ML061240255
| ML061240255 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 06/05/2006 |
| From: | Plant Licensing Branch III-2 |
| To: | |
| beltz T, NRR/DORL/LPL3-1, 301-415-3049 | |
| Shared Package | |
| ML061240241 | List: |
| References | |
| TAC MC7505, TAC MC7597, TAC MC7598, TAC MC7599, TAC MC7600, TAC MC7601, TAC MC7602, TAC MC7603, TAC MC7604, TAC MC7605, TAC MC7606, TAC MC7607, TAC MC7608, TAC MC7609, TAC MC7610, TAC MC7611, TAC MC8887 | |
| Download: ML061240255 (67) | |
Text
Table A - Administrative ChangesMonticello Page 1 of 67 ATTACHMENT 2 ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS Requirement 1.0 A.1 In the conversion of the Monticello Current Technical Specifications (CTS) to the plantspecific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numberi ng, etc.) are made to obtain consistencywith NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants,BWR/4" (ISTS).1.11.0, 3.1.A, 3.3.A.1 1.0 A.2The CTS Section 1.0 Definition introduction states "The succeeding frequently usedterms are explicitly defined so that a uniform interpretation of the Specifications may beachieved." The Note to ITS Section 1.1 states "The defined terms of this section appearin capitalized type and are applicable throughout these Technical Specifications andBases." This changes the CTS by replacing the CTS Section 1.0 introduction of thedefinitions with a Note.1.11.0, 3.1.A, 3.3.A.1 1.0 A.3CTS 1.0.A provides the definition of Alteration of the Reactor Core. ITS Section 1.1provides a definition of CORE ALTERAT ION that includes an additional phrase thatstates "Suspension of CORE ALTERAT IONS shall not preclude completion of movement of a component to a safe position." This changes the CTS by adding this phrase to the definition.1.11.0.A 1.0 A.4CTS Section 1.0 does not provide a definition of SHUTDOWN MARGIN (SDM). However, CTS 3.3.A.1 does specify that the core loading shall be limited to that "which can be made subcritical in the most reactive condition during the operating cycle with the strongest operable control r od in its full-out position and all other operable rods fullyinserted," and CTS 4.3.A.1 spec ifies "that the core can be made subcritical at any timein the subsequent fuel cycle with the strongest operable control rod fully withdrawn andall other operable rods fully inserted." IT S Section 1.1 includes a definition for SDM,which states "SDM shall be the amount of reactivity by which the reactor is subcritical orwould be subcritical assuming that: a. The reactor is xenon free; b. The moderatortemperature is 68°F; and c. All control rods are fully in serted except for the singlecontrol rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM." This changes the CTS as follows:a. An explicit allowance has been included in the ITS Section 1.1 SDM definition tocompensate for control rods which are not capable of being fully inserted; and b. This change adds specific details defining the most reactive shutdown condition towhich the SDM is analyzed; i.e., the reactor is xenon free and the moderatortemperature is 68°F.1.13.3.A.1, 4.3.A.1 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 2 of 67 ATTACHMENT 2 1.0 A.5CTS 1.0.D includes the definiti on of Immediate. It states "Immediate means that therequired action will be initiated as soon as pr acticable considering the safe operation of the unit and the importance of the required action." The ITS includes Section 1.3,"Completion Times," which describes the meaning of the term "immediately" when usedas a Completion Time. It states "When "immediately" is used, the Required Actionshould be pursued without delay and in a controlled manner." This changes the CTS by deleting the definition of "Immediate" but adds a description to the ITS of "immediately"when used as a Completion Time.1.31.0.D 1.0 A.6CTS 1.0.E defines Instrument Functional Test as "the injection of a simulated signal intothe primary sensor to verify proper instrum ent channel response, al arm, and/or initiatingaction." ITS Section 1.1 defines CHANNEL FUNCTIONAL TEST as "the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verifyOPERABILITY of all devices in the channel required for channel OPERABILITY" and states that the test "may be performed by means of any series of sequential,overlapping, or total channel steps." This results in a number of changes to the CTS. The addition of use of an "actual" signal is discussed in DOC L.2 while the allowance to inject the signal "as close to the sensor as practicable" in lieu of "into" the sensor is discussed in DOC L.3.a. The CTS definition states that the Instrument Functional Test shall verify "proper instrument channel response, al arm, and/or initiating action." The ITS definition statesthat the CHANNEL FUNCTIONAL TEST shall verify "OPERABILITY of all devices in thechannel required for channel OPERABILITY."b. The ITS definition states "The CHANNEL FUNCTIONAL TEST may be performed bymeans of any series of sequential, overlapping, or total channel steps." The CTS definition does not in clude this statement.1.11.0.E 1.0 A.7CTS 1.0.F defines an Instrument Calibration as "the adjustment of an instrument signaloutput so that it corresponds, within acceptable range, accuracy, and response time to aknown value(s) of the parameter which t he instrument monitors. Calibration shall encompass the entire instrument including actuation, alarm or trip. Response time is not part of the routine instrument calibration but will be checked once per cycle." ITS1.0 defines a CHANNEL CALIBRATION as "the adjustment, as necessary, of thechannel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and theCHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistancetemperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of s ensor behavior and normal calibration of the remaining1.11.0.F Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 3 of 67 ATTACHMENT 2adjustable devices in the channel. The CHANNEL CALIBRATION may be performed bymeans of any series of sequential, overlapping, or total channel steps." This results in anumber of changes to the CTS.a. The CTS definition states "Calibra tion shall encompass the entire instrument including actuation, alarm or trip." The ITS definition states "The CHANNELCALIBRATION shall encompass all devic es in the channel required for channelOPERABILITY."b. The ITS definition states that the CHANNEL CALIBRATION shall encompass the"CHANNEL FUNCTIONAL TEST." The CTS def inition does not incl ude this statement.c. The ITS definition adds the statement "Calibration of instrument channels withresistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sens or behavior and normal calibration of the remaining adjustable devices in the channel." This allowance is not specifically stated inthe CTS definition.d. The ITS definition states "The CHANNEL CALIBRATION may be performed bymeans of any series of sequential, overlapping, or total channel steps." The CTS definition does not in clude this statement.e. The CTS definition states t hat the response time is not part of the routine instrumentcalibration but is checked once per cycle. The ITS definition does not include this statement.
1.0 A.8CTS Section 1.0 includes the following definitions:
1.0.G, Limiting Conditions for Operation (LCO);1.0.I, Limiting Safety System Setting (LSSS);
1.0.M, Operating; 1.0.N, Operating Cycle; 1.0.P, Primary Containment Integrity; 1.0.Q, Protective Instrumentation Logic Definitions;
1.0.R, Rated Neutron Flux;1.0.T, Reactor Coolant System Pre ssure or Reactor Vessel Pressure; 1.0.U, Refueling Operat ion and Refueling Outage;1.0.V, Safety Limit; 1.0.W, Secondary Containment Integrity;1.0.Z, Simulated Automatic Actuation;N/A1.0.G, 1.0.I, 1.0.M, 1.0.N, 1.0.P, 1.0.Q, 1.0.R, 1.0.T, 1.0.U, 1.0.V, 1.0.W, 1.0.Z, 1.0.AA, 1.0.AI, Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 4 of 67 ATTACHMENT 21.0.AA, Transition Boiling; 1.0.AI, Purging;
1.0.AJ, Venting; and 1.0.AR, Allowable Value.The ITS does not use this terminology and ITS Section 1.1 does not contain thesedefinitions. This changes the CTS by delet ing definitions that are not necessary.
1.0.AJ, 1.0.AR 1.0 A.9The CTS 1.0.J definition of Minimum Critical Power Ratio (MCPR) states that "Theminimum critical power ratio is the value of critical power ratio associated with the mostlimiting assembly in the reactor core." In addition, the CTS 1.0.J definition states thatthe "Critical power ratio (CPR) is the ratio of that power in a fuel assembly which iscalculated by the GEXL correlation to cause some point in the assembly to experienceboiling transition to the actual assembly operating power." ITS Section 1.1 definition ofMCPR states that "The MCPR shall be the smallest critical power ratio (CPR) that existsin the core for each class of fuel. The CPR is that power in the assembly that iscalculated by application of t he appropriate correlation(s) to cause some point in theassembly to experience boiling transition, divided by the actual assembly operatingpower." This changes the CTS definition of MCPR by specifying a separate MCPR is applicable to "each class of fuel" instead of a single MCPR is associated with the "mostlimiting assembly" and removes the explicit correlation that must be used to calculate CPR.1.11.0.J 1.0 A.10The CTS 1.0.L definition of Operable requires a system, subsystem, train, component, or device to be capable of performing its "specified function(s)," and requires allnecessary support systems that are required for the system, subsystem, train, component, or device to perform its "functi on(s)" also be capable of performing theirrelated support function(s). The ITS Section 1.1 definition of OPERABLE-OPERABILITY requires the system, subsyste m, division, component, or device to be capable of performing the "specified safety function(s)," and requires all necessarysupport systems that are required for the system, subsystem, division, component, ordevice to perform its "specified safety functi on(s)" to also be capable of performing theirrelated support functions. This changes the CTS by altering the requirement of thesystem, subsystem, etc., to be able to perfo rm "specified function(s)" or "function(s)" toa requirement to be able to perform "specified safety function(s)."1.11.0.L Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 5 of 67 ATTACHMENT 2 1.0 A.11The CTS 1.0.L definition of Operable requires that all necessary normal "and"emergency electrical power sources be available for the system, subsystem, train,component, or device to be OPERABLE. The ITS Section 1.1 definition of OPERABLE-OPERABILITY requires all necessary normal "or" emergency electrical power beavailable for the system, subsystem, etc. This changes the CTS definition of Operableby allowing a device to be considered OPERABLE with either normal or emergencypower available.1.11.0.L 1.0 A.12CTS Section 1.0 provides definitions for Pressure Boundary Leakage (CTS 1.0.AB),Identified Leakage (CTS 1.0.
AC), Unidentified Leakage (CTS 1.0.AD), and TotalLeakage (CTS 1.0.AE). ITS Section 1.1 incl udes these requirement s in one definition called LEAKAGE and includes four categorie s: identified L EAKAGE; unidentified LEAKAGE; total LEAKAGE; and pressure boundary LEAKAGE. This changes the CTSby incorporating the four s eparate definitions into a single definition with no technical changes.1.11.0.AB, 1.0.AC, 1.0.AD, 1.0.AE 1.0 A.13CTS 1.0.AB states "Pressure boundary l eakage shall be the leakage through a non-isolable fault in the reactor coolant system pressure boundary." ITS Section 1.1 statespressure boundary LEAKAGE is the LEAKAGE th rough a nonisolable fault in a ReactorCoolant System (RCS) "component body, pipe wall, or vessel wall." This changes theCTS by explicitly stating the components of the RCS pressure boundary.1.11.0.AB 1.0 A.14ITS Section 1.1 provides definitions of ACTIONS, AVERAGE PLANAR LINEAR HEATGENERATION RATE (APLHGR), LINEAR HEAT GENERATION RATE (LHGR), LOGICSYSTEM FUNCTIONAL TEST, STAGGERED TEST BASIS, THERMAL POWER, and TURBINE BYPASS SYSTEM RESPONSE TIME. These terms are not defined in the CTS. This changes the CTS by adding the above terms.1.1N/A 1.0 A.15ITS Sections 1.2, 1.3, and 1.4 contain information that is not in the CTS. This change tothe CTS adds explanatory information on ITS usage that is not applicable to the CTS. The added sections are:
Section 1.2 - Logical Connectors Section 1.2 provides s pecific examples of t he logical connectors "AND" and "OR" andthe numbering sequence associated with their use.Section 1.3 - Completion Times Section 1.3 provides guidanc e on the proper use and interpretation of CompletionTimes. The section also provides spec ific examples that aid in the use andunderstanding of Completion Times.
1.2, 1.3, 1.4 N/A Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 6 of 67 ATTACHMENT 2Section 1.4 - Frequency Section 1.4 provides guidanc e on the proper use and interpretation of SurveillanceFrequencies. The section also provides s pecific examples that aid in the use andunderstanding of Surveillance Frequency.
1.0 A.16CTS 3.1.A states that the time from initiation of any Reactor Protection System (RPS) channel trip to the de-energization of the scram pilot valve solenoids shall not exceed 50milliseconds. ITS Section 1.1 includes a definition of REACTOR PROTECTIONSYSTEM (RPS) RESPONSE TIME. The ITS definition is consistent with the CTS 3.1.A, but includes the statement "The response time may be measured by means of any series of sequential, overlapping, or total steps so that the ent ire response time ismeasured." This changes the CTS by addi ng the sentence associated with the mannerof testing. Any change to the response va lue of 50 milliseconds is discussed in theDiscussion of Changes for ITS 3.3.1.1.1.13.1.A 1.0 A.17These changes to CTS 1.0.U are provided in the Monticello ITS consistent with theTechnical Specifications Change Request s ubmitted to the NRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, these changes are administrative.None1.0.U 2.0 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).2.02 3.0 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.04 3.0 A.2ITS LCO 3.0.1 and LCO 3.0.2 are added to the CTS to provide guidance regardingLCOs and ACTIONS. ITS LCO 3.0.1 states "LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO3.0.7." ITS LCO 3.0.2 states "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of thespecified Completion Time(s), completion of the Required Action(s) is not required,unless otherwise stated." The changes to the CTS are as follows:CTS 3/4.0 does not include any general LCO/ACTION guidance requirements. However, in general the CTS LCOs require either the equipment to be OPERABLE or parameters to be met during the specified conditions. This is consistent with ITS LCO LCO 3.0.1, LCO 3.0.2 N/A Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 7 of 67 ATTACHMENT 2 3.0.1. In addition, if the LCO is not met, the applicable CTS Specif ication provides theappropriate actions to take. ITS LCO 3.0.2 states, in part, "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met." Thisstatement is consistent with the current application of CTS actions. The secondsentence of ITS LCO 3.0.2 states, in part, " If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required." Th is statement is also consistent with the current applicationof the CTS actions. The second sentence of ITS LCO 3.0.2 includes the phrase,"unless otherwise stated" at the end of the sentence. There are some ITS ACTIONS,which must be completed, even if the LCO is met or is no longer applicable. While thisis a new requirement, the technical aspec ts of these changes are discussed in theappropriate ITS Specifications.
LCO 3.0.2 includes exceptions for LCO 3.
0.5 and LCO 3.0.6.
LCO 3.0.5 is a newallowance, for a system returned to servic e under administrative control to perform the testing required to demonstrate OPERABILITY, that takes exception to the ITS LCO3.0.2 requirement. LCO 3.0.6 is a new allowance that takes exception to the ITS LCO 3.0.2 requirement to take the Required Actions of a supported system LCO when theinoperability is only associated with a support system LCO. These exceptions are included in LCO 3.0.2 to avoid conflicts between the applicability requirements.ITS LCO 3.0.1 includes a stat ement that exceptions to ITS LCO 3.0.1 are provided inLCO 3.0.2 and LCO 3.0.7. ITS LCO 3.0.2 de scribes the appropriate actions to be takenwhen ITS LCO 3.0.1 is not met. LCO 3.0.7 describes Test Exception LCOs, which are exceptions to other LCOs.
3.0 A.3ITS LCO 3.0.6 is added to the CTS to provide guidance regarding the appropriateACTIONS to be taken when a single inoperability (a support system) also results in theinoperability of one or more related systems (supported system(s)).
LCO 3.0.6 states"When a supported system LCO is not met solely due to a support system LCO not
being met, the Conditions and Required Actions associated with this supported systemare not required to be entered. Only the support system LCO ACTIONS are required tobe entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specificati on 5.5.10, "SafetyFunction Determination Program (SFDP)." If a loss of safety function is determined toexist by this program, the appropriate C onditions and Required Actions of the LCO inwhich the loss of safety function exists are required to be entered. When a supportsystem's Required Action directs a supported system to be declared inoperable ordirects entry into Conditions and Required Actions for a supported system, theapplicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.6N/A Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 8 of 67 ATTACHMENT 2 LCO 3.0.2." In the CTS, based on the intent and interpretation provided by the NRC over the years, there has been an ambiguous approach to the combined support/supportedinoperability.Some of this history is summarized below:
Guidance provided in the June 13, 1979, NRC memorandum from Brian K. Grimes (Assistant Director for Engineering and Projects) to Samuel E. Bryan (Assistant Directorfor Field Coordination) would indicate an in tent/interpretation consistent with theproposed LCO 3.0.6, without the necessity of also requiring additional ACTIONS. Thatis, only the inoperable support system ACTIONS need be taken.Guidance provided by the NRC in its April 10, 1980, letter to all Licensees, regarding thedefinition of OPERABILITY and its impact as a support system on the remainder of theCTS, would indicate a similar philosophy of not taking ACTIONS for the inoperable supported equipment. However, in this case , additional actions (similar to the proposedSafety Function Determination Program actions) were addressed and required.
Generic Letter 91-18 and a plain-English reading of the CTS provide an interpretationthat inoperability, even as a result of a Technical Specification support systeminoperability, requires all associated ACTIONS to be taken.Certain CTS contain ACTIONS such as "D eclare the {supported system} inoperable andtake the ACTIONS of {its Specification}." In many cases, the supported system wouldlikely already be considered inoperable. The imp lication of this pres entation is that theACTIONS of the inoperable supported system would not have been taken without the specific direction to do so.Considering the history of misunderstandings in this area, the BWR/4 ISTS,NUREG-1433, Rev. 3, was developed with Industry input and approval of the NRC toinclude LCO 3.0.6 and a new program, Spec ification 5.5.10, "Safety FunctionDetermination Program (SFDP)." This c hange is acceptable since its function is toclarify existing ambiguities and to maintain actions within the realm of previousinterpretations. This change is designat ed as administrative because it does nottechnically change the Tec hnical Specifications.
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 9 of 67 ATTACHMENT 2 3.0 A.4ITS LCO 3.0.7 is added to the CTS. LCO 3.
0.7 states "Special Operations LCOs inSection 3.10 allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, allother TS requirements remain unchanged. Compliance with Test Exception LCOs isoptional. When a Special Operations LCO is desired to be met but is not met, theACTIONS of the Special Operations LCO shall be met. When a Special OperationsLCO is not desired to be met, entry into a MODE or other specified condition in theApplicability shall be made in accordance with the other applicable Specifications." Thischanges the CTS by adding specific guidanc e concerning the use of special testexception type LCOs.LCO 3.0.7N/A 3.0 A.5CTS 4.0.A states "The surveillance requirem ents of this section shall be met. Each surveillance requirement shall be performed at the specified times except as allowed inB and C below." CTS 4.0.C states, in part, "W henever the plant condition is such that asystem or component is not required to be operable the surveillance testing associatedwith that system or component may be discontinued." CTS 4.0.
D states "If it isdiscovered that a surveillance was not performed within the extended time intervalallowed by 4.0.B, then the affected equipment shall be declared inoperable." ITS SR 3.0.1 states "SRs shall be me t during the MODES or other specified conditions in theApplicability for individual LCOs, unless otherwi se stated in the SR. Failure to meet aSurveillance, whether such failure is experienced during the performance of theSurveillance or between performances of the Su rveillance, shall be failure to meet theLCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits." The changesto the CTS are:CTS 4.0.A states, in part, "The surveillance r equirements of this section shall be met." CTS 4.0.A also states, in part, "Each surve illance requirement shall be performed at thespecified times except as allowed in . . . C below." CTS 4.0.C states "Whenever theplant condition is such that a system or component is not required to be operable thesurveillance testing associated with that system or component may be discontinued." The first sentence of ITS SR 3.0.1 states "SRs shall be met during the MODES or otherspecified conditions in the Applicability for individual LCOs, unless otherwise stated inthe SR." This changes the CTS by combining the two CTS requirements into a single cogent requirement.The second sentence of ITS SR 3.0.1 includes the statement, "Failure to meet aSurveillance, whether such failure is experienced during the performance of theSurveillance or between performances of the Su rveillance, shall be failure to meet theSR 3.0.14.0.A, 4.0.C, 4.0.D Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 10 of 67 ATTACHMENT 2LCO." This changes the CTS by adding the clarification "whether such failure is experienced during the performanc e of the Surveillance or between performances of the Surveillance."ITS 4.0.A states, in part, "Each surveill ance requirement shall be performed at thespecified times except as allowed in B - below." CTS 4.0.D states "If it is discoveredthat a surveillance was not performed within the extended time interval allowed by 4.0.B, then the affe cted equipment shall be declared inoperable." The third sentence ofITS SR 3.0.1 states "Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3." This changes theCTS by replacing the CTS phrases "except as allowed in B ... below" and "within the extended time interval allowed by 4.0.B" with the ITS phrase "within the specifiedFrequency" and the CTS statement "then t he affected equipment shall be declaredinoperable" with the ITS statement "shall be fa ilure to meet the LCO." In addition, areference to ITS SR 3.0.3 (CTS 4.0.E) has been added. The CTS is also changed bycombining CTS 4.0.A and CTS 4.0.D.
3.0 A.6CTS 4.0.B states, in part, "Specific time intervals between tests may be extended up to25% of the surveillance interval." ITS SR 3.0.2 states "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified inthe Frequency, as measured from the previous performance or as measured from thetime a specified condition of the Frequency is met. For Frequencies specified as"once," the above interval extension does not apply. If a Completion Time requires periodic performance on a "once per . . ." basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications." This results in several changes to the CTS.ITS SR 3.0.2 adds to the CTS "For Frequencie s specified as 'onc e,' the above intervalextension does not apply." This change is described in DOC M.2.ITS SR 3.0.2 adds to the CTS "If a Completion Time requires periodic performance on a"once per . . ." basis, the above Frequency ex tension applies to each performance afterthe initial performance." Th is is described in DOC L.3.CTS 4.0.B states, in part, "Specific time intervals between tests may be extended up to25% of the surveillance interval." ITS SR 3.0.2 states, in part, "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the intervalspecified in the Frequency." This change to the CTS is made to be consistent with theITS terminology and to clarify the concept of the specified SR Frequency being met.SR 3.0.24.0.B Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 11 of 67 ATTACHMENT 2ITS SR 3.0.2 is also more specific regar ding the start of the Frequency by stating "as measured from the previous performance or as measured from the time a specifiedcondition of the Frequency is met." This direction is consistent wi th the current use andapplication of the Tec hnical Specifications.ITS SR 3.0.2 adds to the CTS the statement "Exceptions to this Specification are stated in the individual Specifications." 3.0 A.7These changes to CTS 4.0.B are provided in the Monticello ITS consistent with theTechnical Specifications Change Request s ubmitted to the NRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, these changes are administrative.None4.0.B 3.1.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.1.13/4.3.A.1, 3.3.G 3.1.1 A.2These changes to CTS 3.3.G are provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-05-013, from Thomas J. Palm isano (NMC) to USNRC, dated April 12, 2005.
As such, these changes are administrative.3.1.1 ACTIONS A, B, C, D, and E 3.3.G.1, 3.3.G.2 3.1.1 A.3CTS 3.3.G.2 requires the immediate suspension of core alterations except for "fuelassembly removal" and to "immediately initiate action to fully insert all insertable control rods in core cell containing one or more fuel assemblies" if CTS 3.3.A is not met whenthe reactor mode switch is in the Refuel position. ITS 3.1.1 ACTION E covers the condition for SDM not met in MODE 5, and in part, requires the immediate suspensionof CORE ALTERATIONS except for "control rod insertion and fuel assembly removal" and requires the immediate initiation of action to fully insert all insertable control rods in core cells containing one or more fuel assemblies. This changes the CTS by clarifyingthat CORE ALTERATIONS that involve "the in sertion of control r ods" are also excepted.3.1.1 ACTION E3.3.G.2 3.1.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.1.23/4.3.E 3.1.2 A.2CTS 4.3.E states, in part, the reactivity anomaly Surveillance must be performed"During the startup test program." ITS SR 3.1.2.1 does not include this requirement. This changes the CTS by deleting the require ment to perform this test "During the startup test program."None4.3.E Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 12 of 67 ATTACHMENT 2 3.1.3 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.1.33/4.3.A.2, 3/4.3.B.1, 3.3.G 3.1.3 A.2CTS 3/4.3.A.2 provides requi rements for stuck control rods. CTS 3/4.3.B.1 providesrequirements for control rod coupling. ITS 3.1.3 provides require ments for each controlrod. ITS LCO 3.1.3 states "Each control rod shall be OPERABLE." This changes theCTS by combining the OPERABILITY r equirements for control rods into one Specification and adding an exp licit statement concerning control rod OPERABILITY.
Additional aspects of control rod OPERABILITY are also added in accordance with DOC M.4.3.1.33/4.3.A.2, 3/4.3.B.1 3.1.3 A.3CTS 3.3.A.2.(a) states that t he directional control valves fo r inoperable control rods shallbe disarmed. CTS 3.3.B.1 stat es that each control rod s hall be coupled to its drive orcompletely inserted and the directional control valves disarmed. These CTS Actions donot limit the number of control rods to which these Actions apply. ITS 3.1.3 ACTIONSNote states "Separate Condition entry is allowed for each control rod." This changesthe CTS by adding an explicit Note for separate condition entry for each control rod.3.1.3 ACTIONS Note3.3.A.2.(a), 3.3.B.1 3.1.3 A.4CTS 3.3.A.2.(a) states, in part, "The directional control valves for inoperable control rodsshall be disarmed." CTS 3.3.B.
1 states, in part, "Each contro l rod shall be coupled to itsdrive or completely inserted and the directional control valves disarmed." Thesecompensatory actions are covered in ITS 3.1.3 ACTION A for stuck rods and ITS 3.1.3ACTION C for coupling inoperabilities. In addition, these ITS 3.1.3 ACTIONS include aNote that states rod worth minimizer (RWM) may be bypassed as allowed by LCO 3.3.2.1, "Control Rod Block In strumentation," if required, to allow continued operation. This changes the CTS by adding these clarification Notes.3.1.3 ACTION A Note, 3.1.3 Required Action
C.1 Note 3.3.A.2.(a), 3.3.B.1 3.1.3 A.5CTS 3.3.A.2 does not explicitly state when the stuck c ontrol rod requirements arerequired to be met. However, CTS 3.3.A.2.(b) states that the reactor should be broughtto hot shutdown under certain situations. ITS 3.1.3 is applicable in MODES 1 and 2. This changes the CTS by explicitly stating the Applicability.3.1.3 Applicability3.3.A.2, 3.3.A.2.(b) 3.1.3 A.6These changes to CTS 3.3.G are provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-05-013, from Thomas J. Palm isano (NMC) to USNRC, dated April 12, 2005.
As such, these changes are administrative.3.1.3 ACTION E3.3.G.1 3.1.4 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.1.43/4.3.C, 3.3.G Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 13 of 67 ATTACHMENT 2 3.1.4 A.2When the scram time requirements of CTS 3.3.C are not met, CTS 3.3.G.1 requires theunit to be in cold shutdown (MODE 4) within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. ITS 3.1.4 ACTION A only requires a shutdown to MODE 3. This changes the CTS by stating the unit must be shut down to MODE 3 instead of to MODE 4. The change to the time allowed to reachthe required shutdown conditi on is discussed in DOC M.3.3.1.4 ACTION A3.3.G.1 3.1.4 A.3These changes to CTS 3.3.G are provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-05-013, from Thomas J. Palm isano (NMC) to USNRC, dated April 12, 2005.
As such, these changes are administrative.
3.1.4ACTION A 3.3.G.1 3.1.5 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.1.53/4.3.D, 3.3.G 3.1.5 A.2CTS 3.3.D states, in part, that if "a" control rod with an inoperable accumulator is inserted full-in and either its directional control valves are electrically disarmed or ishydraulically isolated, it shall not be c onsidered to have an inoperable accumulator. CTS 3.3.D.1 states, in part, that "a" rod accumulator may be inoperable provided that noother control rod within two control rod cells in any direction has an inoperable accumulator or directional control valve are electrically disarmed while in a non-fullyinserted position. These CTS Actions do not limit the number of accumulators to whichthese Actions apply. ITS 3.1.5 ACTIONS Note allows separate Condition entry for eachcontrol rod scram accumulator. This changes the CTS by adding an explicit Note forseparate Condition entry for each control rod scram accumulator.3.1.5 ACTIONS Note3.3.D, 3.3.D.1 3.1.5 A.3These changes to CTS 3.3.G are provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-05-013, from Thomas J. Palm isano (NMC) to USNRC, dated April 12, 2005.
As such, these changes are administrative.
3.1.5ACTION D 3.3.G.1 3.1.6 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.1.63.3.B.3.(a), 3.3.G 3.1.6 A.2CTS 3.3.B.3.(a) states "Control rod withdrawal sequences shall be established so thatthe maximum calculated reactivity that could be added by dropout of any increment ofany one control blade will not make the core mo re than 1.3% Dk supercritical." Implicit in this requirement is that once the control rod withdrawal sequence is established it willbe maintained. ITS LCO 3.1.6 states "OPERABLE control rods shall comply with the requirements of the banked position withdrawal sequence (BPWS)." This changes theCTS by requiring a control rod withdrawal sequence to be continuously met by clarifyingthe actual control rod withdrawal sequence being used at Monticello. The change thatLCO 3.1.63.3.B.3.(a)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 14 of 67 ATTACHMENT 2relocates the details of the system design of control rod withdrawal sequences is discussed in DOC LA.1.
3.1.6 A.3These changes to CTS 3.3.G are provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-05-013, from Thomas J. Palm isano (NMC) to USNRC, dated April 12, 2005.
As such, these changes are administrative.3.1.6 ACTIONS A and B3.3.G.1 3.1.7 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.1.73/4.4 3.1.7 A.2CTS 3.4.A.1 requires the Standby Liquid Control (SLC) System to be OPERABLE at alltimes when fuel is in the reactor and the reactor is not shut down by control rods. ITSLCO 3.1.7 requires the SLC System to be OPERABLE in MODES 1 and 2. Thischanges the CTS by explicitly stating the applicable MODES in which the SLC System must be OPERABLE.3.1.7 Applicability3.4.A.1 3.1.7 A.3CTS 4.4.A.1 specifies thos e Surveillance Requirements that must be performed "Atleast once per quarter." CTS 4.4.A.1 only requires the performance of a SLC Systemflow test. However, CTS 4.4.A.1 also states that the SLC System flow test must beperformed "in accordance with the Inservice Testing Program." ITS SR 3.1.7.7 requires the same test to be performed "In accordance with the Inservice Testing Program." Thischanges the CTS by deleting the duplicative information associated with the testingFrequency.SR 3.1.7.74.4.A.1 3.1.7 A.4CTS 4.4.B.1 requires a dete rmination of boron enrichment, but does not specify theactual limit. The design limit for Monticello is 55.0 atom percent, as stated in CTSFigure 3.4-1. ITS SR 3.1.7.10 requires verification that t he sodium pentaborate enrichment is > 55.0 atom percent. This changes the CTS by specifying the actual limit in the sodium pentaborate enrichm ent verification Surveillance.SR 3.1.7.104.4.B.1, Figure 3.4-1 3.1.7 A.5CTS 4.4.A.2 requires the performance of a SLC System test at least once "during eachoperating cycle." ITS SR 3.1.7.8 requires performance of an SLC test every "24months" on a STAGGERED TEST BASIS. This changes the CTS by changing theFrequency from "during each operating cycle" to "24 months."SR 3.1.7.84.4.A.2 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 15 of 67 ATTACHMENT 2 3.1.7 A.6CTS 4.4.A.2.a requires the performance of a SLC subsystem test to verify flow can be injected into the reactor vessel. During this test SLC pump capacity must be verified. ITS SR 3.1.7.8 requires the performance of the same test; however, the requirement toverify pump capacity has not been included. This changes the CTS by deleting thespecific requirement to verify SLC pump capacity during the SLC subsystem reactor vessel injection test.None4.4.A.2.a 3.1.8 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.1.83/4.3.F 3.1.8 A.2CTS 3.3.F.2.b states, in par t, "Maintaining the inoperable va lves(s), or the associated redundant valve(s), in the closed position" if the inoperable valve is not restored toOPERABLE status in 7 days. ITS 3.1.8 Requi red Actions A.1 and B.1 state "Isolate theassociated line." This changes the CTS by simplifying the Required Action by requiring isolation of the associated line instead of explicitly stating wh ich valves to use to perform the isolation (i.e., inoperable valve(s) or the associated redundant valves(s)).
3.1.8 Required Actions A.1 and B.13.3.F.2.b 3.1.8 A.3CTS 3.3.F.2 states, in part, "If a or b abov e cannot be met, at least all but one operable control rods (not including rods removed per specification 3.
10.E or inoperable rodsallowed by 3.3.A.2) shall be fully inserted." ITS 3.1.8 ACTION C, under the same conditions requires the unit to be in MODE 3. This changes the CTS by more clearly defining the all rods in condition as MODE 3.3.1.8 ACTION C3.3.F.2 3.1.8 A.4CTS 3.3.F states, in part, "verify the scr am discharge volume vent and drain valvesclose within 30 seconds after receipt of a reactor scram signal and open when the scram is reset." ITS SR 3.1.8.3 requires the same test; however, the proposed Surveillance states that the reactor scram signal may be an "actual or simulated" signal. This changes the CTS by clarifying that the reactor scram signal may be either an"actual or simulated" reactor scram signal.SR 3.1.8.33.3.F 3.1.8 A.5CTS 4.3.F requires a SDV vent and drai n valve test to be performed "Once peroperating cycle." ITS SR 3.1.8.3 requires performance of an SDV vent and drain valvetest every "24 months." This changes the CTS by changing the Frequency from "Onceper operating cycle" to "24 months."SR 3.1.8.34.3.F 3.2.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.2.13/4.11.A Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 16 of 67 ATTACHMENT 2 3.2.1 A.2CTS 3.11.A states that the APLHGR should not exceed limits during "power operation," which is defined in CTS 1.0.O as "above 1% rated thermal power." However, CTS3.11.A only states to reduce thermal power to "less than 25%" if the APLHGR LCO is being exceeded and the APLHGRs are not returned to within limits within the specifiedtime. ITS LCO 3.2.1 is applicable at THERMAL POWER > 25% RTP. ITS 3.2.1ACTION B requires a THERMAL POWER reduction to < 25% RTP if the APLHGR(s) are not restored to within limits within the specified time limit of ACTION A. This changes the CTS by changing the Applicability from > 1% rated thermal power to >
25%RTP.3.2.1 Applicability3.11.A 3.2.1 A.3CTS 3.11.A states "Surveillance and corres ponding action shall continue until reactoroperation is within the prescribed limits." ITS 3.2.1 does not include this statement. This changes the CTS by deleting this statement.None3.11.A 3.2.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.2.23/4.11.C 3.2.2 A.2CTS 3.11.C does not state when the MCPR LCO is required to be met, however CTS 3.11.C states "reduce thermal power to less than 25%" if the limiting value for MCPR is being exceeded and the MCPR is not returned to within limits within the specified time. ITS LCO 3.2.2 is applicable at THERMAL POWER > 25% RTP. ITS 3.2.2 ACTION Brequires a THERMAL POWER reduction to < 25% RTP if the MCPR(s) are not restoredto within limits within specified time limit of ACTION A. This changes the CTS by clearlyspecifying the Applicability as > 25% RTP.3.2.2 Applicability3.11.C 3.2.2 A.3CTS 3.11.C states "Surveillance and corres ponding action shall continue until reactoroperation is within the prescribed limits." ITS 3.2.2 does not include this statement. This changes the CTS by deleting this statement.None3.11.C 3.2.3 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.2.33.11.B Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 17 of 67 ATTACHMENT 2 3.2.3 A.2CTS 3.11.B states that the LHGR should not exceed limits during "power operation,"which is defined in CTS 1.0.O as "above 1% rated thermal power." However, CTS3.11.B only states to reduce THERMAL POWER to "less than 25%" if the limiting values for LHGR is being exceeded and the LHGRs are not returned to within limits within thespecified time. ITS LCO 3.2.3 is applicable at THERMAL POWER > 25% RTP. ITS3.2.3 ACTION B requires a THERMAL POWER reduction to < 25% RTP if the LHGR(s)are not restored to within limits within the specified time limit of ACTION A. Thischanges the CTS by changing the Applicability from > 1% RATED THERMAL POWER
> 25% RTP.3.2.3 Applicability3.11.B 3.2.3 A.3CTS 3.11.B states "Surveillance and corres ponding action shall continue until reactoroperation is within the prescribed limits." ITS 3.2.3 does not include this statement. This changes the CTS by deleting this statement.None3.11.B 3.3.1.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.1.13.1.A, 3.1.B, 4.1.A,Tables 3.1.1, 4.1.1, and
4.1.2 3.3.1.1 A.2CTS 3.1.A specifies the applicability requirements for the RPS InstrumentationFunctions based on "each position of the reactor mode switch as indicated in Table3.1.1." ITS Table 3.3.1.1-1 either specifies the Applicable MODES as defined in ITS Section 1.1 or other specified conditions. This changes the CTS by using the definedterm of MODES in the Applicability, w henever possible. Changes to the actualrequirements for when the RPS instrum entation must be OPERABLE are discussedbelow in other DOCs.Table 3.3.1.1-13.1.A 3.3.1.1 A.3CTS 3.1.B states "Upon discovery that t he requirements for the number of operable oroperating trip systems or instrument channels are not satisfied, action shall be initiatedas follows:" ITS 3.3.1.1 ACTIONS Note states "Separate Condition entry is allowed foreach channel." This changes the CTS by clarifying that separate Condition entry isallowed for each channel.3.3.1.1 ACTIONS Note3.1.B 3.3.1.1 A.4CTS Table 3.1.1 Trip Function 8.a requires two "East" Scram Discharge Volume High Level channels to be OPERABLE in each trip system while CTS Table 3.1.1 TripFunction 8.b requires two "West" Scram Discharge Volume High Level channels to be OPERABLE in each trip system. ITS Table 3.3.1.1-1 Function 7.a requires twoResistance Temperature Detector channels to be OPERABLE in each trip system whileFunction 7.b requires two Float Switch channels to be OPERABLE in each trip system. This changes the CTS by specifying the "ty pe of channels" instead of the "location" of the channels.Table 3.3.1.1-1Functions 7.a and 7.bTable 3.1.1 TripFunctions 8.a and 8.b Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 18 of 67 ATTACHMENT 2 3.3.1.1 A.5CTS Table 3.1.1 requires the Main Steamline Isolation Valve Closure Trip Function (TripFunction 10) to be OPERABLE when the reactor mode switch is in the Refuel, Startup,and Run positions. However, CTS Table 3.1.1 Note (b) states that the MSIV closurescram function may be bypassed in the Refuel and Startup modes if reactor pressure isbelow 600 psig. Furthermore, CTS Table 3.1.1 Note (3) states that the only RPS TripFunctions that are required to be OPERABLE when in the refueling mode with thereactor subcritical and reactor water temperature less than 212°F are Mode Switch inShutdown, Manual Scram, High Flux IRM (i.e., Neutron Flux IRM High - High andNeutron Flux IRM Inoperative), and Scram Discharge Volume High Level. ITS Table 3.3.1.1-1 Function 5 requires the Main Steam Isolation Valve - Closure Functionto be OPERABLE in MODE 1 and MODE 2 with reactor pressure >
600 psig (as statedin ITS Table 3.3.1.1-1 Note c). This changes the CTS by clearly st ating the Applicability of the Main Steamline Isolation Valve Closure Trip Function.Table 3.3.1.1-1 Function 5 including Note cTable 3.1.1 TripFunction 10, including
Notes (b) and (3) 3.3.1.1 A.6CTS Table 3.1.1 Note (1) states that a channel may be placed in an inoperable statusfor up to 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> for required surveillance without placing the trip system in the tripped condition provided "that at least one other operable channel in the same trip system is monitoring that parameter." ITS 3.3.1.1 Surveillance Requirements Table Note 2 statesthat when a channel is placed in an inoperable status solely for performance of requiredSurveillances, entry into associated Conditions and Required Actions may be delayed
for up to 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> provided "the associated Function maintains RPS trip capability." Thischanges the CTS by replacing the words "at least one other operable channel in thesame trip system is monitoring that parameter" with "the associated Function maintainsRPS trip capability." 3.3.1.1 Surveillance Requirements Note 2Table 3.1.1 Note (1) 3.3.1.1 A.7CTS Table 3.1.1 requires the Turbine Control Valve Fast Closure and Turbine StopValve Closure Trip Functions (Trip Functions 11 and 12) to be OPERABLE when the reactor mode switch is in the Run position. However, CTS Tabl e 3.1.1 f ootnote **.d states that these scram functions may be bypassed when the reactor thermal power is <45%. The Note also provides a parenthetical reference that 45% rated thermal power isequivalent to 798.75 MWt. CTS Table 3.1.
1 Required Condition D also provides asimilar parenthetical reference. ITS Table 3.3.1.1-1 Functions 8 and 9 specify theApplicability to be > 45% RTP and ITS 3.3.1.1 ACTION E requires the unit to be <
45%RTP. This changes the CTS by deleting the actual thermal power level (798.75 MWt)from the Applicability and Action.3.3.1.1 ACTION E, Table3.3.1.1-1 Functions 8
and 9Table 3.1.1 TripFunctions 11 and 12
including footnote **.d, Table 3.1.1 Required
Condition D 3.3.1.1 A.8When the requirements of CT S 3.1.B are not met for the Mode Switch in Shutdown,Manual Scram, Neutron Flux IRM High - High, Neutron Flux IRM Inoperable, HighReactor Pressure, High Drywell Pressure, Reactor Low Water Level, and ScramDischarge Volume High Level (East and West) Trip Functions (CTS Table 3.1.1 Trip Functions 1, 2, 3.a, 3.b, 5, 6, 7, 8.a, and 8.b), CTS Table 3.1.1 (Required Condition A)requires all OPERABLE control rods to be fully inserted. Under similar conditions in the3.3.1.1 ACTION GTable 3.1.1 RequiredCondition A for Table 3.1.1 Trip Functions 1, 2, 3.a, 3.b, 5, 6, 7, 8.a, and 8.b Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 19 of 67 ATTACHMENT 2ITS (i.e., the Required Actions and associated Completion Times of ACTIONS A, B, andC are not met) and when the unit is in MODE 1 or 2, ITS 3.3.1.1 ACTION G will requirethe unit to be in MODE 3. This changes the CTS by specifying that the unit must be in MODE 3 instead of all OPERABLE control rods must be fully inserted.CTS 3.1.B.3 states that t he plant must be placed and ma intained in the specified required condition (i.e., one of the Required Conditions referenced in CTS Table 3.1.1)"using normal operating procedures." The Monticello shutdown procedure requires thereactor mode switch to be placed in the shutdown position after all the control rods areinserted, if shutting down the plant by individually inserting each control rod. The other method specified in the Monticello shutdown procedure for shutting down the plantincludes placing the reactor mode switch in the shutdown position while still critical.Therefore, the normal operating procedures invoked by the CTS already require thereactor mode switch to be placed in the shutdown position.
3.3.1.1 A.9CTS Table 4.1.1 for the Mode Switch in Shutdown Instrument Channel specifies an"Operating Cycle" Frequency for the CHANNEL FUNCTIONAL TEST. CTS Table 4.1.2for the Low Reactor Water Level transmitte rs, Main Steamline Isolation Valve ClosureChannels, and Turbine Stop Valve Closure Instrument Channels is specifies an"Operating Cycle" Frequency for the CHANNEL CALIBRATION. CTS 1.0.F, the definition of Instrument Calibra tion, states that Response time is not part of the routineinstrument calibration but will be checked once "per cycle." ITS SR 3.3.1.1.10 requiresthe performance of a CHANNEL FUNCTIONAL TEST and SR 3.3.1.1.11 requiresperformance of a CHANNEL CALIBRATION every "24 months." ITS SR 3.3.1.1.14 requires verification that the RPS RESPONSE TIME is within limits every "24 months"on a STAGGERED TEST BASIS. This changes the CTS by changing the Frequencyfrom once each "Operating Cycle" to "24 months." The change to add theSTAGGERED TEST BASIS allowance to ITS SR 3.3.1.1.14 is di scussed in DOC L.11.
SR 3.3.1.1.10, SR 3.3.1.1.11, SR 3.3.1.1.14Table 4.1.1 (for ModeSwitch in Shutdown channel), Table 4.1.2 (for Low Reactor Water
Level transmitters, Main
Steamline Isolation
Valve Closure channels, and Turbine Stop Valve
Closure channels, 1.0.F 3.3.1.1 A.10CTS Table 4.1.1 Note 4 states that functional tests are not required when the systems are not required to be OPERABLE or are tripped.
In addition, the Note states that iftests are missed, they shall be performed prior to returning the systems to anOPERABLE status. CTS Table 4.1.2 Note 2 in cludes a similar Note for calibration tests. These explicit requirements are not retained in ITS 3.3.1.1. The allowances in SR 3.0.1 and the associated actions provide adequate guidance with respect to when the associated surveillances are required to be performed and this explicit requirement isnot retained. This changes the CTS by not including these ex plicit requirements.SR 3.0.1Table 4.1.1 Note 4,Table 4.1.2 Note 2 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 20 of 67 ATTACHMENT 2 3.3.1.1 A.11CTS Table 4.1.1 Note 5 states that a functional test of this instrument means the injection of a simulated signal into the instrument (not primary sensor) to verify the proper instrument channel response, alarm, and/or initiating action. These explicitrequirements are not retained in ITS 3.3.1.1. The ITS 1.0 defin ition provides adequateguidance with respect to performance requirements of a CHANNEL FUNCTIONALTEST and this explicit requirement is not retained. This changes the CTS by not including these explicit requirements.
1.0 definition of CHANNEL FUNCTIONAL TESTTable 4.1.1 Note 5 3.3.1.1 A.12CTS Table 3.1.1 requires the Turbine Control Valve Fast Closure and Turbine StopValve Closure Trip Functions (Trip Functions 11 and 12) to be OPERABLE when the reactor mode switch is in the Run position. However, CTS Tabl e 3.1.1 f ootnote **.d states that these scram functions may be bypassed when the reactor thermal power is <45%. ITS Table 3.3.1.1-1 Functions 8 and 9 require the Turbine Stop Valve - Closureand Turbine Control Valve Fast Closure, Acceleration Relay Oil Pressure - LowFunctions to be OPERABLE at > 45% RTP. This changes the CTS by clearly statingthe Applicability of the Turbine Control Valve Fast Closure and Turbine Stop ValveClosure Trip Functions.Table 3.3.1.1-1Functions 8 and 9Table 3.1.1 TripFunctions 11 and 12
including footnote **.d 3.3.1.1 A.13When the requirements of CT S 3.1.B are not met for the Mode Switch in Shutdown,Manual Scram, Neutron Flux IRM High - High, Neutron Flux IRM Inoperable, and ScramDischarge Volume High Level (East and West) Trip Functions (CTS Table 3.1.1 Trip Functions 1, 2, 3.a, 3.b, 8.a, and 8.b), CTS Table 3.1.1 (Required Condition A) requiresall OPERABLE control rods to be fully inserted. Under similar conditions in the ITS (i.e., the Required Actions and associated Completion Times of ACTIONS A, B, and C arenot met) and when the unit is in MODE 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies, ITS 3.3.1.1 ACTION H requires immediateinitiation of action to fully insert all insert able control rods in core cells containing one ormore fuel assemblies. This changes the CTS by specifying the unit must initiate actionto fully insert all insertable control rods in core cells containing one or more fuel assemblies instead of all OPERABLE control rods must be fully inserted. The change toallow some control rods to not be inserted (those in core cells containing no fuel) is discussed in DOC L.3.
3.3.1.1ACTION HTable 3.1.1 RequiredCondition A for Table 3.1.1 Trip Functions 1, 2, 3.a, 3.b, 8.a, and 8.b 3.3.1.1 A.14CTS Table 3.1.1 Note (1) states that there shall be two operable "or tripped" tripsystems for each function. The allowance for tripping a channel or trip system isincluded in the ITS 3.3.1.1 ACTIONS. This changes the CTS by deleting the statementrequiring two "tripped" trip systems for each function. The detail that there are two tripsystems has been relocated to the Bases in accordance with DOC LA.1.3.3.1.1 ACTIONS A and BTable 3.1.1 Note (1)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 21 of 67 ATTACHMENT 2 3.3.1.1 A.15When the requirements of CTS 3.1.B are not met for the Flow Referenced Neutron FluxAPRM High-High, Inoperative, and High Flow Clamp Trip Functions (CTS Table 3.1.1Trip Functions 4.a, 4.b, and 4.c), CTS T able 3.1.1 Required Condition A or B must betaken. When the requirements of CTS 3.
1.B are not met for the Main SteamlineIsolation Valve Closure Trip Function (CTS Table 3.1.1 Trip Function 10), CTS Table
3.1.1 Required Condition A or C must be ta ken. Required Condition A requires allOPERABLE control rods to be fully insert ed, Required Condition B requires reactorpower to be on the IRM range or below and t he reactor to be in Startup, Refuel, orShutdown mode, and Required Condition C require s the unit to be in Startup or Refuelmode and pressure below 600 psig. Under similar conditions in the ITS (i.e., the Required Actions and associated Completion Times of ACTIONS A, B, and C not met),ITS 3.3.1.1 ACTION F requires the unit to be in MODE 2, and for the Main SteamIsolation Valve - Closure Function only, r equires reactor pressure to be reduced to <600 psig within 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br />. This changes the CTS by only specifying the highest MODEthat will result in the unit exiting the Applicability.3.3.1.1 ACTION FTable 3.1.1 TripFunctions 4.a, 4.b, 4.c, and 10, Table 3.1.1
Required Condition B 3.3.1.1 A.16CTS 3.1.A states that the "setpoints" must be set in accordance with Table 3.1.1.CTS Table 3.1.1 has a column that specifies the "Limiting Trip Settings" for eachRPS instrument Function. ITS LCO 3.3.1.
1 requires the RPS instrumentation foreach Function in Table 3.3.1.1-1 to be OPERABLE and ITS Table 3.3.1.1-1 hasa column that specifies the "Allowable Value" for each Function. This changesthe CTS by replacing the term "setpoints" in CTS 3.1.A and the column title"Limiting Trip Settings" in CTS Table 3.1.1 with the column title "Allowable Value" in ITS 3.3.1.1 and Table 3.
3.1.1-1. Note that th is change does not change theindividual values in the CTS Table 3.1.1 Limiting Trip Settings column. Anychanges to the individual values in the CTS Table 3.1.1 Limiting Trip Setting
column is discussed in DOC L.12.
LCO 3.3.1.1, Table 3.3.1.1-13.1.A, Table 3.1.1 3.3.1.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.1.23.3.B.4, 3.3.G.1, 3.10.B, 4.3.B.4, 4.10.B 3.3.1.2 A.2CTS 3.10.B.2 states that an OPERABLE SRM shall have a minimum of 3 CPS. ITS SR 3.3.1.2.4 requires verification t hat the SRM count rate is >
3 CPS and also requires that the signal to noise ratio is > 3:1. This change is "A" because the current requirement for the SRM to be 3 CPS is based upon a signal to noise ratio > 3:1. This changes theCTS by adding a requirement to verify the SRM signal to noise ratio is within limit.SR 3.3.1.2.43.10.B.2 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 22 of 67 ATTACHMENT 2 3.3.1.2 A.3These changes to CTS 3.3.G are provided in the Monticello ITSs consistent with theTechnical Specifications Change Request s ubmitted to the NRC for approval in NMCletter L-MT-05-013, from Thomas J. Palm isano (NMC) to USNRC, dated April 12, 2005.
As such, these changes are administrative.3.3.1.2 ACTIONS A, B, C, and E 3.3.G 3.3.2.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.2.11.0.Y, 3.2.
C, 3.3.B.3.(b), 4.2, 4.2.C, Table 3.2.3,Table 4.2.1 (Rod
Blocks), 4.3.B.3.(a),
4.3.B.3.(b) 3.3.2.1 A.2CTS Table 4.2.1 Note (3) stat es that functional tests, calibrations, and sensor checksare not required when these instruments are not requir ed to be OPERABLE or are tripped. In addition, the Note states that if tests are missed, they shall be performedprior to returning the systems to an OPERABLE status. These explicit requirements arenot retained in ITS 3.3.2.1. The allow ances in SR 3.0.1 and the associated actionsprovide adequate guidance with respect to when the associated surveillances arerequired to be performed. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.2.1 Note (3) 3.3.2.1 A.3CTS Table 4.2.1 Note (5) stat es that a functional test of this instrument means the injection of a simulated signal into the instrument (not primary sensor) to verify the proper instrument channel response alarm and or initiating action. This explicit Note isnot needed in ITS 3.3.2.1 since the requirements for the CHANNEL FUNCTIONALTEST are included in ITS 1.0, "Definitions." These explicit requirements are notretained in ITS 3.3.2.1. This changes the CTS by not including these explicit requirements.
1.0 definition of CHANNEL FUNCTIONAL TESTTable 4.2.1 Note (5) 3.3.2.1 A.4CTS 3.2.C.2.b states that the RBM "Setpoints" for t he control rod block are given inTable 3.2.3. CTS Table 3.2.3 specifies the "Trip Settings" for each RBM Function. ITS LCO 3.3.2.1 requires the control rod block instrumentations for each Function in Table 3.3.2.1-1 to be OPERABLE and ITS Table 3.3.2.1-1 specifies the "Allowable Value" foreach Function. This changes the CTS by replacing the terms "Setpoints" and "TripSettings" with "Allowable Value."Table 3.3.2.1-13.2.C.2.b, Table 3.2.3 3.3.2.1 A.5This change to CTS Table 4.2.1 is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 144 (ADA MS Accession No.: ML053570161), dated January 12, 2006. As such, this change is administrative. NoneTable 4.2.1 (Rod Blocks) 3.3.3.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.3.13.14, 4.14, Tables 3.14.1 and
4.14.1 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 23 of 67 ATTACHMENT 2 3.3.3.1 A.2CTS Table 3.14.1 Required Actions A, B, and D specify the compensatory actions totake when PAM Instrumentation is inoperable. ITS 3.3.3.1 ACTIONS provide thecompensatory actions for inoperable PAM Instrumentation. The ITS 3.3.3.1 ACTIONSinclude a Note that allows separate Condition entry for each Function. This modifies theCTS by providing a specific allowance to enter the Action for each inoperable PAMinstrumentation Function.3.3.3.1 ACTIONS NoteTable 3.14.1 Required Actions A, B, and D 3.3.3.1 A.3CTS Table 4.14.1 Note (1) stat es that functional tests, calibrations, and sensor checksare not required when these instruments are not requir ed to be OPERABLE or are tripped. In addition, the Note states that if tests are missed, they shall be performedprior to returning the systems to an operable status. These explic it requirements are notretained in ITS 3.3.3.1. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.14.1 Note (1) 3.3.3.1 A.4CTS Table 4.14.1 specifies an "Operating Cycle" Frequency for the CHANNELCALIBRATION. ITS SR 3.3.3.1.2 requires performance of a CHANNEL CALIBRATIONevery "24 months." This changes the CTS by changing the Frequency from once per"Operating Cycle" to "24 months."SR 3.3.3.1.2Table 4.14.1 3.3.3.1 A.5CTS Table 4.14.1 Note (3), which applies to the Reactor Vessel Fuel Zone Water Level Monitor states the "Once/month sensor check will consist of verifying that the fuel zonelevel indicates off scale high." ITS Table 3.3.3.1-1 does not retain this detail. Thischanges the CTS by deleting a specific method of completing the sensor check.NoneTable 4.14.1 Note (3) 3.3.3.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.3.23.13.A, 4.13.A 3.3.3.2 A.2CTS 3.13.A.1 states, in part, that 12 RHR service water pump shall be OPERABLEwhenever there is irradiated fuel in the vessel and water temperature is greater than 212 °F. CTS 3.13.A.2 states, in part, that an inoperable 12 RHR service water pumpshall be restored to OPERABLE within 7 days. ITS LCO 3.3.3.2 retains requirementsfor OPERABILITY of the 12 RHR service water controls associated with the AlternateShutdown System but does not retain requi rements for the OPERABILITY of the 12RHR service water pump. This change is adm inistrative because a new Specification,ITS LCO 3.7.1, "RHR Service Water System," has been added (ITS 3.7.1 DOC M.1) toaddress the OPERABILITY of the RHR Service Water System, including 12 RHRservice water pump. This changes the CTS by deleting 12 RHR service water pumpOPERABILITY requirements from the Alternate Shutdown System Specification. 3.7.13.13.A.1, 3.13.A.2 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 24 of 67 ATTACHMENT 2 3.3.3.2 A.3CTS 4.13.A.1 requires the sw itches on the Alternate Shutdown System be functionallytested once per "operating cycle." CTS 4.13.A.2 requires the Alternate ShutdownSystem panel master transfer switch to be functionally tested once per "operatingcycle." ITS SR 3.3.3.2.2 requires performance of a similar test every "24 months." Thischanges the CTS by changing the Frequency from once per "operating cycle" to "24 months."SR 3.3.3.2.24.13.A.1, 4.13.A.2 3.3.3.2 A.4CTS 3.13.A.1 specifies the compensatory actions to take when Alternate ShutdownSystem controls are inoperable. ITS 3.3.3.2 ACTIONS provi de the compensatoryactions for inoperable Alternate Shutdown System Functions. The ITS 3.3.3.2ACTIONS include a Note that allows separate Condition entry for each Function. Thismodifies the CTS by providing a specific allowance to enter the Action for eachinoperable Alternate Shutdown System Function.3.3.3.2 ACTIONS Note3.13.A.1 3.3.4.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.4.13.2.F, 4.2, Table 3.2.5, Table 4.2.1 (Recirculation Pump Trip)3.3.4.1 A.2CTS Table 3.2.5 Required Condition A requires the plant to be in Startup, Refuel, orShutdown Mode if the Required Actions provided in Note 1 are not met. When the Required Actions and associated Conditions are not met in the ITS, ITS 3.3.4.1 Required Action D.2 requires the plant to be in MODE 2. This changes the CTS by onlyspecifying a default action to be in MODE 2 (Startup) instead of pr oviding the option tobe in the Refuel or Shutdown Mode.
3.3.4.1 Required Action D.2Table 3.2.5 Required Condition A 3.3.4.1 A.3CTS Table 4.2.1 Instrument Channels 1 and 2 associated with the Recirculation PumpTrip Instrumentation specifies an "Operating Cycle" Frequency for the CHANNELCALIBRATION of the transmitter. ITS SR 3.3.4.1.5 requires the performance of aCHANNEL CALIBRATION every "24 months." This changes the CTS by changing theFrequency from once per "Operating Cycle" to "24 months."SR 3.3.4.1.5Table 4.2.1 (Recirculation Pump Trip)3.3.4.1 A.4CTS Table 4.2.1 Note (3) states that, func tional tests, calibrations, and sensor checksare not required when the syst ems are not required to be OPERABLE or are tripped. In addition, the Note states t hat if tests are missed, they shall be performed prior toreturning the systems to an OPERABLE status. These explicit requirements are notretained in ITS 3.3.4.1. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.2.1 Note (3) 3.3.4.1 A.5CTS Table 4.2.1 Note (5) stat es that functional test of this instrument means the injection of a simulated signal into the instrument (not primary sensor) to verify the proper instrument channel response, alarm, and/or initiating action. These explicitrequirements are not retained in ITS 3.3.4.1. This changes the CTS by not including these explicit requirements.
1.0 Definition of CHANNEL FUNCTIONAL TESTTable 4.2.1 Note (5)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 25 of 67 ATTACHMENT 2 3.3.4.1 A.6CTS 3.2.F states that the Limiting Conditions for Operati on for the instrumentation listedin Table 3.2.5 shall be met. CTS Table 3.2.5 specifies the "Trip Setting" for eachATWS-RPT instrument Function. ITS LCO 3.3.4.1 requires the ATWS-RPTinstrumentations for each Function to be OPERABLE and ITS SR 3.3.4.1.5 specifies the"Allowable Value" for each Function. This changes the CTS by replacing the term "TripSetting" with "Allowable Value."Table 3.3.4.1-1Table 3.2.5 3.3.5.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.5.13.2.B, 3.2.D, 4.2, Table3.2.2, Table 3.2.8, Table
4.2.1 (ECCS
Instrumentation) 3.3.5.1 A.2CTS Table 3.2.2 and CTS Table 3.2.8 specify the "Minimum No. of Operable orOperating Instrument Channels Per Trip System." ITS Table 3.3.5.1-1 specifies the"REQUIRED CHANNELS PER FUNCTION." This changes the CTS by listing the "REQUIRED CHANNELS PER FUNCTION" instead of the "Minimum No. of Operable orOperating Instrument Channels Per Trip System." To reflect this change, the number ofchannels required has been increased by multiplying the number of trip systems (specified in the "Minimum No. of Operable or Operating Trip Systems" column) by thenumber of required channels per trip system (s pecified in the "Minimum No. of Operableor Operating Instrument Channels Per Trip System" column). The ADS instrumentationhas been split into two Functions (Trip System A and Trip System B).Table 3.3.5.1-1Tabl es 3.2.2 and 3.2.8 3.3.5.1 A.3CTS Table 3.2.2 Functions A.
1.a, A.1.c, D.2, and D.3 (Low Low Reactor Water Leveland High Drywell Pressure) require four channels per trip system to be OPERABLE. CTS Table 3.2.2 Functions A.1.b.i and A.2 (Reactor Low Pressure Permissive and Low Reactor Pressure (Valve Permissive)) require two channels per trip system to beOPERABLE. For all four of these Functions, CTS Table 3.2.2 states that there are twotrip systems. Furthermore, CTS Table 3.2.2 Note 4, which applies to each of theseFunctions, states that all in strument channels are shared by both trip systems, and CTSTable 3.2.2 Note 6, which applies to each of these Functions, states, in part, that a shared channel is considered one channel. ITS Table 3.3.5.1-1 F unctions 1.a and 2.a(Reactor Vessel Water Level - Low Low) and Functions 1.b and 2.b (Drywell Pressure -
High) require four channels per Function to be OPERABLE and ITS Table 3.3.5.1-1Functions 1.c and 2.c (Reactor Steam Dome Pressure - Low (Injection Permissive) andFunctions 1.d and 2.d (Reactor Steam Dome Pressure - Low (Pump Permissive))
require two channels per Function to be OPERABLE. This changes the CTS by clarifying the actual number of channels required to be OPERABLE on a per Function basis.Table 3.3.5.1-1Functions 1.a, 1.b, 1.c, 1.d, 2.a, 2.b, 2.c, and 2.dTable 3.2.2 Functions A.1.a, A.1.b.i, A.1.c, A.2, D.2, and D.3, Table 3.2.2 Notes 4 and 6 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 26 of 67 ATTACHMENT 2 3.3.5.1 A.4CTS Table 4.2.1 ECCS Instrument Channel 8, Instrument Channel 10, and InstrumentChannel 11 require the performance of a CHANNEL FUNCTIONAL TEST and a CHANNEL CALIBRATION at the same Frequency (Refueling Interval). ITS Table 3.3.5.1-1 Functions 1.e, 2.e, 3.d, 4.b, and 5.b only r equire the performance of aCHANNEL CALIBRATION at a similar Frequency. This changes the CTS by combining the current CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION testing
requirements into a single Surveillance Requirement.Table 3.3.5.1-1Functions 1.e, 2.e, 3.d, 4.b, and 5.bTable 4.2.1 ECCS Instrument Channels 8, 10, and 11 3.3.5.1 A.5CTS Table 4.2.1 ECCS Instrument Channels 1 and 9 specify an "Operating Cycle"Frequency for the CHANNEL CALIBRATION requirement while CTS Table 4.2.1 ECCS Instrument Channels 8, 10, and 11 specify a "Refueling Interval" Frequency for both theCHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION requirements. ITS SR
3.3.5.1.7 requires the performance of a CHANNEL CALIBRATION every "24 months." This changes the CTS by changing the Frequency from once per "Operating Cycle" or"Refueling Interval" to "24 months."SR 3.3.5.1.7T able 4.2.1 ECCS Instrument Channels 1, 8, 9, 10, and 11 3.3.5.1 A.6CTS Table 4.2.1 Note (3) stat es that functional tests, calibrations, and sensor checksare not required when the syst ems are not required to be OPERABLE or are tripped. In addition, the Note states t hat if tests are missed, they shall be performed prior toreturning the systems to an OPERABLE status. These explicit requirements are notretained in ITS 3.3.5.1. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.2.1 Note (3) 3.3.5.1 A.7CTS Table 4.2.1 Note (5) stat es that a functional test of this instrument means the injection of a simulated signal into the instrument (not primary sensor) to verify the proper instrument channel response, alarm, and/or initiating action. These explicitrequirements are not retained in ITS 3.3.5.1. This changes the CTS by not including these explicit requirements.
1.0 definition of CHANNEL FUNCTIONAL TESTTable 4.2.1 Note (5) 3.3.5.1 A.8CTS 3.2.B states that the limiting conditions for operation for the instrumentation whichinitiates ECCS are given in Table 3.2.2. CTS Table 3.2.2 specifies the "Trip Setting" foreach ECCS Function. CTS 3.2.
D states that the limiting c onditions for operation for theinstrumentation listed in Table 3.2.8 shall be met. CTS Table 3.2.8 specifies the "TripSetting" for HPCI actuation Functions. ITS LCO 3.3.5.1 requires the ECCSinstrumentation for each Function in Table 3.3.5.1-1 to be OPERABLE and ITS Table 3.3.5.1-1 specifies the "Allowable Value" for each Function. This changes the CTS byreplacing the term "Trip Setting" with "Allowable Value."Table 3.3.5.1-1Tabl es 3.2.2 and 3.2.8 3.3.5.1 A.9These changes to CTS Table 3.2.2 and CTS T able 4.2.1 are provi ded in the MonticelloITS consistent with the Technical Spec ifications Change Request submitted to theUSNRC for approval in NMC letter L-MT-04-036, from Thomas J. Palmisano (NMC) to
USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, these changes are administrative.Table 3.3.5.1-1Table 3.2.2 and Table 4.2.1 (ECCS
Instrumentation)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 27 of 67 ATTACHMENT 2 3.3.5.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.5.23.2.D, 3.5.D.3, 4.2,Table 3.2.8, Table 4.2.1 (ECCS Instrumentation) 3.3.5.2 A.2CTS Table 3.2.8 specifies t he "Minimum No. of Operabl e or Operating InstrumentChannels Per Trip System." ITS Table 3.
3.5.2-1 specifies t he "REQUIRED CHANNELSPER FUNCTION." This changes the CTS by changing the title of the "Minimum No. of Operable or Operating Instrument Channels Per Trip System" column to "REQUIREDCHANNELS PER FUNCTION."Table 3.3.5.2-1Table 3.2.8 3.3.5.2 A.3If one or both channels of the RCIC Reactor Vessel Water Level - High Function (CTSTable 3.2.8 Function B.1) are inoperable and the requirements of CTS Table 3.2.8Notes 1.a and 1.b cannot be met, then Table 3.
2.8 Note 1.c requires Required Condition A to be taken (since this is the Required Condition listed in Table 3.2.8 for Function B.1). Required Condition A requires compliance with CTS 3.5.A (i.e., declare RCICinoperable and take the actions required by CTS 3.5.A). However, CTS 3.5.A provides the ECCS requirements, not the RCIC requirements. ITS 3.3.5.2 ACTION E requiresthe RCIC System to be declared inoperable, which will then require entry into theappropriate RCIC System ACTIONS (ITS 3.5.3). This changes the CTS by providing the correct reference to the appropriate RCIC System ACTIONS.3.3.5.2 ACTION ETable 3.2.8 Required Condition A 3.3.5.2 A.4CTS Table 4.2.1 ECCS Instrument Channel 8 requires the performance of a CHANNELFUNCTIONAL TEST and a CHANNEL CALIBRATION at the same Frequency (Refueling Interval). ITS Table 3.3.5.2-1 Function 3 only requires the performance of aCHANNEL CALIBRATION at a similar Frequency. This changes the CTS by combining the current CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION testing
requirements into a single Surveillance Requirement.Table 3.3.5.2-1 Function 3Table 4.2.1 ECCS Instrument Channel 8 3.3.5.2 A.5CTS Table 4.2.1 for ECCS Instrument Channels 1 and 9 specifies an "Operating Cycle"Frequency for the CHANNEL CALIBRATION requirement while CTS Table 4.2.1 ECCS Instrument Channel 8 specifies a "Refueling Interval" Frequency for both the CHANNELFUNCTIONAL TEST and CHANNEL CALIBRATION requirements. ITS SR 3.3.5.2.4 requires the performance of a CHANNEL CALIBRATION every "24 months." Thischanges the CTS by changing the Frequency from once per "Operating Cycle" and Refueling Interval" to "24 months."SR 3.3.5.2.4Table 4.2.1 ECCS Instrument
Channels 1, 8, and 9 3.3.5.2 A.6CTS Table 4.2.1 Note (3) stat es that functional tests, calibrations, and sensor checksare not required when the syst ems are not required to be OPERABLE or are tripped. In addition, the Note states t hat if tests are missed, they shall be performed prior toreturning the systems to an OPERABLE status. These explicit requirements are notretained in ITS 3.3.5.2. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.2.1 Note (3)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 28 of 67 ATTACHMENT 2 3.3.5.2 A.7CTS Table 4.2.1 Note (5) stat es that a functional test of this instrument means the injection of a simulated signal into the instrument (not primary sensor) to verify the proper instrument channel response, alarm, and/or initiating action. These explicitrequirements are not retained in ITS 3.3.5.2. This changes the CTS by not including these explicit requirements.
1.0 definition of CHANNEL FUNCTIONAL TESTTable 4.2.1 Note (5) 3.3.5.2 A.8CTS 3.2.D states that the limiting conditions for operati on for the instrumentation listedin Table 3.2.8 shall be met. CTS Table 3.2.8 specifies the "Trip Setting" for each RCICFunction. ITS LCO 3.3.5.2 requires the RCIC System instrumentation for each Functionin Table 3.3.5.2-1 to be OPERABLE and ITS Table 3.3.5.2-1 specifies the "AllowableValue" for each Function. This changes the CTS by replacing the term "Trip Setting" with "Allowable Value."Table 3.3.5.2-1Table 3.2.8 3.3.5.2 A.9These changes to CTS Table 4.2.1 are provided in the Monticello ITS consistent withthe Technical Specificati ons Change Request submitted to the USNRC for approval inNMC letter L-MT-04-036, from Thomas J.
Palmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept.
30, 2005, ML052700252.
As such, these changes are administrative.Table 3.3.5.2-1Table 4.2.1 (ECCS Instrumentation) 3.3.6.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.6.13.2.A, 4.2, Table 3.2.1,Table 4.1.1, Table 4.1.2, Table 4.2.1 (Isolation Functions) 3.3.6.1 A.2CTS Table 3.2.1 Function 1.b requires eight channels of High Flow in Main Steam LineFunction to be OPERABLE in each trip system, while CTS Table 3.2.1 Function 1.crequires two of four channels in each of tw o sets of High temp in Main Steam LineTunnel Function to be OPERABLE in each trip system. ITS Table 3.3.6.1-1 Function1.c (Main Steam Line Flow - High) requires two channels per steam line in each tripsystem, while ITS Table 3.3.6.1-1 Function 1.d (Main Steam Line Tunnel Temperature -High) requires two channels per trip string in each trip system. This changes the CTSby clarifying the requirement by replacing the minimum number "8" with "2 per steamline" and by replacing the words "2 of 4 in each of 2 sets" with "2 per trip string."Table 3.3.6.1-1Functions 1.c and 1.dTable 3.2.1 Functions 1.b and 1.c 3.3.6.1 A.3CTS Table 3.2.1 Note (1) states that there shall be two OPERABLE "or tripped" tripsystems for each function. The allowance to trip a channel (which could result in atripped trip system) is included in the ITS 3.3.6.1 ACTIONS. This changes the CTS by deleting the statement requiring two "tripped" trip systems for each function. The detailthat there are two trip systems has been re located to the Bases as discussed in DOC LA.1.3.3.6.1 ACTIONS A and BTable 3.2.1 Note (1)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 29 of 67 ATTACHMENT 2 3.3.6.1 A.4CTS Table 3.2.1 Note (1) states that a channel may be placed in an inoperable statusfor up to 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> for required Surveillances without placing the trip system in the tripped condition provided "that at least one other operable channel in the same trip system is monitoring that parameter." ITS 3.3.6.1 Surveillance Requi rements Note 2 states thatwhen a channel is placed in an inoperable status solely for performance of requiredSurveillances, entry into associated Conditions and Required Actions may be delayed
for up to 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> provided "the associated Function maintains primary containmentisolation capability." This changes the CTS by replacing the words "at least one otheroperable channel in the same trip system is monitoring that parameter" with "the associated Function maintains primary containment isolation capability." 3.3.6.1 Surveillance Requirements Note 2Table 3.2.1 Note (1) 3.3.6.1 A.5If CTS Table 3.2.1 Function 1.d channels are inoperable and the requirements of CTSTable 3.2.1 Notes (2)(a) and (2)(b) cannot be met, then Table 3.2.1 Note (2)(c) requiresRequired Condition B to be taken (since this is the Required Condition listed in Table 3.2.1 for Function 1.d). CTS Table 3.2.1 Required Condition B requires reactor powerto be on IRM range or below and the reactor mode switch to be in startup, refuel, orshutdown mode. Under similar conditions in the ITS (i.e., the Required Actions andassociated Completion Times of ACTIONS A and B not met), ITS 3.3.6.1 ACTION Erequires the unit to be in MODE 2. This changes the CTS by only specifying the highestMODE that will result in the unit exiting the Applicability.3.3.6.1 ACTION ETable 3.2.1 Required Condition B 3.3.6.1 A.6CTS Table 3.2.1 Note ** and CTS Table 4.2.1 Note
- state "Function changed from LowReactor Water Level to Low Low Reactor Water Level following completion of designchange." CTS Table 3.2.1 Note *** states "Function change from <
150,000 lb/hr, <
60second delay, and <
300,000 lb/hr, instantaneous, isolation to <
300,000 lb/hr, <
7second delay, isolation following completi on of design change." ITS 3.3.6.1 does notinclude these Notes. This changes the CTS by deleting the Notes.NoneTable 3.2.1 Notes ** and ***,
Table 4.2.1 Note
- 3.3.6.1 A.7CTS Table 4.2.1 Main Steam Line Isolation Instrument Channel Function 1 specifies"Refueling Interval" Frequency for both the CHANNEL FUNCTIONAL TEST andCHANNEL CALIBRATION requirements. CTS Table 4.2.1 Main Steam Line IsolationFunction 4 and RWCU Isolation Functions 1 and 2 specify an "Operating Cycle"Frequency for the CHANNEL CALIBRATION requirements. CTS Table 4.1.2 Instrument Channel 5 specifies an "Operating Cycle" Frequency for the CHANNELCALIBRATION requirement. ITS SR 3.3.6.
1.5 requires the performance of a CHANNELCALIBRATION every "24 months." This changes the CTS by changing the Frequencyfrom "Operating Cycle" and "Refue ling Interval" to "24 months."SR 3.3.6.1.5Table 4.1.2 InstrumentChannel 5, Table 4.2.1
MSL Isolation
Instrument Channels 1 and 4, Table 4.2.1
RWCU Isolation
instrument Channels 1
and 2 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 30 of 67 ATTACHMENT 2 3.3.6.1 A.8CTS Table 4.2.1 Main Steam Line Isolat ion Instrument Channel 1 requires theperformance of a CHANNEL FUNCTIONAL TEST and a CHANNEL CALIBRATION at the same Frequency (Refueling Interval). ITS Table 3.3.6.1-1 Function 1.d only requiresthe performance of a CHANNEL CALIBRATION (ITS SR 3.3.6.1.5) at a similarFrequency. This changes the CTS by combining the current CHANNEL FUNCTIONALTEST and CHANNEL CALIBRATION testing requirements into a single Surveillance
Requirement.Table 3.3.6.1-1 Function 1.dTable 4.2.1 MSL Isolation Instrument
Channel 1 3.3.6.1 A.9CTS Table 4.2.1 Note (3) stat es that functional tests, calibrations, and sensor checksare not required when the syst ems are not required to be OPERABLE or are tripped. In addition, the Note states t hat if tests are missed, they shall be performed prior toreturning the systems to an OPERABLE status. CTS Table 4.1.1 Note 4 includes asimilar allowance for the functional test and CTS Table 4.1.2 Note 2 includes a similarallowance for the calibration test. These explicit requirements are not retained in ITS3.3.6.1. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.1.1 Note 4,Table 4.1.2 Note 2.
Table 4.2.1 Note (3) 3.3.6.1 A.10CTS Table 4.2.1 Note (5) and CTS Table 4.1.1 No te 5 state that a f unctional test of this instrument means the injecti on of a simulated signal into the instrument (not primarysensor) to verify the proper instrument channel response, alarm, and/
or initiating action. These explicit requirements are not retained in ITS 3.3.6.1. This changes the CTS by not including these ex plicit requirements.
1.0 definition of CHANNEL FUNCTIONAL TESTTable 4.1.1 Note 5,Table 4.2.1 Note (5) 3.3.6.1 A.11CTS Table 4.2.1 Note (12) st ates that calibration of instrument channels with resistancetemperature detector (RTD) or thermocouples sensors may consist of an inplace qualitative assessment of s ensor behavior and normal calibration of the remainingadjustable devices in the channel. These explicit requirements are not retained in ITS3.3.6.1. This changes the CTS by not including these explicit requirements.
1.0 definition of CHANNEL CALIBRATIONTable 4.2.1 Note (12) 3.3.6.1 A.12CTS Table 3.2.1 Required Condition F require s the High Pressure Coolant Injection (HPCI) steam line to be isolated and includes a statement to see S pecification 3.5 for additional requirements. Specification 3.5 includes requirements for inoperableEmergency Core Cooling Systems including HPCI. ITS 3.3.6.1 ACTION F does not
include this cross reference to the ECCS requirements. This changes the CTS by deleting a cross-reference to the System Specification.NoneTable 3.2.1 Required Condition F 3.3.6.1 A.13CTS 3.2.A states that the limiting conditions for operat ion for the instrumentation thatinitiates primary containment isolation are given in Table 3.2.1. CTS Table 3.2.1specifies the "Trip Settings" for each primary containment isolation Function. ITS LCO3.3.6.1 requires the primary containment isolation instrumentation for each Function inTable 3.3.6.1-1 to be OPERABLE and ITS T able 3.3.6.1-1 specifies the "AllowableValue" for each Function. This changes the CTS by replacing the term "Trip Settings"with "Allowable Value."Table 3.3.6.1-1Table 3.2.1 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 31 of 67 ATTACHMENT 2 3.3.6.1 A.14These changes to CTS Table 4.2.1 are provided in the Monticello ITS consistent withthe Technical Specificati ons Change Request submitted to the USNRC for approval inNMC letter L-MT-04-036, from Thomas J.
Palmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept.
30, 2005, ML052700252.
As such, these changes are administrative.Table 3.3.6.1-1Table 4.2.1 (Isolation Functions) 3.3.6.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.6.23.2.E, 4.2, Table 3.2.4,Table 4.1.1, Table 4.1.2, Table 4.2.1 (Reactor
Building Ventilation and SGT System) 3.3.6.2 A.2CTS Table 3.2.4 Note (1) states that there shall be two operable "or tripped" tripsystems for each function. The allowance to trip a channel (which could result in atripped trip system) is included in the ITS 3.3.6.2 ACTIONS. This changes the CTS by deleting the statement requiring two "tripped" trip systems for each function. The detailthat there are two trip systems has been relocated to the Bases in accordance with DOC LA.1.3.3.6.2 ACTIONS A and BTable 3.2.4 Note (1) 3.3.6.2 A.3CTS Table 3.2.4 Note (1) states that a channel may be placed in an inoperable status for up to 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> for performance of required Surveillances without placing the tripsystem in the tripped condition provided "t hat at least one other OPERABLE channel inthe same Trip System is monitoring that parameter." ITS 3.3.6.2 SurveillanceRequirements Note 2 states that when a c hannel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions andRequired Actions may be delayed for up to 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> provided "the associated Functionmaintains secondary containment isolation capability." This changes the CTS byreplacing the words "at least one other OPERABLE channel in the same Trip System ismonitoring that parameter" with "the associated Function maintains secondary containment isolation capability." 3.3.6.2 Surveillance Requirements Note 2Table 3.2.4 Note (1) 3.3.6.2 A.4CTS Table 3.2.4 Note (2) provides Acti ons for inoperable inst rumentation channels. When the minimum number of OPERABLE c hannels is less than required for a givenFunction, the action must be taken within t he specified time for each individual channel. This CTS Action does not limit the number of Functions to which this Action cansimultaneously apply. ITS 3.3.6.2 ACTIONS Note states "Separate Condition entry isallowed for each channel." This changes the CTS by adding an explicit Note for separate condition entry for each channel.3.3.6.2 ACTIONS NoteTable 3.2.4 Note (2) 3.3.6.2 A.5CTS Table 3.2.4 Note (2)(a)2) requires the Function 3 or 4 inoperable channels to beplaced in the downscale trip condition or to place the trip system in the tripped condition. ITS 3.3.6.2 ACTION A requires the placement of the channel in trip. This changes theCTS by replacing the wording to place the "inoperable Channel in a downscale trip condition, or place the Trip System in t he tripped condition" to place "channel in trip."3.3.6.2 ACTION ATable 3.2.4 Note (2)(a)2)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 32 of 67 ATTACHMENT 2 3.3.6.2 A.6CTS Table 4.2.1 Instrument Channel Function 1 associated with the Reactor BuildingVentilation and Standby Gas Treatment specifies an "Operating Cycle" Frequency forthe CHANNEL CALIBRATION requirement. IT S SR 3.3.6.2.5 requi res the performanceof a CHANNEL CALIBRATION every "24 months." This changes the CTS by changingthe Frequency from once per "Operating Cycle" to "24 months."SR 3.3.6.2.5Tabl e 4.2.1 Reactor Building Ventilation and SGT System Instrument
Channel 1 3.3.6.2 A.7CTS Table 4.2.1 Note (3) stat es that functional tests, calibrations, and sensor checksare not required when the syst ems are not required to be OPERABLE or are tripped. In addition, the Note states t hat if tests are missed, they shall be performed prior toreturning the systems to an OPERABLE status. CTS Table 4.1.1 Note 4 includes asimilar allowance for the functional test and CTS Table 4.1.2 Note 2 includes a similarallowance for the calibration test. These explicit requirements are not retained in ITS3.3.6.2. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.1.1 Note 4,Table 4.1.2 Note 2, Table 4.2.1 Note (3) 3.3.6.2 A.8CTS Table 4.2.1 Note (5) stat es that a functional test of this instrument means the injection of a simulated signal into the instrument (not primary sensor) to verify the proper instrument channel response, alarm, and/or initiating action. These explicitrequirements are not retained in ITS 3.3.6.2. This changes the CTS by not including these explicit requirements.
1.0 definition of CHANNEL FUNCTIONAL TESTTable 4.2.1 Note (5) 3.3.6.2 A.9CTS 3.2.E states that the limiting conditions for operati on for the instrumentation listedin Table 3.2.4 shall be met. CTS Table 3.2.4 specifies the "Trip Settings" for eachsecondary containment isolation instrumentation Function. ITS LCO 3.3.6.2 requiresthe secondary containment isolation instrumentation for each Function in Table 3.3.6.2-1 to be OPERABLE and ITS Table 3.3.6.2-1 specifies the "Allowable Value" foreach Function. This changes the CTS by replacing the term "Trip Settings" with "Allowable Value."Table 3.3.6.2-1Table 3.2.4 3.3.6.2 A.10These changes to CTS Table 3.2.4 are provided in the Monticello ITS consistent withthe Technical Specificati ons Change Request submitted to the USNRC for approval inNMC letter L-MT-04-023, from Thomas J. Palmisano (NMC) to USNRC, dated
April 29, 2004. As such, t hese changes are administrative.Table 3.3.6.2-1Table 3.2.4 3.3.6.2 A.11CTS 3.2.E requires secondary c ontainment isolation instrumentation Functions listed inTable 3.2.4 to be OPERABLE whenever the secondary containment integrity is requiredas specified in CTS 3.7.C. CTS Tabl e 3.2.4 requires each secondary containmentisolation Function to be OPERABLE during the conditions specified in Table 3.2.4. ITSTable 3.3.6.2.1-1 requires the secondary containment isolation Functions to be OPERABLE at the same conditions specified in CTS Table 3.2.4. This changes theCTS by deleting the statement in CTS 3.2.E regarding the Applicability of the secondarycontainment isolation Functions.Table 3.3.6.2-13.2.E Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 33 of 67 ATTACHMENT 2 3.3.6.2 A.12This change to CTS Table 4.2.1 is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143 (ADA MS Accession No.: ML052700252), dated September 30, 2005. As such, this change is administrative.Table 3.3.6.2-1Table 4.2.1 3.3.6.3 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.6.33.2.H, 3.6.E.1, 4.2,Table 3.2.7, Table 4.2.1 (S/RV LLS
Logic),
Table 4.14.1 (S/RV
Position (Pressure Switch Function) 3.3.6.3 A.2CTS Table 3.2.7 requires 2 channels of each Function for each trip system and alsostates that there are two trip systems for each Function. Furthermore, CTS Table 3.2.7 Note (2) states that each LLS valve is provided with two trip systems. ITS Table 3.3.6.3-1 requires 4 channels per LLS valve for each Function. This changes the CTSby changing the channel requirements for each Function from 2 channels per tripsystem for 2 trip systems to 4 channels per valve.Table 3.3.6.3-1Tabl e 3.2.7 including Note (2)3.3.6.3 A.3CTS Table 4.2.1 S/RV LLS Logic Instrum ent Channels 2 and 3 spec ifies an "OperatingCycle" Frequency for the CHANNEL CALIBRATION requirement and CTS Table 4.14.1specifies an "Operating Cycle" Frequency for the CHANNEL CALIBRATION requirement of the S/RV Position (Pressure Switch) Function. ITS SR 3.3.6.3.5 requiresthe performance of a CHANNEL CALIBRATION every "24 months." This changes theCTS by changing the Frequency from once per "Operating Cycle" to "24 months."SR 3.3.6.3.5Tabl e 4.2.1 S/RV LLS Logic Instrument
Channels 2 and 3, Table 4.14.1 (S/RV
Position (Pressure Switch) Function) 3.3.6.3 A.4CTS Table 4.2.1 Note (3) stat es that functional tests, calibrations, and sensor checksare not required when the syst ems are not required to be operable or are tripped. In addition, the Note states t hat if tests are missed, they shall be performed prior toreturning the systems to an operable status. These explicit requirements are notretained in ITS 3.3.6.3. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.2.1 Note (3) 3.3.6.3 A.5CTS Table 4.2.1 Note (5) stat es that a functional test of this instrument means the injection of a simulated signal into the instrument (not primary sensor) to verify the proper instrument channel response, alarm, and/or initiating action. These explicitrequirements are not retained in ITS 3.3.6.3. This changes the CTS by not including these explicit requirements.
1.0 definition of CHANNEL FUNCTIONAL TESTTable 4.2.1 Note (5)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 34 of 67 ATTACHMENT 2 3.3.6.3 A.6CTS 3.2.H states that the limiting conditions for operati on for the instrumentation listedin Table 3.2.7 shall be met. CTS Table 3.2.7 specifies the "Trip Setting" for each LLSisolation instrumentation Function. ITS LCO 3.3.6.3 requi res the LLS instrumentationfor each Function in Table 3.3.6.3-1 to be OPERABLE and ITS Table 3.3.6.3-1 specifiesthe "Allowable Value" for each LLS instrumentation Function. This changes the CTS byreplacing the term "Trip Setting" with "Allowable Value."Table 3.3.6.3-1Table 3.2.7 3.3.6.3 A.7CTS Table 4.14.1 Note (1) stat es that functional tests, calibrations, and sensor checksare not required when these instruments are not requir ed to be OPERABLE or are tripped. In addition, the Note states that if tests are missed, they shall be performedprior to returning the systems to an operable status. These explic it requirements are notretained in ITS 3.3.6.3. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.14.1 Note (1) 3.3.6.3 A.8These changes to CTS Table 3.2.7 and CTS T able 4.2.1 are provi ded in the MonticelloITS consistent with the Technical Spec ifications Change Request submitted to theUSNRC for approval in NMC letter L-MT-04-036, from Thomas J. Palmisano (NMC) to
USNRC, dated June 30, 2004, and granted in Amendment 144, (ADAMS AccessionNo.: ML053570161), dated January 12, 2006. As su ch, this change is administrative. Table 3.3.6.3-1Table 3.2.7, Table 4.2.1 (S/RV LLS
Logic)3.3.7.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.7.13.2.I, 4.2, Table 3.2.9, Table 4.2.1 (Control
Room Habitability
Protection) 3.3.7.1 A.2CTS Table 3.2.9 Note (1) allows, in part, an instrument channel to be bypassed fortesting for up to 8 hours0.333 days <br />0.0476 weeks <br />0.011 months <br />. ITS 3.3.7.1 Surve illance Requirements Note provides a similarallowance, but limits the allowance to only when the Control Room Radiation - HighFunction maintains CREF initiation capability. This changes the CTS by explicitlystating that the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> allowance can only be used if the other Control Room Radiation -
High channel is OPERABLE.
3.3.7.1 Surveillance Requirements NoteTable 3.2.9 Note (1) 3.3.7.1 A.3CTS Table 3.2.9 Required Condition A or B applies each time a radiation channel isinoperable. This CTS Action does not limit the number of channels to which this Actioncan simultaneously apply. ITS 3.3.7.1 ACT IONS Note states "Separate Condition entryis allowed for each channel." This changes the CTS by adding an explicit Note for separate condition entry for each channel.3.3.7.1 ACTIONS NoteTable 3.2.9 Required Conditions A and B 3.3.7.1 A.4CTS Table 4.2.1 Note (3) stat es that functional tests, calibrations, and sensor checksare not required when the syst ems are not required to be operable or are tripped. In addition, the Note states t hat if tests are missed, they shall be performed prior toreturning the systems to an operable status. These explicit requirements are notretained in ITS 3.3.7.1. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.2.1 Note (3)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 35 of 67 ATTACHMENT 2 3.3.7.1 A.5CTS Table 4.2.1 Note (5) stat es that a functional test of this instrument means the injection of a simulated signal into the instrument (not primary sensor) to verify the proper instrument channel response, alarm, and/or initiating action. These explicitrequirements are not retained in ITS 3.3.7.1. This changes the CTS by not including these explicit requirements.
1.0 definition of CHANNEL FUNCTIONAL TESTTable 4.2.1 Note (5) 3.3.7.1 A.6CTS 3.2.I.1 states that the Limiting C onditions for Operation for the radiationInstrumentation listed in Table 3.2.9 shall be met. CTS Table 3.2.9 specifies the "TripSettings" for the CREF System Function. ITS LCO 3.3.7.1 requires one channel per tripsystem for the Control Room Air Inlet Radiation - High Function to be OPERABLE andITS SR 3.3.7.1.3 specifies the "Allowable Value" for this Function. This changes theCTS by replacing the term "Trip Settings" with "Allowable Value."SR 3.3.7.1.3Table 3.2.9 3.3.7.1 A.7This change to CTS Table 4.2.1 is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, this change is administrative.SR 3.3.7.1.3Table 4.2.1 (Control Room Habitability Protection) 3.3.8.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.8.13.2.G, 4.2, Table 3.2.2 Function D, Table 3.2.6, Table 4.2.1 (Safeguards
Bus Voltage) 3.3.8.1 A.2CTS Table 3.2.6 specifies t he "Minimum No. of Operabl e or Operating InstrumentChannels Per Trip System." ITS Table 3.3.8.1-1 only specif ies the "REQUIREDCHANNELS PER BUS." This changes the CTS by changing the title of the "Minimum No. of Operable or Operating Instrument Channels Per Trip System" column to"REQUIRED CHANNELS PER BUS" and changi ng the number of channels for the Loss of Voltage channels from "2" to "4."Table 3.3.8.1-1Table 3.2.6 3.3.8.1 A.3CTS Table 3.2.6 Note (1) provides the Ac tion for inoperable required instrumentationchannels. When the minimum number of O PERABLE channels is less than required fora given Function, the appropriate channels or systems must be placed in the tripped condition or the plant must be in cold shutdown within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. This CTS Action doesnot limit the number of Functions or channels to which this Action can simultaneouslyapply. ITS 3.3.8.1 ACTIONS Note states "Separate Condition entry is allowed for eachchannel." This changes the CTS by adding an explicit Note for separate condition entry for each channel.3.3.8.1 ACTIONS NoteTable 3.2.6 Note (1)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 36 of 67 ATTACHMENT 2 3.3.8.1 A.4CTS Table 4.2.1 Safeguards Bus Voltage Inst rument Channel 2 spec ifies an "OperatingCycle" Frequency for the CHANNEL CALIBRATION requirement. ITS SR 3.3.8.1.3 requires the performance of a CHANNEL CALIBRATION every "24 months." Thischanges the CTS by changing the Frequency from once per "Operating Cycle" to "24 months."SR 3.3.8.1.3Tabl e 4.2.1 Safeguards Bus Voltage Instrument
Channel 2 3.3.8.1 A.5CTS Table 4.2.1 Note (3) stat es that functional tests, calibrations, and sensor checksare not required when the syst ems are not required to be OPERABLE or are tripped. In addition, the Note states t hat if tests are missed, they shall be performed prior toreturning the systems to an OPERABLE status. These explicit requirements are notretained in ITS 3.3.8.1. This changes the CTS by not including these explicit requirements.SR 3.0.1Table 4.2.1 Note (3) 3.3.8.1 A.6CTS 3.2.G states that the Limiting Conditi ons for Operation for the Instrumentationlisted in Table 3.2.6 shall be met. CTS Table 3.2.6 specifies the "Trip Setting" for eachLOP Instrumentation Function. ITS LCO 3.
3.8.1 requires the LOP instrumentations foreach Function in Table 3.3.8.1-1 to be OPERABLE and ITS Table 3.3.8.1-1 specifiesthe "Allowable Value" for each Function. This changes the CTS by replacing the term"Trip Setting" with "Allowable Value."Table 3.3.8.1-1Table 3.2.6 3.3.8.1 A.7This change to CTS Table 3.2.6 is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, this change is administrative.Table 3.3.8.1-1Table 3.2.6 3.3.8.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.3.8.23.1.C, 4.1.C 3.3.8.2 A.2CTS 3.1.C.1 does not specify when the RPS electric power monitoring assemblies arerequired to be OPERABLE. ITS 3.3.8.2 requires the RPS electric power monitoring assemblies to be OPERABLE in MODES 1, 2, and 3, MODES 4 and 5 with residualheat removal (RHR) shutdown cooling (SDC) suction isolation valves open, MODE 5with any control rod withdrawn from a core cell containing one or more fuel assemblies,during movement of recently irradiated fuel assemblies in the secondary containment,and during OPDRVs. This changes the CTS by specifying explicitly when the RPSelectric power monitoring assemblies are required to be OPERABLE.3.3.8.2 Applicability3.1.C.1 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 37 of 67 ATTACHMENT 2 3.3.8.2 A.3CTS 3.1.C.2 and CTS 3.1.
C.3 provide the option of eit her restoring the inoperable RPSelectric power monitoring channels to OPER ABLE status or removing the associatedRPS MG set or alternate power supply from service. ITS 3.3.8.2 Required Actions A.1and B.1 require the associated inservice power supply(s) to be removed from service. This changes the CTS by deleting the explicit allowance to restore the RPS electricpower monitoring channels to OPERABLE status.
3.3.8.2 Required Actions A.1 and B.1 3.1.C.2, 3.1.C.3 3.3.8.2 A.4CTS 4.1.C.2 specifies an "Operating Cycle" Frequency for the CHANNELCALIBRATION of the RPS electric power monitoring channels. ITS SR 3.3.8.2.3 requires the performance of a CHANNEL CALIBRATION of each overvoltage,undervoltage, and underfrequency time delay relay every "24 months." This changesthe CTS by changing the Frequency from once each "Operating Cycle" to "24 months."SR 3.3.8.2.34.1.C.2 3.3.8.2 A.5CTS 3.1.C.1 requires RPS electric power monitoring assemblies to be OPERABLE and specifies the "setpoints" for the overvoltage, undervo ltage, and underfrequencyFunctions. ITS LCO 3.3.8.2 requires the RPS electric power monitoring assemblies tobe OPERABLE and ITS SR 3.3.8.2.2 and SR 3.3.8.2.3 specify the "Allowable Value" foreach Function. This changes the CTS by replacing the term "setpoints" with "Allowable Value." SR 3.3.8.2.2, SR 3.3.8.2.3 3.1.C.1 3.4.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.4.13/4.5.F 3.4.1 A.2CTS 3.5.F.3.a.3 requires the Average Power Range Monitor (APRM) Rod Block setpoints to be adjusted if single recirculat ion loop operation is entered. ITS 3.4.1 doesnot include this requirement. This changes the CTS by deleting the requirement toadjust the APRM Rod Block setpoints w hen single recirculation loop operation isentered. The requirements for the APR M Rod Block have been relocated to theTechnical Requirements Manual (TRM), as described in the Discussion of Changes inITS 3.3.2.1. Therefore, a reference to this requirement in the ITS is not necessary. Any required changes to the APRM Rod Block setpoints will be controlled in accordance withchanges to the TRM. As such, since the S pecification has been relo cated, the deletionof this specific requirement, which is simply a cross-reference to the affectedSpecification, is acceptable. This c hange is designated as adm inistrative because itdoes not result in any technical changes to the CTS.None3.5.F.3.a.3 3.4.1 A.3CTS 3.5.F.4.a requires compliance with CTS 3.6.A.2 and CTS 3.5.F.3 for onerecirculation loop in operation. ITS 3.4.1 does not include this cross reference to otherrequirements. This changes the CTS by deleting references to other TS requirements.None3.5.F.4.a Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 38 of 67 ATTACHMENT 2 3.4.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.4.23/4.6.G 3.4.2 A.2When the jet pump requirements of CTS 3.6.G are not met, CTS 3.6.G requires the unitto be in cold shutdown (MODE 4). ITS 3.4.2 ACTION A only requires a shutdown toMODE 3. This changes the CTS by stating the unit must be in shutdown to MODE 3instead of to MODE 4. The purpose of CTS 3.6.G, in part, is to place the unit in acondition in which the jet pumps are not required to be OPERABLE. CTS 3.6.G requires the jet pumps to be OPERABLE in the Run mode (i.e., MODE 1). Thus, while the CTSAction requires a shutdown to MODE 4, in actuality, only a shutdown to MODE 2 is required. Once MODE 2 is achieved, conti nuation to MODE 4 is not required since the jet pumps are not required OPERABLE in MODES other then MODE 1. However, since the requirement that the jet pumps be OPERABLE in MODE 2 has been added (DOCM.1), ITS 3.4.2 ACTION A includes a shutdown to MODE 3. This change is acceptable because MODE 3 is outside the Applicability of the proposed Specification. Therefore, this change is considered a presentation preference change with the deletion of MODES 3 and 4 being made to be consistent with the actual CTS LCO statement and the inclusion of MODE 3 being made to be consistent with the change discussed in DOC M.1. As such, this change is considered an adm inistrative change.3.4.2 ACTION A3.6.G 3.4.2 A.3CTS 4.6.G.1 states that the jet pump OPERABILITY Surveillance must be performed by"recording" jet pump loop flows, recirculation pump flows, recirculation pump speeds,and individual jet pump D/P. ITS SR 3.4.2.1 does not include this requirement to recordthe stated parameters. This changes the CTS by deleting the explicit requirements torecord the unit parameters. The purpose of CTS 4.6.G.1 is to verify jet pumpOPERABILITY. This change is acceptable bec ause this requirement duplicates therequirements of 10 CFR 50 Appendix B, Section XVII (Quality Assurance Records):
maintain records of activities affecting quality, including the results of tests (i.e.,Technical Specification Surveillances). Compliance with 10 CFR 50 Appendix B isrequired by the Monticello Operating License. The details of the regulations within theTechnical Specifications are repetitious and unnecessary. Therefore, retaining the requirement to perform the associated Surv eillances and eliminating the details fromTechnical Specifications that are found in 10 CFR 50 Appendix B is considered a presentation preference. As such, this change is considered an administrative change.None4.6.G.1 3.4.3 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.4.33/4.6.E Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 39 of 67 ATTACHMENT 2 3.4.3 A.2CTS 3.6.E.1 includes a cross reference to ot her Specifications "(note: Low-Low Set and ADS requirements are located in Specificat ion 3.2.H and 3.5.A, respectively)," thatgovern additional requirements associated with the S/RVs. CTS 4.6.E.2 includes a cross reference to Surveillance Requirements in CTS Table 4.2.1 associated with theLow-Low Set logic. These cross references to other Specifications or SurveillanceRequirements are not included in ITS 3.4.3. This changes the CTS by deleting the cross reference to other Specification requirements.None3.6.E.1, 4.6.E.2 3.4.3 A.3CTS 3.6.E.1 states, in part, that "sev en" S/RVs are required to be OPERABLE. However, CTS 3.6.E.1 also st ates that "8" valves shall be set within the prescribedlimits. ITS LCO 3.4.3 requires "seven" valves to be OPERABLE and ITS SR 3.4.3.1requires the verification that the safety func tion lift setpoints of the "required" S/RVs arewithin limits. This changes the CTS by only requiring the "required" valves to be set to the prescribed limits.LCO 3.4.3, SR 3.4.3.13.6.E.1 3.4.3 A.4These changes to CTS 4.6.E.1.a and CTS 4.6.E.1.b are provided in the Monticello ITSconsistent with the Technical Specific ations Change Request submitted to the USNRCfor approval in NMC letter L-MT-04-036, from Thomas J. Palmisano (NMC) to USNRC, dated June 30, 2004, and granted in Am endment 143, Sept.
30, 2005, ML052700252.
As such, these changes are administrative.SR 3.4.3.14.6.E.1.a, 4.6.E.1.b 3.4.4 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.4.43/4.6.D.1 3.4.5 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.4.53/4.6.D.2 3.4.5 A.2CTS 4.6.D.2.b requires a CHANNEL FUNCTIONAL TEST of the required leakage detection instrumentation (flow instruments only) and foot note ** states "A functional test of this instrument means injection of a simulated signal into the instrument (notprimary sensor) to verify the proper instru ment channel response alarm and/or initiatingaction." ITS SR 3.4.5.2 requires the performance of a CHANNEL FUNCTIONAL TEST,but the footnote words are not included. This changes the CTS by deleting themodifying words of the footnote.None4.6.D.2.b 3.4.5 A.3CTS 4.6.D.2.a requires a CHANNEL CALIBRATION of the primary containmentatmosphere particulate monitoring system at least once per operating cycle. CTS 4.6.D.2.b requires a CHANNEL CALIBRATION of the required leakage detection instrumentation at least once per operating cycle. ITS SR 3.4.5.3 requires similar testsevery "24 months." This changes the CTS by changing the Frequencies from once per"operating cycle" to "24 months."SR 3.4.5.34.6.D.2.a, 4.6.D.2.b Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 40 of 67 ATTACHMENT 2 3.4.5 A.4CTS 3.6.D.2.a allows 30 days to restore the inoperable drywell floor drain sumpmonitoring system to OPERABLE status. CTS 3.6.D.2.b allows the plant to operatecontinuously when the drywell particulate radioactivity monitoring system is inoperableas long as grab samples of the primary containment atmosphere are analyzed every 12hours. CTS 3.6.D.2.a and CTS 3.6.D.2.b both incl ude a footnote
- that states, "A modechange is allowed when this system is inoperable." ITS 3.4.5 ACTION A covers the condition when LCO 3.4.5.a is not met (i.e., both the drywell floor drain sump monitoringsystem and the drywell equipment drain sump monitoring system are inoperable), andrequires LCO 3.4.5.a to be met in 30 days.
A Note is also included that states LCO3.0.4.c is applicable. ITS 3.4.5 ACTION B covers the condition for when the drywellparticulate radioactivity monitoring system is inoperable, and requires a grab sample tobe analyzed every 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br />. However, it does not include a Note similar to the ACTIONA Note. This changes the CTS by deleting the modifying words of the footnote for thedrywell particulate radioactivity monitoring system. Other changes to CTS 3.4.6.D.2.a are discussed in DOC A.5.
3.4.5 Required Action A.1 3.6.D.2.a and 3.6.D.2.b footnote
- 3.4.5 A.5CTS 3.6.D.2.a requires the drywell floor drain sump monitoring system to beOPERABLE. CTS 3.6.D.2.a.1) covers the condition for an inoperable drywell floor drainsump monitoring system and it allows 30 days to restore the inoperable drywell floordrain sump monitoring system to OPERABLE status. CTS 3.6.D.2.c covers thecondition for all channels of both systems (drywell floor drain sump monitoring systemand drywell particulate radioactivity monitoring system) inoperable. ITS LCO 3.4.5.arequires either the drywell floor drain sump monitoring system or the drywell equipmentdrain sump monitoring system with the drywell floor drain sump overflowing into thedrywell equipment drain sump system. ITS 3.4.5 ACTION A covers the condition when LCO 3.4.5.a is not met, and requires LCO 3.4.5.a to be satisfied. ITS 3.4.5 ACTION Ccovers the condition when all "required" leakage detection systems are inoperable. Thischanges the CTS by providing the option to allow the drywell equipment drain sumpmonitoring system with the drywell floor drain sump overflowing into the drywellequipment drain sump system to be used instead of the drywell floor drain monitoringsystem and adjusts the Actions, as required. The NRC has previously stated, "Analternate to the drywell floor drain pump monitoring system is the drywell equipmentdrain sump monitoring system, provided the floor drain sump is overflowing to theequipment drain sump. The system becomes inoperable during periods when the floordrain sump level and flow indications are not capable of being monitored. Once thedrywell floor drain sump is overflowing to the equipment drain sump, NMC can use thedrywell equipment drain sump monitoring system to quantify leakage (i.e., unidentifiedleakage) into the floor drain sump. This alternate method gives added flexibility, andsafety is not reduced because unidentified l eakage is still being monitored and indicatedin the control room. Theref ore, the NRC staff finds t he proposed changes acceptable."3.4.5 ACTION A3.6.D.2.a, 3.6.D.2.a.1),
3.6.D.2.c Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 41 of 67 ATTACHMENT 2See Issuance of Amendment Re: Drywe ll Leakage and Sump Monitoring DetectionSystem (TAC No. MB7945) dated August 21, 2003 (ADAMS Accession No.:
3.4.6 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.4.63/4.6.C.1, 3.6.C.4 3.4.9 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.4.93/4.6.A, 3/4.6.B 3.4.9 A.2CTS 3.6.A.1 includes a limit for average ra te of reactor coolant temperature changeduring normal heatup and cooldown. CTS 3.6.A.
2 includes a limit for the differentialtemperature between an idle recirculation l oop and the reactor coolant temperature priorto an idle recirculation loop startup. CTS 3.6.B includes limitations on the reactor vessel temperature and pressure during various plant conditions. ITS LCO 3.4.9 states "RCS pressure, RCS temperature, RCS heatup and cooldown rates, and the recirculation pump starting temperature requirements shall be maintained within limits" and includesan Applicability of "At all times." The app licable limits are included in the SurveillanceRequirements associated with ITS 3.4.9. This changes the CTS by combining therequirements of CTS 3.6.A.1, CTS 3.6.A.2, and CTS 3.
6.B in one LCO, including the limits in the Surveillance Requirements, and providing an Applicability.3.4.93.6.A.1, 3.6.A.2, 3.6.B 3.4.9 A.3CTS 3.6.B.2 states that P/T limits of Figure 3.6.3 are applicable during a heatup by non-nuclear means "(except with the reactor vessel vented)" and CTS 3.6.B.3 states thatP/T limits of Figure 3.6.4 are applicable during all operation wi th a critical core "otherthan...at times when the reactor vessel is vented." ITS LCO 3.
4.9 and SRs 3.4.9.1 and3.4.9.2 are applicable even when the reactor vessel is vented. This changes the CTSby requiring the applicable P/T limits to be met when the reactor vessel is vented.LCO 3.4.9 Applicability, SR 3.4.9.1, SR 3.4.9.2 3.6.B.2, 3.6.B.3 3.4.9 A.4CTS 4.6.A requires various RCS temper atures to be "recorded" during heatup andcooldowns. CTS 4.6.B.1 requires various RCS temperatures to be "recorded" duringthe inservice hydrostatic or leak testing. ITS SR 3.4.9.1 requires a verification that theRCS pressure and temperature and heatup and cooldown rates are within the applicable limits. This changes the CTS by delet ing the specific requi rement to "record" the temperatures.SR 3.4.9.14.6.A, 4.6.B.1 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 42 of 67 ATTACHMENT 2 3/4.6.H A.1These changes to CTS 4.6.H.1, CTS 4.6.H.3, and CTS 4.
6.H.6 are provided in theMonticello ITS consistent with the Tec hnical Specifications Change Request submitted to the USNRC for approval in NMC letter L-MT-04-036, from Thomas J. Palmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143 (ADAMS Accession No.: ML052700252), dated September 30, 2005. As such, these changes are administrative.None4.6.H.1, 4.6.H.3, 4.6.H.6 3/4.6.C.2, 3/4.6.C.3, 3/4.6.C.4 A.1CTS Figure 4.6.2 provides an illustration of the chloride stress corrosion test results ofstressed 304 stainless steel specimens. This figure is not included in the ITS. Thischanges the CTS by deleting Figure 4.6.2.NoneFigure 4.6.2 3.5.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.5.13/4.5.A, 3/4.5.B 3.5.1 A.2CTS 3.5.A.3.d specifies a condition for one of the two LPCI injection paths beinginoperable while CTS 3.5.A.3.e specifies a condition for two RHR pumps beinginoperable. Both CTS 3.5.A.3.d and CTS 3.5.A.3.e allow 7 days to restore the associated inoperabilities before requiring a unit shutdown. ITS 3.5.1 ACTION B (first Condition) provides the actions for one LPCI subsystem inoperable while ITS 3.5.1ACTION C provides the actions for one LPCI pump in each subsystem being inoperable. Both of the ACTIONS also allow a 7 day restoration time. This changes theCTS by specifying the LPCI inoperabilities with respect to a LPCI "subsystem" instead of LPCI "injection path" or "RHR pumps."3.5.1 ACTIONS B and C3.5.A.3.d, 3.5.A.3.e 3.5.1 A.3CTS 4.5.A.3.b requires the low pressure HPCI pump flow test to be performed once peroperating cycle. CTS 4.5.A.4 requires the performance of an automatic actuation test ofthe CS, LPCI, HPCI, and ADS Systems each operating cycle. CTS 4.5.A.4 alsorequires the cycling of each ADS valve and observing a compensatory turbine bypass or control valve position each operating cycle. ITS SR 3.5.1.9, SR 3.5.1.10, SR 3.5.1.11, and SR 3.5.1.12 require similar tests every "24 months." This changes the CTS bychanging the Frequencies from once per "operating cycle" to "24 months." SR 3.5.1.9, SR 3.5.1.10, SR 3.5.1.11 4.5.A.3.b, 4.5.A.4 3.5.1 A.4CTS 4.5.A.4 requires the perfo rmance of a simulated automat ic actuation test of theECCS subsystems. ITS SR 3.5.1.10 requires the performance of a similar test for theECCS injection/spray subsystems, howev er a Note has been included that states"Vessel injection/spray may be excluded." ITS SR 3.5.1.11 requires the performance ofa similar test for the ADS, however a Note has been included that states "Valveactuation may be excluded." This changes the CTS by provid ing clarification Notes thatexclude vessel injection/spray for the ECCS injection/spray subsystems and valve actuation for the ADS.
SR 3.5.1.10 Note, SR 3.5.1.11 Note 4.5.A.4 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 43 of 67 ATTACHMENT 2 3.5.1 A.5The ITS 3.5.1 ACTIONS include a Note that states LCO 3.0.4.b is not applicable toHPCI. The CTS does not include this Note. This changes the CTS by including the ACTION Note.3.5.1 ACTIONS NoteNone 3.5.1 A.6CTS 3.5.B.2 states that if one RHR intertie return line isolation valve is inoperable to either close the inoperable valve or close t he other return line isolation valve and the RHR suction line isolation valve.
No specific time is provi ded to complete this action. However, if the requirement in CTS 3.5.B.2 cannot be met, CTS 3.5.B.3 requires thereactor to be taken out of the Run mode within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. ITS 3.5.1 ACTION F covers the condition for inoperable RHR intertie return line isolation valve(s) in MODE 1 andrequires isolation of the RHR intertie line within 18 hours0.75 days <br />0.107 weeks <br />0.0247 months <br />. ITS 3.5.1 ACTION G coversthe condition when ACTION F is not met and it requires the unit to be in MODE 2 within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />. This changes the CTS by dividing the completion time in CTS 3.5.B.3 into two specific times; one time to isolate the RHR intertie line and one time to be in MODE 2. Other changes to CTS 3.5.B.2 (relative to how to isolate the RHR intertie line) are discussed in DOC LA.5.3.5.1 ACTIONS F and G3.5.B.2, 3.5.B.3 3.5.1 A.7This change to CTS 4.5.A.4 is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, this change is administrative.
SR 3.5.1.10, SR 3.5.1.114.5.A.4 3.5.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.5.23.5.E.1, 3.5.E.2, 3.7.A.1, 3.7.A.1.e, 3.7.A.1.f, 4.7.A.1.e 3.5.2 A.2CTS 3.5.E.1 and 3.5.E.2, in part, require low pressure ECCS subsystems to beOPERABLE during OPDRVs. While no actions are specified if a low pressure ECCSsubsystem becomes inoperable during OPDRVS, it is implicit that OPDRVs would haveto be suspended. ITS 3.5.2 ACTION B and Required Action C.1, which cover thecondition of one inoperable low pressure ECCS subsystem and two inoperable ECCS subsystems, respectively, require immedi ate action to be taken to suspend OPDRVs. This changes the CTS by clearly stating to suspend OPDRVS. Other changes to theimplicit CTS actions are de scribed in DOCs M.1 and L.1.3.5.2 ACTION B, 3.5.2 Required Action C.1 3.5.E.1, 3.5.E.2 3.5.2 A.3CTS 3.7.A.1.e requires suppression pool water level to be > - 4.0 and <
+3.0 inches. ITS SR 3.5.2.1.a requires the suppression pool water level to be > - 3 ft. This changesthe CTS by not including the upper suppression pool water level limit during shutdownconditions. The change to the lowe r limit is discussed in DOC L.7.SR 3.5.2.1.a3.7.A.1.e Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 44 of 67 ATTACHMENT 2 3.5.3 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.5.33/4.5.D 3.5.3 A.2The ITS 3.5.3 ACTIONS include a Note that states LCO 3.0.4.b is not applicable toRCIC. The CTS does not include this Note. This changes the CTS by including the ACTION Note.3.5.3 ACTIONS NoteNone 3.5.3 A.3CTS 4.5.D.1.b requires the low pressure RCIC pump flow test to be performed once peroperating cycle. CTS 4.5.D.2 requires the performance of an automatic actuation test ofthe RCIC System each refueling interval. IT S SR 3.5.3.3 and SR 3.
5.3.4 require similartests every "24 months." This changes the CTS by changing the Frequencies fromonce per "operating cycle" and each "r efueling interval" to "24 months."SR 3.5.3.3, SR 3.5.3.44.5.D.1.b, 4.5.D.2 3.5.3 A.4CTS 4.5.D.2 requires the perfo rmance of a simulated automat ic actuation test of theRCIC System. ITS SR 3.5.3.4 requires the performance of a similar test however, a Note has been included that states "Vessel injection may be excluded." This changesthe CTS by providing a clarification Note that excludes vessel injection for the RCICSystem.SR 3.5.3.4 Note4.5.D.2 3.5.3 A.5This change to CTS 4.5.D.2 is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, this change is administrative.SR 3.5.3.44.5.D.2 3.6.1.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.1.13.7.A.2.a.(1), 3.7.A.2.a.(4), 4.7.A.1.d, 4.7.A.2.a, 4.7.A.2.d, 4.7.A.4.a.(2), 1.0.P 3.6.1.1 A.2CTS 3.7.A.2.a.(1) references the CTS Section 1.0 Primary C ontainment Integritydefinition. ITS does not use this terminology; it requires the primary containment to beOPERABLE. This changes the CTS by deleting the reference to Primary ContainmentIntegrity and replaces it with a requirement for the primary containment to be OPERABLE.LCO 3.6.1.1, ACTION A3.7.A.2.a.(1), 3.7.A.2.a.(4),
4.7.A.2 3.6.1.1 A.3CTS 4.7.A.4.a.(2) requires the drywell to suppression chamber leakage to bedemonstrated "once per operating cycle." IT S SR 3.6.1.1.2 requires performance of asimilar test every "24 months." This changes the CTS by changing the Frequency from"Once each operating cycle" to "24 months."SR 3.6.1.1.24.7.A.4.a.(2)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 45 of 67 ATTACHMENT 2 3.6.1.1 A.4This change to CTS 4.7.A.1.c is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, this change is administrative.SR 3.6.1.1.14.7.A.1.c 3.6.1.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.1.23.7.A.3.c, 4.7.A.3.c.(1),
4.7.A.3.c.(2),
1.0.P 3.6.1.2 A.2ITS 3.6.1.2 ACTIONS Note 2 states "Ent er applicable Conditions and Required Actionsof LCO 3.6.1.1, "Primary Containment," when air lock leakage results in exceedingoverall primary containment leakage rate acceptance criteria." This requirement is notspecifically stated in the CTS. This changes the CTS by explicitly requiring the Primary Containment Actions be entered when the Primary Containment LCO is not met as a result of air lock leakage exceeding limits.3.6.1.2 ACTIONS Note 2None 3.6.1.2 A.3CTS 3.7.A.3.c requires the primary containment air lock to be OPERABLE wheneverthe Primary Containment Integrity is required. ITS LCO 3.6.1.2 requires the primary containment air lock to be OPERABLE during MODES 1, 2, 3. This changes the CTSby deleting a cross reference to the Primary Containment Integrity Applicability andreplacing it with the specific Applicability for the primary containment air lock.3.6.1.2 Applicability3.7.A.3.c 3.6.1.3 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.1.33.7.D, 3.7.A.2.a.(1),
3.7.A.2.a.(4),
4.7.D, 1.0.P 3.6.1.3 A.2CTS 3.7.D.1 includes the requirements for t he "automatic" PCIVs. CTS 3.7.A.2.a.(1) includes the requirements for all "manual" PCIVs since the CTS definition of PrimaryContainment Integrity includes these valves. ITS LCO 3.6.1.3 includes therequirements for both types of PCIVs. This changes the CTS by combining the requirements for all PCIVs in one LCO statement.LCO 3.6.1.33.7.D.1, 3.7.A.2.a(1) 3.6.1.3 A.3CTS 3.7.D.1 includes all requirements for "automatic" PCIVs, except for reactor building-to-suppression chamber vacuum breakers, which are covered under CTS3.7.A.3. ITS 3.6.1.3 also includes requirements for automat ic PCIVs, but the specific exclusion statement of, "except reacto r building-to-suppression chamber vacuumbreakers," is included in the ITS LCO 3.6.1.3 statement. This changes the CTS by adding a specific exclusion statement concerning the r eactor building-to-suppression chamber vacuum breakers.LCO 3.6.1.33.7.D.1, 3.7.A.3 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 46 of 67 ATTACHMENT 2 3.6.1.3 A.4CTS 3.7.D.2.a provides requirements to be taken for one or more penetration flow pathswith one PCIV inoperable while CTS 3.7.D.2.
b provides requirements to be taken forone or more penetration flow paths with two PCIVs inoperable. ITS 3.6.1.3 includes anexplicit Note (ACTIONS Note 2) that provi des instructions for the proper application ofthe ACTIONS for ITS compliance (i.e., Separate Condition entry is allowed for eachpenetration flow path). This changes the CTS by providing explicit direction as to howto utilize the ACTIONS when a PCIV is inoperable.3.6.1.3 ACTIONS Note 23.7.D.2.a, 3.7.D.2.b 3.6.1.3 A.5CTS 3.7.D does not specifically require Conditions to be entered for systems supportedby inoperable containment is olation valves. OPERABILITY of supported systems is addressed through the definition of OPERABILITY for each system, and appropriateLCO Actions are taken. ITS 3.6.1.3 ACTIONS Note 3 states "Enter applicableConditions and Required Actions for systems made inoperable by PCIVs." ITS LCO 3.0.6 provides an exception to ITS LCO 3.0.2, stating "When a supported system LCOis not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not r equired to be entered." This changes the CTS by adding a specific statement to require supported system Conditions and Required Actions be entered, whereas in the CTS this would be donewithout the Note.3.6.1.3 ACTIONS Note 3None 3.6.1.3 A.6CTS 3.7.D does not include a reference to entering applicable Conditions and Actions ofthe Primary Containment Integrity LCO (CTS 3.7.A.2) (changed to Primary ContainmentOPERABILITY in the ITS). ITS 3.6.1.3 ACTIONS Note 4 states "Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall contai nment leakage rate acceptance criteria." This changes the CTS by explicitly stati ng an existing requirement that the PrimaryContainment Specification ACTIONS be taken when the Primary Containment LCO is not met as a result of PCIV leakage exceeding limits.3.6.1.3 ACTIONS Note 4None 3.6.1.3 A.7CTS 4.7.D.1.a requires t he OPERABLE automatic PCIVs to be tested once peroperating cycle. CTS 4.7.D.1.b requires the primary system instrument line flow checkvalves to be tested once per operating cycle. ITS SR 3.6.1.3.5 requires verification of automatic PCIV isolation time, except for main steam isolation valves (MSIVs), every"24 months," while ITS SR 3.6.1.3.6 require s the verification of MSIV isolation timeevery "24 months." ITS SR 3.6.1.3.7 requires verification every "24 months" that each automatic PCIV actuates to the isolation position on an isolation signal. ITS SR3.6.1.3.8 requires verification every "24 months" that each excess flow check valve actuates on a simulated instrument line break to restrict flow to < 2 gpm. This changesthe CTS by changing the Frequency from "operating cycle" to "24 months." SR 3.6.1.3.5, SR 3.6.1.3.6, SR 3.6.1.3.7, SR 3.6.1.3.8 4.7.D.1.a, 4.7.D.1.b Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 47 of 67 ATTACHMENT 2 3.6.1.3 A.8CTS 4.7.D.1.b requires each primary system instrument line excess flow check valve(EFCVs) to be tested for proper operation. Per the CTS Bases, the OPERABILITY requirements are specified in a letter from L. O. Mayer (Northern States Power) to J. F.O'Leary (NRC) dated July 27, 1973. This letter requires the valves to limit leakage to amaximum of 2 gpm. ITS SR 3.6.1.3.8 r equires the verification that the reactorinstrumentation line EFCV act uates on a simulated instrument line break to restrict flow to < 2 gpm. This changes the CTS by specifying the leakage limit for the individual EFCVs.SR 3.6.1.3.84.7.D.1.b 3.6.1.3 A.9CTS 3.7.D.2.a requires restoring the inoperable valve to OPERABLE status within 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />, 8 hours0.333 days <br />0.0476 weeks <br />0.011 months <br />, or 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> (bas ed on the kind of valve) or requires at least one valve in each line having an inoperable valve to be deactivated in the isolated condition. CTS 3.7.D.2.b requires restoring the inoperable valves to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or requires at least one valve in each line havi ng inoperable valves to be deactivated in theisolated condition. CTS 3.7.
D.3.b requires restoring the inoperable valve(s) to withinleakage limits within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> or requires at least one valve in each line having a purgeand vent valve not within leakage limits to be deactivated in the isolated position. TheITS 3.6.1.3 ACTIONS do not include the spec ific option to restore the valve(s) to OPERABLE status or restore leakage to within leakage limits, but includes othercompensatory Required Actions to take with in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />, 8 hours0.333 days <br />0.0476 weeks <br />0.011 months <br />, or 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />, asapplicable. This changes the CTS by not explicitly stating the requi rement to restore aninoperable valve to OPERABLE status or to within leakage limits.None3.7.D.2.a, 3.7.D.2.b, 3.7.D.3.b 3.6.1.3 A.10CTS 4.7.D.2 and CTS 4.
7.D.3 require the pos ition of the deactiva ted and isolated valves or the isolation device(s) to be "recorded." ITS 3.6.1.3 R equired Actions A.2, C.2, andD.2 only include the requirement to "verify" the applicable valve is "closed." Thischanges the CTS by deleting t he specific requirement to "record" the valve position.
3.6.1.3 Required Actions A.2, C.2, and D.2 4.7.D.2, 4.7.D.3 3.6.1.3 A.11CTS 4.7.D.4 discusses the periodic Type C leakage testing of the 18 inch primarycontainment purge and vent valves (which is required by CTS 4.7.A.2.a). ITS SR 3.6.1.3.11 requires the perform ance of leakage rate testing for each 18 inch primarycontainment purge and vent valve with resilient seals in accordance with the PrimaryContainment Leakage Testing Program. This changes the CTS by stating to perform leakage rate testing for each 18 inch primary containment pur ge and vent valve inaccordance with the Primary Containment Leakage Testing Program.SR 3.6.1.3.114.7.D.4 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 48 of 67 ATTACHMENT 2 3.6.1.3 A.12CTS 1.0.P definition of Primary Containment Integrity states, in part, that all automatic containment isolation valves are OPERABLE "or are deactiva ted in the closed position or at least one valve in each line having an inoperable valve is closed." CTS 3.7.D.1requires all primary containm ent automatic isolation valves to be OPERABLE and CTS3.7.D.2 and CTS 3.7.
D.3 provide the actions that must be taken when the valves are not OPERABLE, and include similar requirements as are in the CTS 1.0.P definition. ITS LCO 3.6.1.3 requires all PCIVs to be OPERABLE and the appropriate compensatoryactions for PCIVs are included in the ITS 3.6.1.3 ACTIONS. This changes the CTS bydeleting the explicit CTS Primary Containment Integrity definition for when an automatic containment isolation valve is not OPERABLE.None1.0.P 3.6.1.5 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.1.53.2.H, Table 3.2-7, 3.6.E.1 3.6.1.6 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.1.63.7.A.3, 4.7.A.3.a 3.6.1.6 A.2CTS 3.7.A.3.a requires "two" reactor building-to-suppression chamber vacuum breakersto be OPERABLE. ITS LCO 3.6.1.6 require s "each" reactor building-to-suppression chamber vacuum breakers to be OPERABLE. This changes the CTS by using the term"each" instead of the actual number of vacuum breakers.LCO 3.6.1.63.7.A.3.a 3.6.1.7 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.1.73.7.A.4, 4.7.A.4, Figure 3.7.1 3.6.1.7 A.2CTS 4.7.A.4.a.(4) requires t he opening setpoint of the va cuum breakers to be testedonce each "operating cycle." ITS SR 3.6.1.7.3 requires a similar verification every "24 months", that each vacuum breaker opening setpoint is le ss than or equal to 0.5 psid. This changes the CTS by changing the Frequency from "operating cycle" to "24 months."SR 3.6.1.7.34.7.A.4.a.(4)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 49 of 67 ATTACHMENT 2 3.6.1.8 A.1CTS 3.7.A.2.a.(2) states that the Primary Containment Integrity is not required whenperforming low power physics tests at atmospher ic pressure during or after refueling atpower levels not to exceed 5 MW(t). The ITS does not include this allowance. Thischanges the CTS by deleting the allowance to not require Primary C ontainment Integrity(changed to Primary Containment OPERABILITY as described in DOC A.2) duringcertain low power physics tests.3.6.1.83.5.C.1, 3.5.C.2, 3.5.C.3, 4.5.C.1 3.6.1.8 A.2CTS 3.5.C.1 Footnote *, which states "For allowed out of service times for the RHR pumps see Section 3.5.A," is a cross refer ence to another Specific ation that providesadditional requirements associated with the RHR pumps. This cross reference is notincluded in ITS 3.6.1.8. This changes the CTS by deleting the cross reference to other Specification requirements.None3.5.C.1 Footnote
- 3.6.2.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.2.13.7.A.1, 3.7.A.1.a, 3.7.A.1.b, 3.7.A.1.c, 3.7.A.1.d, 3.7.A.1.f, 4.7.A.1.a, 4.7.A.1.b, 4.7.A.1.d 3.6.2.1 A.2CTS 3.7.A.1.a requires wa ter temperature to be < 90°F during the condition of normaloperation. ITS 3.6.2.1 restates this condition as THERMAL POWER > 1% RTP. Thischanges the CTS by restating the term normal operation in a more specific form used inthe ITS.LCO 3.6.2.1.a3.7.A.1.a 3.6.2.1 A.3Whenever there is indication of relief valv e operation that adds heat to the suppressionpool, CTS 4.7.A.1.b requires suppression pool temperature be continuously monitored, and to also be observed and logged every 5 minutes until the heat addition is terminated. Under similar conditions (as modified by DOC M.5), ITS SR 3.6.2.1.1 requires suppression pool temperature to be verified (which is analogous to observed)to be within the applicable limit once per 5 minutes. This changes the CTS by deletingthe requirements to continuously monitor and log every 5 minutes suppression pooltemperature. The every 5 minute logging r equirement duplicates the requirements of 10 CFR 50 Appendix B, Section XVII (Quality A ssurance Records) to maintain recordsof activities affecting quality, including the results of tests (i.e., Technical Specification Surveillances).While the CFR does not specifically state to "log" this item every 5 minutes, since ITS SR 3.6.2.1.1 is required to be performed every 5 minutes, t hen it must be recorded (i.e.,logged) to comply with the CFR requirement. The applicable MNGP procedure will
continue to require the value to be logged every 5 minutes to ensure compliance withthe ITS SR 3.6.2.1.1 requirement and 10 CFR 50 Appendix B, Section XVII.
SR 3.6.2.1.14.7.A.1.b Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 50 of 67 ATTACHMENT 2 3.6.2.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.2.23.7.A.1, 3.7.A.1.e, 3.7.A.1.f, 4.7.A.1.e 3.6.2.3 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.2.33.5.C.1, 3.5.C.2, 3.5.C.3, 4.5.C.1 3.6.2.3 A.2CTS 3.5.C.1 Footnote *, which states "For allowed out of service times for the RHR pumps see Section 3.5.A," is a cross refer ence to another Specific ation that providesadditional requirements associated with the RHR pumps. This cross reference is notincluded in ITS 3.6.2.3. This changes the CTS by deleting the cross reference to other Specification requirements.None3.5.C.1 Footnote
- 3.6.3.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.3.13.7.A.5, 4.7.A.5 3.6.3.1 A.2CTS 4.7.A.5 states that whenever inerting is required, the primary containment oxygen concentration shall be measured and recorded on a weekly basis. Under similarconditions, ITS SR 3.6.3.1.1 requires a verifi cation that the primary containment oxygenconcentration is within limits, but does not in clude this requirement to record the primarycontainment oxygen concentration. This changes the CTS by deleting the explicit requirement to record the primary containment oxygen concentration.SR 3.6.1.3.14.7.A.5 3.6.4.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.4.13.7.C.1, 3.7.C.2, 3.7.C.4, 4.7.C.1.a, 1.0.W Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 51 of 67 ATTACHMENT 2 3.6.4.1 A.2CTS 3.7.C.1 requires the Secondary Containment Integrity to be maintained and CTS1.0.W and CTS 3.7.C.2 use the term Secondary Containment Integrity. ITS LCO 3.6.4.1 requires the secondary containment to be OPERABLE. This changes the CTSby deleting the specific Secondary Containment Integrity term and replacing it with arequirement for the secondary containment to be OPERABLE.LCO 3.6.4.13.7.C.1, 3.7.C.2, 1.0.W 3.6.4.1 A.3CTS 3.7.C.1 specifies requirements for the secondary containment during "all modes ofplant operation." However, CTS 3.7.C.2 states that secondary containment is notrequired "when all of the list ed conditions are satisfied," and provides a list of sixconditions (CTS 3.7.C.2.a through f). ITS LCO 3.6.4.1 specifies requirements for thesecondary containment in the positive sense (when the secondary containment isrequired to be OPERABLE). This changes the CTS by specifying the requirements forthe secondary containment w hen it is required to be OPERABLE instead of when it is not required to be OPERABLE. Changes to the list of six conditions is discussed in DOCs M.1 and L.1.LCO 3.6.4.13.7.C.1, 3.7.C.2 3.6.4.1 A.4CTS 4.7.C.1.a requires the secondary containment capability test to be performed at"each refueling interval." ITS SR 3.6.4.1.4 requires this same test, however it isrequired to be performed every "24 months." This changes the CTS by changing theFrequency from "each refueling interval" to "24 months."SR 3.6.4.1.44.7.C.1.a 3.6.4.1 A.5CTS 3.7.C.4.b requires the unit to suspend handling of recently irradiated fuel. ITS3.6.4.1 ACTION C includes the same requirement, however, ITS 3.6.4.1 Required Action C.1 includes a Note that states that LCO 3.0.3 is not applicable. This changesthe CTS by adding this Note.
3.6.4.1 Required Action C.1 Note 3.7.C.4.b 3.6.4.1 A.6These changes to CTS 3.7.C.2.c, CTS 3.7.C.2.d, and CTS 3.7.C.4, and the addition ofCTS 3.7.C.2.d and e are provided in the Monticello ITS consistent with the Technical Specifications Change Request submitted to the USNRC for approval in NMC letter L-MT-05-013, from Thomas J. Palmisano (N MC) to USNRC, dated April 12, 2005. As such, these changes are administrative.3.6.4.13.7.C.2.c, 3.7.C.2.d, 3.7.C.4, 3.7.C.2.d, 3.7.C.2.e 3.6.4.1 A.7This change to CTS 4.7.C.1.a is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, this change is administrative.SR 3.6.4.1.44.7.C.1.a 3.6.4.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.4.23.7.C.1, 3.7.C.2, 3.7.C.3, 3.7.C.4, 3.7.C.5, 4.
7.C.1.b, 1.0.W Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 52 of 67 ATTACHMENT 2 3.6.4.2 A.2CTS 3.7.C.1 requires the Secondary Containment Integrity to be maintained and CTS 3.7.C.2 uses the term Secondary Containment Integrity. CTS 1.0.W, the SecondaryContainment Integrity def inition, in part, states that the reactor building is closed. This definition is interpreted to mean that all secondary containment penetrations are closed (i.e., penetrations including manual valves and are required to be closed during accident conditions). CTS 1.0.W.3 also requires all reactor building ventilation system automaticvalves to be OPERABLE. ITS LCO 3.
6.4.2 requires the Secondary Containment Isolation Valves (SCIVs) to be OPERABLE. This changes the CTS by including the requirements for SCIVs (i.e., manual va lves, blind flanges, and reactor building automatic valves) in a separate Specification.LCO 3.6.4.23.7.C.1, 3.7.C.2, 1.0.W 3.6.4.2 A.3CTS 3.7.C.1 specifies requirements for the secondary containment during "all modes ofplant operation." However, CTS 3.7.C.2 states that secondary containment is notrequired "when all of the list ed conditions are satisfied," and provides a list of sixconditions (CTS 3.7.C.2.a through f). ITS LCO 3.6.4.2 specifies requirements for thesecondary containment isolat ion valves in the positive sense (when the secondary containment isolation valves are required to be OPERABLE). This changes the CTS byspecifying the requirements for the secondary containment isolation valves when theyare required to be OPERABLE instead of when they are not required to be OPERABLE.LCO 3.6.4.23.7.C.1, 3.7.C.2 3.6.4.2 A.4CTS 3.7.C.3 provides requirements to be taken for one or more penetration flow pathswith a SCIV inoperable. ITS 3.6.4.2 includes an explicit Note (ACTIONS Note 2) that provides instructions for the proper application of the ACTIONS for ITS compliance (i.e.,Separate Condition entry is allowed for each penetration flow path). This changes theCTS by providing explicit direction as to how to utilize the ACTIONS when a SCIV is inoperable.3.6.4.2 ACTIONS Note 23.7.C.3 3.6.4.2 A.5CTS 3.7.C.3 does not specifically require Conditions to be entered for systemssupported by inoperable secondary containment isolation valves. OPERABILITY ofsupported systems is addressed through the definition of OPERABILITY for eachsystem, and appropriate LCO Actions are taken. ITS 3.6.4.2 ACTIONS Note 3 states"Enter applicable Conditions and Required Actions for systems made inoperable bySCIVs." ITS LCO 3.0.6 provides an exception to ITS LCO 3.0.2, stating "When asupported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are notrequired to be entered." This changes the CTS by adding a specific statement torequire supported system Conditions and Required Actions be entered, whereas in theCTS this would be done without the Note.3.6.4.2 ACTIONS Note 3None Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 53 of 67 ATTACHMENT 2 3.6.4.2 A.6CTS 3.7.C.3 requires restori ng the inoperable damper to OPER ABLE status or isolatingthe affected duct by use of a closed damper or blind flange within eight hours. ITS3.6.4.2 ACTIONS do not include the specific option to rest ore the valves to OPERABLE status, but includes other compensatory Required Actions to take within 8 hours0.333 days <br />0.0476 weeks <br />0.011 months <br />. Thischanges the CTS by not explicitly stating the requirement to restore an inoperable valve to OPERABLE status.None3.7.C.3 3.6.4.2 A.7CTS 3.7.C.3 states the actions that must be taken w hen the reactor building ventilationsystem automatic isolati on dampers (valves) are not OPERABLE and requires thevalves to be isolated by a closed damper or blind flange. In addition, CTS 1.0.W.3 requires all reactor building ventilation sy stem automatic isolation valves to be OPERABLE or "secured in the closed position." ITS 3.6.4.2 ACTION A coversinoperabilities associated with these penetra tions and requires the affected penetrationflow path to be isolated by use of at least one closed "and de-activated automatic valve," closed manual valve, or blind flange. This changes the CTS by incorporating theexplicit CTS definition stat ement concerning the option to have the penetration "securedin the closed position" into ITS 3.6.4.2 ACTION A. The change that allows use of a manual valve is discussed in DOC L.4.3.6.4.2 ACTION A3.7.C.3, 1.0.W.3 3.6.4.2 A.8CTS 4.7.C.1.b.(1) requires ve rification that each automatic damper actuates to its isolation position "each refueling interval." ITS SR 3.6.4.2.3 requires a similar test every"24 months." This changes the CTS by changing the Frequency from "refueling interval" to "24 months."SR 3.6.4.2.34.7.C.1.b.(1) 3.6.4.2 A.9CTS 3.7.C.4.b.2 require s the unit to suspend handling of recently irradiated fuel. ITS3.6.4.2 ACTION D includes the same requirement; however, ITS 3.6.4.2 Required Action D.1 includes a Note that states t hat LCO 3.0.3 is not applicable. This changesthe CTS by adding this Note.
3.6.4.2 Required Action D.1 Note 3.7.C.4.b.2 3.6.4.2 A.10These changes to CTS 3.7.C.2.c, CTS 3.7.C.2.d, and CTS 3.7.C.4, and the addition ofCTS 3.7.C.2.d and e are provided in the Monticello ITS consistent with the Technical Specifications Change Request submitted to the USNRC for approval in NMC letter L-MT-05-013, from Thomas J. Palmisano (N MC) to USNRC, dated April 12, 2005. As such, these changes are administrative.3.6.4.23.7.C.2.c, 3.7.C.2.d, 3.7.C.4, 3.7.C.2.d, 3.7.C.2.e 3.6.4.2 A.11This change to CTS 4.7.C.1.b.(1) is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, this change is administrative.SR 3.6.4.2.34.7.C.1.b.(1)
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 54 of 67 ATTACHMENT 2 3.6.4.3 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.6.4.33.7.B.1, 3.7.B.2.c, 4.7.B.1, 4.7.B.2.d, 1.0.W 3.6.4.3 A.2CTS 3.7.B.1 requires the SGT System to be OPERABLE whenever the secondarycontainment integrity is required and CTS 3.7.B.1.a references the conditions of CTS 3.7.C.2.(a) through (f). IT S LCO 3.6.4.3 requires the SGT System to be OPERABLE during MODES 1, 2, and 3, during movement of recently irradiated fuel assemblies inthe secondary containment, and during operations with a potential for draining thereactor vessel (OPDRVs). This changes the CTS by deleting a cross reference to thesecondary containment Applicability and replacing it with the specific Applicability for theSGT System.LCO 3.6.4.3 Applicability3.7.B.1, 3.7.B.1.a 3.6.4.3 A.3CTS 3.7.B.1.c.2)(b)(1) and 3.
7.B.1.d state to immediately suspend movement ofrecently irradiated fuel assemblies in the secondary containment. ITS 3.6.4.3 ACTIONSC and E include the same requirement, howev er a Note has been added that states thatLCO 3.0.3 is not applicable. This changes the CTS by adding this Note.
3.6.4.3 ACTIONS C and E Note 3.7.B.1.c.2)(b)(1), 3.7.B.1.d 3.6.4.3 A.4CTS 3/4.7.B.2 specifies the performance requirements for the SGT subsystems whileCTS 3/4.7.B.3 specifies t he post maintenance requirements for the SGT subsystems. ITS 3.6.4.3.2 requires the performance of the required SGT f ilter testing in accordancewith the Ventilation Filter Testing Program (VFTP). CTS 3/4.7.B does not include aVFTP, but the requirements that make up the VFTP are being moved to ITS 5.5. Thischanges CTS by requiring testing in accordance with the VFTP, whose requirementsare being moved to ITS 5.5.SR 3.6.4.3.23/4.B.2, 3/4.B.3 3.6.4.3 A.5CTS 4.7.B.2.d requires verifi cation of automatic initiation of each SGT subsystem each"operating cycle." ITS SR 3.6.4.3.3 requires this same test however it is required to beperformed every "24 months." This changes the CTS by changing the Frequency from"operating cycle" to "24 months."SR 3.6.4.3.34.7.B.2.d 3.6.4.3 A.6CTS 3.7.B.1 allows one SGT subsystem to be inoperable with reactor water temperature >
212F for 7 days "provided that all active components in the otherstandby gas treatment system are operable." ITS 3.6.4.3 does not explicitly state thisrequirement in the ACTION for one inoperable SGT subsystem. This changes the CTSby deleting a provision to when the 7 day allowed outage time is applicable.None3.7.B.1 3.6.4.3 A.7These changes to CTS 3.7.B.1, CTS 3.7.B.1.a, and CTS 3.7.B.1.b, and the addition ofCTS 3.7.B.1.c and d are provided in the Monticello ITS consistent with the Technical Specifications Change Request submitted to the USNRC for approval in NMC letter L-MT-05-013, from Thomas J. Palmisano (N MC) to USNRC, dated April 12, 2005. As such, these changes are administrative.3.6.4.33.7.B.1, 3.7.B.1.a, 3.7.B.1.b, 3.7.B.1.c, 3.7.B.1.d Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 55 of 67 ATTACHMENT 2 3.6.4.3 A.8This change to CTS 4.7.B.2.c is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, this change is administrative.SR 3.6.4.3.34.7.B.2.c 3.7.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.7.13.5.C 3.7.4 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.7.43.17.B.1, 3.17.B.2.c.(3),
4.17.B.1, 4.17.B.2.c, 4.17.B.2.c.(3) 3.7.4 A.2CTS 4.17.B.1 states to operate each CREF subsystem for at least 10 hours0.417 days <br />0.0595 weeks <br />0.0137 months <br /> with theheaters "operable." ITS SR 3.7.4.1 requires the CREF System to operate with theheaters "operating." This changes the CTS by requiring the CREF heaters to be"operating" in lieu of being "operable" during the test.SR 3.7.4.14.17.B.1 3.7.4 A.3Under certain conditions, CTS 3.17.B.1.c and 3.17.B.
1.d, in part, require the immediatesuspension of movement of recently i rradiated fuel assemblies in the secondarycontainment. ITS 3.7.4 ACTIONS D and F include the same requirement; however, a
Note has been added that states that LCO 3.0.3 is not applicable. This changes theCTS by adding this Note.3.7.4 ACTIONS D and F Note 3.17.B.1.c, 3.17.B.1.d 3.7.4 A.4CTS 3/4.17.B.2 specifies the performance requirements for the CREF subsystems whileCTS 3/4.17.B.3 specifies the post maintenance requirements for the CREF subsystems. ITS SR 3.7.4.2 requires the performance of the required CREF filter testing inaccordance with the Ventilation Filter Testing Program (VFTP). CTS 3/4.17.B does notinclude a VFTP, but the requirements that make up the program are being moved to ITS5.5. This changes the CTS by requiring testing in accordance with the VFTP, whoserequirements are being moved to ITS 5.5.SR 3.7.4.23/4.17.B.2, 3/4.17.B.3 3.7.4 A.5CTS 4.17.B.2.c requires verification of the OPERABILITY of each CREF subsystemeach "operating cycle." ITS SR 3.7.4.3 and ITS SR 3.7.4.4 require the same testinghowever the Surveillances are required to be performed every "24 months." Thischanges the CTS by changing the Frequency from "operating cycle" to "24 months." SR 3.7.4.3, SR 3.7.4.44.17.B.2.c 3.7.4 A.6These changes to CTS 3.17.B.1, CTS 3.17.B.1.c, and CTS 3.17.B.
1.d are provided inthe Monticello ITS consistent with the Technical Specifications Change Request submitted to the USNRC for approval in NMC letter L-MT-04-023, from Thomas J.
Palmisano (NMC) to USNRC, dated April 29, 2004. As such, these changes are administrative.3.7.4 Applicability, 3.7.4ACTIONS A and F 3.17.B.1, 3.17.B.1.c, 3.17.B.1.d Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 56 of 67 ATTACHMENT 2 3.7.4 A.7This change to CTS 4.17.B.2.c is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, this change is administrative.
SR 3.7.4.3, SR 3.7.4.4 4.17.B.2.c 3.7.5 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.7.53.17.A, 4.17.A 3.7.5 A.2Under certain conditions, CTS 3.17.A.2.c and CTS 3.
17.A.3.c, in part, require immediate suspension of movement of irradiated fuel assemblies in the secondary containment. ITS 3.7.5 ACTIONS C and E include the same requirement; however, a Note has been
added that states that LCO 3.0.3 is not applicable. This changes the CTS by adding this Note.3.7.5 ACTIONS C and E Note 3.17.A.2.c, 3.17.A.3.c 3.7.5 A.3These changes to CTS 3.17.A.1, CTS 3.17.A.2.c, and CTS 3.17.A.
3.c are provided inthe Monticello ITS consistent with the Technical Specifications Change Request submitted to the NRC for approval in NMC letter L-MT-04-023, from Thomas J.
Palmisano (NMC) to USNRC, dated April 29, 2004. As such, these changes are administrative.3.7.5 Applicability, 3.7.5ACTIONS C and E 3.17.A.1, 3.17.A.2.c, 3.17.A.3.c 3.7.6 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.7.63.8.A, 4.8.A 3.7.6 A.2CTS 3.8.A.1 requires the main condenser offgas activity to be within limit "Whenever the Steam Jet Air Ejectors (SJAEs) are in operation." CTS 4.8.A requires the maincondenser offgas activity Surveillance to be performed "after the SJAEs are in operation." ITS LCO 3.7.6 also requires the main condenser offgas activity to be withinlimit; however, the Applicability is MODE 1, and MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation. ITS SR 3.7.6.1 includesthe same SR to verify the main condenser offgas activity; however, a Note has been included that requires the Surveillance to be performed "after any main steam line is notisolated and SJAE in operation." This changes the CTS by clarifying that the LCO isalways applicable in MODE 1, and only in MODES 2 and 3 when any main steam line is
opened and a SJAE is in operation, and it also allows the Surveillance to be performedonly after both a main steam line is opened and a SJAE is in service.3.7.6 Applicability3.8.A.1, 4.8.A 3.7.8 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.7.83.10.C, 4.10.C Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 57 of 67 ATTACHMENT 2 3.7.8 A.2These changes to CTS 3.10.C and CTS 4.10.C are provided in the Monticello ITSconsistent with the Technical Specific ations Change Request submitted to the USNRCfor approval in NMC letter L-MT-05-013, from Thomas J. Palmisano (NMC) to USNRC, dated April 12, 2005. As such, these changes are administrative.
LCO 3.7.8, 3.7.8Applicability, SR 3.7.8.1 3.10.C, 4.10.C 3.7.8 A.3Under certain conditions, CTS 3.10.C, in part, requires immediate suspension of movement of irradiated fuel assemblies. ITS 3.7.8 ACTION A includes the samerequirement; however, a Note has been added that states that LCO 3.0.3 is notapplicable. This changes the CTS by adding this Note.3.7.8 ACTION A3.10.C 3.7.8 A.4CTS 4.10.C.2 requires verificati on that the spent fuel storage pool water level is withinlimit once every 7 days when i rradiated fuel assemblies ar e stored in the spent fuelstorage pool. This Surveillance is not included in ITS 3.7.8. This changes the CTS by deleting this Surveillance.None4.10.C.2 3.8.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.8.13.9.A, 3.9.B, 4.9.A, 4.9.B, 1.0.L 3.8.1 A.2The ITS 3.8.1 ACTIONS include a Note that st ates LCO 3.0.4.b is not applicable to theemergency diesel generators (EDGs). The CTS does not include this Note. Thischanges the CTS by including the ACTION Note.3.8.1 ACTIONS NoteNone 3.8.1 A.3CTS 4.9.B.3.a.1) requires, in part, a manual start of the EDGs while CTS 4.9.B.3.a.2)requires verification of EDG performance when simulating a loss of offsite power in conjunction with an Emergency Core Cooling System (ECCS) actuation test signal. ITS SR 3.8.1.2 also requires the EDGs to be started similar to CTS 4.9.B.3.a.1); however, it includes a Note (Note 1) that states all EDG starts may be preceded by an engineprelube period and followed by a warmup period prior to loading. ITS SR 3.8.1.12 requires verification of EDG performance during the actual or simulated conditions of a loss of coolant accident (LOCA) and loss of offsite power; however, it includes a Note (Note 1) that states all EDG starts may be preceded by an engine prelube period. Thischanges the CTS by adding Notes allowing a prelube period and a Note allowing a warmup period to the applicable Surveillance Requirements.
SR 3.8.1.2 Note 1, SR 3.8.1.12 Note 1 None 3.8.1 A.4CTS 4.9.B.3.a.1) requires, in part, a manual start of the EDGs. ITS SR 3.8.1.2 alsorequires the EDGs to be started; however, it includes a Note (Note 2) that states the amodified EDG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. This changes the CTS by adding the Note to the Surveillance Requirement.SR 3.8.1.2 Note 2None Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 58 of 67 ATTACHMENT 2 3.8.1 A.5CTS 4.9.B.3.a.1) requires, in part, that each EDG be loaded for > 60 minutes. ITS SR3.8.1.3 requires a similar test; however, it in cludes a Note (Note 1) that states the EDGloading may include gradual loading as recommended by the manufacturer, and a Note (Note 4) that states this SR shall be preceded by and immediately follow, withoutshutdown, a successful performance of SR 3.8.1.2. This changes the CTS by addingNotes to allow gradual loading and require the EDG loading test to immediately follow the EDG start test.
SR 3.8.1.3 Notes 1 and 4 None 3.8.1 A.6CTS 4.9.B.3.a.2) requires the simulation of a loss of offsite power in conjunction with an ECCS actuation signal test to be performed once each operating cycle. ITS SR3.8.1.12 requires a similar test every "24 months." This changes the CTS by changingthe Frequency from once per "Operating Cycle" to "24 months." SR 3.8.1.12 4.9.B.3.a.2) 3.8.3 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.8.33.9.B.3.b, 3.9.B.3.c, 4.9.B.3.b, 4.9.B.3.c 3.8.3 A.2CTS 3.9.B.3.b specifies require ments for diesel oil stored in the diesel oil storage tank. CTS 3.9.B.3.c specified requirements for the emergency diesel generator (EDG) airstarting receivers. CTS 3.9.B.3.b and CTS 3.9.B.3.
c state that thes e requirements are required to consider the associated EDG to be OPERABLE. ITS LCO 3.8.3 states, in part, that the stored diesel fuel oil and starting air subsystems shall be within limits foreach required EDG. The Applicability for this requirement is when associated EDG isrequired to be OPERABLE. This changes the CTS by combining the requirements for diesel fuel oil and starting air into one Specification.
LCO 3.8.3, including Applicability 3.9.B.3.b, 3.9.B.3.c 3.8.3 A.3CTS 3.9.B.3.c.1), CTS 3.9.B.3.c.2), and CTS 3.9.B.c.3) specify the compensatoryactions to take when the starting air pressure is not within limits for the associated EDG. ITS ACTIONS E, F, and G specify similar compensatory actions under the same condition. However, ITS 3.8.3 ACTIONS Note has been added and allows separateCondition entry for each EDG. This changes the CTS by explicitly stating that theActions are to be taken separately for each required EDG.3.8.3 ACTIONS Note3.9.B.3.c.1), 3.9.B.3.c.2),
3.9.B.3.c.3) 3.8.3 A.4CTS 4.9.B.3.b.3) specif ies a requirement to sample the diesel fuel and check for qualityonce a month. ITS SR 3.8.3.
3 requires the verification that fuel oil properties of newand stored fuel oil are tested in accordance with, and maintained within the limits of, theDiesel Fuel Oil Testing Program. This changes CTS by requiring testing in accordancewith the Diesel Fuel Oil Testing Program, whose requirements are being moved to ITS 5.5.8.SR 3.8.3.34.9.B.3.b.3) 3.8.4 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.8.43.9.A, 3.9.A.4, 3.9.B, 3.9.B.4, 3.9.B.5, 4.9.B.4, 4.9.B.5 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 59 of 67 ATTACHMENT 2 3.8.6 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.8.63.9.A, 3.9.A.4, 3.9.B, 3.9.B.4, 4.9.B.4 3.8.6 A.2CTS 3.9.A does not allow the reactor to be made critical unless the requirements in CTS3.9.A.4 are met. CTS 3.9.A.4, in part, requires the 125 VDC and 250 VDC batteries to be charged and in service and the associated battery chargers to be OPERABLE. Thus, the battery parameter requirements are covered by this LCO statement. ITS3.8.6 requires the battery parameters associated with the 125 VDC and 250 VDCbatteries to be within limits whenever the associated DC electrical power subsystemsare required to be OPERABLE. The require ments for the batteries and chargers areincluded in ITS 3.8.4 and ITS 3.8.5. This changes the CTS by dividing the requirementsfor the battery and the requirements for battery parameters into two separate Specifications, and specifies the Applicability of the Battery Parameter requirements tobe the same as the DC Sources they support.
3.8.6, including Applicability 3.9.A, 3.9.A.4 3.8.6 A.3CTS 4.9.B.4.c requires the "rated load discharge test" (i.e., a "performance dischargetest" in the ITS) to be performed, but it does not provide any restrictions for when thetest may be performed. ITS SR 3.8.6.6 requires the same test; however, a Note to SR 3.8.6.6 specifies that this Surveillance shall not normally be performed in MODE 1, 2, or3. However, portions of the Surveillance may be performed to reestablishOPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. In addition, the Note further states that credit may be taken for unplannedevents that satisfy the SR. This changes the CTS by adding a specific restriction as towhen the Surveillance can be performed. Currently, this Surveillance would notnormally be performed while operating (i.e., MODES 1, 2, and 3), since performing thisSurveillance would result in the inoperability of the associated battery, and the Actionsrequire a plant shutdown if the battery is inoperable. The ITS Note clearly presents thecurrent practice on when the test may be performed and the allowance of the current practice of taking credit for unplanned events, provided the necessary data is obtained.This change is designated as adm inistrative because it does not result in technicalchanges to the CTS.SR 3.8.6.6 Note4.9.B.4.c 3.8.6 A.4This change to CTS 4.9.B.4.c is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-04-036, from Thomas J. Pa lmisano (NMC) to USNRC, dated June 30, 2004, and granted in Amendment 143, Sept. 30, 2005, ML052700252. As such, this change is administrative.SR 3.8.6.64.9.B.4.c Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 60 of 67 ATTACHMENT 2 3.8.7 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.8.73.9.A, 3.9.A.3, 3.9.A.4, 3.9.B, 3.9.B.4 3.8.7 A.2CTS 3.9.A.4 requires the st ation 125 VDC and 250 VDC batteries to be charged and "inservice"; however, the CTS does not explicitly require the associated DC distributionpanels to be to be OPERABLE. ITS LCO 3.
8.7, in part, requires the Division 1 andDivision 2 DC electrical power distribution subsystems to be OPERABLE. This changesthe CTS by specifying the require ments for DC distribution buses.LCO 3.8.73.9.A.4 3.8.8 A.1The CTS does not contain any specific OPERABILITY requirements for the DistributionSystems during shutdown conditions. However, the CTS 1.0.W definition of OPERABLE requires that, for all equipment required to be OPERABLE, "all necessaryattendant ... normal and emergency electrical pow er sources ... that are required for thesystem, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s)." ITS LCO 3.8.8 requires thenecessary portions of the AC and DC electrical power distribution subsystem to be OPERABLE to support equipment required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment. If one ormore required AC or DC electrical power distribution subsystems are inoperable, ITS3.8.8 ACTION A must be entered and the a ssociated supported r equired features(s) must be declared inoperable or certai n activities must be suspended (COREALTERATIONS, movement of irradiated fuel assemblies in the secondary containment,and operations with a potential for draining the reactor vessel (OPDRVs)), action must be initiated to restore the inoperable distribution subsystem, and the required shutdowncooling subsystem(s) must be declared inoperable and not in operation. This changesthe CTS by adding the explicit requirements of ITS LCO 3.8.8 and ITS 3.8.8 ACTION A.
LCO 3.8.8, 3.8.8ACTION A 1.0.W 3.9.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.9.13.10.A, 4.10.A 3.9.1 A.2CTS 3.10.A requires the reactor mode switch to be in the refuel position during core alterations and the refueling interlocks to be OPERABLE. ITS LCO 3.9.1 only requires the refueling "equipment" interlocks associated with the reactor mode switch refuelposition to be OPERABLE. This changes the CTS by splitting the requirement of therefueling interlocks into two Specifications. All other refueling interlocks with the reactormode switch in the refuel position are covered in ITS 3.9.2.LCO 3.9.13.10.A Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 61 of 67 ATTACHMENT 2 3.9.1 A.3CTS 4.10.A requires refueling interlocks to be functionally tested. ITS SR 3.9.1.1 requires the same test on the required ref ueling equipment interlock inputs and providesa list of equipment interlocks. This changes the CTS by providing a specific list of refueling equipment interlocks.SR 3.9.1.14.10.A 3.9.1 A.4CTS 3.10.A states that the refueling interlocks are required to be operable "except as specified in specification 3.10.E." The ITS does not include this sentence. Thischanges the CTS by deleting this cro ss-reference to another Specification.None3.10.A 3.9.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.9.23.10.A, 4.10.A 3.9.2 A.2CTS 3.10.A requires the reactor mode switch to be in the refuel position during core alterations and the refueling interlocks to be OPERABLE. ITS LCO 3.9.2 only requires the refueling "position one-rod-out" interlock to be OPERABLE. This changes the CTSby splitting the requirement of the refueling interlocks into two Specifications. All otherrefueling interlocks with the reactor mode switch in the refuel position are covered in ITS 3.9.1.LCO 3.9.23.10.A 3.9.2 A.3CTS 3.10.A states that the refueling interlocks are required to be operable "except as specified in specification 3.10.E." The ITS does not include this sentence. Thischanges the CTS by deleting this cro ss-reference to another Specification.None3.10.A 3.9.5 A.1In the conversion of the Monticello CTSs to the plant specific Improved ITSs, certainchanges (wording preferences, editorial changes , reformatting, revised numbering, etc.)are made to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.9.53.3.D, 3.3.G, 4.3.D 3.9.5 A.2CTS 3.3.D states, in part, that if an inoperable control rod is inserted full in, it shall not be considered to have an inoperable accumulator. ITS LCO 3.9.5 states "Eachwithdrawn control rod shall be OPERABLE." ITS 3.9.5 ACTION A requires action to beinitiated immediately to fully insert any inoperable control rods. This changes the CTSby restating the existing control rod OPERABILITY requirement and specifying the implied action required to exit the OPERABILITY requirement.
LCO 3.9.5, 3.9.5ACTION A 3.3.D 3.9.5 A.3CTS 3.3.G.1 states, in part, if Specificati on 3.3.D is not met the unit must be in coldshutdown in 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. ITS LCO 3.9.5 is applicable only in MODE 5. This changes theCTS by deleting the reference to unit shutdown requirements associated with an inoperable control rod accumulator in Refuel Mode.None3.3.G.1 3.9.5 A.4This change to CTS 3.3.G is provided in the Monticello ITS consistent with theTechnical Specifications Change Request subm itted to the USNRC for approval in NMCletter L-MT-05-013, from Thomas J. Pa lisano (NMC) to USNRC, dated April 12, 2005.
As such, this change is administrative.3.9.5 ACTION A3.3.G.1 Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 62 of 67 ATTACHMENT 2 3.10.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.10.13.5.A.2, 3.5.D.1, 3.6.C.1.(b),
3.7.A.2.a.(3) 3.10.1 A.2CTS 3.5.A.2 requires the High Pressure Coolant Injection (HPCI) System and theAutomatic Depressurization System (ADS) to be OPERABLE whenever the reactor pressure is greater than 150 psig and irradi ated fuel is in the reactor vessel "exceptduring reactor vessel hydrostatic or leakage tests." CTS 3.5.D.1 requires the ReactorCore Isolation Cooling System (RCIC) to be OPERABLE whenever irradiated fuel is in the reactor vessel and reactor pressure is greater than 150 psig "e xcept during reactorvessel hydrostatic or leakage tests." CTS 3.
7.A.2.a.(3) states that Primary ContainmentIntegrity is not required when performing reactor vessel hydrostatic or leakage tests withthe reactor not critical. ITS LCO 3.10.1, in part, states that t he average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3 to allow performance of an inservice leak orhydrostatic test provided certain MODE 3 LCOs are met. ITS LCO 3.5.1, LCO 3.5.3,and LCO 3.6.1.1, which specify the requirements for the HPCI System and ADS, RCICSystem, and Primary Containment, respectively, are not among the MODE 3 LCOs thatare required to be met. This changes the CTS by deleting the explicit exception to notrequire the HPCI System, ADS, RCIC System, and Primary Containment to beOPERABLE during the reactor vessel hydrostatic or leakage tests.LCO 3.10.13.5.A.2, 3.5.D.1, 3.7.A.2.a.(3) 3.10.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.10.23.10.E 3.10.6 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).3.10.63.10.E 3.10.6 A.2CTS 3.10.E requires all fuel assemblies to be removed from the core cells associatedwith the control rods to be removed from the core. It does not make a statement about other control rods that have fuel assemblies in core cells containing one or more fuelassemblies. ITS LCO 3.10.6.b includes a stat ement that all other control rods in core cells containing one or more fuel assemblies must be fully inserted. This changes theCTS by adding a specific statem ent that all other control r ods in core cells containingone or more fuel assemblies must be fully inserted.LCO 3.10.6.b3.10.E Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 63 of 67 ATTACHMENT 2 3.10.6 A.3CTS 3.10.E requires the reactor mode switch to be in the Refuel position during extended core and control rod drive maintenance. ITS 3.10.6 specifies the Applicabilityto be MODE 5 with LCO 3.9.3, LCO 3.9.4, or LCO 3.9.5 not met. This changes the CTSby adding the explicit Applicability for multiple control rod withdrawal during refueling.
3.10.6 Applicability3.10.E 4.0 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).
45 5.1 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).5.16.1.A 5.2 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).5.26.1.A, 6.1.B, 6.1.C, 6.1.D, 6.1.F, Table 6.1.1 5.2 A.2CTS 6.1.C.2 states "At leas t one licensed operator shall be in the control room whenfuel is in the reactor." CTS 6.1.C.3 states "At least two licensed operators shall be present in the control room during cold startup, scheduled reactor shutdown, and duringrecovery from reactor trips." CTS 6.1.C.5 states "All alterations of the reactor core shall bedirectly supervised by a licensed Senior Reactor Operator or Senior Reactor OperatorLimited to Fuel Handling who has no other concurrent responsibilities during this operation." The ITS does not include these requirements. This changes the CTS by deleting theserequirements. This change is acceptable because the requirement s deleted from theTechnical Specifications are already required by 10 CFR 50.54(m)(2)(iii) and 10 CFR 50.54(m)(2)(iv) and the Monticello Operating License requires compliance with all NRCregulations. This change is designated as adm inistrative because it does not result intechnical changes to the CTS.None6.1.C.2, 6.1.C.3, 6.1.C.5 5.2 A.3CTS 6.1.D provides, in part, qualification requirements for the Shift Technical Advisor(STA), and requires the STA to have a bachelor
's degree or equivalent in a scientific orengineering discipline with specific training in plant design, and response and analysisof the plant for transients and accidents. ITS 5.2.2.f requires this individual to meet the qualification requirements of the Commission Policy Statement on EngineeringExpertise on Shift. This changes the CTS by referencing the Commission Policy
Statement on Engineering Expertise on Shi ft for qualification requirements instead of listing the specific qua lification requirements.5.2.2.f6.1.D Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 64 of 67 ATTACHMENT 2 5.2 A.4CTS Table 6.1.1 requires the total number of licensed and non-licensed operatorsduring MODES 4 and 5 (i.e., SHUTDOWN or REFUELING MODE and < 212°F) to be 3
and requires the total number of licensed and unlicensed operators during MODES 1, 2,and 3 (i.e., STARTUP or RUN MODE or > 212°F) to be 6. ITS 5.2.2.a requires the total number of non-licensed operators to be 1 in MODES 4 and 5 and to be 2 in MODES 1,2, and 3. This changes the CTS by specifically stating the tota l number of non-licensed operators required in MOD ES 1, 2, 3, 4, and 5.5.2.2.aTable 6.1.1 5.2 A.5CTS Table 6.1.1 Note 5 states "One LSO position shall be filled by an individual who meets the qualifications of a Shift Technical Advisor as defined in Section 6.1.D(2). If a qualified individual to staff the combined LSO/STA position is not available, a dedicatedShift Technical Advisor shall be on duty, in addition to two licensed senior operators." ITS 5.2.2, in part, requires the STA to m eet the qualifications specified by theCommission Policy Statement on Engineering Ex pertise on Shift; it does not include thisspecific information. This changes the CTS by deleting this specific information.NoneTable 6.1.1 Note 5 5.2 A.6CTS 6.1.B.1 specifies that the plant-specific titles of personnel fulfilling the responsibilities of the positions delineated in the Tec hnical Specifications are documented in the USAR or the Operational Quality Assurance Plan (OQAP). ITS 5.2.1.a includes a similar requirement, ex cept uses the docum ent title "QualityAssurance Topical Report" in lieu of the OQAP. This changes the CTS by using the most current document title.5.2.1.a6.1.B.1 5.3 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).5.36.1.C.8, 6.1.D 5.3 A.2CTS 6.1.C.8 states "Licens ed reactor operators and senior operators shall completequalification training in accordance with a Commission-approved training program that isbased on a systems approach to training and uses a simulation facility that is acceptable to the Commission." CTS 6.1.D, in part, states "licensed reactor operators and senior reactor operators sha ll meet the requirements of Specification 6.1.C.8." TheITS does not include these requirements. This changes the CTS by deleting theserequirements. The purpose of CTS 6.1.C.8 and 6.1.D part (4) is to provide training requirements for the licensed Senior Oper ators and Operators. 10 CFR 55 specifies these training requirements. This change is acceptabl e because the requirementsdeleted from the Technical Specifications are already required by 10 CFR 55 and the Monticello Operating License requires compliance with all NRC regulations. This change is designated as adminis trative because it does not result in technical changesto the CTS.None6.1.C.8, 6.1.D Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 65 of 67 ATTACHMENT 2 5.3 A.3ITS 5.3.2 states "For the purpose of 10 CFR 55.4, a lic ensed Senior Operator and a licensed Operator are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perfo rm the functions described in 10 CFR 50.54(m)." The CTSdoes not include such a statement. This changes the CTS by clarifying that these individuals must meet all of the qualification requirements referenced in ITS 5.3.1 and be capable of performing the functi ons described in 10 CFR 50.54(m).5.3.2None 5.4 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).5.46.5 5.5 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).5.56.8, 3/7.7.B.2, 3/4.7.B.3, 3/4.17.B.2, 3/4.17.B.3, 4.7.D.4, 4.
9.B.3.b.3) 5.5 A.2CTS 6.8.B includes the program requirements for the Primary Coolant Sources Outside Containment Program and incl udes a statement that a pr ogram acceptable to theCommission was described in a letter dated December 31, 1979, from L.O. Mayer, NSP, to Director of Nuclear Reactor R egulation, "Lessons Learned Implementation." ITS 5.5.2 contains the requirements for the Primary Coolant Sources OutsideContainment; however, the statement concerning a type of NRC-acceptable program isnot included. This changes the CTS by deleting this additional statement.None6.8.B 5.5 A.3CTS 6.8.M includes the program requirem ents for the Primary Containment LeakageRate Testing Program. CTS 6.8.M.1 incl udes an exception from the requirements ofRegulatory Guide 1.1.63, "P erformance-Based Containment Leak-Test Program," datedSeptember 1995. CTS 6.8.M.6 states that "Nothing in these Technical Specificationsshall be construed to modify the testing Frequencies required by 10 CFR 50, AppendixJ." This statement is not included in the ITS. This changes the CTS by deleting theCTS 6.8.M.6 statement.None6.8.M.6 5.5 A.4The Performance Requirements (CTS 3.7.B.2.a and CTS 3.7.B.2.b), Post MaintenanceRequirements (CTS 3.7.B.3.a and CTS 3.7.B.3.b), Performance Requirement Tests (4.7.B.2.a, 4.7.B.2.b, and 4.7.B.2.c), and Post Maintenance Testing (4.7.B.3.a and 4.7.B.3.b) requirements associated with the ventilation filter testing for the Standby GasTreatment (SGT) System and the Performance Requirements (CTS 3.17.B.2.a, CTS3.17.B.2.b, CTS 3.17.B.2.c.(1), and CTS 3.17.B.
2.c.(2)), Post MaintenanceRequirements (CTS 3.17.B.3.a and CTS 3.17.B.3.b), Performance Requirement Tests(CTS 4.17.B.2.a, CTS 4.17.B.2.b, CTS 4.17.B.2.c.(1), and CTS 4.17.B.2.c.(2)), andPost Maintenance Testing (CTS 4.17.B.3.a and CTS 4.17.B.3.
b) requirementsassociated with the ventilation filter testing for the Control Room Emergency Filtration(CREF) System have been placed in a program in the proposed Administrative Controls5.5.63.7.B.2.a, 3.7.B.2.b, 3.7.B.3.a, 3.7.B.3.b, 4.7.B.2.a, 4.7.B.2.b, 4.7.B.2.c, 4.7.B.3.a, 4.7.B.3.b, 3.17.B.2.a, 3.17.B.2.b, 3.17.B.2.c.(1),
3.17.B.2.c.(2),
3.17.B.3.a, 3.17.B.3.b, 4.17.B.2.a, 4.17.B.2.b, 4.17.B.2.c.(1),
Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 66 of 67 ATTACHMENT 2Chapter 5.0 (ITS 5.5.6). As such, a general program statement has been added as ITS 5.5.6. Also, a statement of the applicability of ITS SR 3.0.2 and SR 3.0.3 is needed toclarify that the allowances for Surveillance Frequency extension apply. This changesthe CTS by moving the ventilation filter testing Surveillances associated with the SGTand CREF Systems to a program in ITS 5.5 and specifically stating the applicability ofITS SR 3.0.2 and SR 3.0.3 in the program.
4.17.B.2.c.(2), 4.17.B.3.a, 4.17.B.3.b 5.5 A.5CTS 4.7.B.2.a requires the per formance of an in-place DOP test of the SGT System HEPA filter banks, an in-place test of the SGT charcoal adsorber banks withhalogenated hydrocarbon tracer, and a laboratory analysis of a carbon test sample fromthe SGT charcoal adsorber once per "operating cycle." CTS 4.7.B.2.c requires theperformance of the SGT System heater test once per "operating cycle." CTS 4.17.B.2.a requires the performance of an in-place DOP test of the CREF System HEPA filterbanks, an in-place test of the CREF charcoal adsorber banks with halogenatedhydrocarbon tracer, and a laboratory analysis of a carbon test sample from the CREFcharcoal adsorber once per "operating cycle." CTS 4.17.B.2.c requires the performanceof the CREF System heater test and comb ined filter pressure drop test once per"operating cycle." ITS 5.5.6 requires the same tests; however, the Surveillances arerequired to be performed every "24 months." This changes the CTS by changing theFrequency from "operating cycle" to "24 months."5.5.64.7.B.2.a, 4.7.B.2.c, 4.17.B.2.a, 4.17.B.2.c 5.5 A.6CTS 4.7.D.4 requires the repl acement of the seat seal of the drywell and suppressionchamber 18 inch purge supply and vent valves once per "six operating cycles." ITS 5.5.11.e requires the same replacement; however, the replacement is required every "9years." In addition, a statement of the applicability of ITS SR 3.0.2 has been added. This changes the CTS by changing the Frequency from "six operating cycles" to "9years" and specifically stating the applicability of ITS SR 3.0.2.5.5.11.e4.7.D.4 5.5 A.7The Surveillance associated with diesel fuel oil testing (CTS 4.9.B.3.b.3)) has been placed in a program in the proposed Administrative Controls Chapter 5.0 (ITS 5.5.8).
As such, a general program statement has been added as ITS 5.5.8. Also, a statementof the applicability of ITS SR 3.0.2 and SR 3.0.3 is needed to clarify that the allowancesfor Surveillance Frequency extension apply. This changes the CTS by moving the
diesel fuel oil testing Surveillance to a program in ITS 5.5 and specifically stating theapplicability of ITS SR 3.0.
2 and SR 3.0.3 in the program. Other changes to the Surveillance are discussed in DOCs M.2 and DOC L.2.5.5.84.9.B.3.b.3) 5.5 A.8CTS 6.8.G requires pump and valve testing per the requirements of Section XI of the ASME Boiler and Pressure Vessel Code. IT S 5.5.5 requires pump and valve testing per the requirements of the ASME Operation and Maintenance (OM) Code. This changesthe CTS by referring to the ASME OM Code instead of ASME Boiler and Pressure
Code,Section XI.5.5.66.8.G Table A - Administrative Changes ITS/CTS No. and DOC No.Description of ChangeITS RequirementCTS RequirementMonticello Page 67 of 67 ATTACHMENT 2 5.5 A.9These changes to CTS 4.7.B.2.a, CTS 4.7.B.2.b, CTS 4.
17.B.2.a, and CT S 4.17.B.2.care provided in the Monticello ITS consistent with the Technica l Specifications Change Request submitted to the USNRC for approval in NMC letter L-MT-04-036, fromThomas J. Palmisano (NMC) to USNRC, dat ed June 30, 2004. As such, these changes are administrative.5.5.64.7.B.2.a, 4.7.B.2.b, 4.17.B.2.a, 4.17.B.2.c 5.6 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).5.66.7, Table 3.14.1 Required
Condition A 5.6 A.2CTS 6.7 requires, in addition to the requirements of 10 CFR, reports be submitted to theU.S. Nuclear Regulatory Commission, Attn: Document Control Desk, Washington DC20555, unless otherwise noted. CTS 6.7.A.7.d requires t he COLR to be submitted tothe NRC Document Control Desk with copi es to the Regional Administrator andResident Inspector. ITS 5.6 requires that the reports be submitted in accordance with10 CFR 50.4. This changes the CTS by remo ving the specifics r egarding distribution of the reports to the NRC.5.66.7, 6.7.A.7.d 5.6 A.3CTS 6.7.A.7.a states, in part, that co re operating limits s hall be established and documented in the Core Operating Limits Report (COLR) before each reload cycle orany remaining part of a reload cycle for the "Power to Flow Map (Bases 3.1)." ITS
5.6.3.a does not include reference to the "Power to Flow Map (Bases 3.1)." Thischanges the CTS by removing the specific reference to "Power to Flow Map (Bases 3.1)."None6.7.A.7.a 5.6 A.4CTS 6.7.D requires special reports be submitted within the time period specified by eachreport. CTS Table 3.14.1 Required Condition A requires the preparation and submittal of aspecial report to the Commission pursuant to CTS 6.7.D. This is the only TechnicalSpecification that currently references CTS 6.7.D. The ITS does not include a SpecialReport requirement; all reports have their own individual titles. This changes the CTS bydeleting the reference to Special Reports. The special report requirement in CTS Table3.14.1 is required by ITS 5.6.4, as modified by DOC M.1.None6.7.D, Table 3.14.1 Required
Condition A 5.7 A.1 In the conversion of the Monticello CTSs to the plant specific ITSs, certain changes(wording preferences, editorial changes, re formatting, revised numbering, etc.) aremade to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).5.76.9