ML20082R505

Requests Relief from Requirements of 10CFR50.55a(g)5(ii) Re Inservice Insp Program.Revised Inservice Insp Tech Specs & Relief Requests Will Be Submitted by 840113

ML20082R505
Person / Time
Site:	Kewaunee
Issue date:	12/06/1983
From:	Giesler C WISCONSIN PUBLIC SERVICE CORP.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
CON-NRC-83-219 TAC-53493, NUDOCS 8312130194
Download: ML20082R505 (2)

Text

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.' NRC-83-219 WISCONSIN PUBLIC SERVICE CORPORATION P.O. Box 1200, Green Bay, Wisconsin 54305 December 6, 1983 Director, Office of Nuclear Reactor Regulation Attention: Mr. D. G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Eisenhut:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Inservice Inspection Technical Specifications

References:

1) Letter from E. W. James to Director, NRR dated April 15, 1977

2) Letter from E. W. James to Director, NRR dated July 18, 1977

3) Letter from E. W. James to A. Schwencer dated February 9, 1978

4) Letter from E. R. Mathews to A. Schwencer dated May 1, 1981

5) Letter from E. R. Mathews to S. A. Varga dated May 7, 1982 In references 1 through 5 we provided you with proposed Technical Specification Amendments which included a tabulation of all the inservice inspection require-ments of the 1974 Edition of the ASME Code (Section XI) including all addenda through the Summer 1975. The bases for relief requests and alternate testing were also provided in the proposed technical specification amendment submit-tals.

In accordance with 10CFR50.55a(g)S(i) we are preparing an updated Inservice Inspection Plan. The next 120-month inspection interval starts June 16, 1984; therefore, in accordance with 10CFR50.55a(g)4(ii) we are updating the plan to address the requirements of the 1980 edition of the ASME Code (Section including all addenda through the Winter 1981.

10CFR50.55a(g)5(ii) requires licensees to apply to the commission for endment of the technical specifications if the revised inservice inspection prog .

conflicts with the technical specifications for the facility. This application is required to be submitted at least six months prior to the star of the period during which the new plan becomes applicable. In the case of the Kewaunee Plant, the technical specification revision should be submitted by December 16, 1983. 8312130194 831206 PDR ADOCK 05000305 hN '

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,- ' Mr. D.-G. Eisenhut December 6 1983 Page 2 The. project to revise and update both the Inservice Inspection (ISI) Program and the Inservice Testing (IST) Program (pumps and valves) has been in progress for about a year. Draft copies of the revised ISI plan are currently being reviewed by WPS personnel and revisions to the draf t are being incorporated. The draft IST program is nearing completion and will soon receive internal distribution for. comment. It is the intent of WPS to conduct a thorough and detailed review

- of the program prior to the technical specification submittal. The internal review is aimed at eliminating any incompleteness or inaccuracies in the plans.

Because of the extensive and comprehensive nature of these documents, the review process will be more time-consuming than anticipated.

A submittal of the revised technical specification to you by December 16, 1983 would require the personnel reviewing the plan to expedite and limit their review. Personnel unavailability due to other work-related responsibilities and vacation schedules during the holiday season has further limited the time available for review. We therefore request an extension of the submittal date until-January 13, 1984.

We feel the extension of the submittal date to January 13, 1984 is justified for

- the following reasons:

1) The WoS detailed internal review is intended to eliminate any errors or inconsistencies in the plan prior to the technical specification and 1

relief request submittal. 'This detailed review prior to the technical specification and relief request submittal will greatly reduce the amount of future correspondence concerning plan modification.

2) The one-month extension does not significantly reduce the time availa-ble for~NRC review. The revised ISI and IST plans will become effec-tive on June 16, 1984; however, due to our refueling outage schedule, the revised ISI plan (NDE exams) is not scheduled to be implemented until our spring refueling outage in 1985.

We request relief from the requirements of 10CFR50.55a(g)5(ii) and we propose to submit our revised Technical Specifications and relief requests by January 13,

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1984. We feel the relief'is warranted based on the justification provided above. This request has been discussed with our NRC Project Manager.

Very truly yours, M V AA 1 h C. W. Giesler Vice-President - Nuclear Power DSN/js cc - Mr. S. A. Varga,-US NRC Mr. Robert Nelron, US NRC

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