ML20235B851

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Application for Amend to License DPR-22,revising Reporting Requirements of Tech Specs
ML20235B851
Person / Time
Site: Monticello, 05000000
Issue date: 11/20/1972
From: Dienhart A
NORTHERN STATES POWER CO.
To:
Shared Package
ML20235B311 List: ... further results
References
FOIA-87-111 NUDOCS 8709240253
Download: ML20235B851 (5)
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, i UNITED STATES ATOMIC ENERGY COMMISSION NORTEERN STATES POWER COMPANY

)bnticello Nuclear Generating Plant Docket No. 50-263 RMUEST FOR AUTHORIZATION OF A CHANGE IN TECHNICAL SPECIFICATIONS OF APPENDIX A PROVISIONAL OPERATING LICENSE NO. DPR-22

( Change Request Dated November 20, 1972)

Northern States Power Company, a Minnesota corporation, requests authori-zation for changes to the Technical Specifications as shown on the attachments labeled Exhibit A, Exhibit B, and Exhibit C. Exhibit A describes the proposed changes along with reasons for change. Exhibit B consists of copies of pages of the Technical Specifications marked up to indicate a portion of ,the proposed changes. Exhibit C consists of newly prepared pages of the Technical Specifi-cations which present the rest of the proposed changes.

This request contains no restricted or other defense infomation.

NORTHERN STATES CO ANY

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By ,W Y ,J - -

Arthur V Dienharf Vice President. Engineering On this M day of wh,1972 before me a notary public in and for said County, persona 2Ay appeared Arthur V. Dienhart, Vice President -

Engineering, and being first duly sworn acknowledged that he is authorized to execute this document in behalf of Northern States Power Company, that he has mad it and knows the contents thereof, that to the best of his knowledge, information and belief, the statements made in it are true and that it is not i terposed or de y.

f* J ohn J(pinith Notary Public, Hennepin County, Minnesota JOHN J. SMITH kwy Pek Hennepin Ceewy, Wnoseste My cansksen Esphoe Mmh 3, M76 8709240253 870921 PDR FOIA MENZ87-111 PDR J

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i' UNITED STATES ATOMIC ENERGY COMMIS5 ION NORMERN STATES POWER COMPANY Monticello Nuclear Gene nting Plant Docket No. 50-263 REQUEST FOR AUTHORIZATION OF A CHANGE IN TECHNICAL SPECIFICATI3S OF APPENDIX A PROVISIONAL OPERATING LICENSE NO. D?3-22

( Change Request Dated November 20, 1972)

Northern States Power Company, a Minnesota corpors-ion, requests authori-zation for changes to the Technical Specifications as shown on the attachments labeled Exhibit A, Exhibit B, and Exhibit C. Exhibit A describes the proposed changes along with reasons for change. Exhibit B consists of copies of pages of the Technical Specifications marked up to indicate a portion of the proposed changes. Exhibit C consists of newly prepared pages of the Technical Specifi-cations which present the rest of the proposed changes.

This request contains no restricted or other defense information.

NORTHERN STATE POWER COMPANY By /s/ Arthur 7 Dienhart Arthur Y Dienhart Vice President-Engineering On this 20 day of November ,1972 before me a notary public in and for said County, personally appeared Arthur V. Die: hart, Vice President -

Engineering, and being first duly sworn acknowledged that he is authorized to execute this document in behalf cf Northern States Power Company, that he has mad it and knows the contents thereof, that to the bes of his knowledge, informtion and belief, the statements made in it are true and that it is not interposed for delay.

/s/JohnJSmith l John J Smith -

Notary Public, Hennepin County, Minnesota NOTARY SEAL 4

% Commission Expires k rch 3, 1976

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EXHIBIT A MONTICELLO NUCLEAR GENERATING PIA.Y1' DOCKET NO. 50-263 CHANGE REQUEST DATED NOVEMBER 20, 1972 PROPOSED CHANGES TO THE TECHNICAL SPECIFICATIONS APPENDIX A 0F PROVISIONAL OPERATING LICENSE NO. DPR-22 Pursuant to 10 CFR 50 59, the holders of the above-mentioned license hereby propose the following changes to Appendix A, Technical Specifications:

Proposed Change On page 61, Section 3 3.E, change ". . . . Specification 6.6. " to read

". . . . Specification 6. 7. B. "

On page 90, Section 3 4.B.2, change ". . . . - Specification 6.6.E, . . . "

to read ". . . . Specification 6. 7. C.2, . . . . "

On page 131, Bases 3.6 and 4.6, change ". . . . Specification 6.6.E.3.d."

to mad ". . . . Specifiestion 6.7. C.1.d. "

On page 136, Bases 3.6 and 4.6, change ".. . . Specification 6.6.E.3. "

to read ". . . . Specification 6.7. C.1. c. "

Reason for Change Substantial revisions to Section 6.0 of the Technical Specifications are pro- l posed later in this change request. 'lhe above revisions are necessary so that i the references confom to the revised paragraph numberir.g in Section 6.0.

Proposed Change On page 108, Section 3 5.H, delete the whole paragraph "When it is determined .... out-of-service period. " and replace it with the fol-loving: "When it is determined that maintenance to restore components or systems to an operable condition vill last longer than the periods specified, the reporting requirements of 6.7.C.2 shall be fulfilled."

Reason for Change Current paragraphs 3 5.H and 6.6.E appear to require two separate reports on the same sub, ject (i.e., extended maintenance of certain components and systems).

"'Ihe determination" as referenced in each of these paragraphs probably vill not be made until some portion of the allowable out-of-service period has elapsed.

The due date for one report is prior to the end of the allovable out-of-service period (seven days in most cases) and the other is due within seven days of "the determination." 'Ihis inconsistency or apparent dual reporting requirement j

e EXHIBIT A (Continued) '

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plus a desire to collect all reporting requirements and their definitions in Section 6.0 is the reason for requesting this change. The proposed wording {

i for this reporting requirement is contained in Section 6.7.C.2 of this change request.

Proposed Change; Page 1, Sections 1.0. A,1.0.B, and 1.0.C, is to be replaced by pages  ;

1 and 1A, Sections 1.0. A,1.0.B, and 1.0.C,as contained in Exhibit C. '

Pages 192 - 211, Section 6.0, Administrative Controla,are to be replaced by Ps6es 192 - 220 as contained in Exhibit C.

Beason for Change ,

2he Technical Specifications, Appendix A of Pmvisional Operating License No.

DPR-22, have been in effect for over two years. Certain portions of Section 6.0, Administrative Controls, have been difficult to interpret, particularly Table 6.1.1 which tends to put the review committees in a line function rather than in a review and audit function. Our operating and reporting experience under Section 6.0 of the Technical Specifications has also identified portions which could be refined for clearer interpretation and improved workability.

Certain changes in the' structures of the organizations, shown in Figure 6.6.1 and 6.6.2, were implemented in 1972 as reported in the NSP letter of krch 10, 1972 to Dr. Peter A Morris. During the past year, Dimetorate of Licensing personnel have expressed a desire for certain changes to this section of the Technical Specifications. A letter dated September 28, 1972 from Mr. D J Skovbolt of AEC-DL to Mr. A V Dienbart of NSP requested that we submit, within~

sixty days, proposed revisions to the reporting requirements in the Adminis-trative Controls of our Technical Specifications which meet the guidance set

  • forth in the enclosures to the subject letter.

NSP representatives have participated in a number of discussions with AEC-Licensing and AEC-Regulatory Opemtions personnel in regard to a more acceptable and somewhat " standardized" format for this section of the Technical Specifica-tions. Based on these discussions and on in-depth guidance from the ANS Pro-posed Standard for Administrative Controls for Nuclear Plants, Section 1.0, Definition of Abnormal Occurrences, and Section 6.0, Administrative Controls, have been rewritten a's contained in Exhibit C attached.

The September 20, 1972 letter from Mr D J Skovholt on reporting requirements requested that additional information be submitted on those Technical Specifica-tion revisions and facility measurements for which it is not practical to follow the guidance set forth in that letter. We believe that Section 6.7, Plant Reporting Requirements, in this change request meets the intent of the guidance provided.

The guidance given for Section 6 7. A.2.g on environmental monitoring reporting in the semi-annual operating report is more extensive than that required in our current Technical Specification. Environmental monitoring sampling can continue right up to the end of the six nonth period. Sample analysis, tabu- 1 lation and statistical analysis of the data, evaluation of the data, and prep-aration of a final draf t of the environmental monitoring section of the semi-annual report in the detail proposed within the 60 day time period allotted 1

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s e EXHIBIT A (Continued) l 1

l appear difficult, if not impracticable. We believe that the annual Environ- I mental Monitoring Report is the more appropriate location for this type' of statistical analysis and evaluation'of its significance, particularly since it treats a whole year with a full cycle of seascnsi variations as opposed to '

the environmentally non-related six month operatin6 report. periods. If the semiannual ~ operating report were to report environmental monitoring data only, without detailed analysis, this could be practicably accomplished in q the 60 day time period. In spite of this apparent diffi:ulty, we have used l the guidance provided by the September 28, 1972 letter fer Section 6 7. A.2.g l of this . change request and.will evaluate the extent'of the burden imposed following the first applicable reporting period. j l

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