05000263/LER-1997-004, :on 970220,failure to Submit Relief Requests for Limited ISI Exams Discovered.Caused by Missed Interpretation of Sections.Required Relief Requests Will Be Submitted for Limited Exams Performed in Future
| ML20140C013 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 03/24/1997 |
| From: | Parker T NORTHERN STATES POWER CO. |
| To: | |
| Shared Package | |
| ML20140C010 | List: |
| References | |
| LER-97-004, LER-97-4, NUDOCS 9704010581 | |
| Download: ML20140C013 (4) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2631997004R00 - NRC Website | |
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e NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 31504104
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EXPIRES 4/30/98 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS LICENSEE EVENT REPORT (LER)
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F ACluiV NAME (1)
DOCKEi NUMBER (2)
PAGE (3)
MONTICELLO NUCLEAR GENERATING PLANT 05000 - 263 1 OF 4 i
TITLE (4)
I Fr.iture to Submit Relief Requests for Limited InservlCe Inspection Examinations EVENT DATE (5)
LER NUMBER (6)
REPORT NUMBER (7)
OTHER FACILITIES INVOLVED (8) 6EQUENT6AL REVISION F ACluTY NAME DOCKEl NUMB 6R MONTH DAY YEAR YEAR NUMBER NUMBER MONTH DAY YE.AR 05000 02 20 97 97 004 00 03 24 97
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THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR i: (Check one or more)(11) f MODE (9) 20.402(b) 20.405(c)
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60.73(a)(2)(iv) 73 71(b)
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LEVEL (10) of, 20 405(a)(1)(si) 50.36(c)(2) 60.73(a)(2)(vn)
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- l 20.405(a)(1)(iv) 60.73(a)(2)(ii) 60.73(a)(2)(vui)(B) 20.405(a)(1)(v) 50.73(a)(2)(ill) 50.73(a)(2)(x)
UCENSEE CONTACT FOR THIS LER (12) l NAME TELEPHONE NUMBER (include Area Code)
Tom Parker 612-295-1014 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)
CAUSE
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NCR FORM 366(4 95)
Rslief requests have not been submitted for limited inservice inspection examinations per the rcquirements of 10 CFR Part 50. In the past, inservice examinations have been done to the extent practical.10 CFR Part 50, Section 50.55a(g) states for plants with construction permits prior to 1971 that examinations need to be performed "to the extent practical". Since Monticello's construction permit was dated prior to January 1,1971, no relief requests were submitted if component design, gnometry or materials of construction limited an examination.10 CFR Part 50, Section 50.55a(g) had been miss-interpreted.
R: quired relief requests will be submitted for all limited examinations that have been performed in the 3rd Ten Year Inservice inspection Interval. Required relief requests will be submitted for all limited examinations performed in the future j
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.U.S. NUCLEAR REGULAYORY APPROVED BY OMB NO. 3150-0104 coMMISSloM EXPIRES 5/31/95 (5-92)
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MONTICELLO NUCLEAR GENERATING 05000 97 004 00 2 of 4 PLANT 263 j
Description
i On February 20,1997, while operating at 100% power, a failure to submit relief i
requests for limited inservice inspection examinations was discovered. Following discussions with NSP personnel from Prairie Island and Material and Special Processes I
conceming this issue, it was determined that this issue was applicable to Monticello. In the past, examinations have been performed to the extent practical and no relief request was believed to be required to comply with 10 CFR Part 50. Limited examinations have been noted on Inservice Inspection examination reports and included in the Inservice Inspection Outage Summary Reports.
i 10 CFR Part 50, Section 50.55a(g) states:
J (1) For a boiling or pressurized water-cooled nuclear power facility whose construction permit was issued prior to January 1,1971, components (including supports) must meet the requirements of paragraphs (g) (4) and (5) of this j
section to the extent practical.
Cause
Since Monticello's construction pemiit was dated prior to January 1,1971, no relief
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requests have been submitted on examinations with inspection limitations.10 CFR Part 50, Section 50.55a(g)(1), quoted above, and Section 50.55.a(g)(4), quoted below, were misinterpreted.
(4)... to the extent practical within the limitations of design, geometry and i
materials of construction of the components.
i The cause of the event is the miss-interpretation of these sections. It was interpreted that this section meant that interferences inherent in the design constituted impracticality and, were therefore exempted because the Monticello construction permit was issued prior to 1971. This was the approach taken for the ISI Program since Section XI was implemented at Monticello.
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aU.S. NUCLEAR REGULATORY APPROVED BY oMB No. 3150-0104 CoMMISslOW EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS C
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MONTICELLO NUCLEAR GENERATING 05000 97 004 00 3 of 4 PLANT 263 Analysis of Reportability The failure to submit relief requests for examinations with inspection limitations constitutes a non-compliance with Technical Specification 3.15.A.1. This section requires the plant to follow the American Society of Mechanical Engineers (ASME) code,Section XI except were exemptions have been granted. Since some examinations have been limited by impracticality and no relief requests have been submitted for them, this condition is not in compliance with Technical Specification 3.15.A.1 and is reportable per 10 CFR Part 50, Section 50.73(a)(2)(i)(B).
Safety Sianificance When relief requests for limited examinations have been granted, the plant will be in literal coropliance with the requirements of the regulations and Technical Specifications.
The non-compliance with Technical Specifications is not related to operability of the affected components and systems but is only related to requesting the appropriate relief for each instance where " essentially 100%" coverage cannot be obtained. This falls under the definition of " Nonconforming Condition" of Generic Letter 91-18, where full qualification is not met but the system, structure, or component can still be considered operable. " Full qualification constitutes conforming to all aspects of the current licensing basis, including codes and standards, design criteria, and commitments."
Although the systems and components in this case cannot be considered fully qualified, their functionality is unaffected. There is good reason to believe there are no problems in the unexamined portions of each examination, since we believe the majority of each examination has been demonstrated fully qualified. This provides excellent justification for concluding the entire component is operable. Therefore, all of the components with limited examinations are considered operable. For this reason, health and safety of the public are unaffected by this event.
Actions All 3rd Ten Year Inservice Inspection Interval limited examinations performed to date will be reviewed for " essentially 100%" coverage per guidance given in NRC Information Notice 96-32, " Implementation of 10 CFR Part 50, Section 50.55a(g)(6)(ii)(A),
Augmented Examination of Reactor Vessel", June 5,1996 and Code Case N-460.
Review may require physical access to components to adequately quantify the extent of
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N MONTICELLO NUCLEAR GENERATING 05000 97 004 00 4 of 4 PLANT 263 1
t the limitation. Due to ALARA concems, the physical reviews will be performed as i
permitted during operation and the rest during the next two refueling outages. As i
physical reviews are completed, the necessary relief requests will be submitted with the j
insen/ ice Inspection Outage summary report following the review.
i Each future examinations with limitations will be documented to quantify the extent of i
limitation and relief will be requested in the subsequent inservice Inspection Outage l
sumrnary report.
Failed Component identification - None Similar Events - None