ML20094M194

Suppl to 950815 LAR to License DPR-22,incorporating Requirements of Option B,Section Iii.A for Type a Testing (Primary Containment ILRT) Per Reg Guide 1.163

ML20094M194
Person / Time
Site:	Monticello
Issue date:	11/14/1995
From:	Hill W NORTHERN STATES POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20094M197	List: ML20094M194 ML20094M198
References
RTR-REGGD-01.163, RTR-REGGD-1.163 NUDOCS 9511210314
Download: ML20094M194 (8)

Text

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Northem States Power Company I

Monticello Nuclear Generating Plant 2807 West Hwy 75 Monticello, Minnesota 55362-9637 I

November 14,1995 U S Nuclear Regulatory Commission 10 CFR Part 50 Attn: Document Control Desk Section 50.90 Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR 22 November 14,1995 Supplement to License Amendment Request Dated August 15,1995 Main Steam Isolation Valve and Appendix J Leak Test Reauirements In our License Amendment Request dated August 15,1995, Monticello proposed changes to section 3.7/4.7.A, Primary Containment. A major portion of this proposed amendment was to remove prescriptive information conceming the primary containment leakage rate testing program and replace it with statements to abide by the requirements of Appendix J of 10 CFR Part 50.

Since that time, Regulatory Guide 1.163 was issued providing guidance on how to implement the newly approved Option B to 10 CFR Part 50, Appendix J which allows performance based testing. Accordingly, we are providing supplementalinformation to our August 15,1995 submittal to incorporate the requirements of Option B, Section Ill.A for Type A testing (primary containment integrated leakage rate testing).

Exhibit A contains a description of the proposed changes, the reasons for requesting the changes, Safety Evaluations, and a Determination of Significant Hazards Consideration, and Environmental Assessment. Exhibit B contains the current Technical Specification pages marked up with the proposed change. Exhibit C contains revised Monticello Technical

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Specification pages.

The original change was proposed as a Cost Beneficial Licensing Action (CBLA). Adopting Option B will further reduce the cost of operating the Monticello plant as under Appendix J Option B, based on good prior test results, containment integrated leakage rate tests (ILRT) will not be required as often. With this proposed amendment, our next ILRT scheduled for the April 1996 refueling outage can be delayed.

This submittal contains no new NRC commitments, nor does it modify any prior commitments.

Please contact Sam Shirey, Sr Ucensing Engineer, at (612) 295-1449 if you require additional information related to this request.

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USARC NORTHERN STATES POWER COMPANY November 14,1995 Page 2 s$&7'l b*

William J Hill Plant Manager Monticello Nuclear Generating Plant c:

Regional Administrator-lil, NRC NRR Project Manager, NRC Resident inspector, NRC State of Minnesota Attn: Kris Sanda J Silberg Attachments: Affidavit to the US Nuclear Regulatory Commission Exhibit A - Evaluation of Proposed Change Exhibit B -

Technical Specification pages marked up with proposed change Exhibit C - Revised Monticello Technical Specification Pages 4

l UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263 REQUEST FOR AMENDMENT TO OPERATING LICENSE DPR-22 November 14,1995 SUPPLEMENT TO LICENSE AMENDMENT REQUEST DATED August 15,1995 Northem States Power Company, a Minnesota corporation, requests authorization for changes to Appendix A of the Monticello Operating License as shown on the attachments labeled i

Exhibits A, B, and C. Exhibit A describes the proposed changes, describes the reasons for the changes, and contains a Safety Evaluation, a Determination of Significant Hazards Consideration and an Environmental Assessment. Exhibit B contains current Technical Specification pages marked up with the proposed changes. Exhibit C is a copy of the Monticello Technical Specifications incorporating the proposed changes.

This letter contains no restricted or other defense information.

NORTHERN STATES POWER COMPANY By En 9

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William J HilV Plant Manager Monticello Nuclear Generating Plant On this/[ day of fle A 199r before me a notary public in and for said County, personally appeared William J Hill, Plant Manager, Monticello Nuclear Plant, and being first duly swom acknowledged that he is authorized to execute this document on behalf of Northem 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 are true and that it is not interposed for delay.

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M RICHARD ENEN 4

p Mariin R.' Engen /

Notary Public-Minnesota Sherbume County My Commission Expires January 31,2000

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Exhibit A j

i MONTICELLO NUCLEAR GENERATING PLANT l

i November 14,1995 Supplement to License Amendment Request Dated August 15,1995 i

l Evaluation of proposed changes to the Technical Specifications for Operating License DPR-22 l

Pursuant to 10 CFR Part 50, Section 50.59 and 50.90, the holders of Operating License DPR-22 hereby propose the following changes to the Monticello Technical Specifications:

l Proposed Chance (Part 1)- Combined MSIV Leakaae:

No change from original submittal.

Proposed Chance (Part 2) - Drywell sorav header and nozzle air test freauency:

No change from original submittal.

Proposed Channes (Part 31-Jtilization of Appendix J. Option B test interval criteria for Primary Containment:

In our original August 15, 1995 amendment request, changes were proposed to Monticello Technical Specification section 3/4.7.A.2 (Primary Containment), conceming the primary containment leakage rate testing program. These changes were to replace existing requirements with statements to abide by the requirements of Appendix J of 10 CFR Part 50. On September 26,1995, Option B to Appendix J was approved and Regulatory Guide 1.163 was issued. This submittal revises changes proposed in our August 15,1995 License Amendment Request to allow performance based testing as proposed in 10 CFR Part 50, Appendix J, Option B, Section Ill.A for Type A tests (primary containment integrated leakage rate tests).

Consequently, the changes presented below are based on our August 15, 1995 submittal, and incorporate the guidance of Regulatory Guide 1.163.

On page 159, section 3.7.A.2.b.2, the words " maximum flow path" are being added.

Also on page 159, section 4.7.A.2.b, which had been changed in our August 15,1995 submittal, is being replaced with the following words:

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" Perform required visual examinations and leakage rate testing for Type A containment integrated leakage rate tests in accordance with Regulatory Guide 1.163, and Type B and C tests in accordance with 10 CFR 50, Appendix J, i

Option A, as modified by approved exemptions."

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On page 160, section 4.7.A.2.b.5 proposed words from our August 15,1995 submittal

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j are being replaced with " deleted".

At the bottom of page 184, the statement "NEXT PAGE IS PAGE 188" is being deleted.

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Page 185 is being added as BASIS information.

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c Reason for Chances:

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l This revision incorporates wording as proposed by the NRC in letter " PROPOSED TECHNICAL SPECIFICATIONS TO ACCOMMODATE THE CHANGES TO APPENDIX l

3 J TO 10 CFR 50" dated July 18,1995 from Christopher 1. Grimes, to the four Owners

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Group Chairmen. As Monticello presently has Custom Technical Specifications rather than the improved Standard Technical Specifications (STS), and Option B, Section Ill.A only is being adopted at this time, the wording matchup is not exact. It is, however, our intent that the proposed wording be as near the STS as practical.

l As proposed in the above mentioned letter, we have elected to take the NRC's Surveillance Requirement (SR) approach to Option B, Section Ill.A at this time as it should result in a simpler change while still meeting the intent of Option D. Monticello has a containment integrated Leak Rate Test (ILRT) scheduled for our April 1996 l

l refueling outage.

Approval of this amendment prior to April would preclude the l

necessity of a specific ILRT exemption submittal, and thus save both NSP and NRC the j

time and resources associated with a specific exemption request.

On page 159, the changes are as in our August 15,1995 submittal, except for changes j

incorporating the requirements to comply with Regulatory Guide 1.163 for type A j

testing only, and to add the words " maximum flow path" for consistency. These new j

changes for Type A tests are as proposed by the NRC's July 18, 1995 letter j

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" PROPOSED TECHNICAL SPECIFICATIONS TO ACCOMMODATE THE CHANGES TO APPENDIX J TO 10 CFR 50".

i On page 160, the prescriptive requirements for MSIV testing that was proposed in our l

August 15,1995 submittal has been changed to " deleted". The leakage rate limit and test pressure requirements are already adequately defined on page 159, Section

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3.7.A.2.b.3, using nearly the same words being deleted here, therefore, this change is merely reducing duplication.

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r On page 184, information is being added as a new page 185, therefore, the next page is 185, not 188.

Page 185 is being added to describe the endorsement of 10 CFR 50, Appendix J, Option B, Section Ill.A for Type A primary containment integrated leakage rate tests.

Safety Evaluation:

This supplemental amendment invokes Section Ill.A of Option B, of 10 CFR 50, Appendix J which is based on the premise that the activities of the Regulatory improvement Program should result in enhanced regulatory focus in areas that are more safety significant. As a result, an overall net increase in safety is expected from the program. The new performance-based :egulation will be less prescriptive and will allow Monticello the flexibility to adopt cost-effective methods for implementing the safety objectives of the original rule. Therefore, this amendment does not introduce any new safety concems.

Monticello Nuclear Generating Plant proposes to adopt the provisions of Appendix J, Option B, for Type A, primary reactor containment integrated leakage rate testing. The provisions of Option B will be implemented in accordance with Regulatory Guide 1.163, Performance Based Containment Leak-Test Program. Type B and C primary reactor containment leakage rate testing will be performed in accordance with the requirements of 10 CFR 50 Appendix J, Option A as they have been in the past.

Determination of Sionificant Hazards Consideration:

This proposed change to the Operating License has been evaluated to determine if it constitutes a significant hazards consideration as required by 10 CFR Part 50, Section 50.91 using the standards provided in Section 50.92. This analysis is provided below-a.

The orocosed amendment will not involve a sionificant increase in the probability or consecuences of an accident previousiv evaluated.

The proposed changes contained in this supplement to Monticello's August 15, 1995 amendment are limited to changes to surveillance testing requirements applicable to 10 CFR Part 50, Appendix J test requirements. Performance of the tests themselves are not input or consideration in any accident previously evaluated, thus the proposed change will not increase the probability of any such accident occurring.

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l The proposed amendment will not adversely affect the function, operation, reliability or capability of the equipment to perform as required during an accident. This change does not alter either how actual testing is accomplished nor the test acceptance criteria. It has been shown that adopting longer test intervals based on performance, maintains the safety objective for containment integrity while at the same time reducing the burden on licensees, and provides a greater level of worker safety than that provided by the previous rule.

Therefore, there will be no increase in post accident off-site or on-site radiation dose as a result of this amendment.

The proposed amendment requires compliance with the regulatory requirements of 10 CFR Part 50, Appendix J Option B, Section Ill.A, for Type A testing that has previously been reviewed by i

the NRC and found to be acceptable.

Therefore, the amendment will not increase the consequences of any accident previously evaluated.

b.

The proposed amendment will not create the oossibility of a new or different kind of accident from any accident previousiv analyzed.

The proposed amendment does not involve modifications to plant equipment or operating procedures, nor will it introduce any new equipment failure modes that have not been previously considered. The proposed amendment is limited to changes in surveillance test frequencies of tests performed while the plant is in cold shutdown when the associated equipment is not required to be operable.

We therefore conclude the proposed changes will not create the possibility of a new or different kind of accident from any accident previously analyzed.

c.

The proposed amendment will not involve a sionificant reduction in the maroin of A!stty.

Extending the intervals between containment integrated leakage tests as authorized by 10 CFR Part 50 Appendix J Option B does not change the acceptance criteria nor how testing is accomplished.

Based on these considerations, we conclude the proposed amendment will not

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involve a significant reduction in the margin of safety.

j Based on the evaluation described above, and pursuant to 10 CFR Part 50, Section 50.91, Northern States Power Company has determined that operation of the Monticello Nuclear Generating Plant in accordance with the proposed license amendment request does not involve any significant hazards considerations as defined by NRC regulations in 10 CFR Part 50, Section 50.92.

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Environmental Assessment:

Northern States Power has evaluated the proposed changes and determined that:

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The changes do not involve a significant hazards consideration, 2.

The changes do not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or i

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The changes do not involve a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR Part 51 Section 51.22(c)(9). Therefore, pursuant to 10 CFR Part 51 Section 51.22(b), an environmental assessment of the proposed changes is not required.

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