown cooling subsystem may be operated in the shutdown cooling mode to remove decay heat to maintain coolant temperature below 212°F. Otherwise, a recirculation pump is required to be in operation.

In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR shutdown cooling supply isolation interlock, this LCO is not applicable. Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the shutdown cooling piping. Decay heat removal at reactor pressures greater than or equal to the RHR shutdown cooling supply isolation interlock is typically accomplished by condensing the steam in the main condenser.

Additionally, in MODE 2, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS) (LCO 3.5.1, "ECCS -

Operating") do not allow placing the RHR shutdown cooling subsystem into operation.

The requirements for decay heat removal in MODE 3 below the cut in permissive pressure and in MODE 5 are discussed in LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown," LCO 3.9.7, "Residual Heat Removal (RHR) - High Water Level," and LCO 3.9.8, "Residual Heat Removal (RHR) - Low Water Level."

Monticello B 3.4.8-2 Revision No. ___

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES ACTIONS (continued)

B.1 and B.2 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, and until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR Shutdown Cooling System or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR subsystem in the control room.

SR 3.4.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points Monticello B 3.4.8-4 Revision No. ___

RHR Shutdown Cooling System - Cold Shutdown B 3.4.8 BASES SURVEILLANCE REQUIREMENTS (continued) and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Shutdown Cooling System piping and the procedural controls governing system operation.

REFERENCES 1. Amendment No. XXX, Monticello Nuclear Generating Plant -

Issuance of Amendment to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Month Day, Year.

(ADAMS Accession No. MLxxxxxxxx)

Monticello B 3.4.8 Last Revision No. ___

ECCS - Operating 3.5.1 BASES APPLICABLE The ECCS performance is evaluated for the entire spectrum of break SAFETY sizes for a postulated LOCA. The accidents for which ECCS operation is ANALYSES required are presented in References 5 and 6. The required analyses and assumptions are defined in Reference 7. The results of these analyses are also described in References 5 and 6.

This LCO helps to ensure that the following acceptance criteria for the ECCS (Ref. 8), established by 10 CFR 50.46 (Ref. 9), will be met following a LOCA, assuming the worst case single active component failure in the ECCS:

a. Maximum fuel element cladding temperature is 2200°F;

b. Maximum cladding oxidation is 0.17°times the total cladding thickness before oxidation;

c. Maximum hydrogen generation from a zirconium water reaction is 0.01 times the hypothetical amount that would be generated if all of the metal in the cladding surrounding the fuel, excluding the cladding surrounding the plenum volume, were to react;

d. The core is maintained in a coolable geometry; and

e. Adequate long term cooling capability is maintained.

The limiting single failures are discussed in Reference 10. For a large discharge pipe break LOCA, failure of the LPCI valve on the unbroken recirculation loop is considered the most limiting break/failure combination. For a small break LOCA, HPCI failure is the most severe failure. Extended Power Uprate removed the allowance for one ADS valve out-of-service (Ref. 17). The remaining OPERABLE ECCS subsystems provide the capability to adequately cool the core and prevent excessive fuel damage. Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY.

The ECCS satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Each ECCS injection/spray subsystem and three ADS valves are required to be OPERABLE. The ECCS injection/spray subsystems are defined as the two CS subsystems, the two LPCI subsystems, and one HPCI System. The low pressure ECCS injection/spray subsystems are defined as the two CS subsystems and the two LPCI subsystems.

With less than the required number of ECCS subsystems OPERABLE, the potential exists that during a limiting design basis LOCA concurrent with the worst case single failure, the limits specified in Reference 9 could be exceeded. All ECCS subsystems must therefore be OPERABLE to satisfy the single failure criterion required by Reference 9.

Monticello B 3.5.1-5 Revision No. __

ECCS - Operating 3.5.1 BASES SURVEILLANCE SR 3.5.1.1 REQUIREMENTS The ECCS injection/spray subsystem flow path piping and components have the potential to develop voids and pockets of entrained gases.

Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS injection/spray subsystems and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS injection/spray subsystem locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The ECCS injection/spray subsystem is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS injection/spray subsystems are not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS injection/spray subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. While the potential for developing voids in the HPCI System exists, the effects of a void have been analyzed and shown to be acceptable. The accuracy of the method used for Monticello B 3.5.1-12 Revision No. __

ECCS - Operating 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued) monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day Frequency is based on the gradual nature of void buildup in the ECCS injection/spray subsystem piping, the procedural controls governing system operation, and operating experience.

SR 3.5.1.2 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. For the HPCI System, this SR also includes the steam flow path for the turbine and the flow controller position.

The 31 day Frequency of this SR was derived from the Inservice Testing Program requirements for performing valve testing at least once every 92 days. The Frequency of 31 days is further justified because the valves are operated under procedural control and because improper valve position would only affect a single subsystem. This Frequency has been shown to be acceptable through operating experience.

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

SR 3.5.1.3 Verification every 31 days that each ADS pneumatic pressure is within the analysis limits (S/RV Accumulator Bank header pressure 88.3 psig and Alternate Nitrogen System supply (ALT N2 TRAIN A (or B) SUPPLY) pressure 410 psig (Ref. 13)) ensures adequate pressure for reliable Monticello B 3.5.1-13 Revision No. __

ECCS - Operating 3.5.1 BASES REFERENCES (continued)

18. Amendment No. XXX, Monticello Nuclear Generating Plant -

Issuance of Amendment to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Month Day, Year.

(ADAMS Accession No. MLxxxxxxxx)

Monticello B 3.5.1 Last Revision No. __

ECCS - Shutdown B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEM (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 ECCS - Shutdown BASES BACKGROUND A description of the Core Spray (CS) System and the low pressure coolant injection (LPCI) mode of the Residual Heat Removal (RHR)

System is provided in the Bases for LCO 3.5.1, "ECCS - Operating."

APPLICABLE The ECCS performance is evaluated for the entire spectrum of break SAFETY sizes for a postulated loss of coolant accident (LOCA). The long term ANALYSES cooling analysis following a design basis LOCA (Ref. 1) demonstrates that only one low pressure ECCS injection/spray subsystem is required, post LOCA, to maintain adequate reactor vessel water level in the event of an inadvertent vessel draindown. It is reasonable to assume, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level. To provide redundancy, a minimum of two low pressure ECCS injection/spray subsystems are required to be OPERABLE in MODES 4 and 5.

The low pressure ECCS subsystems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Two low pressure ECCS injection/spray subsystems are required to be OPERABLE. The low pressure ECCS injection/spray subsystems consist of two CS subsystems and two LPCI subsystems. Each CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or one or two condensate storage tanks (CSTs) to the reactor pressure vessel (RPV). Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or from one or two CSTs to the RPV. A single LPCI pump is required per subsystem because of similar injection capacity in relation to a CS subsystem. In addition, in MODES 4 and 5 the RHR System cross-tie valve is not required to be open. Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY.

As noted, one LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned (remote or local) to the LPCI mode and is not otherwise inoperable. Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is realigned from or to the RHR shutdown cooling mode. This allowance is necessary since the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Because of low pressure and low temperature Monticello B 3.5.2-1 Revision No. __

ECCS - Shutdown B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 REQUIREMENTS The minimum water level of -3 ft required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for the CS System and LPCI subsystem pumps, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, all ECCS injection/spray subsystems are inoperable unless they are aligned to an OPERABLE CST.

When suppression pool level is < -3 ft, the CS and LPCI subsystems are considered OPERABLE only if they can take suction from the CST(s),

and the CST(s) water level is sufficient to provide the required NPSH and vortex prevention for the CS pump or LPCI pump. Therefore, a verification that either the suppression pool water level is -3 ft or that the required low pressure ECCS injection/spray subsystems are aligned to take suction from the CST(s) and the CST(s) contain 58,000 gallons of water, equivalent to 4 ft in both CSTs when they are cross-tied (normal configuration) and 7 ft in one CST when they are not cross-tied, ensures that the required low pressure ECCS injection/spray subsystems can supply at least 50,000 available gallons of makeup water to the RPV.

The low pressure ECCS injection/spray suction is uncovered at the 2366 gallon level. However, as noted, only one required low pressure ECCS injection/spray subsystem may take credit for the CST option during OPDRVs. During OPDRVs, the volume in the CST(s) may not provide adequate makeup if the RPV were completely drained.

Therefore, only one low pressure ECCS injection/spray subsystem is allowed to use the CST(s). This ensures the other required ECCS subsystem has adequate makeup volume.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency of these SRs was developed considering operating experience related to suppression pool water level and CST water level variations and instrument drift during the applicable MODES.

Furthermore, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal suppression pool or CST water level condition.

SR 3.5.2.2, SR 3.5.2.4, and SR 3.5.2.5 The Bases provided for SR 3.5.1.1, SR 3.5.1.7, and SR 3.5.1.10 are applicable to SR 3.5.2.2, SR 3.5.2.4, and SR 3.5.2.5, respectively.

Monticello B 3.5.2-4 Revision No. __

ECCS - Shutdown B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.3 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The 31 day Frequency is appropriate because the valves are operated under procedural control and the probability of their being mispositioned during this time period is low.

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

REFERENCES 1. USAR, Section 14.7.2.3.6.

2. Amendment No. XXX, Monticello Nuclear Generating Plant -

Issuance of Amendment to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Month Day, Year.

(ADAMS Accession No. MLxxxxxxxx)

Monticello B 3.5.2 Last Revision No. __

RCIC System B 3.5.3 BASES BACKGROUND (continued) height of the feedwater line connection for RCIC is such that the water in the feedwater lines keeps the remaining portion of the RCIC discharge line full of water. Therefore, RCIC does not require a "keep fill" system.

APPLICABLE The function of the RCIC System is to respond to transient events by SAFETY providing makeup coolant to the reactor. The RCIC System is not an ANALYSES Engineered Safety Feature System and no credit is taken in the safety analyses for RCIC System operation. The RCIC System satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity for maintaining RPV inventory during an isolation event. Management of gas voids is important to RCIC System OPERABILITY.

APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure 150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the low pressure ECCS injection/spray subsystems can provide sufficient flow to the RPV.

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC System. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC System and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is immediately verified to be OPERABLE, the RCIC System must be restored to OPERABLE status within 14 days. In this condition, loss of the RCIC System will not affect the overall plant capability to provide Monticello B 3.5.3-2 Revision No. __

RCIC System B 3.5.3 BASES ACTIONS (continued) makeup inventory at high reactor pressure since the HPCI System is the only high pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of HPCI is therefore verified immediately when the RCIC System is inoperable. This may be performed as an administrative check, by examining logs or other information, to determine if HPCI is out of service for maintenance or other reasons. It does not mean it is necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the HPCI System. If the OPERABILITY of the HPCI System cannot be immediately verified, however, Condition B must be entered. For transients and certain abnormal events with no LOCA, RCIC (as opposed to HPCI) is the preferred source of makeup coolant because of its relatively small capacity, which allows easier control of the RPV water level. Therefore, a limited time is allowed to restore the inoperable RCIC to OPERABLE status.

The 14 day Completion Time is based on a reliability study (Ref. 2) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (AOTs). Because of similar functions of HPCI and RCIC, the AOTs (i.e.,

Completion Times) determined for HPCI are also applied to RCIC.

B.1 and B.2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to 150 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.5.3.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RCIC flow path provides assurance that the proper flow path will exist for RCIC operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, Monticello B 3.5.3-3 Revision No. __

RCIC System B 3.5.3 BASES SURVEILLANCE REQUIREMENTS (continued) sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. For the RCIC System, this SR also includes the steam flow path for the turbine and the flow controller position.

The 31 day Frequency of this SR was derived from the Inservice Testing Program requirements for performing valve testing at least once every 92 days. The Frequency of 31 days is further justified because the valves are operated under procedural control and because improper valve position would affect only the RCIC System. This Frequency has been shown to be acceptable through operating experience.

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

SR 3.5.3.2 and SR 3.5.3.3 The RCIC pump flow rates ensure that the system can maintain reactor coolant inventory during pressurized conditions with the RPV isolated.

The flow tests for the RCIC System are performed at two different pressure ranges such that system capability to provide rated flow against a system head corresponding to reactor pressure is tested both at the higher and lower operating ranges of the system. The required system head should overcome the RPV pressure and associated discharge line losses. Adequate reactor steam pressure must be available to perform these tests. Additionally, adequate steam flow must be passing through the turbine bypass valves to continue to control reactor pressure when the RCIC System diverts steam flow. Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these SRs.

Reactor steam pressure must be 950 psig to perform SR 3.5.3.2 and 150 psig to perform SR 3.5.3.3. Adequate steam flow is represented by at least one turbine bypass valve 80% open. Reactor startup is allowed prior to performing the low pressure Surveillance because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance is short. The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure Surveillance has been satisfactorily completed and there is no indication Monticello B 3.5.3-4 Revision No. __

RCIC System B 3.5.3 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SR 3.5.3.5 The RCIC System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RCIC System and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RCIC System locations susceptible to gas accumulation is based on a self-assessment of the piping configuration to identify where gases may accumulate and remain even after the system is filled and vented, and to identify vulnerable potential degassing flow paths. The review is supplemented by verification that installed high-point vents are actually at the system high points, including field verification to ensure pipe shapes and construction tolerances have not inadvertently created additional high points. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RCIC System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met. If it is determined by subsequent evaluation that the RCIC Systems are not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RCIC System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the Monticello B 3.5.3-6 Revision No. __

RCIC System B 3.5.3 BASES SURVEILLANCE REQUIREMENTS (continued) maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day Frequency is based on the gradual nature of void buildup in the RCIC piping, the procedural controls governing system operation, and operating experience.

REFERENCES 1. USAR, Section 10.2.5.

2. Memorandum from R.L. Baer (NRC) to V. Stello, Jr. (NRC),

"Recommended Interim Revisions to LCOs for ECCS Components,"

December 1, 1975.

3. Amendment No. XXX, Monticello Nuclear Generating Plant -

Issuance of Amendment to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Month Day, Year.

(ADAMS Accession No. MLxxxxxxxx)

Monticello B 3.5.3 Last Revision No. __

RHR Drywell Spray B 3.6.1.8 BASES LCO (continued) single active failure. An RHR drywell spray subsystem is OPERABLE when one of the pumps, the heat exchanger, and associated piping (including drywell spray header and nozzles), valves, instrumentation, and controls are OPERABLE. Management of gas voids is important to RHR Drywell Spray System OPERABILITY.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause pressurization of primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining RHR drywell spray subsystems OPERABLE is not required in MODE 4 or 5.

ACTIONS A.1 With one RHR drywell spray subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this condition, the remaining OPERABLE RHR drywell spray subsystem is adequate to perform the primary containment bypass leakage mitigation function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced drywell spray mitigation capability. The 7 day Completion Time was chosen in light of the redundant RHR drywell spray capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

B.1 With both RHR drywell spray subsystems inoperable, at least one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition, there is a substantial loss of the drywell spray mitigation function.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to remove heat from primary containment are available.

C.1 and C.2 If the inoperable RHR drywell spray subsystem cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Monticello B 3.6.1.8-2 Revision No. __

RHR Drywell Spray B 3.6.1.8 BASES SURVEILLANCE SR 3.6.1.8.1 REQUIREMENTS Verifying the correct alignment for manual and power operated valves in the RHR drywell spray mode flow path provides assurance that the proper flow paths will exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR drywell spray mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the subsystem is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.

SR 3.6.1.8.2 This Surveillance is performed every 10 years to verify that the drywell spray nozzles are not obstructed and that spray flow will be provided when required. The 10 year Frequency is adequate to detect degradation in performance due to the passive nozzle design and has been shown to be acceptable through operating experience.

SR 3.6.1.8.3 RHR Drywell Spray System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR drywell spray subsystems and may also prevent water hammer and pump cavitation.

Selection of RHR Drywell Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped Monticello B 3.6.1.8-3 Revision No. __

RHR Drywell Spray B 3.6.1.8 BASES SURVEILLANCE REQUIREMENTS (continued) or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Drywell Spray System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Drywell Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Drywell Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Drywell Spray System piping and the procedural controls governing system operation.

REFERENCES 1. USAR, Section 5.2.3.9.

2. Calculation 11-173, MNGP EPU Task Report T0400, Revision 3, Containment System Response Monticello B 3.6.1.8-4 Revision No. __

RHR Drywell Spray B 3.6.1.8 BASES REFERENCES (continued)

3. Amendment No. 176, Monticello Nuclear Generating Plant -

Issuance of Amendment No. 176 to Renewed Facility Operating License Regarding Extended Power Uprate, (ADAMS Accession No. ML13316C459)

4. Amendment No. XXX, Monticello Nuclear Generating Plant -

Issuance of Amendment to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Month Day, Year.

(ADAMS Accession No. MLxxxxxxxx)

Monticello B 3.6.1.8 Last Revision No. __

RHR Suppression Pool Cooling B 3.6.2.3 BASES LCO During a DBA, a minimum of one RHR suppression pool cooling subsystem is required to maintain the primary containment peak pressure and temperature below design limits (Ref. 1). To ensure that these requirements are met, two RHR suppression pool cooling subsystems must be OPERABLE with power from two safety related independent power supplies. Therefore, in the event of an accident, at least one subsystem is OPERABLE assuming the worst case single active failure.

An RHR suppression pool cooling subsystem is OPERABLE when one of the pumps, the heat exchanger, and associated piping, valves, instrumentation, and controls are OPERABLE. Management of gas voids is important to RHR Suppression Pool Cooling System OPERABILITY.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment and cause a heatup and pressurization of primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, the RHR Suppression Pool Cooling System is not required to be OPERABLE in MODE 4 or 5.

ACTIONS A.1 With one RHR suppression pool cooling subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this condition, the remaining OPERABLE RHR suppression pool cooling subsystem is adequate to perform the primary containment cooling function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability. The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

B.1 With two RHR suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition, there is a substantial loss of the primary containment pressure and temperature mitigation function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and the potential avoidance of a plant shutdown transient that could result in the need for the RHR suppression pool cooling subsystems to operate.

Monticello B 3.6.2.3-2 Revision No. __

RHR Suppression Pool Cooling B 3.6.2.3 BASES SURVEILLANCE REQUIREMENTS (continued)

The Frequency of this SR is in accordance with the Inservice Testing Program.

SR 3.6.2.3.3 RHR Suppression Pool Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR suppression pool cooling subsystems and may also prevent water hammer and pump cavitation.

Selection of RHR Suppression Pool Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Suppression Pool Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Suppression Pool Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Suppression Pool Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote Monticello B 3.6.2.3-4 Revision No. __

RHR Suppression Pool Cooling B 3.6.2.3 BASES SURVEILLANCE REQUIREMENTS (continued) monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Suppression Pool Cooling System piping and the procedural controls governing system operation.

REFERENCES 1. USAR, Section 5.2.3.

2. ASME Operation and Maintenance (OM) Code.

3. Amendment No. XXX, Monticello Nuclear Generating Plant -

Issuance of Amendment to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Month Day, Year.

(ADAMS Accession No. MLxxxxxxxx)

Monticello B 3.6.2.3 Last Revision No. __

RHR - High Water Level B 3.9.7 B 3.9 REFUELING OPERATIONS B 3.9.7 Residual Heat Removal (RHR) - High Water Level BASES BACKGROUND The purpose of the RHR System in MODE 5 is to remove decay heat and sensible heat from the reactor coolant, as described by USAR, Section 10.2.4.2 (Ref. 1). Each of the two shutdown cooling loops of the RHR System can provide the required decay heat removal. Each loop consists of two motor driven pumps, a heat exchanger, and associated piping and valves. Both loops have a common suction from the same recirculation loop. Each pump discharges the reactor coolant, after it has been cooled by circulation through the respective heat exchangers, to the reactor via either recirculation loop. The RHR heat exchangers transfer heat to the RHR Service Water (SW) System. The RHR shutdown cooling mode is manually controlled.

In addition to the RHR subsystems, the volume of water above the reactor pressure vessel (RPV) flange provides a heat sink for decay heat removal.

APPLICABLE With the unit in MODE 5, the RHR Shutdown Cooling System is not SAFETY required to mitigate any events or accidents evaluated in the safety ANALYSES analyses. The RHR Shutdown Cooling System is required for removing decay heat to maintain the temperature of the reactor coolant.

The RHR Shutdown Cooling System satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO Only one RHR shutdown cooling subsystem is required to be OPERABLE and in operation in MODE 5 with irradiated fuel in the RPV and the water level 21 ft 11 inches above the RPV flange. Only one subsystem is required to be OPERABLE because the volume of water above the RPV flange provides backup decay heat removal capability.

An OPERABLE RHR shutdown cooling subsystem consists of an RHR pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path. In addition, the necessary portions of the RHRSW System must be capable of providing cooling water to the RHR heat exchanger. Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

Additionally, the RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. Operation (either continuous or intermittent) of one subsystem can maintain and reduce the reactor coolant temperature as required. However, to ensure adequate Monticello B 3.9.7-1 Revision No. __

RHR - High Water Level B 3.9.7 BASES SURVEILLANCE SR 3.9.7.1 REQUIREMENTS This Surveillance demonstrates that the RHR shutdown cooling subsystem is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR shutdown cooling subsystem in the control room.

SR 3.9.7.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RHR shutdown cooling subsystem(s) and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

Monticello B 3.9.7-4 Revision No. __

RHR - High Water Level B 3.9.7 BASES SURVEILLANCE REQUIREMENTS (continued)

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Shutdown Cooling System piping and the procedural controls governing system operation.

REFERENCES 1. USAR, Section 10.2.4.2.

2. Amendment No. XXX, Monticello Nuclear Generating Plant -

Issuance of Amendment to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Month Day, Year.

(ADAMS Accession No. MLxxxxxxxx)

Monticello B 3.9.7 Last Revision No. __

RHR - Low Water Level B 3.9.8 B 3.9 REFUELING OPERATIONS B 3.9.8 Residual Heat Removal (RHR) - Low Water Level BASES BACKGROUND The purpose of the RHR System in MODE 5 is to remove decay heat and sensible heat from the reactor coolant, as described by USAR, Section 10.2.4.2 (Ref. 1). Each of the two shutdown cooling loops of the RHR System can provide the required decay heat removal. Each loop consists of two motor driven pumps, a heat exchanger, and associated piping and valves. Both loops have a common suction from the same recirculation loop. Each pump discharges the reactor coolant, after it has been cooled by circulation through the respective heat exchangers, to the reactor via either recirculation loop. The RHR heat exchangers transfer heat to the RHR Service Water (SW) System. The RHR shutdown cooling mode is manually controlled.

APPLICABLE With the unit in MODE 5, the RHR Shutdown Cooling System is not SAFETY required to mitigate any events or accidents evaluated in the safety ANALYSES analyses. The RHR Shutdown Cooling System is required for removing decay heat to maintain the temperature of the reactor coolant.

The RHR Shutdown Cooling System satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO In MODE 5 with irradiated fuel in the reactor pressure vessel (RPV) and the water level < 21 ft 11 inches above the RPV flange both RHR shutdown cooling subsystems must be OPERABLE and one RHR shutdown cooling subsystem must be in operation.

An OPERABLE RHR shutdown cooling subsystem consists of an RHR pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path. To meet the LCO, both pumps in one loop or one pump in each of the two loops must be OPERABLE. In addition, the necessary portions of the RHRSW System must be capable of providing cooling water to the RHR heat exchanger. Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

Additionally, each RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. Operation (either continuous or intermittent) of one subsystem can maintain and reduce the reactor coolant temperature as required. However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. A Note is provided to allow a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months exception for the operating subsystem to be removed from operation every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Monticello B 3.9.8-1 Revision No. __

RHR - Low Water Level B 3.9.8 BASES SURVEILLANCE SR 3.9.8.1 REQUIREMENTS This Surveillance demonstrates that one RHR shutdown cooling subsystem is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR shutdown cooling subsystems in the control room.

SR 3.9.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

Monticello B 3.9.8-4 Revision No. __

RHR - Low Water Level B 3.9.8 BASES SURVEILLANCE REQUIREMENTS (continued)

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Shutdown Cooling System piping and the procedural controls governing system operation.

REFERENCES 1. USAR, Section 10.2.4.2.

2. Amendment No. XXX, Monticello Nuclear Generating Plant -

Issuance of Amendment to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Month Day, Year.

(ADAMS Accession No. MLxxxxxxxx)

Monticello B 3.9.8 Last Revision No. __

v t e Letter Sequence Request
TAC:MD7847, (Approved, Closed)
Initiation Request Acceptance... Supplement Administration Questions 30 July 2009 1 November 2010 Answers 20 May 2011 Results Approval Other: L-MT-08-063, Nine-Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems., ML111710637
MONTHYEAR2009-07-06 [Table View]

L-MT-15-048, License Amendment Request: Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process

Text

References:

Enclosures:

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

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L-MT-15-048, License Amendment Request: Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process

Text

References:

Enclosures:

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

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