ML20010E768
| ML20010E768 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/12/1981 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20010E765 | List: |
| References | |
| FRN-46FR26491, RTR-NUREG-0737, RTR-NUREG-737, RULE-PR-50 NUDOCS 8109080234 | |
| Download: ML20010E768 (3) | |
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SACA'aMENTO MUNICIPAL UTILITY DISTRK:T C 6201 S Street. Sos 15830. Secremento. Califomie 95813;(916) 452 3231 August 12, 1981 V
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.f SECRETARY OF THE COMMISSION G
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ATTENTION DOCKETING AND SE".VICE BRANCH
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i RANCHO SECO NUCLEAR GENERATING STATION UNIT NO 1
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COMMENTS ON PROPOSED RULE, 46 FEDERAL g)#
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_ REGISTER 26491 (MAY 13, 1981) efs t
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l The Sacramento Municipal Utility District has reviewed the subject proposed rule for incorporating the post-TMI requirements. NUREG-0737, into 10 CFR Part 50.
The District possesses Operating License DPR-54 for Rancho Seco Nuclear Generating Station Unit I and realizes that the proposed.
rule is applicable to pending applications for an operating license; however, we are concerned that these requirements may impact us in our current effort j
to comply with NUREG-0737.
We do not favor codifying the NUREG-0737 requirements into the Com=ission's regulations. The proposed rule is extensive and detailed to an extent inconsistent with the gre..ter part of the existing body of Co= mission regu-lations. Most of the details of the Co= mission's regulatory requirements ar-reflected in standard review plans, branch technical positions, regulatary guides, generic letters, and other documents which reflect the NRC staff's c
positions, rather than in the regulations.
Detailed requirements in the form of regulations remove any flexibility on the part of the licensee to meet the objectives of the requirements in a manner consistent with the individual characteristics of nuclear plants oper-
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ating today. This often produces an undue and unnecessary hardship on the facility operator, and does not necessarily result in the optimum safety arrangement for any given plant.
If a licensee feels there is a better or more reasonable method, or more sensible schedule of meeting a particular l
safety objective than that which is detailed in the regulations, his only oI' course of action vould oe to file a formal request for exemption.
Not only
-l is such a course administrative 1y cumbersome and time consuming, it is not condusive to positive discussions and exchanges of views and information, and y
is therefore not the best way to determine reasanable methods and schedules for achieving the desired levels of safety, i
T01090eo234 810827 PDR ADOCK 05000312 r.
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4 SECRETARY OF THE CO.*011SS10N Paga 2 August 12, 1981
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-We agree that the rule should not be incumbered by including the detailed criteria, staff positions, and guidance in NUREG-0737 for satisfying many of these requirements.
However, we question whether any purpose is served by putting the requirements themselves in a rule where, taken out of context they will be subject to ambiguity and misinterpretation.
We are concerned over what appears to be a recent. Commission trend toward imposing detailed regulatory requirements en masse on all licensees.
l indiscriminently, through the use of regulations. We do not feel this approach to be the most reasonable for optimizing safkty considerations at individual. plants.
Tr We have previously commented on the requirements of NUREG-0737 in letters dated October 9. October 29 November 17, and December 15, 1980, and January 16. April 6. June 1 July 1 July 24, and August 3, 1981.
The District has submitted additional information to the staff in response to the requirements of NUREG-0737 however, we feel the above letters contain information relative to the proposed rule and should be considered as comments.
[Theschedulerequirementsforthecompletionoftheitemsidentifiedin l
b'UREG-0737 cannot be met by the District.
Our primary scheduling protlems relate to the need for additional safety grade power and control room modifi-cations.
The additional equipment requiring Class IE power vill overload
'our existing emergency diesels and has also created the necessity for additional space for electrical panels and equipment.
To accomodate these, needs, we have l
ordered two more emergency diesel generators and are building two Class I t
buildings to house the diesels and electrical equipment.
Since practically
- all the modifications involve the electrical equipment to be housed in one of
}' these new buildings, their completion is on the critical path for this work.
The April 1,1982 shutdown date, for the co=pl.etion of modifications which we co=mitted to in our Dece=ber 15, 1980 lett'er, was based on the completion of the electrical equipment building by Dececher 1, 1981.
All work on this building has ceased due to'a labor strike and there are no signs of a settlement at this
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time.
The principle problem in the control room is a lack of space for additional information which must be displayed in this area. To resolve this problem..
we vill be installing a complete new computer system which vill process all normal and emergency plar,t information for use in the control room, the technical support center, the emergency operations facility, and for other 3
c offsite requirements.
This computer system, as well as a number of other major components have a long lead time and cannot be delivered until the
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refueling outage scheduled for the vinter of 1983 - 1984.
It is our plan to provide some interim systems and measures to compensate for this schedule i
during our 1982 outage and therefore, meet the intent of NUREG-073,7 until all systems are completed. We do find it impossible however, to meet the specifict, of this document.
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SECRETARY OF THE CO.'DilSSION Page 3 August 12, 1981 If the Commission or the st.aff would like to review our schedule or plans in detail, we would be willing to schedule 'a meeting for that purpose. Your consideration of our comments on the propor,ed rule and an affirmative response to our proposed schedule will be appreciated.
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I John. Mattimoe Acting General Manager cc: Thomas M. Novak l
Assistant Director for Operating Reactors
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