ML19317G995
| ML19317G995 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/14/1978 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8004020654 | |
| Download: ML19317G995 (3) | |
Text
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REGULATORY INFORMATION DISTRIDUTION SYSTEM (RIDS)
DISTRICUTION FOR INCOMING MATERIAL 50-312 REC: REID R W ORG: MATTIMOE J J DOCDATE: 08/14/78 NRC SACRAMENTO MUN UTIL DIST DATE RCVD: 08/14/7E DOCTYPE: LETTER NOTARIZED: NO COPIES RECEIVED
SUBJECT:
LTR 1 ENCL 0 FURNISHING COMMENTS AND DETERMINATIONS IN RESPONSE TO NRC LTR DTD 07/11/78 WHICH TRANS THE "MODEL APPENDIX I,
TECH SPECS.
PLANT NAME: RANCHO SECO (SMUD)
REVIEWER INITI AL:
XJN DISTRIBUTOR INITIAL: D'Y oooo************* DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ******************
GENERAL DISTRIBUTION FOR AFTER ISSUANCE OF OPERATING LICENSE.
(DISTRIBUTION CODE AOO1)
FOR ACTION:
BR CHIEF ORB #4 BC**LTR ONLY(7)
INTERNAL:
fREGFILE**LTRONLY(1)
NRC PDR**LTR ONLY(1) uxatlH ONLY(2)
OELD**LTR ONLY(1) i u HANAUER**LTR ONLY(1)
CORE PERFORMANCE BR**LTR ONLY' AD FOR SYS & PROJ**LTR ONLY(1)
ENGINEERING BR**LTR ONLY(1)
REACTOR SAFETY BR**LTR ONLY(1)
PLANT SYSTEMS BR**LTR ONLY(1)
EEB**LTR ONLY(1)
EFFLUENT TREAT SYS**LTR ONLY(:
J.
MCGOUGH**LTR ONLY(1)
EXTERNAL:
LPDR'S SACRAMENTO, CA**LTR ONLY(1)
REGION V**LTR ONLY(1)
TERA **LTR ONLY(1)
NSIC**LTR ONLY(1)
ACRS CAT B**LTR ONLY(16) 7821}{3g DISTRIBUTION:
LTR 41 ENCL 0 CONTROL NBR:
SIZE: 2P oooo*******'***********************
THE END
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di= IIlld $ U d 'I.S SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 15830, Sacramento. California 95813; (916) 452-3211 August 14, 1978 U. S. Nuclear Regulatory Commission ATTN:
Mr. Robert W. Reid, Chief Operating Reactors Branch No. 4 Division of Operating Reactors Washington, D.C. 20555 Re: Model Appendix I Technical Specifications NRC to SMUD Letter dated July 11, 1978 Gentlemen:
The Sacramento Municipal Utility District is responding to your letter dated July 11, 1978, which transmitted the "Model Appendix I, Technical Specifications"; The District's review of the document has resulted in the following comments and determinations:
- 1) The District had no prior review to make comments on the draft. As a result, many sections and requirements are not applicable to the design or operating conditions at Rancho Seco;
- 2) During all previous Technical Specification changes, the District has endeavored to separate all radiological requirements from Appendix A.
These requirements are specified in our Appendix B which is based on the NRC " Standard Guide" of July 16, 1973.
The District feels that no present problem exists in Appendix B and your request constitutes a change in our present philosophy of separation and the requirements that were in your original " Standard";
3)
Integrating radiological requirements into operating require-ments would necessitate amending Appendix B to avoid ambiguity.
If this was not done, all future amendments in this area would have to be addressed to both Appendix A and Appendix B.
This unnecessary redundancy could eventually lead to inconsistancies and contradictions which, in the District's opinion, would be highly undesirable in the license, confusing to operational personnel and could potentially lead to exceeding the license limits; Roolf6*
min ljo AN ELECTRIC SYSTE M 'S E RVIN G MORE THAN 600,000 IN THE H E A,R T OF C A LIF0 R N I A
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- c R. W. Reid August' 14, 1978
- 4) ~To require licensee-proposed changes to Technical Specifications to meet standardized Technical Specifications criteria is understandable.
However, for.NRC to require the licensee to propose an amendment to a major portion of their license has connotations of a ratchet process.-
This would be inconsistent with your past position that standardized Technical Specifications are beneficial to both the NRC and the utilities;
- 5) The District feels that it would incur considerable cost to integrate the requirements into our existing Technical Specifications, with the resultant product being a less beneficial and more cumbersome document. The process should proceed with revision of one section at a time instead of the mass conversion proposed. A major change of the magnitude required by your letter will require a complete revision of procedures, retraining of operators and health physics personnel and during the transition period would produce undesirable results.
The Technical Specifications presently in effect at Rancho Seco are meeting the requirements of Appendix I.
The evaluation performed for the District by TERA Corporation, " Appendix I Evaluatior. Report," and submitted to Mr. Robert W. Reid on June 4,1976, verifies that Appendix B to our license is in compliance with Appendix I to 10 CFR 50.
Since Rancho Seco is in compliance with the requirements of the letter from Mr. Brian Grimes, we do not intend 'to further pursue a course of action of a license revision unless further justified by him.
Respectfully submitted, J
J. Mattimoe Assistant General Manager and Chief Engineer JJM:RWC: sal Os
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