ML20094M198

Proposed Tech Specs,Incorporating Requirements of Option B, Section Iii.A for Type a Testing (Primary Containment ILRT)

ML20094M198
Person / Time
Site:	Monticello
Issue date:	11/14/1995
From:	NORTHERN STATES POWER CO.
To:
Shared Package
ML20094M197	List: ML20094M194 ML20094M198
References
NUDOCS 9511210316
Download: ML20094M198 (10)

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Exhibit B l Monticello Nuclear Generating Plant License Amendment Reauest Dated November 14.1995 l J

Technical Specification Pages Marked Up l with Proposed Wording Changes 1

Exhibit B consists of the existing Technical Specification pages marked up with the proposed changes. Existing pages affected by this change are listed below-P_R92 159 160 184 185 (new) l

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9511210316 951114 PDR ADOCK 05000263 P PDR

Perform required visual examinations and leakage rate ~7 '.

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t: sting for Type A containment integrated leakage rat 3 C ombel mAxe mu m -Noe [%Th Mage tests in accordance with Regulatory Guide 1.163, and Type . ,

,B and C tests in accordance with 10 CFR 50, Appendix J, ,

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Option A, as modified by approved exemptions.

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3.0 LIMITING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS J

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b. When Primary Containment Integrity is required, b con all b demon rated -

nm th; f" p-in-a acwe ue. d leakage rates shall be limited to: d ch d 5: f:dni .:d

1. An overall integrated leakage rate of less

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7 than or equal to La, 1.2 percent by weight anodprovi ema w T ou M onsofjf0CFRP t 50; flon g' of the containme_nt air _per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at Pa. }y orp9 rove e.f.e tw .

42 psig. $ggQ q j-(,g- -

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T ee Type A overall integrate A combined eakage rate of less than or equal cont ent leakage rate t shall

2. h intervals

• to 0.6La for all penettations and valves, be conduc at 40i10 ne pt f:r ::1 : ::: 1 :12tir- relr::, during shutdo a _ a during each subject to Type B and C tests when pressurized 10-year servi od. The third test of e set shal conducted to Pa 3L{2. p sig. duri e shutdown for ti 0-year 4L

3. Less than or equal to 41 scf per hour or all t inservice inspection.

eny :ne main steam isolation valveSwhen tested Dele.Tarl at 25 ps 2. any periodic Type A test fails

@ meet subseque 75La, the test schedul pe A tests sh be or With the measured over integrated primary roved the Commission.

containment leakage ce exceeding 0.75La, or the reviewed an measured combined 1 kage rate for all penetrations If two consecuti e A tests fail to and valves, _-i- rte-- irelatie- rel _--  ;, meet 0.75La, a e t shall be eeept[n_dCtestingexceed ype B La, or performed a east every onths until leak rate exceeding t c5- f per hour I two con utive Type A tests m 0.75La, the measgr time the above test sche le for an,8_n: main steam isolation valven restore at w leakage rates to less than or equal to these values be resuged.

prior to increasing reactor coolant system temper- e\ste, d ature above 212*F or, alternatively, restore 3. e A test leakage rates s measured leakage rates to within these limits within calculat observ a converted one hour or be in at least Hot Shutdown within the to absolute va . analyses next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the shall ormed to select ced following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. integrated leakage measuremen m.

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• ie test of the see ar i Coyd*gned vvwMmtAm Du3 o servlCe periot onducted during i th e ueling outage. ,

159 3.7/4.7 ' "" l '"'  : 1/:'/3

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3.0 LIMITING CONDITIONS FOR OPERATION 4.0 SkIRVEI CE REQUIREMENTS C5 elate

4. e accuracy of each Type A test shall b '

ve ied by a supplemental test which:

a. Con a the accuracy of the at by

. verify that the differen between the supp ental data and e Type A  !

test data within 0.2 , and i

b. Has duration su e nt to establish accurately the ch e in leakage rate between the Typ At and the supple- ,

mental test, d I

c. Requires e rate of gas in ted into t containment or bled the cont nment during the supplemen to be limited between 75 to 1 te b e\<t

5. Q: 5 ::' t_;t: ;5:11 5 5.p_t;d

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lin "::leti:n ::1 ::._.-- in steam ,

- isolation va e tests shall conducted i with gas at > psig east _S :: th:. A

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. -tosse. leak i rate o 11. ", yauf per hour sh b emonstrated +eek. main i steam ne' solation valves, a.ll  !

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3.//4.7 160

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j Bases Continued: . .

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! While the design of the Monticello plant predates 10 CFR Part 50, Appendix J, " Primary Reactor Containment Lankage Testing for Water-Cooled Power Reactors," testing substantially conforms to the

• requirements of Appendix J. The design of the plant was thoroughly reviewed to determine where compliance with Appendix J was, impossible or impractical. In each case where a departure from the requirements of Appendix J was identified, a request for exemption from the requirements of Appendix J or a plant modification was proposed and submitted for NRC Staff review. Exemptions were proposed in those cases where compliance with Appendix J would have provided no meaningful improvement in plant safety.

In their review of Appendix J compliance II) , the NRC Staff approved a number of exemption requests, denied others, and provided'necessary interpretation and clarification of the requirements of i Appendix J. The Technical S$ecification surveillance requirements reflect the results of this review.

Exemption from the requirements of Appendix J was provided in the following areas:

a. Testing of valves sealed by water

b. Low pressure testing of main steam line isolation valves

c. Low pressure testing of the primary containment airlock

d. Reduced airlock testing frequency when the airlock is in frequent use s/

The Monticello airlock is tested by pressurizing the space between the inner.and outer doors.

Individual door seal leakage tests cannot be performed. Since the inner door is designed to seat with containment pressure forcing. the door closed, special bracing must be installed for each leakage test. The outer door must be opened to install and remove this bracing. Because of the l complexity of this operation,~up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> may be necessary to perform a leakage test.

(1) Letter from D G Eisenhut, Director, Division of Licensing, USNRC, dated June 3,1984, " Safety .

Evaluation by the Office of NRR, Appendix J Review".  !

4.7 BASES - - . TA;; IS ra0E 100 184  :

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Bases Continued:

On September 26, 1995, Regulatory Guide 1.163 became effective providing guidance on performance based testing to the requirements of 10 CFR 50, Appendix J, Option B. Monticello has adopted Option B, Section ,

III.A of 10 CFR Part 50, Appendix J, . for_ Type A primary reactor containment integrated leakage rate - l testing. Monticello will continue to perform Type B and C testing in accordance with 10 CFR Part 50, ,

I Appendix J, Option A. r 4

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l 4.7 BASES NEXT PAGE IS PAGE 188 185

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Exhibit C Monticello Nuclear Generating Plant License Amendment Reauest Dated November 14.1995 Revised Monticello Technical Specification Pages Exhibit C consists of revised Technical Specification pages that incorporate the proposed changes. The pages included in this exhibit are as listed below. Note that due to removal of specific material and the resulting reconciliation, page 161 is no  ;

longer included.

.Pjagg 159 160 184 185 (new) i 1

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3.0 LIMITING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS

b. When Primary Containment Integrity is required, b. Perform required. visual examinations and leakage rates shall be limited to: leakage rate testing for Type A containment '

integrated leakage rate tests in accordance

l. An overall integrated leakage rate of less with Regulatory Guide 1.163, and for Type B and than or equal to La, 1.2 percent by weight C tests in accordance with 10 CFR 50, Appendix of the containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at Pa, J, Option A, as modified by approved 42 psig. exemptions.

i .2. A combined maximum flow path leakage rate 1. Deleted of less than or equal to 0.6La for all penetrations and valves, subject to Type B 2. Deleted and C tests when pressurized to Pa, 42

, psig. 3. Deleted

3. Less than or equal to 46 scf per hour 4. Deleted combined maximum flow path leakage for all main steam isolation valves when tested at 5. Deleted 25 psig.

With the measured overall integrated primary i containment leakage rate exceeding 0.75La, or the measured combined leakage rate for all penetrations and valves subject to Type B and C testing exceeding 0.6La, or the measured combined maximum flow path leakage rate exceeding 46 scf per hour for all main steam isolation valves, restore leakage rates to less than or equal to these values prior to ,

increasing reactor coolant system temperature above 212*F or, alternatively, restore measure .

leakage rates to within these limits within one hour or be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

i 159 3.7/4.7

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3.0 LIMITING CONDITIONS EDR OPERATION 4.0 SURVEILIANCE REQUIREMENTS

c. When Primary Containment Integrity is required, c. The primary containment airlock shall be the primary containment airlock shall be demonstrated operable:

operable with:

1. By performing overall airlock leakage rate

1. Both doors closed except when the airlock testing in accordance with 10 CFR 50, is being used, then at least one airlock Appendix J, as modified by approved door shall be closed, and exemptions.

2. An overall airlock leakage rate of less 2. Deleted than or equal to 0.05La at Pa or 0.007La at 10 psig. 3. At six month intervals by verifying that only one door can be opened at With the primary containment airlock a time. If the airlock has not been inoperable, maintain at least one airlock door used since the last door interlock closed and restore the airlock to Operable test, this test is not required.

status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold d. The interior surfaces of the drywell shall Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. be visually inspected each operating cycle for evidence of deterioration.

3.7/4.7 160 NEXT PAGE IS PAGE 163

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,~f Bases Continued:

l While the design of the Monticello plant predates 10 CFR Part 50, Appendix J, " Primary Reactor. ,

i Containment Leakage Testing for Water-Cooled Power Reactors," testing substantially conforms to the f requirements of Appendix J. The design of the plant was thoroughly reviewed to determine where  !

compliance with Appendix J was impossible or impractical. In each case where a departure from the requirements of Appendix J was identified, a request for exemption from the requirements of Appendix l J or a plant modification was proposed and submitted for NRC Staff review. Exemptions were proposed in those cases where compliance with Appendix J would have provided no meaningful improvement in j plant safety. t i

! In their review of Appendix J compliancetu, the NRC Staff approved a number of exemption requests, I i denied others, and provided necessary interpretation and clarification of the requirements of Appendix J. The Technical Specification surveillance requirements reflect the results of this  ;

review.

Exemption from the requirements of Appendix J was provided in the following areas:

a. Testing of valves sealed by water 5

b. Low pressure testing of main steam line isolation valves.

c. Low pressure testing of the primary containment airlock

d. Reduced airlock testing frequency when the airlock is in frequent use The Monticello airlock is tested by pressurizing the space between the inner and outer doors.

i Individual door seal leakage tests cannot be performed. Since the inner door is designed to seat  !

with containment pressure forcing the door closed, special' bracing must be installed for each leakage test. The outer door must be opened to install and remove this bracing. Because of the ,

complexity of this operation, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> may be necessary to perform a leakage test. i i

(1) Letter from D C Eisenhut, Director, Division of Licensing, USNRC, dated June 3,1984, " Safety Evaluation by the Office of NRR, Appendix J Review".

4.7 BASES 184 g j REV I i

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s Beses Continued: ,

On September 26, 1995, Regulatory Guide 1.163 became effective providing guidance on performance based testing to the requirements of 10 CFR 50, Appendix J, Option B. Monticello has adopted Option B,Section III. A of 10 CFR Part 50, Appendix J, for Type A primary reactor containment integrated leakage rate testing. Monticello will continue to perform Type B and C testing in accordance with 10 CER Part 50, Appendix J Option A.

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4.7 BASES NEXT PAGE IS PAGE.188 185 L

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