ML060230431

ITS Conversion Beyond Scope Issue 7

ML060230431
Person / Time
Site:	Monticello
Issue date:	01/23/2006
From:	Nuclear Management Co
To:	Office of Nuclear Reactor Regulation
References
TAC MC7610
Download: ML060230431 (3)

Text

ED NRC ITS TRACKING NRC Reviewer ID 200510281131 Conferece CalRequested? No Category Discussion

[IS Section: D)O( Number: JFI) Number: Page Nurnhcr(s):

ITSnformation 5.0 L.4 None 101 ISITSNumber: I asesJ _Nurrber:

BSI 7 None This is a Beyond Scope Issue (TAC No. MC7610)

You propose to delete CGCS from ITS 5.!.2, based upon the following:

The Combustible Gas Control System is rno longer required and has been removed from the Monticello Technical Specifications, and that this has been documented in License Amendment No. 138, dated May 21, 2004 (ADAMS Accession No. ML041180612).

A plant modification is complete which removes all CGCS communication with primary containment.

A plant modification is complete which removes Residual Heat Removal (RIIR) System supply lines to the CGCS. The RIIR system is included in ITS 5.5.2, but removing the RIIR system from the CGCS removes any potehtial for highly radioactive fluid from entering CGCS via RIIR.

1. In the application, it states that Techniaal Specification requirements governing the OPERABILITY of the Combustible Gas Control System (CGCS ) have been previously removed. The Hydrogen Recombiner portion of the CGCS was removed from Technical Specifications; however, it appears much of the CGCS piping appears to still exist.

The statement was also made that a plant modification was completed which removed all CGCS communication with primary containment. The Containment Atmosphere Monitoring System (CAMS) appears to still be available to place in service, and the CAMS appears to be part of the CGCS, in that the inlet and return lines tap off the 4" CGCS process line.

Although the Hydrogen Recombiner portion of the CGCS may be retired in place, a portion of the CGCS still appears Comment to communicate with primary containment and may still be subject to highly radioactive fluid, as in the case when the CAMS is placed in service post-accident.

1) Provide further clarification as to the status of the CGCS and the system current system interface with primary containment.

2) Provide justification as to how the CGCS may be completely removed from the proposed program requirements of ITS 5.5.2 if it may still be subject to potentially radioactive fluid.

2. If a proposed response to Question 1 is utilizing the ITS 5.5.2 requirement related to Process Sampling equipment monitoring, then

1) Is the CAMS being monitored as part of your CTS 6.8.11 program?

2) Will it be monitored under the proposed ITS 5.5.2

3. You state that the RIIR system cooling water supply lines have been eliminated to the CGCS.

If the CGCS supply valves (CGC-1-1 or CGC-1-2) are open or can re-opened, then it appears that the RIIR system could potentially communicate with the CGCS.

1) Explain how the RIIR supply line is eliminated and where is this isolation (the supply isolation valve or at the recombiner skid)?

2) Are CGC-1-1 and CGC-1-2 administratively controlled closed and/or another method used (i.e. a blank flange installed) for positive isolation?

4. What will be the process for maintaining the CGCS and associated RIIR system configuration, such that any future modifications do not inadvertently impact this proposed change?

Issue Date 10/28/2005

> Responses Date Created: 10128/2005 11:31 AM by Terry Beltz http://www.excelserv ices.com/exceldbs/itstrackmontice]l.o.nsf/I fddcea 1Od3bdbb585256e85000138e4/01... 1/23/2006

-3 LICENSEE COMMINENTS lI1 200510281131 Validation Required? No lResp*~Rse Suhrnittei 11/08/2005 Improved Technical Specification (ITS) 5.5 Discussion of Changes (DOC) L.4 (Attachment 1, Volume 17, Rev. 0, Page 76 of 143) states that a pl!ant modification has been completed that removes all communication between the Combustible Gas Control System (CGCS) and the containment and eliminated the Residual Heat Removal (RIIR) System cooling water supply lines to the CGCS. This plant modification was documented under Modification Procedure 03Q145, and the piping modifications were performed during refueling outage RF022. The CGCS inlet and return lines piping was cut and capped on the containment side of the Containment Atmosphere Monitoring System (CAMS) sample connection points. The RIIR Comment System cooling water supply lines wvere cut on the CGCS side of valves CGC-1-1 and CGC-1-2.

Furthermore, a high point vent connection was added to the RIIR System just downstream of CGC-1-1 and CGC-1-2 (and the valves were redesignated as RIIR System valves) and two vent valves were added and the vent capped.

In addition, during the development cf the Monticello response to this question, it was noted that the Current Technical Specifications (CTS) Markup page associated with this change was not correctly annotated. The words "Combustible Gas Control," in CTS 6.8.B (Page 55 of 143) should have been deleted and annotated with DOC L.4. This will be corrected as shown in the attachment to this response.

Date Created: 11/08/2005 04:57 PM by Jerry Jones Last Modified: 11/08/2005 05:00 PM ITS submittal changed rages.pdf http://www.excelser-vices.com/exceldbs/itstrackmonticeLlo.nsf/I fddcea 1Od3bdbb5 85256e85000 13 8e4/cb... 1/23/2006

ITS 5.5 ITS 5.5.2 B. Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain

,I-. 5.5.2 highly radioactive fluids during a serious transient or accident to levels as low as practicable. stems indude Core Sp a) High Pressure Coolant Injection. Residual Heat Removal, Reactor Core Isolation CoolingGa n proces sampling, and Standby Gas Treatment. The program shall include the following:

0 5.5.2.a 1. Preventive maintenance and periodic visual inspection requirements; and 5.5.2.b 2. Integrated leak test requirements for each system 0 5.5.2 The provisions of Specification 4.0.B are applicable.

A program acceptdle to the Commission was describedn a Inttnrr tprtf n~rnmhe r.1 1707<4 m" L I nr) nIar tK fl,..to of Nuclear qetctor Regulation, 'Lessons LearnedAifiplementatlon.' l

-4 C. (Deleted) I

-U

'U 03 to3 CA) 6.8 254 06/17/03 Amendment No. 4244 136 Page 2 of 15