ML20214L317

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Describes Special Circumstances of 10CFR50.12(a) Directly Applicable to Technical Justifications Provided in Util 860721 Request for Exemption to Inservice Insp Requirements of 10CFR50.55a.NRC Review Requested by 860930
ML20214L317
Person / Time
Site: Rancho Seco
Issue date: 08/26/1986
From: Julie Ward
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Miraglia F
Office of Nuclear Reactor Regulation
References
JEW-86-367, TAC-64448, NUDOCS 8609100080
Download: ML20214L317 (2)


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SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S Street. P.O. Box 15830. Sacramento CA 95f 521830, (916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HE ART OF CALIFORNIA August 26 1956 DIRECTOR OF NUCLEAR REACTOR REGULATION ATTENTION:FRANI: J. MIRAGLIA DIRECTOR PWR-B DIVISION US NUCLEAR REGULATORY COMMISSION WASHINGTON.DC. 20555 DOCI:ETN0.50-312 LICENSE NO. DPR-54 5UPPLEMENT TO THE EXEMIrfION REQUEST TO 10 CFR PART 50.55a FOR A PORTION OF THE 10-YEAR ISIEIAMINATIONS The Sacramento Municipal Utility District requested, by letter from John Ward to Frank Miraglia dated July 21.1986. an exemption to a portion of the In-Service Inspection (ISI) requirements of 10 CFR Part 50.55a pursuant to 10 CFR Part 50.12(a). Within the request. the District provided the technical justifications for the requested exemption. Consistent with the provisions of 10 CFR Part 50.12 the NRC will only consider granting exemptions when special circumstances are present.

In order to facilitate the NRC Staff review. the District hereby delineates which special circumstances of 10 CFR Part 50.12(a) are directly applicable to the technical justifications provided in the District's July 21.1%6 letter.

The underlying purpose of 10 CFR Part 50.55a and the stipulation of ISI requirements is to ensure that plant components have not degraded significantly as a result of years of plant operation. The request to postpone the examination of a small portion of the ISI programmatic examinations, which require reactor vessel head removal, is consistent with the underlying purpose of the rule since Rancho Seco operated at a reduced capacity over the 10-year ISI period. This request, therefore. is consistent with special circumstance (ii) of 10 CFR Part 50.12(a)(2).

A concomitant benefit of the approval of exemption request by the NRC Staff would be the elimination of approximately 45 person-rem in personnel exposure as stated in the District's July 12.1986 letter. This reduction in personnel radiation exposure represents a special circumstance as specified in 10 CFR Part 50.12'a)(2)(iv).

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F. J. MIRAGLI A August 26,1%6 l

Finally, as indicated in the July 21.1%6 letter, the District originally scheduled the 10-year ISI examinations for the Cycle 8 Refueling Outage. However, due to the protracted nature of the current plant outage. the District undertook the extensive effort of performing the majority of the 10-year ISI examinations including the Containment Integrated Leak Rate Test. ASME Code Class 1 and 2 component structural inspections. nozzle safe-end inspections, pipe supports and attachments, and various system hydro:tatic and leak tests during this outage. This exemplifies that the District made good faith efforts to comply with the regulation as specified in 10 CFR Part 50.12(a)(2)(v).

In summary, the District respectfully requests that the NRC staff provide scheduler relief to the next refueling outage for the examinations identified in the July 21.1%6 letter and confirmation of the acceptability of deferring the Once-Through-Steam-Generator Auxiliary Feedwater Internal Header examination until the next refueling outage. The District also requests that the NRC Staff conclude this review by September 30.1%6. In order to minimize the impact on the planning for start-up from the current outage.

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HN.ErWARD PUTY GENERAL MANAGER.

NUCLEAR cc: REGION V INP0

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