ML20006D677

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Requests Limited Scope Exemption from Requirements of 10CFR26 Fitness for Duty Programs.Util Currently Implementing Program in Accordance W/Enforcement Discretion Granted in Commission
ML20006D677
Person / Time
Site: Rancho Seco
Issue date: 02/08/1990
From: Keuter D
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AGM-NUC-90-034, AGM-NUC-90-34, NUDOCS 9002140223
Download: ML20006D677 (2)


Text

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9 g uun SACRAMENTO MUNICIPAL UTILITY C! STRICT O P. O. Box 15830 Sacramento CA 95852-183o,(916) 452-3211 L;

AN ELECTRIC SYSTEM SERVING THE HEART OF CAllFORNIA ^

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.AGM/NUC 90-034 i

February 8, 1990.

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~U.'S.. Nuclear Regulatory Commission Attn:

Document Control Desk

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.Hashington,- DC _20555 Doc'ket No. 50-312 Rancho,Seco Nuclear Generating Station

- License No. ~ DPR-54 EXEMPTION:FROM FITNESS FOR DUTY PROGRAMS, 10 CFR 26 Attention:

George Knighton-

]

The District hereby requests a " limited scope" exemption from the requirements

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.of 10 CFR 26,. Fitness for-Duty Programs.

This regulation was published in-the Federal Register.on June 7, 1989, and became effective on January 3, 1990.

1The District is currently implementing-the program in accordance with'the enforcement discretion granted in a letter from the Commission to Mr. David

-Boggs, dated January' 18, 1990.-- This exemption is' requested per 10 CFR 26.6, Exemptions.

h Exemption from the enforcement of 10 CFR 26 is requested based on the fact if V

that Rancho Seco is:in a defueled condition and that the District does not intend to resume power operations.

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Considering Rancho Seco's present and future status, the District is requesting an exemption commensurate ~to the current enforcement discretion which waives the requirement that the District comply with the full provisions Lof;10 CFR 26.

Specifically, only those persons who have unescorted access to the spent fuel pool-~ building or to any area, wherever located, which contains o

equipment necessary to support and maintain the continued safe storage or

. handling of spent fuel are subject to the requirements of 10 CFR 26.

Currently, the District is subjecting the following areas to the requirements-ofL10 CFR 26:

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The Spent Fuel Building; p

2.

The Tank Farm;

-3.

The Control Room; 4.

The -20 foot and -47 foot Tevel of the Auxiliary Building; and j

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The Reactor Building.

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9002140223 900208 p/ S,jM,f[//frSkffr4

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p LRANCHO SECO NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935

2-AGM/NUC 90-034

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George Kn'.ghton

The exemptio_n:is. requested on: the following basis:

1.

Rancho Seco is defueled with all fuel in the spent fuel pool

' building.

2.

The District does not intend to resume power operations at Rancho Seco.

3.

Design basis accidents for a nuclear facility in a defueled condition are all associated with loss of fuel pool water inventory or with-fuel handling.

While'this exemption would represent a reduction from the full scope of 10 CFR 26 as applied to nuclear-power plants with operating licenses, it still provides for the adequate protection of the public health and safety and is consistent with.the potential safety hazards associated with a defueled reactor.

By.providing-for the full application of-the Commission's fitness Lfor duty requirements to those persons with unescorted access to those areas

-of the plant containing equipment necessary to ensure safe spent fuel handling

and' storage, the safety intent of these requirements will be met at Rancho Seco.

Should the District decide to refuel the reactor, we will-provide notification to the Commission to comply to the' exempted portion of 10 CFR 26.

Members of your staff with questions requiring additional information or t

clarification may contact Ms. Rita Bowser at (209) 333-2935, extension 4522.

Sincerely, QnD--!w

' Dan R. Keuter Assistant General-Manager Nuclear cc:

'J. B. Martin, NRC, Halnut Creek A. D'Angelo, NRC, Rancho Seco i

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