ML041340003

RAI, License Amendment Request for Technical Specification Tables 3.2.1 and 3.2.4

ML041340003
Person / Time
Site:	Monticello
Issue date:	05/13/2004
From:	Padovan L NRC/NRR/DLPM/LPD3
To:	Thomas J. Palmisano Nuclear Management Co
Padovan L, NRR/DLPM, 415-1423
References
TAC MC1804
Download: ML041340003 (5)

Text

May 13, 2004 Mr. Thomas J. Palmisano Site Vice President Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR TECHNICAL SPECIFICATION TABLES 3.2.1 AND 3.2.4 (TAC NO. MC1804)

Dear Mr. Palmisano:

The Nuclear Management Company, LLC, letter of December 23, 2003, requested Nuclear Regulatory Commission (NRC) approval of an amendment to the Monticello Nuclear Generating Plant technical specifications to eliminate the reactor head cooling containment isolation function and make other changes. The NRC staff is reviewing your request and finds that additional information is needed as shown in the enclosed request for additional information (RAI).

I discussed the enclosed RAI with Mr. John Fields of your organization on April 30, 2004, and he agreed to respond within 30 days of receipt of the RAI. Please contact me at (301) 415-1423 if you have questions.

Sincerely,

/RA by D. Beaulieu for/

L. Mark Padovan, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-263

Enclosure:

Request for Additional Information cc w/encl: See next page

ML041340003 Request for Additional Information License Amendment Request for Technical Specification Tables 3.2.1 and 3.2.4 Monticello Nuclear Generating Station Docket No. 50-263 The Nuclear Regulatory Commission (NRC) staff is reviewing the Nuclear Management Companys (NMCs) license amendment request to change Technical Specification (TS) Tables 3.2.1 and 3.2.4 for the Monticello Nuclear Generating Station and have determined that the following additional information is needed in order to complete the review:

1. The regulation at 10 CFR 50.36(c)(2)(ii) specifies that a TS Limiting Condition for Operation (LCO) must be established for each item meeting one or more of four criteria. Generic Letter 95-10, Relocation of Selected Technical Specifications Requirements Related to Instrumentation, uses the same criteria for relocating any item from the TSs. Justify removing the reactor head cooling containment isolation function from the TSs based on the four criteria identified in 10 CFR 50.36(c)(2)(ii).

2. Has the NRC staff reviewed NMCs plant modification to the reactor head cooling system in response to General Electrics Service Information Letter 643, Potential for Radiolytic Gas Detonation? If so, identify where the NRC staff reviewed and accepted the modification.

If not, provide NMCs 10 CFR 50.59 evaluation for the modification.

3. Proposed TS Table 3.2.4 shows the total number of instrument channels per trip system is two for Function 3 (reactor building plenum radiation monitors) and Function 4 (refueling floor radiation monitors). However, each radiation monitor inputs to both of the trip systems.

Therefore, failure of one channel will result in the failure of one channel in each trip system.

Based on this, justify how GEs topical report NEDC-31677-P-A, Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation, July 1990," applies to the system since NMC uses the report as the basis for changing the LCO requirements.

4. Proposed TS Table 3.2.4 specifies a 6-hour allowed outage time (AOT) for surveillance testing without entering the TS actions, and a 24-hour repair time before placing an inoperable channel in the trip condition for the Function 3 and Function 4 radiation monitors.

These allowances are based on the reliability analysis of NEDC-31677-P-A. What NRC staff safety evaluation report approved applying this topical report to Table 3.2.4, Functions 3 and 4?

5. Current Table 3.2.4, Note 5(a), as applied to Function 1 (low-low reactor water level) and Function 2 (high drywell pressure), states, With one required instrument channel inoperable per trip function (emphasis added), place the inoperable channel or trip system in the tripped condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Proposed Table 3.4.2, Note 2(a)1) would revise Note 5(a) as follows: With one Instrument Channel per Trip System (emphasis added) inoperable: 1) For Functions 1 or 2, place the inoperable Channel or Trip System in the tripped condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The current TS action applies only to one channel ENCLOSURE

inoperable per function, whereas the proposed TS applies to the condition of one channel inoperable per Trip System. The difference between the current and proposed action requirements is not evaluated. Provide additional justification for this proposed change.

6. Current Table 3.2.4, Note 4, applies to Functions 3 and 4. Note 4 says One of the two monitors may be bypassed for maintenance and/or testing. Proposed Table 3.2.4 would delete Note 4. NMC justified this as being acceptable because the current TS reference to a single-train instrument channel is used in conjunction with two trip systems. However, the NRC staff notes that the 6-hour AOT for surveillance testing without placing a channel in the tripped condition (proposed Note 1) essentially replaces the current note with an approved topical report allowance. Provide a safety-basis justification for the proposed change.

Monticello Nuclear Generating Plant cc:

Jonathan Rogoff, Esquire Commissioner Vice President, Counsel & Secretary Minnesota Department of Commerce Nuclear Management Company, LLC 121 Seventh Place East 700 First Street Suite 200 Hudson, WI 54016 St. Paul, MN 55101-2145 U.S. Nuclear Regulatory Commission Manager - Environmental Protection Division Resident Inspectors Office Minnesota Attorney Generals Office 2807 W. County Road 75 445 Minnesota St., Suite 900 Monticello, MN 55362 St. Paul, MN 55101-2127 Manager, Regulatory Affairs John Paul Cowan Monticello Nuclear Generating Plant Executive Vice President & Chief Nuclear Nuclear Management Company, LLC Officer 2807 West County Road 75 Nuclear Management Company, LLC Monticello, MN 55362-9637 700 First Street Hudson, WI 54016 Robert Nelson, President Minnesota Environmental Control Nuclear Asset Manager Citizens Association (MECCA) Xcel Energy, Inc.

1051 South McKnight Road 414 Nicollet Mall, R.S. 8 St. Paul, MN 55119 Minneapolis, MN 55401 Commissioner Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, MN 55155-4194 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Commissioner Minnesota Department of Health 717 Delaware Street, S. E.

Minneapolis, MN 55440 Douglas M. Gruber, Auditor/Treasurer Wright County Government Center 10 NW Second Street Buffalo, MN 55313 October 2003