Text

License Amendment Request: Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements
	ML20267A139
Person / Time
Site:	Monticello
Issue date:	09/22/2020
From:	Conboy T; Northern States Power Company, Minnesota, Xcel Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-MT-20-018
	Download: ML20267A139 (44)
	v • d • e

2807 West County Road 75 Monticello, MN 55089 September 22, 2020 L-MT-20-018 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket No. 50-263 Renewed Facility Operating License No. DPR-22 License Amendment Request: Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, the Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), is submitting a request for an amendment to the Technical Specifications (TS) for the Monticello Nuclear Generating Plant (MNGP).

NSPM requests adoption of TSTF 582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583, TSTF-582 Diesel Generator Variation. The TS related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control.

Enclosed is a description and assessment of the proposed TS changes. Attachment 1 to the enclosure provides the existing TS pages marked up to show the proposed change. to the enclosure provides the TS Bases pages marked up to show the associated TS bases changes and is provided for information only.

NSPM requests that this license amendment request be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested by January 15, 2021. Once approved, the amendment shall be implemented within 90 days.

In accordance with 10 CFR 50.91, Notice for public comment; State consultation, paragraph (b), NSPM is notifying the State of Minnesota by providing a copy of this application, with this enclosure and attachments, to the designated State Official.

If additional information is needed, please contact Mr. Richard Loeffler at (612) 342-8981.

fl Xcel Energy"

Document Control Desk Page 2 Summary of Commitments This letter makes no new commitments an_d no revisions to existing commitments.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on September Z.2,.-2020.

~SS:~4~ -

Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc:

Administrator, Region 111, US NRC Project Manager, Monticello, US NRC Resident Inspector, Monticello, US NRC State of Minnesota

L-MT-20-018 Enclosure Page 1 of 6 LICENSE AMENDMENT REQUEST APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-582, REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL (RPV WIC)

ENHANCEMENTS

1.0 DESCRIPTION

In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, the Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), requests an amendment to the Technical Specifications (TS) for the Monticello Nuclear Generating Plant (MNGP). NSPM requests adoption of TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC)

Enhancements, and TSTF-583, TSTF-582 Diesel Generator Variation, (References 1 and 2). The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation NSPM has reviewed the safety evaluation for TSTF-582 provided to the Technical Specifications Task Force (TSTF) in a letter dated August 13, 2020 (Reference 3). This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-582. As described herein, NSPM has concluded that the justifications presented in TSTF-582 and the safety evaluation prepared by the NRC staff are applicable to the MNGP and justify this amendment for the incorporation of the changes to the MNGP TS.

NSPM verifies that the required Emergency Core Cooling System (ECCS) injection/spray subsystem can be aligned and the pump started using relatively simple evolutions involving the manipulation of a small number of components. These actions can be performed in a short time (less than the minimum Drain Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) from the control room following plant procedures.

2.2 Optional Changes and Variations NSPM is proposing the following variations from the TS changes described in TSTF-582 or the applicable parts of the NRC staffs safety evaluation.

The MNGP TS utilize different numbering than the Standard Technical Specifications (STS) on which TSTF-582 was based. Specifically, Specification 3.3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation, in the STS was numbered as Specification 3.3.5.3 in the MNGP TS. This difference is administrative and does not affect the applicability of TSTF-582 to the MNGP TS.

L-MT-20-018 Enclosure Page 2 of 6 The following changes in TSTF-582 were incorporated in the MNGP TS as variations during adoption of TSTF-542 (Reference 4). MNGP Specification 3.3.5.3, RPV Water Inventory Control Instrumentation, does not include the Core Spray Pump Discharge Flow - Low (Bypass) function. A Logic System Functional Testing surveillance was not included in the specification since that had not previously been included in the MNGP TS. Also, Specification 3.3.5.3 was revised to eliminate the manual ECCS initiation function to start the Core Spray and Low Pressure Coolant Injection (LPCI) Systems and instead to rely on manual valve alignment and pump start. SR 3.5.2.5 was revised to verify that each ECCS injection/spray subsystem could be manually operated. Therefore, these particular TSTF-582 changes are not needed.

Additionally, the following variations are included in accordance with the guidance of TSTF-583.

Specification 3.3.8.1, "Loss of Power (LOP) Instrumentation," is applicable in Modes 1, 2, and 3, and when the associated diesel generator is required to be operable by Specification 3.8.2. TSTF-582 revised Specification 3.8.2, AC Sources - Shutdown, to no longer require automatic start and loading of a diesel generator on a loss of offsite power signal.

Consequently, the LOP instrumentation that generates the loss of offsite power signal should not be required to be operable when the diesel generator is required to be operable by Specification 3.8.2. The Applicability of LCO 3.3.8.1 is revised to not include the specified condition When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown.

SR 3.8.2.1 lists the Specification 3.8.1, AC Sources - Operating, SRs that must be met or are excluded while in the applicability of Specification 3.8.2. With the proposed change, about half of the Specification 3.8.1 SRs are not applicable. Therefore, as an editorial improvement, SR 3.8.2.1 is revised to list the Specification 3.8.1 SRs that are applicable instead of the Specification 3.8.1 SRs that are not applicable. This has no effect on the requirements. The SR 3.8.2.1 Bases continue to explain why certain Specification 3.8.1 SRs are omitted from the list.

SR 3.8.2.1 requires SR 3.8.1.10 (NUREG-1433 SR 3.8.1.15) to be met. SR 3.8.1.10 requires that the EDG starts and achieves required voltage and frequency within 10 seconds. The 10 second start requirement supports the assumptions in the design basis LOCA analysis. This capability is not required during a manual EDG start to respond to a draining event, which has a minimum Drain Time of one hour.

SR 3.8.2.1 requires SR 3.8.1.13 (NUREG-1433 SR 3.8.1.18) to be met but not performed. SR 3.8.1.13 states, Verify interval between each sequenced load block is greater than or equal to the minimum design load interval. The load sequencing is only used for the automatic start and loading of the EDG and is not used during a manual EDG start.

Therefore, SR 3.8.2.1 is revised to remove SR 3.8.1.10 and SR 3.8.1.13 from the list of Specification 3.8.1 SRs that are applicable.

L-MT-20-018 Enclosure Page 3 of 6

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), requests adoption of TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements. The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control. TSTF-582 includes the following applicable changes to the MNGP Technical Specifications (TS):

1.

The TS are revised to eliminate the requirement for a manual ECCS initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start.

2.

The Drain Time definition is revised to move the examples of common mode failure mechanisms to the Bases and seismic events are no longer considered a common mode failure mechanism.

3.

The Drain Time definition exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are that are locked, sealed, or otherwise secured is revised to apply the exception for manual or automatic valves that are closed and administratively controlled.

4.

The TS are revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.

5.

A Surveillance Requirement (SR) that requires operating the required ECCS injection/spray subsystem for at least 10 minutes through the recirculation line, is modified to permit crediting normal operation of the system to satisfy the SR and to permit operation through the test return line.

6.

TS 3.8.2, AC Sources - Shutdown, SR 3.8.2.1, is revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and 5. Automatic ECCS initiation in Modes 4 and 5 was eliminated in TSTF-542. This was an oversight in TSTF-542.

7.

The TS are revised to use wording and to define acronyms in a manner consistent with the remainder of the TS. These changes are made for consistency and have no effect on the application of the TS.

NSPM has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

L-MT-20-018 Enclosure Page 4 of 6 The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control. Draining of RPV water inventory in Mode 4 (i.e., cold shutdown) and Mode 5 (i.e., refueling) is not an accident previously evaluated and, therefore, revising the existing TS controls to prevent or mitigate such an event has no effect on any accident previously evaluated. RPV water inventory control in Mode 4 or Mode 5 is not an initiator of any accident previously evaluated. The existing and revised TS controls are not mitigating actions assumed in any accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control. The event of concern under the current requirements and the proposed change is an unexpected draining event. The TS have contained requirements related to an unexpected draining event during shutdown for over 40 years and this event does not appear as an analyzed event in the Updated Safety Analysis Report (USAR) for any plant or in the NRC's Standard Review Plan (NUREG-0800). Therefore, an unexpected draining event is not a new or different kind of accident not considered in the design and licensing bases that would have been considered a design basis accident in the USAR had it been previously identified.

None of the equipment affected by the proposed change has a design function described in the USAR to mitigate an unexpected draining event in Modes 4 or 5, although the equipment may be used for that purpose. Therefore, the proposed amendment will not change the design function of the affected equipment. The proposed change will affect the operation of certain equipment, such as the manual initiation function and related instrumentation to permit initiation of the required ECCS injection/spray subsystem, and the control of valves credited for preventing a draining event. However, these changes provide adequate protection to prevent or mitigate an unexpected draining event and do not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

L-MT-20-018 Enclosure Page 5 of 6

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control.

The safety basis for the RPV WIC requirements is to protect Safety Limit 2.1.1.4. The proposed change does not affect any specific values that define a safety margin as established in the licensing basis. The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the USAR or the license. Therefore, the proposed change does not significantly reduce the margin of safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, NSPM concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, Standards for Protection Against Radiation, or would change an inspection or surveillance requirement. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22, Criteria for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, specifically paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed change.

L-MT-20-018 Enclosure Page 6 of 6

5.0 REFERENCES

1.

Technical Specification Task Force (TSTF) Traveler TSTF-582, RPV WIC Enhancements, Revision 0

2.

TSTF Traveler TSTF-583, TSTF-582 Diesel Generator Variation, Revision 0

3.

U.S. NRC to TSTF, Final Safety Evaluation of Technical Specification Task Force (TSTF) Traveler TSTF-582, Revision 0, RPV WIC Enhancements, Using the Consolidated Line Item Improvement Process (EPID L-2019-PMP-0199, dated August 13, 2020

4.

U.S. NRC to NSPM, Monticello Nuclear Generating Plant - Issuance of Amendment Re: Adoption of TSTF-542, Reactor Pressure Vessel Water Inventory Control (EPID:

L-2017-LLA-0360), dated October 29, 2018 (ADAMS Accession No. ML18250A075)

ENCLOSURE ATTACHMENT 1 MONTICELLO NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-582, REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL (RPV WIC)

ENHANCEMENTS TECHNICAL SPECIFICATION PAGES (MARKED-UP)

(12 pages follow)

Definitions 1.1 Monticello 1.1-2 Amendment No. 146, 148, 194,198 1.1 Definitions CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel.

The following exceptions are not considered to be CORE ALTERATIONS:

a.

Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement); and

b.

Control rod movement, provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that provides cycle REPORT (COLR) specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.3. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The dose conversion factors used for this calculation shall be those listed in Federal Guidance Report (FGR)-11, "Limiting Values of Radionuclide Intake and Air Concentration Factors for Inhalation, Submersion and Ingestion," September 1988, and FGR-12, "External Exposure to Radionuclides in Air, Water and Soil,"

September 1993.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a)

The water inventory above the TAF is divided by the limiting drain rate; b)

The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single TBD

Definitions 1.1 Monticello 1.1-3 Amendment No. 146, 194, 198 1.1 Definitions DRAIN TIME (continued) human error), for all penetration flow paths below the TAF except:

1.

Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2.

Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3.

Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c)

The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d)

No additional draining events occur; and e)

Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

closed and administratively controlled TBD

RPV Water Inventory Control Instrumentation 3.3.5.3 Monticello 3.3.5.3-1 Amendment No. 198 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.3-1.

ACTIONS

NOTE-----------------------------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels inoperable.

A.1 Enter the Condition referenced in Table 3.3.5.3-1 for the channel.

Immediately B. As required by Required Action A.1 and referenced in Table 3.3.5.3-1.

B.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND B.2 Calculate DRAIN TIME.

Immediately Immediately C. As required by Required Action A.1 and referenced in Table 3.3.5.3-1.

C.1 Place channel in trip.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months D. As required by Required Action A.1 and referenced in Table 3.3.5.3-1.

D.1 Restore channel to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TBD Add Required Action Specification 3.3.5.3 Insert on Next Page

Specification 3.3.5.3 Insert - Required Action A.

One or more channels inoperable.

A.1 Initiate action to place channel in trip.

Immediately OR A.2.1 Declare associated penetration flow path(s) incapable of automatic isolation.

Immediately AND A.2.2 Initiate action to calculate DRAIN TIME.

Immediately

RPV Water Inventory Control Instrumentation 3.3.5.3 Monticello 3.3.5.3-2 Amendment No. 200 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and associated Completion Time of Condition C or D not met.

E.1 Declare associated low pressure ECCS injection/spray subsystem inoperable.

Immediately SURVEILLANCE REQUIREMENTS

NOTE-----------------------------------------------------------

Refer to Table 3.3.5.3-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program These SRs apply to each Function in TBD

RPV Water Inventory Control Instrumentation 3.3.5.3 Monticello 3.3.5.3-3 Amendment No. 198 Table 3.3.5.3-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE 1.

Core Spray System a.

Reactor Steam Dome Pressure - Low (Injection Permissive) 4, 5 2(a)

C SR 3.3.5.3.2 397 psig and 440psig 2.

Low Pressure Coolant Injection (LPCI) System a.

Reactor Steam Dome Pressure -

Low (Injection Permissive) 4, 5 2(a)

C SR 3.3.5.3.2 397 psig and 440 psig b.

Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass) 4, 5 1 per pump(a)

D SR 3.3.5.3.2 360 gpm and 745 gpm 3.

Shutdown Cooling System Isolation a.

Reactor Vessel Water Level - Low (b) 2 in one trip system B

SR 3.3.5.3.1 SR 3.3.5.3.2 7 inches 4.

Reactor Water Cleanup (RWCU) System Isolation a.

Reactor Vessel Water Level - Low Low (b) 2 in one trip system B

SR 3.3.5.3.1 SR 3.3.5.3.2

-48 inches (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel (RPV)

Water Inventory Control."

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

TBD 1.

2.

(Deleted)

LOP Instrumentation 3.3.8.1 Monticello 3.3.8.1-1 Amendment No. 146 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, When the associated emergency diesel generator (EDG) is required to be OPERABLE by LCO 3.8.2, "AC Sources - Shutdown."

ACTIONS

NOTE-----------------------------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels inoperable.

A.1 Place channel in trip.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months B. Required Action and associated Completion Time not met.

B.1 Declare associated EDG inoperable.

Immediately

RPV Water Inventory Control 3.5.2 Monticello 3.5.2-2 Amendment No. 146, 198 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.2 Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 4 hours D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

D.1

NOTE ---------------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to restore secondary containment boundary.

AND Immediately Immediately (SGT)

TBD

RPV Water Inventory Control 3.5.2 Monticello 3.5.2-3 Amendment No. 200 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.3 Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to verify one standby gas treatment subsystem is capable of being placed in operation.

Immediately Immediately E. Required Action and associated Completion Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

E.1 Initiate action to restore DRAIN TIME to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for the required ECCS injection/spray subsystem, the:

a. Suppression pool water level is -3 ft; or

b. Condensate storage tank(s) water level is 7 ft for one tank operation and 4 ft for two tank operation.

In accordance with the Surveillance Frequency Control Program SGT TBD

RPV Water Inventory Control 3.5.2 Monticello 3.5.2-4 Amendment No. 200 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.3

NOTE------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify, for the required ECCS injection/spray subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.4 Operate the required ECCS injection/spray subsystem for 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5

NOTE------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program (Not Used)

NOTES--------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

TBD

PCIVs 3.6.1.3 Monticello 3.6.1.3-5 Amendment No. 146, 148, 198 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more penetration flow paths with one or more 18 inch primary containment purge and vent valves not within purge and vent valve leakage limits.

D.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

AND D.2

NOTES-------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Once per 31 days for isolation devices outside containment E. One or more MSIVs with leakage rate not within limits.

E.1 Restore leakage rate to within limits.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months F. Required Action and associated Completion Time of Condition A, B, C, or D not met in MODE 1, 2, or 3.

F.1 Be in MODE 3.

AND F.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours TBD

AC Sources - Shutdown 3.8.2 Monticello 3.8.2-3 Amendment No. 146, 198 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1

NOTES-----------------------------

1. The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.7, and SR 3.8.1.8 through SR 3.8.1.13.

2. SR 3.8.1.8 and SR 3.8.1.12 are not required to be met when associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, "RPV Water Inventory Control."

For AC sources required to be OPERABLE the SRs of Specification 3.8.1, except SR 3.8.1.6, are applicable.

In accordance with applicable SRs TBD SR 3.8.1.9, and SR 3.8.1.11.

The following SRs are applicable for SR 3.8.1.1 SR 3.8.1.2 SR 3.8.1.3 SR 3.8.1.4 SR 3.8.1.5 SR 3.8.1.7 SR 3.8.1.9 SR 3.8.1.11 NOTE

ENCLOSURE ATTACHMENT 2 MONTICELLO NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-582, REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL (RPV WIC)

ENHANCEMENTS TECHNICAL SPECIFICATION BASES PAGES (MARKED-UP - FOR INFORMATION ONLY)

(22 pages follow)

RPV Water Inventory Control Instrumentation B 3.3.5.3 Monticello B 3.3.5.3-2 Revision No. 52 BASES BACKGROUND (continued)

The purpose of the RPV Water Inventory Control Instrumentation is to support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV)

Water Inventory Control, and the definition of DRAIN TIME. There are functions that are required for manual operation of the ECCS injection/spray subsystem required to be OPERABLE by LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports manual operation of core spray (CS) and low pressure coolant injection (LPCI).

The equipment involved with each of these systems is described in the Bases for LCO 3.5.2.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not required SAFETY to mitigate any events or accidents evaluated in the safety analyses.

ANALYSES, LCO, RPV water inventory control is required in MODES 4 and 5 to protect and APPLICABILITY Safety Limit 2.1.1.4 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is postulated in which a single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g.,

seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

considered an TBD

RPV Water Inventory Control Instrumentation B 3.3.5.3 Monticello B 3.3.5.3-3 Revision No. 52 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

Core Spray and Low Pressure Coolant Injection Systems 1.a, 2.a. Reactor Steam Dome Pressure - Low (Injection Permissive)

Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystems. This function ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. While it is assured during MODES 4 and 5 that the reactor steam dome pressure will be below the ECCS maximum design pressure, the Reactor Steam Dome Pressure -

Low (Injection Permissive) signals are assumed to be OPERABLE and capable of permitting manual initiation of the ECCS subsystems.

The Reactor Steam Dome Pressure - Low (Injection Permissive) signals are initiated from two pressure switches (shared by both CS and LPCI) that sense the reactor dome pressure.

The Allowable Value is low enough to prevent overpressurizing the equipment in the low pressure ECCS susbystems.

The two channels of Reactor Steam Dome Pressure - Low (Injection Permissive) Function are required to be OPERABLE in MODES 4 and 5 when the associated ECCS subsystems are required to be OPERABLE by LCO 3.5.2.

2.b. Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)

The minimum flow instruments are provided to protect the associated LPCI pump from overheating when the pump is operating and the associated injection valve is not fully open. The LPCI minimum flow valves are time delayed such that the valves will not open for 10 seconds after the pump start. This delay can reduce the reactor vessel inventory loss (to the suppression pool) during the startup of the RHR pump while aligned in the shutdown cooling mode, since it provides time (prior to opening the minimum flow valve) to manually increase RHR flow above the minimum flow closure setpoint.

One flow switch per LPCI pump is used to detect the associated subsystems' flow rates. The logic is arranged such that each switch causes its associated minimum flow valve to open. The logic will close TBD

RPV Water Inventory Control Instrumentation B 3.3.5.3 Monticello B 3.3.5.3-4 Revision No. 52 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) the minimum flow valve once the closure setpoint is exceeded. The LPCI minimum flow valves are time delayed such that the valves will not open for 10 seconds after the pump start. The time delay is provided to limit reactor vessel inventory loss during the startup of the Residual Heat Removal (RHR) shutdown cooling mode.

The LPCI Pump Discharge Flow - Low (Bypass) Allowable Values are high enough to ensure that the pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core.

One channel of the LPCI Pump Discharge Flow - Low (Bypass) Function is required to be OPERABLE in MODES 4 and 5 when the associated LPCI pump is required to be OPERABLE by LCO 3.5.2 to ensure the pump is capable of injecting into the Reactor Pressure Vessel when manually operated.

Shutdown Cooling System Isolation 3.a - Reactor Vessel Water Level - Low The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low Function associated with Shutdown Cooling System may be credited for automatic isolation of the Shutdown Cooling System suction flow path.

Reactor Vessel Water Level - Low signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low Function are available, only two channels (all in the same trip system) are required to be OPERABLE to ensure automatic isolation of one of the two isolation valves.

The Reactor Vessel Water Level - Low Allowable Value was chosen to be the same as the Primary Containment Isolation Instrumentation Reactor Vessel Water Level - Low Allowable Value (LCO 3.3.6.1), since the capability to cool the fuel may be threatened.

1 TBD

RPV Water Inventory Control Instrumentation B 3.3.5.3 Monticello B 3.3.5.3-5 Revision No. 52 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

The Reactor Vessel Water Level - Low Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

This Function isolates the Group 2 drywell and sump isolation valves.

Reactor Water Cleanup (RWCU) System Isolation 4.a - Reactor Vessel Water level - Low Low The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low Low Function associated with RWCU System isolation may be credited for automatic isolation of penetration associated with the RWCU System suction flow path.

Reactor Vessel Water Level - Low Low signals are initiated from four differential pressure transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low Low Function are available, only two channels (all in the same trip system) are required to be OPERABLE to ensure automatic isolation of one of two isolation valves.

The Reactor Vessel Water Level - Low Low Allowable Value was chosen to be the same as the ECCS Reactor Vessel Water Level - Low Low Allowable Value (LCO 3.3.5.1), since the capability to cool the fuel may be threatened.

The Reactor Vessel Water Level - Low Low Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

This Function isolates the Group 3 valves.

2 TBD

RPV Water Inventory Control Instrumentation B 3.3.5.3 Monticello B 3.3.5.3-6 Revision No. 52 BASES ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels. 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 continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.3-1. The applicable Condition specified in the Table is Function or other specified condition dependent. Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

B.1 and B.2 Shutdown Cooling System Isolation, Reactor Vessel Water Level - Low and Reactor Water Cleanup System Isolation, Reactor Vessel Water Level - Low Low functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating Drain Time. If the instrumentation is inoperable, Required Action B.1 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation. Required Action B.2 directs calculation of DRAIN TIME. The calculation cannot credit automatic isolation of the affected penetration flow paths.

C.1 Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. If the permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive in the trip condition, manual operation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

A.1, A.2.1, and A.2.2 A.1 immediate action to place the channel in trip.

With the inoperable channel in the tripped condition, the remaining channel will isolate the penetration flow path on low water level. If both channels are inoperable and placed in trip, the penetration flow path will be isolated.

Alternatively, Required Action A.2.1 requires the associated penetration flow path(s) to be immediately declared TBD A.2.2 directs initiating action to calculate

RPV Water Inventory Control Instrumentation B 3.3.5.3 Monticello B 3.3.5.3-7 Revision No. 52 BASES ACTIONS (continued)

D.1 If a LPCI Pump Discharge Flow - Low Bypass function is inoperable, there is a risk that the associated low pressure ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection valve to ensure the pump does not overheat.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the ECCS pumps and open the injection valves and to manually ensure the pump does not overheat.

E.1 With the Required Action and associated Completion Time of Condition C or D not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

TBD

RPV Water Inventory Control Instrumentation B 3.3.5.3 Monticello B 3.3.5.3-8 Revision No. 52 BASES SURVEILLANCE As noted in the beginning of the SRs, the SRs for each RPV Water REQUIREMENTS Inventory Control instrumentation Function are found in the SRs column of Table 3.3.5.3-1.

SR 3.3.5.3.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL FUNCTIONAL TEST.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.3.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire 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.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

TBD The following SRs apply to the s

Primary Containment Isolation Instrumentation B 3.3.6.1 Monticello B 3.3.6.1-21 Revision No. 52 BASES ACTIONS (continued)

I.1 If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, the associated penetration flow path should be closed. However, if the shutdown cooling function is needed to provide core cooling, these Required Actions allow the penetration flow path to remain unisolated provided action is immediately initiated to restore the channel to OPERABLE status Actions must continue until the channel is restored to OPERABLE status.

SURVEILLANCE As noted at the beginning of the SRs, the SRs for each Primary REQUIREMENTS Containment Isolation instrumentation Function are found in the SRs column of Table 3.3.6.1-1.

The Surveillances are modified by a Note to indicate that when a channel (a channel that is directed to two trip systems is considered to be one channel) is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains primary containment isolation capability. Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. This Note is based on the reliability analysis (Refs. 5 and 6) assumption of the average time required to perform channel surveillance. That analysis demonstrated that the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months testing allowance does not significantly reduce the probability that the PCIVs will isolate the penetration flow path(s) when necessary.

SR 3.3.6.1.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

<add period> "."

TBD

LOP Instrumentation B 3.3.8.1 Monticello B 3.3.8.1-3 Revision No. 52 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) methodology. The Allowable Values are derived from the design limits.

The difference between the design limit and the Allowable Value allows for channel instrument accuracy, calibration accuracy, process measurement accuracy, and primary element accuracy. The margin between the Allowable Value and the NTSP allows for instrument drift that might occur during the established surveillance period. Two separate verifications are performed for the calculated NTSP. The first, a Spurious Trip Avoidance Test, evaluates the impact of the NTSP on plant availability. The second verification, an LER Avoidance Test, calculates the probability of avoiding a Licensee Event Report (or exceeding the Allowable Value) due to instrument drift. These two verifications are statistical evaluations to provide additional assurance of the acceptability of the NTSP and may require changes to the NTSP. Use of these methods and verifications provides the assurance that if the setpoint is found conservative to the Allowable Value during surveillance testing, the instrumentation would have provided the required trip function by the time the process reached the design limit for the applicable events.

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

1. 4.16 kV Essential Bus Loss of Voltage Loss of voltage on a 4.16 kV essential bus indicates that offsite power may be completely lost to the respective essential bus and is unable to supply sufficient power for proper operation of the applicable equipment.

Therefore, the power supply to the bus is transferred from offsite power to EDG power when the voltage on the bus drops below the 4.16 kV Essential Bus Loss of Voltage Function Allowable Value. This ensures that adequate power will be available to the required equipment.

The 4.16 kV Essential Bus Loss of Voltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that power is available to the required equipment.

Four channels of 4.16 kV Essential Bus Loss of Voltage Function per associated essential bus are only required to be OPERABLE when the associated EDG is required to be OPERABLE to ensure that no single instrument failure can preclude the EDG function. (Four channels input to each of the two EDGs.) Refer to LCO 3.8.1, "AC Sources - Operating,"

and 3.8.2, "AC Sources - Shutdown," for Applicability Bases for the EDGs.

TBD

LOP Instrumentation B 3.3.8.1 Monticello B 3.3.8.1-4 Revision No. 52 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

2. 4.16 kV Essential Bus Degraded Voltage A reduced voltage condition on a 4.16 kV essential bus indicates that, while offsite power may not be completely lost to the respective essential bus, available power may be insufficient for starting large ECCS motors without risking damage to the motors that could disable the ECCS function. Therefore, power supply to the bus is transferred from offsite power to onsite EDG power when the voltage on the bus drops below the 4.16 kV Essential Bus Degraded Voltage Function Allowable Values (degraded voltage with a time delay). This ensures that adequate power will be available to the required equipment.

The 4.16 kV Essential Bus Degraded Voltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that sufficient power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that sufficient power is available to the required equipment.

Three channels of 4.16 kV Essential Bus Degraded Voltage Function per associated bus are only required to be OPERABLE when the associated EDG is required to be OPERABLE to ensure that no single instrument failure can preclude the EDG function. (Three channels input to each of the two essential buses and EDGs.) Refer to LCO 3.8.1 and LCO 3.8.2 for Applicability Bases for the EDGs.

ACTIONS A Note has been provided to modify the ACTIONS related to LOP instrumentation channels. 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 inoperable LOP instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable LOP instrumentation channel.

A.1 With one or more channels of a Function inoperable, the Function is not capable of performing the intended function. Therefore, only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the inoperable channel to OPERABLE status. If the inoperable channel cannot be restored to OPERABLE status within the TBD

LOP Instrumentation B 3.3.8.1 Monticello B 3.3.8.1-5 Revision No. 52 BASES ACTIONS (continued) allowable out of service time, the channel must be placed in the tripped condition per Required Action A.1. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure (within the LOP instrumentation), and allow operation to continue. Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the channel in trip would result in an EDG initiation), Condition B must be entered and its Required Action taken.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

B.1 If any Required Action and associated Completion Time are not met, the associated Function is not capable of performing the intended function.

Therefore, the associated EDG is declared inoperable immediately. This requires entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2, which provide appropriate actions for the inoperable EDG.

SURVEILLANCE As noted at the beginning of the SRs, the SRs for each LOP REQUIREMENTS Instrumentation Function are located in the SRs column of Table 3.3.8.1-1.

The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided the associated Function maintains EDG initiation capability. Upon completion of the Surveillance, or expiration of the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.

SR 3.3.8.1.1 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 TBD

LOP Instrumentation B 3.3.8.1 Monticello B 3.3.8.1-6 Revision No. 52 BASES SURVEILLANCE REQUIREMENTS (continued) 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 Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.8.1.2 and SR 3.3.8.1.3 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 CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

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

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

SR 3.3.8.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel. The system functional testing performed in LCO 3.8.1 and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety functions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

TBD

RPV Water Inventory Control B 3.5.2 Monticello B 3.5.2-1 Revision No. 52 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control BASES BACKGROUND The Reactor Pressure Vessel (RPV) contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.4 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

APPLICABLE With the unit in MODES 4 or 5, RPV water inventory control is not SAFETY required to mitigate any events or accidents evaluated in the safety ANALYSES analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.4 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is considered in which single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g.,

seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

As discussed in References 3, 4, 5, 6, 7, and 8 operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The RPV water level must be controlled in MODES 4 and 5 to ensure that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1.4.

TBD considered an (an event that creates a drain path through multiple vessel penetrations located below the top of active fuel.)

RPV Water Inventory Control B 3.5.2 Monticello B 3.5.2-2 Revision No. 52 BASES LCO (continued)

The Limiting Condition for Operation (LCO) requires the DRAIN TIME of RPV water inventory to the TAF to be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A DRAIN TIME of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate an unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.4 and can be managed as part of normal plant operation.

One low pressure ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually started to provide defense-in-depth should an unexpected draining event occur. A low pressure ECCS injection/spray subsystem consists of either one Core Spray (CS) subsystem or one Low Pressure Coolant Injection (LPCI) subsystem.

Each CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or one or both condensate storage tanks (CSTs) to the reactor pressure vessel (RPV).

Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or from one or both CSTs to the RPV. In addition, in MODES 4 and 5 the RHR System cross-tie valve is not required to be open. Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY (Ref. 2).

The LCO is modified by a Note which allows a required LPCI subsystem to be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned (remote or local) to the LPCI mode and is not otherwise inoperable. Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is realigned from or to the RHR shutdown cooling mode. This allowance is necessary since the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Because of the restrictions on DRAIN TIME, sufficient time will be available following an unexpected draining event to manually align and initiate LPCI subsystem operation to maintain RPV water inventory prior to the RPV water level reaching the TAF.

OPERABILITY of the ECCS injection/spray subsystem includes any necessary valves, instrumentation, or controls needed to manually align and start the subsystem from the control room.

aligned and started from the control room TBD

RPV Water Inventory Control B 3.5.2 Monticello B 3.5.2-3 Revision No. 52 APPLICABILITY RPV water inventory control is required in MODES 4 and 5.

Requirements on water inventory control in other MODES are contained in LCOs in Section 3.3, Instrumentation, and other LCOs in Section 3.5, ECCS, RCIC, and RPV Water Inventory Control. RPV water inventory control is required to protect Safety Limit 2.1.1.4 which is applicable whenever irradiated fuel is in the reactor vessel.

ACTIONS A.1 and B.1 If the required low pressure ECCS injection/spray subsystem is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In this Condition, the LCO controls on DRAIN TIME minimize the possibility that an unexpected draining event could necessitate the use of the ECCS injection/spray subsystem, however the defense-in-depth provided by the ECCS injection/spray subsystem is lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for restoring the required low pressure ECCS injection/spray subsystem to OPERABLE status is based on engineering judgment that considers the LCO controls on DRAIN TIME and the low probability of an unexpected draining event that would result in loss of RPV water inventory.

If the inoperable ECCS injection/spray subsystem is not restored to OPERABLE status within the required Completion Time, action must be initiated immediately to establish a method of water injection capable of operating without offsite electrical power. The method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The method of water injection may be manually initiated and may consist of one or more systems or subsystems, and must be able to access water inventory capable of maintaining the RPV water level above the TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

If recirculation of injected water would occur, it may be credited in determining the necessary water volume.

C.1, C.2, and C.3 With the DRAIN TIME less than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months but greater than or equal to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , compensatory measures should be taken to ensure the ability to implement mitigating actions should an unexpected draining event occur.

Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material. Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment.

The secondary containment provides a controlled volume in which fission products can be contained, diluted, and processed prior to release to the environment. Required Action C.1 requires verification of the capability to "Instrumentation,"

"ECCS, RPV Water Inventory Control, and RCIC System."

TBD

RPV Water Inventory Control B 3.5.2 Monticello B 3.5.2-8 Revision No. 52 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.3 Verifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path provides assurance that the proper flow paths will be available for ECCS operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed (Ref. 2).

SR 3.5.2.4 Verifying that the required ECCS injection/spray subsystem can be manually started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. Testing the ECCS injection/spray subsystem through the recirculation line (Torus Cooling/Mixing) is necessary to avoid overfilling the refueling cavity. The minimum operating time of 10 minutes was based on engineering judgement.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.5 The required ECCS subsystem shall be capable of being manually operated. This Surveillance verifies that the required CS or LPCI subsystem (including the associated pump and valve(s)) can be manually operated to provide additional RPV Water Inventory, if needed.

TBD (Not Used) aligned, and the pump started and operated This SR is modified by two Notes. Note 1 states that testing the ECCS injection/

spray subsystem may be done through the test return line to avoid overfilling the refueling cavity. Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using the RHR mode of LPCI for 10 minutes.

can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CSTs to the RPV.

RPV Water Inventory Control B 3.5.2 Monticello B 3.5.2-10 Revision No. 52 BASES SURVEILLANCE REQUIREMENTS (continued)

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths. A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining in the event of an Operating Basis Earthquake. Normal or expected leakage from closed systems or past isolation devices is permitted. Determination that a system is intact and closed or isolated must consider the status of branch lines and ongoing plant maintenance and testing activities.

The Residual Heat Removal (RHR) Shutdown Cooling System is only considered an intact closed system when misalignment issues (Reference 8) have been precluded by functional valve interlocks or by isolation devices, such that redirection of RPV water out of an RHR subsystem is precluded. Further, RHR Shutdown Cooling System is only considered an intact closed system if its controls have not been transferred to the Alternate Shutdown System, which disables the interlocks and isolation signals.

The exclusion of penetration flow paths from the determination of DRAIN TIME must consider the potential effects of a single operator error or initiating event on items supporting maintenance and testing (rigging, scaffolding, temporary shielding, piping plugs, snubber removal, freeze seals, etc.). If failure of such items could result and would cause a draining event from a closed system or between the RPV and the isolation device, the penetration flow path may not be excluded from the DRAIN TIME calculation.

Surveillance Requirement 3.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

closed and administratively controlled by TBD a single penetration flow path, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME should consider the effects of temporary alterations in support of maintenance (rigging, scaffolding, temporary shielding, piping plugs, freeze seals, etc.). If reasonable controls are implemented to prevent such temporary alterations from causing a draining event from a closed system, or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered.

Reasonable controls include, but are not limited to, controls consistent with the guidance in NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

Revision 4, NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," or commitments to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants."

PCIVs B 3.6.1.3 Monticello B 3.6.1.3-9 Revision No. 52 BASES ACTIONS (continued)

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable considering the time required to restore the leakage by isolating the penetration, the fact that MSIV closure will result in isolation of the main steam line(s) and a potential for plant shutdown, and the relative importance of MSIV or main steam pathway leakage to the overall containment function.

F.1 and F.2 If any Required Action and associated Completion Time cannot be met in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

G.1 If any Required Action and associated Completion Time cannot be met for PCIV(s) required OPERABLE in MODE 4 or 5, the unit must be placed in a condition in which the LCO does not apply. Action must be immediately initiated to restore the valve(s) to OPERABLE status. This allows RHR shutdown cooling to remain in service while actions are being taken to restore the valve.

SURVEILLANCE SR 3.6.1.3.1 REQUIREMENTS This SR ensures that the 18 inch primary containment purge and vent valves are closed as required or, if open, open for an allowable reason. If a purge or vent valve is open in violation of this SR, the valve is considered inoperable. If the inoperable valve is not otherwise known to have excessive leakage when closed, it is not considered to have leakage outside of limits. The SR is modified by a Note stating that the SR is not required to be met when the purge and vent valves are open for the stated reasons. The Note states that these valves may be opened for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open.

The 18 inch purge and vent valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time.

TBD

AC Sources - Shutdown B 3.8.2 Monticello B 3.8.2-2 Revision No. 51 BASES APPLICABLE SAFETY ANALYSES (continued)

MODES 4 and 5, the activities are generally planned and administratively controlled. Relaxations from typical MODES 1, 2, and 3 LCO requirements are acceptable during shutdown MODES, based on:

a.

The fact that time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.

b.

Requiring appropriate compensatory measures for certain conditions.

These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operation MODE analyses, or both.

c.

Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.

d.

Maintaining, to the extent practical, the ability to perform required functions (even if not meeting MODES 1, 2, and 3 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability of supporting systems necessary for avoiding immediate difficulty, assuming either a loss of all offsite power or a loss of all onsite (emergency diesel generator (EDG)) power.

AC Sources - Shutdown satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO One offsite circuit capable of supplying the onsite Class 1E power distribution subsystem(s) of LCO 3.8.8, "Distribution Systems -

Shutdown," ensures that all required loads are powered from offsite power. An OPERABLE EDG, associated with a Distribution System 4.16 kV essential bus required OPERABLE by LCO 3.8.8, ensures that a diverse power source is available for providing electrical power support assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit and EDG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents involving handling recently irradiated fuel). Automatic initiation of the required EDG during shutdown conditions is specified in LCO 3.3.8.1, "LOP Instrumentation."

The qualified offsite circuit(s) must be capable of maintaining rated frequency and voltage while connected to their respective 4.16 kV essential bus, and of accepting required loads during an accident. The primary AC electrical power distribution subsystem for each division TBD

AC Sources - Shutdown B 3.8.2 Monticello B 3.8.2-3 Revision No. 51 BASES LCO (continued) consists of a 4.16 kV essential bus (essential bus 15 for Division 1 and essential bus 16 for Division 2) having several offsite sources of power available. One offsite circuit consists of incoming disconnects to the 2R transformer, associated 2R transformer, and the respective circuit path including buses and feeder breakers to all 4.16 kV essential buses required by LCO 3.8.8. The second circuit consists of incoming disconnects to the 1R transformer, associated 1R transformer, and the respective circuit path including buses and feeder breakers to all 4.16 kV essential buses required by LCO 3.8.8. The third qualified offsite circuit consists of incoming disconnects to the 1AR transformer, associated 1AR transformer, and the respective circuit path including feeder breakers to all 4.16 kV essential buses required by LCO 3.8.8 (Ref. 1).

The required EDG must be capable of starting, accelerating to rated speed and voltage, connecting to its respective 4.16 kV essential bus on detection of bus undervoltage, and accepting required loads. This sequence must be accomplished within 10 seconds. Each EDG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the 4.16 kV essential buses. These capabilities are required to be met from a variety of initial conditions such as EDG in standby with engine hot and EDG in standby with engine at ambient conditions. Additional EDG capabilities must be demonstrated to meet required Surveillances, e.g., capability of the EDG to reject a load equivalent to its associated single largest post-accident load.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for EDG OPERABILITY. In addition, proper sequence operation is an integral part of offsite circuit OPERABILITY since its inoperability impacts the ability to start and maintain energized loads required OPERABLE by LCO 3.8.8.

The necessary portions of the Emergency Diesel Generator - Emergency Service Water System capable of providing cooling to the required EDG are also required.

being manually

started, TBD

AC Sources - Shutdown B 3.8.2 Monticello B 3.8.2-5 Revision No. 51 BASES ACTIONS (continued) involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required EDG inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, and movement of recently irradiated fuel assemblies in the secondary containment.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC source and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power source should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any required 4.16 kV essential bus, ACTIONS for LCO 3.8.8 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit whether or not a division is de-energized. LCO 3.8.8 provides the appropriate restrictions for the situation involving a de-energized division.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.6 is not required to be met since only one offsite circuit is required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by two Notes. The reason for Note 1 is to preclude requiring the OPERABLE required EDG from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and to preclude deenergizing a required 4.16 kV essential bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the EDG. It is the intent that these SRs must still be capable of being met, but actual performance TBD a Note indicating that SR 3.8.1.3, SR 3.8.1.7, SR 3.8.1.9, and SR 3.8.1.11 are not required to be performed.

the

AC Sources - Shutdown B 3.8.2 Monticello B 3.8.2-6 Revision No. 51 BASES SURVEILLANCE REQUIREMENTS (continued) is not required during periods when the EDG and offsite circuit is required to be OPERABLE. Note 2 states that SRs 3.8.1.8 and 3.8.1.12 are not required to be met when its associated ECCS subsystem(s) are not required to be OPERABLE. These SRs demonstrate the EDG response to an ECCS signal (either alone or in conjunction with a loss-of-power signal). This is consistent with the ECCS instrumentation requirements that do not require the ECCS signals when the ECCS System is not required to be OPERABLE. In Modes 4 and 5 one ECCS subsystem is required to be capable of manual initiation but is not required to be OPERABLE; therefore SRs that demonstrate the EDG response to an ECCS signal are not required to be met in these Modes.

REFERENCES

1.

USAR, Section 8.2 TBD

v t e Letter Sequence Request
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L-MT-20-018, License Amendment Request: Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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L-MT-20-018, License Amendment Request: Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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