ML20134C557
| ML20134C557 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf |
| Issue date: | 01/30/1997 |
| From: | Beckner W NRC (Affiliation Not Assigned) |
| To: | Hagan J ENTERGY OPERATIONS, INC. |
| Shared Package | |
| ML20134C561 | List: |
| References | |
| TAC-M96621, NUDOCS 9702030167 | |
| Download: ML20134C557 (4) | |
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UNITED STATES O
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NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 2066M001
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January 30, 1997 Mr. Joseph J. Hagan Vice President, Operations GGNS Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150
SUBJECT:
DENIAL OF EXEMPTION FROM IMPLEMENTATION OF 10 CFR 50.55a AMENDMENT REGARDING REPAIR AND REPLACEMENT ASPECTS OF THE RULE, GRAND GULF, UNIT 1 (TAC NO. M96621)
Dear Mr. Hagan:
By letter dated September 10, 1996, you requested an exemption from the subject rule published in the Federal Reaister on August 8,1996 (61 FR 41303). The subject rule required the licensees of operating nuclear reactors to start implementing the requirements of Subsection IWE,
" Requirements for Class MC and Metallic Liners of Class CC Components of Light Water Cooled Plants," and Subsection IWL, " Requirements for Class CC Concrete Components of Light-Water Cooled Plants," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) from the effective date of September 9, 1996.
It provided for a period of 5 years within which the licensees must complete the first inspection (of the first interval) of the containment structures utilizing the requirements of the rule (i.e., effective September 9, 2001). Also, any repair and replacement activities for the containment structure, that are within the scope of the rule, must be performed using Subsections IWE and IWL, effective September 9, 1996.
In your letter, you requested an exemption from immediately implementing the requirements of the rule for the repairs and replacement activities required by Subsections IWE and IWL that may have to be performed between September 9, 1996, and September 9, 2001.
You stated that immediate implementation of Subsections IWE and IWL was impractical, providing the details in your letter, and requested an exemption from the new requirements for a period of 5 years from the effective date of September 9, 1996, or until September 9, 2001.
As noted in the enclosed safety evaluation, the staff has reviewed your request and determined, because 10 CFR 50.55a(a)(3) and (g)(6)(i) permit relief from, and the use of alternatives to, the requirements of 10 CFR 50.55a (i.
e., the new requirements in IWE and IWL), that the proper avenue for relief from compliance with the repair and replacement requirements of Subsections IWE and IWL is a relief request in accordance with 10 CFR 50.55a, and not an exemption from the subject rule.
9702030167 970130 PDR ADOCK 05000416 P
Mr. Joseph J. Hagan Therefore, based on this, the staff denies your exemption request.
In addition, your submittal does not contain sufficient justification to obtain relief from the new requirements in IWE and IWL pursuant to 10 CFR 50.55a in that you have not (1) proposed an alternative which would provide an acceptable level of quality or safety, (2) shown compliance with the requirements of IWE and IWL would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, or (3) shown that these requirements are impractical for your facility.
Therefore, relief cannot be granted unless you submit the necessary information under 10 CFR 50.55a.
Sincerely, WA -- D. hk William D. Beckner, Director Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-416
Enclosure:
Safety Evaluation cc w/ encl: See next page
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Mr. Joseph J. Hagan '
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Therefore, based on this, the staff denies your exemption request.
In 4
j addition, your submittal does not contain sufficient justification to obtain relief from the new requirements in IWE and IWL pursuant to 10 CFR 50.55a in 4
j that you have not (1) proposed an. alternative which would provide an i
acceptable level of quality or safety, (2) shown compliance with the i-requirements of IWE and IWL wou'id result in hardship or _ unusual difficulty j
without a compensating increase in: the level 'of _ quality and safety, or (3) shown that these requirements are impractical for your facility'.
i i
Therefore, relief cannot be granted unless you submit the necessary l
information under 10 CFR 50.55a.'
i Sincerely,
)
ORIGINAL SIGNED BY:
j William D. Beckner, Director Project Directorate IV-1 4
Division of Reactor Projects III/IV j
Office of Nuclear Reactor Regulation i
Docket No. 50-416 4
j
Enclosure:
Safety Evaluation
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cc w/ encl:
See next page i,
DISTRIBUTION:
TDocket1 File 3 PUBLIC PD4-1 r/f l
J. Roe E. Adensam (EGA1)
J. Donohew l
C. Hawes W. Beckner G. Bagchi H. Ashar i
SE Memo dated November 13, 1996 l_
Document Name: GG96621.EXE
- See Previous Concurrence 2
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DATE
) /30/97 l/50/97 01/15/97 01/21/97
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OFFICIAL RECORD COPY
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Mr. Joseph J. Hagan Entergy Operations, Inc.
Grand Gulf Nuclear Station cc:
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Executive Vice President General Manager GGNS
& Chief Operating Officer Entergy Operati 7, Inc.
Entergy Operations, Inc.
P. O. Box 756 j
P. O. Box 31995 Port Gibson, MS 39150 Jackson, MS 39286-1995 Attorney General Wise, Carter, Child & Caraway Department of Justice 4
i P. O. Box 651 State of Louisiana Jackson, MS 39205 P. O. Box 94005 Baton Rouge, LA 70804-9005 Winston & Strawn i
1400 L Street, N.W. - 12th Floor State Health Officer Washington, DC 20005-3502 State Board of Health P. O. Box 1700 Director Jackson, MS 39205 Division of Solid Waste Management Mississippi Department of Natural Office of the Governor Resources State of Mississippi P. O. Box 10385 Jackson, MS 39201 Jackson, MS 39209 Attorney General President, Asst. Attorney General Claiborne County Board of Supervisors State of Mississippi Port Gibson, MS 39150 P. O. Box 22947 l
Jackson, MS 39225 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Vice President, Operations Support 611 Ryan Plaza Drive, Suite 1000 Entergy Operations, Inc.
Arlington, TX 76011 P.O. Box 31995 Jackson, MS 39286-1995 Senior Resident Inspector U. S. Nuclear Regulatory Commission Director, Nuclear Safety Route 2, Box 399 and Regulatory Affairs Port Gibson, MS 39150 Entergy Operatians, Inc.
P.O. Box 756 Nuclear Operating Plant Services Port Gibson, MS 39150 Bechtel Power Corporation 9801 Washington Boulevard Gaithersburg, MD 20878