ML20203H818

Forwards 860116 Proposed Amend 133 to License DPR-54.Amend Returned as Cover Ltr Contains Errors,Safety Analysis Does Not Properly Evaluate Impact of Proposed Changes & NSHC Evaluation Not in Accordance w/10CFR50.91

ML20203H818
Person / Time
Site:	Rancho Seco
Issue date:	07/25/1986
From:	Stolz J Office of Nuclear Reactor Regulation
To:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
TAC-61480, NUDOCS 8608050102
Download: ML20203H818 (3)

Text

., .' ' . I July 25, 1986

,p Docket"No. 50-312 Mr. John E. Ward Assistant General Manager, Nuclear Sacramento Municipal Utility District 6201 S Street P. 0. Box 15830 Sacramento, California - 95813

Dear Mr. Ward:

Your submittal for proposed Technical Specification Amendment No.133 is enclosed. The proposed amendment has not been processed and is being returned for the following reasons:

1. There are errors in the cover letter.

2. The accompanying Safety Analysis does not properly evaluate or address the impact of the proposed changes.

3. The "No Significant Hazards Evaluation" is not written in accordance with 10 CFR 50.91.

Specific reasons for returning your submittal are listed below:

1. Cover Letter - (1) License amendments are not issued in accordance with

,10 CFR 50.59. Section 50.90 is the appropriate reference for license amendments. (2) It is not appropriate to reference an amendment request-notice in-the Federal Register as a basis for changing the Technical Specifications. The Federal Register is a mechanism for informing the general public of proposed licensing actions. The "No Significant Hazards Evaluation" in the Federal Register does not constitute approval of the proposed action by the Commission.

2. Safety Analysis - Your Safety Analysis states the deletion of the terms "all" and " entire" and deletion of the central files requirement are in accord with Comission determinations. As a minimum, you should reference where the Commission made these determinations and confirm that these determinations are applicable to Rancho Seco. The word " entire" is included in the audit section (section 6.5.2.8.b) of the B&W Standard Specifications. To remove the word " entire", your analysis should specifically address why the " training and qualifications of the entire facility staff" should not be audited at least once per year.

3. No Significant Hazards Evaluation - The "No Significant Hazards Evaluation" is not written in accordance with 10 CFR 50.91. You quoted a previous

. Federal Register Notice as the basis for concluding that your submittal meets the no significant hazards criteria. However, for the reasons stated in the preceding paragraphs, the referenced submittal is not applicable to. Rancho Seco.

8608050102 860725 PDR ADOCK 05000312 P PDR _

i

P%R 'O l d Since some of these administrative problems have also occurred in previous submittals, it is clear that management attention is needed to avoid future licensing delays.

If you wish to pursue this amendment request, you should address the deficiencies noted herein and resubmit your request.

Sincerely, cEloin1L s :. r at a v.s r . nu. -

John F. Stolz, Director PWR Project Directorate #6 Division of PWR Licensing-B l

Enclosure:

As Stated cc w/ enclosure:

See next page 4

DISTRIBUTION ACRS-10 Q U 61 Filj BGrimes NKC PDK JPartlow L PDR GKalman PBD-6 Rdg RIngram FMiraglia Gray File OELD NThompson EJordan SMiner i

I

/d s W PBDg PBD-6 PBD-6 P

'eflman;jak RWeller JS z p//f 7 /86 SMing/86 7/27 7/2f/86 7/g(/86 l

Mr. John E. Ward Rancho Seco Nuclear Generating Sacramento Municipal Utility District Station cc:

Mr. David S. Kaplan, Secretary Sacramento County and General Counsel Board of Supervisors Sacramento Municipal Utility 827 7th Street, Room 424 District Sacramento, California 95814 6201 S Street P. O. Box 15830 Ms. Helen Hubbard Sacramento, California 95813 P. O. Box 63 Sunol, California 94586 Thomas Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 Mr. Ron' Columbo Sacramento Municipal Utility District Rancho Seco Nuclear Generating Station 4440 Twin Cities Road Herald, California 95638-9799 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 20814 Resident Inspe'ctor/ Rancho Seco c/o U. S. N. R. C.

14410 Twin Cities Road Herald, California 95638 Regional Administrator, Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Director Energy Facilities Siting Division Energy Resources Conservation &

Development Commission 1516 - 9th Street Sacramento, California 95814 Mr. Joseph 0. Ward, Chief Radiological Health Branch State Department of Health Services 714 P Street, Office Building #8 Sacramento, California 95814 l

SMUD (h) SACRAMENTO MUNICIPAL UTILITY DISTRICT C AN ELECTRIC SYSTEM SERVING THE HEART oF CALIFORNIA RJR 85~608 January 16, 1986 DIRECTOR OF NUCLEAR REACTOR REGULATION ATTENTION FRANK J MIRAGLIA JR DIRECTOR, PWR B-DIVISION US NUCLEAR REGULATORY COMMISSION WASHINGTON DC 20555 DOCKET NO. 50-312 LICENSE N0. DPR-54 PROPOSED AMENDMENT NO. 133 In accordance with 10 CFR 50.59, the Sacramento Muncipal Utility District proposes to amend its Operating License DPR;54 for Rancho Seco Nuclear Generating Station Unit No. 1.

In accordance with the Commission's determination (Federal Register, Vol.

49, No.120, June 20,1984, page 25371) that the tenns "all" and " entire" can be deleted from technical specifications involving audits (Specifica-tions 6.2.8a, b, c and d), this proposed amendment implements those dele-tions.

In addition, earlier determination by the Commission (Federal Register, Vol . 48, No.15, January 21, 1983, page 2732) which allows deletion of the

" central file" requirement with respect to location of Equipment Oualifica-tion records is likewise implemented in this proposed amendment.

Attachments I, II and III to this submittal provide the Safety Analysis "No Significant Hazards" Evaluation and Description of Proposed Changes, re-spectively.

Pursuant to 10 CFR 50.91(b)(1), the Radiolooical Health Branch of the California State Department of Health Services has been informed of this proposed amendment by copy of this submittal.

Enclosed is a check in the amount of $150.00 as required by 10 CFR 170.21,

" Schedule of Fees."

l l LN

-8601220079 B6011632 ADOCK O f p{g g f0 @

DR 9

- \

,y 4 l

s l

% \

a.

PA - 133 January ,1986 Should you require any further infonnation with respect to this proposed amendment, please contact Mr. Ron W. Colombo at Rancho Seco Nuclear ergingStationUnitNo.1.

\R. .

't DRIG 7 Y

ASSISTANT GENE L MANAGER, NUCLEAR Attachments (3)

Subscribed and sworn to before me this /cd day of (w , 1986 **m'*"n====n===o"='"amaan= nim'a==nna g

} f9; PATRICIA K. GEISLER 3 i

l *?,7 A,/

Norany n me.-caumns 4 3 Patytx u. <>rHCE IN M l ,M;f, S.tCitA\tENTO COUNTY l H My Commission Ex

+-em===.pires february ne.=namun16. 1988 u

5

=+

'N6tary Public /

s

.y

. . . 1

+

. ATTACi# LENT I SAFETY ANALYSIS

't .

Deletion of the terms "all" and." entire" with respect to Audits, and the i- central files requirement regarding the location of Equipment Qualification

- records are in accord with Commission determinations. A review of these ~

deletions does not disclose any adverse effects on plant safety nor are they f

seen to constitute an unreviewed safety question.

1 i

I i

f I

i r-

~

1 I; I

ATTACHMENT II q

"N0 SIGNIFICANT HAZARD 5" EVALUATION The proposed deletions from the Rancho Seco Technical Specification of the-terms "all" and " entire" with respect to Audits, and " central storage" with respect to Equipment Qualification records are in accordance with NRC deter-minations (Federal Register Vol. 49, No. 120, page 25371 and Vol. 48, No.15, page 2732, respectively). Therefore, Proposed Amendment No. 133 constitutes a purely administrative change which, by Commission guidance concerning the application of 10 CFR 50.92, is judged not likely to involve significant hazards considerations.

1 Y

ATTACHMENT III DESCRIPTION OF PROPOSED CHANGES

1. Specification 6.5.2.8a, page 6-9: Deleted word "all", first line.

2. Specification 6.5.2.8b, page 6-9: Deleted word " entire", first line. /

l 3. Specification 6.5.2.8c, page 6-9: Deleted word "all", first line.

4. Specification 6.5.2.8c, page 6-9: Replaced word "all" with " selected",

first line.

5. Specification 6.14.2, pay 6-16: Deleted words "at a central location",

second line.

1

}

I I

i l

l 1

I v

l

. . - - - - - - . - , - . - - - - . - - - . _ . . - . - . . .--.- - -..-, --- . , - . - , . - , . , .,