ML051960242

Improved Technical Specifications, Volume 3, Revision 0, ITS Chapter 1.0, Use & Application

ML051960242
Person / Time
Site:	Monticello
Issue date:	06/29/2005
From:	Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
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Download: ML051960242 (71)

Text

IMPROVED TECHNICAL SPECIFICATIONS 0*.

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MONTICELLO NUCLEAR GENERATING PLANT VOLUME 3 ITS Chapter 1.0, Use and Application Nue E Commitned to Nuldear xcdll//

, Volume 3, Rev. 0, Page 1 of 70 ATTACHMENT I VOLUME 3 MONTICELLO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS CHAPTER 1.0 USE AND APPLICATION Revision -0, Volume 3, Rev. 0, Page 1 of 70

, Volume 3, Rev. 0, Page 2 of 70 LIST OF ATTACHMENTS

1.

ITS Chapter 1.0, Volume 3, Rev. 0, Page 2 of 70

, Volume 3, Rev. 0, Page 3 of 70 ATTACHMENT I ITS Chapter 1.0, Use and Application, Volume 3, Rev. 0, Page 3 of 70

, Volume 3, Rev. 0, Page 4 of 70 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs), Volume 3, Rev. 0, Page 4 of 70

c C

C 00 ITS Chapter 1.0 ITS These Technica pecifications are prepared In accord a with the requirements of 10 CFR 50.

and apply to the Monticello Nuclear Generating Pnt, Unit No. 1. The bases for these Secficatlons are included for Informatlo nd understandability wurnoses Su 0

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04/05/01 Amendment No. 29,63r 119 Page 1 of 14

, Volume 3, Rev. 0, Page 6 of 70 ITS Chapter 1.0 INSERT I

~-----------------

OTE---

The defined terms of this section appear in capitalized type and are applicable throughout these.

Technical Specifications and Bases.

O INSERT 2 of any fuel, sources, or reactivity control components, INSERT 3 The following exceptions are not considered to be CORE ALTERATIONS:

}

(3

a.

Movement of source range monitors, local power range monitors, intermediate ranged monitors, traversing incore probes, or special movable detectors (including go) undervessel replacement); and

b.

Control rod movement, provided there are no fuel assemblies in the associated core cell.

(

INSERT 4 Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

INSERT 5 OPERABILITY of all devices in the channel required for channel OPERABILITY INSERT 6 The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps.

Insert Page 1 Page 2 of 14, Volume 3, Rev. 0, Page 6 of 70

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C 00 ITS Chapter 1.0 ITS 1.1 0

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up ao Mo

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) M En] MMMhA(MCPR)-,

tathett cor calculated byfth e t

corar9 to ici operating power.

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~seal water* lubrIcatlon e aer auxilIary o viceto perform itsfunctlon(s) are also capable of (A.io) 1.0 2

9/28/89 Amendment No. 29. 70 Page 3 of 14

, Volume 3, Rev. 0, Page 8 of 70 ITS Chapter 1.0 INSERT 7 all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (G1 INSERT 8 Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

INSERT 9 A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

Insert Page 2 Page 4 of 14, Volume 3, Rev. 0, Page 8 of 70

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C 00 ITS Chapter 1.0 ITS C,

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MODES 1

_ and 2 0

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.4 0to to When a system, subsystem, train, component or device Is determined to be Inoperable soley because Its emergency power source Is Inoperable, or soley because is normal power source Is Inoperable, it may be considered operable for the purpose of satisfying the requirements of Its applicable Umiting Condition for Operation provided: (1) Its corresponding normal or See TS.8.

emergency power source Is operable; and (2) all of Its redundant system(s), subsystem(s), trains(s), component(s) and device(s)

J are Operable, or likewise satisfy the requirements of this paragraph.

IM. Oeralperatin means that em or component Is perf its s e e unctions.

m

.Ovr irIleafin bew Ieen heend oieoruellng outage and the end ot 34exr-suBsequent refuelng MODESe 1an I 0. Power Onertlon - Power Operation Is any oper fon with the mode switch In the 'Start-Up' r"Run positlo re or Fcritira'and above4 rated 1hWtfaI Power. Ig<

xahry Lconlainmentunte vP S mav Containment Inte ri means that the drwall and ressure suppression chamber are See ITS 3.6.1.1 )

/Ltlac ftefngor congiton~weselzsxsle

' Se-S3..

1. All manual containment isolation valves on lines connecting to the reactor coolant system or containment which are not i/

See ITS 3.6.13 In g accident conditions are closed.

See ITS 3.6.1.2

12.

At least one door in the airlock is close an seal.

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3.

Al atoatic containment Isolatlon valves are operable or are deactivated In the closed position or at least one valve In eac l in hain a

nIoeable valve Is closed

• -See ITS 3.6.1 3

14.

All blind tlannes and manwav are closed.

I

0.

Protective Instrumqftation Logic Definition/

1.

- An Instrument channel means n arrangement of a sensor and auxilla equlpment required to generate an transmit to a trip system, a single trip ignal related to the plant parameter ma itored by that Instrument channel././

2.

A trip system means an arrangeme of Instrument channel trip signals and uxiliary equipment required to initiate a troectilon action. A trip system may re ire one or more Instrument channel Irl signals related to one or more plant par meters to Initiate trip system actIon. I itietion of the protective function may re uire tripping of a single trip system (e.g., H CI system isolation, off-gas system Iso allan, reactor building Isolation and ste by gas treatment Initiation, and rod block), rthe coincident tripping of two trip syrems (e.g., initiation of scram, reactor IsatIon, and primary containment Isolaahn).

3.

Action - An action Initiated by the rotection system when a limit Is excee

d. A protective action can be at channel or system level.

See lTS 3.86.1.1 andl ITS 3.6.1.3 J

.8 3

1123184 Amendment No. 21 Page 5 of 14

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2 0

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II. AtlestoedoorIn each access openingIs closed.l

2.

The standby gas treatment system Is operable.

See ITS 3.6.4.3 CHANNEL CHECK All reactor building ventilation system automatic isolation valves are operable or are secured in the closed pos0oni See ITS 3.6.4.2on qualitativ a

by obbehavrof

.urlng operation. This determination

' Vshali include, wherpo~ssible, compartsonyother inaen Worsmeasuring the same s

Go dicatios or stalu derived from 1.0t Ideper Bawd chameh 4

9/16/98 Amendment No. 4a, 102 Page 6 of 14

ITS C

C 00 ITS Chapter 1.0 0) o Table 1.1-1 MODE 3 0

MODE 4 Ifng, also referred to as partial

, Intermittently with neither type

U CD) 0 to s_L 0

-40 1.1 norngsolable fauatijieactortoolant I

16 a) 0 0

(1) 0 CD 0

0) 0

1.

elinto the drywell, such as that from pump seals or valve packing[!e--jsthat is captured and conduced to a sumpor colleling tani r

2. La" Into tdydl atmosphere from sources that are both specifically tocatld and known elther not to Interfere with the operation of leakage detection systems or not to be ressureJoundary H AllE Into the drywell that Is notidentifded L

4

]Total L

- Sum of theJdentified andonidentified 1

A. throug.

(Ueleteq Al.

Purglng - Purgin is the controlled process of dlschargi air or gas from a confinement to ma pfaln temperature, pressure, humidity, coc conditIon, such a manner that replacement air gas Is required to purity the confinement

/

o AJ. Ventin enting Is the controlled process of di Iargng air or gas from a confinemen o maintain temperature, pressure, humiditm conenntratlnn or nther nparatinn co ditlan.

In suEh a manner that reolaca nt air or ias Is not provided or reouirad

_G 1.0 5

08/21/03 AmendmentNo. 14,15,120, 137 Page 7 of 14

ITS Chapter 1.0 ITS 0

f hl mthatl 1.1 E

-j Eiqui~aien113th concentration of 1131 (mIcrocurtes/gram) alione would produce the same thyroid dose as the quantity and Isotopic mixture of 1-131, 1-132.1-133, 1-134and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed In Table Ill of TID-1 4844. Calculatlon of Distance Factors for Q

=

Power and Test Reactor Site orMM Regulatory Guid e

1.1 09eyRpc 1L97.)e3 c

[-V those listed in

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[S AL. through (Dntpi r-X alE-d 5

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I21 CA n 1"ThelCor~iOrerali Llmi g nrtlis theunit specific document that provides corg o er in llimits 63 for the currentlqera reload cycle. These cyle~specific era m

lmits shall be determined for each reload cycle in accordance with Specificatlo

. Plant operation within these o era limits Is addressed In individual Spednfcatlons.

O R. Allowable VLuf -The Allowable Value Is the limi alue of the sensed process vaneat whIch the trip setpoint may be C,

1A found dyn g instnument surveillance.

0 N CACD 1

5a 07/24/01 1

Amno N

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rAdd proposed ITS Sections 4

1.3 - Completion Times 5a 07/24101 Amendment No. 4-5, 4 8, 120 Page 8 of 14

, Volume 3, Rev. 0, Page 13 of 70 ITS Chapter 1.0 INSERT 10 ACTIONS AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

LINEAR HEAT GENERATION RATE (LHGR)

LOGIC SYSTEM FUNCTIONAL TEST STAGGERED TEST BASIS THERMAL POWER TURBINE BYPASS SYSTEM

RESPONSE

TIME ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

The APLHGR shall be applicable to a specific planar height and is equal to the sum of the LHGRs for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods In the fuel bundle at the height.

The LHGR shall be the heat generation rate per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY.

The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

The TURBINE BYPASS SYSTEM RESPONSE TIME shall be that time interval from when the main turbine trip solenoid Is activated until 80% of the turbine bypass capacity is established.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

Insert Page 5a (1)

Page 9 of 14, Volume 3, Rev. 0, Page 13 of 70

, Volume 3, Rev. 0, Page 14 of 70 ITS Chapter 1.0 INSERT 11 Table 1.1-1 (page 1 of 1)

MODES AVERAGE REACTOR COOLANT REACTOR MODE TEMPERATURE MODE TITLE SWITCH POSITION '

(OF)

I 2

3 4

Power Operation Startup I

Hot Shutdowrj Cold Shutdown&T Run Refue t Standby Shutdown Shutdown NA

• N

> 12

< 212

/

NA

/

15 Refueling(b)

Shutdown or Refuel L

~

j (a)

(b)

All reactor vessel head closure bolts fully tensioned.

One or more reactor vessel head closure bolts less than fully tensioned.

Insert Page 5a (2)

Page 10 of 14, Volume 3, Rev. 0, Page 14 of 70

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ITS Chapter 1.0 0

ITS

'1..I'd 3.0 OMING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS 1*

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U' 0

3.1 REACTOR PROTECTION SYSTEM AiDplicabilitz.

Applies to the Instrumentation and associated devices which Initiate a reactor scram.

Oblectle:

To assure the operability of the reactor protection system.

~Specdfcatlon:

A. The setpolnts, minimum number of trip systems, and minimum number of instrument channels that must be operable for each position of the reactor mode switch 4.1 REACTOR PROTECTION SYSTEM l

Applies to the surveillance of the Instrumentation and associated devices which Initiate reactor scram.-

Objective:

To specify the type and frequency of surveillance to be applied to the Instrumentation that Initiates a scram to verify Rs operability.

A. Instrumentation systems shall be functionally tested and calibrated as Indicated In Tables 4.1.1 and 4.1.2.

7 respectively.

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3.3.1.1}

Tha RPS RESPONSE TiME shall be that time interval 3.1/4.1 26 5/4181 Amendment No. 5 Page 11 of 14

, Volume 3, Rev. 0, Page 16 of 70 ITS Chapter 1.0 O

INSERT 12 The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

Insert Page 26 Page 12 of 14, Volume 3, Rev. 0, Page 16 of 70

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3.3/4.3 76 1/9/81 Amendment No. 0 Page 13 of 14

, Volume 3, Rev. 0, Page 18 of 70 ITS Chapter 1.0 INSERT 13 or would be subcritical assuming that:

a.

The reactor is xenon free;

b.

The moderator temperature is 680F; and INSERT 14

c.

All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

Insert Page 76 Page 14 of 14, Volume 3, Rev. 0, Page 18 of 70

, Volume 3, Rev. 0, Page 19 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION ADMINISTRATIVE CHANGES A.1 In the conversion of the Monticello Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 The CTS Section 1.0 Definition introduction states "The succeeding frequently used terms are explicitly defined so that a uniform interpretation of the

. Specifications may be achieved." The Note to ITS Section 1.1 states "The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.". This changes the CTS by replacing the CTS Section 1.0 introduction of the definitions with a Note.

The ITS Section 1.0 Note serves the same purpose of the CTS Section 1.0 introduction. A major change to the ITS definitions is that the entire defined term is capitalized in ITS Section 1.1 instead of just the first letter in the CTS. In addition, whenever the term is used throughout the Technical Specifications and Bases, the term will be capitalized. This change is consistent with formatting requirements ini the ISTS. This change is designated as administrative because it does not represent a technical change to the Technical Specifications.

A.3 CTS 1.0.A provides the definition of Alteration of the Reactor Core. ITS Section 1.1 provides a definition of CORE ALTERATION that includes an additional phrase that states "Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position." This changes the CTS by adding this phrase to the definition.

The ITS definition of CORE ALTERATION states that the suspension of CORE ALTERATIONS shall not preclude completion of the movement of a component to a safe position. This change is acceptable because it clearly states current plant practice. The unit will not be maintained in an unsafe condition. This change is designated administrative because it represents a clarification to existing practice.

A.4 CTS Section 1.0 does not provide a definition of SHUTDOWN MARGIN (SDM).

However, CTS 3.3.A.1 does specify that the core loading shall be limited to that "which can be made subcritical in the most reactive condition during the operating cycle with the strongest operable control rod in its full-out position and all other operable rods fully inserted," and CTS 4.3.A.1 specifies "that the core can be made subcritical at any time in the subsequent fuel cycle with the strongest operable control rod fully withdrawn and all other operable rods fully inserted." ITS Section 1.1 includes a definition for SDM, which states "SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical assuming that: a. The reactor is xenon free; b. The moderator temperature is 680F; and c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn.

Monticello Page 1 of 14, Volume 3, Rev. 0, Page 19 of 70

, Volume 3, Rev. 0, Page 20 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM." This changes the CTS as follows:

An explicit allowance has been included in the ITS Section 1.1 SDM definition to compensate for control rods which are not capable of being fully inserted.

This change is necessary because ITS 3.1.3 allows the plant to operate with stuck control rods. This change is discussed in the Discussion of Changes for ITS 3.1.3.

This change adds specific details defining the most reactive shutdown condition to which the SDM is analyzed; i.e., the reactor is xenon free and the moderator temperature is 680F.

This change is acceptable since it is consistent with current practice, as indicated in UFSAR Section 3.3.3.3, which states that shutdown capability is evaluated assuming a cold and xenon-free core. The moderator temperature used in the shutdown capability calculations assumes a moderator temperature of 680F.

These changes are designated as administrative because they do not represent a technical change to the Technical Specifications.

A.5 CTS 1.0.D includes the definition of Immediate. It states "Immediate means that the required action will be initiated as soon as practicable considering the safe operation of the unit and the importance of the required action." The ITS includes Section 1.3, "Completion Times," which describes the meaning of the term "immediately" when used as a Completion Time. It states "When "immediately" is used, the Required Action should be pursued without delay and in a controlled manner." This changes the CTS by deleting the definition of "Immediate" but adds a description to the ITS of "immediately" when used as a Completion Time.

The purpose of the CTS definition of Immediate is to ensure that the required action will be initiated as soon as practicable considering the safe operation of the unit and the importance of the required action. In the ITS, the meaning of the word "immediately" is described in ITS Section 1.3. Although the wording is not identical, the intent is the same. These changes are designated as administrative because they do not represent a technical change to the Technical Specifications.

A.6 CTS 1.0.E defines Instrument Functional Test as "the injection of a simulated signal into the primary sensor to verify proper instrument channel response, alarm, and/or initiating action." ITS Section 1.1 defines CHANNEL FUNCTIONAL TEST as "the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY" and states that the test "may be performed by means of any series of sequential, overlapping, or total channel steps." This results in a number of changes to the CTS. The Monticello Page 2 of 14, Volume 3, Rev. 0, Page 20 of 70

, Volume 3, Rev. 0, Page 21 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION addition of use of an "actual" signal is discussed in DOC L.2 while the allowance to inject the signal "as close to the sensor as practicable" in lieu of "into" the sensor is discussed in DOC L.3.

The CTS definition states that the Instrument Functional Test shall verify "proper instrument channel response, alarm, and/or initiating action." The ITS definition states that the CHANNEL FUNCTIONAL TEST shall verify "OPERABILITY of all devices in the channel required for channel OPERABILITY."

This change is acceptable because the statements are equivalent in that both require that the channel be verified to be OPERABLE. The CTS and the ITS use different examples of what is Included in a channel, but this does not change the intent of the requirement. The ITS use of the phrase "all devices in the channel required for channel OPERABILITY" reflects the CTS understanding that the test includes only those portions of the channel needed to perform the safety function.

The ITS definition states "The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps." The CTS definition does not include this statement.

This change is acceptable because it states current Industry practice, and is not specifically prohibited by the CTS. This is consistent with the current implementation of the CHANNEL FUNCTIONAL TEST and does not result in a technical change to the Technical Specifications.

These changes are designated as administrative because they do not result in a technical change to the Technical Specifications.

A.7 CTS 1.0.F defines an Instrument Calibration as "the adjustment of an instrument signal output so that it corresponds, within acceptable range, accuracy, and response time to a known value(s) of the parameter which the instrument monitors. Calibration shall encompass the entire instrument including actuation, alarm or trip. Response time is not part of the routine instrument calibration but will be checked once per cycle." ITS 1.0 defines a CHANNEL CALIBRATION as "the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps." This results in a number of changes to the CTS.

Monticello Page 3 of 14, Volume 3, Rev. 0, Page 21 of 70

, Volume 3, Rev. 0, Page 22 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION The CTS definition states "Calibration shall encompass the entire instrument including actuation, alarm or trip." The ITS definition states.

"The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY."

This change is acceptable because the statements are equivalent in that both require that all needed portions of the channel be tested. The ITS definition reflects the CTS understanding that the CHANNEL CALIBRATION includes only those portions of the channel needed to perform the safety function.

The ITS definition states that the CHANNEL CALIBRATION shall encompass the "CHANNEL FUNCTIONAL TEST." The CTS definition does not include this statement.

This change is acceptable because the new ITS statement does not add any requirements. In both the CTS and the ITS, performance of a single test that fully meets the requirements of other tests can always be credited for satisfying the other tests.

The ITS definition adds the statement "Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel."

This allowance is not specifically stated in the CTS definition.

The purpose of a CHANNEL CALIBRATION is to adjust the channel output so that the channel responds within the necessary range and accuracy to known values of the parameters that the channel monitors.

This change is acceptable because RTDs and thermocouples are designed such that they have a fixed Input/output response, which cannot be adjusted or changed once installed. Calibration of a channel containing an RTD or thermocouple is performed by applying the RTD or thermocouple fixed input/output relationship to the remainder of the channel, and making the necessary adjustments to the adjustable devices in the remainder of the channel to obtain the necessary output range and accuracy. Therefore, unlike other sensors, an RTD or thermocouple is not actually calibrated. The ITS CHANNEL CALIBRATION allowance for channels containing RTDs and thermocouples is consistent with the CTS calibration practices of these channels. It is also consistent with the allowance provided in CTS Table 4.2.1 Note (12), which states that calibration of instrument channels with RTD or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

This information is included in the ITS to avoid confusion, but does not change the current CHANNEL CALIBRATION practices for these types of channels.

Monticello Page 4 of 14, Volume 3, Rev. 0, Page 22 of 70

, Volume 3, Rev. 0, Page 23 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION The ITS definition states "The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps." The CTS definition does not include this statement.

This change is acceptable because it states current Industry practice, and is not specifically prohibited by the CTS. This is consistent with the current implementation of the CHANNEL CALIBRATION and does not result in a technical change to the Technical Specifications.

The CTS definition states that the response time is not part of the routine instrument calibration but is checked once per cycle. The ITS definition does not include this statement.

This change is acceptable because the applicable Specifications in ITS Section 3.3 include Surveillances to cover the current response time testing requirements and the ITS includes the appropriate response time definitions.

These changes are designated as administrative because they do not result in a technical change to the Technical Specifications.

A.8 CTS Section 1.0 includes the following definitions:

1.0.G, Limiting Conditions for Operation (LCO);

1.0.1, Limiting Safety System Setting (LSSS);

1.0.M, Operating; 1.0.N, Operating Cycle; 1.0.P, Primary Containment Integrity; 1.0.Q, Protective Instrumentation Logic Definitions; 1.0.R, Rated Neutron Flux; 1.0.T, Reactor Coolant System Pressure or Reactor Vessel Pressure; 1.0.U, Refueling Operation and Refueling Outage; 1.0.V, Safety Limit; 1.0.W, Secondary Containment Integrity; 1.0.Z, Simulated Automatic Actuation; 1.0.AA, Transition Boiling; 1.0.AI, Purging; 1.0.AJ, Venting; and 1.0.AR, Allowable Value.

The ITS does not use this terminology and ITS Section 1.1 does not contain these definitions. This changes the CTS by deleting definitions that are not necessary.

These changes are acceptable because the terms are not used as defined terms in the ITS. Discussions of any technical changes related to the deletion of these terms are included in the applicable DOCs for the ITS Specifications in which the terms are dispositioned. These changes are designated as administrative because they eliminate defined terms that are no longer used.

Monticello Page 5 of 14, Volume 3, Rev. 0, Page 23 of 70

, Volume 3, Rev. 0, Page 24 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION A.9 The CTS 1.0.J definition of Minimum Critical Power Ratio (MCPR) states that "The minimum critical power ratio is the value of critical power ratio associated with the most limiting assembly in the reactor core." In addition, the CTS 1.0.J definition states that the "Critical power ratio (CPR) is the ratio of that power in a fuel assembly which is calculated by the GEXL correlation to cause some point in the assembly to experience boiling transition to the actual assembly operating power." ITS Section 1.1 definition of MCPR states that 'The MCPR shall be the smallest critical power ratio (CPR) that exists in the core for each class of fuel.

The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power." This changes the CTS definition of MCPR by specifying a separate MCPR is applicable to "each class of fuel" instead of a single MCPR is associated with the "most limiting assembly" and removes the explicit correlation that must be used to calculate CPR.

This change is acceptable since it will allow separate MCPRs to be monitored for each class of fuel, instead of a single, most limiting MCPR. In addition, the deletion of the specific correlation (GEXL) is acceptable since the ITS continues to require the documents that describe the appropriate analytical methods used to calculate MCPR to be listed in ITS 5.6.3, "CORE OPERATING LIMITS REPORT." These documents, which have been previously reviewed and approved by the NRC, indicate that the GEXL correlation is the approved correlation for calculating CPR (i.e., NEDE-2401 1-P-A, Section 1.2.5). In order to utilize a different correlation, the references listed in ITS 5.6.3 would have to be reviewed and approved by the NRC. This change is designated as administrative since there is no technical change because the MCPR is still monitored and the GEXL correlation must still be used to calculate CPR.

A.10 The CTS 1.O.L definition of Operable requires a system, subsystem, train, component, or device to be capable of performing its "specified function(s)," and requires all necessary support systems that are required for the system, subsystem, train, component, or device to perform Its "function(s)" also be capable of performing their related support function(s). The ITS Section 1.1 definition of OPERABLE-OPERABILITY requires the system, subsystem, division, component, or device to be capable of performing the "specified safety function(s)," and requires all necessary support systems that are required for the system, subsystem, division, component, or device to perform its "specified safety function(s)" to also be capable of performing their related support functions. This changes the CTS by altering the requirement of the system, subsystem, etc., to be able to perform "specified function(s)" or "function(s)" to a requirement to be able to perform "specified safety function(s)."

The purpose of the CTS definition of Operable is to ensure that the safety analysis assumptions regarding equipment and variables are valid. This change is acceptable because the intent of both the CTS and ITS definitions is to address the safety function(s) assumed in the accident analysis and not encompass other non-safety functions a system, subsystem, etc., may also perform. These non-safety functions are not assumed in the safety analysis and are not needed in order to protect the public health and safety. This change is consistent with the current interpretation and use of the terms OPERABLE and Monticello Page 6 of 14, Volume 3, Rev. 0, Page 24 of 70

, Volume 3, Rev. 0, Page 25 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION OPERABILITY. This change is designated as administrative as it does not change the current use and application of the Technical Specifications.

A.11 The CTS 1.O.L definition of Operable requires that all necessary normal "and" emergency electrical power sources be available for the system, subsystem, train, component, or device to be OPERABLE. The ITS Section 1.1 definition of OPERABLE-OPERABILITY requires all necessary normal "or" emergency electrical power be available for the system, subsystem, etc. This changes the CTS definition of Operable by allowing a device to be considered OPERABLE with either normal or emergency power available.

The OPERABILITY requirements for normal and emergency power sources are clearly addressed in the second part to the CTS 1.0.L definition. These requirements allow only the normal or the emergency electrical power source to be OPERABLE, provided all of its redundant system(s), subsystem(s), train(s),

component(s), and device(s) (redundant to the systems, subsystems, trains, components, and devices with an inoperable power source) are OPERABLE.

This effectively changes the current "and" to an "or." The existing requirements (in the second part of CTS 1.0.L) are incorporated into ITS 3.8.1 ACTIONS for when a normal (offsite) or emergency (diesel generator) power source is inoperable. Therefore, the ITS definition now uses the word "or" instead of the current word "and." In ITS 3.8.1, new times are provided to perform the determination of OPERABILITY of the redundant systems. This change is discussed in the Discussion of Changes (DOCs) for ITS 3.8.1. This change is designated administrative since the ITS definition is effectively the same as the CTS definition or will be justified in the DOCs of ITS 3.8.1.

A.12 CTS Section 1.0 provides definitions for Pressure Boundary Leakage (CTS 1.0.AB), Identified Leakage (CTS 1.0.AC), Unidentified Leakage (CTS 1.0.AD), and Total Leakage (CTS 1.0.AE). ITS Section 1.1 includes these requirements in one definition called LEAKAGE and includes four categories: identified LEAKAGE; unidentified LEAKAGE; total LEAKAGE; and pressure boundary LEAKAGE. This changes the CTS by incorporating the four separate definitions into a single definition with no technical changes.

This change is acceptable because it results in no technical changes to the Technical Specifications. This change is designated an administrative change in that it rearranges existing definitions, with no change in intent.

A.13 CTS 1.0.AB states "Pressure boundary leakage shall be the leakage through a non-isolable fault in the reactor coolant system pressure boundary." ITS Section 1.1 states pressure boundary LEAKAGE is the LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) "component body, pipe wall, or vessel wall." This changes the CTS by explicitly stating the components of the RCS pressure boundary.

This change is acceptable because it results In no technical changes to the Technical Specifications. The CTS term "reactor coolant pressure boundary" is considered to be covered by the ITS phrase RCS "component body, pipe wall, or vessel wall." This change is administrative since the new definition of Pressure Monticello Page 7 of 14, Volume 3, Rev. 0, Page 25 of 70

, Volume 3, Rev. 0, Page 26 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION Boundary LEAKAGE covers the same boundary as the CTS definition of RCS pressure boundary.

A.14 ITS Section 1.1 provides definitions of ACTIONS, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR), LINEAR HEAT GENERATION RATE (LHGR), LOGIC SYSTEM FUNCTIONAL TEST, STAGGERED TEST BASIS, THERMAL POWER, and TURBINE BYPASS SYSTEM RESPONSE TIME.

These terms are not defined in the CTS. This changes the CTS by adding the above temms.

The purpose of these ITS definitions is to define terms used in various ITS Specifications. This change is acceptable because the definitions do not impose any new requirements or alter existing requirements. Any technical changes due to the addition of these definitions will be addressed in the DOCs for the sections of the Technical Specifications in which the definitions are used. These changes are designated as administrative as they add defined terms that do not involve a technical change to the Technical Specifications.

A.15 ITS Sections 1.2, 1.3, and 1.4 contain information that is not in the CTS. This change to the CTS adds explanatory information on ITS usage that is not applicable to the CTS. The added sections are:

Section 1.2 - Logical Connectors Section 1.2 provides specific examples of the logical connectors "AND" and "OR" and the numbering sequence associated with their use.

Section 1.3 - Completion Times Section 1.3 provides guidance on the proper use and interpretation of Completion Times. The section also provides specific examples that aid in the use and understanding of Completion Times.

Section 1.4 - Frequency Section 1.4 provides guidance on the proper use and interpretation of Surveillance Frequencies. The section also provides specific examples that aid in the use and understanding of Surveillance Frequency.

This change is acceptable because it aids in the understanding and use of the format and presentation style of the ITS. The addition of these sections does not add or delete technical requirements, and will be discussed specifically in those Technical Specifications where application of the added sections results in a change. This change is designated as administrative because it does not result in a technical change to the Technical Specifications.

A.16 CTS 3.1.A states that the time from initiation of any Reactor Protection System (RPS) channel trip to the de-energization of the scram pilot valve solenoids shall not exceed 50 milliseconds. ITS Section 1.1 includes a definition of REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME. The ITS definition is Monticello Page 8 of 14, Volume 3, Rev. 0, Page 26 of 70

, Volume 3, Rev. 0, Page 27 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION consistent with the CTS 3.1A, but includes the statement "The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured." This changes the CTS by adding the sentence associated with the manner of testing. Any change to the response value of 50 milliseconds is discussed in the Discussion of Changes for ITS 3.3.1.1.

This change is acceptable because the ITS definition testing allowance is consistent with current plant practices and it is not specifically prohibited by the CTS. In addition, while Monticello is not committed to IEEE-338-1977, "Response Time Verification Tests," the definition is consistent with the guidance provided in IEEE 338-1977, Section 6.3.4. Furthermore, the results of the test are unaffected by this allowance. This change is designated as administrative as it doe's not result in a technical change to the response time tests.

A.17 These changes to CTS 1.0.U are provided in the Monticello ITS consistent with the Technical Specifications Change Request submitted to the NRC for approval in NMC letter L-MT-04-036, from Thomas J. Palmisano (NMC) to USNRC, dated June 30, 2004. As such, these changes are administrative.

MORE RESTRICTIVE CHANGES M.1 The CTS 1.0.A definition of Alteration of the Reactor Core applies to the act of moving any component in the region "above the core support plate, below the upper grid, and within the shroud with the vessel head removed and fuel in the vessel." The ITS Section 1.1 definition of CORE ALTERATION will only apply to the movement of fuel, sources, or reactivity control components "within the reactor vessel." This changes the CTS by expanding the region to be considered a CORE ALTERATION. The change concerning the types of "components" to be considered in the CORE ALTERATION definition Is discussed in DOC L.1.

The purpose of the CORE ALTERATION definition is to assure the appropriate LCOs are being met when a CORE ALTERATION is in progress to mitigate the consequences of a reactivity excursion. This change expands the region to be considered a CORE ALTERATION from the limited region of "above the core support plate, below the upper grid, and within the shroud" to "within the reactor vessel." This change is acceptable since the applicable LCOs must now be met to limit the consequences of a reactivity excursion when any of the specified components (fuel, sources, or reactivity control components) are being moved within the reactor vessel. This will ensure the applicable LCOs are met before there is a potential to affect core reactivity. This change is designated as more restrictive because the applicable LCOs must be met when the specified components are being moved over a larger region.

M.2 CTS 1.0.A definition of Alteration of the Reactor Core exempts control rod movement using the normal drive mechanism. The ITS Section 1.1 definition of CORE ALTERATION only exempts control rod movement if there is no fuel assemblies in the associated core cell. This changes the CTS by only exempting control rod movement from the definition if there are no fuel assemblies in the associated core cell.

Monticello Page 9 of 14, Volume 3, Rev. 0, Page 27 of 70

, Volume 3, Rev. 0, Page 28 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION The purpose of the CORE ALTERATION definition is to define components that can be moved and could result in a reactivity excursion event during refueling.

Movement of a control rod whose core cell contains one or more fuel assembles could affect the reactivity of the core. Therefore, considering this type of movement a CORE ALTERATION and placing similar Technical Specification restrictions as are required for other CORE ALTERATIONS is acceptable. This change is designated as more restrictive because the applicable LCOs must be met during certain control rod movements.

M.3 CTS 1.0.K states the definition of Mode as "The reactor mode is that which is established by the mode-selector switch." CTS 1.0.B states the definition of Hot Standby as "Hot Standby means operation with the reactor critical in the startup mode at a power level just sufficient to maintain reactor pressure and temperature." CTS 1.0.0 states the definition of Power Operation as "Power Operation is any operation with the mode switch in the "Start-Up" or "Run" position with the reactor critical and above 1% rated thermal power." CTS 1.0.Y states the definition of Shutdown as "The reactor is in a shutdown condition when the reactor mode switch is in the shutdown mode position and no core alterations are being performed. In this condition, a reactor scram is initiated and a rod block is inserted directly from the mode switch. The scram can be reset after a short time delay. 1. Hot Shutdown means conditions as above with reactor coolant temperature greater than 2120F. 2. Cold Shutdown means conditions as above with reactor coolant temperature equal to or less than 2120F." ITS Section 1.1 states the definition of MODE as "A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel." In addition, a new Table (ITS Table 1.1-1) has been added that defines the actual MODES. ITS Table 1.1-1 defines the different MODES as follows:

• MODE 1 (Power Operation) is when the reactor mode switch is in the Run position; MODE 2 (Startup) is when the reactor mode switch is in the Refuel position' and all reactor vessel head closure bolts are fully tensioned (footnote (a)) or when the reactor mode switch is in the Startup/Hot Standby position; MODE 3 (Hot Shutdown) is when the reactor mode switch is in the Shutdown position, all reactor vessel head closure bolts are fully tensioned (footnote (a))

and the average reactor coolant temperature is > 2120F; MODE 4 (Cold Shutdown) is when the reactor mode switch is in the Shutdown position, all reactor vessel head closure bolts are fully tensioned (footnote (a)) and the average reactor coolant temperature is < 2120F; and

• MODE 5 (Refueling) is when the reactor mode switch is in the Shutdown or Refuel position and one or more reactor vessel head closure bolts are less than fully tensioned (footnote (b)).

This changes the CTS in several ways:

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• The CTS 1.0.K definition of Mode is changed by adding "average reactor coolant temperature," "reactor vessel head closure bolt tensioning specified in Table 1.1-1," and "with fuel in the reactor vessel" to the definition.

This portion of the change is considered acceptable since the new definition is consistent with the actual ITS Table 1.1-1 requirements. Any technical changes associated with the new ITS Table 1.1-1 requirements are discussed below as part of the discussion for each of the different MODES (i.e., MODES 1 through 5). As such, this portion of the change is considered administrative but is included in this more restrictive change discussion for clarity.

The CTS 1.0.0 definition of Power Operation is being split into two distinct MODES: MODE I for when the reactor mode switch is in Run position; and MODE 2 for when the reactor mode switch is In the Startup/Hot Standby position. Furthermore, the reference to a power level is deleted for both MODES. Also, the CTS 1.0.B definition of Hot Standby is being combined with the MODE 2 portion of the CTS 1.0.0 Power Operation definition. This changes the CTS definition such that: a. when the reactor mode switch is in Run, the unit will always be in MODE 1, even if reactor power level is < 1%

rated thermal power or the reactor is subcritical; and b. when the reactor mode switch is in Startup/Hot Standby position, the unit will always be in MODE 2, even if reactor power level is < 1% rated thermal power (or just sufficient to maintain reactor pressure and temperature) or the reactor is subcritical.

This change is acceptable since it cleafrly defines that MODES 1 and 2 depend on the position of the reactor mode switch, not on the power level.

This ensures that the unit is always in a MODE when the reactor mode switch is placed in either the Run or Startup/Hot Standby position. Thus in the individual ITS Specifications, a CTS LCO that is applicable in the Power Operation Mode will now be required to be OPERABLE during ITS MODES 1 and 2 and a CTS LCO applicable in the CTS Hot Standby Mode (referred to as startup in the CTS LCOs) will now be required to be OPERABLE during MODE 2.

ITS MODE 2 will now include the mode switch position of Refuel when the head closure bolts are fully tensioned (as stated in ITS Table 1.1-1 footnote (a)). Currently, this reactor mode switch and head closure bolt combination is not defined in the CTS.

This change is considered acceptable since this is currently a plant condition that has no corresponding MODE. The new requirement will ensure proper and adequate Technical Specification requirements are applied when the reactor mode switch is in the Refuel position when all head closure bolts are fully tensioned.

The CTS 1.0.Y definition of Shutdown is being split into two distinct MODES:

MODE 3 for when the reactor mode switch is in Shutdown and (as described in part 1 of the CTS definition) the average reactor coolant temperature is Monticello Page 11 of 14, Volume 3, Rev. 0, Page 29 of 70

, Volume 3, Rev. 0, Page 30 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION K)

> 21 20F; and MODE 4 for when the reactor mode switch is in Shutdown and (as described in part 2 of the CTS definition) the average reactor coolant temperature is < 2120F. Furthermore, for both MODE 3 and MODE 4, all reactor vessel head closure bolts must be fully tensioned. This changes the CTS definition such that all head bolts must be fully tensioned to be in either MODE 3 or 4, instead of the current requirement that no CORE ALTERATIONS are being performed.

This change is considered acceptable since it ensures that it is physically impossible to perform CORE ALTERATIONS with all head bolts fully tensioned. As a result of this change, in the individual ITS Specifications, a CTS LCO that is applicable in the Shutdown/Hot Shutdown Mode will now be required to be OPERABLE during ITS MODE 3 and a CTS LCO applicable in the CTS Shutdown/Cold Shutdown Mode will now be required to be OPERABLE during MODE 4.

ITS MODE 5 has been added to clearly define when the unit is in the refuel mode. ITS MODE 5 is defined as the reactor mode switch in either the Shutdown or Refuel position with one or more reactor vessel head closure bolts less than full tensioned. Currently, no defined term exists in the CTS for the Refuel Mode, even though many CTS Specifications use the term Refuel Mode.

This change is acceptable because it clearly defines when the unit is considered in the Refuel Mode. This precludes being in an undefined mode and not applying the applicable Technical Specifications when the reactor mode switch is in the Refuel position or in the Shutdown position with any reactor vessel head closure bolt not fully tensioned.

These changes are designated as more restrictive because the applicable LCOs must be met under more conditions in the ITS as compared to the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES.

LA.I (Type I - Removing Details of System Design and System Description, Including Design Limits) The CTS 1.0.Y definition of Shutdown states that with the reactor mode switch in Shutdown, "a reactor scram is initiated...directly from the mode switch. The scram can be reset after a short time delay." ITS Table 1.1-1 does not include this additional design information. This changes the CTS by moving the functional description and logic associated with the reactor mode switch scram to the ITS 3.3.1.1 Bases.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not Monticello Page 12 of 14, Volume 3, Rev. 0, Page 30 of 70

, Volume 3, Rev. 0, Page 31 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS (ITS 3.3.1.1) still retains the requirement that the reactor mode switch scram be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the' Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 CTS 1.0.A definition of Alteration of the Reactor Core applies to the act of moving "any component." However, the definition also states that the normal operating functions such as control rod movement using the normal drive mechanism, tip scans, SRM and IRM detector movements, etc., are not to be considered core alterations. The ITS Section 1.1 definition of CORE ALTERATION will only apply to the movement of "fuel, sources, or reactivity control components." In addition, the following exceptions are not considered to be CORE ALTERATIONS in the ITS: a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement); and b. control rod movement, provided there are no fuel assemblies in the associated core cell. This changes the CTS by eliminating from the definition of Alteration of the Core the movement of components that do not affect the reactivity of the core i.e., that are not fuel, sources, or reactivity control components, and also explicitly excludes local power range monitors and special moveable detectors from being a CORE ALTERATION. The change in the control rod movement portion of the definition is discussed in DOC M.2.

The purpose of the CORE ALTERATION definition is to define components that can be moved and could result in a reactivity excursion event during refueling.

This change eliminates the movement of components that do not affect the reactivity of the core from the definition. This change is acceptable because the ITS definition of CORE ALTERATION and the associated Specifications which require equipment to be OPERABLE or parameters be met during a CORE ALTERATION will help ensure the proper controls during the movement of components such as fuel, sources, and reactivity control components. The movement of these components may affect the core reactivity, therefore these controls are necessary. Movement of local power range monitors, special movable detectors, and control rods with no fuel in the associated core cells are explicitly excluded from the definition since the movement of these components does not affect the reactivity of the core. This change is designated as less restrictive because the ITS definition of CORE ALTERATION applies in fewer circumstances than does the CTS definition.

L.2 The CTS 1.0.E definition of Instrument Functional Test requires the use of a "simulated" signal when performing the test. The ITS Section 1.1 CHANNEL FUNCTIONAL TEST definition allows the use of a "simulated or actual" signal Monticello Page 13 of 14, Volume 3, Rev. 0, Page 31 of 70

, Volume 3, Rev. 0, Page 32 of 70 DISCUSSION OF CHANGES ITS CHAPTER 1.0, USE AND APPLICATION when performing the test. This changes the CTS by allowing the use of unplanned actuations to perform the Surveillance if sufficient information is collected to satisfy the surveillance test requirements.

This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change is designated as less restrictive because it allows an actual signal to be credited for a Surveillance where only a simulated signal was previously allowed.

L.3 CTS 1.0.E defines Instrument Functional Test as the injection of a simulated signal "into the primary sensor." ITS Section 1.1 defines CHANNEL FUNCTIONAL TEST as the injection of a simulated or actual signal "into the channel as close to the sensor as practicable." This changes the CTS by allowing a signal to be injected "in the channel as close to the sensor as practicable" instead of "into the primary sensor."

The purpose of a CHANNEL FUNCTIONAL TEST is to ensure a channel is OPERABLE. This change allows a CHANNEL FUNCTIONAL TEST to be performed by injecting a signal "as close to the sensor as practicable" instead of "into the primary sensor." Injecting a signal into the primary sensor would, in some cases, involve significantly increased probabilities of initiating undesired circuits during the test since several logic channels are often associated with a particular sensor. Performing the test by injection of a signal into the primary sensor could also require jumpering of the other logic channels to prevent their initiation during the test or increasing the scope of the tests to include multiple tests of the other logic channels. Either method significantly increases the difficulty of performing the surveillance. Allowing initiation of the signal close to the sensor in lieu of into the sensor provides a complete test of the logic channel while significantly reducing the probability of undesired initiation. In addition, the sensor is still being checked during a CHANNEL CALIBRATION. This change is designated as less restrictive because the ITS definition of CHANNEL FUNCTIONAL TEST will allow the test to be performed injecting a signal "into the channel as close to the sensor as practicable" instead of "into the primary sensor."

Monticello Page 14 of 14, Volume 3, Rev. 0, Page 32 of 70

, Volume 3, Rev. 0, Page 33 of 70 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs), Volume 3, Rev. 0, Page 33 of 70

, Volume 3, Rev. 0, Page 34 of 70 Definitions 1.1 1.0 USE AND APPLICATION CTS 1.1 Definitions DOC A2 The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition DOC A.14 ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

Doc AVERAGE PLANAR LINEAR M14 HEAT GENERATION RATE (APLHGR) 1.-.F CHANNEL CALIBRATION 1.0.x CHANNEL CHECK 1..E CHANNEL FUNCTIONAL TEST The APLHGR shall be applicable to a specific planar height and is equal to the sum of theRLHGRsJ heat ggaer ion rate per unit lea f fuel rod] for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundlepat the height.

A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal Into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps.

0D 0D BWR/4 STS 1.1-1 Rev. 3.0, 03/31/04, Volume 3, Rev. 0, Page 34 of 70

, Volume 3, Rev. 0, Page 35.of 70 Definitions 1.1 c 1.1 Definitions 1.o-A CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel.

The following exceptions are not considered to be CORE ALTERATIONS:

a.

Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement)an

b.

Control rod movement, provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

REPORT (COLR) 1.0-AK DOSE EQUIVALENT 1-IITS The COLR is the unit specific document that provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6fg. Plant o eration within TSTF teelimits is addressed in individual pecifications.la.

369 I

DOSE EQUIVALENT 1-1 31 shall be that concentration of 1-1 31 kU (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132,1-133, 1-1 34, and 1-1 35 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in M~able Ill of TID-14844, AEC, 1962, "Calculation of Distance(T Factors for Power and Test Reactor Sites~lor those listed in 'Ui,-

ICRP0 Supplement to Part 1, age 192-212, Tafile titled, 3 The ECCS ESPONSE TIM salbtat time interval from when thie onitored paramer exedis ECCS initiation setpoint the channel senso unihECS equipment is capable fperforming its saft fuc i.e., the valves travel to their euired positions, pmdiare pressures reach their r uired values, etc.). Ties all include diesel EMERGENC OECOLIN(

SYSTEM(EC

)RSONSE TIME generptor starting and sequence 19ading delays, whlere applipable. The response time rriy be measured by means of anyperies of sequential, overlapping, or total steps so that the BWR/4 STS 1.1-2 Rev. 3.0, 03/31/04 Attachiment 1, Volume 3, Rev. 0, Page 35 of 70

, Volume 3, Rev. 0, Page 36 of 70 Definitions 1.1 OLE 1.1 Definitions ECCS RESPO E TIME (contiiiued)

//

entire r ponse time is measured. I lieu of measurement, respore time may be verified for s lected components provi ed that the components an methodology for verification hay been Dreviouslv reviewed d approved by the NRC.

0 END OF CYCL RECIRCULA-TION PUMP T IP (EOC RPT)

SYSTEM RES ONSE TIME The EOC PT SYSTEM RESPONSE T ME shall be that time interval fr initial signal generation by [the associated turbine stop valv limit switch or from when th turbine control valve hydrauli oil control oil pressure drop below the pressure switch s tpoint] to complete suppres ion of the electric arc betwee the fully open contacts of t e recirculation pump circuit reaker. The response time ay be measured by mean of any series of sequential, verlapping, or total steps so th t the entire response time is measured, [except for the brea er arc suppression time, wh ich is not measured but is vali ated to conform to the man facturer's design value].

0 0

ISOLATION SYVEM RESPONSE TI E The ISOLAtION SYSTEM RESPONSE IME shall be that time interv I from when the monitored p rameter exceeds its isolation i itiation setpoint at the channeI sensor until the isolation Ialves travel to their required/positions. Times shall include esel generator starting and equence loading delays, where plicable. The response tim may be measured by means f any series of sequential, c erlapping, or total steps so tha the entire response time is reasured. In lieu of meas rement, response time may e verified for selected com onents provided that the co ponents and methodology for v rification have been previou ly reviewed and approved bv te NRC.

DOC A.12 LEAKAGE 1.O.AC 1.0.AC LEAKAGE shall be:

a.

Identified LEAKAGE

1.

LEAKAGE into the drywell, such as that from pump seals or valve packing that is captured and conducted to a sump or collecting tan

2.

LEAKAGE into the drywell atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE,,

1

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, Volume 3, Rev. 0, Page 37 of 70 Definitions 1.1 cTs 1.1 Definitions LEAKAGE (continued) 1.0.AD

b.

Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAG

c.

Total LEAKAGE Sum of the identified and unidentified LEAKAGE and

d.

Pressure Boundarv LEAKAGE 1.0-AE 1.0.AB LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall.

DOC

[M]LINEAR HEAT GENERATION A.14 RATE (LHGR)

DoC LOGIC SYSTEM FUNCTIONAL A14 TEST The LHGR shall be the heat generation rate per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length. I NJ A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system Ctnc^

fknf tht tnire Ie,,i.r cv1wetm IC Itcine4

--YLUa Q QJ Lu IAl To BI

§til UI %&U Iue ;aa~ 1YL lI lo.;>nu

[ MAXIMUM F OTION OF The MFL shall be the largest value f the fraction of limiting LIMITING P ER DENSITY power nsity in the core. The fractjn of limiting power (MFLPD) densi shall be the LHGR existingat a given location divided by e specified LHGR limit for tat bundle type. ]

0 1.0oJ MINIMUM CRITICAL POWER RATIO (MCPR)

The MCPR shall be the smallest critical power ratio (CPR) that exists in the core Ifor each class of fueQ. The CPR is that 0

power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.

I.O.K MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

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, Volume 3, Rev. 0, Page 38 of 70 Definitions 1.1 cTs 1.1 Definitions 1.0.L OPERABLE - OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for, the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PHYSIS TESTS PHYSICS ESTS shall be those tests p rformed to measure the fundar ental nuclear characteristics of the reactor core and related in trumentation.

Theset ts are:

a.

0 scribed in Chapter [14, Initi I Test Program] of the F AR,

b.

uthorized under the provisi ns of 10 CFR 50.59, or

c.

Otherwise approved by the uclear Regulatory Commission.

0D PRESSURE A The PTLR s the unit specific documen hat provides the TEMPERATU E LIMITS reactor v ssel pressure and temperat re limits, including REPORT (P R) heatup nd cooldown rates, for the c rrent reactor vessel 4

fluenc period. These pressure an temperature limits shall be d ermined for each fluence peiod in accordance with Spe ification 5.6.

1 0

1.o.S RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) 3.1A REACTOF SYSTEM 4 TIME reactor coolant oU?.061 M~t Z PROTECTION The RPS RESPONSE TIME shall be that time interval from

RPS) RESPONSE when he monitored parameter exceeds its RPS tr p setpoint ati

..the channel sensor until ofthe initiation of any valve solenoids. The response time may be measured by toP thane l t means of any series of sequential, overlapping, or total steps

~~~so that the entire response time is measured0I iuo me

sret, response tim m

evriedfr sectd components provided tha t tec c

ponents and mtooo for verification have been previ usly reviewed an approved BWR/4 STS 1.1-5 Rev. 3.0, 03/31/04, Volume 3, Rev. 0, Page 38 of 70

, Volume 3, Rev. 0, Page 39 of 70

'Definitions 1.1

=

1.1 Definitions 3.3A1 SHUTDOWN MARGIN (SDM)

SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical assuming that:

a.

The reactor is xenon free1

b.

The moderator temperature is 680Ft and

c.

All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

DOC A.14 STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency Intervals, where n is the total number of systems, subsystems, channels, or other designated components In the associated function.

THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

DOC THERMAL POWER A.14 DOC JTURBINE BYPASS SYSTEM A-14 RESPONSE TIME The TURBINE BYPASS SYSTEM RESPONSE 0

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, Volume 3, Rev. 0, Page 40 of 70 Definitions 1.1 Table 1.1-1 (page 1 of 1)

MODES AVERAGE REACTOR COOLANT REACTOR MODE TEMPERATURE MODE TITLE SWITCH POSITION (OF)

I 1.0.0 1.0.0 1.0.Y.1 1.0.Y.2 DOC M.3 1

2 3

4 5

Power Operation Startup Hot Shutdown(a)

Cold Shutdown(a)

Refueling(b)

Run Refuel(a) or Startup/Hot Standby Shutdown Shutdown Shutdown or Refuel NA NA NA 1.0.0, 1.0.Y K )

~DOC M.3 (a)

(b)

All reactor vessel head closure bolts fully tensioned.

One or more reactor vessel head closure bolts less than fully tensioned.

BWR/4 STS 1.1-7, Volume 3, Rev. 0, Page 40 of 70 Rev. 3.0, 03/31/04

, Volume 3, Rev. 0, Page 41 of 70 Logical Connectors 1.2 1.0 USE AND APPLICATION cTs 1.2 Logical Connectors DOC PURPOSE A.15 The purpose of this section is to explain the meaning of logical connectors.

Logical connectors are used in Technical Specifications (TS) to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies. The only logical connectors that appear in TS are AND and OR. The physical arrangement of these connectors constitutes logical conventions with specific meanings.

BACKGROUND Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action).

The successive levels of logic are identified by additional digits of the Required Action number and by successive indentions of the logical connectors.

When logical connectors are used to state a Condition, Completion Time, Surveillance, or Frequency, only the first level of logic is used, and the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency.

EXAMPLES The following examples illustrate the use of logical connectors.

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, Volume 3, Rev. 0, Page 42 of 70 Logical Connectors 1.2 cTS 1.2 Logical Connectors DOC EXAMPLES (continued)

A.15

.EXAMPLE 1.2-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met.

A.1 Verify...

AND A.2 Restore...

In this example the logical connector AND is used to indicate that when in Condition A, both Required Actions A.1 and A.2 must be completed.

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, Volume 3, Rev. 0, Page 43 of 70 Logical Connectors 1.2 Us 1.2 Logical Connectors AO1 EXAMPLES (continued)

EXAMPLE 1.2-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met.

A.1 Trip...

OR A.2.1 Verify...

AND A.2.2.1 Reduce...

OR A.2.2.2 Perform...

OR A.3 Align...

This example represents a more complicated use of logical connectors.

Required Actions A.1, A.2, and A.3 are alternative choices, only one of which must be performed as indicated by the use of the logical connector OR and the left justified placement. Any one of these three Actions may be chosen. If A.2 is chosen, then both A.2.1 and A.2.2 must be performed as indicated by the logical connector AND. Required Action A.2.2 is met by performing A.2.2.1 or A.2.2.2. The indented position of the logical connector OR indicates that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.

BWR/4 STS 1.2-3 Rev. 3.0, 03/31/04, Volume 3, Rev. 0, Page 43 of 70

, Volume 3, Rev. 0, Page 44 of 70 Completion Times 1.3 1.0 USE AND APPLICATION CTS 1.3 Completion Times DOC A.15 PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a.

Must exist concurrent with the first inoperability and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

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, Volume 3, Rev. 0, Page 45 of 70 Completion Times 1.3 1.3 Completion Times AO1 DESCRIPTION (continued)

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery..." Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

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, Volume 3, Rev. 0, Page 46 of 70 Completion Times 1.3 cls 1.3 Completion Times DOC A.15 EXAMPLES (continued)

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and associated AND Completion Time not met.

B.2 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

?

Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) is allowed for reaching MODE 4 from the time that Condition B was entered. If MODE 3 is reached within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for reaching MODE 4 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for reaching MODE 4 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

If Condition B is entered while in MODE 3, the time allowed for reaching MODE 4 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

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, Volume 3, Rev. 0, Page 47 of 70 Completion Times 1.3 Cm 1.3 Completion Times DOC A.15 EXAMPLES (continued)

EXAMPLE 1.3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One pump A.1 Restore pump to 7 days inoperable.

OPERABLE status.

B. Required B.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and associated AND Completion Time not met.

B.2 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> When a pump is declared inoperable, Condition A is entered. If the pump is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the inoperable pump is restored to OPERABLE status after Condition B is entered, Conditions A and B are exited, and therefore,

• the Required Actions of Condition B may be terminated.

When a second pump is declared inoperable while the first pump is still inoperable, Condition A is not re-entered for the second pump.

LCO 3.0.3 is entered, since the ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered, but continues to be tracked from the time Condition A was initially entered.

While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has not expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition A.

While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition B. The Completion Time for Condition B is tracked from the time the Condition A Completion Time expired.

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, Volume 3, Rev. 0, Page 48 of 70 Completion Times 1.3 CTS 1.3 Completion Times DOC EXAMPLES (continued)

A.15 On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days.

EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore Function X 7 days Function X subsystem to subsystem OPERABLE status.

AND inoperable.

10 days from discovery of failure to meet the LCO B. One B.1 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y subsystem to subsystem OPERABLE status.

AND inoperable.

10 days from discovery of failure to meet the LCO C. One CA Restore Function X 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function X subsystem to subsystem OPERABLE status.

inoperable.

OR AND C.2 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> One subsystem to Function Y OPERABLE status.

subsystem inoperable.

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, Volume 3, Rev. 0, Page 49 of 70 Completion Times 1.3 CTS 1.3 Completion Times DOC EXAMPLES (continued)

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).

I If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).

The Completion Times of Conditions A and B are modified by a logical connector with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock." In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.

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, Volume 3, Rev. 0, Page 50 of 70 Completion Times 1.3 PM 1.3 Completion Times A.15 EXAMPLES (continued)

EXAMPLE 1.3-4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Restore valve(s) to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves OPERABLE status.

inoperable.

B. Required B.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and associated AND Completion Time not met.

B.2 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per valve basis. Declaring subsequent valves inoperable, while Condition A is still in effect, does not trigger the tracking of separate Completion Times.

Once one of the valves has been restored to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first valve was declared inoperable. The Completion Time may be extended if the valve restored to OPERABLE status was the first inoperable valve. The Condition A Completion Time may be extended for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provided this does not result in any subsequent valve being inoperable for > 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

If the Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (plus the extension) expires while one or more valves are still inoperable, Condition B is entered.

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, Volume 3, Rev. 0, Page 51 of 70 Completion Times 1.3 08 1.3 Completion Times A.15 EXAMPLES (continued)

EXAMPLE 1.3-5 ACTIONS Satoio-------NOTEd fore p---

Separate Condition entry is allowed for each inoperable valve.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Restore valve to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves OPERABLE status.

inoperable.

B. Required B.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and associated AND Completion Time not met.

B.2 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> The Note above the ACTIONS Table Is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.

The Note allows Condition A to be entered separately for each inoperable valve, and Completion Times tracked on a per valve basis. When a valve is declared inoperable, Condition A is entered and its Completion Time starts. If subsequent valves are declared inoperable, Condition A is entered for each valve and separate Completion Times start and are tracked for each valve.

If the Completion Time associated with a valve in Condition A expires, Condition B is entered for that valve. If the Completion Times associated with subsequent valves in Condition A expire, Condition B is entered separately for each valve and separate Completion Times start and are tracked for each valve. If a valve that caused entry into Condition B is restored to OPERABLE status, Condition B is exited for that valve.

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, Volume 3, Rev. 0, Page 52 of 70 Completion Times 1.3 CTS 1.3 Completion Times DOC A.15 EXAMPLES (continued)

Since the Note in this example allows multiple Condition entry and tracking of separate Completion Times, Completion Time extensions do not apply.

EXAMPLE 1.3-6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel A.1 Perform SR 3.x.x.x.

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable.

OR A.2 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> POWER to

• 50% RTP.

B. Required B.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and associated Completion Time not met.

Entry into Condition A offers a choice between Required Action A.1 or A.2. Required Action A.1 has a "once per" Completion Time, which qualifies for the 25% extension, per SR 3.0.2, to each performance after the initial performance. The initial 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval of Required Action A.1 begins when Condition A is entered and the initial performance of Required Action A.1 must be complete within the first 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval. If Required Action A.1 is followed and the Required Action is not met within the Completion Time (plus the extension allowed by SR 3.0.2),

Condition B is entered. If Required Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not met, Condition B is entered.

If after entry into Condition B, Required Action A.1 or A.2 is met, Condition B is exited and operation may then continue in Condition A.

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, Volume 3, Rev. 0, Page 53 of 70 Completion Times 1.3 CTS 1.3 Completion Times A.1 EXAMPLES (continued)

• EXAMPLE 1.3-7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Verify affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> subsystem subsystem isolated.

inoperable.

AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND A.2 Restore subsystem 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to OPERABLE status.

B. Required B.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and associated AND Completion Time not met.

B.2 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time begins at the time the Condition is entered and each 'Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter" interval begins upon performance of Required Action A.1.

If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or any subsequent 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval from the previous performance (plus the extension allowed by SR 3.0.2), Condition B is entered. The Completion Time clock for Condition A does not stop after Condition B is entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired.

BWR/4 STS 1.3-10 Rev. 3.0, 03/31/04, Volume 3, Rev. 0, Page 53 of 70

, Volume 3, Rev. 0, Page 54 of 70 Completion Times 1.3 CTS 1.3 Completion Times 1.0.0 IMMEDIATE When "Immediately" is used as a Completion Time, the Required Action COMPLETION TIME should be pursued without delay and in a controlled manner.

BWR/4 STS 1.3-11 Rev. 3.0, 03/31/04, Volume 3, Rev. 0, Page 54 of 70

, Volume 3, Rev. 0, Page 55 of 70 Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency DOC PURPOSE The purpose of this section is to define the proper use and application of A.15 Frequency requirements.

DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated LCO. An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.

L; The "specified Frequency" is referred to throughout this section and eachl of the Specifications of Section 3.0.0,4Surveillance Requirement (SR)

/

)

Applicability.YThe "specified Frequency" consists of the requirements of the Frequency column of each SR as well as certain Notes in the Surveillance column that modify performance requirements.

Sometimes special situations dictate when the requirements of a Surveillance are to be met. They are "otherwise stated" conditions allowed by SR 3.0.1. They may be stated as clarifying Notes in the Surveillance, as part of the Surveillance, or both.

Situations where a Surveillance could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated LCO is within its Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is only "required" when it can be and should be performed. With an SR satisfied, SR 3.0.4 imposes no restriction.

The use of "met" or "performed" in these instances conveys specific meanings. A Surveillance is "met" only when the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being "performed," constitutes a Surveillance not "met." "Performance" refers only to the requirement to specifically determine the ability to meet the acceptance criteria.

Some Surveillances containotes that modify the Frequency of performance or the conditions during which the acceptance criteria must be satisfied. For these Surveillances, the MODE-entry restrictions of SR 3.0.4 may not apply. Such a Surveillance is not required to be performed prior to entering a MODE or other specified condition in the Applicability of the associated LCO if any of the following three conditions are satisfied:

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, Volume 3, Rev. 0, Page 56 of 70 Frequency 1.4 CTS 1.4 Frequency DOC A.15 DESCRIPTION (continued)

a.

The Surveillance is not required to be met in the MODE or other specified condition to be entered; El

b.

The Surveillance is required to be met in the MODE or other specified condition to be entered, but has been performed within the specified Frequency (i.e., it is current) and is known not to be failed; or

c.

The Surveillance is required to be met, but not performed, in the MODE or other specified condition to be entered, and is known not to be failed.

Examples 1.4-3, 1.4-4, 1.4-5, and 1.4-6 discuss these special situations.

0 EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO).

If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable.

BWR/4 STS 1.4-2 Rev. 3.0, 03/31/04, Volume 3, Rev. 0, Page 56 of 70

, Volume 3, Rev. 0, Page 57 of 70 Frequency 1.4 cls 1.4 Frequency DOC EXAMPLES (continued)

A.15 If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition. Failure to do so would result.

in a violation of SR 3.0.4.

EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits.

Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after 225% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time reactor power is increased from a power level

< 25% RTP to 2 25% RTP, the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND").

This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2. "Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If reactor power decreases to

< 25% RTP, the measurement of both intervals stops. New intervals start upon reactor power reaching 25% RTP.

BWRI4 STS 1.4-3 Rev. 3.0, 03/31/04, Volume 3, Rev. 0, Page 57 of 70

, Volume 3, Rev. 0, Page 58 of 70 Frequency 1.4 CTS DOC A.15 1.4 Frequency EXAMPLES (continued)

EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS '

SURVEILLANCE FREQUENCY

--- NOTE-Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after 2 25% RTP.

Perform channel adjustment.

7 days The interval continues, whether or not the unit operation is < 25% RTP between performances.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches 2 25% RTP to perform the Surveillance.

3{

The Surveillance is still considered to be within the "specified Frequency."

Therefore, if the Surveillance " r"ot performed within the 7 day interval (plus the extension allowed by 3.0.2), but operation was < 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO.

Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with power 2 25% RTP.

Once the unit reaches 25% RTP, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be allowed for completing the Surveillance. If the Surveillance r not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

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, Volume 3, Rev. 0, Page 59 of 70 Frequency 1.4 1.4 Frequency CTS DOC A.15 EXAMPLES (continued)

EXAMPLE 1.4-4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY NOTE-------

Only required to be met in MODE 1.

Verify leakage rates are within limits.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Example 1.4-4 specifies that the requirements of this Surveillance do not have to be met until the unit is in MODE 1. The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-1. However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance. Therefore, if the Surveillancew r -not performed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval (plus the extension allowed by SR 3.0.2), but the unit was not in MODE 1, there would be no failure of the SR nor failure to meet the LCO. Therefore, no violation of SR 3.0.4 occurs when changing MODES, even with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency exceeded, provided the MODE change was not made into MODE 1. Prior to entering MODE 1 (assuming again that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency R.

EXAMPLE 1.4-5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

-- NOTE---

Only required to be performed in MODE 1.

Perform complete cycle of the valve.

7 days The interval continues, whether or not the unit operation is in MODE 1, 2, or 3 (the assumed Applicability of the associated LCO) between performances.

BWR/4 STS 1.4-5 Rev. 3.0, 03/31/04, Volume 3, Rev. 0, Page 59 of 70

, Volume 3, Rev. 0, Page 60 of 70 Frequency 1.4 CTa 1.4 Frequency DOC EXAMPLES (continued)

A.1 As the Note modifies the required performance of the Surveillance, the Note is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is not in MODE 1, this Note allows entry into and operation in MODES 2 and 3 to perform the Surveillance. The Surveillance is still considered to be performed within the "specified Frequency" if completed prior to entering MODE 1.

Therefore, if the Surveillance Enot per ormed within the 7 day (plus the extension allowed by SR 3.0.2) interval, but operation was not in MODE 1, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not result in entry into MODE 1.

Once the unit reaches MODE 1, the requirement for the Surveillance to be performed within its specified Frequency applies and would require that the Surveillance had been performed. If the Surveillance girViot performed prior to entering MODE 1, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

EXAMPLE 1.4-6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

-- NOTES---

Not required to be met in MODE 3.

Verify parameter is within limits.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Example 1.4.6j specifies that the requirements of this Surveillance do not Qi have to be met while the unit is in MODE 3 (the assumed Applicability of the associated LCO is MODES 1, 2, and 3). The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-1. However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance. Therefore, if the Surveillanc wro pe ormed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval (plus the extension allowed by SR 3.0.2), and the unit was in MODE 3, there would be no failure of the SR nor failure to meet the LCO. Therefore, no violation of SR 3.0.4 occurs when changing MODES to enter MODE 3, BWR/4 STS 1.4-6 Rev. 3.0, 03/31/04, Volume 3, Rev. 0, Page 60 of 70

, Volume 3, Rev. 0, Page 61 of 70 Frequency 1.4 cTs 1.4 Frequency DoC EXAMPLES (continued)

A.15 even with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency exceeded, provided the MODE change does not result in entry into MODE 2. Prior to entering MODE 2 (assuming again that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency w re not met), SR 3.0.4 would require satisfying the SR.

wa)

BWR/4 STS 1.4-7 Rev. 3.0, 03/31/04, Volume 3, Rev. 0, Page 61 of 70

, Volume 3, Rev. 0, Page 62 of 70 JUSTIFICATION FOR DEVIATIONS ITS CHAPTER 1.0, USE AND APPLICATION

1. The brackets are removed and the proper plant specific information/value is provided.

2. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

3. Typographical/grammatical error corrected.

4. The definitions of EOC-RPT SYSTEM RESPONSE TIME, MAXIMUM FRACTION OF LIMITING POWER DENSITY, and PHYSICS TESTS have been deleted since they are not used in the Monticello ITS.

5. The current licensing basis definition for the RPS RESPONSE TIME has been maintained.

6. ECCS RESPONSE TIME and ISOLATION SYSTEM RESPONSE TIME definitions have not been adopted, consistent with Monticello current licensing basis. Monticello response time requirements reflect the industry standards and regulations to which the plant has been committed to and licensed to since the operating license was granted. Monticello is committed to the testing requirements contained in IEEE-279-1968 and IEEE-338-1971. These industry standards provide guidance and requirements for conducting periodic testing of protection systems. IEEE-279-1968 does not address response time testing. Response time testing requirements do not appear in IEEE-338 until the 1975 revision.

7. Monticello does not propose to use a PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) and will not relocate the Pressure and Temperature limits from the Technical Specifications. The current limits will be retained in the ITS. Therefore, the definition of PTLR has not been incorporated into the ITS.

8. The brackets are removed and the proper plant specific information is provided. This is consistent with current transient analysis assumptions, plant design, and the manner in which the TURBINE BYPASS SYSTEM RESPONSE TIME is currently measured.

Monticello Page 1 of I, Volume 3, Rev. 0, Page 62 of 70

, Volume 3, Rev. 0, Page 63 of 70 Specific No Significant Hazards Considerations (NSHCs), Volume 3, Rev. 0, Page 63 of 70

, Volume 3, Rev. 0, Page 64 of 70 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.1 Nuclear Management Company, LLC (NMC) is converting the Monticello Current Technical Specifications (CTS) to the Improved Technical Specifications (ITS) as outlined in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1433.

CTS 1.0.A definition of Alteration of the Reactor Core applies to the act of moving "any component." However, the definition also states that the normal operating functions such as control rod movement using the normal drive mechanism, tip scans, SRM and IRM detector movements, etc., are not to be considered core alterations. The ITS Section 1.1 definition of CORE ALTERATION will only apply to the movement of "fuel, sources, or reactivity control components." In addition, the following exceptions are not considered to be CORE ALTERATIONS in the ITS: a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement); and b.

control rod movement, provided there are no fuel assemblies in the associated core cell.

This changes the CTS by eliminating from the definition of Alteration of the Core the movement of components that do not affect the reactivity of the core i.e., that are not fuel, sources, or reactivity control components, and also explicitly excludes local power range monitors, special moveable detectors, and control rods with no fuel in the associated core cells from being a CORE ALTERATION. The change in the control rod movement portion of the definition is discussed in DOC M.2.

The purpose of the CORE ALTERATION definition is to define components that can be moved and could result in a reactivity excursion event during refueling. This change eliminates the movement of components that do not affect the reactivity of the core from the definition. This change is acceptable because the ITS definition of CORE ALTERATION and the associated Specifications which require equipment to be OPERABLE or parameters be met during a CORE ALTERATION will help ensure the proper controls during the movement of components such as fuel, sources, and reactivity control components. The movement of these components may affect the core reactivity, therefore these controls are necessary. Movement of local power range monitors and special movable detectors are explicitly excluded from the definition since the movement of these components does not affect the reactivity of the core. This change is designated as less restrictive because the ITS definition of CORE ALTERATION applies in fewer circumstances than does the CTS definition.

NMC has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No.

Monticello Page 1 of 7, Volume 3, Rev. 0, Page 64 of 70

, Volume 3, Rev. 0, Page 65 of 70 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION The proposed change revises the definition of CORE ALTERATION to be only the movement of fuel, sources, or reactivity control components rather than the movement of any component, and also explicitly excludes local power range monitors, special moveable detectors, and control rods with no fuel in the associated core cells. This change will not affect the probability of an accident.

The only component assumed to be an initiator of an event previously evaluated is an irradiated fuel assembly when it is dropped. None of the other components are initiators of any analyzed event. As fuel is retained in the list of components which, when moved, constitutes a CORE ALTERATION, the probability of a fuel handling accident is not affected. The consequences of an accident are not affected by this change as movement of the components being excluded from the definition of CORE ALTERATION do not act to mitigate the consequences of any accident previously evaluated. 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 the definition of CORE ALTERATION to be the movement of fuel, sources, or reactivity control components rather than the movement of any component, and also explicitly excludes local power range monitors, special moveable detectors, and control rods with no fuel in the associated core cells. This change will not physically alter the plant (no new or different type of equipment will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions.

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

3.

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

Response: No.

The proposed change revises the definition of CORE ALTERATION to be the movement of fuel, sources, or reactivity control components rather than the movement of any component, and also explicitly excludes local power range monitors, special moveable detectors, and control rods with no fuel in the associated core cells. The margin of safety is not affected by this change because the safety analysis assumptions are not affected. The safety analyses do not address the movement of components within the reactor vessel other than fuel and reactivity control components. Fuel continues to be included in the CORE ALTERATION definition. Also, the SHUTDOWN MARGIN is unaffected by the movement of components other than fuel, sources, and reactivity control components because the movement of other components will not significantly change core reactivity. No change is being proposed in the application of the definition to the movement of components that are factors in the design basis analyses. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Monticello Page 2 of 7, Volume 3, Rev. 0, Page 65 of 70

, Volume 3, Rev. 0, Page 66 of 70 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION Based on the above, NMC concludes that the proposed change presents 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.

Monticello Page 3 of 7, Volume 3, Rev. 0, Page 66 of 70

, Volume 3, Rev. 0, Page 67 of 70 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.2 Nuclear Management Company, LLC (NMC) is converting the Monticello Current Technical Specifications (CTS) to the Improved Technical Specifications (ITS) as outlined in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1433.

The CTS 1.0.E definition of Instrument Functional Test requires the use of a "simulated" signal when performing the test. The ITS Section 1.1 CHANNEL FUNCTIONAL TEST definition allows the use of an "simulated or actual" signal when performing the test.

This changes the CTS by allowing the use of unplanned actuations to perform the Surveillance if sufficient information is collected to satisfy the surveillance test requirements.

This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change is designated as less restrictive because it allows an actual signal to be credited for a Surveillance where only a simulated signal was previously allowed.

NMC has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," 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 adds an allowance that an actual as well as a simulated signal can be credited during the CHANNEL FUNCTIONAL TEST. This change allows taking credit for unplanned actuations if sufficient information is collected to satisfy the surveillance test requirements. This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated" signal, and the proposed requirement does not change the technical content or validity of the test. This change will not affect the probability of an accident. The source of the signal sent to components during a Surveillance is not assumed to be an initiator of any analyzed event. The consequence of an accident is not affected by this change. The results of the testing, and, therefore, the likelihood of discovering an inoperable component, are unaffected. As a result, the assurance that equipment will be available to mitigate the consequences of an accident is unaffected. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Monticello Page 4 of 7, Volume 3, Rev. 0, Page 67 of 70

, Volume 3, Rev. 0, Page 68 of 70 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION

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 adds an allowance that an actual as well as a simulated signal can be credited during the CHANNEL FUNCTIONAL TEST. This change will not physically alter the plant (no new or different type of equipment will be installed). The change also does not require any new or revised operator actions. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

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

Response: No.

The proposed change adds an allowance that an actual as well as a simulated signal can be credited during the CHANNEL FUNCTIONAL TEST. The margin of safety is not affected by this change. This change allows taking credit for unplanned actuations if sufficient information is collected to satisfy the surveillance test requirements. This change is acceptable because the channel itself cannot discriminate between an "actual" or "simulated" signal. As a result, the proposed requirement does not change the technical content or validity of the test. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, NMC concludes that the proposed change presents 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.

Monticello Page 5 of 7, Volume 3, Rev. 0, Page 68 of 70

, Volume 3, Rev. 0, Page 69 of 70 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.3 Nuclear Management Company, LLC (NMC) is converting the Monticello Current Technical Specifications (CTS) to the Improved Technical Specifications (ITS) as outlined in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWRA4." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1433.

CTS Section 1.0 defines Instrument Functional Test as the injection of a simulated signal "into the primary sensor." ITS Section 1.1 defines CHANNEL FUNCTIONAL TEST as the injection of a simulated or actual signal "into the channel as close to the sensor as practicable." This changes the CTS by allowing a signal to be injected "in the channel as close to the sensor as practicable" instead of "into the primary sensor."

The purpose of a CHANNEL FUNCTIONAL TEST is to ensure a channel is OPERABLE.

This change allows a CHANNEL FUNCTIONAL TEST to be performed by injecting a signal "as close to the sensor as practicable" instead of "into the primary sensor."

Injecting a signal into the primary sensor would, in some cases, involve significantly increased probabilities of initiating undesired circuits during the test since several logic channels are often associated with a particular sensor. Performing the test by injection of a signal into the primary sensor could also require jumpering of the other logic channels to prevent their initiation during the test or increasing the scope of the tests to include multiple tests of the other logic channels. Either method significantly increases the difficulty of performing the surveillance. Allowing initiation of the signal close to the sensor in lieu of into the sensor provides a complete test of the logic channel while significantly reducing the probability of undesired initiation. In addition, the sensor is still being checked during a CHANNEL CALIBRATION. This change is designated as less restrictive because the ITS definition of CHANNEL FUNCTIONAL TEST will allow the test to be performed injecting a signal "into the channel as close to the sensor as practicable" instead of "into the primary sensor."

NMC has evaluated whether or not a significant hazards consideration is involved with these proposed Technical Specification changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No.

Testing of instrument channels such that the test signal does not include the "sensor" will significantly reduce the complications associated with performance of a surveillance on a sensor that provides input to multiple logic channels. The sensor will still be checked during a CHANNEL CALIBRATION. This reduction of complication will not affect the failure probability of the equipment but may reduce the probability of personnel error during the surveillance. Such reductions will not involve a significant increase in the probability or consequences of an accident previously evaluated.

Monticello Page 6 of 7, Volume 3, Rev. 0, Page 69 of 70

, Volume 3, Rev. 0, Page 70 of 70 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 1.0, USE AND APPLICATION

2.

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

Response: No.

The possibility of a new or different kind of accident from any accident previously evaluated is not created because the proposed change does not introduce a new mode of plant operation and does not involve physical modification to the plant.

3.

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

Response: No.

This change does not involve a change to the limits or limiting condition of operation; only the method for performing a surveillance is changed. Since the proposed method affects only a single logic channel rather than potentially affecting multiple logic channels simultaneously, and the sensor is adequately tested during a CHANNEL CALIBRATION, the change does not involve a significant reduction in a margin of safety.

Based on the above, NMC concludes that the proposed change presents 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.

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