ML19317G990
| ML19317G990 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/27/1978 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| TAC-10816, NUDOCS 8004020650 | |
| Download: ML19317G990 (4) | |
Text
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O REGULATORY INFO'RMATION DISTRIBUTION SYSTEM '(RIDS)
DISTRIBUTTON FOR INCOMING MATERIAL 50-312 P.EC: REID R W ORG: MATTIMOE J J DOCDATE: 02/27/78 NRC SACREMENTO MUN UTIL DIST DATE RCVD: 03/07/78 DOCTYPE: LETTER NOTARIZED: NO COPIES RECEIVED
SUBJECT:
LTR 1 ENCL 0 REQUESTING RELIEF FROM REQUIREMENTS OF 10 CFR 50.55A(G) PURSUANT TO 10 CFR 50.12 FOR A 14-MONTH EXTENSION OF APPLICANT"S FIRST 40-MONTH INSPECTION PERIOD, AND ADVISING TECH SPEC CHANGE FOR PUMP AND VALVE TESTING AND INSERVICE INSPEC WOULD BE SUBMITTED 04 PLANT NAME: RANCHO SECO (SMUD)
REVIEWER INITI AL:
XJM DISTRIBUTOR INITI AL:
o*oooo*********** DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ******************
GENERAL DISTRIBUTION FOR AFTER ISSUANCE OF OPERATING LICENSE.
(DISTRIBUTION CODE AOO1)
FOR ACTION:
BR CHIEF REID**LTR ONLY(7)
INTERNAL:
ILE**LTR ONLYT4 NRC PDR**LTR ONLY(1)
I & E**LTR ONIV _
OELD**LTR ONLY(1) nansutM**LTR ONLY(1)
CHECK **LTR ONLY(1)
EISENHUT**LTR ONLY(1)
SHAO**LTR ONLY(1)
BAER**LTR ONLY(1)
BUTLER **LTR ONLY(1.)
GRIMES **LTR ONLY(1)
J COLLINS **LTR ONLY(1)
J.
MCGOUGH**LTR ONLY(1)
EXTERNAL:
LPDR'S SACRAMENTO. CA**LTR ONLY(1)
REGION V**LTR ONLY(1)
TIC **LTR ONLY(1)
NSIC**LTR ONLY(1)
ACRS CAT B**LTR ONLY(16)
DISTRIBUTION:
LTR 41 ENCL 0 CONTROL NBR:
M SIZE: 3P Ag A Ll dd c*ooo******************************
THE END
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SMUD lEM MiM 95813; (916) 452-3211 February 27, 1978 (Q,
Yfff h U. S. Nuclear Regulatory Commission Q a. J C
gf ATTN:
Mr. Robert W. Reid, Chief g'q 7
Operating Reactors Branch No. 4
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Division of Operating Reactors Washington, D.C.
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R.W. Reid to J.J. Mattimoe i
Letter dated 2/15/78 8'
Dear Mr. Reid:
As suggested by you in the above referenced letter, the Sacramento Municipal Utility District hereby formally requests relief from the require-ments of 10 CFR 50.55a(g) pursuant to 10 CFR 50.12.
Specifically, we request a 14-month extension of our first 40-month inspection period (which would normally end on August 18, 1978, based on 40 calendar months from our date of commercial operation, April 18, 1975) to October 18, 1979.
Based on this 14-month extension, our Technical Specification change for Pump and Valve Testing and Inservice Inspection would be submitted April 18, 1979, and our Waiver Requests, with supporting information and justification, would be submitted July 18, 1979. Justifica~ tion for this request appears below.
1.
Through conversations held with various members of the ASME Section XI Subcommittee, personnel from other utilities who are conversant in the requirements, bases and intent of Section XI and personnel from Dr. Chang's staff, we have determined that the widely understood intent of Section XI is to provide a mechanism for the direction of an inspection and testing program based on operating time of the power facility.
This view is reflected by Paragraph IWA-2400(c) of the 1977 Section XI with Addenda through Winter 1977 (and has been part of the Code since Winter 1975 Addenda),
which states:
"For power units that are out of service continuously for 6 months or more, the inspection interval during which the outage occurred may be extended for a period equivalent to the outage."
We understand that no editions beyond that of 1974, or Addenda beyond that of Summer 1975,of Section XI have been approved for use by NRC. We would point out, however, that to our knowledge NRC has not objected to the language of this paragraph as it has appeared in any of the editions of Section XI beyond Summer 1975.
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-Robert W. Reid-February 27, 1978 included in Dr. Anderson's presentation of "the most complete summary" of NRC concerns with Section XI in his letter of June 2,1977 to Larry Chockie, Chairman of the Section XI Subcommittee.
Rancho Seco has undergone two outages since commercial operation on April 18, 1975.
The first, due to turbine failure, began on June 29, 1975, and extended until February 23, 1976; a period of 7 months and 25 days.
The second, due to Surveillance Specimen Holder Tube removal and rewinding the Main Generator, lasted from April 4, 1976, to October 9, 1976; a period of 6 months and 5 days.
The total outage time was 14 months.
Since the intent of the Code is to provide for inspections based on operating time of equipment, we are requesting the outage time of 14 months be added to our first 40-month interval to provide for more meaningful inspections.
2.
Due to the outages mentioned above, Rancho Seco has undergone only one refueling. Therefore, we have not completed the inspections required to be completed during our first 40-month period.
Submittal ~
of a program and its possible acceptance prior to a point in time when we can rc9sonably complete the inspections required during the first 40-month period would put us in the unreasonable position of having to comply with the requirements of an updated program when the requirements of our original program have not yet been completed.
3.
Paragraph 4.4.2 of our Technical Specifications currently requires that Inservice Inspection on components of the Reactor Coolant System be performed in accordance with the 1971 edition of Section XI with Addenda through Summer, 1973. A comparison of this Code and Addenda with Subsection IWB of the 1974/ Summer-1975 Code shows that there are no significant differences in inspection requirements. We submit that operation for an additional 14-month period under the rules of the earlier Code will not result in any undue safety hazard nor endanger life or property because of the similarity of the Nuclear Class I inspection requirements of the two Codes.
During 1976 and 1977 as a response to IE Circular 76-06 concerning stress corrosion cracking in stainless steel piring systems with stagnated borated water, a significant portion of Nuclear Class 2 systems were subjected to hydrostatic test and volumetric inspection in accordance with requirements outlined in the 1974 edition of Section XI with Addenda through Summer, 1975, wherever possible, with no indications noted. To cover the Nuclear Class 2 and 3 systems which would otherwise be left uninspected during the 14-month extension, we will commit to complete the first one-third interval piping inspection requirements on Nuclear Class 2 and 3 systems by the completion of refueling, 1978 (2nd refueling).
Inspections will be completed in accordance with the 1974 edition of Section XI with Addenda through Summer, 1975, wherever possible.
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Robert W. Reid : February 27, 1978 Paragraph 4.13 of our Technical Specifications outlines an. augmented inspection program for high energy lines outside containment.
This program will be completed as outlined in the Technical Specifications.
We. submit tnat operation for an additional 14 months under the program outlined above will not result in any undue safety hazard nor endanger life.or property.
4.
Rancho Seco Technical Specifications currently outline extensive testing programs for Nuclear Class 2 and 3 pumps and valves.
The principal differences between our current program and an updated program lie in frequency of test'ing (i.e., quarterly vs. monthly),
verification of valve position indication, failsafe operation of valves and stroking of check valves.. To bring our current program into closer compliance with 1974/ Summer-1975 Code requirements during the 14-month extension, in addition to performing pump testing as is currently outlined in our Technical Specifications, we will start (and verify proper operation on miniflow) each of the High Pressure Injection, Low Pressure Inj ection, Containment Building Spray, Auxiliary Feedwater Pumps, Nuclear Service Cooling Water-and Nuclear Service Raw Water Pumpa monthly.
We have made a review of our valve stroking / timing program and feel that as the program is currently written it meets the intent of Section XI.
Our Technical Specifications currently require that we make ECCS Flow Tests on the High Pressure Injection, Low Pressure Inj ection and Core Flood Systems.
Checks are made to assure that control board indication accurately reflects valve and pump status after manual ECCS initiation and that all valves have completed their travel. Positive verification of coolant injection into the core is made by observation of various coolant level changes. We feel these tests provide adequate ' assurance that all required valves have operated properly. We submit that the additional testing we have proposed, in conjunction with testing as currently outlined in our Technical Specifications, will not result in any undue safety hazard nor endanger life or property during the proposed 14-month extension period.
Please consider this request promptly.
We would appreciate a reply by March 20, 1978.
If you have any questions or wish to discuss this further, please do not hesitate to call.
Respectfully submitted, 0.
. Ltt;.x (h. J. Mattimoe Assistant General Manager and Chief Engineer JJM:RJR:WBG: sal c:
Region V
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