ML050180738

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Second Request for Additional Information Related to Technical Specifications Change Request to Implement a 24-hour Fuel Cycle
ML050180738
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 01/31/2005
From: Padovan L
NRC/NRR/DLPM/LPD3
To: Thomas J. Palmisano
Nuclear Management Co
Padovan L, NRR/DLPM, 415-1423
References
TAC MC3692
Download: ML050180738 (4)


Text

January 31, 2005 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 SECOND REQUEST FOR ADDITIONAL INFORMATION RELATED TO TECHNICAL SPECIFICATIONS CHANGE REQUEST TO IMPLEMENT A 24-MONTH FUEL CYCLE (TAC NO. MC3692)

Dear Mr. Palmisano:

The Nuclear Management Companys, LLCs, letter of June 30, as supplemented November 5, 2004, submitted a license amendment request implement a 24-month fuel cycle at Monticello Nuclear Generating Plant. The Nuclear Regulatory Commission 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 January 28, 2005, 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/

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

ML050180738 NRR-088 OFFICE PDIII-1/PM PDIII-1/LA PDIII-1/(A)SC NAME MPadovan:mp THarris MKotzalas DATE 01/28/05 01/28/05 01/31/05

ENCLOSURE Monticello Nuclear Generating Plant License Amendment Request to Support 24-Month Operating Cycles Second Request for Additional Information Docket No. 50-263

1. Enclosure 1 to Nuclear Management Companys (NMCs) November 5, 2004, submittal contains sample calculation CA-97-241 where the allowable value is derived from the analytical limit (AL). This is similar to Instrumentation, Systems, and Automation (ISA)

Society ANSI/ISA-S67.04-2000, Setpoints for Nuclear Safety-Related Instrumentation, Method 2, but the uncertainty components are not defined in the calculation. Please confirm that the setpoint methodology used at Monticello is equivalent to ISA Method 2.

2. In sample calculation CA-97-241, Section 6.5 indicates that many analyses assume a trip value of 200 EF, and then NMC uses an AL of 212 EF. If the analyses simply indicate that the value will only reach 200 EF, but corrective action is based upon something else, then this is stated unclearly. If the analyses presume corrective action at 200 EF, then the AL must be 200 EF. Is NMC claiming that the temperature will always rise to 212 EF in a "negligible" amount of time whenever it hits 200 EF, or does this not matter because the device in question is only a "backup" device? Please more explicitly justify these points. In particular, it seems that the analyses either presume action based upon this switch or they do not. It is not clear in this context what it means to say that this is a "backup" device or function.
3. NMCs June 30, 2004, submittal proposes allowing a significant increase in the amount of drift for each component, and extends the time available for random failures to occur. Since the amount of setpoint drift could increase, it would be appropriate to make most setpoints and AVs more conservative. NMC has proposed changing very few setpoints and AVs. Is NMC maintaining that experience shows that drift is far less than assumed in the existing technical specifications (TS), and that the existing TS are overconservative and bound the increased drift? If so, then demonstrate that existing data show that present TS surveillance requirements are usually met. Explain how NMC has extrapolated the 18-month data to justify a 24-month interval considering both random failures and calibration drift. Please provide additional documentation to demonstrate the results of your evaluation that the projected 30-month drift value for these instruments does not exceed the drift allowance provided in the setpoint calculation for these instruments. Please show that the change in channel availability (in regard to equipment failures) is acceptable.
4. Pages 102 and 105 in Enclosure 6 of NMCs June 30, 2004, submittal contain marked-up changes from Low reactor water level to Low-Low reactor water level. Justify these changes and also provide references to related Updated Safety Analysis Report sections.
5. In the first paragraph on page 9 of 17 in Enclosure 1 of NMCs June 30, 2004, submittal, NMC states NTSPs [nominal trip setpoints] were changed where it was not possible to accommodate the projected drift by adjusting plant settings.... What plant settings other than setpoint change is NMC referring to?

Monticello Nuclear Generating Plant cc:

Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 U.S. Nuclear Regulatory Commission Resident Inspector's Office 2807 W. County Road 75 Monticello, MN 55362 Manager, Regulatory Affairs Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637 Robert Nelson, President Minnesota Environmental Control Citizens Association (MECCA) 1051 South McKnight Road St. Paul, MN 55119 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 Commissioner Minnesota Department of Commerce 85 7th Place East, Suite 500 St. Paul, MN 55101-2198 Manager - Environmental Protection Division Minnesota Attorney Generals Office 445 Minnesota St., Suite 900 St. Paul, MN 55101-2127 John Paul Cowan Executive Vice President & Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Nuclear Asset Manager Xcel Energy, Inc.

414 Nicollet Mall, R.S. 8 Minneapolis, MN 55401