ML19309A662
| ML19309A662 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 05/30/1978 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19309A660 | List: |
| References | |
| TAC-11130, TAC-54441, NUDOCS 8003310569 | |
| Download: ML19309A662 (6) | |
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f SAFETY EVALUATIOTI BY THE OFFICE OF ?!UCLEAR' REACTOR REGULATION SUPPORTit!G Ai1Ef!D 1Fl!T f10. 20 TO FACILITY OPERATIttr, LICEriSE fl0. DPR-54 SACR #1EllTO "UNICIPAL UTILITY DISTRICT RAEll0 SECO '!UCLEAR GFilERATI;;r, STATIO*1 DOCKET fl0. 50-312 Introduction By letter dated February 27, 1973, Sacramento ftunicipal Utility District (the licensee) requested exemption, pursuant to 10 CFR 50.12(a), of Rancho Seco lluclear Generating Station (P.S) from the effective date provision of 10 CFR 50.55a(g)(4)(v). The specific request would extend the date by which the RS Inservice Inspection and Test,ing Program must be in conformance with the provisions of 10 CFR 50.55a(c)(4) by fourteen months (from August 18, 1978 to October 18,1979).
Backaround Inservice inspection requirements for boiling and pressurized water reactors are set forth in 10 CFR 50.55a(g).
Accordino to Section 50.55a(g)(4)(v) the provisions of Section 50.55a(n)(4) become effective '
for RS at the start of the next regular 40-nonth period of a series of such perioos beninnina at the start of facility commercial operation.
Based on the date of initial commercial operation of RS, April 10, 1975, the provisions of Section 50.55a(g)(a) would become effecthe on August 18, 1978.
By letter dated February 27, 1978, the licensee reauested that the effective date for conformance with Section 50.55c(a)(4) be extended by fourteen months to October 18, 1979.
This request for extension is based on the fact that RS has suffered two extended outaaes totaling fourteen nonths since beginnirig conmercial operation. -The first of these outages, lastina 7 months 25 days, was due to turbine failure.
The second outace, lasting 6 months 5 days, was needed for removal of Surveillance Specimen Holder Tubes and rewinding of the main generator.
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- The licensee's basis for requesting extension of the effective date is given in paragraph IWA-2400(c) of Section XI of the AStiE Boiler and Pressure Vessel Code,llinter 1975 Addendum, which states:
"For power units that.are out of service continuously for 6 months or more, the inspection interval durina which the outage occurred may be extended for a period equivalent to the outage."
The licensee correctly notes, however, that the NRC has not yet approved for use (pursuant to 10 CFR 50.55a(b)) addenda beyond_the.
Summer 1975 Addendum.
Accordingly, the above provision, being one of many revised provisions contained in the Winter 1975 Addendum, is not yet approved by the fiRC.
An operational reason given by the licensee for requesting the extension is that he has initiated, but not yet completed the series of inspec-tions of the ASMF Code Class 1 reactor coolant system components required dering the first 40-month period by the previous reaulations.
Accordingly, he states that it is unreasonable to require compliance with an updated program before the requirements of the original procram have been completed.
At the same time, while noting that there are differences in detail between the previous program for ir.spection of ASME Code Class i reactor coolant systeu components, and the updated program, the licensee notes that both proarams are fundamentally similar with respect to these inspections.
He, therefore, maintains that completion of the 40-month program during the proposed extension in accordance with the previous requirements does not pose any undue hazard to the he alth and safety of the public.
The principal difference between the present rer.uirements for inservice inspection and the requirements which become effective for RS at the end of the current 40-month inspection interval (or 54-month interval if extended) is that the new program adds requirements for inservice inspection of AS!!E Code Class 2 and 3 components, including supports and adds requirements for periodic testing of ASME Code Class 1, 2 and '
3 pumps and valves.
The licensee acknowledges that the requested exemption would delay by fourteen months the effective date for imple-mentation of these updated requirements.
To compensate for the delay in 6
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3-implementation that would occur if the requested extension were granted, the licensee has committed to perform the following supple-mentary inspections and tests during the 14-month extension:
1.
Complete the first one-third interval pipina inspection requirements for Nuclear Class 2 and 3 systems by' the completion of the 1978 refueling outage in'accordance with the new requirements (1974 edition of ASME Section XI w'ith Addenda through Summer 1975) wherever possible; 2.
Supplement the present pump testing program as defined in the current RS Technical Specifications, by starting (and verifying proper operation on miniflow) each of the High Pressure Injection, Low Pressure Injection, Containment Building Spray, Auxiliary Feedwater, Nuclear Service Cooling Pater and Nuclear Service Raw Water pumps monthly - as opposed to the present quarterly schedule.
Evaluation The principal basis for the licensee's request for extension of the effective date of an updated inservice inspection program is paragraph IWA-E400(c) of ASME Section XI, quoted above.
Although this provision l
first appeared in the Winter 1975 Addendum to Section XI which has not yet been approved in total by the NRC, the inclusion of this specific provision is not why approval of the entire Addendum has not been granted.
Indeed, we consider that affording the opportunity to adjust inservice inspection intervals 'to reflect major plant outages is appropriate in that it allows the inspections and the concomitant personnel radiation exposures to be coordinated with actual plant usage.
Accordingly, since this provision maintai.ns an acceptable inspection frequency related to usage, we conclude that, in the absence of other considerations, it is an acceptable basis for extending the inservice inspection period.
In the present instance, however, by extending the inspection period in accordance with the licensee's request, there would also be a correspond-!
ing postponement of the effective date by which the licensee must be in conformance wit' updated and expanded requirements for inservice inspec-tion and testing.
Specifically, in the absence of supplementary commitments by the licensee, there would be a deferral of the expansion of inservice inspection requirements to include Nuclear Class 2 and 3 components and deferral of ASME Code-imposed requirements for inservice testing of pumps and valves.
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With regard to inservice inspection of Nuclear Class 2 and 3 systems, the licensee has committed to include such inspections in his current progran if the extension is granted and has further committed to complete the first one-third interval-piping inspections on such systems by the conpletion of the 1978 refueling.
In addition, he has stated that these inspections will be performed-in accordance with the latest NRC-approved requirements wnerever possible.* Based on these conraitments, we find the proposed procram for including inspection of Nuclear Class 2 and 3 system in the RS inservice inspection program to be comparable to that required by the current reculations, and therefore with recard to this matter, find the requested extension of the inspection interval acceptable.
Regarding periodic testing of pumps nd valves, the RS Technical Specifi-cations already contain provisions which were previously found acceptable for testing of safety-related pumps and valves.
When RS becomes subject to the new Code requirements, the requirements for pump and valve' testing will be increased with respect to both the frequency and the number of types of tests to be performed.
In order to bring the RS program into closer compliance with the new requirements during the requested extension, the licensee has committed to increase the test frequency of the present pump testing procram from quarterly to monthly.
This is the frequency that will be required when RS becomes subject to the currently applicable code.
The licensee, however, has not proposed any interim upgradina of the valve testing program.
In support of this position, the licensee states his belief that the present test program provides adequate assurance that all valves have coerated properly.
With regard to pumo and valve testing, therefore, we note that by granting the requested extension, we would be deferring from August 18, 1978 to October 18, 1979, the date by which RS would have to conform to the upgraded testing requirements.
We also note, however, that during this period there would be some upgrading of the pump testing program.
To place the issue in perspective, it is important to note that the regulation which implemented the requirement for upgraded inservice inspection and testino did not attempt to effect implementation immediately or by a fixed date at all operating plants.
Rather, it was designed to effect implementation in an orderly manner over a 40-month period of time spenning the expiration of the inspection I
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- It is noted that 10 CFR 50.55a(g)(4) permits exceptions within the limitations of design, geometry and materials of. construction.
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period for the various operating reactors.
As'a result of this policy, several facilities will not be subject to the upgraded requirements until the latter half of 1979, and in the meantime these facilities are not required to have upgraded inspection and testing programs for
, the interim period.
Based on the above, we conclude.that:
1.
Section IWA-2400(c) of ASME Section XI (1975 Winter Addendum)
.provides a reasonable basis for extending the effective date for conforming to the updated inservice inspection program by 14 months (to October 18, 1979);
2.
Although the extension provision of IWA-2400(c) of ASME Section XI (1975 Winter Addendum) does not apply to the Section XI program for inservice testing of pumps and valves, an equal extension should be granted for such testing in order to provide for orderly implementation of an upgraded overall program in accordance with the purpose of the regulation; 3.
The programs proposed by the licensee for expanded inservice inspection and for more frequent testing of the specified safety-related pumps during the requested extension period are acceptable and should be implemented; and f
4.
The granting of the requested extension will not cause the effective date for implementation of an upgraded program at RS to extend beyond that time period during which other facilities will be implementing similarly upgraded programs.
Accordingly, subject to the licensee's performance of the additional inspections and testing committed to in his letter of February 27, 1978, we conclude that granting an exemption from the provisions of 10 CFR 55 a(g)(4)(v) pursuant to 10 CFR 50.12, to permit extension of the effective date for compliance with 10 CFR 50.55a(g)(4) from August 18, 1978 to October 18, 1979, will not endanger life or property or the common defense and, insofar as the extension would pennit coordination of the inspection program and the associated radiation exposure of plant maintenance personnel with actual plant usage and would pemit an orderly implementation of the upgraded program, the exemption is in the public interest.
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6-Environmental Consideration We have determined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Having made this determination, we have further concluded that the amendment involves an action which is insignificant from the standpoint of environmental-impact and, pursuant to 10 CFR 551.5(d)(4), that an environmental
. impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.
Conclusion We have concluded, based on the considerations discussed above, that:
(1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the h-ith and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Dated: May 30, 1978 f
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