ML20206R863

Informs That Staff Has Prepared TS Interpretation of Requirements for Extending Surveillance Intervals at Plant,Per NRC Request

ML20206R863
Person / Time
Site:	Monticello
Issue date:	01/12/1999
From:	Adensam E NRC (Affiliation Not Assigned)
To:	Richard Anderson NORTHERN STATES POWER CO.
References
TAC-M98821, TAC-MA4277, NUDOCS 9901200329
Download: ML20206R863 (4)

Text

. _ _ _ . _ _ __ _ __- -- - - - - - - - -

ur Y p

• UNITED STATES

=

i NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30886 4001

%, January 12, 1999 pfy Mr. Roger O. Anderson, Director Nuclear Energy Engineering i Northern States Power Company j 414 Nicollet Mall '

Minneapolis, Minnesota 55401 l l

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT- TECHNICAL SPECIFICATION i INTERPRETATION OF SURVEILLANCE INTERVALS REQUIRED TO BE MET 4 FOR MONTICELLO (TAC NOS. M98821 and MA4277) l

Dear Mr. Anderson:

i i

In response to a request from the NRC Region lli office, the staff has prepared a technical j specification (TS) interpretation of the requirements for extending surveillance intervals at Monticello. Region lil's request was due to an apparent inconsistency between TS 4.0.B and -

the Bases for TS 4.0.B. TS 4.0.B states that surveillance intervals could be extended by up to 25% and implies the surveil!ance clock is reset each time a surveillance is performed. The intent appears to be to limit the maximum period of time a safety system or parameter may go untested or unchecked. The Bases for TS 4.0.B describes a fixed surveillance schedule in which surveillances could be performed up to 25% earlier or later than a fixed date.

Subsequent tests are based on fixed dates, independent of when the surveillance was last performed. This fixed scheduling could allow a 50% extension of a surveillance interval. After evaluation, the staff has prepared the following TS interpretation:

The Monticello TS 4.0 B. states:

Specific time intervals between tests may be extended up to 25% of the surveillance interval to accommodate normal test schedules with the exception that, (sic) the intervals between test scheduled for refueling shutdowns shall not exceed two years.

On May 5,1986, Northern States Power Company (NSP) submitted a license amendment request entitled, " Miscellaneous Technical Specification improvements,' in which NSP proposed to add a Bases section for TS 4.0 B., that states in part:

A tolerance for performing surveillance activities beyond the nominal interval is l provided to allow operational flexibility because of scheduling and performance considerations. The plant uses a fixed surveillance program that prevents repetitive addition of the allowable 25% extension. Each surveillance test is completed within plus or minus 25% of each scheduled fixed date. Scheduled dates are based on dividing each calendar year into four 13-week ' surveillance" quarters consisting of 3 4-week " surveillance" months and one " catch-up" week.

This method of scheduling permits certain tests always to be scheduled on certain days of the week.

9901200329 990112 &? r r r -

PDR ADOCK 05000263 L~ @ "l- ' " ' ' ' ~ "

,' ', . m) E P PDR '

+ - - '

J

. -. ,- --. -.n. -

. ~ - - --n - - - -

i-4 1

R. Anderson 2 January 12, 1999

)

' On April 18,1989, the staff issued Amendment 63 that included the above Bases section for TS 4.0.B. as proposed by NSP, and the staff stated the following in the associated safety evaluation (SE):

Revise the Bases section to explain the surveillance testing requirements in

' Section 4.0 of the TSs and add information to assist in understanding and i~ applying this section. The proposed wording is derived from the NRC Standard j TSs. Additional clarification of the surveillance interval tolerance is derived from i

clarifying information contained in NRC Inspection Report 50-263/85012(DRP) dated July 19,1985. This addition to the Bases will help in understanding l

Section 4.0 of the TSs. This section was recently added to provide general requirements for the Surveillance program.' The proposed wording summarizes the application related to surveillance intervals and surveillance scheduling established with NRC inspectors over a period of many years.

i Based on the above information, the staff has determined that the Monticello TS do not allow NSP's " fixed date" surveillance program, regardless of the fact that the staff had previously

. endorsed NSP's surveillance program in an SE. In addition, the staff has determined that the

TS remtJn as the governing requirement and that NSP should revise its TS Bases section to make it consistent with the TS.

i j On February 27,1998, the staff communicated its determination as described 'above to NSP.

j The staff made it clear to NSP that NSP must comply with the TS regardless of the fact that the staff had previously endorsed NSP's surveillance program in an SE. NSP indicated that it has taken initial steps to ensure that it is in compliance with the TS, and that it will submit a TS amendment request to adopt the wordings in the current TS Bases section for TS 4.0 B.

On March 2,1998, the staff, together with the NRC's Region 111 personnel, held a conference call with NSP and reiterated the staff's conclusion that NSP must comply with the TS regardless of the fact that the staff had previously endorsed NSP's surveillance program in an SE. In response to NSP's question regarding the acceptability of a license amendment request to allow the " fixed date" surveillance program, the staff stated that NSP must provide adequate justifications to address the acceptability of extending the surveillance interval between two tests by up to 50%.

The substance of this letter was discussed in a telephone call between Mr. T. Kim (NRC) and Mr. M. Voth (NSP) on November 30,1998.

Backfit Evaluation in accordance with 10 CFR 50.109, the staff has performed a backfit evaluation. The objective of the staff's action, as described above with respect to Monticello, is to ensure that NSP's surveillance program complies with the TS. Because the TS requirement existed but was not satisfied, this backfit is to bring the facility into compliance with the existing TS requirement.

This staff action is considered a compliance backfit in accordance with 10 CFR 50.109(a)(4)(i) and, therefore, a full backfit analysis was not performed.

I 1

j

R. Anderson 3 January 12, 1999 NSP may appeal the NRC decision that the above described staff action is a compliance backfit, and request that a full backfit analysis be performed. Should NSP decide to appeal, the appeal should be made within 60 days of the date of this letter and it should be addressed to the Director of NRR with a copy to the Executive Director for Operations of NRC.

Please contact Mr. F. Lyon of my staff at (301) 415-2296, if you have any questions regarding this staff action.

Sincerely, ORIGINAL SIGNED BY Elinor G. Adensam, Acting Director Division of Reactor Projects - lil/IV <

Office of Nuclear Reactor Regulation  ;

- Docket No. 50-263 l cc: See next page i

I l

l DISTRIBUTION: EAdensam (EGA1) SCollins Docket File BBurgess, Rlli CRGR PUBLIC BBoger PDill-1 r/f BSheron THiltz OGC,0-15 B18 RZimmerman JZwolinski EDO WBeckner JDyer, Rlli DOCUMENT NAME: G:\WPDOCS\PD3-1\MONTICEL\LTR98821 *See Previous Concurrence in TIA for TAC M98821 To roc we a copy of thle document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment /e re "N' OFFICE PM;PD31l C LA:PD31 l0 BC:TSB l D:PD31 6 DJEYWT ADP NAME Flyon:db P CJamerson Gj/ WBeckner* CACarpenter c IL. EAd 6am BBoger //"

DATE 1/ 5 /99 1/ .5 /99 // 10/14/98 1/(p /99 1/ / / /99 1/ / L-/99

" OFFICIAL RECORD COPY l

f i

1 Mr. Roger O. Anderson, Director Monticello Nuclear Generating Plant Northern States Power Company cc:

J. E. Silberg, Esquire Kris Sanda, Commissioner Shaw, Pittman, Potts and Trowbridge Department of Public Service  :

2300 N Street, N. W. 121 Seventh Place East Washington DC .20037 Suite 200

. St. Paul, Minnesota 55101-2145 U.S. Nuclear Regulatory Commission Resident inspector's Office Adonis A. Nebiett 2807 W. County Road 75 Assistant Attorney General Monticello, Minnesota 55362 Office of the Attomey General 445 Minnesota Street Plant Manager Suite 900 Monticello Nuclear Generating Plant St. Paul, Minnesota 55101-2127 ATTN: Site Licensing Northern States Power Company 2807 West County Road 75 Monticello, Minnesota 55362-9637

' Robert Nelson, President Minnesota Environmental Control Citizens Association (MECCA)  ;

1051 South McKnight Road St. Paul, Minnesota 55119 l

Commissioner Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, Minnesota 55119 Regional Administrator, Region lll U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Commissioner of Health Minnesota Department of Health 717 Delaware Street, S. E.

Minneapolis, Minnesota 55440 Darla Groshens, Auditor / Treasurer Wright County Govemment Center 10 NW Second Street Buffalo, Minnesota 55313 January 1995

. . _ . . .._ ._,.-_ _