View source for L-MT-08-070, Response to September 16, 2008, Request for Additional Information for License Amendment Request for Power Range Neutron Monitoring System Upgrade

{{Adams
| number = ML083150022
| issue date = 11/06/2008
| title = Response to September 16, 2008, Request for Additional Information for License Amendment Request for Power Range Neutron Monitoring System Upgrade
| author name = O'Connor T
| author affiliation = Northern States Power Co, Xcel Energy
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000263
| license number = DPR-022
| contact person = 
| case reference number = L-MT-08-070, TAC MD8064
| document type = Letter type:L
| page count = 7
| project = TAC:MD8064
| stage = Request
}}

=Text=
{{#Wiki_filter:@ Xcel Energye November 6,2008                                                                   L-MT-08-070 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 Renewed Facility Operating License No. DPR-22 Response to September 16, 2008, Request for Additional Information for License Amendment Request for Power Range Neutron Monitoring Svstem Upgrade (TAC No. MD8064)
On February 6,2008, the Nuclear Management Company, LLC, a predecessor license holder to the Northern States Power Company, a Minnesota corporation (NSPM),(')
submitted a request to revise the Monticello Nuclear Generating Plant (MNGP)
Technical Specifications (TS) in conjunction with the installation of the General Electric
- Hitachi Nuclear Measurement Analysis and Control Power Range Neutron Monitoring System (Enclosure 1, Reference 1). Enclosure 1 to this letter contains the NSPM response to a U.S. Nuclear Regulatory Commission (NRC) request for additional information (RAI) dated September 16, 2008 (Enclosure 1, Reference 6).
In response to the September 16, 2008 RAI, the NSPM has revised Note (e) to the proposed TS Table 3.3.1.1-1 within the MNGP TS. Enclosure 2 provides a revised copy of the pertinent page of the TS which includes the revised note.
Summarv of Commitments No new commitments or changes to any existing commitments are proposed by this letter.
The NSPM has reviewed the No Significant Hazards Consideration and the Environmental Consideration determinations provided in the February 6, 2008, license amendment request relative to the supplemental information being provided herein and has determined that no changes are required to either determination.
: 1. Northern States Power Company - Minnesota (NSPM) is incorporated as a wholly owned subsidiary of Xcel Energy, Inc. Transfer of operating authority from the Nuclear Management Company, LLC to NSPM occurred on September 22, 2008.
2807 West County Road 75   Monticello, Minnesota 55362-9637 Telephone: 763.295.5151 Fax: 763.295.1454

Document Control Desk Page 2 of 2 The MNGP Plant Operations Review Committee has reviewed this RAI response and enclosed revised TS page. In accordance with 10 CFR 50.91, a copy is being provided to the designated Minnesota Official.
erjury that the foregoing is true and correct. Executed
                    , Monticello Nuclear Generating Plant pany - Minnesota Enclosures (2) cc:    Administrator, Region Ill, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce

ENCLOSURE I RESPONSE TO THE SETEMBER 16,2008 REQUEST FOR ADDITIONAL INFORMATION On February 6,2008, the Nuclear Management Company, LLC(') submitted a request (Reference 1) to revise the Monticello Nuclear Generating Plant (MNGP) Technical Specifications (1s) in conjunction with the installation of the General Electric - Hitachi Nuclear Measurement Analysis and Control Power Range Neutron Monitoring (PRNM)
System.
The U.S. Nuclear Regulatory Commission (NRC) requested additional information (RAI) on the basis for this proposed change by three e-mails, dated June 13, June 25 and July I , 2008 (References 2 , 3 and 4, respectively). A response to these three RAls was provided in a letter dated September 16, 2008 (Reference 5).
An additional e-mail RAI was issued by the NRC on September 16, 2008 (Reference 6).
The response to the June 25, 2008, e-mail request provided in Enclosure 2 of the September 16, 2008, response letter partially addressed the two new September 16, 2008, NRC e-mail RAI questions. Two telephone discussions by the Northern States Power Company - Minnesota (NSPM) were held with the NRC on October 23 and 24, 2008, to clarify the NRC requests. The first question concerning the testing rate for response time testing of the 2-Out-Of-4 Voter function (Function 2.e) in accordance with SR 3.3.1.14 was resolved during the phone calls. The second question and the NSPM response is provided below.
: 1.      Explain how proposed Note (e) i n Table 3.3.1 .I      -1 of L C 0 3.3.1 .Iensures that Surveillance Requirements (SR) associated with Function 2.f are met per SR 3.0.1, thereby ensuring that 10 CFR 50.36(d)(3) is met.

==Background:==
L C 0 3.3.1.1, "RPS Instrumentation," has proposed Function 2.f, OPRM Upscale, in Table 3.3.1.1-1. The SR associated with Function 2.f have a proposed Note (e) which states in part that:
              "Initial declaration of Operability is based upon factory acceptance testing, post-modification testing (including full or partial-surveillance performance during the RFO or during operation, as applicable) and industry experience with the PRNM System.
First performance of these new surveillance requirements is due at the end of the first surveillance interval, which begins on the date the OPRM Upscale function was initially declared Operable following the 2009 RFO."
: 1.       Northern States Power Company - Minnesota (NSPM) is incorporated as a wholly owned subsidiary of Xcel Energy, Inc. Transfer of operating authority from the Nuclear Management Company, LLC to NSPM occurred on September 22, 2008.
Page 1 of 3

ENCLOSURE I RESPONSE TO THE SEPTEMBER 16,2008 REQUEST FOR ADDITIONAL INFORMATION SR 3.0.1 states that "SRs shall be met during the Modes or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO."
10 CFR 50.36(d)(3) states technical specifications will include surveillance requirements which "are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met."
It is unclear how proposed Note (e) ensures that SRs associated with Function 2.f are met per SR 3.0.1, thereby ensuring that 10 CFR 50.36(d)(3) is met, i f there is no initial performance of these new SRs until the end of the first surveillance interval (i.e., how can a SR be met i f it was never performed).

===Response===
At the time the PRNM System license amendment request was being prepared, and it was not known with certainty exactly how the system would be tested on-line. To address this uncertainty, Note (e) was added to allow utilization of other test data, from sources such as, factory acceptance testing, post-modification testing, and full or partial-surveillance performance (during the refueling outage or during operation, as applicable). This other testing would be evaluated and credited, if necessary, to demonstrate compliance in conjunction with those portions of the surveillances that could be performed to declare the OPRM Upscale function (Function 2.f) OPERABLE on-line.
Since that time, it has been determined that the required surveillance testing can be performed during the refueling outage, and that any additional partial follow-up surveillance testing concerned with activation of the OPRM Upscale function can be performed on-line.
Consequently, the portions of Note (e) concerned with the initial declaration of operability and surveillance performance scheduling are no longer necessary. Note (e) has been moved to the function column, i.e.,
after the OPRM Upscale function title, from the Function 2.f surveillance requirements listed under that column to clarify that the OPRM Upscale function is inoperable during the OPRM Monitoring Period. Enclosure 2 provides a revised copy of the pertinent page of the MNGP TS which includes a revised Note (e) to the proposed TS Table 3.3.1.I-1.
Page 2 of 3

ENCLOSURE 1 RESPONSE TO THE SEPTEMBER 16,2008 REQUEST FOR ADDITIONAL INFORMATION REFERENCES
: 1. NMC letter to NRC, "License Amendment Request: Power Range Neutron Monitoring System Upgrade," (L-MT-08-004), dated February 6, 2008.
: 2. Email from P. Tam (NRC) to R. Loeffler (NMC) dated June 13,2008, "Monticello - Draft RAI re: Proposed Amendment on PRNM System (TAC MD8064) --- Enclosure 1 RAI Questions 1 through 6.
: 3. Email from P. Tam (NRC) to R. Loeffler (NMC) dated June 25, 2008, "Monticello - Additional Draft RAI re: Proposed Amendment on PRNM System (TAC MD8064) --- Enclosure 2 RAI Questions 1 through 3.
: 4. Email from P. Tam (NRC) to R. Loeffler (NMC) dated July 1, 2008, "Monticello -
Draft Reactor Systems RAI re. Proposed Amendment on PRNM (TAC MD8064)
    --- Enclosure 3 RAI Questions 1 through 3.
: 5. NMC letter to NRC, "Response to Requests for Additional Information for License Amendment Request for Power Range Neutron Monitoring Svstem Upgrade (TAC No. MD8064),11(L-MT-08-049), dated September 16, 2008.
: 6. Email from P. Tam (NRC) to R. Loeffler (NMC) dated September 23, 2008, "Monticello - Draft Reactor Systems RAI re. Proposed Amendment on PRNM (TAC MD8064)
Page 3 of 3

ENCLOSURE 2 MONTICELLO NUCLEAR GENERATING PLANT RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION FOR LICENSE AMENDMENT REQUEST FOR POWER RANGE NEUTRON MONITORING SYSTEM UPGRADE (TAC NO. MD8064)
MNGP TECHNICAL SPECIFICATION REVISION REPLACEMENT PAGE FOR TS INSERTS 1 Page Follows

REPLACEMENT INSERT 5:                                             Adds LSSS Notes APPLICABLE                     CONDITIONS MODES OR        REQUIRED     REFERENCED OTHER         CHANNELS          FROM SPECIFIED        PER TRIP      REQUIRED             SURVEILLANCE       ALLOWABLE FUNCTION               CONDITIONS        SYSTEM       ACTION D.1           REQUIREMENTS           VALUE
: 2. Average Power Range Monitors
: a. Neutron Flux - High,                 2            +I               G           SR   3.3.1.1.1         1 2 0 % RTP (Setdown)                                                                     SR   3.3.1.1.4 SR   3.3.1.1.6 SR   3.3.1.1.11 SR   3.3.1.1.15
: b. Simulated Thermal Power              1            g(c)              F          SR   3.3.1.1.1         r 0.66 W + 61.6%
        - High                                                                        SR   3.3.1.1.2         RTP(~)
SR   3.3.1.1.4            and SR   3.3.1.1.6          1116% RTP SR   3.3.1.1.11 SR   3.3.1.1.15
: c. Neutron Flux - High                  1            3(c)              F          SR   3.3.1.1.1         1122% RTP SR   3.3.1.1.2 SR   3.3.1.1.4 SR   3.3.1.1.6 SR   3.3.1.I .I I"'~'
SR   3.3.1.1.15
: d. lnop
: e. 2-Out-0f-4 Voter
: f. OPRM      scale'^'            r 20% RTP          3'4               I          SR 3.3.1.1.1                As specified SR 3.3.1.1.4                  in COLR SR 3.3.1.1.6 SR 3.3.1.1.11 SR 3.3.1.1.15 SR 3.3.1. I . I 6 (b)      5 0.66 (W - Delta W) + 61.6% RTP when reset for single loop operation per LC0 3.4.1, "Recirculation Loops Operating." The cycle-specific value for Delta W is specified in the COLR.
(c)      Each APRM IOPRM channel provides inputs to both trip systems.
(e)      During the OPRM Monitoring Period the OPRM Upscale function is inoperable.
(9      If the as-found channel setpoint is not the Nominal Trip Setpoint but is conservative with respect to the Allowable Value, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(g)     The instrument channel setpoint shall be reset to the Nominal Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable. The NTSP and the methodology used to determine the NTSP are specified in the Technical Requirements Manual.}}