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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M3801999-10-21021 October 1999 Forwards Insp Rept 50-263/99-06 on 990813-0923.Four Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217G0711999-10-13013 October 1999 Forwards Insp Rept 50-263/99-12 on 990913-17.No Violations Noted ML20216J2491999-09-30030 September 1999 Ack Receipt of 980804,990626 & 0720 Ltrs in Response to GL 98-01,suppl 1, Year 2000 Readiness of Computer Sys at Npps. Staff Review Has Concluded That All Requested Info Has Been Provided ML20217B1421999-09-30030 September 1999 Informs That on 990902,NRC Staff Completed mid-cicle Plant Performance Review of Monticello Nuclear Generating Station. Staff Conducted Reviews for All Operating NPPs to Integrate Performance Information & to Plan for Insp Activities ML20212K9131999-09-30030 September 1999 Refers to 990920 Meeting Conducted at Monticello Nuclear Generating Station to Discuss Initiatives in Risk Area & to Establish Dialog Between SRAs & PRA ML20216J8091999-09-24024 September 1999 Informs That New Diaphragm Matl Has Corrected Sticking Problem Associated with Increased Control Rod Drive Scram Times.Augmented Testing of Valves at Monticello Has Been Discontinued ML20216G4341999-09-24024 September 1999 Forwards Exam Rept 50-263/99-301 on 990823-26.Violation Occurred & Being Treated as Ncv,Consistent with App C of Enforcement Policy.Test Was Administered to Two Applicants. Both Applicants Passed All Sections of Exam ML20212G7171999-09-24024 September 1999 Submits Semiannual Status Update on Project Plans for USAR Review Project & Conversion to Its.Conversion Package Submittal Continues to Be Targeted for Aug of 2000 ML20212G9801999-09-23023 September 1999 Refers to Resolution of Unresolved Items Identified Re Security Alarm Station Operations at Both Monitcello & Prairie Island ML20212F0901999-09-21021 September 1999 Confirms Discussion Between M Hammer & Rd Lanksbury to Have Routine Mgt Meeting on 991005 in Lisle,Il.Purpose of Meeting to Discuss Improvement Initiatives in Areas of Operations & Equipment Reliability ML20212A9761999-09-0909 September 1999 Submits 1999 Annual Rept of Any Changes or Errors Identified in ECCS Analytical Models or Applications ML20217A5751999-09-0909 September 1999 Forwards Individual Exam Results for Licensee Applicants Who Took Aug 1999 Initial License Exam.Without Encls ML20211Q6981999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Monticello Operator License Applicants During Wks of 010604 & 11.Validation of Exam Will Occur at Station During Wk of 010514 ML20211L1981999-09-0101 September 1999 Forwards Insp Rept 50-263/99-05 on 990702-0812.No Violations Noted ML20211K7971999-09-0101 September 1999 Informs That Util Reviewed Rvid as Requested in NRC .Recommended Corrections Are Listed ML20211K2591999-08-27027 August 1999 Forwards NSP Co Fitness for Duty Program Performance Data for Six Month Period Ending 990630 ML20211F9961999-08-26026 August 1999 Forwards Effluent & Waste Disposal Semi-Annual Rept for 990101-990630, Revised Effluent & Waste Disposal Semi-Annual Rept for 980701-981231 & Revs to ODCM for Monitcello Nuclear Generating Plant ML20211C9501999-08-23023 August 1999 Forwards Rev 17 to Monticello Nuclear Generating Plant USAR, Updating Info in USAR to Reflect Implementation of Increase in Licensed Core Thermal Power from 1,670 Mwt to 1,775 Mwt.Rept of Changes,Tests & Experiments Not Included ML20210U1831999-08-12012 August 1999 Revises 980202 Commitment Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design- Basis Accident Conditions ML20210T9601999-08-12012 August 1999 Provides Rept on Status of Util RPV Feedwater Nozzle Insps Performed in Response to USI A-10 Re BWR Nozzle Cracking ML20210Q0341999-08-0404 August 1999 Forwards SE Granting Licensee 980724 Relief Request 10 Re Third 10-year Interval ISI Program Plan,Entitled, Limited Exam ML20210H0861999-07-28028 July 1999 Forwards Insp Rept 50-263/99-04 on 990521-0701.No Violations Noted.Licensee Conduct at Monticello Facility Characterized by safety-conscious Operations,Sound Engineering & Maint Practices & Appropriate Radiological Controls ML18107A7051999-07-20020 July 1999 Provides Suppl Info Which Supersedes Info in 990625 Ltr in Response to NRC RAI Re GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. ML20212H3191999-07-16016 July 1999 Forwards Aug 1999 Monticello RO Exam Package,Including Revised Outlines.All Changes Are in Blue Font ML20209G5621999-07-14014 July 1999 Forwards Insp Rept 50-263/99-11 on 990621-24.No Violations Noted.Objective of Insp,To Determine Whether Monticello Nuclear Generating Station Emergency Plan Adequate & If Station Personnel Properly Implemented Emergency Plan ML20196J5351999-07-0202 July 1999 Discusses GL 92-01,Rev 1,Supp 1, Rv Integrity, Issued by NRC on 950515 & NSP Responses & 980917 for Monticello Npp.Informs That Staff Revised Info in Rvid & Released Info as Rvid Version 2 ML20196J9681999-07-0101 July 1999 Informs That in Sept 1998,Region III Received Rev 20 to Portions of Util Emergency Plan Under 10CFR50.54(q).Based on Determination That Changes Do Not Decrease Effectiveness of Licensee Emergency Plan,No NRC Approval Required ML20209B6151999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Y2K Readiness Disclosure Attached ML20196H2291999-06-24024 June 1999 Responds to Administrative Ltr 99-02,dtd 990603,requesting Licensee to Provide Estimate of Licensing Action Submittals Anticipated.Four New Submittals Per Year Are Anticipated ML20207D5851999-05-25025 May 1999 Submits Info Re Partial Fulfillment of License Conditions Placed on Amend 101,which Approved Use of Ten Exceptions for 24 Months Subject to Listed App C Conditions.Util Will Submit Second Rept to Obtain Approval for Continued Use ML20206S0911999-05-17017 May 1999 Forwards Response to NRC 990324 RAI Re Proposed Amend to pressure-temp Limits & Surveillance Capsule Withdrawal Schedule, .Supporting Calculations Also Encl ML20206N5601999-05-13013 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Cm Craig Will Be Section Chief for Monticello Npp.Organization Chart Encl ML20206G2181999-05-0505 May 1999 Discusses Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, Dtd 960110,for Plant ML20206G4901999-05-0404 May 1999 Forwards Staff Review of Licensee 960508 Response to NRC Bulletin 96-002, Movement of Heavy Loads Over Sf,Over Fuel in Rc or Over Safety-Related Equipment, .Overall, Responses Acceptable.Tac M95610 Closed ML20206G7741999-05-0303 May 1999 Forwards Insp Rept 50-263/99-02 on 990223-0408.One Violation Occurred & Being Treated as non-cited Violation,Consistent with App C of Enforcement Policy ML20206D1651999-04-27027 April 1999 Forwards Radiation Environ Monitoring Program for MNGP for Jan-Dec 1998, Per Plant TS 6.7.C.1.Ltr Contains No New NRC Commitments or Modifies Any Prior Commitments ML20205N0821999-04-12012 April 1999 Forwards SE of NSP Response to NRC GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Licensee Adequately Addressed Actions Requested in GL ML20205N4811999-04-0909 April 1999 Forwards Licensing Requalification Insp Rept 50-263/99-10 on 990308-12.No Violations Noted.However,Inspectors Through Observation of Simulator Scenario Exams Noted Difficulties in Ability of SM to Simultaneously Implement Duties of SM ML20205N5301999-04-0909 April 1999 Discusses Arrangements Made on 990406 for Administration of Licensing Exams at Monticello Nuclear Generating Station During Wk of 990823.Requests That Exam Outlines Be Submitted by 990128 & Supporting Ref Matls by 990719 ML20196K7831999-03-31031 March 1999 Forwards Decommissioning Funding Status Rept for Monticello & Prairie Island Nuclear Generating Plants,Per Requirements of 10CFR50.75(f)(1) ML20205H5731999-03-29029 March 1999 Submits Required 1998 Actual & 1999 Projected Cash Flow Statements for Monticello Nuclear Generating Plant & PINGP, Units 1 & 2.Encl Contains Proprietary Info.Proprietary Info Withheld,Per 10CFR2.790(b)(1) ML20205C4851999-03-26026 March 1999 Informs That on 990203,NRC Staff Completed PPR of Nuclear Plant.Staff Conducts Reviews for All Operating NPPs to Develop an Integrated Understanding of Safety Performance ML20205C6561999-03-26026 March 1999 Submits Semiannual Update on Project Plans for USAR Review Project & Conversion to ITS ML20205A5881999-03-24024 March 1999 Forwards Request for Addl Info Re Submittal Requesting Rev of pressure-temperature Limits & Surveillance Capsule Withdrawal Schedule ML20204H4711999-03-18018 March 1999 Forwards SER Concluding That Util Established Acceptable Program to Verify Periodically design-basis Capability of safety-related MOVs at Monticello & Adequately Addressed Actions Requested in GL 96-05 ML20207H5161999-03-11011 March 1999 Forwards Insp Rept 50-263/99-01 on 990112-0222.No Violations Noted ML20207F4091999-02-28028 February 1999 Forwards Fitness for Duty Program Performance Data for Six Month Period from 980701-981231,IAW 10CFR26.71 ML20207F6741999-02-24024 February 1999 Forwards Summary of Nuclear Property Insurance Maintained at Monticello & Prairie Island Nuclear Generating Plants ML20207F6901999-02-23023 February 1999 Forwards Effluent & Waste Disposal Semi-Annual Rept for 980701-981231, Off-Site Radiation Dose Assessment for 980101-981231 & Revised Effluent & Waste Disposal Semi- Annual Rept for 980101-980630, for Monticello ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20216J8091999-09-24024 September 1999 Informs That New Diaphragm Matl Has Corrected Sticking Problem Associated with Increased Control Rod Drive Scram Times.Augmented Testing of Valves at Monticello Has Been Discontinued ML20212G7171999-09-24024 September 1999 Submits Semiannual Status Update on Project Plans for USAR Review Project & Conversion to Its.Conversion Package Submittal Continues to Be Targeted for Aug of 2000 ML20212A9761999-09-0909 September 1999 Submits 1999 Annual Rept of Any Changes or Errors Identified in ECCS Analytical Models or Applications ML20211K7971999-09-0101 September 1999 Informs That Util Reviewed Rvid as Requested in NRC .Recommended Corrections Are Listed ML20211K2591999-08-27027 August 1999 Forwards NSP Co Fitness for Duty Program Performance Data for Six Month Period Ending 990630 ML20211F9961999-08-26026 August 1999 Forwards Effluent & Waste Disposal Semi-Annual Rept for 990101-990630, Revised Effluent & Waste Disposal Semi-Annual Rept for 980701-981231 & Revs to ODCM for Monitcello Nuclear Generating Plant ML20211C9501999-08-23023 August 1999 Forwards Rev 17 to Monticello Nuclear Generating Plant USAR, Updating Info in USAR to Reflect Implementation of Increase in Licensed Core Thermal Power from 1,670 Mwt to 1,775 Mwt.Rept of Changes,Tests & Experiments Not Included ML20210U1831999-08-12012 August 1999 Revises 980202 Commitment Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design- Basis Accident Conditions ML20210T9601999-08-12012 August 1999 Provides Rept on Status of Util RPV Feedwater Nozzle Insps Performed in Response to USI A-10 Re BWR Nozzle Cracking ML18107A7051999-07-20020 July 1999 Provides Suppl Info Which Supersedes Info in 990625 Ltr in Response to NRC RAI Re GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. ML20212H3191999-07-16016 July 1999 Forwards Aug 1999 Monticello RO Exam Package,Including Revised Outlines.All Changes Are in Blue Font ML20209B6151999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Y2K Readiness Disclosure Attached ML20196H2291999-06-24024 June 1999 Responds to Administrative Ltr 99-02,dtd 990603,requesting Licensee to Provide Estimate of Licensing Action Submittals Anticipated.Four New Submittals Per Year Are Anticipated ML20207D5851999-05-25025 May 1999 Submits Info Re Partial Fulfillment of License Conditions Placed on Amend 101,which Approved Use of Ten Exceptions for 24 Months Subject to Listed App C Conditions.Util Will Submit Second Rept to Obtain Approval for Continued Use ML20206S0911999-05-17017 May 1999 Forwards Response to NRC 990324 RAI Re Proposed Amend to pressure-temp Limits & Surveillance Capsule Withdrawal Schedule, .Supporting Calculations Also Encl ML20206D1651999-04-27027 April 1999 Forwards Radiation Environ Monitoring Program for MNGP for Jan-Dec 1998, Per Plant TS 6.7.C.1.Ltr Contains No New NRC Commitments or Modifies Any Prior Commitments ML20196K7831999-03-31031 March 1999 Forwards Decommissioning Funding Status Rept for Monticello & Prairie Island Nuclear Generating Plants,Per Requirements of 10CFR50.75(f)(1) ML20205H5731999-03-29029 March 1999 Submits Required 1998 Actual & 1999 Projected Cash Flow Statements for Monticello Nuclear Generating Plant & PINGP, Units 1 & 2.Encl Contains Proprietary Info.Proprietary Info Withheld,Per 10CFR2.790(b)(1) ML20205C6561999-03-26026 March 1999 Submits Semiannual Update on Project Plans for USAR Review Project & Conversion to ITS ML20207F4091999-02-28028 February 1999 Forwards Fitness for Duty Program Performance Data for Six Month Period from 980701-981231,IAW 10CFR26.71 ML20207F6741999-02-24024 February 1999 Forwards Summary of Nuclear Property Insurance Maintained at Monticello & Prairie Island Nuclear Generating Plants ML20207F6901999-02-23023 February 1999 Forwards Effluent & Waste Disposal Semi-Annual Rept for 980701-981231, Off-Site Radiation Dose Assessment for 980101-981231 & Revised Effluent & Waste Disposal Semi- Annual Rept for 980101-980630, for Monticello ML20203A3081999-01-28028 January 1999 Forwards TS Page 60d,as Supplement 3 to 971125 LAR Re CST Low Level Hpci/Rcic Suction Transfer.Page Includes NRC Approved Amend 103 Changes for Use by NRC in Issuing SER ML20202F7821999-01-27027 January 1999 Forwards 1999 Four Year Simulator Certification Rept for MNGP Simulation Facility, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(vi).Ltr Contains No New Commitments or Modifies Any Prior Commitments ML20206S0331999-01-20020 January 1999 Submits Annual Rept of Safety & Relief Valves Failure & Challenges ML20206P1221998-12-31031 December 1998 Forwards LAR for License DPR-22,revising TS pressure-temp Curves Contained in Figures 3.6.1,3.6.2,3.6.3 & 3.6.4, Deleting Completed RPV Sample SRs & Requirement to Withdraw Specimen at Next Refueling Outage & Removing Redundant SR ML20198M3271998-12-28028 December 1998 Submits Change to Commitment for Submittal of ITS Application.Util Plans to Provide ITS Conversion Package Submittal to NRC in Dec of 2000 ML20198J7511998-12-22022 December 1998 Informs of Completion of Listed Commitment Made in Re Severe Accident Mgt. Severe Accident Mgt Guidelines Have Been Assessed,Plant Procedures Have Been Modified & Training of Affected Plant Staff Has Been Completed ML20198J4311998-12-21021 December 1998 Forwards Rev 2 to SIR-97-003, Review of Test Results of Two Surveillance Capsules & Recommendations for Matls Properties & Pressure-Temp Curves to Be Used for Monticello Rpv. Under Separate Cover,Licensee Is Providing LAR to Revise Curves ML20198J7711998-12-14014 December 1998 Documents 981214 Discussion with NRC Staff Re Deviation from Emergency Procedure Guidelines ML20195C8781998-11-11011 November 1998 Forwards Supplement to 971125 License Amend Request Re Condensate Storage Tank Low Level Suction Transfer Setpoints for HPCI Sys & Reactor Core Isolation Cooling Sys ML20195C9631998-11-11011 November 1998 Forwards 120-day Response to NRC GL 98-04, Potential for Degradation of ECCS & CSS After LOCA Because of Construction & Protective Coating Deficiencies & Foreign Matl in Containment ML20195E2261998-11-10010 November 1998 Submits Suppl 1 to Util Response to NRC Request for Addl Info Re 981118 Request for Deviation from Emergency Procedure Guidelines ML20155H6591998-11-0404 November 1998 Forwards Response to 980910 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20155F9091998-10-27027 October 1998 Forwards Master Table of Contents to Rev 16 of Usar.Info Was Inadvertantly Omitted at Time of 981023 Submittal 05000263/LER-1998-005, Forwards LER 98-005-00,re HPCI Being Removed from Service to Repair Steam Leak in Drain Trap Bypass.Commitments Made by Util Are Listed1998-10-21021 October 1998 Forwards LER 98-005-00,re HPCI Being Removed from Service to Repair Steam Leak in Drain Trap Bypass.Commitments Made by Util Are Listed ML20154L9321998-10-12012 October 1998 Forwards Suppl 2 to LAR & Suppl 980319,which Proposed Changes to Ts,App a of Operating License DPR-22 for Mngp.Number of Addl Typos & One Title Change on Pages Associated with Amend Request Have Been Identified 05000263/LER-1998-004, Forwards LER 98-004-00 Re Manual Scram Inserted Following Pressure Transient Closes Air Ejector Suction Isolation Valves & Trips Offgas Recombiners.Ler Contains Listed Commitment1998-10-0909 October 1998 Forwards LER 98-004-00 Re Manual Scram Inserted Following Pressure Transient Closes Air Ejector Suction Isolation Valves & Trips Offgas Recombiners.Ler Contains Listed Commitment ML20154L8671998-10-0909 October 1998 Forwards Suppl 1 to LAR for License DPR-22, Replacing Exhibits B & C of Original Submittal to Reflect Item 2 & Subsequent Changes.Request for APRM Flow Converter Calibr Interval Extension,Withdrawn ML20154J6201998-10-0505 October 1998 Forwards Rev 49 to Monticello Security Plan.Encl Withheld, Per 10CFR73.21 ML20153F5351998-09-25025 September 1998 Submits Semiannual Status Update on Project Plans for USAR Review Project & Conversion to Improved TS ML20153F0051998-09-25025 September 1998 Forwards Suppl 1 to 971031 Application for Amend to License DPR-22,replacing Exhibit C Which Contains TS Pages Incorporating Proposed Changes Described in Original 971031 Request ML20153D8561998-09-17017 September 1998 Forwards Rev 17 to EPIP A.2-414, Large Vol Liquid Sample &/ or Dissolved Gas Sample Obtained at Post Accident Sampling Sys. Superseded Procedures Should Be Destroyed.Ltr Contains No New NRC Commitments,Nor Does It Modify Prior Commitments ML20153D1441998-09-17017 September 1998 Informs NRC That Listed Commitments 1 & 3 Were Completed by End of 1998 Refueling Outage.Commitments Involved Final Disposition of Remaining Outlier Components Re All Known Outstanding Work Associated with GL 87-02,Suppl 1,USI A-46 ML20153E0331998-09-17017 September 1998 Forwards Response to NRC 980629 RAI Re RPV Weld Chemistry Values Previously Submitted as Part of Plant Licensing Basis.Next Monticello RPV Sample Capsule Scheduled to Be Removed During 1999/2000 Refueling Outage ML20153E9011998-09-0909 September 1998 Forwards Rev 1 to MNGP Colr,Cycle 19, Incorporating Changes to power-flow Maps in Figures 6 & 7.Changes Made to Correct Errors in Stability Exclusion Region & Stability Buffer Region Shown on Rev 0 ML20151S7401998-08-28028 August 1998 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 ML20238E8201998-08-26026 August 1998 Forwards Effluent & Waste Disposal Semi-Annual Rept for Jan-June 1998 & Revised Effluent & Waste Disposal Semi- Annual for Jul-Dec 1997. Ltr Contains No New NRC Commitments,Nor Does It Modify Any Prior Commitments ML20237E9741998-08-26026 August 1998 Forwards Rev 4 to EWI-09.04.01, Inservice Testing Program. Rev of Inservice Testing Program Reflects Valves Added as Result of Component Mods Recently Performed ML20237E6821998-08-25025 August 1998 Forwards fitness-for-duty Program Performance Data for Six Months Period Ending 980630 1999-09-09
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414 Nicollet Mall Minneapolis, Minnesota 55401-1927 Telephone (612) 330-5500 March 13,1995 10 CFR Part 50 Section 50.55a US Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 Request for Review and Approval of Inservice Testino Proaram Relief Reauests RSW-1 and NB-1 Enclosed for NRC staff review are relief request RSW-1 and NB-1. Relief Request RSW-1 is a new request for relief from the code requirements for stroke time testing as applied to control valves in the Residual Heat Removal Service Water (RHRSW) system. This revision of Relief Request NB-1 revises the basis for relief from valve exercising testing of the Main Steam Safety / Relief Valves due to a change to the plant technical specifications goveming safety / relief valve surveillance requirements.
NRC Inspection Report 50-263/94008 identified unresolved item 94008-2 concerning testing of control valves in the RHRSW system. Monticello provided our resolution of the unresolved item by letter dated November 28,1994 and in discussions held with members of the NRC Staff on December 9,1994. Relief Request RSW-1 is provided to resolve the above open item as discussed during the December 9.1994 conference call and in NRC letter dated December 23,1994, with Subject " UNRESOLVED ITEMS (NRC INSPECTION REPORT NO.
50-263/94008(DRS)).
Relief Request NB-1 was submitted for NRC review by letter dated December 7,1992 with subject, " Revision 1 to Third Ten-Year Inservice Testing Program". Approval of Relief Request NB-1 was provided by NRC letter dated July 6,1993, with subject "MONTICELLO NUCLEAR GENERATING PLA.NT- APPROVAL OF THIRD TEN-YEAR INSERVICE TESTING PROGRAM *. NRC letter dated September 15,1994, issued Amendment 92 to Facility Operating License No. DPR-22 for the Monticello plant. This amendment revised the requirement which previously required a minimum of seven of eight safety / relief valves to be bench checked or replaced with bench checked valves each refueling outage. The revised requirement specifies that the valves be tested in accordance with Section XI Inservice Testing Requirements of the ASME Boiler and Pressure Vessel Code. ASME Section XI, Subarticle IWV-3200, states that pressure relief devices shall be tested in accordance with the requirements of ANSI /ASME OM-1-1981. Paragraph 1.3.3.1.2 of ANSI /ASME OM 1-1981 addresses the applicable test frequency of Class 1 pressure relief devices, and requires that:
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.a USNRC! ' NORTHERN STATES POWER COMPANY. i March 13,1995 +
Page 2 "All valves of each type and manufacture shall be tested within each subsequent 5 year period with a minimum oi20% of tha valves tested within any 24 months. This 20% . j shall be previously untestec velds, if they exist." l Relief Request NB-1 provides an exception from the quarterly valve exercising tests specified in the ASME Code (Section XI, Subarticle IWV-3410) in recognition of the fact that testing of !
the subject valves during power operation is impractical. However, the altamative testing of - i the relief request reflects our past practice by stating that all eight safety / relief valves are l bench checked or replaced each outage, which is no longer necessarily the case per the ;
issued license amendment. The enclosed revision to NB-1 proposes revised altamative !
testing. ;
The proposed change will have no significant adverse impact on the reliability of the safety / relief valves. Although any single valve may ultimately have the safety function tested less frequently, we expect overall reliability to increase since the most common performance problems associated with these valves, seat leakage and setpoint drift, can be induced by ;
valve handling or disassembly work. The proposed change would enable us to minimize such !
work to the extent permitted by Section XI of the ASME Code and ANSI /ASME OM-1-1981. I These valves will be exercised each operating cycle to test the power operated function.
This letter contains no new NRC commitments, nor does it modify any prior commitments. This submittal does modify Monticello regulatory obligations regarding implementation of the ASME Code per 10 CFR 50.55a. Please contact Mary Engen, Sr Licensing Engineer, at (612) 295 - !
4 1291 if you require further information.
// h., ' ff W J Hill Plant Manager Monticello Nuclear Generating Plant c: Regional Administrator- 111, NRC NRR Project !.5 nager, NRC Sr Resident inspector, NRC State of Minnesota 1 Attn: Kris Sanda J E Silberg
Enclosure:
Relief Request RSW-1 i Relief Request NB-1 l
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,, - , . _ . . _ . - , - _ _ , _ y--,_.. .,
RELIEF REQUEST NUMBER RSW-1 System: Residual Heat Removal Service Water (RHRSW)
Valves: CV-1728 CV-1729 Class: B-1 Category: 3 ,
Function: To open, providing a flow path for RHRSW through the RHR heat exchanger.
Test Requirement from which Relief is Sought:
Section XI, paragraph IWV-3413, (a) The limiting value of Full-stroke time of each power operated valve shall be specified by the Owner. Full-stroke time is that time interval from initiation of the actuating signal to the end of the actuating cycle. ,
(b) The stroke time of all power operated valves shall be measured to the nearest second...whenever such a valve is full-stroke tested.
Section XI, Paragraph IWV-3417, ,
(a) If, for power operated valves, an increase in stroke time of 25% or more from the previous test, ... test frequency shall be increased to once each month until corrective action is taken....
Basis for relief:
10 CFR 50, Section 50.55a(f)(5) & (6) states, (in part):
(5)(iii) If the licensee has determined that conformance with certain code requirements is impractical for its facility, the licensee shall notify the commission....
(6)(i) ... The commission may grant relief and may impose altemative requirements ... giving due consideration to the burden upon the licensee....
In addition,10 CFR Part 50, Section 50.55a(a)(3) states (in part):
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RSW-1 Page 2 of 3 -
" Proposed alternatives to the requirements of paragraphs ... may be used when.. .
(i) The proposed alternatives would provide an acceptable level of quality' and safety...."-
lWV-3413 requires that a limiting value of full stroke time be established for a j power operated valve and that the stroke time be measured whenever such a j valve is full stroke tested. Performing full stroke time testing of these valves is i impractical based on the control scheme design of the valves, adverse plant j impact, and the functional requirements of the valves.
i IWV-3413 states that full stroke time is that time interval from initiation of the I actuating signal to the end of the actuating cycle. The control scheme design of these valves does not receive an actuation signal (neither by manual handswitch '
nor by automatic logic) to stroke to the position required to fulfill their safety function. RHRSW valves CV-1728 and CV-1729 pre air operated control valves on the outlet line of the RHRSW side of the "A" and "B" RHR heat exchangers, :
respectively. These control valves maintain a differential pressure between the RHRSW process stream and the RHR process stream during RHRSW system ,
operation. The valves are controlled by a positioner, controlled by a differential pressure indicating controller (DPIC). The DPIC senses pressure.on the RHRSW discharge line and the RHR inlet line to the RHR heat exchanger. The-desired differential pressure control point, and thus the desired valve position for -
system flow, is manually set by the operator by manual adjustment of the DPIC .,
setpoint. The valve positioner positions the valve and modulates the valve ;
position as necessary to maintain this control point. Stroke time testing of these !
valves on quarterly basis is not consistent with the design of the valve's control scheme and is not in the interest of plant safety. l These valves are interlocked to receive a closed signal when the Residual Heat .l Removal Service Water (RHRSW) pumps are de-energized. This interlock is ;
provided to ensure that system water inventory is not lost during system ,
shutdown. Stroke time testing of valves CV-1728 and CV-1729 when the Residual Heat Removal Service Water pumps are de-energized would result in the loss of liquid fill for a significant portion of the RHRSW system as well as :
require the bypassing of an interlock designed to minimize the potential for water hammer. Such testing increases the possibility of an adverse water han.mer :
during startup of the RHRSW system as well as requires filling and venting of !
the system following the stroke time testing. In addition to the adverse impact on l plant operation, such testing results in an undesirable burden on plant resources - '
via the expenditure of person-hours and person-rem to perform system filling !
and venting. l l
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~ RSW-1 )
Page 3 of 3 - l
' troke time testing of the valves during RHRSW pump operation negates the S
loss of system fill concern; however, this testing would also have an adverse impact on plant safety and equipment integrity. Stroke time testing during pump operation would require the valve be initially in the closed position during pump l operation. ' Establishing the initial test conditions of a closed valve during pump : '
operation would result in an undesirable deadheading of the pump. Subsequent opening of the valve to perform stroke time testing will result in pump runout if a single RHRSW pump is in operation, an undesirable condition which adversely _ -
impacts pump integrity and performance. The pump runout concern can be n addressed by stroke timing the valve open during operation of both RHRSW pumps; however this exacerbates the pump deadheading concerns and would result in undesirable transients on the system.
Proper stroke time testing would require the plant to modify the control logic of the valves. This hardship is not offset by an increase in public safety, in addition, the application of stroke time testing requirements to control valves has recently become an issue with the OM code committee and is subject to change and/or clarification. The proposed attemative testing is an effective means to ensure the valves perform their safety function and is consistent with other valve !
category test requirements, such as check valve exercisinc ;
Alternate Testing:
l IWV-3412 provides for demonstrating the necessary valve disk movement by observing indirect evidence (such as changes in system pressure, flow rate, :
level, or temperature), which reflect stem or disk position. The most representative test of the capability of valves CV-1728 and CV-1729 to perform .
their intended function is performed during inservice testing of the RHRSW pumps. Quarterly testing of the RHRSW pumps verifies the capability of the valves to operate properly to pass the maximum required accident flow as well ;
as the recording of the valve position necessary to achieve required flow f conditions. Testing of the valves in this manner demonstrates valve .
performance capability and provides a means to monitor for valve degradation. !
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I RELIEF REQUEST NB-1 l l
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. System: Nuclear Boiler / Main Steam Va'ves:
I RV-2-71 A, RV-2-718, RV-2-71C, RV-2-71D, RV-2-71E, RV-2-71F, RV-2-71G, RV-2-71H Category: B, C-1 Class: 1 Function: To provide automatic depressurization or overpressure protection for the reactor coolant pressure boundary.
Code Test Requirement: IWV-3410, Valve Exercising Test i
Basis for Relief:
10 CFR 50, Section 50.55a(f)(5) & (6). states, (in part):
(5)(iii) If the licensee has determined that conformance with certain code requirements is impractical for its facility, the licensee shall notify the '
commission....
(6)(i) ... The commission may grant relief and may impose altemative requirements ... giving due consideration to the burden upon the licensee....
In addition,10 CFR Part 50, Section 50.55a(a)(3) states (in part): ,
" Proposed alternatives to the requirements of paragraphs ... may be used when... ,
(i) The proposed attematives would provide an acceptable level of quality and .
safety,..."
These valves have an active, self actuation safety function to open and relieve an overpressurization condition in the reactor vessel. The valves also have an auxiliary actuating device (as defined in OM-1-1981) that acts to open the valves and depressurivs the reactor vessel. This function allows low pressure emergency core cooling systems to inject during a LOCA (ADS) and also controls reactor pressure in
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, NB-1 Page 2 of 2 certain' design transients (Iow low set). The ADS automatic actuation provides for d'epressurizing the rector vessel to permit low pressure ECCS system injection during a loss of coolant accident. The low low set automatic actuation provides control of the opening and closing setpoint following s scram during pressurization transients.
Although ?hese valves have an auxiliary actuating device, they can not be treated and tested as category B, power operated valves. The requirements to stroke time them quarterly is not within the design capability f the valves or the plant. First of all, these valves have a passive safety function to remain closed and provide reactor coolant pressure boundary. Exercising them during power operation would cause a severe reactor power and pressure transient that could result in a reactor scram. It also increases the potential for second stage or pilot stage leakage due to seat wear or fouling. If this leakage is high enough, it can cause a spurious SRV lift and prevent e reclosure of the valve. This condition is equivalent to an unisolable small break LOCA event. The NRC states in several documents that such challenges to the ADS function of the main steam safety / relief valves should be minimized. Therefore, justification to perferm an exercise test on a once-per-cycle frequency is well established.
The reason the valves can not be stroke timed to provide meaningful data is that there is no direct indication of valve position. Their stroke time is less than one second and can only be measured by indirect means such as changes in SRV discharge line pressure and temperature indication. This results in a high degree of variability in the measured stroke times due to other plant variables such as valve pneumatic supply pressure, recctor pressure, turbine bypass valve condition, measuring instrumentation response time, etc. This prohibits repeatable test conditions without a heavy burden on the licensee to fix these parameters during each test to within a narrow enough range commensurate with a less than one second stroke time. This burden is not offset by an increase in public safety.
Alternative Testing:
These valves will be monitored for degradation by testing them in accordance with all applicable sections of OM-1-1981, including the requirement: ft,r auxiliary actuating devices. This testing is in accordance with the Monticello plant technical specifications.
The valves will also be tasted in accordance with Technical Specification 4.6.E which includes disassembly and inspection of at least two SRVs each refueling outage.
All SRVs will be exercised at reduced recctor pressure. M clace, each operating cycle to verify the open and close capability of the valve.
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TRANSMITTAL MANIFEST l NORTHERN STATES POWER COMPANY :
3 NUCLEAR LICENSING DEPARTMENT MONTICELLO NUCLEAR GENERATING PL ANT ;
Request for Review and Approval of inservice Testino Proaram Relief Reauests RSW-1_and NB-1 -
Correspondence Date: March 13,1995 ;
Monticello Intemal Site Distribution Special Instructions Kaleen Hilsenhoff......USAR file.. . . ...........Yes No_x_
Steve Ludders ..........NRC Commitment .....Yes No_x_
Lila Imholte.... ...........Monti OC Sec . . . ...Yes No_x_ - 11, No dist to OC members below if YES Mel Opstad.. . . ... .....Monti SAC Sec. .. ....Yes No_x_ - 5 l
Monticello Intemal Site Distribution:
- Monti Document Control File Monti Site L!c File W J Hill, Plant MGR Steve Ray, SR Res insp, NRC ,
Al Wojchouski ,
Steve Hammer '
Dean Carstens D:ve Pennington Jim Freborg NSP Intemal Distribution E L Watzl, VP Nuc Gen R O Anderson, Dir LMI, SAC Mike Wadley, Pl Communicat on Dept Yes No_x_ :
t Extemal NSP Distribution
<dese Centref Desh"40RCA. Kris Sanda, State of Minn Regional Admin-lli,NRC J E Silberg -
Beth Wetzel, NRR-PM, NRC
- Advance Distribution made by Site Licensing Manifest Date: March 14,1995