ML18347A583
| ML18347A583 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/20/1976 |
| From: | Bixel D Consumers Power Co |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| Download: ML18347A583 (2) | |
Text
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consumers Power company General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201
- Area Code 517 788-0550 July 20, 1976 Director of Nuclear Reactor Att:
Mr Albert Schwencer Operating Reactor Branch No 1 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255, LICENSE DPR-20 PALISADES PLANT, INSERVICE INSPECTION
/
By letter dated June 11, 1976 we responded to questions concerning the Inservice
- Inspection program at our Palisades Plant.
Since that time we have had the op-portunity to discuss this program and our interpretation of applicable parts of 10 CFR 50.55a with members of your staff.
The following item:::: appear to need ad.ditional clarification; our interpretation is presented below:
Item 1, Acceptable Additions of *criteria, Codes and Standards Paragraph 10 CFR 50. 55a( g) ( 4 )(ii) states, "The inservice examinations conducted during successive 40-month periods throughout tpe service life of the facility thereafter shall comply with those requirements in editions of th~ code and ad-denda in effect no more than 6 months prior to the start of each 40-month period."
We further note that Footnote 4 appears to define "in effect" as follows:
"ASME and United States of America.Standard Code Addenda are considered 'in effect' 6 months after their date of issue."
From the above we conclude that any edition of Section XI of the ASME Boiler and Pressure Vessel Code that is "in effect" no more than 6 months prior to the start of the 40-month period is acceptable.
Based on this conclusion, we are currently revising our Inservice Inspection pro-gram to meet the requirements, to the extent practical, of Section XI through the summer of 1976 addenda.
We beljeve that this is the proper course of action since this addenda will be in effect soon after the beginning of our inspection program's second 40-month interval.
To plan an additional revision of our Inservice Inspec-tion program at the start of the next 40-month interval would appear to incur sig-nificant unnecessary additional costs.
If this interpretation of 10 CFR 50.55a is not corrected, we request an exemption from this part to permit use of Section XI through the summer of 1976 addenda.
2 Item 2, Application for Amendment of the Technical Specifications at Least 6 Months Before the Start of the Period During Which the Provision Became Applicable Paragraph 10 CFR 50.55a{g){5)(ii) appears to limit the time when an amendment to the Technical Specifications can be requested.
We noted in our June 11, 1976 letter that since unforeseen circumstances may prevent inspection as originally planned, we may not be able to anticipate all required Technical Specifications amendments 6 months in advance.
This letter requested an exemption from the ap-plication time requirement of 10 CFR 50.55a{g){5)(ii).
We would further like to clarify that this request was for plant life.
If this interpretation is incorrect, please advise us of the proper interpreta-tion.
We would reevaluate our exemption request based on your clarification of the present meaning of this paragraph.
czr~ay David A. Bixel Assistant Nuclear Licensing Administrator CC:
JGKeppler, USNRC