ML20151S740

Responds to NRC Re Violations Noted in Insp Rept 50-263/98-09.Corrective Actions:Procedure 4 AWI-04.04.03 Will Be Revised to Eliminate Term Urgent from Section 4.3.1.D

ML20151S740
Person / Time
Site:	Monticello
Issue date:	08/28/1998
From:	Hammer M NORTHERN STATES POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-263-98-09, 50-263-98-9, NUDOCS 9809090030
Download: ML20151S740 (3)

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a Northem States Power Company Monticello Nuclear Generating Plant 2807 West Hwy 75 Monticello, Minnesota 55362-9637 August 28,1998 US Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 Reply Requested by Letter Transmitting NRC Inspection Report 50-263/98009 l

Reference 1. Letter from John A. Grobe, USNRC, to M. Wadley, NSP, "NRC Inspection Report 50-263/98000(DRS)," July 30,1998.

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The July 30,1998 letter which transmitted Inspection Report 50-263/98009(DRS)

(Reference 1) requested that within 30 days of receipt of the letter NSP respond to an unresolved item related to our procedure for controlling temporary modifications.

/g Specifically, the inspection report states:

Bypass ControlProcedure: During the review of bypass controlprocedure 4AWI-04.04.03, " Bypass Control," Revision 9, the inspectors noted that Section 4.3.1.D of the procedure stated "..a System Engineeris required to determine the need %- l for a 10 CFR 50.59 evaluation. Note that for an Urgent or Emergency condition, the bypass may be used and the review performed later."

While 10 CFR 50.54(x) allows immediate action in an emergency condition, the procedure does not define the terms " urgent or emergency condition."

Immediate action and bypass of the requirements of 10 CFR 50.59 are acceptable only within the context of the conditions describedin 10 CFR 50.54(x). The procedure, as written, does not provide adequate controls to assure that the requirements of 10 CFR 50.59 are snet.

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-.' USNRC NORTHERN STATES POWER COMPANY August 28,1998 s

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Departures from license conditions or Technical Specifications are addressed in Section 4.3.2.C of procedure 4 AWI 04.01.01 Revision 19, " General Plant Operating Activities,"

1 which states, in part:

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C. Specialplant conditions involving departures from license conditions of TechnicalSpecifications.

1. A departure from license conditions or Technical Specifications SHALL be made when necessary and provided the following conditions have been met:

a. The departure has receivedproperauthorization.

b. Emergency conditions exist.

c. The departure is necessary to protect the public health and safety (including a likely threat ofinjury to plant personnel).

d. Adequate orequivalent protective action consistent with the I

operating license is not immediately apparent.

The wording in items c and d above address 10 CFR 50.54(x). However, we acknowledge that Section 4.3.1.D of 4 AWI 04.04.03 introduces the term " urgent" without definition. This is the only place the word urgent is used in the procedure. We will therefore amend 4 AWi-04.04.03 by eliminating the term " urgent," thereby retaining only the words " emergency condition" which are cons! stent with 10 CFR 50.54(x).

In the event that under emergency conditions a 10 CFR 50.59 review is deferred, the i

Bypass Control procedure contains provisions for it to be completed promptly. Section 1

4.1.2.A of 4 awl-04.04.03 states the following:

4.1.2 In an emergency situation as determined by the Shift Supervisor, a bypass may be issued prior to completion of the required Jumper Bypass Form and 10CFR50.59 screening.

. A. If the bypass was notinstalledper an OC reviewedprocedure,

1. The Shift Supervisor SHALL complete andprovide a copy of l

the Jumper Bypass Form to the General Superintendent Engineering as soon as possible.-

2. The Gen Supt Engr SHALL ensure the 10CFR50.59 screening l'

is conducted.

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USNRC NORTHERN STATES POWER COMPANY August 28,1998 s

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3. If a 10CFR50.59 evaluation is required, the General Superintendent Engineering SHALL ensure that an SRIis prepared and approved.

This letter contains the following new NRC commitment:

By October 30,1998 procedure 4 AWi-04.04.03 will be revised to eliminate the term " urgent" from Section 4.3.1.D.

Please contact Marcus Voth, Licensing Project Manager, at (612) 271-5116 if you require further information.

Michael F. Hammer.

- Plant Manager Monticello Nuclear Generating Plant c:

Regional Administrator-lil, NRC NRR Project Manager, NRC Sr Resident inspector, NRC J

State of Minnesota Attn: Kris Sanda

- J Silberg j

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