Text

Improved Technical Specifications, Volume 5, Revision 0, ITS Section 3.0, LCO Applicability & SR Applicability.
	ML051960253
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Site:	Monticello
Issue date:	06/29/2005
From:	; Nuclear Management Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
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IMPROVED TECHNICAL SPECIFICATIONS

- A, _ '

MONTICELLO NUCLEAR GENERATING PLANT VOLUME 5 ITS Section 3.0, LCO Applicability and SR Applicability Commited to Nuclear Excellence

Attachment 1, Volume 5, Rev. 0, Page 1 of 63 ATTACHMENT I VOLUME 5 I

- MONTICELLO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.0 LCO- and SR APPLICABILITY Revision 0 Attachment 1, Volume 5, Rev. 0, Page 1 of 63

Attachment 1, Volume 5, Rev. 0, Page 2 of 63 LIST OF ATTACHMENTS

1. ITS Section 3.0 Attachment 1,Volume 5, Rev. 0, Page 2 of 63

Attachment 1, Volume 5, Rev. 0, Page 3 of 63 ATTACHMENT I ITS Section 3.0, LCO and SR Applicability Attachment 1, Volume 5, Rev. 0, Page 3 of 63

Attachment 1, Volume 5, Rev. O,Page 4 of 63 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 5, Rev. 0, Page 4 of 63

C C ITS Section 3.0 0

[(LCO)APPLCABI 3.0 LIMING CONDITIONS FOR OPERATION 4 3.0 4.0 SURVEILLANCE REQUIREMEN79r14 E/

3.0 4.0 SURVEILLANCE REQUIREMENTI I INSERT 7 . -A-' .

ISR3.0.1 A. I The surveillanc tmsntsfHblssectionl shall be met. Eh surveillancrequirement shall by performedi e s ecilled times Oxcept as allowed a) hblod CD CD s SR B. 3.0.2

A.2 INSERT 1 0

'-I. -M CD 0

C.

M.1 INSERT2 SR CD 3.0.1

-(3 =D 0

-U Li INSERT 3 SR C" 3.0.4 a) 0 L2 INSERT 4 SR D. If it is discovered that a s~6rve=iance was Piot performed -

3.0.1 within tJse extended tini interval allowe:by 4.0.B, then _ a)

CD A.3 INSERT 5 4ET1 the afected equipmept shall be declarid inoperable. 0Dn CD

0) SR to E. {ompliance with"4 imay be delayed, from the time of to 3.0.3 discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the jI"]

- -o at whichever Is greater. This-delay period Is 0l A.4 INSERTO permitted to allow performance of the Ajrveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk Impact shall be managed. k 3.0/4.0 25a 05/31/02.

Amendment No. 32,115, 127 Page 1 of 6

Attachment 1, Volume 5, Rev. 0 Page 6 of 63 ITS Section 3.0 INSERT I LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

INSERT 2 LCO 3.0.3 When an LCO is not met and th6 associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

Insert Page 25a (1)

Page 2 of 6 Attachment 1, Volume 5, Rev. 0, Page 6 of 63

Attachment 1, Volume 5, Rev. 0, Page 7 of 63 ITS Section 3.0 INSERT 3 LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

O@INSERT4 LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

Insert Page 25a (2)

Page 3 of 6 Attachment 1, Volume 5, Rev. 0, Page 7 of 63

Attachment 1, Volume 5, Rev. 0, Page 8 of 63 ITS Section 3.0 O INSERT5 LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system.

Inthis event, an evaluation shall be performed in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

O INSERT 6 LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.

@INSERT 7 during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

Insert Page 25a (3)

Page 4 of 6 Aftachment 1, Volume 5, Rev. 0, Page 8 of 63

Attachment 1, Volume 5, Rev. 0, Page 9 of 63 ITS Section 3.0 INSERT 8 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the A6 interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per.I.a." basis, the above Frequencyoa extension applies to each performance after the initial performance. J Exceptions to this Specification are stated in the individual Specifications.

1A.6 INSERT 9 SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an

LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

GD INSERT 10 If it is discovered that a Surveillance was not performed within its specified Frequency, then Insert Page 25a (4)

Page 5 of 6 Attachment 1, Volume 5, Rev. 0, Page 9 of 63

Attachment 1, Volume 5, Rev. 0, Page 10 of 63 ITS Section 3.0 INSERT 11 If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Insert Page 25a (5)

Page 6 of 6 Attachment .1,Volume 5, Rev. 0, Page 10 of 63

Attachment 1, Volume 5, Rev. 0, Page 11 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY 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 ITS LCO 3.0.1 and LCO 3.0.2 are added to the CTS to provide guidance regarding LCOs and ACTIONS. ITS LCO 3.0.1 states "LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7." ITS LCO 3.0.2 states "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s),

completion of the Required Action(s) is not required, unless otherwise stated."

The changes to the CTS are:

CTS 3/4.0 does not include any general LCO/ACTION guidance requirements. However, in general the CTS LCOs require either the equipment to be OPERABLE or parameters to be met during the specified conditions. This is consistent with ITS LCO 3.0.1. In addition, if the LCO is not met, the applicable CTS Specification provides the appropriate actions to take. ITS LCO 3.0.2 states, in part, "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met." This statement is consistent with the current application of CTS actions. The second sentence of ITS LCO 3.0.2 states, in part, "If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required." This statement is also consistent with the current application of the CTS actions. The second sentence of ITS LCO 3.0.2 includes the phrase, "unless otherwise stated" at the end of the sentence. There are some ITS ACTIONS, which must be completed, even if the LCO is met or is no longer applicable. While this is a new requirement, the technical aspects of these changes are discussed in the appropriate ITS Specifications.

This change is acceptable because the intent of the CTS requirements is preserved and results in no technical changes to the Technical Specifications.

LCO 3.0.2 includes exceptions for LCO 3.0.5 and LCO 3.0.6. LCO 3.0.5 is a new allowance, for a system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY, that takes exception to the ITS LCO 3.0.2 requirement. LCO 3.0.6 is a new allowance that takes exception to the ITS LCO 3.0.2 requirement to take the Required Actions of a supported system LCO when the inoperability is Monticello Page 1 of 13 Attachment 1, Volume 5, Rev. 0, Pagle 11 of 63

Attachment 1, Volume 5, Rev. 0, Page 12 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY only associated with a support system LCO. These exceptions are included in LCO 3.0.2 to avoid conflicts between the applicability requirements.

This change is acceptable because it includes a reference to new items in the ITS. Changes resulting from the incorporation of LCO 3.0.5 are discussed in DOC L.2 while changes resulting from the incorporation of LCO 3.0.6 are discussed in DOC A.3.

ITS LCO 3.0.1 includes a statement that exceptions to ITS LCO 3.0.1 are provided in LCO 3.0.2 and LCO 3.0.7. ITS LCO 3.0.2 describes the appropriate actions to be taken when ITS LCO 3.0.1 is not met. LCO 3.0.7 describes Test Exception LCOs, which are exceptions to other LCOs.

This change is acceptable because adding the exception for LCO 3.0.2 and LCO 3.0.7 prevents a conflict within the Applicability section. This addition is needed for consistency in the ITS requirements and does not change the intent or application of the Technical Specifications. Changes resulting from the incorporation of LCO 3.0.2 are discussed in DOC A.2 while changes resulting from the incorporation of LCO 3.0.7 are discussed in DOC A.4.

These changes are designated administrative because they are editorial and result in no technical changes to the Technical Specifications.

A.3 ITS LCO 3.0.6 is added to the CTS to provide guidance regarding the appropriate ACTIONS to be taken when a single inoperability (a support system) also results in the inoperability of one or more related systems (supported system(s)). LCO 3.0.6 states "When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered.

Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2." Inthe CTS, based on the intent and interpretation provided by the NRC over the years, there has been an ambiguous approach to the combined support/supported inoperability. Some of this history is summarized below:

Guidance provided in the June 13, 1979, NRC memorandum from Brian K. Grimes (Assistant Director for Engineering and Projects) to Samuel E.

Bryan (Assistant Director for Field Coordination) would indicate an intent/interpretation consistent with the proposed LCO 3.0.6, without the Monticello Page 2 of 13 Attachment 1, Volume 5, Rev. 0, Page 12 of 63

Attachment 1, Volume 5, Rev. 0, Page 13 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY necessity of also requiring additional ACTIONS. That is, only the inoperable support system ACTIONS need be taken.

Guidance provided by the NRC in their April 10, 1980, letter to all Licensees, regarding the definition of OPERABILITY and its impact as a support system on the remainder of the CTS, would indicate a similar philosophy of not taking ACTIONS for the inoperable supported equipment. However, in this case, additional actions (similar to the proposed Safety Function Determination Program actions) were addressed and required.

.

Generic Letter 91-18 and a plain-English reading of the CTS provide an F interpretation that inoperability, even as a result of a Technical Specification support system inoperability, requires all associated ACTIONS to be taken.

Certain CTS'contain ACTIONS such as "Declare the {supported system) inoperable and take the ACTIONS of {its Specification)." In many cases, the supported system would likely already be considered inoperable. The implication of this presentation is that the ACTIONS of the inoperable supported system would not have been taken without the specific direction to do so.

Considering the history of misunderstandings in this area, the BWR/4 ISTS, NUREG-1433, Rev. 3, was developed with Industry input and approval of the NRC to include LCO 3.0.6 and a new program, Specification 5.5.10, "Safety Function Determination Program (SFDP)." This change is acceptable since its function is to clarify existing ambiguities and to maintain actions within the realm of previous interpretations. This change is designated as administrative because it does not technically change the Technical Specifications.

A.4 ITS LCO 3.0.7 is added to the CTS. LCO 3.0.7 states "Special Operations LCOs in Section 3.10 allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications." This changes the CTS by adding specific guidance concerning the use of special test exception type LCOs.

The purpose of ITS LCO 3.0.7 is to provide guidance on the use of Special Operations LCOs. This change is acceptable because the CTS contain test exception Specifications (CTS 3.10.A and CTS 3.10.E) that allow certain LCOs to not be met for the purpose of special tests and operations. However, the CTS does not contain the equivalent of ITS LCO 3.0.7. As a result, there could be confusion regarding which LCOs are applicable during special tests and operations. LCO 3.0.7 was crafted to avoid that possible confusion. LCO 3.0.7 is consistent with the use and application of CTS test exception Specifications Monticello Page 3 of 13 Attachment 1, Volume 5, Rev. 0, Page 13 of 63

Attachment 1, Volume 5, Rev. 0, Page 14 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY and does not provide any new restriction or allowance. This change is designated as administrative because it does not technically change the Technical Specifications.

A.5 CTS 4.0.A states 'The surveillance requirements of this section shall be met.

Each surveillance requirement shall be performed at the specified times except as allowed in B and C below." CTS 4.0.C states, in part, "Whenever the plant condition is such that a system or component is not required to be operable the surveillance testing associated with that system or component may be discontinued." CTS 4.0.0 states "If it is discovered that a surveillance was not performed within the extended time interval allowed by 4.0.B, then the affected equipment shall be declared inoperable." ITS SR 3.0.1 states "SRs shall be met during the MODES or other specified conditions In the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.

Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits." The changes to the CTS are:

CTS 4.0.A states, in part, "The surveillance requirements of this section shall be met." CTS 4.0.A also states, in part, "Each surveillance requirement shall be performed at the specified times except as allowed in ... C below."

CTS 4.0.C states "Whenever the plant condition is such that a system or component is not required to be operable the surveillance testing associated with that system or component may be discontinued." The first sentence of ITS SR 3.0.1 states "SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR." This changes the CTS by combining the two CTS requirements into a single cogent requirement.

This change is acceptable because the requirements are identical. ITS SR 3.0.1 and CTS 4.0.A both state that SRs shall be met. ITS SR 3.0.1 also states when the SRs are required to be met (i.e., during the MODES or other specified conditions in the Applicability), while CTS 4.0.C states when SRs are not required to be met. This change combines the requirements of CTS 4.0.C with CTS 4.0.A (ITS SR 3.0.1) and describes the requirements in a positive way. In the ITS, certain SRs may not be required to be met in all MODES or conditions specified in the Applicability therefore, the phrase "unless otherwise stated" has been added. Changes to the Applicability of any SR will be discussed in the Discussion of Changes for the applicable ITS LCO.

The second sentence of ITS SR 3.0.1 includes the statement, "Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO." This changes the CTS by adding the clarification "whether such failure is experienced during the Monticello Page 4 of 13 Attachment 1, Volume 5, Rev. 0, Page 14 of 63

Attachment 1, Volume 5, Rev. 0, Page 15 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY performance of the Surveillance or between performances of the Surveillance."

This change is acceptable because it is consistent with the current use and application of the Technical Specifications.

CTS 4.0.A states, in part, "Each surveillance requirement shall be performed at the specified times except as allowed in B ... below." CTS 4.0.D states "If it is discovered that a surveillance was not performed within the extended time interval allowed by 4.0.B, then the affected equipment shall be declared inoperable." The third sentence of ITS SR 3.0.1 states "Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3." This changes the CTS by replacing the CTS phrases "except as allowed in B ... below" and "within the extended time interval allowed by 4.0.B" with the ITS phrase "within the specified Frequency" and the CTS statement "then the affected equipment shall be declared inoperable" with the ITS statement "shall be failure to meet the LCO." In addition, a reference to ITS SR 3.0.3 (CTS 4.0.E) has been added.

The CTS is also changed by combining CTS 4.0.A and CTS 4.0.D.

The change associated with the replacement of the phrases "except as allowed by B ... below" and "within the extended time interval allowed by 4.0.B" is acceptable because the words "specified Frequency" imply that the allowance of CTS 3.0.B (ITS SR 3.0.2) still applies and the explicit reference to it not needed. The change associated with the replacement of the phrase "then the affected equipment shall be declared inoperable" with "shall be failure to meet the LCO" is acceptable because the intent of the CTS requirement has not changed. 'This change also provides the clarification "except as provided in SR 3.0.3." This change Is acceptable since CTS 4.0.E (ITS SR 3.0.3) currently references CTS 4.0.B via a reference to CTS 4.0.D.

Therefore this change simply places the reference in the proper location. The change associated with combining CTS 4.0.D with CTS 4.0.A is acceptable since the requirements are related to one another and their discussion in one Specification is more appropriate.

These changes are acceptable and designated administrative because they move and clarify information within the Technical Specifications.

A.6 CTS 4.0.B states, in part, "Specific time intervals between tests may be extended up to 25% of the'surveillance interval." ITS SR 3.0.2 states "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as "once," the above interval extension does not apply. If a Completion Time requires periodic performance on a "once per. . ." basis, the above Frequency extension applies to each performance after the initial performance. Exceptions to this Specification are stated in the individual Specifications." This results in several changes to the CTS.

Monticello Page 5 of 13 Attachment 1, Volume 5, Rev. 0, Page 15 of 63

Attachment 1, Volume 5, Rev. 0, Page 16 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY

ITS SR 3.0.2 adds to the CTS "For Frequencies specified as 'once,' the above interval extension does not apply." This change is described in DOC M.2.

ITS SR 3.0.2 adds to the CTS "If a Completion Time requires periodic performance on a "once per. . .".basis, the above Frequency extension applies to each performance after the initial performance." This is described in DOC L.3.

CTS 4.0.B states, in part, "Specific time intervals between tests may be extended up to 25% of the surveillance interval." ITS SR 3.0.2 states, in part, "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency." This change to the CTS is made to be consistent with the ITS terminology and to clarify the concept of the specified SR Frequency being met.

The change is acceptable since it does not change the intent of the requirements.

ITS SR 3.0.2 is also more specific regarding the start of the Frequency by stating "as measured from the previous performance or as measured from the time a specified condition of the Frequency is met." This direction is consistent with the current use and application of the Technical Specifications.

This change is acceptable because the ITS presentation has the same intent as the CTS requirement.

ITS SR 3.0.2 adds to the CTS the statement "Exceptions to this Specification are stated in the individual Specifications."

This change is acceptable because it reflects practices used in the ITS that are not used in the CTS. Any changes to aTechnical Specification, by inclusion of such an exception, will be addressed in the affected Technical Specification.

These changes are designated as administrative because they reflect presentation and usage rules of the ITS without making technical changes to the Technical Specifications.

A.7 These changes to CTS 4.0.B 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 does not include any general LCOIACTION guidance requirements.

ITS LCO 3.0.3 is added to the CTS to provide guidance when an LCO is not met Monticello Page 6 of 13 Attachment 1, Volume 5, Rev. 0, Page 16 of 63

Attachment 1, Volume 5, Rev. 0, Page 17 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS. ITS LCO 3.0.3 states "When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in: a. MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ; b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and c.

MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3." This changes the CTS by adding ITS LCO 3.0.3.

The purpose of ITS LCO 3.0.3 is to ensure a set of actions exists for all plant conditions when an LCO is not met. This change is acceptable since it provides the appropriate actions to take under certain conditions. These conditions are an associated Required Action and Completion Time Is not met and no other Condition applies or the condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately. This Specification also delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Upon entering LCO 3.0.3. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs: a. The LCO is now met; b.A Condition exists for which the Required Actions have now been performed; or c. ACTIONS exist that do not have expired Completion Times. The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation.

In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. The ITS LCO 3.0.3 Bases describes examples for this situation. This change is designated as more restrictive because explicit requirements have been included in the Technical Specifications to cover conditions not currently addressed in the CTS.

Monticello Page 7 of 13 Attachment 1, Volume 5, Rev. 0, Page 17 of 63

Attachment 1, Volume 5, Rev. 0, Page 18 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY M.2 CTS 4.0.B states, in part, "Specific time intervals between tests may be extended up to 25% of the surveillance interval." ITS SR 3.0.2 includes a similar requirement, but adds the following restriction: "For Frequencies specified as "once," the above interval extension does not apply." This changes the CTS by adding a restriction that Frequencies specified as "once' do not receive a 25%

extension.

The purpose of the 1.25 extension allowance to Surveillance Frequencies is to allow for flexibility in scheduling tests. This change is acceptable because Frequencies specified as "once" are typically condition-based one-time only Surveillances in which the performance demonstrates the acceptability of the current condition and are not required to be repeated until the condition again applies. Such demonstrations should be accomplished within the specified Frequency without extension in order to avoid operation in unacceptable conditions. This change is designated as more restrictive because-an allowance to extend Frequencies by 25% is eliminated from some Surveillances.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.0.B states that the purpose of the 25%

extension of the specified surveillance interval is "to accommodate normal test schedule." ITS SR 3.0.2 does not include this detail. This changes the CTS by moving details of the purpose of the 25% surveillance time interval extension from the CTS to the ITS Bases.

The removal of these details for meeting TS requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement that the specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency. Also, this change is acceptable because these types of procedural details 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 procedural details for meeting Technical Specification requirements are being removed from the CTS.

LESS RESTRICTIVE CHANGES L.1 The CTS does not include any general LCO/ACTION guidance requirements.

However, CTS 3.6.D.2 provides an explicit allowance that entry into a MODE is allowed when either a drywell floor drain sump monitoring system or the drywell Monticello Page 8 of 13 Attachment 1, Volume 5, Rev. 0, Page 18 of 63

Attachment 1, Volume 5, Rev. 0, Page 19 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY particulate radioactivity monitoring system is inoperable. Thus, it is implicit that for all other Specifications, entry into a MODE or other specified condition in the Applicability of a Specification is not allowed. 'ITS LCO 3.0.4 is added to provide guidance when an LCO is not met and entry into a MODE or other specified condition in the Applicability is desired. ITS LCO 3.0.4 states "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made: a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or c.

When an allowance is stated in the individual value, parameter, or other Specification. This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit." This changes the CTS by providing explicit guidance for entry into a MODE or other specified condition in the Applicability when an LCO is not met.

The purpose of LCO 3.0.4 is to provide guidance when an LCO is not met and entry into a MODE or other specified condition in the Applicability is desired. The change is acceptable because LCO 3.0.4 provides the appropriate guidance to enter the Applicability when an LCO is not met. LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 Monticello Page 9 of 13 Attachment 1, Volume 5, Rev. 0, Page 19 of 63

Attachment 1, Volume 5, Rev. 0, Page 20 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components. The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented. The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable. These systems are the High Pressure Coolant Injection System, Reactor Core Isolation Cooling System, and emergency diesel generators (ITS 3.5.1, ITS 3.5.3, and ITS 3.8.1, respectively). LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable.

These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components.

For this reason, LCO 3.0.4.c is typically applied to Specifications that describe values and parameters. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to.

comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, Monticello Page 10 of 13 Attachment 1, Volume 5, Rev. 0, Page 20 of 63

Attachment 1, Volume 5, Rev. 0, Page 21 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY until the LCO is met, or until the unit is not within the Applicability of the Technical Specifications. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO. This change is designated as less restrictive because entry into MODES or other specified conditions in the Applicability of a Specification might be made with an LCO not met as long as the plant is in compliance with LCO 3.0.4.

L.2 ITS LCO 3.0.5 has been added to establish allowances for restoring equipment to service. ITS LCO 3.0.5 states "Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY." This changes the CTS by adding the explicit allowance stated in LCO 3.0.5.

The purpose of LCO 3.0.5 isto establish an allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The change is acceptable since its sole purpose is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate: a. The OPERABILITY of the equipment being returned to service; or b. The OPERABILITY of other equipment. The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. Many Technical Specification ACTIONS require an inoperable component to be removed from service, such as maintaining an isolation valve closed, disarming a control rod, or tripping an inoperable instrument channel. To allow the performance of Surveillance Requirements to demonstrate the OPERABILITY of the equipment being returned to service, or to demonstrate the OPERABILITY of other equipment or variables within limits, which otherwise could not be performed without returning the equipment to service, an exception to these Required Actions is necessary. ITS LCO 3.0.5 is necessary to establish an allowance that, although informally utilized in restoration of inoperable equipment, is not formally recognized in the CTS. Without this allowance, certain components could not be restored to OPERABLE status and a plant shutdown would ensue. Clearly, it is not the intent or desire that the Technical Specifications preclude the return to service of a suspected OPERABLE component to confirm its OPERABILITY.

This allowance is deemed to represent a more stable, safe operation than requiring a plant shutdown to complete the restoration and confirmatory testing.

This change is designated as less restrictive because LCO 3.0.5 will allow the restoration of equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS.

Monticello Page 11 of 13 Attachment 1, Volume 5, Rev. 0, Page 21 of 63

Attachment 1, Volume 5, Rev. 0, Page 22 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY L.3 CTS 4.0.B states, in part, "Specific time intervals between tests may be extended up to 25% of the surveillance interval." ITS SR 3.0.2 includes a similar requirement, but adds the following: "If a Completion Time requires periodic performance on a "once per:.." basis, the above Frequency extension applies to each performance after the initial performance." This changes the CTS by adding an allowance that if a Required Action's Completion Time requires periodic performance on a "once per. . ." basis, the 25% Frequency extension applies to each performance after the initial performance.

This change is acceptable because the 25% Frequency extension given to provide scheduling flexibility for Surveillances is equally applicable to Required Actions that must be performed periodically. The initial performance is excluded because the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Completion Time without extension in order to avoid operation in unacceptable conditions. This change is designated as less restrictive because additional time is provided to perform some periodic Required Actions.

L.4 CTS 4.0.C states "Discontinued surveillance tests shall be resumed less than one test interval before establishing plant conditions requiring operability of the associated system or component." ITS SR 3.0.4 states "Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit." This changes the CTS by allowing a discontinued Surveillance (a Surveillance discontinued due to being outside the Applicability of the LCO) to be met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. This also changes the CTS by allowing a change in MODES or other specified conditions in the Applicability when a Surveillance is not current, provided the change in MODES or other specified conditions in the Applicability are allowed by LCO 3.0.4, are required to comply with ACTIONS, or are part of a shutdown of the unit.

The purpose of CTS 4.0.C is to ensure that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the plant. This change allowing use of the 25% Frequency extension allowance prior to changes in MODES or other specified conditions in the Applicability is acceptable because the 25%

Frequency extension given to provide scheduling flexibility for-Surveillances is equally applicable to discontinued Surveillance tests. The acceptability of a Surveillance test should not be affected by plant conditions. If the unit is operating, CTS 3.0.B (ITS SR 3.0.2) considers a Surveillance to be acceptable if the Surveillance is performed within 1.25 times the interval specified in the Frequency. The OPERABILITY of a system is normally not affected by plant Monticello Page 12 of 13 Attachment 1, Volume 5, Rev. 0, Page 22 of 63

Attachment 1, Volume 5, Rev. 0, Page 23 of 63 DISCUSSION OF CHANGES ITS SECTION 3.0, LCO AND SR APPLICABILITY conditions; therefore this change is appropriate and acceptable. The change that allows a change in MODES or other specified conditions in the Applicability when a Surveillance is not current, provided the change in MODES or other specified conditions in the Applicability are allowed by LCO 3.0.4, is acceptable because LCO 3.0.4 provides the proper guidance to enter the Applicability of an LCO when the LCO's Surveillance are not performed. Furthermore, failure to perform the Surveillance does not necessarily mean that the affected system or component is inoperable; just that it has not been demonstrated OPERABLE.

The change that allows a change in MODES or other specified conditions in the Applicability when a Surveillance is not current, provided the change in MODES or other specified conditions in the Applicability is required to comply with ACTIONS or are a part of a shutdown of the unit is also acceptable. Normal shutdowns may be shutdowns required by Technical Specifications that are commenced early (e.g., prior to the absolutely, required shutdown, such as day 2 of an allowed 7 day Completion Time) or shutdowns for other purposes such as refueling. Normal shutdowns would typically be performed with a full complement of OPERABLE safety systems consistent with the Bases of ITS LCO 3.0.4, which states "The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability." The addition of the allowance to perform a normal shutdown while relying on ACTIONS is appropriate because the Technical Specifications contain appropriate controls to ensure the safety of the unit in these conditions. As the unit transitions to lower MODES, less equipment is required to be OPERABLE. In addition, the Technical Specifications themselves are actually forcing the unit shutdown due to inoperability of safety system equipment, thus the shutdown should not be delayed just to perform routine, required Surveillances of other Technical Specification required equipment that is not otherwise known to be inoperable.

This change is designated as less restrictive because changes in MODES or other specified conditions of the Applicability will be allowed under more conditions if a Surveillance is not current and will allow use of the 25%

Frequency extension allowed under more conditions.

Monticello Page 13 of 13 Attachment 1, Volume 5, Rev. 0, Page 23 of 63

Attachment 1, Volume 5, Rev. 0, Page 24 of 63 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 5, Rev. 0, Page 24 of 63

Attachment 1, Volume 5, Rev. 0, Page 25 of 63 LCO Applicability 3.0 CTS 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY DOC LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the A.2 Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.

DOC LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the A.2 associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

DOC LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an M.1 associated ACTION is not provided; or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 2 within 7M hoursg 0

b. MODE 3 within 13 ho3ur

c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

-0 Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1,2, and 3.

-_C11CtAr-D0 KnN ------- JvTF The bra ets around the time ovided to reach MOD 2 allow a plant to extend e time from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months a plant specific time. Before the time can be ch ged, plant specific d a must be provided to/support the extended 0

time.

DOC LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition Li in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; BWR/4 STS 3.0-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 25 of 63

Attachment 1, Volume 5, Rev. 0, Page 26 of 63 LCO Applicability 3.0 CTs LCO Applicability DOC LCO 3.0.4 (continued)

Li

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications3 or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

DOC LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

DoC LCO 3.0.6 When a supported system LCO is not met solely due to a support system A@3 LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.wl"Safety Function s Determination Program (SFDP)." If a loss of safety function Is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

BWR/4 STS 3.0-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 26 of 63

Attachment 1, Volume 5, Rev. 0, Page 27 of 63 LCO Applicability 3.0 LCO Applicability DOC AA4 LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of, special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met.

When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.

BWR/4 STS 3.0-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 27 of 63

Attachment 1, Volume 5, Rev. 0, Page 28 of 63 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 4.OA. SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the 4.0.C, 4.0.0 Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.B SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per. ..

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

4.0.E SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

4.0.C SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

BWR14 STS 3.0-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 28 of 63

Attachment 1, Volume 5, Rev. 0, Page 29 of 63 SR Applicability 3.0 SR Applicability 4.O.C SR 3.0.4 (continued)

This provision shall not prevent entry Into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

BWR/4 STS 3.0-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 29 of 63

Attachment 1, Volume 5, Rev. 0, Page 30 of 63 JUSTIFICATION FOR DEVIATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY

1. The brackets have been removed and the proper plant specific information/value has been 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. The Reviewer's Note is deleted as it is not part of the plant specific ITS.

4. Changes have been made to reflect changes in other Specifications.

Monticello Page 1 of 1 Attachment 1, Volume 5, Rev. 0, Page 30 of 63

Attachment 1, Volume 5, Rev. 0, Page 31 of 63 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 5, Rev. 0, Page 31 of 63

Attachment 1, Volume 5, Rev. 0, Page 32 of 63 LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.7 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated. nSections 3.1 through 3.10 0 LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Completing the Required Actions is not required when an LCO is met or Is no longer applicable, unless otherwise stated in the individual Specifications.

BWR/4 STS B 3.0-1 Rev. 3.0, 03131/04 Attachment 1, Volume 5, Rev. 0, Page 32 of 63

Attachment 1, Volume 5, Rev. 0, Page 33 of 63 LCO Applicability B 3.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Re uired Actions where this is the case. An example of this is in LCO 3.4.tIW"RCS Pressure and Temperature (PIT) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.

Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered.

Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a. An associated Required Action and Completion Time is not met and no other Condition applies or BWR/4 STS B 3.0-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 33 of 63

Attachment 1, Volume 5, Rev. 0, Page 34 of 63 LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)

b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.> @

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited If any of the following occurs:

a. The LCO is now met1

b. A Condition exists for which the Required Actions have now been performed or

c. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

BWR/4 STS B 3.0-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 34 of 63

Attachment 1, Volume 5, Rev. 0, Page 35 of 63 LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)

The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE applies. If a lower MODE is reached in less time than allowed, however, the total allowable time to reach MODE 4, or other applicable MODE, is not reduced. For example, if MODE 2 is reached in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for reaching MODE 3 is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for reaching MODE 3 is not reduced from the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reach a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictivegondition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability 0

(unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided In instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.8, "Spent Fuel Storage Pool Water Level." LCO 3.7.8 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.8 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained lacin the unit in a shutdown condition. The Required Action of LCO 3.7.8 "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability ;, the Applicability desired to be entered) when unitjrD @

conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

BWRI4 STS B 3.0-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 35 of 63

Attachment 1, Volume 5, Rev. 0, Page 36 of 63 LCO Applicability.

B 3.0 BASES LCO 3.0.4 (continued)

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria In place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, uAssessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

BWR/4 STS B 3.0-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 36 of 63

Attachment 1, Volume 5, Rev. 0, Page 37 of 63 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically ap to Primary Specifications which describe values and parameters (e.g., rontainment Air Temperature, C nment Pre MCPC , Mo era m erature cn and may be applied to othe Specifications based on NRC plant specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

BWR/4 STS B 3.0-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 37 of 63

Attachment 1, Volume 5, Rev. 0, Page 38 of 63 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.

Upon entry into a MODE or other specified condition in the Applicabilit e3 with the LCO not mEat, LCO 3.0.1 LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specifications.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a. The OPERABILITY of the equipment being returned to service or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance.

ra An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening acontainment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.

BWRI4 STS B 3.0-7 Rev. 3.0, 03/31/04 Aftachment 1, Volume 5, Rev. 0, Page 38 of 63

Attachment 1, Volume 5, Rev. 0, Page 39 of 63 LCO Applicability B 3.0 BASES LCO 3.0.5 (continued)

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception isjustified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support system LCO's Required Actions. These Required Actions may include entering the supported systenft Conditions and Required Actions or may specify other Required Actions.

0 When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable Ifdetermined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and Inconsistency of requirementjelated to the entry into multiple support and supported systems' LCOM Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the 0D plant is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared Inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

BWR/4 STS B 3.0-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 39 of 63

Attachment 1, Volume 5, Rev. 0, Page 40 of 63 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)

Specification 5.5. "Safety Function Determination Program (SFDP),"

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross division checks to identify a loss of safety function for those support systems that support safety systems are required. The cross division.

check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. I A loss of safety function may exist when a support system is inoperable, and:

0

a. A required system redundant to system(s) supported by the inoperable support system is also inoperable (EXAMPLE B 3.0.6-1)

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable (EXAMPLE B 3.0.6-2jor

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable (EXAMPLE B 3.0.6-3).

EXAMPLE B 3.0.6-1 0D If System 2 of ,arinA is inoperable and System 5 of r B is inoperable, a loss of safety function exists in supported System 5.

EXAMPLE B 3.0.6-2 0 If System 2 of T i A is inoperable, and System 11 of Gin B is inoperable, a loss of safety function exists in System 11 which is in turn supported by System 5.

EXAMPLE B 3.0.6-3 0 If System 2 of A is inoperable, and System 1 of r i B is Inoperable, a loss of safety function exists in Systems 2, 4, 5, 8,910 and 11.0 0 BWR/4 STS B 3.0-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 40 of 63

Attachment 1, Volume 5, Rev. 0, Page 41 of 63 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)

If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

Se Itu a- a 5w<+^m v System 4 m System 9 Systemn 9 System 2 System 2

vetm an - aIn move to end of System 5 System ' mS1 section system ii System 11t System I System 1 0 System 12 System 12 System S System 6 System 13 System 13 System 3 System 3 System 14 System 14 System 7 Syst m 7 System is System IS l Figure B 3.0-1 Configuration of r I and Systems u 0D This loss of safety function does not require the assumption of additional single failures or loss of offsite power. Since operations Go restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken into account. Similarly, the ACTIONS for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the definition of OPERABILITY).

BWR/4 STS B 3.0-1 0 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 41 of 63

Attachment 1, Volume 5, Rev. 0, Page 42 of 63 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)

When loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately addressEthe inoperabilities of that system without reliance on entering (

its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.

LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.

Special Operations LCOs in Section 3.10 allow specified TS requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special

,test or operation will remain in effect.

The Applicability of a Special Operations LCO represents a condition not necessarily in compliance with the normal requirements of the TS.

Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO ACTIONS may direct the other LCdfACTIONS be met. The Surveillances of the other LCO are not required to be met, unless 0

specified in the Special Operations LCO. If conditions exist such that the INSERT from page Applicability of any other LCO is met, all the other LCO's requirements B 3.0-10 (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO. 0 BWR/4 STS B 3.0-11 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 42 of 63

Attachment 1,Volume 5, Rev. 0, Page 43 of 63 SR Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specificationsyand apply at all times, unless otherwise stated.

n [i-n~e-rions 3.1 through 3.1J SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must be met during the MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified Frequency, in accordance with SR 3.0.2, constitutes a failure to meet an LCO. Surveillances may be performed by means of any series of sequential, overlapping, or total steps provided the entire Surveillance is performed within the specified Frequency. Additionally, the definitions related to instrument testing (e.g., CHANNEL CALIBRATION) specify that these tests are performed by means of any series of sequential, overlapping, or total steps.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the SRs or

b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

Surveillances do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified. The SRs associated with a Special Operations LCO are only applicable when the Special Operations LCO is used as an allowable exception to the requirements of a Specification.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this case, the unplanned event may be credited as fulfilling the performance of the S.lTi loac Lincludes tho!sd SRs whose performance ig(normally prcue nagie IMODE or othier specified condition]

BWR/4 STS B 3.0-12 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 43 of 63

Attachment 1,Volume 5, Rev. O,Page 44 of 63 SR Applicability B 3.0 BASES SR 3.0.1 (continued)

Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are:

a. Control Rod Drive maintenance during refueling that requires scram testing at > j800 pg However, if other appropriate testing is satisfactorily completed an e scram time testing of SR 3.1.4.3 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reachJ800 psijto perform other necessary testing.

b. High pressure coolant injection (HPCI) maintenance during shutdown that requires system functional tests at a specified pressure.

Provided other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..." interval.

SR 3.0.2 permits a 25% extension of the Interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).

BWR/4 STS B 3.0-13 Rev. 3.0, 03/31/04 Attachment 1,Volume 5, Rev. 0, Page 44 of 63

Attachment 1, Volume 5, Rev. 0, Page 45 of 63 SR Applicability B 3.0 BASES SR 3.0.2 (continued)

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example of where SR 3.0.2 does-not apply is in the Primary Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Cormipletion Time-that requires performance on a "once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

BWR/4 STS B 3.0-14 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 45 of 63

Attachment 1, Volume 5, Rev. 0, Page 46 of 63 SR Applicability B 3.0 BASES SR 3.0.3 (continued)

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through

-the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NM Regulatory Guide 1.182, uAssessing and 8 Managing Risk Before Maintenance Activities at Nuclear Power Plants."

This Regulatory Guide addresses consideration of temporary and BWR/4 STS B 3.0-15 Rev. 3.0, 03/31/04 Attachment 1,Volume 5, Rev. 0, Page 46 of 63

Attachment 1, Volume 5, Rev. 0, Page 47 of 63 SR Applicability B 3.0 BASES SR 3.0.3 (continued) aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to a Surveillance not being met in accordance with LCO 3.0.4.

BWRI4 STS B 3.0-16 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 47 of 63

Attachment 1, Volume 5, Rev. 0, Page 48 of 63 SR Applicability B 3.0 BASES SR 3.0.4 (continued)

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change.

When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states thatfurveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE I to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met.

Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4,tFrequency. v BWR/4 STS B 3.0-17 Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 48 of 63

Attachment 1, Volume 5, Rev. 0, Page 49 of 63 JUSTIFICATION FOR DEVIATIONS ITS SECTION 3.0 BASES, LCO AND SR APPLICABILITY

1. The LCO and SR Applicability only apply to Specifications in Sections 3.1 through 3.10; they do not apply to Specifications in Chapters 4.0 and 5.0, unless specifically stated in the individual Specification. Therefore, this statement has been added for clarity.

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 brackets have been removed and the proper plant specific information/value has been provided.

5. The Bases are changed to reflect the terminology in the definition of OPERABLE-OPERABILITY.

6. The Figure has been moved to the end of the Section, consistent with the format of the ITS.

7. The ITS SR 3.0.3 Bases allows credit to be taken for unplanned events that satisfy Surveillances. The Bases further states that this allowance also includes those SRs whose performance is normally precluded in a given MODE or other specified condition. This portion of the allowance has been deleted. As documented in Part 9900 of the NRC Inspection Manual, Technical Guidance - Licensee Technical Specifications Interpretations, and in the Bases Control Program (ITS 5.5.10), neither the Technical Specifications Bases nor Licensee generated interpretations can be used to change the Technical Specification requirements. Thus, if the Technical Specifications preclude performance of an SR in certain MODES (as is the case for some SRs in ITS Section 3.8), the Bases cannot change the Technical Specifications requirement and allow the SR to be credited for being performed in the restricted MODES, even if the performance is unplanned.

8. Changes have been made for consistency with similar discussions/terminology in the Bases.

9. Changes have been made to reflect changes in other Specifications.

Monticello Page 1 of 1 Attachment 1, Volume 5, Rev. 0, Page 49 of 63

Attachment 1, Volume 5, Rev. 0, Page 50 of 63 Specific No Significant Hazards Considerations (NSHCs)

I4 Attachment 1, Volume 5, Rev. 0, Page 50 of 63

Attachment 1, Volume 5, Rev. 0, Page 51 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY 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 3/4.0 does not include any general LCO/ACTION guidance requirements. However, CTS 3.6.D.2 provides an explicit allowance that entry into a MODE is allowed when either a drywell floor drain sump monitoring system or the drywell particulate radioactivity monitoring system is inoperable. Thus, it is implicit that for all other Specifications, entry into a MODE or other specified condition in the Applicability of a Specification is not allowed. ITS LCO 3.0.4 is added to provide guidance when an LCO is not met and entry into a MODE or other specified condition in the Applicability is desired. ITS LCO 3.0.4 states "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made: a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or c. When an allowance is stated in the individual value, parameter, or other Specification. This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit." This changes the CTS by providing explicit guidance for entry into a MODE or other specified condition in the Applicability when an LCO is not met.

The purpose of LCO 3.0.4 is to provide guidance when an LCO is not met and entry into a MODE or other specified condition in the Applicability is desired. The change is acceptable because LCO 3.0.4 provides the appropriate guidance to enter the Applicability when an LCO is not met. LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability-when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk Monticello Page 1 of 13 Attachment 1, Volume 5, Rev. 0, Page 51 of 63

Attachment 1, Volume 5, Rev. 0, Page 52 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take Into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."

Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable.

NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components. The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions.

The LCO 3.0.4.b risk assessments do not have to be documented. The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable. These systems are the High Pressure Coolant Injection System, Reactor Core Isolation Cooling System, and emergency diesel generators (ITS 3.5.1, ITS 3.5.3, and ITS 3.8.1, respectively). LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications that describe values and parameters. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit Monticello Page 2 of 13 Attachment 1, Volume 5, Rev. 0, Page 52 of 63

Attachment 1, Volume 5, Rev. 0, Page 53 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specifications. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for Surveillances that have not been performed on inoperable equipment.

However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO. This change is designated as less restrictive because entry into MODES or other specified conditions in the Applicability of a Specification might be made with an LCO not met as long as the plant is in compliance with LCO 3.0.4.

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 provides explicit guidance for entry into a MODE or other specified condition in the Applicability when an LCO is not met. If the inoperability of a component or variable could increase the probability of an accident previously evaluated, the corresponding ACTIONS would not allow operation in that condition for an unlimited period of time; the risk assessment will not allow entry into the condition, and an allowance will not be provided in accordance with LCO 3.0.4. As a result, the probability of an accident previously evaluated is not significantly affected by this change. ACTIONS which allow operation for an unlimited period of time with an inoperable component or variable provide compensatory measures that protect the affected safety function, including any mitigation actions assumed in accidents previously evaluated. For example, inoperable isolation valves are closed or inoperable instrument channels are placed in trip. Since the affected safety functions continue to be protected, the mitigation functions of the component or variable continue to be performed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment.

Therefore, entry will not be allowed if there is a loss of safety functions. Finally a Note permits the use of the provisions of LCO 3.0.4.c in LCO 3.4.5, 'RCS Leakage Detection Instrumentation," and LCO 3.4.6, "RCS Specific Activity."

This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. This allowance is acceptable for LCO 3.4.5 as documented in the NRC safety evaluation for Technical Specification Amendment 137, dated August 21, 2003 and for LCO 3.4.6 due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions. As a result, the consequences of any accident previously Monticello Page 3 of 13 Attachment 1, Volume 5, Rev. 0, Page 53 of 63

Attachment 1, Volume 5, Rev. 0, Page 54 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY evaluated are not increased significantly. 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 allows entering a MODE or other specified condition in the Applicability when the allowances of LCO 3.0.4 are met. 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 in that operation of the unit while complying with ACTIONS is common. 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 allows entering a MODE or other specified condition in the Applicability when the allowances of LCO 3.0.4 are met. This change will allow unit operation in MODES or other specified conditions in the Applicability while relying on ACTIONS that would have been previously prohibited. However, LCO 3.0.4 will only allow entry as long as the safety function is maintained. As a result, the margin of safety is not significantly affected. 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 4 of 13 Attachment 1, Volume 5, Rev. 0, Page 54 of 63

Attachment 1, Volume 5, Rev. 0, Page 55 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY 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.

ITS LCO 3.0.5 has been added to establish allowances for restoring equipment to service. ITS LCO 3.0.5 states "Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY." This changes the CTS by adding the explicit allowance stated in LCO 3.0.5.

The purpose of LCO 3.0.5 is to establish an allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The change is acceptable since its sole purpose is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate: a. The OPERABILITY of the equipment being returned to service; or b. The OPERABILITY of other equipment. The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY.

This Specification does not provide time to perform any other preventive or corrective maintenance. Many Technical Specification ACTIONS require an inoperable component to be removed from service, such as maintaining an isolation valve closed, disarming a control rod, or tripping an inoperable instrument channel. To allow the performance of Surveillance Requirements to demonstrate the OPERABILITY of the equipment being returned to service, or to demonstrate the OPERABILITY of other equipment or variables within limits, which otherwise could not be performed without returning the equipment to service, an exception to these Required Actions is necessary. ITS LCO 3.0.5 is necessary to establish an allowance that, although informally utilized in restoration of inoperable equipment, is not formally recognized in the CTS. Without this allowance, certain components could not be restored to OPERABLE status and a plant shutdown would ensue. Clearly, it is not the intent or desire that the Technical Specifications preclude the return to service of a suspected OPERABLE component to confirm its OPERABILITY. This allowance is deemed to represent a more stable, safe operation than requiring a plant shutdown to complete the restoration and confirmatory testing.

This change is designated as less restrictive because LCO 3.0.5 will allow the restoration of equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS.

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:

Monticello Page 5 of 13 Attachment 1, Volume 5, Rev. 0, Page 55 of 63

Attachment 1, Volume 5, Rev. 0, Page 56 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY

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 for restoring equipment to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. ITS LCO 3.0.5 is necessary to establish an allowance that, although informally utilized in restoration of inoperable equipment, is not formally recognized in the CTS.

Without this allowance, certain components could not be restored to OPERABLE status and a plant shutdown would ensue. Clearly, it is not the intent or desire that the Technical Specifications preclude the return to service of a suspected OPERABLE component to confirm its OPERABILITY. This allowance is deemed to represent a more stable, safe operation than requiring a plant shutdown to complete the restoration and confirmatory testing. 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 adds an allowance for restoring equipment to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This change will not physically alter the plant (no new or different type of equipment will be installed).

Also, the change does not involve 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 for restoring equipment to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY. of other equipment. The margin of safety is not affected by this change because without this allowance, certain components could not be restored to OPERABLE status and a plant shutdown would ensue.

ITS LCO 3.0.5 is necessary to establish an allowance that, although informally utilized in restoration of inoperable equipment, is not formally recognized in the CTS. Without this allowance, certain components could not be restored to OPERABLE status and a plant shutdown would ensue. Clearly, it is not the intent or desire that the Technical Specifications preclude the return to service of a suspected OPERABLE component to confirm its OPERABILITY. This allowance is deemed to represent a more stable, safe operation than requiring a plant shutdown to complete the restoration and confirmatory testing. Thus, the margin of safety impact is no different than that currently exists when equipment Monticello Page 6 of 13 Attachment 1, Volume 5, Rev. 0, Page 56 of 63

Attachment 1, Volume 5, Rev. 0, Page 57 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY is restored to service. 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 7 of 13 Attachment 1, Volume 5, Rev. 0, Page 57 of 63

Attachment 1, Volume 5, Rev. 0, Page 58 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY 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, 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 4.0.2 states, in part, "Specific time intervals between tests may be extended up to 25% of the surveillance interval." ITS SR 3.0.2 includes a similar requirement, but adds the following: "If a Completion Time requires periodic performance on a "once per. .

basis, the above Frequency extension applies to each performance after the initial performance." This changes the CTS by adding an allowance that if a Required Action's Completion Time requires periodic performance on a "once per. . ." basis, the 25%

Frequency extension applies to each performance after the initial performance.

This change is acceptable because the 25% Frequency extension given to provide scheduling flexibility for Surveillances is equally applicable to Required Actions that must be performed periodically. The initial performance is excluded because the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Completion Time without extension in order to avoid operation in unacceptable conditions. This change is designated as less restrictive because additional time is provided to perform some periodic Required Actions.

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 inthe probability or consequences of an accident previously evaluated?

Response: No.

The proposed change allows the Completion Time for periodic actions to be extended by 25%. This change does not affect the probability of an accident.

The length of time between performance of Required Actions is not an initiator to any accident previously evaluated. The consequences of any accident previously evaluated are the same during the Completion Time or during any extension of the Completion Time. As a result, the consequences of any accident previously evaluated are not increased. - Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

Monticello Page 8 of 13 Attachment 1, Volume 5, Rev. 0, Page 58 of 63

Attachment 1, Volume 5, Rev. 0, Page 59 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY The proposed change allows the Completion Time for periodic actions to be extended by 25%. This change will not physically alter the plant (no new or different type of equipment will be installed). Also, the change does not involve 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 ina margin of safety?

Response: No.

The proposed change allows the Completion Time for periodic actions to be extended by 25%. The 25% extension allowance is provided for scheduling convenience and is not expected to have a significant effect on the average time between Required Actions. As a result, the Required Actions will continue to provide appropriate compensatory measures for the subject Condition.

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 9 of 13 Attachment 1, Volume 5, Rev. 0, Page 59 of 63

Attachment 1, Volume 5, Rev. 0, Page 60 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L.4 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 4.0.C states "Discontinued surveillance tests shall be resumed less than one test interval before establishing plant conditions requiring operability of the associated system or component." ITS SR 3.0.4 states "Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit." This changes the CTS by allowing a discontinued Surveillance (a Surveillance discontinued due to being outside the Applicability of the LCO) to be met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. This also changes the CTS by allowing a change in MODES or other specified conditions in the Applicability when a Surveillance is not current, provided the change in MODES or other specified conditions in the Applicability are allowed by LCO 3.0.4, are required to comply with ACTIONS, or are part of a shutdown of the unit.

The purpose of CTS 4.0.C is to ensure that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the plant. This change allowing use of the 25% Frequency extension allowance prior to changes in MODES or other specified conditions in the Applicability is acceptable because the 25% Frequency extension given to provide scheduling flexibility for Surveillances is equally applicable to discontinued Surveillance tests. The acceptability of a Surveillance test should not be affected by plant conditions. If the unit is operating, CTS 3.0.B (ITS SR 3.0.2) considers a Surveillance to be acceptable if the Surveillance is performed within 1.25 times the interval specified in the Frequency. The OPERABILITY of a system is normally not affected by plant conditions; therefore this change is appropriate and acceptable. The change that allows a change in MODES or other specified conditions in the Applicability when a Surveillance is not current, provided the change in MODES or other specified conditions in the Applicability are allowed by LCO 3.0.4, is acceptable because LCO 3.0.4 provides the proper guidance to enter the Applicability of an LCO when the LCO's Surveillance are not performed. Furthermore, failure to perform the Surveillance does not necessarily mean that the affected system or component is inoperable; just that it has not been demonstrated OPERABLE. The change that allows a change in MODES or other specified conditions in the Applicability when a Surveillance is not current, provided the change in MODES or other specified conditions in the Applicability is required to comply with ACTIONS or are a part of a Monticello Page 10 of 13 Attachment 1, Volume 5, Rev. 0, Page 60 of 63

Attachment 1, Volume 5, Rev. 0, Page 61 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY shutdown of the unit is also acceptable. Normal shutdowns may be shutdowns required by Technical Specifications that are commenced early (e.g., prior to the absolutely required shutdown, such as day 2 of an allowed 7 day Completion Time) or shutdowns for other purposes such as refueling. Normal shutdowns would typically be performed with a full complement of OPERABLE safety systems consistent with the Bases of ITS LCO 3.0:4, which states "The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability." The addition of the allowance to perform a normal shutdown while relying on ACTIONS is appropriate because the Technical Specifications contain appropriate controls to ensure the safety of the unit in these conditions. As the unit transitions to lower MODES, less equipment is required to be OPERABLE. In addition, the Technical Specifications themselves are actually forcing the unit shutdown due to inoperability of safety system equipment, thus the shutdown should not be delayed just to perform routine, required Surveillances of other Technical Specification required equipment that is not otherwise known to be inoperable. This change is designated as less restrictive because changes in MODES or other specified conditions of the Applicability will be allowed under more conditions if a Surveillance is not current and will allow use of the 25% Frequency extension allowed under more conditions.

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 inthe probability or consequences of an accident previously evaluated?

Response: No.

The proposed change will allow a discontinued Surveillance (a Surveillance discontinued due to being outside the Applicability of the LCO) to be met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. This change also changes the CTS by allowing a change in MODES or other specified conditions in the Applicability when a Surveillance is not current, provided the change in MODES or other specified conditions in the Applicability are allowed by.

LCO 3.0.4, are required to comply with ACTIONS, or are part of a shutdown of the unit. Failure to perform the Surveillance does not necessarily mean that the affected system or component is inoperable; just that it has not been demonstrated OPERABLE. The length of time between performance of Surveillances Is not an initiator to any accident previously evaluated. The consequences of any accident previously evaluated are the same during the normal Surveillance interval not being met or during any extension of the Surveillance interval. This change will allow unit operation in MODES or other specified conditions in the Applicability while relying on ACTIONS that would have been previously prohibited. However, LCO 3.0.4 will only allow entry if the associated ACTIONS to be entered permit continued operation for an unlimited period of time, a risk evaluation is performed prior to entry into the MODE, or when specific analysis has been previously approved allowing entry. This Monticello Page 11 of 13 Attachment 1, Volume 5, Rev. 0, Page 61 of 63

Attachment 1, Volume 5, Rev. 0, Page 62 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY change also allows a change in MODES or other specified conditions in the Applicability when a Surveillance is not current provided entry is required to comply with ACTIONS or are part of a shutdown of the unit. Normal shutdowns would typically be performed with a full complement of OPERABLE safety systems consistent with the Bases of ITS LCO 3.0.4, which states "The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability." The addition of the allowance to perform a normal shutdown while relying on ACTIONS is appropriate because the Technical Specifications contain appropriate controls to ensure the safety of the unit in these conditions. These allowances are not considered to increase the probability of an accident previously evaluated or significantly increase the consequences of an accident previously evaluated since the failure to perform the Surveillance does not necessarily mean that the affected system or component is inoperable; just that it has not been demonstrated OPERABLE. 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 will allow a discontinued Surveillance (a Surveillance discontinued due to being outside the Applicability of the LCO) to be met if the Surveillance is performed within 1.25 times the Interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency Is met. This change also changes the CTS by allowing a change in MODES or other specified conditions in the Applicability when a Surveillance is not current, provided the change in MODES or other specified conditions in the Applicability are allowed by LCO 3.0.4, are required to comply with ACTIONS, or are part of a shutdown of the unit. These proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. 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?

The extended Frequency for discontinued Surveillances tests will ensure the equipment is OPERABLE prior to entry into the proposed Applicability therefore this change does not result in a significant reduction in the margin of safety. The acceptability of a Surveillance test should not be affected by plant conditions. If the unit is operating CTS 3.0.B (ITS SR 3.0.1) considers a Surveillance to be acceptable if the Surveillance is performed within 1.25 times the interval specified in the Frequency. CTS 3.0.C does not allow the 25% extension of the Frequency if the plant is outside the Applicability of the Specification and the Surveillance has been discontinued. The OPERABILITY of a system is normally not affected Monticello Page 12 of 13 Attachment 1, Volume 5, Rev. 0, Page 62 of 63

Attachment 1, Volume 5, Rev. 0, Page 63 of 63 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS SECTION 3.0, LCO AND SR APPLICABILITY by plant conditions; therefore this change is appropriate and acceptable. Thus, there is confidence that the equipment can perform its assumed safety function.

This change also changes the CTS by allowing a change in MODES or other specified conditions in the Applicability when a Surveillance is not current, provided the change in MODES or other specified conditions in the Applicability are allowed by LCO 3.0.4, are required to comply with ACTIONS, or are part of a shutdown of the unit. This change will allow unit operation in MODES or other specified conditions in the Applicability while relying on ACTIONS that would have been previously prohibited. However, LCO 3.0.4 will only allow entry if the associated ACTIONS to be entered permit continued operation for an unlimited period of time, a risk evaluation is performed prior to entry into the MODE, or when specific analysis has been previously approved allowing entry. This change also allows a change in MODES or other specified conditions in the Applicability when a Surveillance is not current provided entry is required to comply with ACTIONS or are part of a shutdown of the unit. Normal shutdowns would typically be performed with a full complement of OPERABLE safety systems consistent with the Bases of ITS LCO 3.0.4, which states "The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability." The addition of the allowance to perform a normal shutdown while relying on ACTIONS is appropriate because the Technical Specifications contain appropriate controls to ensure the safety of the unit in these conditions. These controls are considered adequate to maintain the margin of safety. As a result, the margin of safety is not significantly affected. 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 13 of 13 Attachment 1, Volume 5, Rev. 0, Page 63 of 63

ML051960253

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