ML20010D956
| ML20010D956 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/27/1981 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| TAC-43460, NUDOCS 8109020178 | |
| Download: ML20010D956 (4) | |
Text
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@ SCU SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S Street. Scr 15830. Sacramento, Cahforn'a 95813;(916) 452-3211 August 27, 1981 h d[.ll[N)M3
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SEP 011981d DIRECTOR OF NUCLEAR REACTOR REGULATION I
ATTENTION JOHN F STOLZ CHIFF
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OPE RATIN G RE ACTORS B RAN CH 4 p
U S NUCLEAR REGULATORY COMMISSION WASHINGTrt1 D C 20555 co
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ro RE:
DOCKET 50-312, RANCHO SECO NUCLEAR GENERATING STATION COMMENTS ON DRAFT l AEA FACILITY ATTACHMENT (FA)
Your letter of Augus t 10, 1981 p rovi de d us wi th a Dra f t Faci l i ty At tachmen t (FA) for Safeguards Application at Rancho Se,co Nuclear Generating Station.
We have revicwed the FA and p rovi de the at tached commen ts.
We understand that the FA is a standard document which applies to various types of facili ties throughout the worl d.
As such, the language in the FA i s i n ten de d to be b roa d an d gene ral. We agree wi th your commen ts that clari-fication details need to be added in order to implement the FA.
The attached commen ts we re p repa red to i den ti fy s uch a reas. We plan to forward proposed words to clari fy those items of the FA on which our comments are based, fo r yo u r con s i de ra t i on in implemen tation.
Fe de ra l Reg ul a ti on 10 CFR 75.8. (b) states that "The Commission will issue l i cense amendments, as necessary, for implementation of the principle text o f the agreemen t and the Faci l i ty At tachmen t" (emphasis added).
Since the Safeguards Appli cation at the Rancho Seco Nuclear Generating Station is scheduled to last for only two to three years, and since the FA is too broad and ambiguous to be used for a license document, we do not believe that issu-ance of a license amendment re fe r ri n g to the FA i s an e f fe ct i ve i mp lemen ta tion me ch an i s m.
An NRC let ter, setting forth the speci fic requi rements to be met, woul d p rovi de a posi ti ve means to accomplish the same resul t as a 1i cense amendment.
We realize that you are aware of the addi tional burden that the implemen tation of these agreements will place on our operation.
It is our intention to coope rate fully wi th the spi ri t of these agreemen ts.
Howeve r, we respect fully reques t that the NRC reevaluate the necessi ty and di fficulty of implementing the FA through license condition.
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-A I
J. Mat tinoc Assistan t Gene ral Manager and Chief Engineer foo S109020178 810327
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ATTACHMENT 1 sheet 1 of 3 Rancho Seco Nuclear Generating Station Commen ts to Faci l i ty Attachmen t (May 1981 Draf t)
Code Connents 2.2 Requi renen ts for an advance noti fication should be clearly speci fied as 70 days before modi fi cations af fecting i tems in the DIO are scheduled to be comp le te.
During the next two yea rs, nume rous f aci l i ty modi fi ca-tions are envisioned due to NUREG-0737 requi rements. This will res ul t in over 50 modi fications of major importance that, based on the FA, may have to be re po r te d.
This would only obscure the issues that are t ruly o f in te res t to the I AEA.
It should be speci fied that no I AEA approval for modi fications are requi red and the modi fications can be ini tiated wi thout prior noti fi cation or review by the I AEA and the NRr( The s
language describing areas fo r noti fi cation a re too broad and should be changed to limi t noti fi cations only to relevant changes.
Cla ri fying detai ls shoul d be adde i to speci fy the magni tude of changes requi ri ng repo rc i ng.
Particular creas of concern are changes in design of reactor fuel, nominal en ri chmen t of the fuel, re fueling equipmen t or nethods,
access routes to the reactor area, equipnent for assemblying/disassem-bling of fuel assemblies, and introduction of new heat remcval equipmen t.
Al te rn ate ly, the NRC, whose onsi te inspectors are aware of pending faci li ty modi fication, could provi de such in formation di rectly to the IAEA. This would allow less opportuni ty for misinterpretation concerning the i n fo rmat i on requi remen ts of I AEA.
3.1.1 The material balance area for Rancho Seco should be speci fied for the reactor faci li ty inside the securi ty fence.
3.1.3 Nominal timing for the physical inventory of at leas t once per year should be clari fied as eve ry refueling, since that is the on l y t i me a physical inventory wi thin the reactor vessel can be taken.
3.1.3 "I den ti fi cation" fo r a physi cal inven tory needs to be clari fied to only ve ri fy the exis tence of fuel assemblies, i t should not req ui re any special me thod such as ve ri fi cation of se rial numbers or actual li f ting of assenblies in the spent fuel pool.
Since the word "I den ti-fi cation" appears in various places of the Faci l i ty At tachnen t, the re shoul d be a clea r de fini tion of "i den ti fi cation."
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ATTACHMENT I Sheet 2 of 3 1
1 Code Conments e
4.1 10 CFR 75.3. (b).1 exenots "special nuclear material in gram quan ti ties 4.2 or less as a sensing component in instruments." This exemption applics l
5.1.1 to an instrument such as fission chamber.
On the other hand, the Fac'-
lity Attachment requi res accounting of small quanti ty nuclear materia.
l (each less than 0.01 -e f fecti ve kilogram). This requi rement in the Faci-4 li ty Attachnent needs to be deleted to be consistent with 10 CFR 75.
i 5.1.2 See i tem 4 above for definition of "identi fication."
a 5.2.1 Thi s req ui remen t is interpreted to requi re a gene ral Indi cation of location ( i. e., co re, f resh fuel s torage or spent fue l s to rage).
This should be clari fied.
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6 Reporting requi rements are delineated in 10 CFR 75.31 through 35 which correlate the requi rements to the existing NRC/ DOE Forms 741 4
1 and 742. However, sone inconsistency exists between these requi re-nents which could be resolved by addi tional clari fications.
Form 742 is required to be submitted twice a year, while the I AEA material balance report only needs to be submi tted once a year (30 j
days af te r discharge). We agree wi th the I AEA requi rement for upon-discharge reporting and suggest the NRC modi fy the 742 Form instruction to be consistent wi th the I AEA requi rement for the safeguard application plant.
Speci fically, 742 and 742C Forms should be requi red only upon refueling of the reactor to satisfy the I AEA requi rements. Only 742 Forms (not i
l 742C Forms) should be requi red on March 31 and Septenber 30 every year.
6.2.2 Precise forecast i s an i mp rope r use o f wo rds.
By de fi n i t ion, a fo re-j cast cannot be precise. The use of "best" to modi fy forecast would j
be appropriate.
6.3.2 The batch data for only KMP A will be based on the shipper's record, KMPs B and C will be based on operator's data. This paragraph, as
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well as Code 4.2 on Page 8, needs to be changed accordingly.
7.3 See i tem 4 above for defini tion of "i denti fi cation."
i 7.4.2 See i tem 4. above for defini tion of "i den ti fi cation."
7.4.3
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ATTACHMENT 1 Sheet 3 of 3 Code Commen ts 7.4.3 The seals on containers of f resh and i rradiated fuel are provided by shippe r/ suppliers. A s tatement regarding "othe r seals" needs to be speci fied.
7.4.4 The Auxiliary Building does not consti tute a strategic point fo r Containment and surveillance of nuclear material.
i t should be changed to Fuel Building.
7.5 It should be clari fied that use of the I AEA equipment will be
" arranged for" when i t would not impact Plant Operations / refueling s che du le s.
7.9.1 Speci fic details need to be provided for services which have to be provided by SMUD (i.e., magni tude of powe r supply, scope of measure-ments and requi red equipmen ts).
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