Text

Issuance of Amendment Adoption of TSTF-542, Reactor Pressure Vessel Water Inventory Control
	ML18250A075
Person / Time
Site:	Monticello
Issue date:	10/29/2018
From:	Robert Kuntz; Plant Licensing Branch III
To:	Church C; Northern States Power Company, Minnesota
	Kuntz R
References
	EPID L-2017-LLA-0360
	Download: ML18250A075 (89)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 o~tober 29, 2018 Mr. Christopher Church Site Vice President Monticello Nuclear Generating Plant Northern States Power Company - Minnesota (NSPM) 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT- ISSUANCE OF AMENDMENT RE: ADOPTION OF TSTF-542, REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL (EPID: L-2017-LLA-0360)

Dear Mr. Church:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 198 to Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating Plant.

The amendment consists of changes to the Technical Specifications in response to your application dated October 20, 2017, as supplemented by letters dated June 1, 2018, and September 11, 2018.

The amendment revises the Monticello Nuclear Generating Plant technical specification to adopt Technical Specification Task Force (TSTF) Travel 542, "Reactor Pressure Vessel Water Inventory Control."

A copy of our related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Robert F. Ku Plant Licensing Br Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263

Enclosures:

1. Amendment No. 198 to DPR-22

2. Safety Evaluation Cc: Listserv

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 198, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented prior to the next refueling outage.

FOR THE NUCLEAR REGULATORY COMMISSION cJJ a David J. Wronak~1ef v <---

Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Operating License No. DPR-22 and Technical Specifications Date of Issuance: October 29, 201 8

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER COMPANY DOCKET NO. 50-263 MONTICELLO NUCLEAR GENERATING PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 198 License No. DPR-22

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Northern States Power Company (NSPM, the licensee), dated October 20 2017, as supplemented by letters dated June 1, 2018, and September 11, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2 of Renewed Facility Operating License No. DPR-22 is hereby amended to read as follows:

Enclosure 1

ATTACHMENT TO LICENSE AMENDMENT NO. 198 MONTICELLO NUCLEAR GENERATING PLANT RENEWED FACILITY OPERATING LICENSE NO. DPR-22 DOCKET NO. 50-263 Replace the following page of Renewed Facility Operating License DPR-22 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 1.1-2 1.1-2 1.1-3 1.1-3 1.1-4 1.1-4 1.1-5 1.1-5 1.1-6 1.1-6 1.1-7 3.3.5.1-1 3.3.5.1-1 3.3.5.1-2 3.3.5.1-2 3.3.5.1-3 3.3.5.1-3 3.3.5.1-6 3.3.5.1-6 3.3.5.1-7 3.3.5.1-7 3.3.5.1-8 3.3.5.1-8 3.3.5.1-9 3.3.5.1-9 3.3.5.1-10 3.3.5.1-10 3.3.5.1-11 3.3.5.1-11 3.3.5.3-1 3.3.5.3-2 3.3.5.3-3 3.3.6.1-3 3.3.6.1-3 3.3.6.1-7 3.3.6.1-7 3.3.6.2-3 3.3.6.2-3 3.3.7.1-3 3.3.7.1-3 3.3.8.2-1 3.3.8.2-1 3.3.8.2-2 3.3.8.2-2 3.5.1-1 3.5.1-1

REMOVE INSERT 3.5.2-1 3.5.2-1 3.5.2-2 3.5.2-2 3.5.2-3 3.5.2-3 3.5.2-4 3.5.3-1 3.5.3-1 3.6.1.3-1 3.6.1.3-1 3.6.1.3-5 3.6.1.3-5 3.6.1.3-6 3.6.1.3-6 3.6.4.1-1 3.6.4.1-1 3.6.4.2-1 3.6.4.2-1 3.6.4.2-3 3.6.4.2-3 3.6.4.3-1 3.6.4.3-1 3.6.4.3-2 3.6.4.3-2 3.7.4-1 3.7.4-1 3.7.4-2 3.7.4-2 3.7.4-3 3.7.4-3 3.7.5-1 3.7.5-1 3.7.5-2 3.7.5-2 3.8.2-2 3.8.2-2 3.8.2-3 3.8.2-3 3.8.5-1 3.8.5-1 3.8.8-1 3.8.8-1 3.8.8-2 3.8.8-2

2. Pursuant to the Act and 10 CFR Part 70, NSPM to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operations, as described in the Final Safety Analysis Report, as supplemented and amended, and the licensee's filings dated August 16, 1974 (those portions dealing with handling of reactor fuel);

3. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use* at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;

4. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and

5. Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess, but not separate, such byproduct and special nuclear material as may be produced by operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

1. Maximum Power Level NSPM is authorized to operate the facility at steady state reactor core power levels not in excess of 2004 megawatts (thermal).

2. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 198, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

3. Physical Protection NSPM shall implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Renewed License No. DPR-22 Amendment No. 198

Definitions 1.1 1.1 Definitions CORE ALTERATl ON CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel.

The following exceptions are not considered to be CORE ALTERATIONS:

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

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

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

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

DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries/gram) that alone would produce the same dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The dose conversion factors used for this calculation shall be those listed in Federal Guidance Report (FGR)-11, "Limiting Values of Radionuclide Intake and Air Concentration Factors for Inhalation, Submersion and Ingestion," September 1988, and FGR-12, "External Exposure to Radionuclides in Air, Water and Soil,"

September 1993.

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

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single Monticello 1.1-2 Amendment No. 146, 148, 194,198 I

Definitions 1.1 1.1 Definitions DRAIN TIME (continued) human error}, for all penetration flow paths below the TAF except:

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

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

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

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used.

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

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

Monticello 1.1-3 Amendment No. 146, 194, 198

Definitions 1.1 1.1 Definitions LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE into the drywell, such as that from pump seals or valve packing that is captured and conducted to a sump or collecting tank; or

2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE;

b. Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE; C. Total LEAKAGE Sum of the identified and unidentified LEAKAGE; and

d. Pressure Boundary LEAKAGE LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall.

LINEAR HEAT GENERATION The LHGR shall be the heat generation rate per unit length of RATE (LHGR) fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

LOGIC SYSTEM A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all FUNCTIONAL TEST logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power ratio (CPR) that RATIO (MCPR) exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.

Monticello 1.1-4 Amendment No. 146,172, 175, 175, 198 I

Definitions 1.1 1.1 Definitions MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

OPERABLE - OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PRESSURE AND The PTLR is the unit specific document that provides the TEMPERATURE LIMITS reactor vessel pressure and temperature limits, including REPORT (PTLR) heatup and cooldown rates, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.5.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant of 2004 MWt.

REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval from SYSTEM(RPS)RESPONSE initiation of any RPS channel trip to the de-energization of the TIME scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

SHUTDOWN MARGIN (SOM) SOM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is xenon free;

b. The moderator temperature is ~ 68°F corresponding to the most reactive state; and

c. All control rods are fully inserted except for the single control 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 SOM.

Monticello 1.1-5 Amendment No. 1<16, 175, 198 I

Definitions 1.1 1.1 Definitions STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

TURBINE BYPASS SYSTEM The TURBINE BYPASS SYSTEM RESPONSE TIME shall be RESPONSE TIME that time interval from when the main turbine trip solenoid is activated until 80% of the turbine bypass capacity is established. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

Monticello 1.1-6 Amendment No. 446, 198 I

Definitions 1.1 Table 1.1-1 (page 1 of 1)

MODES AVERAGE REACTOR COOLANT REACTOR MODE TEMPERATURE MODE TITLE SWITCH POSITION (OF) 1 Power Operation Run NA 2 Startup Refue1<aJ or Startup/Hot Standby NA 3 Hot Shutdown<aJ Shutdown > 212 4 Cold Shutdown<aJ Shutdown ::;; 212 5 Refueling(b) Shutdown or Refuel NA (a) All reactor vessel head closure bolts fully tensioned.

(b) One or more reactor vessel head closure bolts less than fully tensioned.

Monticello 1.1-7 Amendment No. 198 I

ECCS Instrumentation 3.3.5.1 3.3 INSTRUMENTATION 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation LCO 3.3.5.1 The ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.1-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.1-1 for the channel.

B. As required by Required B.1 --------------NOTE-------------

Action A.1 and Only applicable for referenced in Functions 1.a, 1.b, 2.a, 2.b, Table 3.3.5.1-1. 2.f, 2.h, and 2.k.

Declare supported 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery feature(s) inoperable when of loss of initiation its redundant feature ECCS capability for initiation capability is feature(s) in both inoperable. divisions AND Monticello 3.3.5.1-1 Amendment No. 44e, 198 I

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2 ---------------NO TE--------------

Only applicable for Functions 3.a and 3.b.

Declare High Pressure 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery Coolant Injection (HPCI) of loss of HPCI System inoperable. initiation capability AND B.3 Place channel in trip. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months C. As required by Required C. 1 --------------NO TE-------------

Action A.1 and Only applicable for referenced in Functions 1.c, 1.d, 1.e, 1.f, Table 3.3.5.1-1. 2.c, 2.d, 2.e, 2.i, 2.j, 2.1, and 2.m.

Declare supported 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery feature(s) inoperable when of loss of initiation its redundant feature ECCS capability for initiation capability is feature(s) in both inoperable. divisions AND C.2 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

Monticello 3.3.5.1-2 Amendment No. 44e, 198 I

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required D.1 ---------------NOTE--------------

Action A. 1 and Only applicable if HPCI referenced in pump suction is not aligned Table 3.3.5.1-1. to the suppression pool.

Declare HPCI System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery inoperable. of loss of HPCI initiation capability AND D.2.1 Place channel in trip. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR D.2.2 Align the HPCI pump 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months suction to the suppression pool.

E. As required by Required E.1 --------------NO TE-------------

Action A.1 and Only applicable for referenced in Function 2.g.

Table 3.3.5.1-1. -----------------------------------

Declare supported 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery feature(s) inoperable when of loss of initiation its redundant feature ECCS capability for initiation capability is subsystems in both inoperable. divisions AND E.2 Restore channel to 7 days OPERABLE status.

Monticello 3.3.5.1-3 Amendment No. 448, 198 I

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 1 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System

a. Reactor Vessel 1,2,3 4(a) 8 SR 3.3.5.1.1 ~ -48 inches Water Level - Low SR 3.3.5.1.2 Low SR 3.3.5.1.3 SR 3.3.5.1.7 SR 3.3.5.1.8

b. Drywell Pressure - 1, 2, 3 4(a) 8 SR 3.3.5.1.2 ~ 2 psig High SR 3.3.5.1.4 SR 3.3.5.1.8 C. Reactor Steam 1, 2, 3 2 C SR 3.3.5.1.2 ~ 397 psig and Dome Pressure - SR 3.3.5.1.4(b)(c) ~ 440 psig Low (Injection SR 3.3.5.1.8 Permissive)

d. Reactor Steam 1, 2, 3 2 C SR 3.3.5.1.2 ~ 397 psig Dome Pressure SR 3.3.5.1.4(b)(c)

Permissive - Low SR 3.3.5.1.8 (Pump Permissive)

e. Reactor Steam 1, 2, 3 2 C SR 3.3.5.1.7 ~ 18 minutes Dome Pressure SR 3.3.5.1.8 Permissive - Bypass Timer (Pump Permissive)

(a) Also required to initiate the associated emergency diesel generator (EDG).

(b) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint; otherwise, the channel shall be declared inoperable. The nominal trip setpoint and the methodology used to determine the as-found tolerance and the as-left tolerance are specified in the Technical Requirements Manual (TRM).

Monticello 3.3.5.1-6 Amendment No. 146, 151, 170, 176, 198 I

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 2 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System

f. Core Spray Pump 1, 2,3 1 per pump C SR 3.3.5.1.7 ~ 15.86 Start - Time Delay SR 3.3.5.1.8 seconds Relay

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Vessel 1, 2, 3 4 B SR 3.3.5.1.1 ;c: -48 inches Water Level - Low SR 3.3.5.1.2 Low SR 3.3.5.1.3 SR 3.3.5.1.7 SR 3.3.5.1.8

b. Drywell Pressure - 1, 2, 3 4 B SR 3.3.5.1.2 ~ 2 psig High SR 3.3.5.1.4 SR 3.3.5.1.8 C. Reactor Steam 1, 2, 3 2 C SR 3.3.5.1.2 ;c: 397 psig and Dome Pressure - SR 3.3.5.1.4<bHc) ~ 440 psig Low (Injection SR 3.3.5.1.8 Permissive)

d. Reactor Steam 1, 2, 3 2 C SR 3.3.5.1.2 ;c: 39? psig Dome Pressure SR 3.3.5.1.4<bHc)

Permissive - Low SR 3.3.5.1.8 (Pump Permissive)

(b) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint; otherwise, the channel shall be declared inoperable. The nominal trip setpoint and the methodology used to determine the as-found tolerance and the as-left tolerance are specified in the TRM.

Monticello 3.3.5.1-7 Amendment No. 448, 198 I

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 3 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTIONA.1 REQUIREMENTS VALUE

2. LPCI System

e. Reactor Steam 1,2,3 2 C SR 3.3.5.1.7 s 18 minutes Dome Pressure SR 3.3.5.1.8 Permissive - Bypass Timer (Pump Permissive)

f. Low Pressure 1, 2, 3 4 per pump B SR 3.3.5.1.7 Coolant Injection SR 3.3.5.1.8 Pump Start - Time Delay Relay Pumps A, B s 5.33 seconds Pumps C, D s 10.59 seconds

g. Low Pressure 1,2,3 1 per pump E SR 3.3.5.1.2 ;;,: 360 gpm and Coolant Injection SR 3.3.5.1.7 s 745 gpm Pump Discharge SR 3.3.5.1.8 Flow- Low (Bypass)

h. Reactor Steam 1, 2, 3 4 B SR 3.3.5.1.2 ;;,: 873.6 psig Dome Pressure - SR 3.3.5.1. 7 and Low (Break SR 3.3.5.1.8 s 923.4 psig Detection)

i. Recirculation Pump 1,2,3 4 per pump C SR 3.3.5.1.2 ;;,: 63.5 inches Differential Pressure SR 3.3.5.1.7 WC

- High (Break SR 3.3.5.1.8 Detection)

j. Recirculation Riser 1, 2, 3 4 C SR 3.3.5.1.2 s 100.0 inches Differential Pressure SR 3.3.5.1.J<bHcJ WC

- High (Break SR 3.3.5.1.8 Detection)

(b) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint; otherwise, the channel shall be declared inoperable. The nominal trip setpoint and the methodology used to determine the as-found tolerance and the as-left tolerance are specified in the TRM.

Monticello 3.3.5.1-8 Correotion Letter of 10.'12.'06 Amendment No. 146, 149, 151, 161, 170, 176, 198

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 4 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

2. LPCI System

k. Recirculation Steam 1,2,3 2 B SR 3.3.5.1.7 s; 2.97 seconds Dome Pressure - SR 3.3.5.1.8 Time Delay Relay SR 3.3.5.1.9 (Break Detection)

I. Recirculation Pump 1,2,3 2 C SR 3.3.5.1.7 s; 0.75 seconds Differential Pressure SR 3.3.5.1.8

- Time Delay Relay SR 3.3.5.1.9 (Break Detection)

m. Recirculation Riser 1, 2, 3 2 C SR 3.3.5.1.7 s; 0.75 seconds Differential Pressure SR 3.3.5.1.8

- Time Delay Relay SR 3.3.5.1.9 (Break Detection)

3. High Pressure Coolant Injection (HPCI) System

a. Reactor Vessel 1, iect>, 3(d) 4 B SR 3.3.5.1.1 2 -48 inches Water Level - Low SR 3.3.5.1.2 Low SR 3.3.5.1.3 SR 3.3.5.1.7 SR 3.3.5.1.8

b. Drywell Pressure - 1, 2(d)' 3(d) 4 B SR 3.3.5.1.2 s; 2 psig High SR 3.3.5.1.4 SR 3.3.5.1.8 C. Reactor Vessel 1, 2(d), 3(d) 2 C SR 3.3.5.1.1 s; 48 inches Water Level - High SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.7 SR 3.3.5.1.8

d. Condensate Storage 1, id), 3(d) 2 D SR 3.3.5.1.7 2 29.3 inches Tank Level - Low SR 3.3.5.1.8

e. Suppression Pool 1, 2(d), 3(d) 2 D SR 3.3.5.1.5 s; 3.0 inches Water Level - High SR 3.3.5.1.6 SR 3.3.5.1.8

f. High Pressure 1, 2<ct>, 3(d) E SR 3.3.5.1.5 2 362 gpm and Coolant Injection SR 3.3.5.1.6 s; 849 gpm Pump Discharge SR 3.3.5.1.8 Flow- Low (Bypass)

(d) With reactor steam dome pressure> 150 psig.

Monticello 3.3.5.1-9 Amendment No. 146, 149, 151, 161, 198

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 5 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTIONA.1 REQUIREMENTS VALUE

4. Automatic Depressurization System (ADS) Trip System A

a. Reactor Vessel 1, 2(d), 3(d) 2 F SR 3.3.5.1.1 :2: -48 inches Water Level - Low SR 3.3.5.1.2 Low SR 3.3.5.1.3 SR 3.3.5.1.7 SR 3.3.5.1.8

b. Automatic 1, id>, 3(d) 1 G SR 3.3.5.1. 7 :,; 120 seconds Depressurization SR 3.3.5.1.8 System Initiation Timer C. Core Spray Pump 1, 2(d), 3(d) 2 G SR 3.3.5.1.2 :2: 75 psig and Discharge Pressure SR 3.3.5.1.4(bJ(cJ :,; 125 psig

- High SR 3.3.5.1.8

d. Low Pressure 1, 2'd)' 3(d) 4 G SR 3.3.5.1.2 :2: 75 psig and Coolant Injection SR 3.3.5.1.4(bJ(cJ :,; 125 psig Pump Discharge SR 3.3.5.1.8 Pressure - High

5. ADS Trip System B

a. Reactor Vessel 1, 2(d), 3(d) 2 F SR 3.3.5.1.1 :2: -48 inches Water Level - Low SR 3.3.5.1.2 Low SR 3.3.5.1.3 SR 3.3.5.1.7 SR 3.3.5.1.8

b. Automatic 1, 2(d), 3(d) G SR 3.3.5.1.7 :,; 120 seconds Depressurization SR 3.3.5.1.8 System Initiation Timer (b) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint; otherwise, the channel shall be declared inoperable. The nominal trip setpoint and the methodology used to determine the as-found tolerance and the as-left tolerance are specified in the TRM.

(d) With reactor steam dome pressure> 150 psig.

Monticello 3.3.5.1-10 Amendment No. 44&, 198 I

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 6 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

5. ADS Trip System B C. Core Spray Pump 1, 2(d)' 3(d) 2 G SR 3.3.5.1.2 2: 75 psig and Discharge Pressure SR 3.3.5.1.4<b)(c) s; 125 psig

- High SR 3.3.5.1.8

d. Low Pressure 1, 2(d)' 3(d) 4 G SR 3.3.5.1.2 2: 75 psig and Coolant Injection SR 3.3.5.1.4(b)(c) s; 125 psig Pump Discharge SR 3.3.5.1.8 Pressure - High (b) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the nominal trip setpoint; otherwise, the channel shall be declared inoperable. The nominal trip setpoint and the methodology used to determine the as-found tolerance and the as-left tolerance are specified in the TRM.

(d) With reactor steam dome pressure> 150 psig.

Monticello 3.3.5.1-11 Amendment No. 44e, 198 I

RPV Water Inventory Control Instrumentation 3.3.5.3 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.3-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.3-1 for the channel.

B. As required by Required B.1 Declare associated Immediately Action A.1 and penetration flow path(s) referenced in incapable of automatic Table 3.3.5.3-1. isolation.

AND B.2 Calculate DRAIN TIME. Immediately C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.5.3-1.

D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and OPERABLE status.

referenced in Table 3.3.5.3-1.

Monticello 3.3.5.3-1 Amendment No. 198

RPV Water Inventory Control Instrumentation 3.3.5.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Declare associated low Immediately associated Completion pressure ECCS Time of Condition C or D injection/spray subsystem not met. inoperable.

SURVEILLANCE REQUIREMENTS

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

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

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST. 92 days Monticello 3.3.5.3-2 Amendment No. 198

RPV Water Inventory Control Instrumentation 3.3.5.3 Table 3.3.5.3-1 (page 1 of 1)

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

1. Core Spray System

a. Reactor 4,5 2(a) C SR 3.3.5.3.2 ~ 397 psig and Steam Dome ~ 440 psig Pressure - Low (Injection Permissive)

2. Low Pressure Coolant Injection (LPCI) System

a. 2(a)

Reactor Steam 4, 5 C SR 3.3.5.3.2 ~ 397 psig and Dome Pressure - ~440 psig Low (Injection Permissive)

b. Low Pressure 4, 5 1 per D SR 3.3.5.3.2 ~ 360 gpm and Coolant Injection pump(a) ~ 745 gpm Pump Discharge Flow - Low (Bypass)

3. Shutdown Cooling System Isolation

a. Reactor Vessel (b) 2 in one trip B SR 3.3.5.3.1 ~ 7 inches Water Level - Low system SR 3.3.5.3.2

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel (b) 2 in one trip B SR 3.3.5.3.1 ~ -48 inches Water Level - Low system SR 3.3.5.3.2 Low (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel (RPV)

Water Inventory Control."

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

Monticello 3.3.5.3-3 Amendment No. 198

Primary Containment Isolation Instrumentation 3.3.6.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME I. As required by Required 1.1 Initiate action to restore Immediately Action C.1 and channel to OPERABLE referenced in status.

Table 3.3.6.1-1.

SURVEILLANCE REQUIREMENTS

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

1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment Isolation Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains primary containment isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.6.1.3 Calibrate the trip unit. 92 days SR 3.3.6.1.4 Perform CHANNEL CALIBRATION. 92 days Monticello 3.3.6.1-3 Amendment No. 44e, 198 I

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 3 of 3)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE

5. RWCU System Isolation

d. SLC System 1,2,3 1 H SR 3.3.6.1.6 NA Initiation

e. Reactor Vessel 1, 2, 3 2 F SR 3.3.6.1.1 ~ -48 inches Water Level - Low SR 3.3.6.1.2 Low SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6

6. Shutdown Cooling System Isolation

a. Reactor Steam 1, 2, 3 2 F SR 3.3.6.1.2 ~ 81.8 psig Dome Pressure - SR 3.3.6.1.4 High SR 3.3.6.1.6

b. Reactor Vessel 3 2 SR 3.3.6.1.1 ~ 7 inches Water Level - Low SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6

7. Traversing lncore Probe System Isolation

a. Reactor Vessel 1, 2, 3 2 G SR 3.3.6.1.1 ~ 7 inches Water Level - Low SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6

b. Drywell Pressure - 1, 2, 3 2 G SR 3.3.6.1.2 ~ 2.0 psig High SR 3.3.6.1.4 SR 3.3.6.1.6 Monticello 3.3.6.1-7 Amendment No. 146, 164, 198 I

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1)

Secondary Containment Isolation Instrumentation APPLICABLE REQUIRED MODES OR CHANNELS OTHER PER SPECIFIED TRIP SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM REQUIREMENTS VALUE

1. Reactor Vessel Water Level - Low 1, 2, 3 2 SR 3.3.6.2.1 ~ -48 inches Low SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.5 SR 3.3.6.2.6

2. Drywell Pressure - High 1, 2, 3 2 SR 3.3.6.2.2 ~ 2 psig SR 3.3.6.2.4 SR 3.3.6.2.6

3. Reactor Building Ventilation Exhaust 1, 2, 3, (a) 2 SR 3.3.6.2.1 ~ 100 mR/hr Radiation - High SR 3.3.6.2.2 SR 3.3.6.2.4 SR 3.3.6.2.6

4. Refueling Floor Radiation - High 1, 2, 3, (a) 2 SR 3.3.6.2.1 ~ 100 mR/hr SR 3.3.6.2.2 SR 3.3.6.2.4 SR 3.3.6.2.6 (a) During movement of recently irradiated fuel assemblies in secondary containment.

Monticello 3.3.6.2-3 Amendment No. 44e, 198 I

CREF System Instrumentation 3.3.7.1 Table 3.3.7.1-1 (Page 1 of 1)

Control Room Emergency Filtration System Instrumentation APPLICABLE REQUIRED MODES OR CHANNELS OTHER PER SPECIFIED TRIP SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM REQUIREMENTS VALUE

1. Reactor Vessel Water 1,2,3 2 SR 3.3.7.1.1 ;;,; -48 inches Level - Low Low SR 3.3.7.1.2 SR 3.3.7.1.3 SR 3.3.7.1.5 SR 3.3.7.1.6

2. Drywell Pressure - 1, 2, 3 2 SR 3.3.7.1.2 s 2 psig High SR 3.3.7.1.4 SR 3.3.7.1.6

3. Reactor Building 1, 2, 3, (a) 2 SR 3.3.7.1.1 s 100 mR/hr Ventilation Exhaust SR 3.3.7.1.2 Radiation - High SR 3.3.7.1.4 SR 3.3.7.1.6

4. Refueling Floor 1, 2, 3, (a) 2 SR 3.3.7.1.1 s 100 mR/hr Radiation - High SR 3.3.7.1.2 SR 3.3.7.1.4 SR 3.3.7.1.6 (a) During movement of recently irradiated fuel assemblies in the secondary containment.

Monticello 3.3.7.1-3 Amendment No. 14e 148, 198 I

RPS Electric Power Monitoring 3.3.8.2 3.3 INSTRUMENTATION 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring LCO 3.3.8.2 Two RPS electric power monitoring assemblies shall be OPERABLE for each inservice RPS motor generator set or alternate power supply.

APPLICABILITY: MODES 1, 2, and 3, MODES 4 and 5 with residual heat removal (RHR) shutdown cooling supply isolation valves open, MODE 5 with 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.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or both inservice A.1 Remove associated 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months power supplies with one inservice power supply(s) electric power from service.

monitoring assembly inoperable.

B. One or both inservice B.1 Remove associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months power supplies with both inservice power supply(s) electric power from service.

monitoring assemblies inoperable.

C. Required Action and C. 1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, or 3. C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Monticello 3.3.8.2-1 Amendment No. 44&,- 198 I

RPS Electric Power Monitoring 3.3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Initiate action to restore one Immediately associated Completion electric power monitoring Time of Condition A or B assembly to OPERABLE not met in MODE 4 or 5 status for inservice power with RHR shutdown supply(s) supplying cooling supply isolation required instrumentation.

valves open.

OR D.2 Initiate action to isolate the Immediately RHR Shutdown Cooling System.

E. Required Action and E.1 Initiate action to fully insert Immediately associated Completion all insertable control rods in Time of Condition A or B core cells containing one or not met in MODE 5 with more fuel assemblies.

any control rod withdrawn from a core cell containing one or more fuel assemblies.

F. Required Action and F.1.1 Isolate the associated Immediately associated Completion secondary containment Time of Condition A or B penetration flow path(s).

not met during movement of recently OR irradiated fuel assemblies in the F.1.2 Declare the associated Immediately secondary containment. secondary containment isolation valve(s) inoperable.

AND F.2.1 Place the associated Immediately standby gas treatment (SGT) subsystem(s) in operation.

OR Monticello 3.3.8.2-2 Amendment No. 449, 198 I

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEM (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC} SYSTEM 3.5.1 ECCS - Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of three safety/relief valves shall be OPERABLE.

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

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) shutdown cooling supply isolation interlock in MODE 3, if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure~ 150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to HPCI.

CONDITION REQUIRED ACTION COMPLETION TIME A. One LPCI pump A.1 Restore LPCI pump to 30 days inoperable. OPERABLE status.

B. One LPCI subsystem 8.1 Restore low pressure 7 days inoperable for reasons ECCS injection/spray other than Condition A. subsystem to OPERABLE status.

OR One Core Spray subsystem inoperable.

Monticello 3.5.1-1 Amendment No. 449, 198 I

RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEM (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

One low pressure ECCS injection/spray subsystem shall be OPERABLE.

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray injection/spray subsystem subsystem inoperable. to OPERABLE status.

B. Required Action and B.1 Initiate action to establish a Immediately associated Completion method of water injection Time of Condition A not capable of operating met. without offsite electrical power.

C. DRAIN TIME< 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and ~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

AND Monticello 3.5.2-1 Amendment No. 446, 198 I

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 ----------- NOTE ---------------

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

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

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

AND Monticello 3.5.2-2 Amendment No. 44e, 198 I

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

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

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

E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Time of Condition C or D not met.

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

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for the required ECCS injection/spray 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months subsystem, the:

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

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

Monticello 3.5.2-3 Amendment No. 146, 167, 198, 198 I

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for the required ECCS injection/spray 31 days subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

SR 3.5.2.3 -------------------------------NOTE------------------------------

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

Verify, for the required ECCS injection/spray 31 days subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.4 Operate the required ECCS injection/spray 92 days subsystem for ~ 10 minutes.

SR 3.5.2.5 -------------------------------NOTE------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem 24 months can be manually operated.

SR 3.5.2.6 Verify each valve credited for automatically isolating 24 months a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

SR 3.5.2.7 Verify DRAIN TIME~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Monticello 3.5.2-4 Amendment No. 198 I

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEM (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to the RCIC System.

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by administrative Immediately inoperable. means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to 14 days OPERABLE status.

B. Required Action and 8.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND 8.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to

150 psig.

Monticello 3.5.3-1 Amendment No. 449, 198 I

PCIVs 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3 ACTIONS

NO TES----------------------------------------------------------

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment,"

when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A. ------------NO TE------------ A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for Only applicable to penetration flow path by main steam line penetration flow paths use of at least one closed with two PCIVs. and de-activated automatic AND

valve, closed manual valve, blind flange, or check valve 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main One or more penetration with flow through the valve steam line flow paths with one secured.

PCIV inoperable for reasons other than AND Condition D or E.

Monticello 3.6.1.3-1 Amendment No. 146, 148, 198 I

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more penetration D.1 Isolate the affected 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months flow paths with one or penetration flow path by more 18 inch primary use of at least one closed containment purge and and de-activated automatic vent valves not within valve, closed manual valve, purge and vent valve or blind flange.

leakage limits.

AND D.2 --------------NOTES-------------

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

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

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment E. One or more MSIVs E.1 Restore leakage rate to within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months with leakage rate not limits.

within limits.

F. Required Action and F.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, AND C., or D not met in MODE 1, 2, or 3. F.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Monticello 3.6.1.3-5 Amendment No. 146, 148, 198

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.1 ------------------------------NOTE------------------------------

Not required to be met when the 18 inch primary containment purge and vent valves are open for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open.

Verify each 18 inch primary containment purge and 31 days vent valve is closed.

Monticello 3.6.1.3-6 Amendment No. 146, 148, 198 I

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable in MODE 1, containment to OPERABLE 2, or 3. status.

B. Required Action and 8.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not AND met.

8.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. Secondary containment C.1 ---------------NO TE--------------

inoperable during LCO 3.0.3 is not applicable.

movement of recently -------------------------------------

irradiated fuel assemblies in the Suspend movement of Immediately secondary containment. recently irradiated fuel assemblies in the secondary containment.

Monticello 3.6.4.1-1 Amendment No. 449;- 198 I

SCIVs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)

LCO 3.6.4.2 Each SCIV shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more penetration A.1 Isolate the affected 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months flow paths with one penetration flow path by SCIV inoperable. use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

Monticello 3.6.4.2-1 Amendment No. 44e, 198 I

SCIVs 3.6.4.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 ---------------NOTE--------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A or B not met during movement of recently Suspend movement of Immediately irradiated fuel recently irradiated fuel assemblies in the assemblies in the secondary containment. secondary containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 ------------------------------NOTES-----------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for SCIVs that are open under administrative controls.

Verify each secondary containment isolation manual 31 days valve and blind flange that is not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed.

SR 3.6.4.2.2 Verify the isolation time of each power operated, 92 days automatic SCIV is within limits.

SR 3.6.4.2.3 Verify each automatic SCIV actuates to the isolation 24 months position on an actual or simulated actuation signal.

Monticello 3.6.4.2-3 Amendment No. 44&,. 198 I

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SGT subsystem A.1 Restore SGT subsystem to 7 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not AND met in MODE 1, 2, or 3.

B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. Required Action and --------------------NOTE-------------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A not ------------------------------------------------

met during movement of recently irradiated fuel C. 1 Place OPERABLE SGT Immediately assemblies in the subsystem in operation.

secondary containment.

OR C.2 Suspend movement of Immediately recently irradiated fuel assemblies in secondary containment.

Monticello 3.6.4.3-1 Amendment No. 448, 198 I

SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two SGT subsystems D.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3.

E. Two SGT subsystems E.1 ---------------NOTE--------------

inoperable during LCO 3.0.3 is not applicable.

movement of recently -------------------------------------

irradiated fuel assemblies in the Suspend movement of Immediately secondary containment. recently irradiated fuel assemblies in secondary containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for 2 15 continuous 31 days minutes.

SR 3.6.4.3.2 Perform required SGT filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual 24 months or simulated initiation signal.

Monticello 3.6.4.3-2 Amendment No. 146, 181, 198 I

CREF System 3.7.4

3. 7 PLANT SYSTEMS 3.7.4 Control Room Emergency Filtration (CREF) System LCO 3.7.4 Two CREF subsystems shall be OPERABLE.

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

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREF subsystem A.1 Restore CREF subsystem 7 days inoperable for reasons to OPERABLE status.

other than Condition B.

B. One or more CREF 8.1 Initiate action to implement Immediately subsystems inoperable mitigating actions.

due to inoperable CRE boundary in MODE 1, 2, AND or 3.

8.2 Verify mitigating actions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ensure CRE occupant exposures to radiological, chemical and smoke hazards will not exceed limits.

AND 8.3 Restore CRE boundary to 90 days OPERABLE status.

Monticello 3.7.4-1 Amendment No. 146, 160, 175, 198 I

CREF *System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, or 3. C.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and --------------------NOTE-------------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A not ------------------------------------------------

met during movement of recently irradiated fuel D.1 Place OPERABLE CREF Immediately assemblies in the subsystem in pressurization secondary containment. mode.

OR D.2 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

E. Two CREF subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

Monticello 3.7.4-2 Amendment No. 146, 160, 198 I

CREF System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREF subsystems --------------------NOTE-------------------

inoperable during LCO 3.0.3 is not applicable.

movement of recently irradiated fuel assemblies in the F.1 Suspend movement of Immediately secondary containment. recently irradiated fuel assemblies in the secondary containment.

One or more CREF subsystems inoperable due to an inoperable CRE boundary during movement of recently irradiated fuel assemblies in the secondary containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Operate each CREF subsystem for ~ 15 continuous 31 days minutes.

SR 3.7.4.2 Perform required CREF filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.7.4.3 Verify each CREF subsystem actuates on an actual 24 months or simulated initiation signal.

SR 3.7.4.4 Perform required CRE unfiltered air in-leakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Envelope Habitability Program Monticello 3.7.4-3 Amendment No. 146, 160, 175, 181, 198 I

Control Room Ventilation System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Control Room Ventilation System LCO 3.7.5 Two control room ventilation subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control room A.1 Restore control room 30 days ventilation subsystem ventilation subsystem to inoperable. OPERABLE status.

B. Two control room B.1 Verify control room area Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ventilation subsystems temperature< 90°F.

inoperable.

AND B.2 Restore one control room 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ventilation subsystem to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, or 3. C.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and --------------------NOTE-------------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A not ------------------------------------------------

met during movement of recently irradiated fuel D.1 Place OPERABLE control Immediately assemblies in the room ventilation subsystem secondary containment. in operation.

OR Monticello 3.7.5-1 Amendment No. 146, 148, 154, 198 I

Control Room Ventilation System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 0.2 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

E. Required Action and --------------------NOTE-------------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition B not ------------------------------------------------

met during movement of recently irradiated fuel E.1 Suspend movement of Immediately assemblies in the recently irradiated fuel secondary containment. assemblies in the secondary containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 Verify each control room ventilation subsystem has 24 months the capability to remove the assumed heat load.

Monticello 3.7.5-2 Amendment No. 146, 148, 154, 198 I

AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2.1 Suspend CORE Immediately AL TE RATIONS.

AND A.2.2 Suspend movement of Immediately recently irradiated fuel assemblies in the

secondary containment.

AND A.2.3 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

B. One required EOG 8.1 Suspend CORE Immediately inoperable. AL TERA TIONS.

AND 8.2 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

AND 8.3 Initiate action to restore Immediately required EOG to OPERABLE status.

Monticello 3.8.2-2 Amendment No. 146, 148, 198 I

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 ------------------------------NOTES-----------------------------

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

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

For AC sources required to be OPERABLE the SRs In accordance of Specification 3.8.1, except SR 3.8.1.6, are with applicable applicable. SRs Monticello 3.8.2-3 Amendment No. 446, 198 I

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 Division 1 or Division 2 125 VDC electrical power subsystem shall be OPERABLE to support one division of the DC Electrical Power Distribution System required by LCO 3.8.8, "Distribution Systems -

Shutdown."

APPLICABILITY: MODES 4 and 5, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Required DC electrical A.1 Suspend CORE Immediately power subsystem AL TE RATIONS.

inoperable.

AND A.2 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

AND A.3 Initiate action to restore Immediately required DC electrical power subsystem to OPERABLE status.

Monticello 3.8.5-1 Amendment No. 14e, 148, 198 I

Distribution Systems - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Distribution Systems - Shutdown LCO 3.8.8 The necessary portions of the AC and DC electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 4 and 5, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare associated Immediately AC or DC electrical supported required power distribution feature(s) inoperable.

subsystems inoperable.

A.2.1 Suspend CORE Immediately ALTERATIONS.

A.2.2 Suspend handling of Immediately recently irradiated fuel assemblies in the secondary containment.

Monticello 3.8.8-1 Amendment No. 14e, 148, 198 I

Distribution Systems - Shutdown 3.8.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2.3 Initiate actions to restore Immediately required AC and DC electrical power distribution subsystems to OPERABLE status.

A.2.4 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and voltage to 7 days required AC and DC electrical power distribution subsystems.

Monticello 3.8.8-2 Amendment No. 449, 198 I

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 198 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-22 NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263

1.0 INTRODUCTION

By application dated October 20, 2017 (Reference 1), and supplemented by letters dated June 1, 2018 (Reference 2), and September 11, 2018 (Reference 3), Northern States Power Company, doing business as Xcel Energy (NSPM, the licensee,) requested to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, (Reference 4), "Reactor Pressure Vessel Water Inventory Control [RPV WIC]," Revision 2, which changes the technical specifications (TSs) for the Monticello Nuclear Generating Plant (MNGP). Traveler TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory Commission (NRC, the Commission) on December 20, 2016 (Reference 5).

The proposed changes would replace existing TSs requirements associated with "operations with a potential for draining the reactor vessel," (OPDRVs) with revised TSs providing alternative requirements for RPV WIC. These alternative requirements would protect Safety Limit TS 2.1.1.4, which states, "Reactor vessel water level shall be greater than the top of active irradiated fuel."

Additionally, a new definition "DRAIN TIME" would be added to the MNGP TSs, Section 1.1, "Definitions." DRAIN TIME would establish requirements for the licensee to make RPV water level inventory determinations and to calculate RPV water inventory drain rates for Modes 4 and 5 outage-related activities. Adequate licensee management of secondary containment requirements or mitigation of certain emergency core cooling system (ECCS) safety injection/spray systems during Modes 4 and 5 requires a properly calculated DRAIN TIME.

The license amendment request (LAR) has proposed several variations from the TS changes described in the applicable parts of TSTF-542, Revision 2, or the NRC-approved TSTF-542 safety evaluation (SE). These are explained below in Section 2.2.5 and evaluated in Section 3.5.

Enclosure 2

The supplements dated June 1, 2018, and September 11, 2018, provided additional information that clarified the application, but did not expand the scope of the application or change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on December 19, 2017 (82 FR 60228).

2.0 REGULATORY EVALUATION

2.1 System Description The boiling-water reactor (BWR) RPVs have a number of penetrations located below the top of active fuel (TAF). These penetrations provide entry for control rods, recirculation flow, reactor water cleanup, and shutdown cooling (SDC). Since these penetrations are below the TAF, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling.

The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release.

During operation in Modes 1 (Power Operation - Reactor Mode Switch in Run), 2 (Startup -

Reactor Mode Switch in Refuel 1 or Startup/Hot Standby), and 3 (Hot Shutdown 1 - Reactor Mode Switch in Shutdown and average reactor coolant temperature> 212 °F (degrees Fahrenheit)),

the TS for instrumentation and ECCSs require operability of sufficient equipment to ensure large quantities of water will be injected into the vessel should level decrease below the preselected value. These requirements are designed to mitigate the effects of a loss-of-coolant accident (LOCA), but also provide protection for other accidents and transients that involve a water inventory loss.

During BWR operation in Mode 4 (Cold Shutdown 1 - Reactor Mode Switch in Shutdown and average reactor coolant temperatures 212 °F), and Mode 5 (Refueling 2- Reactor Mode Switch in Shutdown or Refuel), the pressures and temperatures that could cause a LOCA are not present. During certain phases of refueling (Mode 5) a large volume of water is available above the RPV (i.e., the head is removed), the water level is~ 21 feet 11 inches over the top of the RPV flange, and the spent fuel storage pool gates are removed.

The large volume of water available in and above the RPV (during much of the time when in Mode 5) provides time for operator detection and manual operator action to stop and mitigate an RPV draining event. However, typically at other times during a refueling outage, during Cold Shutdown (Mode 4) or Refueling (Mode 5), there may be a potential for significant drainage paths from certain outage activities, human error, and other events when it is more likely to have some normally available equipment, instrumentation, and systems inoperable due to maintenance and outage activities. There may not be as much time for operator action as compared to times when there are large volumes of water above the RPV.

In comparison to Modes 1, 2, and 3, with typical high temperatures and pressures (especially in Modes 1 and 2), Modes 4 and 5 generally do not have the high pressure and temperature considered necessary for a LOCA envisioned from a high energy pipe failure. Thus, while the potential sudden loss of large volumes of water from a LOCA are not expected, operators monitor for BWR RPV water level decrease from potentially significant or unexpected drainage paths. These potential drainage paths in Modes 4 and 5 generally would require less water replacement capability to maintain water above the TAF.

1 With all reactor vessel head closure bolts fully tensioned.

2 One or more reactor vessel head closure bolts less than fully tensioned.

To address the drain down potential during Modes 4 and 5, the current MNGP TSs contain specifications that are applicable during an OPDRV, or require suspension of OPDRVs if certain equipment is inoperable. The term OPDRV is not specifically defined in the TSs and historically has been subject to inconsistent application by licensees. The changes discussed in this SE are intended to resolve any ambiguity by creating a new RPV WIC TS with attendant equipment operability requirements, required actions, and surveillance requirements (SRs) and deleting references to OPDRVs throughout the TS.

2.2 Proposed TS Changes Section 2.2.1 describes the proposed addition of a new definition, "DRAIN TIME" (evaluated below in Section 3.1 ).

Section 2.2.2 describes the proposed revisions; (1) TS 3.3, "Instrumentation," including the proposed revisions to TS 3.3.5.1, "ECCS Instrumentation"; (2) proposed addition of new TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" (including Table 3.3.5.3-1 ); and (3) proposed revisions to TS pages for TS 3.3.6.1, "Primary Containment Isolation Instrumentation" (including Table 3.3.6.1-1 ). Section 2.2.2 is evaluated below in Sections 3.2 and 3.4.

Section 2.2.3 describes the proposed revisions to TS 3.5, "Emergency Core Cooling Systems System (ECCS) and Reactor Core Isolation Cooling (RCIC) System," including the proposed revisions to TS 3.5.2 "ECCS - Shutdown" (evaluated below in Section 3.3).

Section 2.2.4 describes the proposed deletion of existing TS references to OPDRVs (evaluated below in Section 3.6).

Section 2.2.5 describes MNGP plant-specific variations to TSTF-542, Revision 2 (evaluated below in Section 3.5).

2.2.1 Addition of "DRAIN TIME" Definition The following definition of "DRAIN TIME" would be added to Section 1.1, "Definitions":

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

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the T AF except:

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

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

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

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used ..

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

2.2.2 TS 3.3, "Instrumentation" The following subsections describe the existing and proposed changes to the MNGP TS, Section 3.3, "Instrumentation."

2.2.2.1 TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation" Proposed changes to TS 3.3.5.1 include the deletion of Note 1 in Required Actions B.1, C.1, and E.1, which states:

"Only applicable in MODES 1, 2, and 3."

As a result, the numbering for Note 2 would be removed with no change in the note.

For TS Table 3.3.5.1-1, the applicability in Modes 4 and 5 was proposed for deletion because the instrumentation requirements during shutdown would be consolidated into the new TS 3.3.5.3, "RPV Water Inventory Control Instrumentation." Modes 4 and 5 Applicability and associated requirements would be deleted for the following functions:

1. Core Spray System; (a) Reactor Vessel Water Level - Low Low (c) Reactor Steam Dome Pressure - Low (Injection Permissive)

(d) Reactor Steam Dome Pressure Permissive - Low (Pump Permissive)

(e) Reactor Steam Dome Pressure Permissive - Bypass Timer (Pump Permissive)

(f) Core Spray Pump Start - Time Delay Relay

2. Low Pressure Coolant Injection (LPCI) System; (a) Reactor Vessel Water Level - Low Low (c) Reactor Steam Dome Pressure - Low (Injection Permissive)

(d) Reactor Steam Dome Pressure Permissive - Low (Pump Permissive)

(e) Reactor Steam Dome Pressure Permissive - Bypass Timer (Pump Permissive)

(f) Low Pressure Coolant Injection Pump Start - Time Delay Relay (g) Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)

Table 3.3.5.1-1, Footnote (a), which states, "When the associated ECCS subsystem(s) are required to be OPERABLE per LCO 3.5.2," would be deleted. Existing Footnotes (b), (c), (d),

and (e) would be renumbered as Footnotes (a), (b), (c), and (d), respectively. The proposed new TS 3.3.5.3 is shown below.

2.2.2.2 New TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" The proposed new TS 3.3.5.3 would contain existing 'ECCS' and 'Primary Containment Isolation' instrumentation functions that are relocated from TSs 3.3.5.1 and 3.3.6.1, as well as new requirements.

The proposed new TS 3.3.5.3 is shown below:

3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.3-1 ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Enter the Condition Immediately channels inoperable. referenced in Table 3.3.5.3-1 for the channel.

B. As required by B.1 Declare associated Immediately Required Action A.1 penetration flow path(s) and referenced in incapable of automatic Table 3.3.5.3-1. isolation.

AND B.2 Calculate DRAIN TIME. Immediately C. As required by C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Required Action A.1 and referenced in Table 3.3.5.3-1.

D. As required by D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Required Action A.1 OPERABLE status.

and referenced in Table 3.3.5.3-1.

E. Required Action and E.1 Declare associated low Immediately associated pressure ECCS Completion Time of injection/spray subsystem Condition C or D not inoperable.

met.

SURVEILLANCE REQUIREMENTS

N()TE----------------------------------------------------------------

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

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.5.3.2 Perform CHANNEL FUNCTl()NAL TEST. 92 days Table 3.3.5.3-1 (Page 1 of 1)

RPVW ater Inventory Contro 11 nstrumentat1on APPLICABLE CONDITIONS REQUIRED MODES REFERENCED CHANNELS SURVEILLANCE ALLOWABLE FUNCTION OR OTHER FROM PER REQUIREMENTS VALUE SPECIFIED REQUIRED FUNCTION CONDITIONS ACTION A.1

1. Core Spray System

a. Reactor Steam Dome 4,5 2(a) C SR 3.3.5.3.2 .: 397 psig and Pressure - Low s 440 psig (Injection Permissive)

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Steam Dome 4,5 2(a) C SR 3.3.5.3.2 .: 397 psig and Pressure - Low s 440 psig (Injection Permissive)

b. Low Pressure Coolant 4,5 1 per D SR 3.3.5.3.2 .: 360 gpm and Injection Pump pump(a) ::: 745 gpm Discharge Flow-Low (Bypass)

3. Shutdown Cooling System Isolation

a. Reactor Vessel Water (b} 2 in one trip B SR 3.3.5.3.1 .: 7 inches Level-Low svstem SR 3.3.5.3.2

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (b} 2 in one trip B SR 3.3.5.3.1 .: - 48 inches Level - Low Low svstem SR 3.3.5.3.2 a) Associated with an ECCS subsystem required to be OPERABLE by LC() 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control."

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

2.2.2.3 TS 3.3.6.1, "Primary Containment Isolation Instrumentation" In TS Table 3.3.6.1-1, Function 6.b, Shutdown Cooling System Isolation, Reactor Vessel Water Level - Low, the applicability in Modes 4 and 5 was proposed for deletion. Also, Footnote (a) to Table 3.3.6.1-1 was proposed to be deleted, as it is applicable only to Function 6.b during Modes 4 and 5. Footnote (a) is related to residual heat removal (RHR) SOC system integrity.

This function would be moved to the new TS Table 3.3.5.3-1, Function 3.a, as shown in Section 2.2.2.2 of this SE.

In TS limiting condition for operation (LCO) 3.3.6.1, Required Action 1.2, was proposed for deletion since it was associated with the isolation of RHR Shutdown Cooling System during Modes 4 and 5.

2.2.3 TS Section 3.5, "Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling System (RCIC) System" The title of MNGP TS Section 3.5 would be revised from "Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling System (RCIC)" to "Emergency Core Cooling Systems (ECCS), RPV Water Inventory Control, and Reactor Core Isolation Cooling (RCIC)

System."

The title of MNGP TS, Section 3.5.2, would be revised from "ECCS - Shutdown" to "Reactor Pressure Vessel (RPV) Water Inventory Control," and TS 3.5.2 would be revised as follows:

LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

One low pressure ECCS injection/spray subsystem shall be OPERABLE.

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

A low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal (OHR) if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS injection/spray 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem subsystem to OPERABLE status.

inoperable.

B. Required Action and B.1 Initiate action to establish a method of water Immediately associated Completion Time injection capable of operating without offsite of Condition A not met. electrical power.

C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and C.1 Verify secondary containment boundary is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

a: : 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary containment penetration 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment subsystem is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D .1--------------NOTE------------

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

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

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

AND D.3 Initiate action to isolate each secondary Immediately containment penetration flow path or verify it can be manually isolated from the control room.

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

E. Required Action and E.1 Initiate action to restore DRAIN TIME to~ 36 Immediately associated Completion Time hours.

of Condition C or D not met.

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

The proposed SRs for TS 3.5.3 are shown below:

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for a required ECCS injection/spray 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months subsystem, the:

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

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

SR 3.5.2.2 Verify, for the required ECCS injection/spray 31 days subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

SR 3.5.2.3 -------------------N()TE---------------------------------

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

Verify, for the required ECCS injection/spray 31 days subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.4 Operate the required ECCS injection/spray 92 days subsystem for~ 1O minutes.

SR 3.5.2.5 ---------------------N ()TE--------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem 24 months can be manually operated.

SR 3.5.2.6 Verify each valve credited for automatically isolating 24 months a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

SR 3.5.2.7 Verify DRAIN TIME~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 2.2.4 Deletion of Reference to OPDRVs and other miscellaneous changes 2.2.4.1 Deletion of Reference to OPDRVs In Reference 1, the licensee proposed to revise existing TS requirements related to "operations with a potential for draining the reactor vessel" or "OPDRVs," with new requirements on RPV WIC that will protect Safety Limit 2.1.1.4. To remain consistent with TSTF-542, all references to the term OPDRVs in the MNGP TSs would be deleted. The TS location of these references are summarized as follows:

MNGPLCO Location of OPDRVs Reference 3.3.6.1, Primary Containment Isolation Table 3.3.6.1-1, Footnote (a) is deleted, Instrumentation Condition I (Previously described in Section 2.2.2.3 of this SE) 3.3.6.2, Secondary Containment Isolation Table 3.3.6.2-1 Footnote (a)

Instrumentation 3.3.7.1, Control Room Emergency Filtration Table 3.3.7.1-1 Footnote (a)

System Instrumentation

3.3.8.2, Reactor Protection System (RPS) Applicability, Condition F Electrical Power Monitorina 3.6.1.3, Primary Containment Isolation Applicability, Condition G Valves (PCIVs) 3.6.4.1, Secondary Containment Applicability, Condition C 3.6.4.2, Secondary Containment Isolation Applicability, Condition D Valves (SCIVs) 3.6.4.3, Standby Gas Treatment (SGT) Applicability, Conditions C and E System 3.7.4, Control Room Emergency Filtration Applicability, Conditions D and F (CREF) System 3.7.5, Control Room Ventilation Svstem Aoolicabilitv, Conditions D and E 3.8.2, AC [alternating current] Sources - Conditions A and B Shutdown Existing Required Actions A.2.4 and 8.4 are renumbered as A.2.3 and 8.3, respectively 3.8.5, DC [direct current] Sources - Condition A Shutdown Existing Required Actions A.4 is renumbered as A.3 3.8.8, Distribution Systems - Shutdown Condition A Existing Required Actions A.2.4 and A.2.5 are renumbered as A.2.3 and A.2.4, respectively 2.2.4.2 Other Miscellaneous Changes The licensee corrected title for LCO 3.5.2 in TS SR 3.8.2.1, Note 2. The proposed changes are shown below.

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

2.2.5 MNGP Plant-Specific TSTF-542 TS Variations Section 2.2, Attachment 1 of Reference 1, identified several MNGP plant-specific TS variations from TSTF-542, Revision 2 (Reference 4), or the NRG-approved TSTF-542 SE (Reference 5).

The licensee states these variations do not affect the applicability of TSTF-542 or the NRC staff's SE. Section 3.5 of this SE includes the staff's evaluation of each of these technical variations.

2.2.5.1 Variation 1, Table 3.3.5.1-1, Core Spray [CS] Pump Discharge Flow - Low (Bypass),

NUREG-1433, Table 3.3.5.1-1, Function 1.d, Core Spray Pump Discharge Flow- Low (Bypass), is not included in the MNGP TSs. As a result, this function was not included in TS 3.3.5.3, RPV WIC, Table 3.3.5.3-1.

2.2.5.2 Variation 2, Table 3.3.5.1-1, Manual Initiation The MNGP TS, Table 3.3.5.1-1, ECCS Instrumentation, does not include functions for manual initiation of CS and LPCI. Since the TS does not include this feature, proposed Table 3.3.5.3-1 in the LAR does not include manual initiation functions for CS and LPCI. In addition, proposed TS Table 3.3.5.3-1 does not include an SR for a logic system functional test since the SR applies only to the manual initiation function. As an alternative to NUREG-1433 SR 3.5.2.8, which demonstrates ECCS injection/spray actuation on a manual initiation signal, NSPM proposes that TS 3.5.2, "RPV Water Inventory Control," include a new SR 3.5.2.5 to verify the required CS or LPCI subsystem can be manually operated through the manipulation of the subsystem components from the control room.

2.2.5.3 Variation 3, TS Table 3.3.5.3-1, Channel Checks The LAR states that MNGP design does not provide the capability to perform channel checks for the following functions in existing Table 3.3.5.1-1: Function 1.c, Reactor Steam Dome Pressure - Low (Injection Permissive), Function 2.c, Reactor Steam Dome Pressure - Low (Injection Permissive), and Function 2.g, Low Pressure Coolant Injection Pump Discharge Flow

- Low (Bypass). Therefore, Channel Checks are not included in Table 3.3.5.3-1 of the LAR for these functions.

In Reference 1, Attachment 1, Section 2.2, "Variation," item h (page 5 of 9), Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass), was incorrectly identified as Function 2.d. This function was corrected in Reference 2 from Function 2.d to Function 2.g.

2.2.5.4 Variation 4, SR 3.5.2.4, Recirculation Line The LAR states that SR 3.5.2.4 has been modified to remove the phrase "through the recirculation line" to avoid potential confusion with the reactor recirculation lines or the CS and RHR pump minimum flow lines, which are sometimes referred to as "recirculation lines" in plant procedures.

2.2.5.5 Variation 5, Table 3.3.5.1-1, Steam Dome Pressure Permissive-Low (Pump Permissive)

The LAR states that MNGP TS Table 3.3.5.1-1, Functions 1.d and 2.d describe the Reactor Steam Dome Pressure Permissive-Low (Pump Permissive) functions for CS and LPCI. These channels delay CS and LPCI pump starts on a Reactor Vessel Water Level - Low Low signal until reactor steam dome pressure is below the setpoint. This.ensures that, prior to starting low pressure ECCS subsystem pumps, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. This function is bypassed during manual operation; therefore, these Modes 4 and 5 functions and their corresponding SR can be removed from the TS because the required ECCS subsystem is proposed to be started by manual operation.

2.2.5.6 Variation 6, Table 3.3.5.1-1, Steam Dome Pressure Permissive- Bypass Timer (Pump Permissive)

The MNGP TS, Table 3.3.5.1-1, Functions 1.e and 2.e, describe Reactor Steam Dome Pressure Permissive bypass time delays for the CS and LPCI pumps. The LAR states that the Bypass Timer channels allow the CS and LPCI pumps to start on a Reactor Vessel Water Level - Low

Low signal after the bypass timer times out, even if the reactor steam dome pressure is above its permissive setpoint. This ensures that starting the pumps of the low pressure ECCS subsystems will occur on a Reactor Vessel Water Level - Low Low signal after an 18-minute time delay.

The LAR states that this time delay is unnecessary for manual operation; therefore, these Mode 4 and 5 functions and their corresponding SRs can be removed from the TS because the required ECCS subsystem is proposed to be started by manual operation.

2.2.5.7 Variation 7, Table 3.3.5.1-1, Core Spray Pump Start-Time Delay Relays MNGP TS, Table 3.3.5.1-1, Function 1.f, describes the Core Spray Pump Start - Time Delay Relays for the CS pumps. The LAR states that this function is not included in NUREG-1433; however, it is similar to the LPCI Pump Start - Time Delay Relays (Function 2.f). The LAR states that the purpose of the time delay relays is to stagger the start of the CS and LPCI pumps that are in Divisions 1 and 2, thus limiting the starting transients on the 4.16 kV (kilovolt) essential buses. This time delay is unnecessary for manual operation; therefore, this function does not need to be included and can be removed from the TS.

2.2.5.8 Variation 8, Table 3.3.7.1-1, Reactor Building Ventilation Exhaust Radiation The LAR includes Table 3.3.7.1-1, Function 3, Reactor Building Ventilation Exhaust Radiation -

High in lieu of a Control Room Air Inlet Radiation - High function (NUREG 1433, Table 3.3.7.1-1, Function 5). The LAR states that like the Control Room Air Inlet Radiation - High function, this function initiates the CREF System to isolate the control room envelope from untreated outside air. Therefore, the Reactor Building Ventilation Exhaust Radiation - High is the MNGP equivalent function to the Standard Technical Specification (STS) Control Room Air Inlet Radiation - High function and is being revised in a similar manner to how TSTF-542 revises the STS Control Room Air Inlet Radiation - High function.

2.2.5.9 Variation 9, TS 3.3.8.2, RPS Electric Power Monitoring (EPM)

The LAR proposed revising TS, Section 3.3.8.2, RPS EPM, to remove references to OPDRVs from the Applicability of the LCO and from Condition F. The LAR states that this is an MNGP specific section and does not have an equivalent in the STS, however, the justification for removing references to OPDRVs found in the STS applies to this section and the references are being removed.

2.2.5.10 Variation 10, SR 3.5.2.1, ECCS Water Supply (suppression pool and condensate storage tank (CST)

The LAR states that the corresponding NUREG -1433, SRs 3.5.2.2 and 3.5.2.3, are combined into a single SR 3.5.2.1 because the requirements for suppression pool water level and CST levels are applicable to both the CS and LPCI systems (i.e., the CS and LPCI systems both have the capability to draw a suction flow path).

2.3 Applicable Regulatory Requirements and Guidane The regulation at Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36(a)(1 ),

requires an applicant for an operating license to include in the application proposed TSs in accordance with the requirements of 10 CFR 50.36. The applicant must also include in the

application, a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." However, per 10 CFR 50.36(a)(1 ), these TS bases "shall not become part of the technical specifications."

As required by 10 CFR 50.36(c)(1)(i)(a), TSs will include items in the following categories:

Safety limits, limiting safety system settings, and limiting control settings. (i)(A) Safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity. If any safety limit is exceeded, the reactor must be shut down. The licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence. Operation must not be resumed until authorized by the Commission.

As required by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The regulation 10 CFR 50.36(c)(2)(ii) requires licensees to establish TS LCOs for items meeting one or more of the listed criteria. Specifically, Criterion 4, "A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety," supports the establishment of LCOs for RPV WIC due to insights gained via operating experience.

The regulation 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

Pursuant to 10 CFR 50.90, whenever a holder of an operating license desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications. The technical information to be included in an application for an operating license is governed in particular by 10 CFR 50.34(b).

As described in 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate. The general considerations that guide the Commission include, as stated in 10 CFR 50.40(a), how the TSs provide reasonable assurance that the health and safety of the public will not be endangered. Also, to issue an operating license, of which TSs are a part, the Commission must make the findings of 10 CFR 50.57, including the 10 CFR 50.57(a)(3)(i) finding that there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public.

NUREG-1433, Revision 4 (References 5 and 6), contains the STSs for BWR/4 [General Electric] plants and is part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the light-water reactor nuclear designs.

The NRC staffs guidance for review of TSs is in Chapter 16, "Technical Specifications," of NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (SRP), dated March 2010 (Reference 6).

2.3.1 MNGP Applicable Regulatory Design Requirements Monticello updated safety analysis report (USAR), Appendix E, "Plant Comparative Evaluation with the Proposed Atomic Energy Commission (AEC) 70 Design Criteria," describes the evaluation of the design basis of MNGP with the 70 General Design Criteria for Nuclear Power Plant Construction Permits proposed by the AEC for public comment in July 1967.

The comparative evaluation is made with each of the nine groups of criteria sent out in the July 1967 AEC release. As to each group, there is a statement of Northern States Power Company's current understanding of the intent of the criteria in that group and a discussion of the plant design conformance with the intent of the group of criteria. The following criteria from the MNGP USAR are related to this LAR.

Criterion 9 - Reactor Coolant Pressure Boundary. The reactor coolant pressure boundary (RCPB) shall be designed and constructed so as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime.

Criterion 12 - Instrumentation and Control Systems. Instrumentation and controls shall be provided as required to monitor and maintain variables within prescribed operating ranges.

Criterion 16 - Monitoring Reactor Coolant Pressure Boundary. Means shall be provided for monitoring the RCPB to detect leakage.

Criterion 37 - Engineering Safety Features Bases for Design. The engineered safety features (ESFs) shall be provided in the facility to back up the safety provided by the core design, the RCPB, and their protection systems. As a minimum, such ESFs shall be designed to cope with any size RCPB break up to and including the circumferential rupture of any pipe in that boundary assuming unobstructed discharge from both ends.

Criterion 41 - Engineering Safety Features Performance Capability. The ESFs such as emergency core cooling and containment heat removal systems shall provide sufficient performance capability to accommodate partial loss of installed capacity and still fulfill the required safety function. As a minimum, each ESF shall provide this required safety function assuming a failure of a single active component.

Criterion 44 - Emergency Core Cooling Systems Capability. At least two ECCS systems, preferably of different design principles, each with a capability for accomplishing abundant emergency core cooling, shall be provided. Each ECCS and the core shall be designed to prevent fuel and clad damage that would interfere with the RCPB, including the double-ended rupture of the largest pipe. The performance of each ECCS core cooling system shall be evaluated conservatively in each area of uncertainty. The systems shall not share active components and shall not share other features or components unless it can be demonstrated that; (a) the capability of the shared feature or components to perform its required function can be readily ascertained during reactor operation, (b) failure of the shared feature or component does not initiate a loss-of-coolant accident, and (c) capability of the shared feature or component to perform its required function is not impaired by the effects of a LOCA and is not lost during the entire period this function is required following the accident.

3.0 TECHNICAL EVALUATION

Section 2.2 above lists the proposed TS changes, as included in References 1, 2, and 3, for the licensee to adopt TSTF-542, Revision 2. The following sections summarize the NRC staff's evaluation of each of these proposed changes.

3.1 Staff Evaluation of Proposed "DRAIN TIME" Definition As discussed in Section 2.2.1 above, the "DRAIN TIME" is the time it would take the RPV water inventory to drain from the current level to the TAF assuming the most limiting of the RPV penetrations flow paths with the largest flow rate, or a combination of penetration flow paths that could open due to a common mode failure, were to open and the licensee took no mitigating action.

The NRC staff reviewed the proposed DRAIN TIME definition from the TSTF-542. For the purpose of staff considerations, the term "break" describes a pathway for water to drain from the RPV that has not been prescribed in the "DRAIN TIME" definition in TSTF-542. Based on the information provided by the licensee, the NRC staff has determined that the licensee is appropriately adopting the principles of DRAIN TIME as described in TSTF-542.

As part of this evaluation, the NRC staff reviewed requests for additional information (RAI) used during the development of TSTF-542, Revision 2, which provided examples of bounding DRAIN TIME calculations for three examples: (1) water level at or below the RPV flange; (2) water level above the RPV flange with fuel pool gates installed; and (3) water level above the RPV flange with fuel pool gates removed. The DRAIN TIME is calculated by taking the water inventory above the break and dividing by the limiting drain rate until the TAF is reached. The limiting drain rate is a variable parameter depending on the break size and the reduction of elevation head above break location during the drain down event. The discharge point will depend on the lowest potential drain point for each RPV penetration flow path on a plant-specific basis. This calculation provides a conservative approach to determining the DRAIN TIME of the RPV.

The NRC staff concludes that the licensee will use methods resulting in conservative calculations to determine DRAIN TIME, thereby, protecting Safety Limit 2.1.1.4 which meets the requirements of 10 CFR 50.36(c)(3). Based on these considerations, the NRC staff has determined that the licensee's proposed addition of the DRAIN TIME definition to the MNGP TSs is acceptable.

3.2 Staff Evaluation of Proposed TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" The LAR states that the purpose of the proposed new TS 3.3.5.3 regarding RPV WIC Instrumentation is to support the requirements of revised TS LCO 3.5.2, and the proposed new definition of DRAIN TIME. There are instrumentation and controls and their signal functions that are required for manual pump starts or required as a permissive or operational controls on the equipment of the systems that provide water injection capability, certain start commands, pump protection, and isolation functions. These instruments are required to be operable if the systems that provide water injection and isolation functions are to be considered operable as described in Section 3.3 of this SE for revised TS 3.5.2. For MNGP, reactor operators have alternate means, often requiring several more steps, to start and inject water than the preferred

simple push button start, but can still be accomplished within the time frames assumed in development of TSTF-542. Specifically, the proposed new TS 3.3.5.2 supports operation of the CS and LPCI including manual starts when needed as well as the system isolation of the RHR SDC and RWCU system. The equipment involved with each of these systems is described in the evaluation of TS 3.5.2 below in Section 3.3 and the Bases for LCO 3.5.2. The following sections provide the NRC staff's evaluation of the new TS 3.3.5.3 for RPV WIC Instrumentation.

3.2.1 Staff Evaluation of Proposed TS 3.3.5.3 LCO and Applicability The LAR proposed a new TS 3.3.5.3 to provide alternative instrumentation requirements to support manual initiation of the ECCS injection/spray subsystem. This subsystem is required in the revised TS 3.5.2 and automatic isolation of penetration flow paths that may be credited in the determination of DRAIN TIME. The current TSs contain instrumentation requirements related to OPDRVs in TS Tables 3.3.5.1-1, 3.3.6.1-1, 3.3.6.2-1, 3.3.7-1, and 3.3.8.2. The requirements from Tables 3.3.5.1-1 and Table 3.3.6.1-1 would be consolidated into new TS 3.3.5.3. The OPDRVs requirements in Tables 3.3.6.2-1, 3.3.7.1-1, and 3.3.8.2 would be deleted, as discussed in Section 3.6 of this SE.

The proposed LCO 3.3.5.3 would state: "The RPV Water Inventory Control Instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE."

The proposed Applicability would state: "According to Table 3.3.5.3-1."

The TSTF-542 selected a table to contain those instrumentation functions needed to support manual initiation of the ECCS injection/spray subsystem required by LCO 3.5.2, and for automatic isolation of penetration flow paths that may be credited in a calculation of DRAIN TIME. The functions that are required in Modes 4 or 5, or during OPDRVs, are relocated to Table 3.3.5.3-1 from existing TS 3.3.5.1, "ECCS Instrumentation," and TS 3.3.6.1, "Primary Containment Isolation Instrumentation." Creation of TS 3.3.5.3 places these functions in a single location with requirements appropriate to support the safety function for TS 3.5.2.

As identified in Section 2.2.5.2 above (Variation 2), the MNGP current design-basis does not include a manual initiation logic for the CS or LPCI systems. Therefore, as an alternative, the licensee proposed to add new SR 3.5.2.5 to TS 3.5.2 to verify that CS and LPCI can be manually operated through the manipulation of subsystem components from the main control room.

The NRC staff concludes that the licensee's proposed alternative is acceptable for MNGP since either CS or LPCI (or both) subsystems would be available to perform the intended function to inject water into the RPV; this meets the intent of the NRC approved TSTF-542.

3.2.2 Staff Evaluation of Proposed TS 3.3.5.3 Actions As discussed in Section 2.2.2.2 above, the NRC staff has reviewed the licensee's proposed new TS 3.3.5.3 "Actions" to determine whether they provide effective remedial measures when one or more instrument channels are inoperable and cannot complete the required function in the normal manner. The "Actions" are evaluated as follows:

Action A would be applicable when one or more instrument channels are inoperable from Table 3.3.5.3-1 and directs the licensee to immediately enter the condition referenced in Table 3.3.5.3-1 for that channel.

Action 8 (concerning the SOC system isolation and RWCU system isolation functions) would be applicable when automatic isolation of the associated penetration flow path is credited as a path for potential drainage in calculating DRAIN TIME. If the instrumentation is inoperable, Required Action 8.1 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation. Required Action 8.2 requires an immediate recalculation of DRAIN TIME but automatic isolation of the affected penetration flow paths cannot be credited.

Action C ( concerning low reactor steam dome pressure permissive functions necessary for ECCS subsystem manual injection valve opening) would address an event in which the permissive is inoperable. The function must be placed in the trip condition within one hour. With the permissive function instrument in the trip condition, manual injection valve opening may now be performed using the preferred control board switches. This 1-hour Completion Time (CT) is acceptable, despite the preferred start method being prevented, the reactor operator can take manual control of the pump and the injection valve to inject water into the RPV and achieve the safety function in that time. The time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months also provides reasonable time for evaluation and placing the channel in trip.

Action D (concerning LPCI pump discharge flow bypass functions) would address actions when the bypass is inoperable and then there is a risk that the associated ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection. Similar to the justification for Action C, while this is not the preferred method, the LPCI subsystem pumps can be started manually and the valves can be opened manually. As functions can be performed manually and allows time for the operator to evaluate the necessary repairs, the 24-hour CT is acceptable.

Action E would apply if the Required Actions and associated CTs of Conditions C or D were not met. If they were not met, then the associated low pressure ECCS injection/spray subsystem might be incapable of performing the intended function, and the CS/LPCI subsystem would be declared inoperable immediately.

These "Actions" direct the licensee to take appropriate actions and enter immediately into the conditions referenced in Table 3.3.5.3-1. The NRC staff has determined that these "Actions" satisfy the requirements of 10 CFR 50.36(c)(2)(i) by providing a remedial action permitted by the TSs until the LCO can be met. Therefore, the NRC staff has concluded there is reasonable assurance that the licensee will take appropriate actions during an unexpected drain event to either prevent or to mitigate RPV water level being lowered to the TAF and, therefore, the proposed actions are acceptable.

3.2.3 Staff Evaluation of Proposed TS 3.3.5.3 Surveillances SR 3.3.5.3.1 would require a Channel Check and applies to system isolation functions in TS Table 3.3.5.3-1 for SOC and RWCU. Performance of the Channel Check would ensure that a gross failure of instrumentation has not occurred. A Channel Check is normally a comparison of the parameter indicated on one channel to a similar parameter on other related channels. A Channel Check is significant in assuring that there is a low probability of an undetected complete channel failure and is a key safety practice to verifying the instrumentation continues to operate properly between each Channel Functional Test. The frequency is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months which is

consistent with the existing requirements found in SR 3.3.5.1.1, Channel Check for Modes 1, 2, and 3.

SR 3.3.5.3.2 would require a Channel Functional Test and applies to all functions in TS Table 3.3.5.3-1. A Channel Functional Test is the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify operability of all devices in the channel required for channel operability. It would be performed on each required channel to ensure that the entire channel will perform the intended function. The frequency is 92 days which is consistent with the existing requirements found in SR 3.3.5.1.2, Channel Functional Test for Modes 1, 2, and 3. This is acceptable because it is consistent with the existing requirements for these Functions. In addition, if the licensee so desires, this SR could be included as part of a refueling activity since during refueling outages in periods in Modes 4 and 5 are often 30 days or less.

The TSTF-542 did not include SRs to verify or adjust the instrument setpoint derived from the allowable value using a Channel Calibration, Logic System Functional Test, or a surveillance to calibrate the trip unit. This is because a draining event in Modes 4 or 5 is not an analyzed accident and, therefore, there is no accident analysis on which to base the calculation of a setpoint. The TS Table 3.3.5.3-1 Functions requiring SR 3.3.5.3.2 allow ECCS manual initiation or automatically isolate a penetration flow path; however, no specific RPV water level is assumed for those actions.

Therefore, the allowable value for Mode 3 was chosen for use in Modes 4 and 5 as it will perform the desired function. Calibrating the functions in Modes 4 and 5 is not necessary as TSs 3.3.5.1 and 3.3.6.1 continue to require the Functions to be calibrated on an established interval. Also, a draining event in Modes 4 or 5 is not an analyzed accident and, therefore, there are no assumptions on response times required as part of this LAR. The NRC staff has determined that the Mode 3 allowable value and established calibration intervals are adequate to ensure the channel will respond as required to allow manual initiation of the pumping systems to inject water and automatic isolation of penetration flow paths.

The proposed new TS 3.3.5.3 SRs include Channel Checks and Channel Functional Tests numbered SRs 3.3.5.3.1 and 3.3.5.3.2, respectively. The NRC staff finds that these tests are sufficient and adequate, because they will ensure the functions of TS 3.3.5.3 are operable (i.e.,

capable of performing the specified safety function in support of TS 3.5.2, DRAIN TIME, and the protection from a potential drain down of the RPV in Modes 4 and 5). The NRG staff finds the proposed SRs of LCO 3.3.5.3 are acceptable and conclude that these SRs satisfy 10 GFR 50.36(c)(3) by providing the specific SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained.

Based on the above, the NRG staff concludes that the proposed SRs of LGO 3.3.5.3 satisfy 10 CFR 50.36(c)(3) by providing the specific SRs relating to test, calibration, or inspection to assure that the necessary operability of systems and components is maintained and are, therefore, acceptable.

3.2.4 Staff Evaluation of Proposed Table 3.3.5.3-1, "RPV Water Inventory Control Instrumentation" In order to support the requirements of proposed TS 3.5.2, the associated instrumentation requirements are designated in Table 3.3.5.3-1. These instruments would be required to be

operable if the systems that provide water injection and isolation functions were to be considered operable as described in the NRC staff's evaluation of TS 3.5.2 (Section 3.3 below).

Proposed Table 3.3.5.3-1 specifies the instrumentation that shall be operable for each function in Modes 4 and 5 (or other specified conditions), the required number of channels per function, conditions referenced from Required Action A.1, SR for the functions, the allowable value, and footnotes concerning items of the table.

The NRC staff finds this proposed table is acceptable because it sufficiently discusses the purpose of the functions, the applicability, the number of required channels, the references to the Condition to be entered by letter (e.g., B, C, D) if the function is inoperable, the applicable SRs, the selection of the allowable value, and justification of differences between the current and proposed TS functions.

This RPV WIC Instrumentation set is acceptable, because it is adequate so that the instrument channels respond with the required accuracy permitting pump systems to inject water when needed, and activating isolation equipment when commanded to support prevention or mitigation of a potential RPV draining event.

3.2.4.1 Staff Evaluation of Proposed Table 3.3.5.3-1 Functions For the Table 3.3.5.3-1, Functions 1.a (CS) and 2.a (LPCI), Reactor Steam Dome Pressure -

Low (Injection Permissive), the signals would be used as permissives for the low pressure ECCS injection/spray subsystem manual initiation functions. This function would ensure that the reactor pressure has fallen to a value below these subsystems' maximum design pressure before permitting the operator to open the injection valves of the low pressure ECCS subsystems. Even though the reactor steam dome pressure is expected to be below the ECCS maximum design pumping pressure during Modes 4 and 5, the Reactor Pressure - Low signals would be required to be operable and capable of permitting initiation of the ECCS. The proposed allowable value would be .:: 397 pounds per square inch gauge (psig) and s; 440 psig, with two required channels per function as it is currently in MNGP TS, Table 3.3.5.1-1.

For the Table 3.3.5.3-1, Functions 2.b, LPCI system, Pump Discharge Flow - Low (Bypass),

these minimum flow instruments were proposed to protect the associated low pressure ECCS pumps from overheating when the pump is operating and the associated injection valve is not fully open. The LPCI minimum flow valves are time delayed such that the valves will not open for 10 seconds after the pump start. This delay can reduce the reactor vessel inventory loss (to the suppression pool) during the startup of the RHR pump while aligned in the SOC mode, since it provides time (prior to opening the minimum flow valve) to manually increase RHR flow above the minimum flow closure setpoint. The proposed required channels per function would be one per pump, as it is currently found in MNGP TS Table 3.3.5.1-1. The proposed allowable values 2.b is.:: 360 gallons per minute (gpm) ands; 745 gpm.

For Table 3.3.5.3-1, Function 3.a, SOC system isolation, Reactor Vessel Water Level - Low, the function would only be required to be operable when automatic isolation of the associated penetration flow path is credited in the DRAIN TIME calculation. The proposed number of required instrument channels is two-in-one trip system. The condition that the RHR system integrity be maintained is a concept related to OPDRVs, so it would not be carried over into TS 3.3.5.3 for RPV WIC Instrumentation. Reactor Vessel Water Level - Low signals are initiated from four level transmitters that sense the difference between the pressure due to a constant cotumn of water (reference leg) and the pressure due to the actual water level (variable leg) in

the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low Function are available, only two channels (all in the same trip system) are required to be Operable to ensure automatic isolation of one of the two isolation valves. The allowable value was chosen to be the same as the Primary Containment Isolation Instrumentation Reactor Vessel Water Level - Low, Allowable Value (Function 6.b) from LCO 3.3.6.1, which is~ 7 inches.

For Table 3.3.5.3-1, Function 4.a, RWCU system isolation, Reactor Vessel Water Level - Low, Low, the function is only required to be operable when automatic isolation of the associated penetration flow path is credited in the DRAIN TIME calculation. The proposed number of required instrument channels is two-in-one trip system. Reactor Vessel Water Level - Low Low signals are initiated from four differential pressure transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low Low Function are available, only two channels (all in the same trip system) are required to be Operable. This proposed change is a new requirement in Modes 4 and 5 for the RWCU system. However, the instrumentation function is the same as TS Table 3.3.6.1, Function 5.e, which contains the requirements for Modes 1, 2, and 3, with the same allowable value, ~ - 48 inches.

The NRC staff finds that the proposed new LCO 3.3.5.3 correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the Required Actions to be taken when the LCO is not met are adequate to protect without endangering the health and safety of the public. This meets the requirements of 10 CFR 50.36(c)(2)(i) and, therefore, the staff has determined that the licensee's proposed changes to LCO 3.3.5.3 are acceptable.

3.3 Staff Evaluation of TS 3.5.2 - RPV WIC The NRC staff reviewed the water sources that would be applicable to the proposed TS 3.5.2.

The proposed LCO 3.5.2 would state, in part:

"One low pressure ECCS injection/spray subsystem shall be OPERABLE."

'One' low pressure ECCS injection/spray subsystem would consist of either one CS subsystem or one LPCI subsystem. A CS subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool or one or both CSTs to the RPV. An LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or one or both CSTs to the RPV. The ECCS pumps are high-capacity pumps with flow rates of thousands of gpm. Most RPV penetration flow paths would have a drain rate on the order of tens or hundreds of gpm. The manual initiation/start of an ECCS pump would provide the necessary water source to counter these expected drain rates. The LPCI subsystem is to be considered operable during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable. The OHR in Modes 4 and 5 is not affected by the proposed MNGP TS change as these requirements on the number of SOC subsystems that must be operable and in operation to ensure adequate OHR from the core are 'unchanged. These requirements can be found in the MNGP TS 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," TS 3.9.7, "Residual Heat Removal (RHR) - High Water Level," and TS 3.9.8, "Residual Heat Removal (RHR) - Low Water Level." These MNGP OHR requirements are similar to the STSs and can be found in the

NUREG-1433 TS 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," TS 3.9.8, "Residual Heat Removal (RHR) - High Water Level," and TS 3.9.10, "Residual Heat Removal (RHR) - Low Water Level." Based on these considerations, the NRC staff finds that the water sources provide reasonable assurances that the lowest functional capability required for safe operation is maintained and the safety limit is protected.

The proposed TS LCO 3.5.2 contains two parts. The first part states that DRAIN TIME of RPV water inventory to the TAF shall be .:: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and the second part states that one low pressure ECCS injection/spray subsystem shall be OPERABLE. The proposed Applicability for TS 3.5.2 is Modes 4 and 5.

The proposed LCO 3.5.2 note states:

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

The NRC staff reviewed the proposed TS 3.5.2, focusing on ensuring that the fuel remains covered with water and on the changes made compared to the current TS. The proposed TS 3.5.2 contains Conditions A through E based on either required ECCS injection/spray subsystem operability or DRAIN TIME.

The current TS LCO states that two low pressure ECCS injection/spray subsystems shall be operable, whereas, the proposed LCO 3.5.2 states that only one low pressure ECCS injection/spray subsystem shall be operable. This change is reflected in Condition A. The change from two low pressure ECCS injection/spray subsystems to one low pressure ECCS injection/spray subsystem is because this redundancy is not required. With one ECCS injection/spray subsystem and nonsafety-related injection sources, defense-in-depth (DID) will be maintained. The DID measure is consistent with other events considered during shutdown with no additional single failure assumed. The DRAIN TIME controls in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

The proposed Modes 4 and 5 Applicability of TS 3.5.2 is appropriate given that the TS requirements on ECCS in Modes 1, 2, and 3 will be unaffected.

The proposed Condition A states that if the required ECCS injection/spray subsystem is inoperable it is to be restored to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The proposed Condition B states that if Condition A is not met, initiate action to establish a method of water injection capable of operating without offsite electrical power immediately. The proposed Condition B provides adequate assurance of an available water source should Condition A not be met within the 4-hour CT.

The proposed Condition C states that for a DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and .:: 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , to (C.1) verify the secondary containment boundary is capable of being established in less than the DRAIN TIME with a CT of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and (C.2) verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME with a CT of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and (C.3) verify one SGT subsystem is capable of being placed in operation in less than the DRAIN TIME with a CT of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The proposed Condition C provides adequate protection should the DRAIN TIME be < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and .:: 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the ability to establish secondary

containment, isolate additional flow paths, and have the SGT subsystem capable of being placed in operations.

The proposed Condition D states that when DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to (D.1) immediately initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for .?: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , (D.2) immediately initiate action to restore secondary containment boundary, and (D.3) immediately initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room, and (D.4) immediately initiate action to verify one SGT subsystem is capable of being placed in operation. Additionally, there is a note stating that required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power which is similar to proposed Condition B. The current MNGP TS for Condition D (Required Action C.2 and associated CT not met) is similar to proposed Condition D. The proposed Condition D provides adequate protection should the DRAIN TIME be < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the requirement for the ability to establish an additional method of water injection (without offsite electrical power), establish secondary containment, isolate additional flow paths, and have the SGT subsystem capable of being placed in operation.

The proposed Condition E states that when the required action and associated CT of Condition C or Dis not met, or the DRAIN TIME is< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , then immediately initiate action to restore DRAIN TIME to.?: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The proposed Condition Eis new as it is not present in the current MNGP TS. The proposed Condition E is acceptable as it provides the necessary step to restore DRAIN TIME to.?: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months should the other conditions not be met or if the DRAIN TIME is

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

The NRC staff evaluated the proposed changes to TS 3.5.2 and finds them acceptable based on the actions taken to mitigate the water level reaching the TAF with the water sources available and maintaining DRAIN TIME .?: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The LCO correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the Required Actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public and, therefore, are acceptable.

3.3.1 Staff Evaluation of Proposed TS 3.5.2 SRs The proposed TS 3.5.2 SRs (Section 2.2.3 above) includes, verification of water levels/volumes that support ECCS injection/spray subsystems, verification of water filled pipes to preclude water hammer events, verification of correct valves positions for the required ECCS injection/spray subsystem, operation of the ECCS injection/spray systems, verification of valves credited for automatic isolation actuated to the isolation position, verification that the required ECCS injection/spray subsystem can be manually operated, and verification of DRAIN TIME.

Each of the seven SRs are described below.

SR 3.5.2.1: The suppression pool water level (.?: - 3 ft) or CSTs water level, .?: 7 feet for one tank operation and .?: 4 feet for two tank operation, for a required ECCS injection/spray subsystem is required to be verified to ensure pump net positive suction head and vortex prevention is available for the ECCS injection/spray subsystem required to be operable by the LCO. This surveillance would be required to be performed with a frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal suppression pool or CST water level condition.

SR 3.5.2.2: The SR to verify the ECCS injection/spray subsystem piping is sufficiently filled with water would be retained from the existing TS 3.5.2. The proposed change would update the SR to reflect the change to LCO 3.5.2, which would require, in part, one low pressure ECCS injection/spray subsystem to be operable instead of two. SR 3.5.2.2 wording would change from "Verify, for each required ECCS ... " to "Verify, for the required ECCS ... " The change clarifies the requirement to maintain consistency with the proposed LCO. The ECCS injection/spray subsystem flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required ECCS injection/spray subsystem and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. ECCS injection/spray subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

This surveillance would be required to be performed with a frequency of 31 days. This frequency is considered adequate based on the gradual nature of void buildup in the ECCS injection/spray subsystem piping, the procedural controls governing system operation, and operating experience.

SR 3.5.2.3: The SR to verify the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path would be retained from the existing TS 3.5.2.

Similar to the change discussed above for proposed SR 3.5.2.2, changes to SR 3.5.2.3 would clarify a proposed requirement for LCO 3.5.2. The proposed SR wording, "Verify, for the required ECCS injection/spray subsystem each manual ... " would replace "Verify each required ECCS injection/spray subsystem manual ... " SR 3.5.2.3 would provide assurance that the proper flow path will be available for ECCS operation to support TS 3.5.2. This surveillance would be required to be performed with a frequency of 31 days. This frequency is appropriate because the valves are operated under procedural control and the probability of their being mispositioned during this time period is low. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned such as check valves.

Existing Note for SR 3.5.2.3 which state; "Not required to be met for system vent flow paths opened under administrative control," is maintained for SR 3.5.2.3.

SR 3.5.2.4: The required ECCS injection/spray subsystem would be required to be operated for

~ 10 minutes. This surveillance would be required to be performed with a frequency of 92 days.

The performance frequency of 92 days is consistent with similar at-power testing required by SR 3.5.1.7. This would demonstrate that the subsystem is capable of operation to support TS 3.5.2. Testing the ECCS injection/spray subsystem through the CS/LPCI minimum flow lines or recirculation line is necessary to avoid overfilling the refueling cavity. The minimum operating time of 10 minutes is based on engineering judgment.

Variation 4 (Section 3.5.4 of this SE) also describes the ECCS operations for~ 10 minutes.

SR 3.5.2.5: This SR would state, "Verify the required ECCS injection/spray subsystem can be manually operated." It would demonstrate that the required CS or LPCI subsystem could be manually initiated using the associated pump and valve switches to provide additional RPV

water inventory, if needed. Vessel injection/spray may be excluded from the SR, per the existing note. This surveillance would be required to be performed with a frequency of 24 months. The 24-month frequency is based on the need to perform the surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the SR when performed at the 24 month frequency, which is based on the refueling cycle.

SR 3.5.2.6: Verification that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal would be required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. This surveillance would be required to be performed with a frequency of 24 months which is based on the need to perform this surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the surveillance were performed with the reactor at power.

SR 3.5.2.7: The DRAIN TIME would be determined or calculated, and required to be verified to be ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This surveillance would be required to be performed with a frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This frequency is based on indications of RPV water level available to the operator. This surveillance would verify that the LCO for DRAIN TIME is met. Numerous indications of changes in RPV level are available to the operator. The period of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate draining of reactor coolant (normally 3 operator shifts). Changes in RPV level would necessitate recalculation of the DRAIN TIME.

The NRC staff evaluated each of these proposed SRs associated with the proposed LCO 3.5.2 and concluded that they are appropriate for ensuring the operability of the equipment and instrumentation specified in LCO 3.5.2. The staff concluded that each of the proposed SRs are acceptable since they meet the requirements of 10 CFR 50.36(c)(2)(ii) regarding insights gained via operating experience and 10 CFR 50.36(c)(3) for SRs by ensuring that the necessary quality of systems and components are maintained.

3.4 Staff Evaluation of TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation" The TS LCO 3.3.5.1 currently states that, "the ECCS instrumentation for each function in Table 3.3.5.1-1 shall be OPERABLE" and the applicability of the action statements are identified in the table. Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," currently contains requirements for function operability during Modes 4 and 5 when the associated ECCS subsystem(s) are required to be operable. Changes to conform the MNGP TS to TSTF-542 were proposed for the actions table of LCO 3.3.5.1 as well.

For the following functions in Table 3.3.5.1-1, Modes 4 and 5 requirements would be either completely deleted or relocated to proposed Table 3.3.5.2-1:

FUNCTION FUNCTIONS FUNCTION COMPLETELY RELOCATED DELETED TO TABLE 3.3.5.3-1

1. Core Spray System (a) Reactor Vessel Water Level - Low Low Yes (c) Reactor Steam Dome Pressure - Low (Injection No Function 1.a Permissive)

(d) Reactor Steam Dome Pressure Permissive - Low (Pump Yes Permissive)

(e) Reactor Steam Dome Pressure Permissive - Bypass Yes Timer (Pump Permissive)

(f) Core Spray Pump Start - Time Delay Relay Yes

2. Low Pressure Coolant Injection (LPCI) System (a) Reactor Vessel Water Level - Low Low Yes (c) Reactor Steam Dome Pressure - Low (Injection No Function 2.a Permissive)

(d) Reactor Steam Dome Pressure Permissive - Low (Pump Yes Permissive)

(e) Reactor Steam Dome Pressure Permissive - Bypass Timer Yes (Pump Permissive)

(f) Low Pressure Coolant Injection Pump Start - Time Delay Yes Relay (g) Low Pressure Coolant Injection Pump Discharge Flow - No Function 2.b Low (Bypass)

The requirements for Functions 1.c, 2.c, and 2.g would be moved to proposed TS Table 3.3.5.3-1 as discussed in Section 3.2.4.1 of this SE.

For TS Table 3.3.5.1-1 Functions 1.a, 1.d, 1.e, 1.f, 2.a, 2.d, 2.e, and 2.f, the Modes 4 and 5 requirements would not be retained. The MNGP TS currently requires automatic initiation of ECCS pumps on low reactor vessel water level. However, in Modes 4 and 5, automatic initiation of ECCS pumps could result in overfilling the refueling cavity or water flowing into the main steam lines, potentially damaging plant equipment.

The NRC staff finds acceptable the deletion of TS Table 3.3.5.1-1, Functions 1.a, and 2.a, because manual ECCS initiation is preferred over automatic initiation during Modes 4 and 5, and the operator would be able to use the most appropriately sized pumps if needed to n:,itigate a draining event.

The deletion of Functions 1.d and 2.d are described under Variation 5, (Section 3.5.5 of this SE), and the deletion of Functions 1.e and 2.e are described under Variation 6, (Section 3.5.6 of this SE).

The NRC staff finds acceptable that the deletion of Functions 1.f and 2.f, CS/LPCI pump start-time delay relay low reactor steam dome, bypass time channels. The Bypass Timer channels allow the CS and LPCI pumps to start on Reactor Vessel Water Level - Low Low after the time delay times out, even if the reactor steam dome pressure is above its permissive setpoint. NRC staff finds the deletion of the two Bypass Timer permissive functions consistent with TSTF-542 since they are no longer needed in Modes 4 and 5. These functions do not have an equivalent described in the STS. The purpose of these time delays is to provide sufficient time for the operator to inhibit any unnecessary automated data system actuation. The deletion of Function 1.f is further described under Variation 7, (Section 3.5. 7 of this SE).

3.5 Staff Evaluation of Proposed Technical Variations The licensee proposed the following technical variations from the TS changes described in TSTF-542 or the applicable parts of the NRC staffs SE for TSTF-542. The licensee stated in the LAR that these variations do not affect the applicability of TSTF-542 or the NRC staffs SE for TSTF-542 to the proposed license amendment. The NRC staff evaluated each variation below.

3.5.1 Variation 1, Table 3.3.5.1-1, Core Spray Pump Discharge Flow - Low (Bypass)

NUREG-1433, Table 3.3.5.1-1, Function 1.d, Core Spray Pump Discharge Flow- Low (Bypass), is not included in the MNGP TSs. As a result, this function is not being included in TS 3.3.5.3, RPV WIC, Table 3.3.5.3-1.

In Reference 2, the licensee stated that each MNGP CS subsystem is equipped with a minimum flow bypass line that contains a restricting orifice and locked open manual isolation valve to ensure the pump will not overheat when the associated injection valve is not fully open. The minimum flow line contains no instrumentation or active components and continuously diverts a portion of the core spray pump discharge back to the drywell suppression pool regardless of reactor system pressure or position of the injection valve.

The NRC staff has determined that the above CS Function 1.d, Table 3.3.5.1-1, noted in STS, is not a function in the MNGP TS and is not included as part of the proposed TS changes the support TSTF-542. NRC staff reviewed the RAI response (Reference 2) which indicates there is adequate protection from pump overheating via the installed minimum flow bypass line that does not require instrumentation or active components; therefore, the NRC staff finds Variation 1 acceptable.

3.5.2 Variation 2, Table 3.3.5.1-1, Manual Initiation The MNGP TS, Table 3.3.5.1-1, ECCS system instrumentation, does not include functions for manual initiation of CS and LPCI. Since the TS does not include this feature, proposed Table 3.3.5.3-1 does not include manual initiation functions for CS and LPCI. In addition, TS Table 3.3.5.3-1 does not include a SR for a logic system functional test since it applies only to the manual initiation function.

As an alternative to NUREG-1433, SR 3.5.2.8, which demonstrates ECCS injection/spray actuation on a manual initiation signal, the licensee proposes that TS 3.5.2, RPV WIC, include a new SR 3.5.2.5 to verify the required CS or LPCI subsystem can be manually operated through the manipulation of the subsystem components from the control room. This alternative is justified by the fact that a draining event is a slow evolution when compared to a design basis

LOCA, which is assumed to occur at full power, and thus there is adequate time to take manual actions (i.e., hours versus minutes). Adequate time to take action is assured since the proposed TS 3.5.2, Condition E, prohibits plant conditions that result in DRAIN TIMEs that are less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Therefore, there is sufficient time for the licensed operators to take manual action to stop an unanticipated draining event, and to manually start an ECCS injection/spray subsystem or the additional method of water injection.

The NRC staff reviewed the licensee proposed alternative and determined that although MNGP does not have the capability to start an ECCS subsystem with a single push button, the components that provide ECCS injection/spray into the RPV can be started, within sufficient time, from the main control room as required to support Modes 4 and 5 operations. The manipulation of low pressure ECCS subsystem components from the main control room would be verified in accordance with new SR 3.5.2.5. This SR verifies that the required CS or LPCI subsystem (including associated pump switches, and valves) can be manually operated to provide additional RPV water inventory, if needed. Therefore, the NRC staff finds Variation 2 acceptable.

3.5.3 Variation 3, TS Table 3.3.5.3-1, Channel Checks The MNGP design does not provide the capability to perform Channel Checks for the following functions in existing Table 3.3.5.1-1: Function 1.c, Reactor Steam .Dome Pressure - Low (Injection Permissive), Function 2.c, Reactor Steam Dome Pressure - Low (Injection Permissive), and Function 2.g, Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass). Therefore, Channel Checks are not included in Table 3.3.5.3-1 for these functions.

In Reference 1, Attachment 1, Section 2.2, "Variation," item h (page 5 of 9), Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass), was incorrectly identified as Function 2.d. This function was corrected in Reference 2 from Function 2.d to Function 2.g.

The NRC staff has determined that the above instrument functions do not have existing Channel Checks (existing TS Table 3.3.5.1-1, SR 3.3.5.1.1 ), and no future Channel Checks were proposed for any instruments being relocated to new TS Table 3.3.5.3-1 related to CS or LPCI steam dome pressure or LPCI pump discharge flow-low. Channel Checks are proposed only for reactor vessel water level-low for the RHR and RWCU systems. Since Channel Checks for these functions have no impact on manual ECCS injection/spray capabilities for CS or LPC, the licensee will retain its current licensing basis for these instruments. Therefore, the NRC staff finds Variation 3 acceptable.

3.5.4 Variation 4, SR 3.5.2.4, Recirculation Line The SR 3.5.2.4 has been modified to remove the phrase "through the recirculation line" to avoid potential confusion with the reactor recirculation lines or the CS and RHR pump minimum flow lines which are sometimes referred to as "recirculation lines" in plant procedures.

The NRC staff has determined that the deletion of the phrase "through the recirculation line" is acceptable since the intent of this SR was to verify pump CS/LPCI flow is available to mitigate a drain down event. For example, flow verification can be performed through the recirculation line and/or minimum flow lines to the suppression loop to avoid overfilling the reactor cavity.

Therefore, the NRC staff finds Variation 4 acceptable.

3.5.5 Variation 5, Table 3.3.5.1-1, Steam Dome Pressure Permissive-Low (Pump Permissive)

The MNGP TS Table 3.3.5.1-1 Functions 1.d and 2.d, describe the Reactor Steam Dome Pressure Permissive-Low (Pump Permissive) functions for CS and LPCI. These channels delay CS and LPCI pump starts on a Reactor Vessel Water Level - Low Low signal until reactor steam dome pressure is below the setpoint defined in operating procedures. This ensures that, prior to starting low pressure ECCS subsystem pumps, the reactor pressure has fallen to a value below these subsystems' maximum design pressure.

The NRG finds that this CS and LPCI steam dome pressure low pump permissive logic is unnecessary giving the new requirements set forth in TSTF-542. This function is bypassed during manual operation; therefore, since the ECCS systems will be manually operated in Modes 4 and 5, these functions and their corresponding SRs can be deleted. Consequently, there is no need for Modes 4 and 5 steam dome pressure low pump permissive logic of CS and LCPI to be operable and to respond to an unexpected draining event. A draining event is a slow evolution when compared to a design basis LOCA assumed to occur at a significant power level. Therefore, the NRG staff finds Variation 5 acceptable.

3.5.6 Variation 6, Table 3.3.5.1-1, Steam Dome Pressure Permissive- Bypass Timer (Pump Permissive)

The MNGP TS Table 3.3.5.1-1 Functions 1.e and 2.e, describe Reactor Steam Dome Pressure Permissive bypass time delays for the CS and LPCI pumps. The bypass timer channels allow the CS and LPCI pumps to start on a Reactor Vessel Water Level - Low Low signal after the bypass timer times out, even if the reactor steam dome pressure is above its permissive setpoint.

The NRG finds that the steam dome pressure permissive bypass time delay logic for the CS and LPCI pumps is unnecessary giving the new requirements set forth in TSTF-542. This logic ensures that starting the pumps of the low pressure ECCS subsystems will occur on a Reactor Vessel Water Level - Low Low signal after an 18-minute time delay. This time delay is unnecessary for manual operation since they will be loaded sequentially via operating procedures; therefore, these Modes 4 and 5 functions and their corresponding SRs can be removed from the TS. Thus, the NRG staff finds Variation 6 acceptable.

3.5.7 Variation 7, Table 3.3.5.1-1, Core Spray Pump Start-Time Delay Relays The MNGP TS Table 3.3.5.1-1 Function 1.f, describes the Core Spray Pump Start - Time Delay Relays for the Core Spray pumps. This function is not included in NUREG-1433; however, it is similar to the LPCI Pump Start - Time Delay Relays (STS Table 3.3.5.1-1, Function 2.f), which is deleted in TSTF-542.

The NRG finds that the CS pump start time delay relay logic is unnecessary given the new requirements set forth in TSTF-542. The purpose of the time delay relays is to stagger the start of the CS and LPCI pumps that are in Divisions 1 and 2, thus limiting the starting transients on the 4.16 kV essential buses. This time delay is unnecessary for manual operation and the function can be removed from the TS. Therefore, the NRG staff finds Variation 7 acceptable.

3.5.8 Variation 8, Table 3.3. 7.1-1, Reactor Building Ventilation Exhaust Radiation The MNGP TS includes Table 3.3.7.1-1, Function 3, Reactor Building Ventilation Exhaust Radiation - High in lieu of a Control Room Air Inlet Radiation - High function (NUREG 1433, Table 3.3. 7.1-1, Function 5). Like the Control Room Air Inlet Radiation - High function, this function initiates the CREF system to isolate the control room envelope from untreated outside air. Therefore, the Reactor Building Ventilation Exhaust Radiation - High is the MNGP equivalent function to the STS Control Room Air Inlet Radiation - High function and is being revised in a similar manner to how TSTF-542 revises the STS Control Room Air Inlet Radiation

- High function.

The NRC staff finds the STS and the MNGP Licensing Bases are slightly different in terminology as it relates to the ventilation systems that isolate the control rooms (CREF) from outside air; however, they are equivalent functions in terms of operation. These actions are required to mitigate the consequences of the LOCA or fuel handling accident involving recently irradiated fuel by limiting the control room doses to less than the limits calculated in the safety analysis.

Therefore, the NRC staff finds Variation 8 acceptable.

3.5.9 Variation 9, TS 3.3.8.2, Reactor Protection System (RPS) Electric Power Monitoring The MNGP TS Section 3.3.8.2 RPS EPM is being revised to remove references to OPDRVs from the Applicability of the LCO and from Condition F.

The NRC staff finds MNGP TS, Section 3.3.8.2, RPS EPM, is an MNGP specific section and does not have an equivalent in the STS; however, the justification for removing references to OPDRVs found in the STS applies to this section and the references are being removed.

Presently, TS LCO 3.3.8.2 requires that two RPS EPM assemblies shall be OPERABLE for each inservice RPS motor generator set or alternate power supply during OPDRVs. Removal of these references to OPDRVs are consistent with the justification found in TSTF-542; therefore, the NRC staff finds Variation 9 acceptable.

3.5.1 O Variation 10, SR 3.5.2.1, ECCS Water Supply (Suppression Pool and CST)

In the MNGP TS, the corresponding NUREG-1433 SRs 3.5.2.2 and 3.5.2.3, are combined into a single SR 3.5.2.1 because the requirements for suppression pool water and CST levels are applicable to both the CS and LPCI systems.

The NRC staff finds the STS and the MNGP licensing bases are different as it relates to ECCS water supplies. Presently, TS SR 3.5.2.2, has both suppression pool and two CSTs as ECCS water supplies for both CS and RHR and LPC combined; therefore, the NRC staff finds Variation 10 acceptable.

3.6 Staff Evaluation of Proposed Deletion of References to OPDRVs and Other Miscellaneous Changes Section 2.2.4.1 above, lists the numerous OPDRVs references proposed for deletion. The proposed changes would replace the existing specifications related to OPDRVs with revised specifications for RPV WIC. For example, the proposed change removes; "operations with a potential for draining the reactor vessel," the acronym "OPDRVs," "during operations with a potential for draining the reactor vessel," and Required Actions to "suspend OPDRVs." For TS 3.6.1.3, "When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation," is also proposed to be deleted.

The term OPDRVs is not specifically defined in the TSs and historically has been subject to inconsistent application by licensees. The changes discussed in this SE are intended to resolve any ambiguity by creating a new RPV WIC TS with equipment operability requirements, required actions, and SRs and deleting references to OPDRVs throughout the TS. The existing MNGP TSs contain instrumentation requirements related to OPDRVs in four TS; three of them, which have references to OPDRVs, and TS 3.3.5.1. The proposed TS 3.3.5.3 consolidates the RPV WIC instrumentation requirements into a single location to simplify the presentation and provides requirements consistent with TS 3.5.2. The remaining TSs with OPDRVs requirements are for primary and secondary containment, primary and secondary containment isolation valves, RPS electrical power monitoring, SGT, control room emergency filtration system, control room ventilation system, and electrical sources. Each of these systems' requirements during OPDRVs were proposed for consolidation into revised TS 3.5.2 for RPV WIC based on the appropriate plant conditions and calculated DRAIN TIME.

Section 2.2.4.2 describes that the licensee corrected title for LCO 3.5.2 in TS SR 3.8.2.1, Note 2. The proposed changes are shown below.

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

The NRC staff has determined that the deletion of OPDRVs references, Modes 4 and 5 references in TS 3.6.1.3, along with the corresponding editorial changes and title changes are appropriate because the proposed TSs governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.3, respectively, are simplified alternative set of controls for ensuring water level is maintained above the TAF and, therefore, these changes are acceptable.

3. 7 Staff Evaluation of TS 3.10, Special Operations and TSTF 484 The current MNGP TS LCO 3.10.1, "lnservice Leak and Hydrostatic Testing Operations," allows performance of an inservice leak or hydrostatic test with the average reactor coolant temperature greater than 212 °F, while considering operational conditions to still be in Mode 4, provided certain secondary containment LCOs are met.

The TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities," revised STS LCO 3.10.1 to expand its scope to include operations where temperature exceeds 200 °F: (1) as a consequence of maintaining adequate reactor pressure for an inservice leak or hydrostatic test, or (2) as a consequence of maintaining adequate reactor pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

By Amendment No. 174, dated August 9, 2013, the NRC approved changes to MNGP TS LCO 3.10.1, in accordance with TSTF-484 (Reference 7). The NRC staff's SE for this amendment stated, in part, that, "two low-pressure emergency core cooling systems (ECCS) injected/spray subsystems are required to be operable in Mode 4 by TS 3.5.2, 'ECCS-Shutdown."' However, per the proposed new LCO 3.5.2, which would replace the requirements of LCO 3.5.2 only one low pressure ECCS injection/spray subsystem would be required to be operable in Mode 4.

The NRC staff determined that changing from two ECCS injection/spray subsystems to one ECCS injection/spray subsystem is acceptable because, as stated previously in Section 3.3 of this SE, this level of redundancy is not required even during application of LCO 3.10.1. When the licensee applies LCO 3.10.1 at the end of a refueling outage, an exceptionally large volume of water is present in the reactor vessel since the vessel is nearly water solid. There is much more water in the reactor vessel present during power operation. Small leaks from the reactor coolant system would be detected by inspections before a significant loss of inventory occurred.

In the event of a large reactor coolant system leak, the RPV would rapidly depressurize and allow operation of the low pressure ECCS. At low decay heat values and near Mode 4 conditions, the stored energy in the reactor core will be very low. Therefore, the reasoning that operators would have time to respond with manual actions to start any ECCS pumps and properly align valves for injection from the control room remains valid.

As stated previously in Section 3.3 of this SE, with one ECCS injection/spray subsystem and nonsafety-related injection sources, defense-in-depth will be maintained. The DID measure is consistent with other events considered during shutdown with no additional single failure assumed. The DRAIN TIME controls, in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

After considering of the reasoning presented in this SE and reviewing Reference 6, the NRC staff determined that the LCOs 3.3.5.3 and 3.5.2 adopted as part of TSTF-542 are satisfactory and will, therefore, be acceptable even during application of LCO 3.10.1.

3.8 Technical Conclusion The MNGP Safety Limit 2.1.1.4 requires that reactor vessel water level shall be greater than the top of active irradiated fuel. Maintaining water level above the T AF ensures that the fuel cladding fission product barrier is protected during shutdown conditions. The proposed changes to the TSs establish new LCO requirements that address the preventive and mitigative equipment and associated instrumentation that provide an alternative means to support Safety Limit 2.1.1.4 during Modes 4 and 5 operations.

The reactor coolant system is at a low operating temperature(< 212 °F) and is depressurized during Modes 4 and 5 conditions. An event involving a loss of inventory while in the shutdown condition does not exceed the capacity of one ECCS subsystem. The accident that is postulated to occur during shutdown conditions, the Fuel Handling Accident (USAR, Section 14.7.6, Refueling Accident Analysis) does not involve a loss of inventory. Therefore, the equipment and instrumentation associated with the Reactor Vessel WIC TS do not provide detection or mitigation related to these design basis accidents.

The proposed TS LCO 3.5.2 contains requirements for operability of one ECCS subsystem, along with requirements to maintain a sufficiently long DRAIN TIME so that plant operators would have time to diagnose and mitigate an unplanned draining event. The NRC staff has determined that the LCOs 3.5.2 and 3.3.5.3 provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility and, therefore, meet the LCO requirements of 10 CFR 50.36(c)(2)(i).

Additionally, the revised TS LCOs 3.5.2 and 3.3.5.3 provide remedial actions to be taken in the event the LCO is not satisfied and, therefore, meet the requirements of 10 CFR 50.36(c)(2)(i).

The NRC staff finds that the proposed action statements provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the T AF.

The NRC staff evaluated the proposed DRAIN TIME definition, TS 3.5.2, which contains the requirements for RPV WIC, and TS 3.3.5.3, which contains the requirements for instrumentation necessary to support TS 3.5.2. Based on the considerations discussed above, the NRC staff concludes that the proposed revisions are acceptable because they consolidate and clarify the RPV WIC requirements that meet 10 CFR 50.36(c)(2)(ii), Criterion 4, to establish LCOs for structures, systems, or components significant to public health and safety as evidenced by operating experience.

The licensee proposed to delete OPDRV references from the TS Applicability descriptions, Conditions, Required Actions, and Footnotes. The NRC staff reviewed the proposed changes and determined that the deletion of OPDRVs references along with the corresponding editorial changes, are appropriate because the proposed TSs governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.3, respectively, are a clarified and simplified alternative set of controls for ensuring that water level is maintained above the TAF.

The NRC staff reviewed the SRs associated with the new LCOs 3.5.2 and 3.3.5.3. The staff finds that the proposed TS SRs in TS 3.5.2 are acceptable since they support TS 3.5.2 DRAIN TIME requirements, assure that water inventory is available for ECCS injection/spray subsystem RPV injection and pump performance, ECCS injection/spray subsystems are adequately filled (mitigates effects of gas accumulation or voiding), the subsystems have verified valve positions to support RPV injection, verified pumps provide adequate flow to support DRAIN TIME and RPV injection, verification of automatic isolation, and ECCS injection/spray subsystems can be manually operated to inject. The staff finds that the two SRs proposed for TS 3.3.5.3 are sufficient and adequate because they ensure that the functions are capable of performing their specified safety functions in support of TS 3.5.2, DRAIN TIME and the protection from a potential drain down of the RPV in Modes 4 and 5. Therefore, the NRC staff concludes that the proposed SRs satisfy 10 CFR 50.36(c)(3).

The NRC staff evaluated the proposed MNGP changes against each of the unit applicable design requirements listed in Section 2.3.1 of this SE. The NRC staff finds that the proposed changes for Mode 4 and 5 operations, as they relate to the proposed TS changes for the new DRAIN TIME definition and the removal of OPDRV references, remain consistent with the plant design criteria in that the design requirements for instrumentation, reactor coolant leakage detection, the RCPB, and reactor coolant makeup are unaffected.

The regulation at 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application but shall not become part of the TSs. In accordance with this requirement, the licensee provided TS Bases changes in the proposed LAR (Reference 1 ). The NRC staff concludes that the TS Bases changes provided describe the basis for the affected TS and follow the Final Policy Statement on TSs Improvements for Nuclear Power Reactors (58 FR 39132).

Additionally, the proposed TS changes were reviewed for technical clarity and consistency with the existing MNGP requirements for customary terminology and formatting. The NRC staff found that the proposed changes were consistent with TSTF-542 and Chapter 16 bf the SRP.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendment on September 4, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or change the surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (82 FR 60228). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1 Letter dated October 20, 2017, from Northern States Power Company, Xcel Energy, to U.S. NRC, Monticello Nuclear Generating Plant, Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control,"

ADAMS Accession No. ML17293A280.

2 Letter dated June 1, 2018, from Northern States Power Company, Xcel Energy, to U.S.

NRC, Monticello Nuclear Generating Plant, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," ADAMS Accession No. ML18157A056.

3 Letter dated September 11, 2018, from Northern States Power Company, Xcel Energy, to U.S. NRC, Monticello Nuclear Generating Plant, Supplement to License Amendment Request to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Water Inventory Control" (EPID: L-2017-LLA-0360), ADAMS Accession No. ML18254A046.

4 Enclosure to Technical Specifications Task Force Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," dated March 14, 2016, ADAMS Accession No. ML16074A448.

5 Letter dated December 20, 2016, from U.S. NRC to Technical Specifications Task Force, Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," (TAC No.

MF3487), ADAMS Accession No. ML163436008.

6 NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (SRP), Section 16, "Technical Specifications," dated March 2010, ADAMS Accession No. ML100351425.

7 Letter dated August 9, 2013, from US NRC to Northern States Power Company -

Minnesota, Monticello Nuclear Generating Plant- Issuance of Amendment No.174 to Adopt TSTF 484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities (TAC No. MF0362)," ADAMS Accession No. ML13168A219.

Principal Contributors: Daniel Warner Muhammad Razzaque Larry Wheeler Date of issuance: October 2 9, 2 O1 8

ML18250A075 *Via memo **via e-mail OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DE/EICB NRR/DSS/SRXB NAME RKuntz SRohrer RAlvarado (A)* JWhitman*

DATE 9/20/18 9/20/18 7/10/18 6/28/18 OFFICE NRR/DSS/STSB/BC OGC NLO** NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME VCusumano* AGhosh DWrona RKuntz DATE 7/11/18 10/9/18 10/26/18 10/29/18

v t e Letter Sequence Approval
EPID:L-2017-LLA-0360, TSTF-542 (Approved, Closed)
Initiation Request Acceptance Supplement, Supplement Administration Questions Answers Results Approval Other: ML19052A142
MONTHYEAR2018-10-29 [Table View]

ML18250A075

Text

SUBJECT:

Dear Mr. Church:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

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