ML051990513

Improved Technical Specifications, Volume 15, Revision 0, ITS Section 3.10, Special Operations.

ML051990513
Person / Time
Site:	Monticello
Issue date:	06/29/2005
From:	Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
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Download: ML051990513 (179)

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{{#Wiki_filter:IMPROVED TECHNICAL SPECIFICATIONS MONTICELLO NUCLEAR GENERATING PLANT VOLUME 15 ITS Section 3. 1 0, Special Operations Committed Nucler Excellence

Attachment 1,Volume 15, Rev. 0, Page 1 of 178 ATTACHMENT 1 VOLUME 15

                                                  . q MONTICELLO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.10 SPECIAL OPERATIONS Revision 0 Attachment 1, Volume 15, Rev. 0, Page 1 of 178

Attachment 1, Volume 15, Rev. 0, Page 2 of 178 LIST OF ATTACHMENTS

1. ITS 3.10.1

2. ITS 3.10.2

3. ITS 3.10.3

4. ITS 3.10.4

5. ITS 3.10.5

6. ITS 3.10.6

7. ITS 3.10.7

8. ITS 3.10.8

9. Improved Standard Technical Specifications (ISTS) not adopted in the Monticello ITS Attachment 1, Volume 15, Rev. 0, Page 2 of 178

Attachment 1, Volume 15, Rev. 0, Page 3 of 178 ATTACHMENT I ITS 3.10.1, Inservice Leak and Hydrostatic Testing Operation Attachment 1, Volume 15, Rev. 0, Page 3 of 178

Attachment 1, Volume 15, Rev. 0, Page 4 of 178 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) Attachment 1, Volume 15, Rev. 0, Page 4 of 178

C C ITS 3.10.1 0 3.0 LIMING CONDIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS 3.5 CORE AND CONTAINMENT SPRAY/COOLING SYSTEMS 4.5 CORE AND CONTAINMENT SPRAY/COOLING SYSTEMS a) A x.illy fu Applies to the operational status of the emergency cooling Applies to the periodic testing of the emergency cooling systems. systems. CD 0 Objecivtl Objective: To insure adequate cooling capability for heat removal In the To verify the operability of the emergency cooling systems. 0 event of a loss of coolant accident or Isolation from the normal reactor heat sink. Specification: 0 Snecification: A. ECCS Systems

-I CD A. ECCS Systems 1. Demonstrate the Core Spray Pumps develop a a) 2,800 gpm flow rate against a system head corresponding to a reactor pressure of 130 psi I See ITS 3.5.1 }

Co 1. Except as specified In section 3.5.A.3. both Core Spray subsystems and the Low Pressure Coolant greater than containment pressure, when tested In Inlection (LPCI) Subsystem (LPCI Mode of RHR accordance with the Inservice Testing Program. CD CD System) shall be operable whenever Irradiated fuel Is In the reactor vessel and the reactor water 2. Demonstrate the LPCI Pumps develop a 3,870 gpof C" temperature is greater than 2126F. flow rate against a system head corresponding to

                                                                               .                   two pumps delivering 7.740 gpm at a reactor
                                                                                                                                                                       -0 CD'

2. Except a specitied In section 3.5.A. , the High pressure of 20 psi greater than containment 0 Pressur0Coolant Injection (HPCI) ystem and the pressure, when tested In accordance with the

-4' Aulomadc Depessurization Sysle (ADS) shall be operable whenever the react pressure is greater J. Inservice Testing Program. I 03 than psig and Irradiated fuel s in the reacor vessI except during reactor ye sel hydrostatic or leakrge tests. Add proposed SR 3.10.1.1 3.5/4.5 4 Add proposed LCO 3.10.1

                                                                                 -O                                 101 Amendment No. 7770,-3 122 0801/01 Adddd poposed   ACTION A including ACTIONS Note                                       (i)

Page 1 of 4

(: c CI ITS 3.1 0.1 0) 3.0 UMmNG CONDIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS 1-D. RCIC 0. RCIC

.It>

1. Except ashpecified In 3.5.D.2 and 3 blowv the 1. NOTE: Not required to be performed until 12 hours C) Reactor gore Isolation Cooling Systrm (RCIC) shall after reactor steam pressure and flow are adequate beoper ble whenever Irradiated tufI is inthe 07 0 to perform the test.

3 reactor *essel and reactor pressurIs greater than CD 150 Ps), except during reactor v9ssel hydrostatic or a. Demonstrate, quarterly, with reactor pressure leakade tests. / s 1120 psig and 2 950 psig, the RCIC pump 1 can develop a flow rate 2 400 gpm against a

2. RCIC may be inoperable for 14 days. provided system head corresponding to reactor pressure.

I HPCI Is onerable. when tested In accordance with the Inservice 0 Testing Program.

3. The controls for the automatic transfer of the pump b. Demonstrate, once per operating cycle, with suction may be inoperable for 30 days, if the pump reactor pressure s 165 psig, the RCIC pump suction is aligned to the suppression pool. can develop a flow rate 2 400 gpm against a 0

EU system head corresponding to reactor pressure. \-{eSee ITS 3.5.3}

4. It the requirements or conditions of 3.5.D.1, 2 or 3 cannot be met, an orderly shutdown of the reactor 2. Perform a simulated automatic actuation test CD shall be Initiated and the reactor shalf be placed in a (Induding transfer lo suppression pool and c condition In which the affected equipment is not automatic restart on subsequent low reactor water required to be operable within 24 hours. level) each refueling outage.

-4 !X I 1 S. . . I co L-{ See ITS 3.3.5.2} 0

-4 Co 3.5/4.5                                                                                                 105          08/01tO1 Amendment No. 27,77,70, 122 Page 2 of 4

C C ITS 3.1 0.1 ITS ITS 3.0 LIMING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS I _______________________________________________________________ e reac vessel head boiting studs shall not be 4 4. When the reactor vessel head studs are under under tension unless the temperature of Ihe vessel tension and the reactor Is In the Cold Shutdown head flange and the head are ?70 0F. ConditIon, the reactor vessel shell flange *}- See ITS 3.4.9 } w W _-

                                                                                                    -    temperature shal be permanently recorded._                                  Su C                      C. Coolant Chemistry I'

I C. Coolant Chemistry 3 CD I

1. (a) The steady slate radlolodine concentration In the reactor coolant shall not exceed 2.0 microcuries of 1-1 31 dose equivalent per gramn

1. (a) A sample of reactor coolant shal be taken at least every 96 hours and analyzed for ft See ITS 3.4.6}

3 3CD of water. _ _ radioactive lodines of 1-131 through 1.135

                                                                                                 -1          during power operation.

0 (b) The steady state radiloodine concentration In 0 3 -L LCO 3.10.1 the reactor coolant shall not exceed 0.02 SR 3.10.1.2 (b) A sample of reactor coolant shell be taken and microcuries of 1-131 dose equivalent per gram analyzed for radioactive lodines of 1-131 3 CD of waler when the reactor coolant temperature CD through 1-135 within 24 hours prior to raising Is >212F. the reactor is not critical, and the reactor coolant temperature >212F. with primary containment integrity has not been U1 the reactor not critical, and with primary 3o established. containment Integrity not established. CD c to (D 0)

                                                                                                                                                                                     -od la CD

-4 0

-4
                                                                                                                                                                                       -4 0

ED

                                                                                                                                                                                      -4' CD 3.6/4.8                                                                                                  123             03/07/01 Amendment No. 0 . 101 107 117 Page 3 of 4

( C- C ITS 3.1 0.1 [fS ee ITS 3.6.1.1 } 3.0 LMITING CONDITIONS FOR OPERATION / 4.0 SURVEILLANCE REQUIREMENTS

2. PrImary Containment Integrity

                                                                  /

a. (1) Primary Containment Integrity as defined In

2. Primary Containment Integrity

a. Perform required visual examinations and s

JW Section 1, shall be maintained at all times See ITS 3.6.1.1 1 0S leakage rate testing except for primairy when the reactor Is critical or when the containment air lock testLn. In accordance wit reactor water temperature Isabove 21l2F the Prlmaey Containment Ges ikage Rate Testin 1 3 CD and fuel is In the reactor vesseielmiJ spedfied In 3.7.A2 a.(2), 1- .e I Program. 3 I r3 7 _F 0 M (2) Prlmary Containment Integrity is not required See ITS 3.6.1.3} 0 when performing low power physics tests at atmospherlo pressure during or after refueling CD at power levels not to exceed 5 MW(tl. See ITS 3.6.1.1 } CD a Z-0 (0 (3) P/mary Containment Integrils not required yfon performing reactor vadsel hydrostatic or_

                        /ieakage tests with the reaeor not critical.
                                                                              .                                                                                       U1
                                                                                                                                                                     -XtD M

(4) If requirements of 3.7A2.a.(1) cannot be CO met restore PrImary Conlanirent Integrity See ITS 3.6.1.1 and ITS 3.6.1.3} 10 within one hour or be In at least Hot 0 . Shutdown within the next 12 hours and Cold Shutdown within the following 24 hours. co CD CD to to 0 0

                                                                                                                                                                       -9'
-4'
-4                                                                                                                                                                     -4 co                                                                                                                                                                     co 3.714.7                                                                                            158           01/20/05 Amendment No. 70, 5. e0. 05, 107, 122,141 Page 4 of 4

Attachment 1, Volume 15, Rev. 0, Page 9 of 178 DISCUSSION OF CHANGES ITS 3.10.1, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION 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 CTS 3.5.A.2 requires the High Pressure Coolant Injection (HPCI) System and the Automatic Depressurization System (ADS) to be OPERABLE whenever the reactor pressure is greater than 150 psig and irradiated fuel is in the reactor vessel "except during reactor vessel hydrostatic or leakage tests." CTS 3.5.D.1 requires the Reactor Core Isolation Cooling System (RCIC) to be OPERABLE whenever irradiated fuel is in the reactor vessel and reactor pressure is greater than 150 psig "except during reactor vessel hydrostatic or leakage tests." CTS 3.7.A.2.a.(3) states that Primary Containment Integrity is not required when performing reactor vessel hydrostatic or leakage tests with the reactor not critical. ITS LCO 3.10.1, in part, states that the average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3 to allow performance of an inservice leak or hydrostatic test provided certain MODE 3 LCOs are met. ITS LCO 3.5.1, LCO 3.5.3, and LCO 3.6.1.1, which specify the requirements for the HPCI System and ADS, RCIC System, and Primary Containment, respectively, are not one of the MODE 3 LCOs that are required to be met. This changes the CTS by deleting the explicit exception to not require the HPCI System, ADS, RCIC System, and Primary Containment to be OPERABLE during the reactor vessel hydrostatic or leakage tests. The purpose of CTS 3.5.A.2, CTS 3.5.D.1, and CTS 3.7.A.2.a.(3) is to specify the conditions for when the HPCI System, ADS, RCIC System, and Primary Containment are required to be OPERABLE. ITS LCO 3.10.1 states that the average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA" and operation considered not to be in MODE 3. Thus, during an inservice leak or hydrostatic test with reactor coolant temperature > 2120 F, the plant is still considered to be in MODE 4. ITS 3.5.1, ITS 3.5.3, and ITS 3.6.1.1 do not require the HPCI System, ADS, RCIC System, or Primary Containment to be OPERABLE in MODE 4. Therefore, this change is acceptable because the requirements of ITS LCO 3.10.1 are consistent with the current requirements. This change is designated as administrative because it does not result in technical changes to the CTS. MORE RESTRICTIVE CHANGES None Monticello Page 1 of 3 Attachment 1, Volume 15, Rev. 0, Page 9 of 178

Attachment 1, Volume 15, Rev. 0, Page 10 of 178 DISCUSSION OF CHANGES ITS 3.10.1, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category I - Relaxation of LCO Requirements) Various current Technical Specifications provide requirements for components to be OPERABLE when the reactor coolant temperature is,> 212 0F. For example, CTS 3.5.A.1 requires the Core Spray and LPCI subsystems to be OPERABLE whenever irradiated fuel is in the reactor vessel and the reactor water temperature is > 21 20F. The above conditions could be met during an inservice leak or hydrostatic test. ITS LCO 3.10.1 states that the average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," may be suspended, to allow performance of an inservice leak or hydrostatic test provided the specific activity of the reactor coolant is < 0.02 tiCi/gm DOSE EQUIVALENT 1-131 and the following MODE 3 LCOs are met: LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation" Functions 1, 3, and 4 of Table 3.3.6.2-1; LCO 3.6.4.1, "Secondary Containment;" LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs);" and LCO 3.6.4.3, "Standby Gas Treatment (SGT) System." In addition, ITS SR 3.10.1.1 requires the performance of the applicable SRs for the required MODE 3 LCOs. In addition, appropriate ACTIONS have been included in the ITS. ITS 3.10.1 ACTION A covers the condition for one or more of the ITS LCO 3.10.1 requirements not met. ITS 3.10.1 Required Action A.1 requires immediate entry into the applicable Condition of the affected LCO. Furthermore, this Required Action is modified by a Note that states "Required Actions to be in MODE 4 include reducing average reactor coolant temperature to < 212 0F." In lieu of performing ITS 3.10.1 Required Action A.1, ITS 3.10.1 Required Action A.2.1 requires an immediate suspension of activities that could increase the average reactor coolant temperature or pressure and ITS 3.10.1 Required Action A.2.2 requires the average reactor coolant temperature to be reduced to

      < 2120 F within 24 hours. ITS 3.10.1 ACTIONS include a Note that states "Separate Condition entry is allowed for each requirement of the LCO." This changes the CTS by not requiring many LCOs required to be met in MODE 3 to be met during an inservice leak or hydrostatic test performed with reactor coolant temperature > 212 0F, provided certain requirements are met, and provides a specific ACTION and Surveillance Requirement.

The purpose of ITS LCO 3.10.1 is to provide the appropriate requirements for inservice leak and hydrostatic testing operation. This change deletes the requirement to maintain certain systems OPERABLE or parameters met during an inservice leak or hydrostatic test performed with reactor coolant temperature Monticello Page 2 of 3 Attachment 1, Volume 15, Rev. 0, Page 10 of 178

Attachment 1, Volume 15, Rev. 0, Page 11 of 178 DISCUSSION OF CHANGES ITS 3.10.1, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION

      >  212 0F. ITS LCO 3.10.1 states that the requirements of ITS LCO 3.4.8 may be suspended. The CTS does not provide a specific requirement for the RHR Shutdown Cooling System. Therefore, the allowance to suspend the requirements for the RHR Shutdown Cooling System is consistent with the current allowances. CTS 3.7.8, Standby Gas Treatment System and CTS 3.7.C, Secondary Containment are required to be OPERABLE when the reactor coolant temperature is above 212 0F. Therefore, the secondary containment type LCOs specified in ITS LCO 3.10.1 are currently required during the inservice leak and hydrostatic testing operations. However, there are other LCOs that are required to be met when the reactor coolant temperature is above 212 0 F in the CTS (e.g.,

CTS 3.5.A.1, Emergency Core Cooling Systems, CTS 3.6.0.1, Reactor Coolant System Operational Leakage, CTS 3.6.D.2, Reactor Coolant System Leakage Detection Instrumentation, CTS 3.7.A.1, Suppression Pool Volume and Temperature) that will not be required to be met if ITS LCO 3.10.1 is applied. These LCOs are not necessary during the inservice leak and hydrostatic testing operations because the protection provided by normally required MODE 4 applicable LCOs, in addition to the specific activity limit and secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions. Furthermore, an appropriate ACTION (ITS 3.10.1 ACTION A) has been provided if the requirements of ITS LCO 3.10.1 are not met. This ACTION will ensure that either action for an inoperable component will be taken, consistent with the actions that normally apply for the component, or the inservice leak or hydrostatic test will be suspended and reactor coolant temperature will be reduced to < 212 0 F (i.e., the LCO will be exited and normal MODE 4 operation will be resumed). ITS SR 3.10.1.1 will ensure that the secondary containment, SCIVs, SGT System, and Secondary Containment Isolation Instrumentation is OPERABLE prior to and during performance of an inservice leak or hydrostatic test. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS. Monticello Page 3 of 3 Attachment 1, Volume 15, Rev. 0, Page 11 of 178

Attachment 1, Volume 15, Rev. 0, Page 12 of 178 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 12 of 178

Attachment 1, Volume 15, Rev. 0, Page 13 of 178 Inservice Leak and Hydrostatic Testing Operation 3.10.1 CTS 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.1 0.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4r 3"Residual Heat Removal t!J (i) 3.5.A.2. 3.5.D.1, (RHR) Shutdown Cooling System - Cold Shutdown," may be suspended, 3.6.C.1 .(b), to allow performance of an inservice leak or hydrostatic test provideckthe (i) 3.7.A.2.a.(3), following MODE 3 LCOs are met: ER DOC 1.1

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation,"

Functions 1, 3, an of Table 3.3.6.2-1

b. LCO 3.6.4.1, "Secondary Containmentin

c. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SClVs)3 and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperaturee>°F. 0 BWR/4 STS 3.10.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 13 of 178

Attachment 1, Volume 15, Rev. 0, Page 14 of 178 3.10.1 Q INSERT 1 the specific activity of the reactor coolant is < 0.02 tiCi/gm DOSE EQUIVALENT 1-131 and Insert Page 3.10.1-1 Attachment 1, Volume 15, Rev. 0, Page 14 of 178

Attachment 1, Volume 15, Rev. 0, Page 15 of 178 Inservice Leak and Hydrostatic Testing Operation 3.10.1 CTS ACTIONS LDOC Separate Condition entry is allowed for each requirement of the LCO. CONDITION REQUIRED ACTION COMPLETION TIME DOC A. One or more of the A.1 ------ NOTE --- L.1 abZv requirements not Required Actions to be in met. MODE 4 include reducing 0 average reactor coolant 212 temperature to _[0F. 0D Enter the applicable Immediately Condition of the affected LCO. OR A.2.1 Suspend activities that Immediately could increase the average reactor coolant temperature or pressure. AND A.2.2 Reduce average reactor 24 hours coolant temperature to 0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC SR 3.10.1.1 Perform the applicable SRs for the required According to the L.1 MODE 3 LCOs. applicable SRs lINSERT 2l 0. BWR/4 STS 3.10.1-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 15 of 178

Attachment 1, Volume 15, Rev. 0, Page 16 of 178 3.10.1 Q5) INSERT 2 4.6.C.1 .(b) Once within SR 3.10.1.2 Verify reactor coolant DOSE EQUIVALENT 1-131 specific activity is < 0.02 piCi/gm. 24 hours prior to increasing average reactor coolant temperature > 212 0F Insert Page 3.10.1-2 Attachment 1, Volume 15, Rev. 0, Page 16 of 178

Attachment 1, Volume 15, Rev. 0, Page 17 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.1, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION

1. The proper LCO number has been provided.

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

3. 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.

4. CTS 3.6.C.1 .(b) requires the specific activity of the reactor coolant to be

  < 0.02 lCi/gm DOSE EQUIVALENT 1-131 during an inservice leak or hydrostatic test. CTS 4.6.C.1.(b) requires verification that the above limit is met prior to increasing reactor coolant temperature above 212 0F. These requirements have been maintained in the ITS (ITS LCO 3.10.1 and SR 3.10.1.2), consistent with current licensing basis.

5. ISTS 3.10.1 Condition A has been changed to be consistent with the wording of the ACTIONS Note.

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 17 of 178

Attachment 1, Volume 15, Rev. 0, Page 18 of 178 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 18 of 178

Attachment 1, Volume 15, Rev. 0, Page 19 of 178 Inservice Leak anid Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures >[ F (normally corresponding to MODE 3). - Q Inservice hydrostatic testing and system leakage pressure tests required by Section Xl of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Recirculation pump operation and a water solid RPV except for an te for pressure o rol are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (PIT) limits required by LCO 3.4j,'"Reactor Coolant (E) System (RCS) Pressure and Temperature (P/T) Limits." These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence. With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases at a given pressure. Periodic updates to the RPV P/T limit curves are performed as necessary, based upon the results of analyses of irradiated surveillance specimens removed from the vessel. Hydrostatic and leak testing will eventually be required with minimum reactor coolant temperatures >L:F. Y2 Lhdotti h etrequires increasing prsue =01-pdsg presute(120 pig)oral I psig, a-nd b'ecause of the expected increase in esse fle, the minimum allowable vessel temperature _E~ accordincreas to F. This increase tp [ a% of Ideignprssue desnoit exceed the SatetvLmit of 1375 s. APPLICABLE SAFETY ANALYSES Allowing the reactor to be considered in MODE 4 durinn hy leak testing, when the reactor coolant temperature is > provides an exception to MODE 3 requirements, including or2o effectively ' OPERABILITY

                                                                                                          '  3 of primary containment and the full complement of redundant Emergency Core Cooling Systems. Since the hydrostatic or leak tests are performed nearly water solid, at low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent increase in coolant activity above the LCO 3.4Z '"RCSSpecific Activity," limits are                 0-L (g

BWR/4 STS B 3.10.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 19 of 178

Attachment 1, Volume 15, Rev. 0, Page 20 of 178 B 3.10.1 Q3 INSERT I not less than nominal operating pressure associated with normal system operation (100% RTP) Insert Page B 3.10.1-1 Attachment 1, Volume 15, Rev. 0, Page 20 of 178

Attachment 1, Volume 15, Rev. 0, Page 21 of 178 Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE SAFETY ANALYSES (continued) minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing.*The required pressure 3(^) testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment. In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2, "ECCS - Shutdown," would be more than adequate to keep the core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred. For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to theTsecondary containment IINSERT3E requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions. As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases. LCO As described in LCO 3.0.7, compliance with this Special Operations LCOM1 (go is optional. Operation at reactor coolant temperatures> F can be in accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to PIT limits, however, which require testing at temperatures >[g F, (21 performance of inservice leak and hydrostatic testing would also necessitate the inoperability of some subsystems normally required to be 0 F. OPERABLE when 212 BWR/4 STS B 3.10.1-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 21 of 178

Attachment 1, Volume 15, Rev. 0, Page 22 of 178 B 3.10.1 Q3 INSERT 2 Furthermore, the specific activity of the reactor coolant is assumed to be -<0.02 Il.Ci/gm DOSE EQUIVALENT 1-131. Q INSERT 3 reactor coolant specific activity limit and Insert Page B 3.10.1-2 Attachment 1, Volume 15, Rev. 0, Page 22 of 178

Attachment 1, Volume 15, Rev. 0, Page 23 of 178 Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LCO (continued) If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOsa specified INSERT MODE 3 LCOs must be met. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LCO 3.4 g"Residual Heat Removal (ST5 (RHR) Shutdown Cooling System - Cold Shutdown." The additional requirements for'secondary containment LCOs to be met will provide 0 sufficient protection for operations at reactor coolant temperatures

                 >       F for the purpose of performing either an inservice leak or             (i hydrostatic test.

This LCO allows primary corntainment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirements that are in effect immediately prior to and immediately after this operation. APPLICABILITY The MODE 4 requirements may only be modified for the performance of inservice leak or hydrostatic tests so that these operations can be t onsidered as in MODE 4, even though the reactor coolant temperature is

                 >MdoF. The additional requirementfo secondary containment [iJ IMERT61              (2 according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur.

Operations in all other MODES are unaffected by this LCO. ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LCO not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO. BWR/4 STS B 3.10.1-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 23 of 178

Attachment 1, Volume 15, Rev. 0, Page 24 of 178 B 3.10.1 Q INSERT 4 ,the reactor coolant specific activity limit, and the O9 INSERT 5 the reactor coolant specific activity limit and the Q3 INSERT 6 the reactor coolant specific activity limit as well as the Insert Page B 3.10.1-3 Attachment 1, Volume 15, Rev. 0, Page 24 of 178

Attachment 1,Volume 15, Rev. 0, Page 25 of 178 Inservice Leak and Hydrostatic Testing Operation B 3.1 0.1 BASES ACTIONS (continued) A.1 If an LCO specified in LCO 3.10.1 is not met, the ACTIONS applicable to the stated requirements are entered immediately and complied with. Required Action A.1 has been modified by a Note that clarifies the intent of another LCO's Required Action to be in MODE 4 includes reducing the average reactor coolant temperature to 212

                                                                                                 .0 A.2.1 and A.2.2 Required Action A.2.1 and Required Action A.2.2 are alternate Required Actions that can be taken instead of Required Action A.1 to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operation LCO's Applicability. Activities that could further increase reactor coolant temperature or pressure are suspended immediately, in accordance with Required Action A.2.1, and the reactor coolant temperature is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours for Required Action A.2.2 is based on engineering judgment and provides sufficient time to reduce the average reactor coolant temperature from the hehest          ,

expected value to sF with normal cooldown procedures. The Completion Time is also consistent with the time provided in LCO 3.0.3 to reach MODE 4 from MODE 3. SURVEILLANCE SR 3.10.1.1 REQUIREMENTS The LCOs made applicable are required to have their Surveillances met to establish that this LCO is being met. A discussion of the applicable SJ3s is provided in their respective Bases. ERT7 0D REFERENCES 1. American Society of Mechanical Engineers, Boiler and Pressure

6) Vessel Code, Section Xl.

L2'T*SAR, Section 1 0D BWR/4 STS B 3.10.1-4 Rev. 3.0, 03/31/04 Attachment 1,Volume 15, Rev. 0, Page 25 of 178

Attachment 1, Volume 15, Rev. 0, Page 26 of 178 B 3.10.1 INSERT 7 SR 3.10.1.2 This Surveillance is performed to ensure the reactor coolant specific activity is within limit. The Frequency is based on ensuring the reactor coolant specific activity is within the limit prior to increasing average reactor coolant temperature above the MODE 3 limit (i.e., 212 0F). Insert Page B 3.10.1-4 Attachment 1, Volume 15, Rev. 0, Page 26 of 178

Attachment 1, Volume 15, Rev. 0, Page 27 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.1 BASES, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION

1. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific nomenclature, number, reference, system description, analysis description, or licensing basis description.

2. Changes have been made to reflect those changes made to the Specifications.

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

4. Changes have been made to be consistent with the Specification.

Monticello Page 1 of I Attachment 1, Volume 15, Rev. 0, Page 27 of 178

Attachment 1, Volume 15, Rev. 0, Page 28 of 178 K Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 15, Rev. 0, Page 28 of 178

Attachment 1, Volume 15, Rev. 0, Page 29 of 178 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.10.1, INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION There are no specific NSHC discussions for this Specification. Monticello Page 1 of I Attachment 1, Volume 15, Rev. 0, Page 29 of 178

Attachment 1, Volume 15, Rev. 0, Page 30 of 178 ATTACHMENT 2 ITS 3.10.2, Reactor Mode Switch Interlock Testing Attachment 1, Volume 15, Rev. 0, Page 30 of 178

Attachment 1, Volume 15, Rev. 0, Page 31 of 178 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) Attachment 1, Volume 15, Rev. 0, Page 31 of 178

ITS 3.10.2 ITS 3.0 LIMITING CONDmONS FOR OPERATiON 4.0 SURVEILLANCE REQUIREMENTS E. IExtended Core and Control Rod Drive Mantenance 1 More than one control rod may be withdraw nfrom th_ I Ireacor core durina outa0es ged that exg en rmmntar switching to the~Isalpmd fr Interlocke\ > LCO 3.10.2 4 ~eent reador mode swtshall be locked Inn tha for MODE 5 ee position. The refueling Interlock signal from a S _ control rod may bypassed after the fuel assemblies I the call co (controiled by that control rod ha

              .          been removed from the reactor core O                                                                                                                                                               0 3                                                                                             . Add proposed SR 3.10.2.1 and SR 3.1022 for                  0

-_ Add proposed LCO 3.10.2 parts a and b for MODE 5 startuplhot standby posftion __ 0 0 C Pd proposed ACTION A for MODE 5 CD r_.Add proposed SR 3.102.1 and SR 3.1022 for

                                   'Add praposed LCO 3.10.2 for MODES 3 and 4                      MODES 3 and 4 and MODE 5 for run position  ' L              CD CD                                  with the reactor rnodeswthItenu,. 1 X                        4      ~~~~~stantup/hot standby, or refuelpstoadL 00 M                               ~proposed ACTION A                                                                                                          i o                                                                                                                                                               0

-J - 00 co 208 4118/89 3.1014.10 Amendment No. 63 Page 1 of 1

Attachment 1, Volume 15, Rev. 0, Page 33 of 178 DISCUSSION OF CHANGES ITS 3.10.2, REACTOR MODE SWITCH INTERLOCK TESTING 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. MORE RESTRICTIVE CHANGES M.1 CTS 3.10.E applies during extended core and control rod drive maintenance. CTS 3.10.E requires the mode switch to be locked in the refuel position, "except for momentary switching to the Startup mode for interlock testing." ITS LCO 3.10.2 also allows the reactor mode switch to be placed in the startup/hot standby position for reactor mode switch interlock testing during MODE 5, however it only allows this testing if all control rods remain fully inserted in core cells containing one or more fuel assemblies (ITS LCO 3.10.2.a) and no CORE ALTERATIONS are in progress (ITS LCO 3.10.2.b). ITS 3.10.2 ACTION A covers the condition for one or more of the requirements in ITS LCO 3.10.2 not met and requires the immediate suspension of CORE ALTERATIONS except for control rod insertion, fully insert all insertable control rods in core cells containing one or more fuel assemblies, and within 1 hour either place the reactor mode switch in the shutdown or refuel position. Furthermore, two Surveillance Requirements have been added (ITS SR 3.10.2.1 and SR 3.10.2.2) to ensure these conditions are periodically met when using the allowances of this LCO. This changes the CTS by adding these limitations for reactor mode switch testing with the mode switch in the startup/hot standby position during MODE 5, adding an appropriate ACTION when the requirements are not met, and adding appropriate Surveillances to periodically ensure the LCO requirements are met. The purpose of CTS 3.10.E, in part, is to allow the reactor mode switch to be placed in the startup/hot standby position when in MODE 5 in order to perform interlock testing. This change adds a requirement that all control rods remain fully inserted in core cells containing one or more fuel assemblies (ITS LCO 3.10.2.a) and no CORE ALTERATIONS are in progress (ITS LCO 3.10.2.b) during reactor mode switch testing. This change also adds an appropriate ACTION for when the requirements of the LCO is not met. Furthermore, two Surveillance Requirements have been added (ITS SR 3.10.2.1 and SR 3.10.2.2) to ensure these conditions are periodically met when using the allowances of this LCO. This change is acceptable because these limitations help ensure the core remains subcritical during reactor mode switch testing with the mode switch in the startup/hot standby position during MODE 5. This change is designated as more restrictive because it adds two new LCO limitations during reactor mode switch testing with the mode switch in the startup/hot standby position during MODE 5, provides an ACTION for when the requirements of the LCO are not met, and adds appropriate Surveillances to periodically ensure the LCO requirements are met. Monticello Page 1 of 3 Attachment 1, Volume 15, Rev. 0, Page 33 of 178

Attachment 1, Volume 15, Rev. 0, Page 34 of 178 DISCUSSION OF CHANGES ITS 3.10.2, REACTOR MODE SWITCH INTERLOCK TESTING RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES NONE LESS RESTRICTIVE CHANGES L.1 (Category I - Relaxation of LCO Requirements) CTS 3.1 0.E applies during extended core and control rod drive maintenance. It allows more than one control rod to be withdrawn from the core during outages, provided that, except for momentary switching to the startup mode for interlock testing, the reactor mode switch shall be locked in the refuel position. The CTS does not allow reactor mode switch interlock testing during MODES 3 and 4, nor does it allow placing the mode switch in the run position during MODE 5. ITS LCO 3.10.2 allows the reactor mode switch position specified in Table 1.1-1 for MODES 3, 4, and 5 to be changed to include run, startup/hot standby, and refuel position, and operation considered not to be in MODE 1 or 2, to allow testing of instrumentation associated with the reactor mode switch interlock functions, provided the conditions specified in ITS LCO 3.10.2.a and b are met. ITS LCO 3.10.2.a requires all control rods to remain fully inserted in core cells containing one or more fuel assemblies and ITS LCO 3.10.2.b requires no CORE ALTERATIONS to be in progress. An ACTION has been provided (ITS 3.10.2 ACTION A) if these two conditions are not met. The ACTION requires the conditions to be met or to exit the LCO's Applicability (i.e., place the reactor mode switch in shutdown or refuel, as appropriate for the current MODE). Furthermore, two Surveillance Requirements have been added (ITS SR 3.10.2.1 and SR 3.10.2.2) to ensure these conditions are periodically met when using the allowances of this LCO. This changes the CTS by: a) allowing reactor mode switch testing to occur in MODES 3 and 4 with the reactor mode switch in the run, startup/hot standby, or refuel position; b) allowing reactor mode switch testing during MODE 5 operations to include the run position; c) providing appropriate actions if the LCO requirements are not met; and 4) providing appropriate Surveillances to periodically ensure the LCO requirements are met. The purpose of CTS 3.1 0.E, in part, is to allow the reactor mode switch to be placed in the Startup position during plant outages in order to perform interlock testing. This change allows reactor mode switch testing to occur in MODES 3 and 4 with the reactor mode switch in the run, startup/hot standby, or refuel position, and allows reactor mode switch testing during MODE 5 to include the run position. This change is acceptable because LCO 3.10.2 includes additional restrictions to ensure the core remains subcritical during all interlock testing. ITS LCO 3.10.2.a requires all control rods to remain fully inserted in core cells containing one or more fuel assemblies and ITS LCO 3.10.2.b does not allow any CORE ALTERATIONS to occur during this testing. This will help ensure the core remains subcritical during testing. In addition, an ACTION (ITS 3.10.2 ACTION A) has been added if it is found that the requirements of the LCO are Monticello Page 2 of 3 Attachment 1, Volume 15, Rev. 0, Page 34 of 178

Attachment 1, Volume 15, Rev. 0, Page 35 of 178 DISCUSSION OF CHANGES ITS 3.10.2, REACTOR MODE SWITCH INTERLOCK TESTING not met and two new Surveillance Requirements have been added to ensure that the new requirements of the LCO 3.10.2 (all control rods are inserted in core cells containing one or more fuel assemblies and that CORE ALTERATIONS do not occur) are met. In MODES 3, 4, and 5 with the reactor mode switch in shutdown as specified in Table 1.1-1, all control rods are fully inserted and a control rod block is initiated. Therefore, all control rods in core cells that contain one or more fuel assemblies must be verified fully inserted while in MODES 3 and 4 with the reactor mode switch in other than the shutdown position, and in MODE 5 with the reactor mode switch in the run position. The additional LCO requirement to preclude CORE ALTERATIONS is appropriate for MODE 5 operations with the vessel head removed and is inherently met in MODES 3 and 4 by the definition of CORE ALTERATIONS, which cannot be performed with the vessel head in place. This change is designated as less restrictive because reactor mode switch interlock testing will now be allowed in MODES 3 and 4, and reactor mode switch testing during MODE 5 is now allowed to include the run position. Monticello Page 3 of 3 Attachment 1, Volume 15, Rev. 0, Page 35 of 178

Attachment 1, Volume 15, Rev. 0, Page 36 of 178 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0,-Page 36 of 178

Attachment 1, Volume 15, Rev. 0, Page 37 of 178 Reactor Mode Switch Interlock Testing 3.10.2 CIS 3.10 SPECIAL OPERATIONS 3.10.2 Reactor Mode Switch Interlock Testing 3.10.E. LCO 3.10.2 The reactor mode switch position specified in Table 1.1-1 for MODES 3, DOC 4, and 5 may be changed to include the run, startup/hot standby, and L.1 refuel position, and operation considered not to be in MODE 1 or 2, to allow testing of instrumentation associated with the reactor mode switch interlock functions, provided: DOCs M.1 a. All control rods remain fully inserted in core cells containing one or and L.1 more fuel assemblies and

b. No CORE ALTERATIONS are in progress.

3.10AE MODES 3 and 4 with the reactor mode switch in the run, startup/hot DOC C. APPLICABILITY: standby, or refuel position, MODE 5 with the reactor mode switch in the run or startup/hot standby position. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME DOCs M.1 A. L fbJe-o more/of Ihel I a ovelequirements not A.1 Suspend CORE ALTERATIONS except for Immediately 0D and L.1 met. ote control rod insertion. AND A.2 Fully insert all insertable 1 hour control rods in core cells containing one or more fuel assemblies. AND A.3.1 Place the reactor mode 1 hour switch in the shutdown position. OR L _________________________ BWR/4 STS 3.10.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 37 of 178

Attachment 1, Volume 15, Rev. 0, Page 38 of 178 Reactor Mode Switch Interlock Testing 3.10.2 CTS ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME A.3.2 ------NOTE--- Only applicable in MODE 5. Place the reactor mode 1 hour switch in the refuel position. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOCs SR 3.10.2.1 Verify all control rods are fully inserted in core cells 12 hours M.A and containing one or more fuel assemblies. L.1 DOCs 24 hours M.1 and SR 3.10.2.2 Verify no CORE ALTERATIONS are in progress. L.A BWR/4 STS 3.10.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 38 of 178

Attachment 1, Volume 15, Rev. 0, Page 39 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.2, REACTOR MODE SWITCH INTERLOCK TESTING

1. 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.

2. Changes made to be consistent with similar wording in other Specifications.

Monticello Page 1 of I Attachment 1, Volume 15, Rev. 0, Page 39 of 178

Attachment 1, Volume 15, Rev. 0, Page 40 of 178 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) - Attachment 1, Volume 15, Rev. 0, Page 40 of 178

Attachment 1, Volume 15, Rev. 0, Page 41 of 178 Reactor Mode Switch Interlock Testing B 3.10.2 B 3.10 SPECIAL OPERATIONS B 3.10.2 Reactor Mode Switch Interlock Testing BASES BACKGROUND The purpose of this Special Operations LCO is to permit operation of the reactor mode switch from one position to another to confirm certain aspects of associated interlocks during periodic tests and calibrations in MODES 3,4, and 5. The reactor mode switch is a conveniently located, multiposition, keylock switch provided to select the necessary scram functions for various plant conditions (Ref. 1). The reactor mode switch selects the appropriate trip relays for scram functions and provides appropriate bypasses. The mode switch positions and related scram interlock functions are summarized as follows: 6

a. Shutdown - Initiates a reactor scram; bypasses main steamaff(7) isolation ndIreactor Mater IevellscramsD_ Icondenserbwvacuum}r

b. Refuel - Selects Neutron Monitoring System (NMS) scram function for low neutron flux level operation (but does node the avera e power ra nein-hitor scram); bypasses main steam Aid isolation~and Intermediate range reactor liiater levelscram

c. Startup/Hot Standby - cenens low vcrum for low neutron 2 flux level operation (intermediate range monitorsland avenge rowe1 Iranaebonijor ); bypasses main steam isolation andl iIJ Ievaveelosscramsure codnebvacuum~{Li 00)

d. Run - Selects NMS scram function for power range operatio

• g~~rangemonitrs The reactor mode switch also provides interlocks for such functions as control rod blocks, scram discharge volume trip bypass, refueling interlocks, suppressi n makeupand main steam isolation valve (I isolations.

APPLICABLE IThelccept ntenon for reactor mode switch interlock testing is to 0 SAFETY prevent fuel failure by precluding reactivity excursions or core criticality. ANALYSES The interlock functions of the shutdown and refuel positions normally maintained for the reactor mode switch in MODES 3, 4, and 5 are provided to preclude reactivity excursions that could potentially result in BWR/4 STS B 3.10.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 41 of 178

Attachment 1, Volume 15, Rev. 0, Page 42 of 178 Reactor Mode Switch Interlock Testing B 3.1 0.2 BASES APPLICABLE SAFETY ANALYSES (continued) fuel failure. Interlock testing that requires moving the reactor mode switch to other positions (run, startup/hot standby, or refuel) while in MODE 3, 4, or 5, requires administratively maintaining all control rods inserted and no ICORE ALTERATIONS in progress. With all control rods inserted in () core cells containing one or more fuel assemblies, and no CORE ALTERATIONS in progress, there are no credible mechanisms for unacceptable reactivity excursions during the planned interlock testing. For postulated such as control rod removal error during refueling or loading of fuel with a control rod withdrawnhaidetlI1 analysis s ra es a fuel failure will not occur Refs and 3. The withdrawal of a single control rod will not result in criticality when adequate SDM is maintained. Also, loading fuel assemblies into the core with a single control rod withdrawn will not result in criticality, thereby preventing fuel failure. As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases. LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. MODES 3, 4, and 5 operations not specified in Table 1.1-1 can be performed in accordance with other Special Operations LCOs (i.e., LCO 3.10.1, "Inservice Leak and Hydrostatic Testing Operation," LCO 3.10.3, "Single Control Rod Withdrawal - Hot Shutdown," LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," and LCO 3.10.8, "SDM Test - Refueling") without meeting this LCO or its ACTIONS. If any testing is performed that involves the reactor mode switch interlocks and requires repositioning beyond that specified in Table 1.1-1 for the current MODE of operation, the testing can be performed, provided all interlock functions potentially defeated are administratively controlled. In MODES 3, 4, and 5 with the reactor mode switch in shutdown as specified in Table 1.1-1, all control rods are fully inserted and a control rod block is initiated. Therefore, all control rods in core cells that contain one or more fuel assemblies must be verified fully inserted while in MODES 3, 4, and 5, with the reactor mode switch in other than the shutdown position. The additional LCO requirement to preclude CORE ALTERATIONS is appropriate for MODE 5 operations, as discussed below, and is inherently met in MODES 3 and 4 by the definition of CORE ALTERATIONS, which cannot be performed with the vessel head in place. BWR/4 STS B 3.10.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 42 of 178

Attachment 1, Volume 15, Rev. 0, Page 43 of 178 Rea6tor Mode Switch Interlock Testing B 3.10.2 BASES LCO (continued) In MODE 5, with the reactor mode switch in the refuel position, only one control rod can be withdrawn under the refuel position one-rod-out interlock (LCO 3.9.2, "Refuel Position One-Rod-Out Interlock"). The refueling equipment interlocks (LCO 3.9.1, "Refueling Equipment Interlocks") appropriately control other CORE ALTERATIONS. Due to the increased potential for error in controlling these multiple interlocks, and the limited duration of tests involving the reactor mode switch position, conservative controls are required, consistent with MODES 3 and 4. The additional controls of administratively not permitting other CORE ALTERATIONS will adequately ensure that the reactor does not become critical during these tests. APPLICABILITY Any required periodic interlock testing involving the reactor mode switch, while in MODES I and 2, can be performed without the need for Special Operations exceptions. Mode switch manipulations in these MODES would likely result in unit trips. In MODES 3, 4, and 5, this Special Operations LCO is only permitted to be used to allow reactor mode switch or testing that must be performed prior to entering interlock testing that cannot conveniently be performed without this 0 another MODE allowanc Such interlock testing may consist of required Surveillances, or may be the result of maintenance, repair, or troubleshooting activities. In MODES 3, 4, and 5, the interlock functions provided by the reactor mode switch in shutdown (i.e., all control rods inserted and incapable of withdrawal) and refueling (i.e., refueling interlocks to prevent inadvertent criticality during CORE ALTERATIONS) positions can be administratively controlled adequately during the performance of certain tests. ACTIONS A.1. A.2, A.3.1. and A.3.2 These Required Actions are provided to restore compliance with the Technical Specifications overridden by this Special Operations LCO. Restoring compliance will also result in exiting the Applicability of this Special Operations LCO. All CORE ALTERATIONS, except control rod insertion, if in progress, are immediately suspended in accordance with Required Action A.1, and all

'Control rods Incore cells        insertable control rods in core cells that contain one or more fuel contaIning no fue assemblies do not affect the     assemblies are fully inserted within 1 hour, in accordance with Required reactlvityof the core and therefore, do no have to be nserted, Action A.2. This will preclude potential mechanisms that could lead to criticality.4Suspension of CORE ALTERATIONS shall not preclude the 0

completion of movement of a component to a safe condition. Placing the reactor mode switch in the shutdown position will ensure that all inserted control rods remain inserted and result in operating in accordance with BWRI4 STS B 3.10.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 43 of 178

Attachment 1, Volume 15, Rev. 0, Page 44 of 178 Reactor Mode Switch Interlock Testing B 3.10.2 BASES ACTIONS (continued) Table 1.1-1. Alternatively, if in MODE 5, the reactor mode switch may be placed in the refuel position, which will also result in operating in accordance with Table 1.1-1. A Note is added to Required Action A.3.2 to indicate that this Required Action is not applicable in MODES 3 and 4, since only the shutdown position is allowed in these MODES. The allowed Completion Time of 1 hour for Required Action A.2, Required Action A.3.1, and Required Action A.3.2 provides sufficient time to r normally insert the control rods and place the reactor mode switch in the required position, based on operating experience, and is acceptable given that all operations that could increase core reactivity have been suspended. SURVEILLANCE SR 3.10.2.1 and SR 3.10.2.2 REQUIREMENTS Meeting the requirements of this Special Operations LCO maintains operation consistent with or conservative to operating with the reactor mode switch in the shutdown position (or the refuel position for MODE 5). The functions of the reactor mode switch interlocks that are not in effect, due to the testing in progress, are adequately compensated for by the Special Operations LCO requirements. The administrative controls are to be periodically verified to ensure that the operational requirements continue to be met. The Surveillances performed at the 12 hour and 24 hour Frequencies are intended to provide appropriate assurance that each operating shift is aware of and verifies compliance with these Special Operations LCO requirements. _ REFERENCES :er [7:7.6.1. ChaASAR, (00

2. FEAR, Section [15.13].

FSAR, Section . .1 . 0 3 BWR/4 STS B 3.10.2-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 44 of 178

Attachment 1, Volume 15, Rev. 0, Page 45 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.2 BASES, REACTOR MODE SWITCH INTERLOCK TESTING

1. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific nomenclature, number, reference, system description, analysis description, or licensing basis description.

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. Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

4. The Bases have been changed to be consistent with the Specification.

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

6. Changes made to be consistent with other Specifications.

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 45 of 178

Attachment 1,Volume 15, Rev. 0, Page 46 of 178 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 15, Rev. 0, Page 46 of 178

Attachment 1, Volume 15, Rev. 0, Page 47 of 178 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.10.2, REACTOR MODE SWITCH INTERLOCK TESTING There are no specific NSHC discussions for this Specification. Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 47 of 178

Attachment 1, Volume 15, Rev. 0, Page 48 of 178 ATTACHMENT 3 ITS 3.10.3, Single Control Rod Withdrawal - Hot Shutdown Attachment 1, Volume 15, Rev. 0, Page 48 of 178

Attachment 1, Volume 15, Rev. 0, Page 49 of 178 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) Attachment 1, Volume 15, Rev. 0, Page 49 of 178

, Volume 15, Rev. 0, Page 50 of 178 ITS 3.10.3
  'ITS                    3.1o0.3 Page 1 of I , Volume 15, Rev. 0, Page 50 of 178

Attachment 1, Volume 15, Rev. 0, Page 51 of 178 DISCUSSION OF CHANGES ITS 3.10.3, SINGLE CONTROL ROD WITHDRAWAL - HOT SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 1 - Relaxation of LCO Requirements) The CTS does not allow the reactor mode switch to be placed in the refuel position to allow withdrawal of a single control rod when the unit is in Hot Shutdown (MODE 3). ITS 3.10.3 allows the reactor mode switch position in ITS Table 1.1-1 for MODE 3 to be changed to include the refuel position, and operation considered not to be in MODE 2, to allow withdrawal of a single control rod, provided specific requirements are met. In addition, an ACTION (ITS 3.10.3 ACTION A) has been added to cover the condition when one or more of the requirements of LCO 3.10.3 are not met. As stated in the ACTIONS Note, ACTION A is allowed to be entered separately for each requirement of the LCO not met. Furthermore, Surveillance Requirements have been added to help ensure the requirements of the LCO are met. This changes the CTS by allowing the withdrawal of a single control rod in MODE 3 by placing the reactor mode switch in the refuel position, and operation not to be considered in MODE 2, provided certain requirements are met. The purpose of ITS LCO 3.10.3 is to allow the withdrawal of a single control rod in MODE 3 by placing the reactor mode switch in the refuel position and operation not to be considered in MODE 2, provided certain requirements are met. This change is acceptable because the additional requirements will ensure the core remains subcritical and to prevent any inadvertent reactivity excursions. LCO 3.10.3 will require LCO 3.9.2, "Refuel Position One-Rod-Out Interlock," and LCO 3.9.4, "Control Rod Position Indication," to be met. In addition, all other control rods must be fully inserted. To back up the refueling interlocks (LCO 3.9.2), the ability to scram the withdrawn control rod in the event of an inadvertent criticality is provided by LCO 3.10.3.d.1. Alternately, provided a sufficient number of control rods in the vicinity of the withdrawn control rod are known to be inserted and incapable of withdrawal (LCO 3.10.3.d.2), the possibility of criticality on withdrawal of this control rod is sufficiently precluded, so as not to require the scram capability of the withdrawn control rod. Also, once Monticello Page 1 of 2 Attachment 1, Volume 15, Rev. 0, Page 51 of 178

Attachment 1, Volume 15, Rev. 0, Page 52 of 178 DISCUSSION OF CHANGES ITS 3.10.3, SINGLE CONTROL ROD WITHDRAWAL - HOT SHUTDOWN this alternate requirement (LCO 3.10.3.d.2) is completed, the SHUTDOWN MARGIN requirement to account for both the withdrawn control rod and the highest worth control rod may be changed to allow the withdrawn control rod to be assumed to be the highest worth control rod. Appropriate Surveillance Requirements also ensure the new requirements are met and periodically verified. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS. Monticello Page 2 of 2 Attachment 1, Volume 15, Rev. 0, Page 52 of 178

Attachment 1, Volume 15, Rev. 0, Page 53 of 178 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 53 of 178

Attachment 1, Volume 15, Rev. 0, Page 54 of 178 Single Control Rod Withdrawal - Hot Shutdown 3.10.3 KJ CTS 3.10 SPECIAL OPERATIONS 3.10.3 Single Control Rod Withdrawal - Hot Shutdown DOC LCO 3.10.3 The reactor mode switch position specified in Table 1.1-1 for MODE 3 LA may be changed to include the refuel position, and operation considered not to be in MODE 2, to allow withdrawal of a single control rod, provided the following requirements are met:

a. LCO 3.9.2, "Refuel Position One-Rod-Out Interlockl,3

b. LCO 3.9.4, "Control Rod Position Indicatiorb /

c. All other control rods are fully insertedfand d.1. LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation,"

MODE 5 requirements for Functionsi .a, 1.b, 7.a, 7.b, 10, and 11M of Table 3.3.1.1-1 and LCO 3.9.5, "Control Rod OPERABILITY - 0 Refueling," OR

2. All other control rods in a five by five array centered on the control rod being withdrawn are disarmed; at which time LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," MODE 3 requirements may be changed to allow the single control rod withdrawn to be assumed to be the highest worth control rod.

APPLICABILITY: MODE 3 with the reactor mode switch in the refuel position. BWR/4 STS 3.10.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 54 of 178

Attachment 1, Volume 15, Rev. 0, Page 55 of 178 Single Control Rod Withdrawal - Hot Shutdown 3.10.3 CIS ACTIONS r7---- DOC Separate Condition entry is allowed for each requirement of the LCO. Li CONDITION REQUIRED ACTION COMPLETION TIME DOC A. One or more of the A.1 -------NOTES---- L.1 [bvd requirements not 1. Required Actions to fully met.' insert all insertable 0D control rods include placing the reactor mode switch in the shutdown position.

2. Only applicable if the requirement not met is a required LCO.

Enter the applicable Immediately Condition of the affected LCO. OR A.2.1 Initiate action to fully insert Immediately all insertable control rods. AND A.2.2 Place the reactor mode 1 hour switch in the shutdown position. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC L.1 SR .3.10.3.1 Perform the applicable SRs for the required LCOs. According to the applicable SRs BWR/4 STS 3.10.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 55 of 178

Attachment 1, Volume 15, Rev. 0, Page 56 of 178 Single Control Rod Withdrawal - Hot Shutdown 3.10.3 CTS SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY DOC SR 3.10.3.2 ------- L.1 Not required to be met if SR 3.10.3.1 is satisfied for LCO 3.1 0.3.d.1 requirements. Verify all control rods, other than the control rod 24 hours being withdrawn, in a five by five array centered on the control rod being withdrawn, are disarmed. DOC SR 3.10.3.3 Verify all control rods, other than the control rod 24 hours L.1 being withdrawn, are fully inserted. BWR/4 STS 3.10.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 56 of 178

Attachment 1, Volume 15, Rev. 0, Page 57 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.3, SINGLE CONTROL ROD WITHDRAWAL- HOT SHUTDOWN

1. 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.

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

3. ISTS 3.10.3 Condition A has been changed to be consistent with the wording of the ACTIONS Note.

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 57 of 178

Attachment 1,Volume 15, Rev. 0, Page 58 of 178 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 58 of 178

Attachment 1, Volume 15, Rev. 0, Page 59 of 178 Single Control Rod Withdrawal - Hot Shutdown B 3.10.3 B 3.10 SPECIAL OPERATIONS B 3.10.3 Single Control Rod Withdrawal - Hot Shutdown BASES BACKGROUND The purpose of this MODE 3 Special Operations LCO is to permit the withdrawal of a single control rod for testing while in hot shutdown, by imposing certain restrictions. In MODE 3, the reactor mode switch is in the shutdown position, and all control rods are inserted and blocked from withdrawal. Many systems and functions are not required in these conditions, due to the other installed interlocks that are actuated when the reactor mode switch is in the shutdown position. However, circumstances may arise while in MODE 3 that present the need to withdraw a single control rod for various tests (e.g., friction tests, scram timing, and coupling integrity checks). These single control rod withdrawals are normally accomplished by selecting the refuel position for the reactor mode switch. This Special Operations LCO provides the appropriate additional controls to allow a single control rod withdrawal in MODE 3. APPLICABLE With the reactor mode switch in the refuel position,lthe analyses for SAFETY ANALYSES control rod withdrawa uring refueling are appiicable and, provided the assumptions oths nayses are satisfied id' MODE 3, these analyses 0 will bound the cneeces of an' accident.) Explicit safet analyses in Ref.1 ) emontrate that the funciioningfof the refueling the SAR interiocks and adequate SDM will preclude unacceptable reactivity excursions. Refueling interlocks restrict the movement of control rods to reinforce operational procedures that prevent the reactor from becoming critical. These interlocks prevent the withdrawal of more than one control rod. Under these conditions, since only one control rod can be withdrawn, the core will always be shut down even with the highest worth control rod withdrawn if adequate SDM exists. The control rod scram function provides backup protection to normal refueling procedures and the refueling interlocks, which prevent inadvertent criticalities during refueling. Alternate backup protection can be obtained by ensuring that a five by five array of control rods, centered on the withdrawn control rod, are inserted and incapable of withdrawal. As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases. BWR/4 STS B 3.10.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 59 of 178

Attachment 1, Volume 15, Rev. 0, Page 60 of 178 Single Control Rod Withdrawal - Hot Shutdown B 3.10.3 BASES LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation in MODE 3 with the reactor mode switch in the refuel position can be performed in accordance with other Special Operations LCOs (i.e., LCO 3.10.2, "Reactor Mode Switch Interlock Testing," without meeting this Special Operations LCO or its ACTIONS. However, if a single control rod withdrawal is desired in MODE 3, controls consistent with those required during refueling must be implemented and this Special Operations LCO applied. "Withdrawal" in this application includes the actual withdrawal of the control rod as well as maintaining the control rod in a position other than the full-in position, and reinserting the control rod. The refueling interlocks of LCO 3.9.2, "Refuel Position One-Rod-Out Interlock," required by this Special Operations LCO, will ensure that only one control rod can be withdrawn. To back up the refueling interlocks (LCO 3.9.2), the ability to scram the withdrawn control rod in the event of an inadvertent criticality is provided by this Special Operations LCO's requirements in Item d.1. Alternately, provided a sufficient number of control rods in the vicinity of the withdrawn control rod are known to be inserted and incapable of (byeuectnicallyor disarming the withdrawal;(Item d.2), the possibility of criticality on withdrawal of this control rod is sufficiently precluded, so as not to require the scram 0 CRD) capability of the withdrawn control rod. Also, once this alternate (Item d.2) is completed, the SDM requirement to account for both the withdrawn-untrippable control rod and the highest worth control rod may be changed to allow the withdrawn-untrippable control rod to be the single highest worth control rod. APPLICABILITY Control rod withdrawals are adequately controlled in MODES 1, 2, and 5 by existing LCOs. In MODES 3 and 4, control rod withdrawal is only allowed if performed in accordance with this Special Operations LCO or "Single Control Rod WIthdrawal - Cold Special Operations LCO 3.10.4Aand if limited to one control rod. This allowance is only provided with the reactor mode switch in the refuel 0D Shutdown,- position. For these conditions, the one-rod-out interlock (LCO 3.9.2), control rod position indication (LCO 3.9.4, "Control Rod Position Indication"), full insertion requirements for all other control rods and scram functions (LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," and LCO 3.9.5," Control Rod OPERABILITY - Refueling"), or the added administrative controls in Item d.2 of this Special Operations LCO, minimize potential reactivity excursions. ACTIONS A Note has been provided to modify the ACTIONS related to a single control rod withdrawal while in MODE 3. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of BWR/4 STS B 3.10.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 60 of 178

Attachment 1, Volume 15, Rev. 0, Page 61 of 178 Single Control Rod Withdrawal - Hot Shutdown B 3.10.3 BASES ACTIONS (continued) the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LCO not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO. A.1 If one or more of the requirements specified in this Special Operations LCO are not met, the ACTIONS applicable to the stated requirements of the affected LCOs are immediately entered as directed by Required Action A.1. Required Action A.1 has been modified by a Note that clarifies the intent of any other LCO's Required Action, to insert all control rods. This Required Action includes exiting this Special Operations Applicability by returning the reactor mode switch to the shutdown position. A second Note has been added, which clarifies that this Required Action is only applicable if the requirements not met are for an affected LCO. A.2.1 and A.2.2 Required Actions A.2.1 and A.2.2 are alternate Required Actions that can be taken instead of Required Action A.1 to restore compliance with the normal MODE 3 requirements, thereby exiting this Special Operations LCO's Applicability. Actions must be initiated immediately to insert all insertable control rods. Actions must continue until all such control rods are fully inserted. Placing the reactor mode switch in the shutdown position will ensure all inserted rods remain inserted and restore operation in accordance with Table 1.1-1. The allowed Completion Time of 1 hour to place the reactor mode switch in the shutdown position provides sufficient time to normally Insert the control rods. SURVEILLANCE SR 3.10.3.1. SR 3.10.3.2. and SR 3.10.3.3 REQUIREMENTS The other LCOs made applicable in this Special Operations LCO are required to have their Surveillances met to establish that this Special Operations LCO is being met. If the local array of control rods is inserted and disarmed while the scram function for the withdrawn rod is not BWR/4 STS B 3.10.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 61 of 178

Attachment 1, Volume 15, Rev. 0, Page 62 of 178 Single Contr6l Rod Withdrawal - Hot Shutdown B 3.10.3 BASES SURVEILLANCE REQUIREMENTS (continued) available, periodic verification in accordance with SR 3.10.3.2 is required _o prec u e the possibility of criticality. SR 3.10.3.2 has been modified by a Note, which clarifies that this SR is not required to be met if SR 3.10.3.1 0 is satisfied for LCO 3.10.3.d.1 requirements, since SR 3.10.3.2 demonstrates that the alternative LCO 3.1 0.3.d.2 requirements are satisfied. Also, SR 3.10.3.3 verifies that all control rods other than the control rod being withdrawn are fully inserted. The 24 hour Frequency is acceptable because of the administrative controls on control rod withdrawal, the protection afforded by the LCOs involved, and hardwire interlocks that preclude additional control rod withdrawals. REFERENCES 11. FSAR oSecton [1.N.1 o]e3 0D BWRI4 STS B 3.10.34 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 62 of 178

Attachment 1, Volume 15, Rev. 0, Page 63 of 178 B 3.10.3 0 INSERT I The control rods can be hydraulically disarmed by closing the drive water and exhaust water isolation valves. Electrically, the control rods can be disarmed by disconnecting power to all four directional control valve solenoids. l Insert Page B 3.10.3-4 Attachment 1, Volume 15, Rev. 0, Page 63 of 178

Attachment 1, Volume 15, Rev. 0, Page 64 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.3 BASES, SINGLE CONTROL ROD WITHDRAWAL - HOT SHUTDOWN

1. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific nomenclature, number, reference, system description, analysis description, or licensing basis description.

2. Changes have been made to reflect changes made to the Specification.

3. Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

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

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 64 of 178

Attachment 1, Volume 15, Rev. 0, Page 65 of 178 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 15, Rev. 0, Page 65 of 178

Attachment 1, Volume 15, Rev. 0, Page 66 of 178 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.10.3, SINGLE CONTROL ROD WITHDRAWAL- HOT SHUTDOWN There are no specific NSHC discussions for this Specification. Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 66 of 178

Attachment 1, Volume 15, Rev. 0, Page 67 of 178 ATTACHMENT 4 ITS 3.10.4, Single Control Rod Withdrawal - Cold Shutdown Attachment 1, Volume 15, Rev. 0, Page 67 of 178

Attachment 1, Volume 15, Rev. 0, Page 68 of 178 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) Attachment 1, Volume 15, Rev. 0, Page 68 of 178

,Volume 15, Rev. 0, Page 69 of 178 ITS 3.10.4
  '        f  dpoos3fT Page 1 of 1 , Volume 15, Rev. 0, Page 69 of 178

Attachment 1, Volume 15, Rev. 0, Page 70 of 178 DISCUSSION OF CHANGES ITS 3.10.4, SINGLE CONTROL ROD WITHDRAWAL- COLD SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category I - Relaxation of LCO Requirements) The CTS does not allow the reactor mode switch to be placed in the refuel position to allow withdrawal of a single control rod when the unit is in Cold Shutdown (MODE 4). ITS 3.10.4 allows the reactor mode switch position in ITS Table 1.1-1 for MODE 4 to be changed to include the refuel position, and operation considered not to be in MODE 2, to allow withdrawal of a single control rod, and subsequent removal of the associated control rod drive if desired, provided specific requirements are met. In addition, ACTIONS (ITS 3.10.4 ACTIONS A and B) have been added to cover the condition when one or more of the requirements of LCO 3.10.4 are not met. As stated in the ACTIONS Note, ACTIONS A and B are allowed to be entered separately for each requirement of the LCO not met. Furthermore, Surveillance Requirements have been added to help ensure the requirements of the LCO are met. This changes the CTS by allowing the withdrawal of a single control rod and subsequent removal of the CRD in MODE 4, by placing the reactor mode switch in the refuel position, and operation not to be considered in MODE 2, provided certain requirements are met. The purpose of ITS LCO 3.10.4 is to allow the withdrawal of a single control rod and subsequent removal of the CRD in MODE 4 by placing the reactor mode switch in the refuel position and operation not to be considered in MODE 2, provided certain requirements are met. This change is acceptable because the additional requirements will ensure the core remains subcritical and to prevent any inadvertent reactivity excursions. LCO 3.10.4 includes a requirement that all other control rods are fully inserted. LCO 3.10.4 will also require LCO 3.9.2, "Refuel Position One-Rod-Out Interlock," and LCO 3.9.4, "Control Rod Position Indication," to be met or a control rod withdrawal block must be inserted. To back up the refueling interlocks, the ability to scram the withdrawn control rod in the event of an inadvertent criticality is provided by LCO 3.10.4.c.1. Alternately, provided a sufficient number of control rods in the vicinity of the withdrawn Monticello Page 1 of 2 Attachment 1, Volume 15, Rev. 0, Page 70 of 178

Attachment 1, Volume 15, Rev. 0, Page 71 of 178 DISCUSSION OF CHANGES ITS 3.10.4, SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN control rod are known to be inserted and incapable of withdrawal (LCO 3.10.4.c.2), the possibility of criticality on withdrawal of this control rod is sufficiently precluded, so as not to require the scram capability of the withdrawn control rod. Also, once this alternate requirement (LCO 3.1 0.4.c.2) is completed, the SHUTDOWN MARGIN requirement to account for both the withdrawn control rod and the highest worth control rod may be changed to allow the withdrawn control rod to be assumed to be the highest worth control rod. Appropriate Surveillance Requirements also ensure the new requirements are met and periodically verified. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS. Monticello Page 2 of 2 Attachment 1, Volume 15, Rev. 0, Page 71 of 178

Attachment 1, Volume 15, Rev. 0, Page 72 of 178 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 72 of 178

Attachment 1, Volume 15, Rev. 0, Page 73 of 178 Single Control Rod Withdrawal - Cold Shutdown 3.10.4 ~4...JCT5 3.10 SPECIAL OPERATIONS 3.10.4 Single Control Rod Withdrawal - Cold Shutdown DOC LCO 3.10.4 The reactor mode switch position specified in Table 1.1-1 for MODE 4 L.1 may be changed to include the refuel position, and operation considered not to be in MODE 2, to allow withdrawal of a single control rod, and subsequent removal of the associated control rod drive (CRD) if desired, provided the following requirements are met:

a. All other control rods are fully inserte {a.

b.1. LCO 3.9.2, "Refuel Position One-Rod-Out Interlock," and LCO 3.9.4, "Control Rod Position Indication," OR

2. A control rod withdrawal block is inserte c.1. LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation,"

MODE 5requirements for Functions l.a, 1.b, 7.a, 7.b, 10, and 11j (E) of Table 3.3.1.1-1 and LCO 3.9.5, "Control Rod OPERABILITY - Refueling," X OR

                                                    , LCO 3.3.8.2, Reactor Protection System (RPS)

Electrc Power Monitortng, MODE 5 requirements, 0

2. All other control rods in a five by five array centered on the control rod being withdrawn are disarmed; at which time LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," MODE 4 requirements may be changed to allow the single control rod withdrawn to be assumed to be the highest worth control rod.

APPLICABILITY: MODE 4 with the reactor mode switch in the refuel position. BWR/4 STS 3.10.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 73 of 178

Attachment 1, Volume 15, Rev. 0, Page 74 of 178 Single Control Rod Withdrawal - Cold Shutdown 3.10.4 CTS ACTIONS kI^T [\It i I r----- DOC Separate Condition entry is allowed for each requirement of the LCO. L.1 CONDITION J REQUIRED ACTION COMPLETION TIME DOC A. One or more of the LCO A.1 ------- -NOTES--- L.1 Lavlequirements not met with the affected

1. Required Actions to fully insert all insertable 0 control rod insertable. control rods include placing the reactor mode switch in the shutdown position.

2. Only applicable if the requirement not met is a required LCO.

Enter the applicable Immediately Condition of the affected LCO. OR A.2.1 Initiate action to fully insert Immediately all insertable control rods. AND A.2.2 Place the reactor mode 1 hour switch in the shutdown position. Immediately DOC L.1 B. One or5 [ovy requirements not 3 B.1 Suspend withdrawal of the control rod and removal of 0 met with the affected associated CRD. control rod not insertable. AND B.2.1 Initiate action to fully insert Immediately all control rods. OR IJ BWR/4 STS 3.10.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 74 of 178

Attachment 1, Volume 15, Rev. 0, Page 75 of 178 Single Control Rod Withdrawal - Cold Shutdown 3.10.4 CTS ACTIONS (continued) - ._ __. CONDITION REQUIRED ACTION COMPLETION TIME B.2.2 Initiate action to satisfy the Immediately requirements of this LCO. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC SR 3.10.4.1 Perform the applicable SRs for the required LCOs. According to the L.1 applicable SRs DOC SR 3.10.4.2 - NOTE---- L.1 Not required to be met if SR 3.10.4.1 is satisfied for LCO 3.10.4.c.1 requirements. Verify all control rods, other than the control rod 24 hours being withdrawn, in a five by five array centered on the control rod being withdrawn, are disarmed. DOC SR 3.10.4.3 Verify all control rods, other than the control rod 24 hours L.1 being withdrawn, are fully inserted. DOC SR 3.10.4.4 NOTE-LA Not required to be met if SR 3.10.4.1 is satisfied for LCO 3.10.4.b.1 requirements. Verify a control rod withdrawal block is inserted. 24 hours BWR/4 STS 3.10.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 75 of 178

Attachment 1, Volume 15, Rev. 0, Page 76 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.4, SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN

1. These punctuation corrections have been made consistent with the Writers Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

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

3. The MODE 4 Applicability of LCO 3.3.8.2, "Reactor Protection System (RPS) Electric Power Monitoring," as it relates to control rod withdrawal has been revised to not include MODE 4, consistent with the applicability of RPS Functions. In MODE 4, a control rod may be withdrawn from a core cell containing one or more fuel assemblies in accordance with LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown." Therefore, LCO 3.10.4 includes OPERABILITY requirements for RPS Functions (ITS 3.3.1.1) and control rods (ITS 3.9.5). As a result, LCO 3.10.4 has been modified to also include requirements for the RPS Electric Power Monitoring assemblies to be OPERABLE when the RPS Functions and control rods are required to be OPERABLE.

4. ISTS 3.10.4 Condition A has been changed to be consistent with the wording of the ACTIONS Note.

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 76 of 178

Attachment 1, Volume 15, Rev. 0, Page 77 of 178 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 77 of 178

Attachment 1, Volume 15, Rev. 0, Page 78 of 178 Single Control Rod Withdrawal - Cold Shutdown B 3.10.4 B 3.10 SPECIAL OPERATIONS B 3.10.4 Single Control Rod Withdrawal - Cold Shutdown BASES BACKGROUND The purpose of this MODE 4 Special Operations LCO is to permit the withdrawal of a single control rod for testing or maintenance, while in cold shutdown, by imposing certain restrictions. In MODE 4, the reactor mode switch is in the shutdown position, and all control rods are inserted and blocked from withdrawal. Many systems and functions are not required in these conditions, due to the installed interlocks associated with the reactor mode switch in the shutdown position. Circumstances may arise while in MODE 4, however, that present the need to withdraw a single control rod for various tests (e.g., friction tests, scram time testing, and coupling integrity checks). Certain situations may also require the removal of the associated control rod drive (CRD). These single control rod withdrawals and possible subsequent removals are normally accomplished by selecting the refuel position for the reactor mode switch. APPLICABLE With the reactor mode switch in the refuel position, the analyses for SAFETY ANALYSES control rod withd rawa uring refueling are applicable and, provided the assumptions of these nalyses are satisfied 1 MODE 4, these analyses 0 ~~will bound the c o of an accident Explicit safely analyses in nedne lortin the FSAR (Ref. 1 that the funqioningfo-fthe refueling eosrte interlocks and adequate SDM will preclude unacceptable reactivity excursions. Refueling interlocks restrict the movement of control rods to reinforce operational procedures that prevent the reactor from becoming critical. These interlocks prevent the withdrawal of more than one control rod. Under these conditions, since only one control rod can be withdrawn, the core will always be shut down even with the highest worth control rod withdrawn if adequate SDM exists. The control rod scram function provides backup protection in the event normal refueling procedures and the refueling interlocks fail to prevent inadvertent criticalities during refueling. Alternate backup protection can be obtained by ensuring that a five by five array of control rods, centered on the withdrawn control rod, are Inserted and incapable of withdrawal. This alternate backup protection is required when removing a CRD because this removal renders the withdrawn control rod incapable of being scrammed. BWR/4 STS B 3.10.4-1 Rev. 3.0, 03/31/04 Attachment 1,Volume 15, Rev. 0, Page 78 of 178

Attachment 1, Volume 15, Rev. 0, Page 79 of 178 Single Control Rod Withdrawal - Cold Shutdown B 3.10.4 BASES APPLICABLE SAFETY ANALYSES (continued) As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases. LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation in MODE 4 with the reactor mode switch in the refuel position can be performed in accordance with other LCOs (i.e., Special Operations LCO 3.10.2, "Reactor Mode Switch Interlock Testing") without meeting this Special Operations LCO or its ACTIONS. If a single control rod withdrawal is desired in MODE 4, controls consistent with those required during refueling must be implemented and this Special Operations LCO applied. "Withdrawal" in this application includes the actual withdrawal of the control rod as well as maintaining the control rod in a position other than the full-in position, and reinserting the control rod. The refueling interlocks of LCO 3.9.2, "Refuel Position One-Rod-Out Interlock," required by this Special Operations LCO will ensure that only one control rod can be withdrawn. At the time CRD removal begins, the disconnection of the position indication probe will cause LCO 3.9.4, "Control Rod Position Indication," and therefore, LCO 3.9.2 to fail to be met. Therefore, prior to commencing CRD removal, a control rod withdrawal block is required to be inserted to ensure that no additional control rods can be withdrawn and that compliance with this Special Operations LCO is maintained. To back up the refueling interlocks (LCO 3.9.2) or the control rod withdrawal block, the ability to scram the withdrawn control rod in the event of an inadvertent criticality is provided by the Special Operations LCO requirements in Item c.1. Alternatively, when the scram function is not OPERABLE, or when the CRD is to be removed, a sufficient number (byeiectricaly of rods in the vicinity of the withdrawn control rod are required to be disarmingthey

       ~CRD) inserted and made incapable of withdrawa (Item c.2). This precludes the possibility of criticality upon withdrawal of this control rod. Also, once this 0

alternate (Item c.2) is completed, the SDM requirement to account for both the withdrawn-untrippable control rod and the highest worth control rod may be changed to allow the withdrawn-untrippable control rod to be the single highest worth control rod. BWR/4 STS B 3.10.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 79 of 178

Attachment 1, Volume 15, Rev. 0, Page 80 of 178 Single Control Rod Withdrawal - Cold Shutdown B 3.10.4

                                                                       -ingle Cont    Ro Withdrawal - Hot Shutdown-BASES APPLICABILITY                  Control rod withdrawals are adequately controlled in MODES 1, 2, and 5                /

by existing LCOs. In MODES 3 and 4, control rod withdrawal is only / allowed if performed in accordance with Special Operations LCO 3.10.3,V or this Special Operations LCO, and if limited to one control rod. This 0 allowance is only provided with the reactor mode switch in the refuel position. During these conditions, the full insertion requirements for all other control rods, the one-rod-out interlock (LCO 3.9.2), control rod position indication LCO 3.3.8.2. 'Reactor (LCO 3.9.4), and scram functions (LCO 3.3.1.1, "Reactor Protection Protection System (RPS) Electric Power Monitorlng,' MODE 5 requirements. System (RPS) Instrumentation," and LCO 3.9.5, "Control Rod OPERABILITY - Refueling"), or the added administrative controls in 0 Item b.2 and Item c.2 of this Special Operations LCO, provide mitigation of potential reactivity excursions. ACTIONS A Note has been provided to modify the ACTIONS related to a single ) control rod withdrawal while in MODEW-.Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LCO not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO. A.1. A.2.1; and A.2.2 If one or more of the requirements of this Special Operations LCO are not met with the affected control rod insertable, these Required Actions restore operation consistent with normal MODE 4 conditions (i.e., all rods inserted) or with the exceptions allowed in this Special Operations LCO. Required Action A.1 has been modified by a Note that clarifies that the intent of any other LCO's Required Action to insert all control rods. This Required Action includes exiting this Special Operations*Applicability by LCO returning the reactor mode switch to the shutdown position. A second Note has been added to Required Action A.1 to clarify that this Required Action is only applicable if the requirements not met are for an affected LCO. BWR/4 STS B 3.10.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 80 of 178

Attachment 1, Volume 15, Rev. 0, Page 81 of 178 Single Control Rod Withdrawal - Cold Shutdown B 3.10.4 BASES ACTIONS (continued) Required Actions A.2.1 and A.2.2 are specified, based on the assumption that the control rod is being withdrawn. If the control rod is still insertable, actions must be immediately initiated to fully insert all insertable control rods and within 1 hour place the reactor mode switch in the shutdown position. Actions must continue until all such control rods are fully inserted. The allowed Completion Time of 1 hour for placing the reactor mode switch in the shutdown position provides sufficient time to normally insert the control rods. B.1. B.2.1, and B.2.2 If one or more of the requirements of this Special Operations LCO are not met with the affected control rod not insertable, withdrawal of the control rod and removal of the associated CRD must be immediately suspended. If the CRD has been removed, such that the control rod is not insertable, the Required Actions require the most expeditious action be taken to either initiate action to restore the CRD and insert its control rod, or initiate action to restore compliance with this Special Operations LCO. SURVEILLANCE SR 3.10.4.1, SR 3.10.4.2, SR 3.10.4.3, and SR 3.10.4.4 REQUIREMENTS The other LCOs made applicable by this Special Operations LCO are required to have their associated surveillances met to establish that this Special Operations LCO is being met. If the local array of control rods is inserted and disarmed while the scram function for the withdrawn rod is not available, periodic verification is required to ensure that the possibility of criticality remains precluded.#Verification that all the other control rods are fully inserted is required to meet the SDM requirements. Verification that a control rod withdrawal block has been inserted ensures that no other control rods can be inadvertently withdrawn under conditions when position indication instrumentation is Inoperable for the affected control rod. The 24 hour Frequency is acceptable because of the administrative controls on control rod withdrawals, the protection afforded by the LCOs involved, and hardwire interlocks to preclude an additional control rod withdrawal. SR 3.10.4.2 and SR 3.10.4.4 have been modified by Notes, which clarify that these SRs are not required to be met if the alternative requirements demonstrated by SR 3.10.4.1 are satisfied. REFERENCES 11. FSAR iecton [15.1.13 . 0 BWR/4 STS B 3.10.4-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 81 of 178

Attachment 1, Volume 15, Rev. 0, Page 82 of 178 B 3.10.4 0 INSERT I The control rods can be hydraulically disarmed by closing the drive water and exhaust water isolation valves. Electrically, the control rods can be disarmed by disconnecting power to all four directional control valve solenoids. Insert Page B 3.10.4-4 Attachment 1, Volume 15, Rev. 0, Page 82 of 178

Attachment 1, Volume 15, Rev. 0, Page 83 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.4 BASES, SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN

1. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific nomenclature, number, reference, system description, analysis description, or licensing basis description.

2. Changes have been made to reflect changes made to the Specification.

3. Typographical error corrected.

4. Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

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

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 83 of 178

Attachment 1, Volume 15, Rev. 0, Page 84 of 178 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 15, Rev. 0, Page 84 of 178

Attachment 1, Volume 15, Rev. 0, Page 85 of 178 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.10.4, SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN There are no specific NSHC discussions for this Specification. Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 85 of 178

Attachment 1, Volume 15, Rev. 0, Page 86 of 178 ATTACHMENT 5 ITS 3.10.5, Single Control Rod Removal - Refueling Attachment 1, Volume 15, Rev. 0, Page 86 of 178

Attachment 1, Volume 15, Rev. 0, Page 87 of 178 Current Technical Specification (CTS) Markup-and Discussion of Changes (DOCs) Attachment 1, Volume 15, Rev. 0, Page 87 of 178

(. C C ITS 3.10.5 3.0 UMING CONDmONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS

2. ReactMty margin . stuck control rods. 2. Reactety margin - stuck control rods.

0) (a) Control rod drives which cannot be moved with (a) Each fully or partially withdrawn operable 0) 0S control rod drive pressure shall be considered control rod shall be exercised at least one notct CS Inoperable. The directional control valves for each week.

0 inoperable control rods shall be disarmed .0e electrIca and the rods shall be In such (b) If power operation Is continuing with one fully oi positIons that Specification 33.A.1 Is met. partially withdrawn control rod that Is Inoperable because It Is stuck (i.e.. cannot be moved by 0 (b) If a partially or fully withdrawn control rod Is drive or scram pressure), each fully or partially (CD 0 -o stuck (.9., cannot be moved with control rod withdrawn operable control rod shall be 4 See ITS 3.1.3 } 0 drive or scram pressure) the reactor shall be exercised at least one notch every 24 hour brought to a hot shutdown condition within 48 period. This surveillance Is not required It It ha! 0 0r hours. Shutdown Is not required If it Is been confirmed that control rod drive collet confirmed that control rod drive collet housing housing failure Is not the cause of the ID Immovable control rod. failure Is not the cause of the Immovable control rod. (c) If power operation Is continuing with two or aCD (c) If more than six non-fully Inserted control rods more non-fully Inserted control rods that are are Inoperable during power operation, the Inoperable, each operable fully or partially (0E, Co withdrawn control rod shall be exercised at C: reactor shal be brought to a hot shutdown 0 condition within 48 hours. least one notch every 24 hour period. Co 0C

                                                                                                                                                                                         #1)

B. Control Rod Withdrawal -t 6. to0 CD 1. Each control rod snail De couped It ve 0. I See ITS 3.1.3 } completely Inserted and the directional control

 -4'                       Ives disarmed electricallryhiE nisrequTtt1                  __ _        ddproposed[TS3.10.5+

00 00

 -.4 drive fr Inspection as long as     e reactor Is In 3.314.3                                                                                                    77               7/12193 Amendment No. 88 Page 1 of 1

Attachment 1, Volume 15, Rev. 0, Page 89 of 178 DISCUSSION OF CHANGES ITS 3.10.5, SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFUELING ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category I - Relaxation of LCO R6quirements) CTS 3.3.B.1 allows a control rod to be uncoupled from its drive for inspection as long as the reactor is in the refueling mode. ITS 3.10.5 allows the requirements of LCO 3.3.1.1, 'Reactor Protection System (RPS) Instrumentation;" LCO 3.3.8.2, "Reactor Protection System (RPS) Electric Power Monitoring;" LCO 3.9.1, "Refueling Equipment Interlocks," LCO 3.9.2, "Refuel Position One Rod Out Interlock;" LCO 3.9.4, "Control Rod Position Indication;" and LCO 3.9.5, "Control Rod OPERABILITY - Refueling," to be suspended in MODE 5 to allow the removal of a single CRD associated with a control rod withdrawn from a core cell containing one or more fuel assemblies, provided certain specific requirements are met. In addition, an ACTION (ITS 3.10.5 ACTION A) has been added to cover the condition when one or more of the requirements of LCO 3.10.5 are not met. Furthermore, Surveillance Requirements have been added to help ensure the requirements of the LCO are met. This changes the CTS by allowing the removal of a single control rod with certain LCOs not met. The purpose of ITS LCO 3.10.5 is to allow the removal of the CRD in MODE 5, with the associated core cell not defueled, provided certain requirements are met. This change is acceptable because specific requirements imposed prior to removing the CRD will ensure the core remains subcritical and to prevent any inadvertent reactivity excursions. The specific requirements are that all other control rods are fully inserted, all other control rods In a five by five array centered on the withdrawn control rod are disarmed, a control rod withdrawal block is inserted, and no other CORE ALTERATIONS are in progress. In addition, ITS LCO 3.10.5.c allows the requirements of LCO 3.1.1, 'SHUTDOWN MARGIN (SDM)," MODE 5 to be changed to allow the single control rod withdrawn to be assumed to be the highest worth control rod. By requiring all other control rods to be inserted and a control rod withdrawal block be Inserted, the function of the inoperable one-rod-out interlock (LCO 3.9.2) is adequately Monticello Page 1 of 2 Attachment 1, Volume 15, Rev. 0, Page 89 of 178

Attachment 1, Volume 15, Rev. 0, Page 90 of 178 DISCUSSION OF CHANGES ITS 3.10.5, SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFUELING maintained. The Special Operations LCO requirement that no other CORE ALTERATIONS are in progress adequately compensates for the inoperable all-rods-in permissive for the refueling equipment interlocks (LCO 3.9.1). Ensuring that the five by five array of control rods, centered on the withdrawn control rod, are inserted and incapable of withdrawal adequately satisfies the backup protection that LCO 3.3.1.1 and LCO 3.9.2 would have otherwise provided. Also, once these requirements (Items a, b, and c) are completed, the SDM requirement to account for both the withdrawn-untrippable control rod and the highest worth control rod may be changed to allow the withdrawn-untrippable control rod to be the single highest worth control rod. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS. Monticello Page 2 of 2 Attachment 1, Volume 15, Rev. 0, Page 90 of 178

Attachment 1, Volume 15, Rev. 0, Page 91 of 178 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 91 of 178

Attachment 1, Volume 15, Rev. 0, Page 92 of 178 Single CRD Removal - Refueling 3.10.5 K-) CTS 3.10 SPECIAL OPERATIONS 3.10.5 Single Control Rod Drive (CRD) Removal - Refueling DOC LCO 3.10.5 The requirements of: LA LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentatior",. 0 LCO 3.3.8.2, "Reactor Protection System (RPS) Electric Power Monitoringa": 0D LCO 3.9.1, "Refueling Equipment Interlocksai',,§ 0D LCO 3.9.2, "Refuel Position One Rod Out InterloclV" LCO 3.9.4, "Control Rod Position Indication",'an 0D 0D LCO 3.9.5, "Control Rod OPERABILITY - Refuelinj 0D may be suspended in MODE 5 to allow the removal of a single CRD associated with a control rod withdrawn from a core cell containing one or more fuel assemblies, provided the following requirements are met:

a. All other control rods are fully insertec$z ,-]

0

b. All other control rods in a five by five array centered on the withdrawn control rod are disarmrededr, 1 0

c. A control rod withdrawal block Is Inserted and LCO 3.1.1, "SHUTDOWN MARGIN (SDM),' MODE 5 requirements may be changed to allow the single control rod withdrawn to be assumed to be the highest worth control rouEId,-.

No other CORE ALTERATIONS are in progress. 0D d. APPLICABILITY: MODE 5 with LCO 3.9.5 not met. BWR/4 STS 3.10.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 92 of 178

Attachment 1,Volume 15, Rev. 0, Page 93 of 178 Single CRD Removal - Refueling 3.10.5 K- CTS ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME DOC L.l A. !Orieor~morf th" LabLovelequirements,,not A.1 Suspend removal of the CRD mechanism. Immediately 0 met. Io CO. AND A.2.1 Initiate action to fully insert Immediately all control rods. OR A.2.2 Initiate action to satisfy the Immediately requirements of this LCO. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC SR 3.10.5.1 Verify all control rods, other than the control rod 24 hours L.1 withdrawn for the removal of the associated CRD, are fully inserted. DOC SR 3.10.5.2 Verify all control rods, other than the control rod 24 hours L.1 withdrawn for the removal of the associated CRD, in a five by five array centered on the control rod withdrawn for the removal of the associated CRD, are disarmed. DOC SR 3.10.5.3 Verify a control rod withdrawal block is inserted. 24 hours L.1 DOC SR 3.10.5.4 Perform SR 3.1.1.1. According to L.1 SR 3.1.1.1 SR 3.10.5.5 Verify no CORE ALTERATIONS are in progress. 24 hours DOC LI 0 BWR/4 STS 3.10.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 93 of 178

Attachment 1, Volume 15, Rev. 0, Page 94 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.5, SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFUELING KJ 1. 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.

2. Typographical/grammatical error corrected.

3. Changes made to be consistent with similar wording in other Specifications.

K> Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 94 of 178

Attachment 1, Volume 15, Rev. 0, Page 95 of 178 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 95 of 178

Attachment 1, Volume 15, Rev. 0, Page 96 of 178 Single CRD Removal - Refueling B 3.10.5 B 3.10 SPECIAL OPERATIONS B 3.10.5 Single Control Rod Drive (CRD) Removal - Refueling BASES BACKGROUND The purpose of this MODE 5 Special Operations LCO is to permit the removal of a single CRD during refueling operations by imposing certain administrative controls. Refueling interlocks restrict the movement of control rods and the operation of the refueling equipment to reinforce operational procedures that prevent the reactor from becoming critical during refueling operations. During refueling operations, no more than((Ad one controlrodFs permitted to bewithdrawnifrril~a core cei cont~a lone or more fuel assembie. The refueling interlocks use the "ful in" position indicators to determine the position of all control rods. If tfu-1-i0 in" position signal is not present for every control rod, then the all rods in permissive for the refueling equipment interlocks is not present and fuel loading is prevented. Also, the refuel position one-rod-out interlock will not allow the withdrawal of a second control rod. me ] The control rod scram function provides backup protection in the event nerelingj normal refueling procedures, and the refueling interlocks described above vent inadvertent criticalities during refueling. The requirement fortis Sctior to be OPERABLE precludes the possibility of removing the CRD once a control rod is withdrawn from a core cell containing one (0 or more fuel assemblies. This Special Operations LCO provides controls sufficient to ensure the possibility of an inadvertent criticality is precluded, while allowing a single CRD to be removed from a core cell containing one or more fuel assemblies. The removal of the CRD involves disconnecting the position indication probe, which causes noncompliance with LCO 3.9.4, "Control Rod Position Indication," and, therefore, LCO 3.9.1, "Refueling Equipment Interlocks," and LCO 3.9.2, "Refueling Position One-Rod-Out Interlock." The CRD removal also requires isolation of the CRD from the CRD Hydraulic System, thereby causing inoperability of the control rod (LCO 3.9.5, "Control Rod OPERABILITY - Refueling"). APPLICABLE With the reactor mode swiitch in the refuel position tthe analyses~for SAFETY ANALYSES control rod withdrawal Purnng refueling are applicable and Prided the assumptions of thes Jaly Is are satisfied, these analysel will bound 0 the consequences of Accidents. Explicit safety analyses irkthe FSAR (Ref. 1) demronstra'te fh/proper operation of the refueling interlocks and adequate SDM will preclude unacceptable reactivity excursions. BWR14 STS B 3.10.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 96 of 178

Attachment 1, Volume 15, Rev. 0, Page 97 of 178 Single CRD Removal - Refueling B 3.10.5 BASES APPLICABLE SAFETY ANALYSES (continued) Refueling interlocks restrict the movement of control rods and the operation of the refueling equipment to reinforce operational procedures that prevent the reactor from becoming critical. These interlocks prevent the withdrawal of more than one control rod. Under these conditions, since only one control rod can be withdrawn, the core will always be shut down even with the highest worth control rod withdrawn if adequate SDM exists. By requiring all other control rods to be inserted and a control rod withdrawal block initiated, the function of the inoperable one-rod-out i k 392) is adequately maintained. This Special Operations t sus inall CORE ALTERATIO NS (4) compensates for the inoperable all rods in permissive for the refueling equipment interlocks (LCO 3.9.1)..1 4 E The control rod scram function provides backup protection to normal refueling procedures and the refueling interlocks, which prevent inadvertent criticalities during refueling. Since the scram function and refueling interlocks may be suspended, alternate backup protection required by this Special Operations LCO is obtained by ensuring that a five by five array of control rods, centered on the withdrawn control rod, are inserted and are incapable of being withdrawnlby insertion of a 1 (Th ontrolr l 6 r od all other control rods are Inserted Xand Incapable of being withdrawn As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases. LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation in MODE 5 with any of the following LCOs, LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," LCO 3.3.8.2, "Reactor Protection System (RPS) Electric Power Monitoring," LCO 3.9.1, LCO 3.9.2, LCO 3.9.4, or LCO 3.9.5 not met, can be performed in accordance with the Required Actions of these LCOs without meeting this Special Operations LCO or its ACTIONS. However, if a single CRD removal from a core cell containing one or more fuel assemblies is desired in MODE 5, controls consistent with those required by LCO 3.3.1.1, LCO 3.3.8.2, LCO 3.9.1, LCO 3.9.2, LCO 3.9.4, and LCO 3.9.5 must be implemented, and this Special Operations LCO applied. BWR/4 STS B 3.10.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 97 of 178

I Attachment 1, Volume 15, Rev. 0, Page 98 of 178 Single CRD Removal - Refueling B 3.10.5 BASES LCO (continued) By requiring all other control rods to be inserted and a control rod progress withdrawal block initiated, the function of the inoperable one-rod-out interlock (LCO 3.9.2) is adequately maintained. This Special Operations thatcat LCO requirement Ito suspend alil CORE ALTERATION iadequately compensates for the inoperable alljrods~in permissive for the refueling 0 other equipment interlocks (LCO 3.9.1). Ensuring that the five by five array of C 0 (by eledncallyor control rods, centered on the withdrawn control rod, are inserted and hydrai disarming iheCRD) incapable of withdraw adequately satisfies the backup protection that

                                      .1 and LCO 3.9.2 would have otherwise provided. Also, once 0

these requirements (Items a, b, and c) are completed, the SDM requirement to account for both the withdrawn-untrippable control rod and the highest worth control rod may be changed to allow the withdrawn-untrippable control rod to be the single highest worth control rod. APPLICABILITY Operation in MODE 5 is controlled by existing LCOs. The allowance to comply with this Special Operations LCO in lieu of the ACTIONS of LCO 3.3.1.1, LCO 3.3.8.2, LCO 3.9.1, LCO 3.9.2, LCO 3.9.4, and LCO 3.9.5 is appropriately controlled with the additional administrative controls required by this Special Operations LCO, which reduce the potential for reactivity excursions. ACTIONS A.1. A.2.1. and A.2.2 If one or more of the requirements of this Special Operations LCO are not met, the immediate implementation of these Required Actions restores operation consistent with the normal requirements for failure to meet LCO 3.3.1.1, LCO 3.9.1, LCO 3.9.2, LCO 3.9.4, and LCO 3.9.5 (i.e., all control rods inserted) or with the allowances of this Special Operations LCO. The Completion Times for Required Action A.1, Required Action A.2.1, and Required Action A.2.2 are intended to require that these Required Actions be implemented in a very short time and carried through in an expeditious manner to either initiate action to restore the CRD and insert its control rod, or initiate action to restore compliance with this Special Operations LCO. Actions must continue until either Required Action A.2.1 or Required Action A.2.2 is satisfied. BWR/4 STS B 3.10.5-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 98 of 178

Attachment 1, Volume 15, Rev. 0, Page 99 of 178 Single CRD Removal - Refueling B 3.10.5 BASES SURVEILLANCE SR 3.10.5.1, SR 3.10.5.2. SR 3.10.5.3. SR 3.10.5.4, and SR 3.10.5.5 REQUIREMENTS Verification that all the control rods, other than the control rod withdrawn for the removal of the associated CRD, are fully inserted is required to ensure the SDM is within limits. Verification that the local five by five array of control rods, other than the control rod withdrawn for removal of the associated CRD, is inserted and disarmed, while the scram function for the withdrawn rod is not available, is required to ensure that the j [INSERT L..

               ]   possibility of criticality remains precluded. *Verification that a control rod withdrawal block has been inserted ensures that no other control rods can (0

be inadvertently withdrawn under conditions when position indication instrumentation is inoperable for the withdrawn control rod. The Surveillance for LCO 3.1.1, which is made applicable by this Special Operations LCO, is required in order to establish that this Special Operations LCO is being met. Verification that no other CORE ALTERATIONS are being made is required to ensure the assumptions of the safety analysis are satisfied. Periodic verification of the administrative controls established by this Special Operations LCO is prudent to preclude the possibility of an inadvertent criticality. The 24 hour Frequency is acceptable, given the administrative controls on control rod removal and hardwire interlock to block an additional control rod withdrawal. REFERENCES I1. FSARISection [15.1.1 31- 0 BWR/4 STS B 3.10.5-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 99 of 178

Attachment 1, Volume 15, Rev. 0, Page 100 of 178 B 3.10.5 0 INSERT I The control rods can be hydraulically disarmed by closing the drive water and exhaust water isolation valves. Electrically, the control rods can be disarmed by disconnecting power to all four directional control valve solenoids. I Insert Page B 3.10.5-4 Attachment 1, Volume 15, Rev. 0, Page 100 of 178

I Attachment 1, Volume 15, Rev. 0, Page 101 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.5 BASES, SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFUELING k" 1. Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

2. Typographical/grammatical error corrected.

3. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific nomenclature, number, reference, system description, analysis description, or licensing basis description.

4. The Bases have been changed to reflect the Specification.

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

K) Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 101 of 178

Attachment 1, Volume 15, Rev. 0, Page 102 of 178 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 15, Rev. 0, Page 102 of 178

Attachment 1, Volume 15, Rev. 0, Page 103 of 178 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.10.5, SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFUELING There are no specific NSHC discussions for this Specification. Monticello Page 1 of I Attachment 1, Volume 15, Rev. 0, Page 103 of 178

Attachment 1, Volume 15, Rev. 0, Page 104 of 178 ATTACHMENT 6 ITS 3.10.6, Multiple Control Rod Withdrawal - Refueling Attachment 1, Volume 15, Rev. 0, Page 104 of 178

Attachment 1, Volume 15, Rev. 0, Page 105 of 178 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) Attachment 1, Volume 15, Rev. 0, Page 105 of 178

C C C ITS 3.10;6 ITS 0 3.0 LIMITING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS 3.10.6 E. Extended Core and Control Rod DrIve Maintenance ITS 3.10.2} f0) 03 LCO 3.10.6 bMore than one control rod may be wnthdrawn from the ASee r C) Lreactor core durlng Wuages provied tha ecpfo / 2) 0 a D M a e'sepIsitonl Irhe refueling Interlock signal from a LCO 3.10.6. .control ro may ybypassed after the fuel assemblies In CO 3.10.6.a the celn containing (controlled by) that control rod have Lbeen removed from the reactor core. 2 0 4 0.6 Prtb LCO 3.13. eAdd proposed SR 3.10.6.1 and SR 3.10.6.2 M.3 03 3 3 Ei' E'3 ~LCO3.10.6 partc HAdd proposed SR 3.10.6.3 (3M 0 5 1n CA -U -o X 0 (D

                                           =    Add proposed A         A           I a 03                                                                                                                                                             o la                                                                                                                                                           fu tQ                                                                                                                                                           to a0 0                                                                                                                                                             0 to                                                                                                                                                            -4' oo 208         4/18/89 3.1014.10                                                                                         Amendment No. 63 Page 1 of 1

Attachment 1, Volume 15, Rev. 0, Page 107 of 178 DISCUSSION OF CHANGES ITS 3.10.6, MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING 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 CTS 3.1 0.E requires all fuel assemblies to be removed from the core cells associated with the control rods to be removed from the core. It does not make a statement about other control rods that have fuel assemblies in core cells containing one or more fuel assemblies. ITS LCO 3.10.6.b includes a statement that all other control rods in core cells containing one or more fuel assemblies must be fully inserted. This changes the CTS by adding a specific statement that all other control rods in core cells containing one or more fuel assemblies must be fully inserted.

The purpose of the ITS 3.1 0.6.b is to provide a specific statement about all other control rods. The change is acceptable because control rods in core cells containing fuel help to ensure the core remains subcritical when a control rod is withdrawn. CTS 3.1 0.E only includes a statement about the fuel assemblies associated with those cells associated with those control rods removed from the core or to be removed from the core. Thus, the CTS assumption is that all other control rods are inserted. Therefore, the ITS LCO 3.10.6.b is consistent with the current requirements. This change is designated as administrative because it does not result in technical changes to the CTS. A.3 CTS 3.10.E requires the reactor mode switch to be in the Refuel position during extended core and control rod drive maintenance. ITS 3.10.6 specifies the Applicability to be MODE 5 with LCO 3.9.3, LCO 3.9.4, or LCO 3.9.5 not met. This changes the CTS by adding the explicit Applicability for multiple control rod withdrawal during refueling. The MODE 5 Applicability addition in ITS 3.10.6 ("with LCO 3.9.3, LCO 3.9.4, or LCO 3.9.5 not met") is derived from the intent of CTS 3.1 0.E, which says "More than one Control Rod may be withdrawn from the reactor core during outages." During the performance of these activities, ITS 3.9.3 (which requires all control rods to be fully inserted), ITS 3.9.4 (which requires each control rod full-in position indication channel for each control rod to be OPERABLE), and ITS 3.9.5 (which requires all withdrawn control rods to be OPERABLE) are not met. Therefore, this change is acceptable since it is only providing a clearer statement as to when the LCO requirements must be met. This change is designated as administrative because it does not result in technical changes to the CTS. Monticello Page 1 of 4 Attachment 1, Volume 15, Rev. 0, Page 107 of 178

Attachment 1, Volume 15, Rev. 0, Page 108 of 178 DISCUSSION OF CHANGES ITS 3.10.6, MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING MORE RESTRICTIVE CHANGES M.1 CTS 3.10.E does not include any restrictions on any allowed reload sequences. ITS LCO 3.1 0.6.c requires fuel assemblies to only be loaded in compliance with an approved reload sequence. In addition, ITS SR 3.10.6.3 requires the verification, every 24 hours, that fuel assemblies being loaded are in compliance with an approved reload sequence. This changes the CTS by placing restrictions on the reload sequence and providing a Surveillance to periodically verify the restriction is met. The purpose of ITS 3.10.6.c is to provide a new restriction on fuel loading with control rods withdrawn. ITS 3.1 0.6.c will only allow fuel to be loaded in an approved reload sequence. When fuel is loaded into the core with multiple control rods withdrawn, reload sequences are used to ensure that reactivity additions are minimized. Otherwise, all control rods must be fully inserted before loading fuel. This will help ensure a reactivity excursion cannot occur with the requirements of this LCO not met. In addition, SR 3.10.6.3 will help to periodically ensure the restriction is met during fuel loading. This change is designated as more restrictive because it adds a new requirement that is not currently in the CTS. M.2 CTS 3.10.E applies during extended core and control rod drive maintenance. CTS 3.10.E does not provide ACTIONS for when the requirements of the LCO are not met. ITS 3.10.6 ACTION A covers the condition for one or more of the requirements of LCO 3.10.6 not met and requires the immediate suspension of withdrawal of control rods and removal of associated control rod drive (CRD), suspension of loading fuel assemblies, initiation of action to fully insert all insertable control rods in core cells containing one or more fuel assemblies, and initiation of action to satisfy the requirements of LCO 3.10.6. This changes the CTS by adding an appropriate ACTION when the requirements of the LCO are not met. This change adds an appropriate ACTION covering the conditions for when the requirements of the LCO is not met. This change is acceptable because these ACTIONS will help ensure the core remains subcritical during reactor mode switch testing. If one or more of the requirements of this Special Operations LCO are not met, the immediate implementation of these Required Actions restores operation consistent with the normal requirements for refueling (i.e., all control rods inserted in core cells containing one or more fuel assemblies) or with the exceptions granted by this Special Operations LCO. The Required Actions must be taken immediately and carried through in an expeditious manner to either initiate action to restore the affected CRDs and insert their control rods, or initiate action to restore compliance with the LCO. This change is designated as more restrictive because it adds an ACTION to cover the condition when one or more of the requirements of the LCO are not met. M.3 CTS 3.10.E does not provide any Surveillance Requirements to periodically ensure the requirements of the LCO are met. ITS SR 3.10.6.1 requires verification, every 24 hours, that the four fuel assemblies are removed from core cells associated with each control rod or CRD removed. ITS SR 3.10.6.2 requires verification, every 24 hours, that all other control rods in core cells Monticello Page 2 of 4 Attachment 1, Volume 15, Rev. 0, Page 108 of 178

Attachment 1, Volume 15, Rev. 0, Page 109 of 178 DISCUSSION OF CHANGES ITS 3.10.6, MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING containing one or more fuel assemblies are fully inserted. This changes the CTS by adding two new Surveillance Requirements. The purpose of ITS SR 3.10.6.1 and SR 3.10.6.2 is to help to periodically ensure the requirements of the LCO are met. This change is acceptable because these Surveillance Requirements help to ensure the core remains subcritical multiple control rod withdrawal during refueling. This change is designated as more restrictive because it adds three new Surveillance Requirements to the Technical Specifications that are not currently required in the CTS. RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category I - Relaxation of LCO Requirements) CTS 3.10.E requires the reactor mode switch to be "locked" in the "Refuel" position during extended core and control rod drive maintenance. ITS 3.10.6 requires the unit to be in MODE 5, which is defined in ITS Table 1.1-1 as having the reactor mode switch in the shutdown or refuel position with one or more reactor vessel head closure bolts less than fully tensioned. This changes the CTS by deleting the requirement to "lock" the reactor mode switch in the "Refuel" position and will also allow the reactor mode switch to be placed in the "Shutdown" position. The purpose of the CTS 3.10.E requirement to keep the reactor mode switch "locked" in the refuel position is to help ensure the refueling interlocks (one-rod-out) are in effect, which helps prevent criticality during refueling. This change deletes the requirement to maintain the reactor mode switch "locked" in the refuel position, and allows the reactor mode switch to be placed in the shutdown position. The position of the reactor mode switch, average reactor coolant temperature, and the status of the reactor vessel head closure bolts defines the MODE in which the unit is operating. The MODES are defined in ITS Table 1.1-1. The reactor mode switch position is only changed under strict administrative controls to ensure compliance with the Technical Specifications at all times. Before changing the position, unit operators will ensure the requirements of the applicable LCOs are met prior to changing the position of the reactor mode switch. Therefore, the requirement that the reactor mode switch be "locked" in the refuel position has been deleted and is acceptable because the position of the reactor mode switch is controlled under strict administrative controls. The allowance to place the reactor mode switch in the shutdown position is acceptable because in this position no control rod will be able to be withdrawn (i.e., a control rod block is inserted, as required by ITS Table 3.3.2.1-1 Monticello Page 3 of 4 Attachment 1, Volume 15, Rev. 0, Page 109 of 178

Attachment 1, Volume 15, Rev. 0, Page 110 of 178 DISCUSSION OF CHANGES ITS 3.10.6, MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING Function 3). This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS. Monticello Page 4 of 4 Attachment 1, Volume 15, Rev. 0, Page 110 of 178

Attachment 1, Volume 15, Rev. 0, Page 111 of 178 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 111 of 178

Attachment 1, Volume 15, Rev. 0, Page 112 of 178 Multiple Control Rod Withdrawal - Refueling 3.10.6 3.10 SPECIAL OPERATIONS CTS 3.10.6 Multiple Control Rod Withdrawal - Refueling 3.1 0.6.E. LCO 3.10.6 The requirements of: DOCs A.2 and M.1 LCO 3.9.3, "Control Rod Positiorn".IiJ. 0 LCO 3.9.4, "Control Rod Position ndicatiorn diaand LCO 3.9.5, "Control Rod OPERABILITY - Refueling' may be suspended, and the "fulljn" position indicators may be bypassed for any number of control rods in MODE 5,to allow withdrawal of these control rods, removal of associated control rod drives (CRDs), or both, provided the following requirements are met:

a. The four fuel assemblies are removed from the core cells associated with each control rod or CRD to be remoo ve

b. All other control rods in core cells containing one or more fuel assemblies are fully insertev : -o

c. Fuel assemblies shall only be loaded in compliance with an approved s ra reload sequence.

                                                                                                                  .0 DOC     APPLICABILITY:           MODE 5 with LCO 3.9.3, LCO 3.9.4, or LCO 3.9.5 not met.

A.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME DOC M.2 A. flormeof Iao th equiremets not IA.1 Suspend withdrawal of control rods and removal of Immediately 0 met. associated CRDs. AND A.2 Suspend loading fuel Immediately assemblies. AND BWR/4 STS 3.10.6-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 112 of 178

Attachment 1, Volume 15, Rev. 0, Page 113 of 178 Multiple Control Rod Withdrawal - Refueling 3.10.6 CTS ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME DOC Immediately M.2 A.3.1 Initiate action to fully insert all control rods in core cells containing one or more fuel assemblies. OR A.3.2 Initiate action to satisfy the Immediately requirements of this LCO. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC SR 3.10.6.1 Verify the four fuel assemblies are removed from 24 hours M.3 core cells associated with each control rod or CRD removed. DOC SR 3.10.6.2 Verify all other control rods in core cells containing 24 hours M.3 one or more fuel assemblies are fully inserted. DOC SR 3.10.6.3 NOTES M.1 Only required to be met during fuel loading. Verify fuel assemblies being loaded are in compliance with an approved ~~J reload 24 hours 0) sequence. BWR/4 STS 3.10.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 113 of 178

Attachment 1, Volume 15, Rev. 0, Page 114 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.6, MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING

1. 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.

2. Typographical/grammatical error corrected.

3. ISTS LCO 3.10.6.c requires all fuel loading to be in compliance with an approved "spiral" reload sequence. ITS LCO 3.10.6.c does not include the bracketed word "spiral," and only requires loading of fuel to be in compliance with an approved reload sequence. At Monticello, a "spiral" reload sequence is not necessary to help ensure that a fuel assembly is not inadvertently loaded into a core cell with the control rod removed. A Monticello approved reload sequence must meet the following criteria: a) after removing 'all four fuel assemblies from a core cell, no fuel can be loaded into the core with a control rod blade guide in the core cell and the associated control rod not fully inserted; and b) prior to loading the first fuel assembly into a cell that previously contained no fuel assemblies, the associated control rod must be verified to be fully inserted by refueling floor personnel. The first criterion ensures that once a control rod is withdrawn, the control rod blade guide must be removed prior to any fuel being loaded anywhere in the core. This provides a visual cue to the refueling floor personnel that the control rod is not inserted in the associated core cell. This helps ensure that the refueling floor personnel do not inadvertently place a fuel assembly in a core cell whose control rod is not fully inserted (i.e., a core cell with no fuel assemblies and no control rod blade guide present results in a location four time larger than a valid fuel assembly location -

therefore do not load fuel in this core cell). The second criterion ensures that prior to loading fuel in an empty core cell, the control rod is visually verified by the refueling floor personnel to be fully inserted. These two criteria are included as specific steps in'the fuel movement sequence (for each occurrence), and must be signed off prior to performing the subsequent steps. Therefore, these two criteria ensure that no fuel assembly is loaded into the core without the associated control rod fully inserted.

4. Changes made to be consistent with similar wording in other Specifications.

Monticello Page 1 of I Attachment 1, Volume 15, Rev. 0, Page 114 of 178

Attachment 1, Volume 15, Rev. 0, Page 115 of 178 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 115 of 178

Attachment 1, Volume 15, Rev. 0, Page 116 of 178 Multiple Control Rod Withdrawal - Refueling B 3.10.6 B 3.10 SPECIAL OPERATIONS B 3.10.6 Multiple Control Rod Withdrawal - Refueling BASES BACKGROUND The purpose of this MODE 5 Special Operations LCO is to permit multiple control rod withdrawal during refueling by Imposing certain administrative controls. Refueling interlocks restrict the movement of control rods and the operation of the refueling equipment to reinforce operational procedures that prevent the reactor from becoming critical during refueling r;'~n~ operations. During refueling operations, no more than one control ro iis 0 l permitted to bewithdrawn rm1acore cell containing one or more fuel 1 U lassmleWeaiorussem blies are removed from acell, the control rod may be withdrawn with no restrictions. Any number of control rods may be withdrawn and removed from the reactor vessel if their cells contain no fuel. The refueling interlocks use the "fullin" position indicators to determined (D the position of all control rods. If the "full in" position signal is not present for every control rod, then the all rods in permissive for the refueling equipment interlocks is not present and fuel loading is prevented. Also, the refuel position one-rod-out interlock will not allow the withdrawal of a second control rod. To allow more than one control rod to be withdrawn during refueling, these interlocks must be defeated. This Special Operations LCO establishes the necessary administrative controls to allow bypassing the 0 -4 NfI~n"

                          -       position indicators.

APPLICABLE Explicit safety analyseg in the FSAR (Ref. 1)Demonstrate that the SAFETY funche refueling interlocks and adequate SDM will prevent ANALYSES Proper unacceptable reactivity excursions during refueling. To allow multiple control rod withdrawals, control rod removals, associated control rod drive (CRD) removal, or any combination of these, the "fultin" position E (i) indication is allowed to be bypassed for each withdrawn control rod if all fuel has been removed from the cell. With no fuel assemblies in the core cell, the associated control rod has no reactivity control function and is not required to remain inserted. Prior to reloading fuel into the cell, however, the associated control rod must be inserted to ensure that an inadvertent criticality does not occud, as evaluated Hi erence 1 analysis. BWR/4 STS B 3.10.6-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 116 of 178

Attachment 1, Volume 15, Rev. 0, Page 117 of 178 Multiple Control Rod Withdrawal - Refueling B 3.10.6 BASES APPLICABLE SAFETY ANALYSES (continued) As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases. LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation in MODE 5 with either LCO 3.9.3, "Control Rod Position," LCO 3.9.4, "Control Rod Position Indication," or LCO 3.9.5, "Control Rod OPERABILITY - Refueling," not metMcan be performed in 2 accordance with the Required Actions of these LCOs without meeting this Special Operations LCO or its ACTIONS. If multiple control rod withdrawal or removal, or CRD removal is desired, all four fuel assemblies are required to be removed from the associated cells. Prior to entering this LCO, any fuel remaining In a cell whose CRD was previously removed under the provisions of another LCO must be removed.

                      "Withdrawal" in this application includes the actual withdrawal of the control rod as well as maintaining the control rod in a position other than the full-in position, and reinserting the control rod.

When fuel is loaded into the core with multiple control rods withdrawn,

      ,-       ,pi                    reload sequences are used to ensure tha rea vi y a itions are minimized. piral reloading encompasses re ading a cell INSRT        (four fuel locations imm diately adjacent to a control rod) n the edge of a B    continuous fueled region (the cell can be loaded in any Seunce).

Otherwise, all control rods must be fully inserted before loading fuel. APPLICABILITY Operation in MODE 5 is controlled by existing LCOs. The exceptions from other LCO requirements (e.g., the ACTIONS of LCO'3.9.3, LCO 3.9.4, or LCO 3.9.5) allowed by this Special Operations LCO are appropriately controlled by requiring all fuel to be removed from cells whose "fullfin" indicators are allowed to be bypassed. ACTIONS A. 10 If one or more of the requirements of this Special Operations LCO are not met, the immediate implementation of these Required Actions restores operation consistent with the normal requirements for refueling (i.e., all control rods inserted in core cells containing one or more fuel assemblies) or with the exceptions granted by this Special Operations LCO. The BWR/4 STS B 3.10.6-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 117 of 178

Attachment 1, Volume 15, Rev. 0, Page 118 of 178 B 3.10.6 0 INSERT I no fuel assembly is loaded into the core without the associated control rod fully inserted. The approved reload sequence must meet the following criteria: a) after removing all four fuel assemblies from a core cell, no fuel can be loaded into the core with a blade guide in the core cell and the associated control rod not fully inserted; and b) prior to loading the first fuel assembly into a cell that previously contained no fuel assemblies, the associated control rod must be verified to be fully inserted by refueling floor personnel. Therefore, these two criteria ensure that no fuel assembly is loaded into the core without the associated control rod fully inserted. Insert Page B 3.10.6-2 Attachment 1, Volume 15, Rev. 0, Page 118 of 178

Attachment 1,Volume 15, Rev. 0, Page 119 of 178 Multiple Control Rod Withdrawal - Refueling B 3.10.6 BASES ACTIONS (continued) ure Completion Times for Required Action A.1, Required Action A.01, and MReuired Action 3.2 are intended to require that these Required Actions 0D be implemented in a very short time and carried through in an expeditious manner to either initiate action to restore the affected CRDs and insert their control rods, or initiate action to restore compliance with this Special Operations LCO. SURVEILLANCE SR 3.10.6.1. SR 3.10.6.2, and SR 3.10.6.3 REQUIREMENTS Periodic verification of the administrative controls established by this Special Operations LCO is prudent to preclude the possibility of an inadvertent criticality. The 24 hour Frequency is acceptable, given the administrative controls on fuel assembly and control rod removal, and takes into account other indications of control rod status available in the control room. REFERENCES 11. FSARSecton [15.1.13 0 BWR/4 STS B 3.10.6-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 119 of 178

Attachment 1, Volume 15, Rev. 0, Page 120 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.6 BASES, MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING

1. Editorial changes made for enhanced clarify or to be consistent with similar statements in other places in the Bases.

2. Typographical/grammatical error corrected.

3. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific nomenclature, number, reference, system description, analysis description, or licensing basis description.

4. The Bases have been changed to be consistent with the Specification.

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

Monticello Pagel of 1 Attachment 1, Volume 15, Rev. 0, Page 120 of 178

Attachment 1, Volume 15, Rev. 0, Page 121 of 178 Specific No Significant Hazards Considerations (NSHCs) Attachment 1,Volume 15, Rev. 0, Page 121 of 178 f

Attachment 1, Volume 15, Rev. 0, Page 122 of 178 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.10.6, MULTIPLE CONTROL ROD WITHDRAWAL - REFUELING There are no specific NSHC discussions for this Specification. Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 122 of 178 r

, Volume 15, Rev. 0, Page 123 of 178 ATTACHMENT 7 .

ITS 3.10.7, Control Rod Testing - Operating Attachment 1, Volume 15, Rev. 0, Page 123 of 178

Attachment 1, Volume 15, Rev. 0, Page 124 of 178 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) Attachment 1, Volume 15, Rev. 0, Page'124 of 178

, Volume 15, Rev. 0, Page 125 of 178 ITS 3.10.7 4       i Add proposedf ITS 3.10.7 Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 125 of 178

Attachment 1, Volume 15, Rev. 0, Page 126 of 178 DISCUSSION OF CHANGES ITS 3.10.7, CONTROL ROD TESTING - OPERATING ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category I - Relaxation of LCO Requirements) The CTS does not provide any specific requirements for control rod testing during MODES 1 and 2. ITS LCO 3.10.7 allows the requirements of LCO 3.1.6, "Rod Pattern Control," to be suspended to allow performance of SDM demonstrations, control rod scram time testing, and control rod friction testing, provided the bank position withdrawal sequence requirements of SR 3.3.2.1.8 are changed to require the control rod sequence to conform to the specified test sequence; or the RWM is bypassed, the requirements of LCO 3.3.2.1, 'Control Rod Block Instrumentation," Function 2 are suspended, and conformance to the approved control rod sequence for the specified test is verified by a second licensed operator or other qualified member of the technical staff. In addition, an ACTION (ITS 3.10.7 ACTION A) has been added to cover the condition when requirements of LCO 3.10.7 are not met. Furthermore, Surveillance Requirements have been added to help ensure the requirements of the LCO are met. This changes the CTS by allowing the Rod Pattern Control Specification to be suspended during the specified testing. The purpose of ITS 3.10.7 is to allow SDM demonstrations, control rod scram time testing, and control rod friction testing to be performed in MODES 1 and 2 with LCO 3.1.6 not met. ITS LCO 3.10.7 allows LCO 3.1.6, "Rod Pattern Control," to be suspended to allow performance of SDM demonstrations, control rod scram time testing, and control rod friction testing, provided the banked position withdrawal sequence requirements of SR 3.3.2.1.8 are changed to require the control rod sequence to conform to the specified test sequence; or the RWM is bypassed, the requirements of LCO 3.3.2.1, Function 2 are suspended, and conformance to the approved control rod sequence for the

   ; specified test Is verified by a second licensed operator or other qualified member of the technical staff. Either of these two requirements for the Special Operation effectively limits the potential amount and rate of reactivity increase that could Monticello                                Page 1 of 2 Attachment 1, Volume 15, Rev. 0, Page 126 of 178

Attachment 1, Volume 15, Rev. 0, Page 127 of 178 DISCUSSION OF CHANGES ITS 3.10.7, CONTROL ROD TESTING - OPERATING occur during a control rod drop accident (CRDA). This is required because during these conditions, control rod testing is sometimes required and may result in control rod patterns not in compliance with the prescribed sequences. Special CRDA analyses are required to demonstrate that the special sequences will not result in unacceptable consequences, should a CRDA occur during the testing. These analyses, performed in accordance with an NRC approved methodology, are dependent on the special test being performed. Furthermore, the banked position withdrawal sequence requirements are changed to be consistent with the analyses; or the RWM is bypassed, the requirements of LCO 3.3.2.1, Function 2 are suspended, and conformance to the approved control rod sequence for the specified test is verified by a second authorized individual. This change is designated as less restrictive because certain tests will be allowed under the specified conditions that are not allowed in the CTS. Monticello Page 2 of 2 Attachment 1, Volume 15, Rev. 0, Page 127 of 178

Attachment 1, Volume 15, Rev. 0, Page 128 of 178 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 128 of 178

Attachment 1, Volume 15, Rev. 0, Page 129 of 178 Control Rod Testing - Operating 3.10.7 K.-)CT 3.10 SPECIAL OPERATIONS 3.10.7 Control Rod Testing - Operating DOC LCO 3.10.7 The requirements of LCO 3.1.6, "Rod Pattern Control," may be L.1 suspended to allow performance of SDM demonstrations, control rod scram time testing,fcontrol rod friction testin , the S l Pr am provided: Test (3

a. The banked position withdrawal sequence requirements of 0D SR 3.3.2.1.8 are changed to require the control rod sequence to conform to the specified test sequenced OR

b. The RWM is bypassed; the requirements of LCO 3.3.2.1, "Control Rod Block Instrumentation," Function 2 are suspended; and conformance to the approved control rod sequence for the specified test is verified by a second licensed operator or other qualified member of the technical staff.

APPLICABILITY: MODES 1 and 2 with LCO 3.1.6 not met. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME DOC A. Requirements of the A.1 Suspend performance of Immediately L.1 LCO not met. the test and exception to LCO 3.1.6. BWR/4 STS 3.10.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 129 of 178

Attachment 1, Volume 15, Rev. 0, Page 130 of 178 Control Rod Testing - Operating 3.10.7 CTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC SR 3.10.7.1 NOTE-L.1 Not required to be met if SR 3.10.7.2 satisfied. Verify movement of control rods is in compliance During control rod with the approved control rod sequence for the movement specified test by a second licensed operator or other qualified member of the technical staff. DOC SR 3.10.7.2 ---------- l- NOTE----I-- L.1 Not required to be met if SR 3.10.7.1 satisfied. Verify control rod sequence input to the RWM is in Prior to control conformance with the approved control rod rod movement sequence for the specified test. BWR/4 STS 3.10.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 130 of 178

Attachment 1, Volume 15, Rev. 0, Page 131 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.7, CONTROL ROD TESTING - OPERATING

1. The Startup Test Program has been completed at Monticello; therefore, a reference is not needed.

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.

Monticello Page 1 of I Attachment 1, Volume 15, Rev. 0, Page 131 of 178

Attachment 1, Volume 15, Rev. 0, Page 132 of 178 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 132 of 178

Attachment 1, Volume 15, Rev. 0, Page 133 of 178 Control Rod Testing - Operating B 3.10.7 B 3.10 SPECIAL OPERATIONS B 3.10.7 Control Rod Testing - Operating BASES BACKGROUND The purpose of this Special Operations LCO is to permit control rod testing, while in MODES 1 and 2, by imposing certain administrative controls. Control rod patterns during startup conditions are controlled by the operator and the rod worth minimizer (RWM) (LCO 3.3.2.1, "Control Rod Block Instrumentation"), such that only the specified control rod sequences and relative positions required by LCO 3.1.6, "Rod Pattern Control," are allowed over the operating range from all control rods inserted to the low power setpoint (LPSP) of the RWM. The sequences effectively limit the potential amount and rate of reactivity increase that could occur during a control rod drop accident (CRDA). During these conditions, control rod testing is sometimes required that may result in control rod patterns not in compliance with the prescribed sequences of LCO 3.1.6. These tests include SDM demonstrations, control rod scram time testing control rod friction testinfi n~estinq pe r urinq the tartup _est-ProgramL This Special Operations LCO provides the necessary exemption to the requirements of LCO 3.1.6 and provides additional administrative controls to allow the deviations in such tests from the prescribed sequences in LCO 3.1.6. APPLICABLE The analytical methods and assmptions used in evaluating the CRDA SAFETY are summarized in References la d CRDA analyses assume the . d(i ANALYSES reactor operator follows prescribed withdrawal sequences. These sequences define the potential initial conditions for the CRDA analyses. The RWM provides backup to operator control of the withdrawal sequences to ensure the initial conditions of the CRDA analyses are not violated. For special sequences developed for control rod testing, the initial control rod patterns assumed in the safety analysis of References 1 [-'I~g 2miay not be preserved. Therefore special CRDA analyses are *and required to demonstrate that these special sequences will not result in unacceptable consequences, should a CRDA occur during the testing. These analyses, performed in accordance with an NRC approved methodology, are dependent on the specific test being performed. As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs Is provided in their respective Bases. BWR/4 STS B 3.10.7-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 133 of 178

Attachment 1, Volume 15, Rev. 0, Page 134 of 178 Control Rod Testing - Operating B 3.10.7 BASES LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Control rod testing may be performed in compliance with the prescribed sequences of LCO 3.1.6, and during these tests, no exceptions to the requirements of LCO 3.1.6 are necessary. For testing performed with a sequence not in compliance with LCO 3.1.6, the requirements of LCO 3.1.6 may be suspended, provided additional administrative controls are placed on the test to ensure that the assumptions of the special safety analysis for the test sequence are satisfied. Assurances that the test sequence is followed can be provided by either programming the test sequence into the RWM, with conformance verified as specified in SR 3.3.2.1.8 and allowing the RWM to monitor control rod withdrawal and provide appropriate control rod perato r blocks if necessar, orb yenfin conformance to the approved test sequence by a second licensed operatorkor other qualified member of the technical staff. These controls are consistent with those normally applied 0 to operation in the startup range as defined in the SRs and ACTIONS of 0 LCO 3.3.2.1, "Control Rod Block Instrumentation." Control rod testing, while in MODES 1 and 2, with THERMAL POWER APPLICABILITY greater than the LPS e RWI, is adequately controlled by the 0D existing LCOs on power distribution limits and control rod block RtP J instrumentation. Control rod movement during these conditions is not restricted to prescribed sequences and can be performed within the constraints of LCO 3.2.1, "AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)," LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)," LCO 3.2.3, "LINEAR HEAT GENERATION RATE LHGR)," and LCO 3.3.2.1. With THERMAL POWER less than or equa l the IPS he MM, the provisions of this Special Operations LCO are necessary to perform special tests that are not in conformance 0D with the prescribed sequences of LCO 3.1.6. While in MODES 3 and 4, control rod withdrawal is only allowed If performed in accordance with Special Operations LCO 3.10.3, "Single Control Rod Withdrawal - Hot Shutdown," or Special Operations LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," which provide adequate controls to ensure 0D that the assumptions of the safety analyses of Referenc6 1a 2,are satisfied. During these Special Operations and while in MODE ih e! Gi;C 0D one-rod-out interlock (LCO 3.9.2, "Refuel Position One-Rod-Out Interlock,") and scram functions (LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," and LCO 3.9.5, "Control Rod OPERABILITY - Refueling"), or the added administrative controls prescribed in the applicable Special Operations LCOs, provide mitigation of potential reacti3 excursions. 0 BWR/4 STS B 3.10.7-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 134 of 178

Attachment 1, Volume 15, Rev. 0, Page 135 of 178 Control Rod Testing - Operating B 3.10.7 BASES ACTIONS A.1 With the requirements of the LCO not met (e.g., the control rod pattern is not in compliance with the special test sequence, the sequence is improperly loaded in the RWM) the testing is required to be immediately suspended. Upon suspension of the special test, the provisions of LCO 3.1.6 are no longer excepted, and appropriate actions are to be taken to restore the control rod sequence to the prescribed sequence of LCO 3.1.6, or to shut down the reactor, if required by LCO 3.1.6. SURVEILLANCE SR 3.10.7.1 REQUIREMENTS With the special test sequence not programmed into the RWM, a second peratoor licensedo erat or other qualified member of the technical staffeis (I.e., engineer) (l) required to verify conformance with the approved sequence for the test. [Note: A member of the technical t nsidered to be qualified if he possesses skills equal t sd operator [in the following areas:].] This verification must be performed during control rod movement to prevent deviations from the specified sequence. A Note is added to indicate that this Surveillance does not need to belpe e if 0 SR 3.10.7.2 is satisfied. SR 3.10.7.2 When the RWM provides conformance to the special test sequence, the test sequence must be verified to be correctly loaded into the RWM prior to control rod movement. This Surveillance demonstrates compliance with SR 3.3.2.1.8, thereby demonstrating that the RWM is OPERABLE. A

               .INote has been added to indicate that this Surveillance does not need to ber       n if SR 3.10.7.1 is satisfied.                                                       0 REFERENCES        1. NEDE24011-P-A-US, General Electric Standard Application for Reactor Fuel, Supplement for            ates (as amended).                                     )

I (revision specified inSpeafficaton 5.6.3)1

2. Letter from T. Pickens (BWROG) to G.C. Lainas (NRC)

                      "Amendment 17 to General Electric Licensing Topical Report NEDE-24011-P-A,'August 15,1986.                                                           0(

3. USAR. Section 14.7.1. I 0 BWR/4 STS B 3.10.7-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 135 of 178

Attachment 1, Volume 15, Rev. 0, Page 136 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.7 BASES, CONTROL ROD TESTING - OPERATING

1. The Bases have been changed to reflect those changes made to the Specification.

2. Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

3. The Bases have been changed to be consistent with the Specification.

4. Typographical error corrected.

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

6. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific nomenclature, number, reference, system description, analysis description, or licensing basis description.

Monticello Page 1 of I Attachment 1, Volume 15, Rev. 0, Page 136 of 178

Attachment 1, Volume 15, Rev. 0, Page 137 of 178 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 15, Rev. 0, Page 137 of 178

Attachment 1, Volume 15, Rev. 0, Page 138 of 178 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.10.7, CONTROL ROD TESTING - OPERATING There are no specific NSHC discussions for this Specification. Monticello Page I of I Attachment 1, Volume 15, Rev. 0, Page 138 of 178

Attachment 1, Volume 15, Rev. 0, Page 139 of 178 ATTACHMENT 8 ITS 3.10.8, SHUTDOWN MARGIN (SDM) Test - Refueling Attachment 1, Volume 15, Rev. 0, Page 139 of 178

Attachment 1, Volume 15, Rev. 0, Page 140 of 178 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) Attachment 1, Volume 15, Rev. 0, Page 140 of 178

, Volume 15, Rev. 0, Page 141 of 178 ITS 3.10.8
      -4     i Add roposed ITS 3.1 0.8 Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 141 of 178

Attachment 1, Volume 15, Rev. 0, Page 142 of 178 DISCUSSION OF CHANGES ITS 3.10.8, SHUTDOWN MARGIN (SDM) TESTING - REFUELING ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L.1 (Category 1 - Relaxation of LCO Requirements) The CTS does not provide any specific requirements for performing a SDM test in MODE 5. ITS LCO 3.10.8 allows the reactor mode switch position specified in Table 1.1-1 for MODE 5 to be changed to include the startup/hot standby position, and operation considered not to be in MODE 2, to allow SDM testing, provided certain requirements are met. In addition, ACTIONS (ITS 3.10.8 ACTIONS A and B) have been added to cover the condition when one or more of the requirements of LCO 3.10.8 are not met. Furthermore, Surveillance Requirements have been added to help ensure the requirements of the LCO are met. This changes the CTS by allowing SDM testing to be performed in MODE 5, by placing the reactor mode switch in startup/hot standby position, and operation not to be considered in MODE 2, provided certain requirements are met. The purpose of ITS 3.10.8 is to allow the SDM testing to be performed by placing the reactor mode switch in the startup/hot standby position and operation not to be considered In MODE 2, provided certain requirements are met. This change is acceptable because of specific requirements imposed when performing this type of SDM test. One requirement is to require all Reactor Protection System shorting links to be removed. This will place the IRM channels in the non-coincidence mode and places the SRM channels in the RPS circuitry, so that if any SRM channel reaches it trip setpoint a reactor scram will be initiated. Another one of the requirements is that LCO 3.3.2.1, "Control Rod Block Instrumentation," MODE 2 requirements for Function 2 of Table 3.3.2.1-1, with the banked position withdrawal sequence requirement of SR 3.3.2.1.8 changed to require the control rod sequence to conform to the SDM test sequence or conformance to the approved rod sequence of the SDM test is verified by a second licensed operator or other qualified member of the technical staff. Other requirements that must be met are that each withdrawn control rod shall be coupled to the associated CRD, all control rod withdrawals during out of Monticello Page 1 of 2 Attachment 1, Volume 15, Rev. 0, Page 142 of 178

Attachment 1, Volume 15, Rev. 0, Page 143 of 178 DISCUSSION OF CHANGES ITS 3.10.8, SHUTDOWN MARGIN (SDM) TESTING - REFUELING sequence control rod moves must be made in the single notch withdrawal mode, no other CORE ALTERATIONS are in progress, and control rod drive charging header pressure MUST be > 940 psig. These requirements will ensure the proper control rod sequence is followed, all withdrawn rods are capable of being fully inserted, all control rods are withdrawn one notch at a time to ensure criticality can be properly observed, and that no other mechanisms (i.e., CORE ALTERATIONS) occur that can change the reactivity of the core. This change is designated as less restrictive because the SDM test that is not allowed in the CTS will be allowed under certain specified conditions. Monticello Page 2 of 2 Attachment 1, Volume 15, Rev. 0, Page 143 of 178

Attachment 1,Volume 15, Rev. 0, Page 144 of 178 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 144 of 178

Attachment 1, Volume 15, Rev. 0, Page 145 of 178 SDM Test - Refueling 3.10.8 3.10 SPECIAL OPERATIONS CTS 3.10.8 SHUTDOWN MARGIN (SDM) Test - Refueling DOC LCO 3.10.8 The reactor mode switch position specified in Table 1.1-1 for MODE 5 L.1 may be changed to include the startup/hot standby position, and operation considered not to be in MODE 2, to allow SDM testing, provided the following requirements are met: AJIReactor Protection System (RPS)

                                                                          -[shorting links are removed           ra

a. LCO 3.3.1.1, "Reactor Protection System Instrum,0intation," MODE 2/

requirerpents for Functions 2.a and 2.e of Table3.3.1.1-5= b.1. LCO 3.3.2.1, "Control Rod Block Instrumentation," MODE 2 requirements for Function 2 of Table 3.3.2.1-1, with the banked position withdrawal sequence requirements of SR 3.3.2.1.8 changed to require the control rod sequence to conform to the SDM test sequence, OR

2. Conformance to the approved control rod sequence for the SDM test is verified by a second licensed operator or other qualified member of the technical sta 2

c. Each withdrawn control rod shall be coupled to the associated CRD

d. All control rod withdrawalszduring out of sequence control rod movesMshall be made in not out modep 0

e. No other CORE ALTERATIONS are in progresand 0a

f. CRD charging water header pressure 24940qpsig. 0 DOC APPLICABILITY: MODE 5 with the reactor mode switch in startup/hot standby position.

Li BWR/4 STS 3.10.8-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 145 of 178

Attachment 1, Volume 15, Rev. 0, Page 146 of 178 SDM Test - Refueling 3.10.8 CTS ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME DOC A. --- NOTE----- -------- NOTE------- L.1 Separate Condition entry Rod worth minimizer may be is allowed for each bypassed as allowed by control rod. LCO 3.3.2.1, "Control Rod Block Instrumentation," if required, to allow insertion of inoperable control One or more control rod and continued operation. rods not coupled to its __ _- _- _ _ _ _ associated CRD. A.1 Fully insert inoperable 3 hours control rod. AND A.2 Disarm the associated 4 hours CRD. DOC L.1 B. f he aovel,requirement not I B.1 Place the reactor mode switch in the shutdown or Immediately 0D met for reasons other refuel position. than Condition A. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY F12 hours l DOC SR 3.10.8.1 Acc rding sethe y L.1 IapolicabletSRs I DOC SR 3.10.8.2 ----- NOTE---- L.1 Not required to be met if SR 3.10.8.3 satisfied. Perform the MODE 2 applicable SRs for According to the LCO 3.3.2.1, Function 2 of Table 3.3.2.1-1. applicable SRs BWR14 STS 3.10.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 146 of 178

Attachment 1, Volume 15, Rev. 0, Page 147 of 178 SDM Test - Refueling 3.10.8 CTS SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY DOC SR 3.10.8.3 --- ----- NOTE---- L.1 Not required to be met if SR 3.10.8.2 satisfied. Verify movement of control rods is in compliance During control rod with the approved control rod sequence for the SDM movement test by a second licensed operator or other qualified member of the technical staff. DOC SR 3.10.8.4 Verify no other CORE ALTERATIONS are in 12 hours Li progress. DOC SR 3.10.8.5 Verify each withdrawn control rod does not go to the Each time the L.1 withdrawn overtravel position. control rod is withdrawn to "full out" position AND Prior to satisfying LCO 3.10.8.c requirement after work on control rod or CRD System that could affect coupling DOC LA1 SR 3.10.8.6 Verify CRD charging water header pressure 2E94Cq psig. 7 days 0 BWR/4 STS 3.10.8-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 147 of 178

Attachment 1, Volume 15, Rev. 0, Page 148 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.8, SHUTDOWN MARGIN (SDM) TEST - REFUELING

1. ISTS LCO 3.10.8.a and ISTS SR 3.10.8.1 have been modified since the Monticello design does not Include the Reactor Protection System Average Power Range Monitor Neutron Flux - High Setddwn Function. The new requirement in ITS LCO 3.10.8.a will require the Reactor Protection System (RPS) shorting links to be removed. This will place the IRM Neutron Flux - High Function in the non-coincident mode (i.e., any IRM channel trip will result in a reactor scram). In addition, it will place the SRM channels in the RPS circuitry, so that if any SRM channel reaches the SRM trip setpoint, a reactor scram will be initiated. Furthermore, SR 3.10.8.1 will require verification that the RPS shorting links are removed every 12 hours. These requirements will provide additional scram protection, beyond the normally required IRMs.

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

4. The proper plant specific terminology has been provided.

5. Changes made to be consistent with similar wording in other Specifications.

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 148 of 178

Attachment 1, Volume 15, Rev. 0, Page 149 of 178 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 149 of 178

Attachment 1, Volume 15, Rev. 0, Page 150 of 178 SDM Test - Refueling B 3.10.8 B 3.10 SPECIAL OPERATIONS B 3.10.8 SHUTDOWN MARGIN (SDM) Test - Refueling BASES BACKGROUND The purpose of this MODE 5 Special Operations LCO is to permit SDM testing to be performed for those plant configurations in which the reactor pressure vessel (RPV) head is either not in place or the head bolts are not fully tensioned. LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," requires that adequate SDM be demonstrated following fuel movements or control rod replacement within the RPV. The demonstration must be performed prior to or within 4 hours after criticality is reached. This SDM test may be performed prior to or during the first startup following the refueling. Performing the SDM test prior to startup requires the test to be performed while in MODE 5, with the vessel head bolts less than fully tensioned (and possibly with the vessel head removed). While in MODE 5, the reactor mode switch is required to be in the shutdown or refuel position, where the applicable control rod blocks ensure that the reactor will not become critical. The SDM test requires the reactor mode switch to be in the startup/hot standby position, since more than one control rod will be withdrawn for the purpose of demonstrating adequate SDM. This Special Operations LCO provides the appropriate additional controls to allow withdrawing more than one control rod from a core cell containing one or more fuel assemblies when the reactor vessel head bolts are less than fully' tensioned. APPLICABLE Prevention and mitigation of unacceptable reactivity excursions during SAFETY control rod withdrawal, with the reactor mode switch in the startup/hot ANALYSES standby position while in MODE 5, is provided by the intermediate range monitor (IRM) neutron flux scram (LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation"), and control rod block instrumentation (LCO 3.3.2.1, "Control Rod Block Instrumentation"). The limiting reactivity excursion during startup conditions while in MODE 5 is the control rod drop accident (CRDA). CRDA analyses assume that the reactor operator follows prescribed withdrawal sequences. For SDM tests Dprformed within these defined 5a31 sequences, the analyses of References I[apdI2are applicable. However, (i nfor some sequences developed for the SDM testing, then rol patterns assumed in the safety analyses of References 1 [ 2wmay not (E) be met. Therefore, special CRDA analyses, performed in accordance with an NRC approved methodology, are required to demonstrate the BWR/4 STS B 3.10.8-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 150 of 178

Attachment 1, Volume 15, Rev. 0, Page 151 of 178 SDM Test - Refueling B 3.10.8 BASES APPLICABLE SAFETY ANALYSES (continued) SDM test sequence will not result in unacceptable consequences should a CRDA occur during the testing. For the purpose of this test, the protection provided by the normally required MODE 5 applicable LCOs, in addition to the requirements of this LCO, will maintain normal test d3 operations as well as postulated dents within the bounds of th E appropriate safety analyses (Refs. In addition to the added

             -s =hI -n           requirements for the RWM'1ARMl, and control rod coupling, the~iXpi     nc-t fiks /         u mde is specified for out of seq~uence -- withdrawals. Requiring the           o
                            /,-if             mode limits withdrawal steps to a single notch, which limits T slng enotcti inserted reactivity, and allows adequate monitoring of changes in neutron withdrawal     flux, which may occur during the test.

As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases. LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. SDM tests may be performed while in MODE 2, in accordance with Table 1.1-1, without meeting this Special Operations LCO or its ACTIONS. For SDM tests performed while in MODE 5, additional requirements must be met to ensure that adequate protection against potential reactivity excursions is available. To rovide additional scram protection, beyond the normally required IRMs, the APRMs are lsreurdto bad OPERABLE (LC O-3.3 .1, FuIn-tions aand -. m-e) asl thuhteractor were in MOD 2/Bcuse multiple control rods will be withdrawn and the reactor will potentially become criticalblE A the RPS non-coincident s[am modeassoctated 2 rehuirements for/unctions 2.a and 2.e of Table 35.1.1-1 fmust be E I enforced and the approved control rod withdrawal sequence must be (OperatororSenior enforced by the RWM (LCO 3.3.2.1, Function 2, MODE 2), or must be Operator verifiedby a second licensed operato= or other qualified member of the (I eginertechnical _ staff* To provide additional protection against an inadvertent (E) criticality, control rod withdrawals that do not conform to the banked position withdrawal sequence specified in LCO 3.1.6, "Rod Pattem Control," (i.e., out of sequence control rod withdrawals) must be made in the individual notched withdrawal mode to minimize the potential reactivity insertion associated with each movement. Coupling Integrity of withdrawn control rods is required to minimize the probability of a CRDA and ensure proper functioning of the withdrawn control rods, if they are required to scram. Because the reactor vessel head may be removed during these tests, no other CORE ALTERATIONS may be in progress. Furthermore, since the control rod scram function with the RCS at BWRI4 STS B 3.10.8-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 151 of 178

Attachment 1, Volume 15, Rev. 0, Page 152 of 178 B 3.10.8 QJ INSERT 1 SRMs are also required to be OPERABLE so that when any SRM reaches its trip setpoint, a reactor scram will be initiated. This is known as the RPS non-coincident scram mode and is accomplished by removing the shorting links associated with the RPS. Insert Page B 3.10.8-2 Attachment 1, Volume 15, Rev. 0, Page 152 of 178

Attachment 1, Volume 15, Rev. 0, Page 153 of 178 SDM Test - Refueling B 3.10.8 BASES LCO (continued) atmospheric pressure relies solely on the CRD accumulator, it is essential that the CRD charging water header remain pressurized. This Special Operations LCO then allows changing the Table 1.1-1 reactor mode switch position requirements to include the startup/hot standby position, such that the SDM tests may be performed while in MODE 5. APPLICABILITY These SDM test Special Operations requirements are only applicable if

                              -hDM tests are to be performed while in MODE 55/with the reactor/

ve bots not ull ten ned. Additional rquiemens drin thee tststo enforce control rod withdrawal tstacibpostion

                   )
                                                                                                          .0 sequences and restrict other CORE ALTERATIONS provide protection against potential reactivity excursions. Operations in all other MODES are unaffected by this LCO.

ACTIONS A.1 With one or more control rods discovered uncoupled during this Special Operation, a controlled insertion of each uncoupled control rod is required; either to attempt recoupling, or to preclude a control rod drop. This controlled insertion is preferred since, if the control rod fails to follow the drive as it is withdrawn (i.e., is "stuck" in an inserted position), placing the reactor mode switch in the shutdown position per Required Action B.1 could cause substantial secondary damage. If recoupling is not accomplished, operation may continue, provided the control rods are fully inserted within 3 hours and disarmed (electrically or hydraulically) within 4 hours. Inserting a control rod ensures the shutdown and scram capabilities are not adversely affected. The control rod is disarmed to prevent inadvertent withdrawal during subsequent operations. The control rods can be hydraulically disarmed by closing the drive water and exhaust water isolation valves. Electrically the control rods can be disarmed by disconnecting power from all four directional control valve solenoids. Required Action A.1 is modified by a Note that allows the RWM to be bypassed if required to allow insertion of the inoperable control rods and continued operation. LCO 3.3.2.1, "Control Rod Block Instrumentation," Actions provide additional requirements when the RWM is bypassed to ensure compliance with the CRDA analysis. The allowed Completion Times are reasonable, considering the small number of allowed inoperable control rods, and provide time to insert and disarm the control rods in an orderly manner and without challenging plant systems. BWR/4 STS B 3.10.8-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 153 of 178

Attachment 1, Volume 15, Rev. 0, Page 154 of 178 SDM Test - Refueling B 3.10.8 BASES ACTIONS (continued) Condition A is modified by a Note allowing separate Condition entry for each uncoupled control rod. This is acceptable since the Required Actions for this Condition provide appropriate compensatory actions for each uncoupled control rod. Complying with the Required Actions may allow for continued operation. Subsequent uncoupled control rods are governed by subsequent entry into the Condition and application of the Required Actions. B.1 With one or more of the requirements of this LCO not met for reasons other than an uncoupled control rod, the testing should be immediately stopped by placing the reactor mode switch in the shutdown or refuel position. This results in a condition that is consistent with the requirements for MODE 5 where the provisions of this Special Operations LCO are no longer required. SURVEILLANCE SR 3.10.8.1 REQUIREMENTS Performanc of the applicable Skis for LCO 3.3.1.1, F ctions 2.a and ST 2 2.d will e ure that the reactorj operated within the ounds of the safety anal sig 0 ISR 30.8.1. SR 3.10.8.2j and SR 3.10.8.3 0 LCO 3.3.1.1, Funcgons 2.a and 2.e, made applicably in this Special \ Operations LCO, Ore required to have applicable Sorveillances meto establish that this/Special Operations LCO is being met. Howeverithe control rod withdrawal sequences during the SDM tests may be enforced [lIe.egineer) [(Operator or Senior by the RWM (LCO 3.3.2.1, Function 2, MODE 2 requirements) or by a LOperator) second licensed operato or other qualified member of the technical stafW kE As noted, either the applicable SRs for the RWM (LCO 3.3.2.1) must be satisfied according to the applicable Frequencies (SR 3.10.8.2), or the proper movement of control rods must be verified (SR 3.10.8.3). This latter verification (i.e., SR 3.10.8.3) must be performed during control rod movement to prevent deviations from the specified sequence. These surveillances provide adequate assurance that the specified test sequence is being followed. BWR/4 STS B 3.10.84 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 154 of 178

Attachment 1, Volume 15, Rev. 0, Page 155 of 178 B 3.10.8 Q J INSERT2 Periodic verification that the RPS shorting links are removed will help ensure the IRM trips are in non-coincidence mode and that when any SRM reaches its trip setpoint, a reactor scram will be initiated. This will ensure that the reactor is operated within the bounds of the safety analysis. The 12 hour Frequency Is intended to provide appropriate assurance that each operating shift is aware of and verifies compliance with these Special Operations LCO requirements. Insert Page B 3.10.8-4 Attachment 1, Volume 15, Rev. 0, Page 155 of 178

Attachment 1, Volume 15, Rev. 0, Page 156 of 178 SDM Test - Refueling B 3.10.8 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.10.8.4 Periodic verification of the administrative controls established by this LCO will ensure that the reactor is operated within the bounds of the safety analysis. The 12 hour Frequency is intended to provide appropriate assurance that each operating shift Is aware of and verifies compliance with these Special Operations LCO requirements. SR 3.10.8.5 Coupling verification is performed to ensure the control rod is connected to the control rod drive mechanism and will perform its intended function when necessary. The verification is required to be performed any time a control rod is withdrawn to the "fulJout" notch position, or prior to , (I declaring the control rod OPERABLE after work on the control rod or CRD System that could affect coupling. This Frequency is acceptable, considering the low probability that a control rod will become uncoupled

• when it is not being moved as well as operating experience related to uncoupling events.

SR 3.10.8.6 CRD charging water header pressure verification is performed to ensure the motive force is available to scram the control rods in the event of a scram signal./A m' ymum accumulator pressure is spciied, below whih the capability of th, accumulator to perform its i neddfunction become aprodmteN/150 graded and the cumulator is considered in pFal.i The minimum approxiately 1500 acc ato pressure of 940 psig is well below the expected pressure of while still ensuring 0 psi The 7 day Frequency has been shown to be acceptable sufficient pressure forrapid throug operating experience and takes into account indications available Control rod insertion the control room. REFERENCES 1. NEDE-2401 1-P-A-US, General Electric Standard Application for Reactor Fuel, Supplement for Y es (as amende l (revision speatfied In Specification 5.6.3)l 0

2. Letter from T. Pickens (BWROG) to G.C. Lainas, NRC, "Amendment 17 to General Electric Licensing Topical Report NEDE-24011-P-A," August 15, 1986. 0D

3. [Plant specif sient analysis-1. USARSe 14.7.1 0

4. [Plant s reload analysisl 0

BWR/4 STS B 3.10.8-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 156 of 178

Attachment 1, Volume 15, Rev. 0, Page 157 of 178 B 3.10.8 0 INSERT 3 Since the reactor is depressurized in MODE 5, there is insufficient reactor pressure to scram the control rods. Verification of charging water header pressure ensures that if a scram were required, capability for rapid control rod insertion would exist. Insert Page B 3.10.8-5 Attachment 1, Volume 15, Rev. 0, Page 157 of 178

Attachment 1, Volume 15, Rev. 0, Page 158 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.8 BASES, SHUTDOWN MARGIN (SDM) TEST - REFUELING

1. Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific nomenclature, number, reference, system description, analysis description, or licensing basis description.

2. The Bases have been changed to reflect those changes made to the Specification.

3. Editorial change made for enhanced clarity or to be consistent with similar statements in other places in the Bases.

4. The Bases have been changed to be consistent with the Specification.

5. Typographical error corrected.

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

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 158 of 178

Attachment 1, Volume 15, Rev. 0, Page 159 of 178 Specific No Significant Hazards Considerations (NSHCs) Attachment 1, Volume 15, Rev. 0, Page 159 of 178

Attachment 1, Volume 15, Rev. 0, Page 160 of 178 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.10.8, SHUTDOWN MARGIN (SDM) TEST - REFUELING There are no specific NSHC discussions for this Specification. Monticello Page I of I Attachment 1, Volume 15, Rev. 0, Page 160 of 178

Attachment 1, Volume 15, Rev. 0, Page 161 of 178 ATTACHMENT 9 Improved Standard Technical Specifications (ISTS) not adopted in the Monticello ITS Attachment 1, Volume 15, Rev. 0, Page 161 of 178

, Volume 15, Rev. 0, Page 162 of 178 ISTS 3.10.9, Recirculation Loops - Testing , Volume 15, Rev. 0, Page 162 of 178

Attachment 1, Volume 15, Rev. 0, Page 163 of 178 ISTS 3.10.9 Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 163 of 178

Attachment 1, Volume 15, Rev. 0, Page 164 of 178 Recirc lation Loops - Testing 3.10.9 3.10 SPECIA OPEI RATIONS 3.10.9 Re irculat ion Loops - Testing LCO 3.10.9 The requirements of CO 3.4.1, "Recirculation Lo ps Operating," may be suspended for *24 ours to allow:

a. PHYSICS TE 5, provided THERMAL PO ER is * [5]% RTP and

b. Performance the Startup Test Program.

APPLICABIL TY: MODES 1 and 2 wi h less than two recirculation I ops in operation. ACTIONS C NDITION EQUIRED ACTION COMPLETION TIME A. Requi ements of A.1 Insert all insertable control [1] hour 0) LCO .4.1 not met for rods.

    > 241 ours.                         ll                                       _

B. Requ ements of the B.1 Place the reactor mode Immediately LCO ot met for reasons switch in the shutdown other han Condition A. position. SURVEIL ANCE REQUIREMENTSl.l SURVEINCE l lFREQUENCY SR 3.1 .9.1 Verify LCO 3.4.1 equirements suspended for 1 hour l S~24 hours. ll SR 3. 0.9.2 Verify THERMAI POWER is * [5]% RTP durig 1 hour PHYSICS TEST. BWR/4 1STS / I 3.10.9-1 Attachment 1, Volume 15, Rev. 0, Page 164 of 178 Rev. 3.0, 03/31/04

Attachment 1, Volume 15, Rev. 0, Page 165 of 178 JUSTIFICATION FOR DEVIATIONS ISTS 3.10.9, RECIRCULATION LOOPS -TESTING

1. The allowance provided by this Specification is not needed at Monticello; therefore, it has been deleted.

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 165 of 178

Attachment 1, Volume 15, Rev. 0, Page 166 of 178 ISTS 3.10.9 Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 166 of 178

Attachment 1, Volume 15, Rev. 0, Page 167 of 178 Recirc lation Loops - Testing B 3.1 0.9 B 3.10 SPEC AL OPERATIONS B 3.10.9 Rec rculation Loops - Testing BASES BACKGROU D The purpose of this pecial Operations LCO in M DES 1 and 2 is to allow either PHYSI S TESTS or the Startup Test Program to be performed with less than two recirculation loops i operation. Testing performed s part of the Startup Test Pr ram (Ref. 1), or PHYSICS TESTS uthorized under the provision of 10 CFR 50.59 (Ref. 2) or otherwi approved by the NRC, ma e required to be performed under n tural circulation conditions wih the reactor critical. LCO 3.4.1, 'Recir lation Loops Operating," reqires that one or both recirculation loops be in operation during MODE 1 and 2. This Special Operations LCO p ovides the appropriate additi nal restrictions to allow testing at natural arculation conditions or in sing e loop operation with the reactor critical. APPLICA E The operation of e Reactor Coolant Recircula on System is an initial SAFETY condition assume in the design basis loss of c olant accident (LOCA) 0 ANALYSE (Ref. 3). During LOCA caused by a recircula on loop pipe break, the intact loop is ass med to provide coolant flow ring the first few seconds of the postulated ccident. During PHYSICS T STS 5 [5]% RTP, or limited testing du ing the Startup Test Program r the initial cycle, the decay heat in thq reactor is sufficiently low, su that the consequences of an accident a reduced and the coastdown characteristics of the recirculation loo s are not important. In additi n, the probability of a Design Basis A ,ident (DBA) or other accidens occurring during the limited time allo ed at natural circulation or in ingle loop operation is low. As described in CO 3.0.7, compliance with pecial Operations LCOs is optional, and th refore, no criteria of 10 CFR 0.36(c)(2)(ii) apply. Special Operati ns LCOs provide flexibility to perform certain operations by appropriatel modifying requirements of ot er LCOs. A discussion of the criteria sat fled for the other LCOs is pro ided in their respective Bases. LCO As described i LCO 3.0.7, compliance with his Special Operations LCO is optional. H wever, to perform testing at n tural circulation conditions or with a singl operating loop, operations st be limited to those tests defined in the tartup Test Program or appr ved PHYSICS TESTS performed at [5]% RTP. To minimize the robability of an accident, BWRI 4 STS I B 3.10.9-1 I Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 167 of 178

Attachment 1, Volume 15, Rev. 0, Page 168 of 178 I I Recircul tion Loops - Testing c/ B 3.10.9 BASES LCO (continu d) while operating at nat ral circulation conditions or w h one operating loop, the duration of t ese tests is limited to 5 24 ho rs. This Special Operations LCO the allows suspension of the requ rements of LCO 3.4.1 during such testing. n addition to the requirements of this LCO, the normally required M DE 1 or MODE 2 applicable L Os must be met. APPLICABIL T This Special Operati ns LCO may only be used wh le performing testing at natural circulation conditions or while operating ith a single loop, as may be required as art of the Startup Test Progra or during low power PHYSICS TESTS. dditional requirements during these tests to limit the time at natural circu ation conditions reduces the p obability that a DBA may occur with bot recirculation loops not in oper tion. Operations in all other MODES are affected by this LCO. ACTIONS A.1 With the testing pe ormed at natural circulation c nditions or with a single operating loop, an the duration of the test excee ing the 24 hour time limit, actions shoul be taken to promptly shut do n. Inserting all insertable control ds will result in a condition th t does not require both recirculation loops o be in operation. The allow Completion Time of 0 1 hour provides s ificient time to normally insert he withdrawn control rods. B.1 With the require ents of this LCO not met for r asons other than those specified in Con tion A (i.e., low power PHYSI S TESTS exceeding [5]% RTP, or un pproved testing at natural circ lation), the reactor mode switch should im ediately be placed in the shu down position. This results in a cond ion that does not require both recirculation loops to be in operation. The ction to immediately place the reactor mode switch in the shutdown positi n prevents unacceptable cons quences from an accident initiate from outside the analysis bou ds. Also, operation beyond authori d bounds should be terminat d upon discovery. BWRIj STS I B3.10.9-2 I Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 168 of 178

Attachment 1, Volume 15, Rev. 0, Page 169 of 178 I I Recircul tion Loops - Testing R B 3.10.9 BASES SURVEILLAN E SR 3.10.9.1 and SR .10.9.2 REQUIREMEN S Periodic verification o the administrative controls es ablished by this LCO will ensure that the re ctor is operated within the bo nds of this LCO. Because the 1 hour F equency provides frequent c ecks of the LCO requirements during tie allowed 24 hour testing int rval, the probability of l operation outside the mits concurrent with a postul ted accident is l reduced even furthers REFERENCED 1.FSAR, Chapter 4].l l 2. 10 CFR 50.59.l

3. FSAR, Section .3.3.4].

4. FSAR, Section ].

0D BWRI4 TS B 3.10.9-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 169 of 178

Attachment 1, Volume 15, Rev. 0, Page 170 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.9 BASES, RECIRCULATION LOOPS -TESTING

1. Changes have been made to reflect those changes made to the Specification.

Monticello Page 1 of I Attachment 1, Volume 15, Rev. 0, Page 170 of 178

, Volume 15, Rev. 0, Page 171 of 178 ISTS 3.10.10, Training Startups , Volume 15, Rev. 0, Page 171 of 178

Attachment 1, Volume 15, Rev. 0, Page 172 of 178 ISTS 3.10.10 Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 172 of 178

Attachment 1, Volume 15, Rev. 0, Page 173 of 178 Training Start. ups 3.10 .10 3.10 SPECIA OPEI RATIONS 3.10.10 Tr ning S;tartups LCO 3.10.10 The low pressure co lant injection (LPCI) OPERA ILITY requirements specified in LCO 3.5 1, "Emergency Core Cooling ystems (ECCS) - Operating," may be hanged to allow one residual heat removal subsystem to be ali ned in the shutdown cooling ode for training startups, provided t following requirements are et:

a. All OPERABL intermediate range monitor IRM) channels are

                          * [25/40] divis ns of full scale on Range 7 nd

b. Average reac r coolant temperature is < 2 00°F.

APPLICABI ITY: MODE 2 with one PCI subsystem suction valv closed. ACTIONS 0 C NDITION REQUIRED ACTION COMPLETION TIME A. One r more of the A.1 Place the reactor mode Immediately abov requirements not switch in the shutdown meposition. SURVEIL NCE REQUIREMENTS _______ SURVEIL NCE FREQUENCY SR 3.1 .10.1 Verify all OPERA LE IRM channels are * [25/ 0] 1 hour divisions of full s ale on Range 7. SR 3. 0.10.2 Verify average r actor coolant temperature is 1 hour

                   <200 0F.

BWR/4 STS 3.10.10-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 173 of 178

Attachment 1, Volume 15, Rev. 0, Page 174 of 178 JUSTIFICATION FOR DEVIATIONS ISTS 3.10.10, TRAINING STARTUPS

1. The allowance provided by this Specification is not needed at Monticello; therefore, it

• has been deleted.

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 174 of 178

Attachment 1, Volume 15, Rev. 0, Page 175 of 178 ISTS 3.1 0.10 Bases Markup and Justification for Deviations (JFDs) Attachment 1, Volume 15, Rev. 0, Page 175 of 178

Attachment 1, Volume 15, Rev. 0, Page 176 of 178 Training Startups B 3.10.10 B 3.10 SPECI L OPERATIONS B 3.10.10 Trai ing Startups BASES , BACKGROU D The purpose of this Special Operations LCO is to ermit training startups to be performed whilh in MODE 2 to provide plant tartup experience for reactor operators. This training involves withdraw I of control rods to achieve criticality a then further withdrawal of c ntrol rods, as would be experienced during n actual plant startup. Durin these training startups, if the reac r coolant is allowed to heat p, maintenance of a constant reactor ve el water level requires the r jection of reactor coolant through the Reactor Water Cleanup Syst m as the reactor coolant specific vol me increases. Since this re ults in reactor water discharge to the ra ioactive waste disposal syst m, the amount of discharge should b minimized. This Special 0 erations LCO provides the appropriate ad tional controls to allow one r sidual heat removal (RHR) subsystem o be aligned in the shutdown cooling mode, so that the reactor coolant ten perature can be controlled d ring the training startups, thereby minimizin the discharge of reactor wat r to the radioactive waste disposal system. 03 APPLICAB E The Emergency re Cooling System (ECCS) i designed to provide SAFETY core cooling folio ing a loss of coolant acciden (LOCA). The low ANALYSE pressure coolant jection (LPCI) mode of the HR System is one of the ECCS subsyste assumed to function during LOCA. With reactor power 5 1% RTP equivalent to all OPERABL intermediate range monitor (IRM) ch nnels < 25/40 divisions of ful scale on Range 7) and average reactor olant temperature < 2000 F, he stored energy in the reactor core and oolant system is very low, a d a reduced complement of ECCS can pr ide the required core coolin thereby allowing operation with o e RHR subsystem in the shu down cooling mode (Ref. 1). As described in CO 3.0.7, compliance with ecial Operations LCOs is optional, and th refore no criteria of 10 CFR 0.36(c)(2)(ii) apply. Special Operations LC s provide flexibility to perfo certain operations by appropriately m difying requirements of othe LCOs. A discussion of the

      . I           criteria satisfie     r the other LCOs Is pr               r respective Bases.

LCO As described i LCO 3.0.7, compliance with is Special Operations LCO is optional. Tr ining startups may be perfor ed while in MODE 2 with no RHR subsyste s aligned in the shutdown oling mode and, therefore, without meetin this Special Operations LC or its ACTIONS. However, to minimize th discharge of reactor coolant the radioactive BWR/41STS I B 3.1 0.10-1 I Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 176 of 178

Attachment 1, Volume 15, Rev. 0, Page 177 of 178 I I Training Startups BASES I' LCO (continue ) waste disposal syste performance of the training lartups may be B 3.1 0.10 accomplished with on RHR subsystem aligned in the shutdown cooling mode to maintain ave ge reactor coolant temperature < 200 0 F. Under these conditions, the HERMAL POWER must be njaintained S 1% RTP (equivalent to all OPE BLE IRM channels 5 25/40 divisions of full scale on Range 7) and the verage reactor coolant temp rature must be

                 < 2000 F. This Speci Operations LCO then allows Changing the LPCI OPERABILITY requir ments. In addition to the req irements of this LCO, the normally required MODE 2 applicable LOOs mijst also be met.

APPLICABILI Training startups whi e in MODE 2 may be perform d with one RHR subsystem aligned i the shutdown cooling mode tf control the reactor coolant temperature Additional requirements during these tests to restrict the reactor p wer and reactor coolant temp rature provide protection against p tential conditions that could r quire operation of both RHR subsystems in the LPCI mode of operation. perations in all other MODES are unaffe ed by this LCO. l ACTIONS A.1 0 With one or more o the requirements of this LCO not met, (i.e., any OPERABLE IRM c annel > 25/40 divisions of full scale on Range 7, or average reactor co lant temperature 2 200 0F) th reactor may be in a condition that requ res the full complement of EC S subsystems and the reactor mode switu( must be immediately placed in the shutdown position. This res Its in a condition that does no require all RHR subsystems to be PERABLE in the LPCI mode of operation. This action may restore comp iance with the requirements o this Special Operations LCO or may resul in placing the plant in either ODE 3 or MODE 4. SURVEILI. NCE SR 3.10.10.1 and SR 3.10.10.2 REQUIRE ENTS Periodic verificati n that the THERMAL POWE and reactor coolant temperature limit of this Special Operations LI0 are satisfied will ensure that the stored e ergy in the reactor core and r actor coolant are sufficiently low t preclude the need for all RH subsystems to be aligned in the LPCI mod of operation. The 1 hour Fre uency provides frequent checks of these CO requirements during the aining startup. REFEREkCES 1. FSAR, Sect on [6.3.2]. BWRI4 TS B 3.10.10-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 0, Page 177 of 178

Attachment 1, Volume 15, Rev. 0, Page 178 of 178 JUSTIFICATION FOR DEVIATIONS ITS 3.10.10 BASES, TRAINING STARTUPS

1. Changes have been made to reflect those changes made to the Specification.

Monticello Page 1 of 1 Attachment 1, Volume 15, Rev. 0, Page 178 of 178}}