ML20135F463

Forwards RAI Re NSP 960314 Submittal Requesting Relief from Section XI of ASME BPV Code, Rules for Inservice Exam of NPP Components, 1986 Edition

ML20135F463
Person / Time
Site:	Monticello
Issue date:	12/09/1996
From:	Kim T NRC (Affiliation Not Assigned)
To:	Richard Anderson NORTHERN STATES POWER CO.
References
TAC-M96255, NUDOCS 9612130073
Download: ML20135F463 (4)

Text

Mr. Roger 0. Anderson, Director Distribution Licensing and Management Issues Docket File TMcLellen Northern States Power Company PUBLIC GBagchi 414 Nicollet Mall PD3-1 Rdg. ACRS Minneapolis, MN 55401 JRoe JGrobe, RIII OGC BMcCabe EAdensam(EGA1) GHill (2)

JJacobson, RIII l

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT - REQUEST FOR ADDITIONAL  !

INFORMATION REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN ASSOCIATED REQUESTS FOR RELIEF (TAC NO. M96255)

Dear Mr. Anderson:

We have reviewed Northern States Power Company's (NSP's) March 14, 1996, submittal requesting relief from Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, " Rules for I Inservice Examination of Nuclear Power Plant Components," 1986 edition, no l addenda. During the review, the staff determined that additional information is needed to complete our review. Enclosed is the request for additional information (RAI). Please provide your response to these questions within 60 days from the date of this letter. In addition, to expedite the review process, please send a copy of your RAI response to NRC's contractor, INEL, at the following address:  !

Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 3 Idaho Falls, Idaho 83415-2209 If you have any questions, please contact me at (301) 415-1392.

Sincerely, Original signed by Tae Kim Tae Kim, Senior Project Manager )

Project Directorate III-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation '

Docket No: 50-263

Enclosure:

As stated cc w/ encl: See next page DOCUMENT NAME: G:\WPDOCS\MONTICEL\ MON 96255.RAI To receive e copy of this document, indicate in the box: "C" = Copy without enclosures *E" = Copy with enclosures "N"

= No copy l0FFICE lNAME PD31:PM TJKim:mc T k lE PD31:LA s lE PD31:PD,1 M. l CJamerson A\/ JHannon#(j ~

}l lDATE 12/ q/96 "

12/9 /96 1 OFFICIAL RECORD COPY -

12/5 /96 6

[

9612130073 961209 PDR ADOCK 05000263 G PDR 120082 NBC File CElHER COPY

) ,# ? %

p 'e UNITED STATES

. g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2006H001 o,

0,!

l

+,*,,,4o December 9, 1996 Mr. Roger 0. Anderson, Director

Licensing and Management Issues Northern States Power Company i 414 Nicollet Mall Minneapolis, MN 55401

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT - REQUEST FOR ADDITIONAL INFORMATION REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN ASSOCIATED REQUESTS FOR RELIEF (TAC NO. M96255)

Dear Mr. Anderson:

We have reviewed Northern States Power Company's (NSP's) March 14, 1996, l

submittal requesting relief from Section XI of the American Society of

. Mechanical Engineers (ASME) Boiler and Pressure Yessel Code, " Rules for Inservice Examination of Nuclear Power Plant Components," 1986 edition, no addenda. During the review, the staff determined that additional information is needed to complete our review. Enclosed is the request for additional information (RAI). Please provide your response to these questions within 60 days from the date of this letter. In addition, to expedite the review process, please send a copy of your RAI response to NRC's contractor, INEL, at the following address:

Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, Idaho 83415-2209 If you have any questions, please contact me at (301) 415-1392.

Sincerely, 426.-

Tae Kim, Senior Project Manager Project Directorate 111-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No: 50-263

Enclosure:

As stated cc w/ enc 1: See next page

i .

l REQUEST FOR ADDITIONAL INFORMATION FOR

! MONTICELLO NUCLEAR GENERATING PLANT

. THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PLAN

RELIEF REQUEST NO. 8 - USE OF EXISTING CALIBRATION BLOCKS ,

The Nuclear Regulatory Commission (NRC) is responsible for the review and

] disposition of licensee requests relating to inservice ' inspection requirements  ;

i contained in the Code of Federal Regulations (CFR) 10 CFR 50.55a, and Section XI of the American Society of Mechanical Engineers' (ASME's) Boiler

, and Pressure Vessel Code. When submitting such requests, licensees are i required to provide both a regulatory basis (by citing the appropriate section '

! of 10 CFR 50.55a) and a technical discussion, supporting the request. This  ;

l information is used in evaluating the request.

l j

~

The staff has reviewed the information submitted by the NSP in a letter dated March 14, 1996, requesting review and approval of ISI Relief Request No. 8 to 4

the third 10-year plan. The staff has concluded that additional information j and/or clarification is required to complete the evaluation. The licensee must state the specific paragraph of the regulations (10 CFR 50.55a) under which the request is submitted and provide supporting justification as discussed below.

The regulations provide that a licensee may propose an alternative to CFR or Code requirements in accordance with 10 CFR 50.55a(a)(3)(1) or 10 CFR 50.55a(a)(3)(ii). Pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative must be shown to provide an acceptable level of quality and safety, i.e., essentially, be equivalent to the original requirement in terms

~

of quality and safety. Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original requirement results in a hardship or unusual difficulty without a compensating increase in the level of quality and ,

safety. Examples of hardship and/or unusual difficulty include, but are not  ;

limited to, excessive radiation exposure, disassembly of components solely to '

provide access for examinations, and development of sophisticated tooling that would result in only minimal increases in examination coverage.

A licensee may also submit a request for relief from ASME requirements. In accordance with 10 CFR 50.55a(g)(5)(iii), tf a licensee determines that conformance with certain Code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in l 10 CFR 50.4, information to support that determination. When a licensee detemines that an inservice inspection requirement is impractical, e.g., the system would have to be redesigned, or a component would have to be replaced to enable inspection, the licensee should cite 10 CFR 50.55a(g)(5)(iii). The NRC may, giving due consideration to the burden placed on the licensee, impose an alternative examination requirement.

Therefore, the staff has concluded that NSP should review the current submittal and provide the required reference to ensure that the proposed alternative or request for relief is evaluated in accordance with the appropriate criteria.

ENCLOSURE

l Mr. Roger 0. Anderson, Director Monticello Nuclear Generating Plant Northern States Power Company j cc:

J. E. Silberg, Esquire Adonis A. Neblett Shaw, Pittman, Potts and Trowbridge Assistant Attorney General 2300 N Street, N. W. Office of the Attorney General Washington DC 20037 445 Minnesota Street Suite 900 U.S. Nuclear Regulatory Comission St. Paul, Minnesota 55101-2127 Resident Inspector's Office 2807 W. County Road 75 Monticello, Minnesota 55362 4 Plant Manager Monticello Nuclear Generating Plant 4

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) l 1051 South McKnight Road I

! St. Paul, Minnesota 55119 l Comissioner Minnesota Pollution Control Agency 520 Lafayette Road l St. Paul, Minnesota 55119 l Regional Administrator, Region III i U.S. Nuclear Regulatory Comission 801 Warrenville Road Lisle, Illinois 60532-4351 Comissioner of Health Minnesota Department of Health 717 Delaware Street, S. E.

Minneapolis, Minnesota 55440 Darla Groshens, Auditor / Treasurer Wright County Government Center '

10 NW Second Street Buffalo, Minnesota 55313 Kris Sanda, Comissioner Department of Public Service 121 Seventh Place East Suite 200 St. Paul, Minnesota 55101-2145 2 .om