ML20024G307
| ML20024G307 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 04/15/1977 |
| From: | Wachter L NORTHERN STATES POWER CO. |
| To: | |
| Shared Package | |
| ML20024G306 | List: |
| References | |
| A00L-770415, AL-770415, NUDOCS 9102110272 | |
| Download: ML20024G307 (5) | |
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.. l UNITED STATES NUCLEAR REGUIATORY COMMISSION l
1 NORIMERN STATES POWER COMPANY MONTICELLO NUCLFAR GENERATING PIANT Docket No. 50 263 f
REQUEST FOR AMEND (ENT TO A
OPERATING LICENSE NO. DFR-22 y
I (License Amendment Request Dated April 15, 1977) 4 Northern States Power Company, a Minnesota corporation, requests q
authorization for changes to the Technical Specifications as shown on the attachments labeled Exhibit A and Exhibit B.
Exhibit A describes 4
i the proposed changes along with reasons for the rhange. Exhibit B is a set of Technical Specification pages incorporating the proposed changes.
l This request contains no restricted or other defense information.
I NORTHERN STATES POWER COMPANY l
By 0 Y $.
p
/4 J Wachter l
Vice President, Power Production 6 System Operation on this 15th day of April 1977, before me a notary pub.2? in and for said County, personally appeared L J Wachter, Vice L
Fr*# dent, Power Production & System Operation, and first being duly sworn 8
acknowledged that he is authorized to execute this document in behalf of Northern States Power Company, that he knows the contents thereof and that to the best of his knowledge, information and belief, the statements made in it g
are true and that it is not interposed for delay.
br/r/) $
b(d4&-XJ P
DENISE E. HALVORSON I I NOTARY PutuC. WINNEsOTA HENNEPIN COUNTY hoy Commise4on hatros oct 10, test l l
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1 9102110272 770415 PDR ADDCK 05000263 P
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A-1 EX111 BIT A t
t MONTICELLO NUCLEAR GENERATING PIANI 1
DOCKET No. 50-263 LICENSE AMENDMENI REQUEST DATED APRIL 15, 1977 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS APPENDIX A 0F PROVISIONAL OPERATING LICENSE DPR-22 k
Pursuant to 10CFR50.59, the holders of Provisional Operating License DPR-22 hereby propoce the following changes to the Appendix A Technical Specifications.
Related changes proposed in our License Amendment Request Dated November 5,1976 have been incorporated in this submittal, superceding the November request; however, the November document must be consulted for supporting information for those changes. Certain pages identified below as containing proposed changes are also subject to unrelated changes by License Amendment Request Dated January '40,1976 as revised May 4, 1976. The latter changes are not incorporated into this submittal; they should be treated independently.
PROPOSED CHANGES 1.
Specifications 3.7. A.1 and 4.7.A.1 (pages 139 and 140) - These specifi-cations have been re-structured as shown in Exhibit B without changing the requirements in any way. This provides consistency with the fomst of other specifications, makes it easier to associate each surveillance requirement with the respective limiting condition for operation and re-places the undefined term " nuclear system" with alternate wording supported by the existing bases.
2.
Specifications 3.7.A.1.f and 4 7. A.1.f (page 140) and Bases (page 157A) -
The proposed wording shown in Exhibit B has been added to specify and discuss suppression chamber water volume indication operability and cali-bration requirements.
3.
Specification 3.7.A.5.a (page 147A) - Remove the obsolete phrase, "After completion of the startup test program and demonstration of plant electrical output".
4.
Specification 3.7.A.7.e (page 147B) and Bases (page 159) - A provision has been added which would remove the drywell to suppression chamber differential pressure requirement for planned safety / relief valve testing.
5.
Specifications 3. 7.A.7.d and 4. 7. A. 7.b (page 147B) and Bases (page 159) -
The proposed wording shown in Erhibit B has been added to specify and discuss drywell to suppression chamber differential pressure indicato.
operability and calibration requirements.
6.
Bases 3.7.A (page 156) - The reference to a control rod worth of 1.57, delta k l
l has been replaced with an increment of rod worth of 1.37 delta k.
(This Bases change was inadvertently omitted when ti.e same change was issued for Specification 3.3.B.3 (a) on November 27, 1973.)
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A-2 7.
Bases 3.7.A (page 158A) - Change the words on the top line frun "3/4 inch opening of any one valve or.08 in opening of all ten valves" to read "one inch opening of any valve or 0.1 inch opening for all ten valves." (his proposed change was inadvertently omitted from an earlier change request.
It should have been included in changes issued on February 26, 1975 to make the Bases consistent with the analysis supporting the change to the specifications.)
f 8.
Specification 3.7/4.7 and Bases (pages 139 throagh 167) - There are numerous minor format changen proposed throughout these pages as shown in Exhibic B, in addition to the more significant changes identified above, to make the specifications easier to use through application of a consistent format.
REASONS FOR CHANGE proposed Changes 1. 3 and 8 - These changes re-structure and/or re-format the existing wording for easier readability and application, n ere are no inherent changes in the requirements of the specifications.
Proposed Cht.nges 2 and 5 - These changes prope.se limiting conditions for opera-tion and surveillance requirements for operaticn and surveillance requirements for instrumentation as requested in Mr Karl R Gdler's February 4,1977 letter.
We do not share in the NRC opinion that Technica t Specifications are appropriate for this type of instrumentation. The parametera monitored, suppression chamber water volume and drywell to sus.oression chamber differer.cial pressure, do not experience rapid changes during normal operation.
ney represent the condition of stagnant, coufined masses of water and gas.
Standard practice for similar situations is to require that a parar eter periodically be verified to be within the Technical Specifice7. ion limit.
Since the parameters in question are not used to initiate automatic action, it is irrelevant what method or instrument is used, as long as the parameter can be shown to be within the specified limit.
Requiring the periodic check to verify conformance to limits, by itself, inherently requires that some acceptable means must exist to monitor a parameter. We also question the NRC staff technical position that instrument sticking or drifting should be addressed by requiring operability of redundant channels of instru-mentation.
If these problems do in fact exist, we believe that they should be addressed directly 'through improved surveillance techniques and a review of the application of instrumentation. Nevertheless, we have proposed limiting condi-tions for operation and surveillance requirements should you remain convinced that such requirements are appropriate.
A question has also arisen whether the suppression chamber water volume should be specified in terms of volume or level.
We proposed Specification maintains a volve criteria, reflecting our position that volume is more correct than level.
The initial plant design specified the esinimum water volume reqaired as a heat sink in the event of a design basis loss of coolant accident and a minimum volume to be consistent with test data availabic at the time.
Subsequent testing and re-calculations have verified the suppression chamber integrity for the range of volumes specified, including the effect of the dryvell to suppression chamber differential pressure.
Our objection to converting from a volume to a 1cvel specification is as follows:
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' 1.
'1he change would simply be a matter of " optics"; the water volume would only be expressed in different units.
2.
The volume is the basic requirement; secondary analyses use that volume expressed in terms of level, downcomer submergence, etc.
to verify that other conditiom; cre acceptable.
Specifying level would lose sight of the asic tequirement.
3.
Volume is not affects Sy containment differential pressure while level is affected.
Ir.lMing this effect would unnecessarily
, complicate the Technica.i Qecifications.
Omitting the effect would either allow operation within Technical Specification limits but outside of the analyzed range or prevent operation over the entire 4
analyzed range through unduly restrictive Technical Specification limits.
4.
Chrnging the units in the Specification does not result in an im-provement in safety. Miking such a change introduces the potential for confusion and error as the change is *.ncorporated into surveillance procedures, operating instructions, operational checklists and operator training.
, Proposed Change 4 - An addition has been proposed, beyond the November 5,1976 i
change request, to conveniently allow for special planned tests of safety / relief valves without processing a formal Technical Specification change.
Proposed Changes 6 and 7 - These changes affect the Bases only.
In both cases the reason for the change was presented earlier when the corresponding Specifi-cations were changed.
SAFETY EVALUATION Pre;osed Changes 1 3, 6. 7 and 8 - These proposed changes only make editorial changes and cerrect previous cmissions.
They do not affect the intent of any
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Specifications. Therefore, they have no affect on plant safety.
PronwOnges 2 and 5 - Instrumentation is presently in place to monitor s'n p u 4 chamber water volume and drywell to suppression chamber differential prer me.
.nese proposed changes add limiting conditions for operation and l
surv6 11.;.uce requirements on the instrumentation. As stated in the proposed Specification, one of two redundant indicators may be out of service for 30 days and coth indicators may be out of service for surveillan e and maintenance for a period of time equal to the interval between surveillance checks of the para-meter. These indicators do not initiate any automatic action; they are of an j
application different from most other instrumentation required by the Technical Specifications.
Being redundant only provides the benefit of comparing one i
channel against another. Inoperability of one channel for up to 30 d, ys is therefore reasonable. The parameters in question do not change rapidly during operation. This fact, coupled with the low probability that a loss of coolant l
<1ccident occurs during a time when the pa;ameter is outside of the specified limit, supports the fact that a check of the two parameters is req stred only once per day and once per shift, respectively. Allowing both channels out of service
- or the same interval is connensurate with the application. An annual calibration l
frequency is consistent with industry standards applied to similar application of analog traneritter devices.
4 Proposed Change 4 - Insufficient details of planned safety / relief valve tests are available for a safety evaluation at this time.
Sufficient information will I
be provided for an NRC Staff safety evaluation supporting the differential i
pressure exemption in sufficient time prior to each such enemption.
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EXHIBIT B LICENSE AMENDMENT REQUEST DATED APRIL 15, 1977 This exhibit consists of the following pages revised or added to incorporate all of the proposed Technical Specification Changes:
139 i
140 147A 147B (Newly created in 11/5/77 Licer.se bk Amendment Request) 148 156 157 157A 158 158A 1
158B 159 4
160 161 161A 165 167