ML023020427

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Draft RAI Proposed TS Changes on Drywell Leakage & Sump Monitoring System
ML023020427
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 11/05/2002
From: Hood D
NRC/NRR/DLPM/LPD3
To:
Office of Nuclear Reactor Regulation
References
TAC MB6493
Download: ML023020427 (5)


Text

November 5, 2002 MEMORANDUM TO: File FROM:

Darl S. Hood, Senior Project Manager, Section 1

/RA/

Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulations

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT - DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED TECHNICAL SPECIFICATION CHANGES ON DRYWELL LEAKAGE AND SUMP MONITORING SYSTEM (TAC NO. MB6493)

On October 25, 2002, I sent the attached e-mail and draft request for additional information (RAI) to Mr. D. Neve, Nuclear Management Company, LLC (the licensee), regarding the Monticello Nuclear Generating Plant. The attached RAI relates to the licensees application dated October 8, 2002, for a license amendment to change the Technical Specifications on drywell leakage and sump monitoring requirements.

On October 28, 2002, Mr. J. Tatum of the Plant Systems Branch and I called Mr. Neve, et al., to discuss the draft RAI. Following a brief summary of the draft RAI, Mr. Neve stated that the RAI was understood and that a written response would be submitted to the NRC on or about November 1, 2002.

Attachment:

E-mail w/Draft Request for Additional Information

ML023020427 OFFICE PDIII-1/PM PDIII-1/LA PDIII-1/SC NAME DHood RBouling LRaghavan DATE 11/05/02 10/31/02 11/05/02

ATTACHMENT From:

Darl Hood To:

internet:douglas.neve@nmcco.com Date:

10/25/02 10:47AM

Subject:

Draft Information Request on Monticello Drywell Leak Monitoring Application Doug Attached is a draft request for addtional information regarding your 10/8/02 application for amendment to change the Monticello TS for drywell leakage and sump monitoring. Call me at 301-415-3049 so we can arrange to discuss them.

CC:

James Tatum; Michelle Hart; Stephen Burton; Theodore Tjader

Mail Envelope Properties (3DB95987.897 : 17 : 21158)

Subject:

Draft Information Request on Monticello Drywell Leak Monitoring Application Creation Date:

10/25/02 10:47AM From:

Darl Hood Created By:

DSH@nrc.gov Recipients Action Date & Time douglas Transferred 10/25/02 10:47AM neve (internet:douglas.neve@nmcco.com) nrc.gov ch_po.CH_DO Delivered 10/25/02 10:48AM SXB3 CC (Stephen Burton)

Opened 10/25/02 10:50AM nrc.gov owf2_po.OWFN_DO Delivered 10/25/02 10:48AM JET1 CC (James Tatum)

Opened 10/25/02 11:25AM MLH3 CC (Michelle Hart)

Opened 10/25/02 10:48AM nrc.gov owf4_po.OWFN_DO Delivered 10/25/02 10:47AM TRT CC (Theodore Tjader)

Opened 10/25/02 10:48AM Post Office Delivered Route douglas internet:nmcco.com ch_po.CH_DO 10/25/02 10:48AM nrc.gov owf2_po.OWFN_DO 10/25/02 10:48AM nrc.gov owf4_po.OWFN_DO 10/25/02 10:47AM nrc.gov Files Size Date & Time RAI_Draft_MB6493.wpd 4951 10/25/02 08:55AM MESSAGE 717 10/25/02 10:47AM Options Auto Delete:

No Expiration Date:

None Notify Recipients:

Yes Priority:

Standard Reply Requested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard To Be Delivered:

Immediate Status Tracking:

Delivered & Opened

DRAFT REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONS The NRC staff is reviewing the licensees letter of October 8, 2002, requesting a license amendment to change the Technical Specifications for the Monticello Nuclear Generating Plant regarding drywell leakage and sump monitoring system requirements. The NRC staff finds that additional information is needed. Comparing the surveillance interval and criteria for the increase in unidentified leakage as discussed in the Standard Technical Specifications (STS, NUREG-1433, Revision 2.1) with the licensees proposed changes, the NRC staff makes the following observations and requests:

1.

Monticellos SR 4.D.1 specifies a 12-hour surveillance interval for monitoring increases in unidentified leakage rate, while the STS specifies a surveillance interval of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

However, regardless of the surveillance interval, the licensee should be trending the results so that it will have some idea when it is about to exceed the limit and take action as required, even if this action may be required before the next 12-hour surveillance interval. The NRC staff requests that the licensee confirm that this is consistent with its understanding and intended operating procedures.

2.

The licensees discussion for the proposed change to TS 3.D.5 does not adequately address the situations when either the drywell floor drain sump (DFDS) or drywell equipment drain sump (DEDS) monitoring system is inoperable, with its respective sump not yet at the point of overflowing and registering in the sump with the operable level monitoring system. During this period, the total leakage rate and/or the unidentified leakage rate are/is indeterminate. The NRC staff requests that the licensee address these situations.

3.

The licensees proposed changes to required action completion times represent a mixture of custom features from the current Monticello TS and completion times from the STS. This mixture is not consistently applied to all TSs of relevance to reactor coolant system operational leakage. The proposed shutdown actions of TS 3.D.2, 3.D.3, 3.D.4, and 3.D.5 (to "[b]e in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />") are based upon the STS. However, no similar change is proposed if the drywell particulate radioactivity monitoring system should be inoperable (i.e., TS 3.D.6.b maintains the Monticello language "Otherwise, initiate an orderly shutdown of the reactor and reduce water temperature to less than 212 F within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). The licensee should confirm that this inconsistency is intentional. The licensee should also explain/justify the proposed relaxation in the shutdown requirement.