ML19318A991
| ML19318A991 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 06/18/1980 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0578, RTR-NUREG-0660, RTR-NUREG-578, RTR-NUREG-660, TASK-***, TASK-TM NUDOCS 8006240488 | |
| Download: ML19318A991 (6) | |
Text
.
e"- SACRAMENTO MUNICIPAL UTILITY oisTRICT C 6201 s stre suun (916) 452 3211 June 18,1980 Mr. Darrell G. Eisenhut Director, Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docket #50-312 NUREG-0660 Cer.itments Rancho Seco
Dear Mr. Eisenhut:
Your letter of May 7,1980, requested that the Sacramento Municipal Utility District consider selected requirements from NUREG-0660, TMI Action Plan, and commit to the requirements and the associated schedules.
The District carefully reviewed each of these items. The attachment to this letter provides the District's position on each item.
Sincerely, h
John f. Mattimoe Assistant General Manager and Chief Engineer Attachment 8006240
4 l
Sacramento Municipal Utility District's Position on Selected NUREG-0660 Action Items as Required by NRC Letter dated May 7,1980 Item I.A.1.3. - Shif t Manning 1
Your letter of May 7,1980 states that additional NRR requirements will be provided. The District awaits these requirements before establishing a position on snif t manning i
Item I.A.3.1. - Revised Scope and Criteria for Licensing Examination Reactor operator and senior reactor operator training program has been upgraded to require a new category on the examination dc' ling with the rmodynamic s.
A time limit for the requalification examination has been estaolished and the passing grades increased to 80 percent overall with a minimum grade of 70 percent in each category.
All operators are required to pass oral examinations. Tne requalification program essentially encompasses the same requirements as those required of initial licenses.
Thus, the above mentioned items are currently in ef fect at Rancho Seco.
The District awaits more detailed information on NRR simulator examinations before embracing them as part of the license examination.
Item I.C.5 - Procedure for Feedback of Operating Experience to Plant Staff 1)
Information on pertinent operating experience is distributed by the Operations Supervisor via "Special Oraers." The Training Coordinator receives copies of all the "Special Orders" and incorporates the information into the training and retraining programs as applicable.
2)
The review of operating experience is conducted by the onsite Plant Review Committee (PRC) or by other site personnel assigned to the task.
The committee recommends to the Plant Superintendeat actions necessary to resolve problems via procedure changes or operating orders.
"Special Orders" requiring immediate attention are issued by the Operations
' Supervisor who is a nember of the Plant Review Committee.
3)
Plant Review Committee minutes are distributed to SMUD managenent who are members of the Management Safety Review Committee, the PRC, all nonmembers at the meeting, the training coordinator and to individuals responsible for scheduling and documentation.
They review the minutes for pertinent infonnation in areas of concern and take necessary action to carry actions to conclusion.
4)
The Operations Supervisor acts as the controlling agent of "Special Orders" to prevent obscure and conflicting information from being distributed to the operations personnel.
Training department personnel also screen for extraneous material.
4 w
nw
~
g
e 5)
Same as 4)-
6)
Same as 4) 7)
The NRC Onsite Inspectors, the Plant Review Committee ana the Quality Assurance Inspectors continually monitor the feedback program function.
Any deficiencies are brought to management's attention via personal contact or regularly-scheduled meetings with the NRC, the PRC ana QA.
Item I.I.K.3.1 - Installation and Testing of Automatic PORV Isolation System i
Tne District intends to install an automatic closure feature on the control circuitry for tne existing PORV block valve curing 1981 refueling outage. A confinnatory operational test will be performed prior to plant startup af ter ti'e outage. The District will analyze.f ailure of the system to determine its
- 4. fluence on overall plant safety during plant transients and accidents.
In response to this action the District strongly urges that your organization reconsider the PORV and Reactor Protection System trips setpoint changes made as a result of I&E Bulletin 79-05B. We believe that the current settings result in unnecessary challenges to the Reactor Protection System and tnerefore reouce overall plant safety and reliability.
Item II.K.3.2 - PWR Vendor Report on PORV Failure Reduction B&W can complete a generic PORV f ailure reduction study in time to support a 1
January 1,1981 submittal date.
The report will include consideration of the automatic PORV isolation system if the details of the system have been finalized by September 1, 1980.
The District intends to provide the report by January 1, 1981.
I Item II.K.3.3 - Reporting Safety and Relief Valve Failures and Challenges The District currently notifies the NRC of reportable occurrences using the guidance of Regulatory Guide 1.16 Revision 4.
That guidance requires prompt reporting of " Failure of a safety / relief valve to close af ter pressure has reduced below the required reseat" pressure.
The District will continue this prompt reporting policy.
Rancho Seco Technical Specifications require submission of monthly reports rather than annual reports.
The District commits to report PORV and safety valve challenges in the monthly report when Regulatory Guide 1.16 is changed i
to reflect this requirement. The District chose this position because we strongly believe that reporting requinnents snould be described by one document rather than by many uncoordinated documents.
i Item II.K.3.5 - Automatic Trip of Reactor Coolant Pumps During LOCA The District-will continue to participate in generic efforts toward development of automatic trip of reactor coolant pumps during a small Dreak b
s.
loss of coolant accident. Tne District and other Licensees are being requesteo to analyze LOFT L3-6 scheduled for December, 1980.
This test may provide useful information related to this analysis. As the schedule for the LOFT ef fort is not compatible with the date suggested in your letter, the District cannot commit to the proposed schedule.
The District will cont 5nue to attempt to cevelop a schedule and will inform you of our progress by august 1, 1980.
J.
Item II.K.3.9 - Proportional Integral Derivative (PID) Controller Modification This item is not applicable to Rancho Seco.
Item II.K.3.10 - Proposed Antic;?atory Trip Modification This item is not applicable to Rancho Seco.
Item II.K.3.12 - Confirm Existence of Anticipatory Trip Upon Turbine Trip This item is not applicable to Rancho Seco.
Item II.K.3.13 - Separation of HPCI and RCIC System Initiation Levels -
Analysis and Implementation This item is not applicable to Rancho Seco.
Item II.K.3.14 - Isolation of Isolation Condensers on Hign Radiation This item is not applicable to Rancho Seco.
Item II.K.3.15 - Modify Break Detection Logic to Prevent Spurious Isolation of HPCI and RCIC Systems This item is not applicable to Rancho Seco.
Item II.K.3.16.- Reduction of Challenges ano Failures of Relief Valves -
Feasibility Study and System Modification This item is not applicable to Rancho Seco.
Item II.K.3.17 - Report on Outage of ECC Systems - Licensee Report and Proposed Technical Specification Changes l
Acquisition of the requested 'information will require scores of man-hours and i
possibly man-weeks of effort by knowledgeable personnel. The District is l
willing to' exert this substantial effort and to accept this considerable l
expense if we'are convinced the results will be used to reasonably enhance the l
i
- ~..
safety of nuclear power plants and in particular Rancho Seco. We request a detailed, explanation of how this information will oe used prior to commiting j
to this substantial task.
t j
3 Item II.K.3.18 - Modification of ADS Logic - Feasibility Study and Modifications for Increased Diversity for Some Event Sequences This item is not applicable to Rancho Seco.
i Item II.K.3.19 - Interlock on Recirculation Pump Loops l
Tnis item is not applicabic to Rancho Seco.
Item II.K.3.20 - Loss of Service Water for Big Rock Point
+
l Tnis item -is not applicable to Rancho Seco.
[
Item II.K.3.21 -Restart of Course Spraj and LPCI Systems on Low Level - Design j
and Modification
(
i This item is not applicable to Rancho Seco.
i Item II.K.3.22 - Automatic Switch Over of RCIC System Suction - Verify t
Procedures and Modify Design This item is not applicable to Rancho Seco.
Item II.K.3.24 - Confirm Adequacy of Spaca Cooling for HPCI and RCIC Systems This item is not applicable to Rancho Seco, i
i Item II.K.3.25 - Effect of Loss of AC Power on Pump Seals t
[
This item is not applicable to Rancho Seco per your June 9,1980 letter.
..m i II.K.3.27 - Provide Common Reference Level for Vessel Level Instrumentation This -item is not applicable to Rancho Seco.
1 Item II.K.3.23 - Study ana Verify Qualification of Accumulators on ADS Valves This. item is not applicable to Rancho Seco.
l
[
c
.m.
e..-.
l 1
Item II.K.3.29 - Study to Demonstrate Performance of Isolation Condensers with Non-Condensables This item is not applicable to Rancho Seco per your June 9,1980 letter.
Item II.K.3.30 - Revise Small Break LOCA Methods to Show Compliance with 10 CFR 50 Appendix K t-The information supplied with this action item in your May 7,1980 letter said that Draf t 4 of NUREG-0660 would provide clarifying information.
Prior to commiting to this potentially large task, the District requires this clarifying information.
The District also requires additional information concerning wnich small break LOCA analysis methods do not satisfy Appendix K to 10 CFR Part 50.
Item II.K.3.31 - Plant Specific Calculations to Show Compliance with i
10 CFR 50.46 The response to Item II.K 3.30 is equally applicable to this response.
Item II.K.3.44 - Evaluation of Anticipated Transients with Single Failure e
to Verify No Fudl Failure This item is not applicable to Rancho Seco per your June 9,1980 letter.
Item II.K.3.45 - Evaluation of Depressurization with Other than ADS This item is not applicable to Rancho Seco.
Item II.K.3.46 - Response to List of Concerns from ACRS Consultant This item is not applicable to Rancho Seco.
Item II.K.3.57 - Identify Water Sources Prior to Manual Activation of ADS 1-This item 1s not applicable to Rancho Seco.
l 1
Item 111.0.3.4 - Control Room Habitability l
The District will complete a review of control room habitability by January 1, 1081.
The review will be done using Regulatory Guides 1.78 and 1.95 and Standard Review Plan Sections 2.2.1, 2.2.2, 2.2.3 and 6.4.
If the review shows that plant modifications are necessary, a schedule will De provided.
__