L-MT-09-041, Supplement to License Amendment Request: Revision to the Allowable Value and Channel Calibration Surveillance Interval for the Recirculation Riser Differential Pressure - High Function

Supplement to License Amendment Request: Revision to the Allowable Value and Channel Calibration Surveillance Interval for the Recirculation Riser Differential Pressure - High Function

ML090930499
Person / Time
Site:	Monticello
Issue date:	04/02/2009
From:	O'Connor T Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-09-041, TAC MD6864
Download: ML090930499 (9)

Text

April 2, 2009 L-MT-09-041 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 Renewed Facility Operating License No. DPR-22 Supplement to License Amendment Request: Revision to the Allowable Value and Channel Calibration Surveillance Interval for the Recirculation Riser Differential Pressure - High Function (TAC No. MD6864)

References:

1) Letter NMC to NRC, "License Amendment Request: Revision to the Allowable Value and Channel Calibration Surveillance Interval for the Recirculation Riser Differential Pressure - High Function,"

(L-MT-07-055), dated September 25, 2007.

2) Letter from the Technical Specification Task Force (TSTF) to the NRC, TSTF-09-07, 'Industry Plan to Resolve TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions",' dated February 23, 2009. (ADAMS Ascension No. ML090540849)

On September 25,2007, the Nuclear Management Company, (NMC) LLC a predecessor license holder to the Northern States Power Company - a Minnesota corporation (NSPM),(') submitted a license amendment request(LAR) to revise the allowable value and channel calibration surveillance interval for the Recirculation Riser Differential Pressure - High function (Function 2.j in Technical Specification (TS) Table 3.3.5.1-1 (Reference I). This proposed change was based on a reanalysis of the small break Loss of Coolant Accident which determined a new minimum detectable break area for the Low Pressure Coolant Injection loop select logic.

At a public meeting on January 8, 2009, the industry and the U.S. Nuclear Regulatory Commission (NRC) discussed actions to resolve TSTF-493. It was agreed the industry would develop and submit a course of action for resolution. As described therein, Reference 2 provides a mutually acceptable approach incorporating both industry and NRC concerns and preferences.

1.

NSPM is incorporated as a wholly owned subsidiary of Xcel Energy, Inc. Transfer of operating authority from the NMC to NSPM occurred on September 15, 2008.

2807 West County Road 75 Monticello, Minnesota 55362-9637 Telephone: 763.295.5151 Fax: 763.295.1454

Document Control Desk Page 2 of 2 Reference 2 indicates that licensees with licensing actions in process during the development, review and approval of TSTF-493, Revision 4, are encouraged to apply approaches consistent with that proposed in Reference 2, with the exception that the TSTF-493 footnotes would be applied only to the specific setpoints being changed.

The NRC indicated during a teleconference with the NSPM on April 1, 2009, that to readily address concerns with respect to the setpoint issues associated with TSTF-493, and facilitate further processing of the LAR (Reference I), that the NSPM should consider adopting an approach consistent with that described in Reference 2, and propose footnotes consistent with that proposal.

Consistent with this direction, NSPM proposes to add appropriate footnotes(*) to Surveillance Requirement (SR) 3.3.5.1.7 in TS Table 3.3.5.1-1 for Function 2.j, Recirculation Riser Differential Pressure - High (Break Detection). provides a copy of the revised TS pages. Enclosure 2 provides a revised copy of the associated draft marked-up TS Bases pages for information.

The NSPM has reviewed the No Significant Hazards Consideration determination provided in Reference I for this LAR and determined that it is still applicable. The MNGP Plant Operations Review Committee has reviewed the proposed changes herein. In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Minnesota Official.

Summary of Commitments No new commitments or changes to any existing commitments are proposed by this letter.

I declare under penalty of perjury that the foregoing is true and correct.

Executedp April aY 2f09.

resident, Monticello Nuclear Generating Plant Power Company - Minnesota cc:

Administrator, Region Ill, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce

2.

Footnotes (c) and (d) within this TS table were developed during the Monticello Improved Standard Technical Specifications conversion and approved by the NRC as part of that amendment, Amendment No. 146.

ENCLOSURE I MONTICELLO NUCLEAR GENERATING PLANT PROPOSED TECHNICAL SPECIFICATION CHANGES (2 pages follow)

ECCS lnstrumentation 3.3.5.1 Table 3.3.5.1-1 (page 3 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED FROM OR OTHER CHANNELS SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.l REQUIREMENTS VALUE

2. LPCl System

e.

Reactor Steam Dome Pressure Permissive - Bypass Timer (Pump Permissive)

f.

Low Pressure Coolant Injection Pump Start - Time Delay Relay Pumps A, B Pumps C, D

g.

Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)

h.

Reactor Steam Dome Pressure -

Low (Break Detection)

i.

Recirculation Pump Differential Pressure

- High (Break Detection)

j.

Recirculation Riser Differential Pressure

- High (Break Detection) 1,2,3 2

C SR 3.3.5.1.7 r 18 minutes SR 3.3.5.1.8 and 5 22 minutes B

SR 3.3.5.1.7 2 18 minutes SR 3.3.5.1.8 and 1

22 minutes I 2 3 4 perpump B

SR 3.3.5.1.7 4(a), '56)

SR 3.3.5.1.8 15.33 seconds 1 10.59 seconds I 2 3 1 perpump E

SR 3.3.5.1.2 2 360 gpm and 4(a),

SR 3.3.5.1.7 s 745 gpm SR 3.3.5.1.8 1, 2, 3, 4

B SR 3.3.5.1.2 r 873.6 psig SR 3.3.5.1.7 and SR 3.3.5.1.8 s 923.4 psig 1,2,3 4 per pump C

SR 3.3.5.1.2 r 63.5 inches SR 3.3.5.1.7 wc SR 3.3.5.1.8 as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(d)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip determine the as-found tolerance and the as-left tolerance are specified in the TRM.

Amendment No. 44G#S

, ?5?,

161

ECCS lnstrumentation 3.3.5.1 Table 3.3.5.1-1 (page 4 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE MODES REQUIRED OR OTHER CHANNELS SPECIFIED PER CONDITIONS FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.l ALLOWABLE VALUE SURVEILLANCE REQUIREMENTS FUNCTION

2.

LPCl System

k.

Reactor Steam Dome Pressure -

Time Delay Relay (Break Detection) 5 2.97 seconds I.

Recirculation Pump Differential Pressure

-Time Delay Relay (Break Detection) s 0.75 seconds

m. Recirculation Riser Differential Pressure

-Time Delay Relay (Break Detection) s 0.75 seconds

3. High Pressure Coolant lnjection (HPCI) System

a.

Reactor Vessel Water Level - Low Low 2 -48 inches 1 2 psig 5 48 inches

b.

Drywell Pressure -

High

c.

Reactor Vessel Water Level - High

d.

Condensate Storage Tank Level - Low r 29.3 inches 1 3.0 inches

e.

Suppression Pool Water Level - High

f.

High Pressure 1, 2(e), 3(8) 1 E

SR 3.3.5.1.5 2 362 gpm and Coolant Injection SR 3.3.5.1.6 1849 gpm Pump Discharge SR 3.3.5.1.8 Flow - Low (Bypass)

(e)

With reactor steam dome pressure > 150 psig.

Monticello 3.3.5.1-9 Amendment No. 4 4 W 4 3, ?5?,

161

ENCLOSURE 3 MONTICELLO NUCLEAR GENERATING PLANT DRAFT TECHNICAL SPECIFICATION BASES PAGES (FOR INFORMATION)

(3 pages follow)

ECCS Instrumentation B 3.3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.5.1.2, SR 3.3.5.1.5 and SR 3.3.5.1.9 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the channel will perform the intended function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Frequency of 92 days for SR 3.3.5.1.2 is based on the reliability analyses of Reference 3. The Frequency of 12 months for SR 3.3.5.1.5 is based on the known reliability of the equipment and the multichannel redundancy available, and has been shown to be acceptable through operating experience. The Frequency of 24 months for SR 3.3.5.1.9 is based on the known reliability of the equipment and the multichannel redundancy available, and has been shown to be acceptable through operating experience.

Calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analyses. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than the setting accounted for in the appropriate setpoint methodology.

The Frequency of 92 days is based on the reliability analysis of Reference 3.

SR 3.3.5.1.4. SR 3.3.5.1.6, and SR 3.3.5.1.7 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL Monticello B 3.3.5.1-34 Revision No. 12

ECCS Instrumentation B 3.3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Frequency of SR 3.3.5.1.4 is based upon the assumption of a 92 day calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. The Frequency of SR 3.3.5.1.6 is based upon the assumption of a 12 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.

The Frequency of SR 3.3.5.1.7 is based upon the assumption of a 24 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis, ap~djo~Fun.~.tjon.2,j1.aa.reyjsed minimum detectable break area for the LPCl loop select logic (Refs. 5 and 61..

~ d d l e A b y 4 his is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of instrument performance will verify that the instrument will continue to behave in accordance with design basis assumptions. The purpose of the assessment is to ensure confidence in the instrument performance prior to returning the instrument to service.

These channels will also be identified in the Corrective Action Program.

In accordance with procedures, entry into the Corrective Action Program will require review and documentation of the condition of OPERABILITY.

The second Note requires the setting for the instrument be returned to within the as-left tolerance of the nominal trip setpoint. This will ensure that sufficient margin to the Safety Limit and /or Analytical Limit is maintained. If the setting for the instrument cannot be returned to within the as-left tolerance of the nominal trip setpoint, then the instrument channel shall be declared inoperable. The second Note also requires that the nominal trip setpoint and the methodology for calculating the as-left and the as-found tolerances be in a document controlled under 10 CFR 50.59 (i.e., Technical Requirements Manual (Ref. 4)).

The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LC0 3.5.1, LC0 3.5.2, LC0 3.8.1, and LC0 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety function.

Monticello B 3.3.5.1-35 Revision No. 12

ECCS Instrumentation B 3.3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency.

REFERENCES

1.

USAR, Section 14.7.2.

2.

USAR, Chapter 14.

3.

NEDC-30936-P-A, "BWR Owners' Group Technical Specification Improvement Analyses for ECCS Actuation Instrumentation, Parts 1 and 2," December 1988.

4.

Technical Requirements Manual.

5.

GE-NE-0000-0052-3113-P-RO, "SAFERIGESTR ECCS-LOCA Analysis - LPCl Loop Selection Detectable Break Area," September 2006.

6. Amendment No. 161, "Issuance of Amendment Re: Revision to the Allowable Value and Channel Calibration Surveillance Interval for the Recirculation Riser Differential Pressure - High Function," dated April XX, 2009. [Working Title]

Monticello B 3.3.5.1 Last Revision No. 12