ML20148H363
| ML20148H363 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 03/23/1988 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Cranston A SENATE |
| Shared Package | |
| ML20148H367 | List: |
| References | |
| 2.206, NUDOCS 8803290407 | |
| Download: ML20148H363 (5) | |
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MAR 2 31S83 The Honorable Alan Cranston United States Senate Washington, D.C. 20510
Dear Senator Cranston:
This is in response to your letter of April 1,1987, forwarding a petition by Ms. Barbara Holler that requested that the Rancho Seco Nuclear Generating Station "not be restarted until a complete check of all cables is undertaken."
In my letter to 24, 1987, I stated that the Nuclear Regulatory Comission (NRC)you woulddated Aprilto Ms. Moller's request once the various NRC respond staff and licensee efforts that were in progress had been completed. I also indicated that the NRC would not authorize restart of Rancho Seco until the cable routing discrepancies were resolved.
The NRC Office of Nuclear Reactor Regulation .. . now completed its safety review of cable discrepancies. For the reasons set forth in the enclosed Director's Decision under 10 CFR 2.206, Ms. Moller's request has been denied.
A letter has been forwarded to Ms. Moller informing her of the denial. A copy of the Director's Decision and the _ Federal Reaister Notice regarding the Director's Decision are enclosed with that letter.
In accordance with 10 CFR 2.206(b), a copy of the Decision will be filed with the Office of the Secretary of the Comission for its review. The Decision will constitute final action of the Comission 25 days after the date of issuance unless the Comission, on its own motion, institutes a review of the Decision within that time.
For your information, I am enclosing with this letter a copy of the Notice regarding this Decision that was filed with the Office of the Federal Register for publication. As requested in your letter of April 1, 1987, I am also enclosing a copy of the letter from Ms. Moller that was attached to your letter.
Sincerely, i priginal signed BD hmes it Taylcr "r Victor Stello, Jr.
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l Executive Director for Operations 8803290407 880323
Enclosures:
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- 1. Director's Cecision bDR PDR
- 2. _ Federal Register Notice
- 3. Letter from B. Moller to NRC dated February 25, 1987
- See previous concurrence g
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Ms. Barbara Holler Post Office Box 163306 Sacramento, California 95816
Dear Ms. Moller:
This Region is YinOffice furtherof response the NucleartoRegulatory your letterComission dated February)25,1987 (NRC . Pursuant to to the 10 CFR 2.206, you requested the NRC to order the licensee of the Rancho Seco Nuclear Generating Station to show cause why the plant should not be prevented from restarting until a complete check of all cables was under-taken or, in the alternative, why the plant should not be completely shut down. As the bases for your Petition, you referenced (1) the "official investigation" concerning falsification of cable tray data and (2) the "problem-laden history" of the facility.
On April 27, 1987, I inforTned you that your letter would be treated under 10 CFR 2.206 and that a formal decision would be issued in a reasonable time.
On September 13, 1987, I informed you of the status of our investigation related to the concerns expressed in your Petition. In my September 13, 1987 letter, I stated that Rancho Seco would not be pemitted to restart until the safety concerns associated with the plant cables were resolved.
For the reasons set forth in the enclosed Director's Decision under 10 CFR 2.206, your Petition has been denied. A copy of the Decision will be filed with the Secretary of the Comission for its review in accordance with 10 CFR 2.206. The Decision will constitute final action of the Comission 25 days after the date of issuance unless the Comission, on its own motion, insti-tutes a review of the Decision within that time.
For your infonnation, I am enclosing a copy of the NRC staff's "Safety Evaluation Report related to the restart of Rancho Seco Nuclear Generating Station Unit 1, following the event of December 26, 1985" (NUREG-1286) and Supplement I to that Report, both of which contain information relied upon in this Decision. I have also enclosed a copy of the notice regarding this Decision that was filed with
- the Office of the Federal Register for publication.
Sincerely, M $
Thomas E. Murley, Director
- Office of Nuclear Reactor Regulation
Enclosures:
- 1. Director's Decision
- 2. Federal Register Notice
- 3. NUREG-1286
- 4. Supplement 1 to NUREG-1286
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DD- 88-4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Thomas E. Murley, Director In the Matter of SACRAMENTO MUNICIPAL UTILITY DISTRICT Docket No. 50-312 (Ranche Seco Nuclear GeneratingStation) ) (10CFR2.206)
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DIRECTOR'S DECISION UNDER 10 CFR 2.206 INTRODUCTION On February 25, 1987, Ms. Barbara Moller submitted a Petition in ascordance with 10 CFR 2.206. The Petition was referred to the Director, Office of Nuclear ReactorRegulation(NRR)forconsideration.
The Petition asked the U. S. Nuclear Regulatory Comission (NRC) to order the licensee of the Rancho Seco Nuclear Power Plant to show cause why the plant should not be prevented from restarting until a complete check of all cables was undertaken or, in the alternative, why the plant should not be completely shut down. Ms. Moller gave as the bases for the Petition (1) the "official investigation" concerning falsification of cable tray data and (2) the "problem-laden" history of the Rancho Seco facility. In the Petition, Ms.
Holler asserted that three forged signatures had been found at each level in the quality control hierarchy on at least seven cable installation cards and that this indicated that proper cross-checking had not been done. Ms. Moller further asserted that in light of the falsification of cable data, sampling was not an effective method for checking cable work. Ms. Moller further asserted that 2000 cables had been added to the plant since 1974, and she expressed
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concern regarding infomation that had indicated to her that a sample of only 215 cables was going to be checked.
On April 1,1987, the Comission's Office of Governmental and Public Affairs received a letter from United States Senator Alan Cranston requesting that the Commission staff respond to the concerns raised in Ms. Moller's Petition. The staff responded in a letter from Mr. Victor Stello, Jr., Executive Director for Operations, dated April 24, 1987. T,he letter stated that a response to Ms. Moller would be made following the completion of evaluations being perfomed by the licensee and the staff and that the NRC would not authorize restart of Rancho Seco until the cable routing discrepancies were resolved.
On April 27, 1987, Dr. Thomas E. Murley, Director, NRC Office of Nuclear Reactor Regulation (NRR), acknowledged receipt of the Petition. He infonned Ms. Moller that the Petition would be treated under 10 CFR 2.206 of the Comission's regulations and that appropriate action would be taken in a reasonable tirne.
Notice of receipt of the Petition was published in the Federal Register on May 6, 1987, (52 FR 16967).
In a letter dated September 13, 1987, Dr. Murley advised Ms. Moller that the licensee was currently working to resolve the cable problems and that the NRC staff l was monitoring this effort and would provide an independent assessment of the extent of the problems and the adequacy of proposed resolutions. He also reiterated the NRC staff's position that Rancho Seco would not be pemitted to restart until the safety concerns associated with the plant cables were resolved.
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BACKGROUND The Rancho Seco Nuclear Generating Station, operated by the Sacramento Municipal Utility District (SMUD, the licensee) is a 916-MWe Babcock and Wilcox (B&W) designed pressurized-water reactor located in Clay, California, about 25 miles southeast of Sacramento. The plant received an NRC operating license in 1974 In the years 1983 through 1985,,the licensee undertook and completed a significant design / construction effort regarding electrical cable at Rancho Seco. These efforts involved rerouting of existing cable, and installation of new cable. This work was done in support of an expanded electrical distribution system, implenentation of requirements imposed on licensees after the accident at Three Mile Island, implementation of modifications for fire protection (delineated in Appendix R to Part 50 of Title 10 of the Code of Federal Regulations), and efforts to environmentally qualify safety-related electrical equipment. In this period, approximately 7800 cables were either installed or rerouted, including 2034 which served safety-related equipment.
Concerns regarding cables began to surface in 1984 when it was alleged that records documenting electrical cable installation were not properly controlled, that some records were missing, and that data entered into the computerized cable raceway and tracking system (CRTS) might be inaccurate.
Subsequent investigation by the licensee and review by the NRC staff has shown these allegations were true. The NRC staff's evaluation is documented in NUREG-1286, Supplement 1.
Following the discovery and investigation of the cable routing discrepancies the licensee developed a plan for cable inspection. In January 1987 the licensee
integrated this inspection activity and reviews of other cable-related problems into a single program under a single program manager.
The NRC staff has monitored and evaluated the licensee's program for identifying and correcting safety-related cable problems. This evaluation is documented in Section 4.8 of the NRC staff's "Safety Evaluation Report related to the restart of Rancho Seco Nuclear Generating Station, Unit 1 following the event of December 26, 1985," and Supplement I to that report (NUREG-1286 and NUREG-1286, Supplement 1). The issues raised by Ms. Moller in her Petition were addressed by the staff in Sections 4.8 and 2.3.2 of NUREG-1286 as discussed below.
DISCUSSION A. Falsification of Cable Pull Cards Investigations of cable discrepancies, including inspections, have been perfomed by the licensee. The results showed that in two separate instances safety-related electrical cables had not been rerouted even though the cognizant field engineers and quality control inspectors had signed off on the cable installation records (cable pull cards) indicating the cables had been rerouted.
Also, in both cases the signature of the cable installer was not on the pull card as it shculd have been, according to established plant procedures. In the first case, which involved 14 cables serving equipment for remote plant shutdown, t
- the cable installer's name was printed on the cards. In the second case, which involved the intemixing of 11 power and control cables with instrumentation l cables in instrumentation cable trays, the field engineer's signature was in l
l the signature block reserved for the signature of the cable installer. The safety implications of these cable discrepancies are discussed below.
e To understand the safety implications associated with the cable discrep-ancies and to detemine the appropriate corrective actions, it was necessary for the licensee to understand the nature of the deficiencies in field engi-neering and quality control. The licensee has detennined the nature and extent of the cable discrepancies with fomal programs for investigation of identified cable discrepancies and inspection of installed cable. The NRC staff has reviewed the licensee's pr,ograms for investigation and inspection and found them acceptable.
The 14 Remote Shutdown Cables The first instance mentioned above involved 14 remote shutdown cables that were to have been rerouted to satisfy separation criteria for fire protection specified in 10 CFR Part 50, Appendix R. In this instance, the field work necessary to reroute the cables was simply not done and the cables remained in an unaccept-able configuration. The licensee's investigation indicates that the work order (i.e., the cable pull cards) for rerouting the cables was never transmitted to the installer from the field engineer. Consequently, the cables were not pulled back and repulled into their new locations. A principal cause of this failure appears to be that instead of using the established procedure for controlling cable pull cards, the field engineer and the Card Control Group (CCG) clerk were using an infonnal procedure developed by an engineering aide in the CCG. It also appears that when the card control discrepancy was detected, proper follow-up action was not taken. The NRC Office of Investigations is currently investigating whether or not wrongdoing was involved in this matter.
The failure of the quality control (QC) inspector to detect the work control error during his inspection is thought to be the result of the practice of some electrical QC inspectors to attempt to inspect cable routing after the work was completed. This practice is unacceptable because it usually allows inspection only in the vicinity of the cable terminations, and hence a failure to reroute a portion of the cable located away from the terminations would not be detected. As discussed in Append,ix A of NRC Inspection Report 50-312/87-21, inspections of this type did not satisfy the existing procedural requirement to verify that the installed cable route was in agreement with the approved design drawings. In a letter from the NRC dated July 30, 1987, the licensee was notified that the improper QC practice was a Severity Level IV violation of 10 CFR Part 50, Appendix B, Criterion X, which governs inspection of activities involving quality. The licensee's corrective actions in response to this violation, are discussed later in this document.
The 11 Interinixed Cables The second instance involved 11 power and control cables that were to have been removed from some of their original trays and rerouted so that the trays could be redesignated and used to house new instrumentation cable. This work i
was to have been done as part of a major modification in 1983 that involved the j
relocation and installation of a large amount of cable over a relatively short time period. As in the first instance, the cable pull cards had been signed off indicating the work necessary to complete the rerouting of the 11 cables
! was done; but the work had not been done. Thus, when the new instrumentation l
cables were pulled into the redesignated cable trays, intermixing of safety-related power / control and insti c entation cables occurred, which constituted a violation of design criteria.
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The licensee's investigation also identified procedural violations on the part of the field engineers and QC inspectors. The procedural violations included the signing of cable pull cards by the field engineer instead of by the craft foreman responsible for actually perfoming the work and the failure of QC inspectors to properly verify that the installed cable route was in accordance with specifications. As discussed above, the licensee was cited with a Severity Level IV violation o,f 10 CFR Part 50, Appendix B, Criterion X, for failing to conduct proper inspection of cable routing. The licensee's corrective acticns in response to this violation are discussed below.
Safety Implications and Corrective Actions Following the completion of the investigation of the 14 remote shutdown cable discrepancies and the discovery of the 11 intemixed cables, it became apparent to both the licensee and the NRC staff that the faulty practices, procedures and controls that had allowed cable routing problems to occur and go undetected could very well have affected other safety-related cables. In a July 2, 1987 letter from G. C. Andognini, SMUD, to Frank J. Miraglia, NRC, the licensee comitted' to expanding the ongoing inspection of safety-related and safe shutdown cable to include all such cables in the population that had been rerouted since the beginning of comercial operation at the plant. The NRC staff agreed that this expansion was necessary because multiple errors in rerouting had occurred and such errors could not be detected if route verifications were not properly performed by QC inspectors. Those inspections have since been completed and no other work control errors were identified. The results of the inspections are discussed below under item C.
In response to the cable installation deficiencies described above, the licensee has developed new procedures and controls and has made improvements to existing ones. The changes have bcen based on the results and recomendations derived from the licensee's investigations of cable discrepancies. The changes that specifically address control of cable work are as follows:
- 1. A new procedure has been developed that establishes instructions for the processing of. cable installation cards. It details the interfaces between the CCG, CRTS Administrator, and Field Engineering.
One important feature of the procedure is that it requires installation cards to be returned to the CRTS Coordinator after the work has been completed and held until the Engineering Change Notice is closed.
The procedure currently exists as an attachment to the Nuclear Engineering Administrative Procedure (NEAP) 4127, Rev. O. and is
- being femalized for use as the card Control Electrical Engineering Instruction. Fomal training on use of the procedure will be given to
! personnel who are either in the CCG or who handle cable installation cards in interfacing groups.
- 2. Existing cable installation procedures (MP/IS 307) have been revised so that cable route inspection is specified as a "hold i point" in the procedure. QC inspectors are now required to l witness cable pulls so that routing can be properly verified.
l Electrical QC inspectors have been trained regarding this procedural clarification. Use of this procedure will ensure that installed cable routes are properly verified.
- 3. Cable route revisions and repulls are to be specified on the cable drawings and foms input to the CRTS. Changes to these documents resulting froni route revisions will be treated as Drawing Change Notices (DCN). New installation documents will not be generated for repulls. The intent of this change is to ensure that field in:;tructions for impimenting route revisions are clear.
1 In addition to the specific changes described above, the licensee has made broad changes in the Rancho Seco quality assurance (QA) program. These changes were presented to the NRC staff in a meeting held September 23, 1987. The more l significant changes include: reorganization of the QA department with the new Director of Nuclear Quality reporting directly to the Chief Executive Officer;
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increased staffing with people who have multidisciplinary backgrounds; organi-zational independence from production organization; and increases in the scope and frequency of audit activities.
The NRC staff considers both the specific and broad changes in procedures and quality control to be acceptable. However, in the course of the normal inspection program the staff will continue to closely monitor perfomance in quality activities to ensure that thp changes are effective.
B. Inspection of Cable Routes The licensee's corrective action regarding inspection of cable routes has been (1) a complete (100%) inspection of all safety-related and safe shutdown cables that have involved route revisions between the start of comercial operation and the initiation of the inspection program on December 22, 1986 (475 cables) and (2) a random sample inspection of cables installed between the start of comercial operation and the initiation of the inspection program thathaveneverundergonerouterevisiens(142of1559 cables). The 14,000 cables installed during th'e original construction of the plant, which have never involved route revisions were excluded from the inspection program by the licensee because
- 1. There has been no indication of any significant installation error or technical problem through startup or subsequent operation or surveillance testing.
- 2. The original architect engineer (Bechtel) had in place and used a rigorous quality control program for the design, installation, and inspection of the original cable population and followed a unifomly consistent set of rules and procedures.
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I The NRC technical staff has reviewed the licensee's documentation for the procedures and controls for cable design and installation in place during original construction. The staff's review is documented in Section 4.0.2.2 of Supplement 1 to NUREG-1286. On the basis of this review, the staff has concluded that (1) the Bechtel quality control program and Bechtel's circuit and raceway scheduling program were sufficient to adequately control the origi-nal design and installation of the original cable population and (2) reinspection of this cable population is not necessary.
The licensee completed the inspections on December 9, 1987. The results were documented in the Wire and Cable Program report transmitted to the NRC by letter dated January 22, 1988. The NRC staff's review of the report is documented in Section 4.8 of Supplement I to NUREG-1286. According to the report, the licensee found no significant routing errors in the sample inspection of the l
- newly installed cables that had never been rerouted. A total of 19 significant l cable discrepancies were identified in the 100% inspection of rerouted cables, excluding the original 7 cable discrepancies that had prompted the inspection program. All 26 identified cable routing discrepancies have been corrected in the plant by properly rerouting the cables.
C. Sampling In the staff's view, the objective of a sample inspection of construction work is to deterinine with reasonable assurance that the number and significance of deficiencies in construction and quality assurance have not degraded safety margins to an unacceptable level. In the case of misrouted electric cables at Rancho Seco, the following criteria were used:
- 1. There is 95% assurance that at least 95% of the cables are correctly routed (95/95).
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- 2. The defects have no significant potential for a loss of redundancy as a result of a single failure during a design-basis accident.
An NRC staff statistician has reviewed the sample sizes included in the revised sampling plan submitted with the licensee's letter of July 2,1987 and has concluded in Section 4.8 of NUREG-1286 that when sampling has been done according to the licensee's plan, the 95/95 acceptance criterion stated above has been met. Sample inspections were completed according to the licensee's plan on December 9,1987. Based on the results of these inspections, the NRC staff has concluded in Section 4.8 of Supplement 1 to NUREG-1286 that the 95/95 acceptance criterien stated above has been met.
- On the basis of the knowledge of the causes of the routing defects identified at Rancho Seco, the types of defects identified and the results of inspections, which ensure that the 95/95 acceptance criterion has been met, the staffhasconcludedthat(1)thelikelihoodofinstalledsafety-relatedandsafe shutdown cables being in a configuration that violates physical separation criteria
! is acceptably low; and (2) the potential for a redundant safety system failure as a result of a possible major cable defect (violation of physical separation criteria) also is acceptably low.
D. ' Problem-Laden History" of the Facility Following issuance of the NRC staff's Incident Investigation Team's (IIT) report on the December 26, 1985 overcooling event at Rancho Seco, it became apparent to both the staff and the licensee that the design and programmatic deficiencies identified during the staff's investigation were symptomatic of more serious problems than those associated with the overcooling event and l would require a corrective action program that embodied more than the narrow 1
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focus of the overcooling event. Accordingly, in the spring of 1986, the licensee embarked on a comprehensive Plant Performance and Management Improvement Program (PP&MIP) that responded to a broader range of issues.
The program was designed by the licensee to comprehensively identify all known problems that had occurred, or that could be anticipated to occur in the future, based on experience at similar facilities. Problems were identified from several sources: a precursor r,eview of historical documents and recomenda-tions; interviews with a cross-section of the plant staff (180 interviews);
a deteministic failure analysis for the effect of loss of electrical power, instrument air, and control power on plant operations; incorporation of relevant Babcock and Wilcox (B&W) Owners Group Safety and Perfomance Improvement Program (SPIP) recomendations; NUREG-1195, the Incident Investigation Team (IIT) report of the December 26th event; and other miscellaneous infomation. The resolution of each problert was prioritized by the licensee as a restart, near-tem, or long-tem item.
The problems identifieo were organized by type or system, reviewed by two licensee boards to eliminate redundancy, and assigned priorities for implementa-tion. At the same time, the recomendations were combined with the functional and test requirements of each plant system to produce a reference document for each system.
The NRC staff has reviewed ther PP&MIP as part of the Rancho Seco restart safety evaluation and found it to be acceptable. The staff's evaluation of the program is documented in Section 2.3.2 of the NRC staff's "Safety Evaluation Report related to the Restart of Rancho Seco Nuclear Generating Station, Unit I following the event of December 26, 1985," and Supplement 1 to that report (NUREG-1286 and NUREG-1286, Supplement 1).
E. Design Control Deficiencies The Petitioner also referenced "significant design control deficiencies" in safety-related pipe supplies. Problems which reflect deficiencies in design control were identified by the NRC staff during its Augmented System Review and Test Progran, (ASRTP) inspection conducted at Rancho Seco in early 1987.
These problems are discussed in Inspection Report 50-312/86-41 and suninarized in Section 3.7.2.2 of NUREG-1286. ;
To address deficiencies in design control the licenser. has developed and implementeditsEngineeringActionPlan(EAP). The purposes of this plan are to improve the quality of work involving design reviews and design changes and to document, in detail, the design bases for key safety systems. The NRC staff evaluated the plan and implementation of the plan during a follow-up ASRTP inspection conducted between September 28 and October 9, 1987. As discussed in its inspection report (50-312/87-29), the staff has concluded that, overall, the quality of design work at Rancho Seco has improved and that remaining weak spots would be corrected when new supervisors and engineering personnel were fully trained in the various aspects of the EAP.
CONCLUSION The Petitioner seeks the institution of a show cause proceeding pursuant to 10 CFR 2.202 to modify or revoke the operating license for the Rancho Seco facility. The institution of proceedings pursuant to 10 CFR 2.202 is appropriate only where substantial health and safety issues have been raised.
See Consolidated Edison Company of New York (Indian Point, Units 1, 2, and 3),
CLI-75-8,2NRC173,175(1976), andWashingtonPublicPowerSystem(WPPS
4 Nuclear Project No. 2), DD-84-7, 19 NRC 899, 923 (1984). This is the standard that I have applied to the concerns raised by the Petitioner in this decision to detennine whether enforcement action is warranted.
For the reasons discussed above, I conclude that no substantial health and safety issues have been raised by the Petitioner. Accordingly, the Petitioner's request for action pursuant to 10 CFR 2.206 is denied. As provided in 10 CFR 2.206(c), a copy pf this Decision will be filed with the Secretary of the Comission for its review.
FOR THE NUCLEAR REGULATORY COMMISSION h
Thomas E. Murley, Director Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this18thday of liarch 1988
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D0-88-4 NUCLEAR REGULATORY COMMISSION SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SEC0 NUCLEAR GENERATING STATION Docket No. 50-312 ISSUANCE OF DIRECTOR'S DECISION UNDER 10 CFR 2.206 Notice is hereby given that the Director, Office of Nuclear Reactor Regulation, has issued a Director's Decision concerning a Petition dated February 25, *.987, filed by Ms. Barbara Moller of Sacramento, California. The Petitioner asked the NRC to order the licensee of the Rancho Seco Nuclear Power Plant to show cause why the plant should not be prevented from restarting until a complete check of all cables is undertaken or in the alternative, why the plant should not be completely shut down. The two bases given by Ms. Moller for the Petition are (1) the "official investigation" concerning falsification of cable tray data and (2) the "problem-laden history" of the facility.
On April 27, 1987, theDirector,OfficeofNuclearReactorRegulation(NRR),
i acknowledged receipt of the Petition. He infonned Ms. Moller that the Petition would be treated under 10 CFR 2.206 of the Commission's regulations and that appropriate action would be taken in a reasonable time. In a letter dated September 13, 1987, the Director gave Ms. Moller the status of the ongoing efforts by the licensee and NRC staff to resolve the cable concerns, and he reiterated the NRC staff's position that Rancho Seco would not be pemitted to restart until the safety concerns associeted with the plant cables were resolved.
The Director has now determined that the Petitioner's request should be denied for the reasons set forth in the "Director's Decision Pursuant to 10 CFR 2.206" (DD 4 ), which is available for inspection and copying in the Comission's Public Document Room,1717 H Street NW, Washington D.C. 20555 N, .
- 000 M,O .<'.Yo W.
2 and at the Local Public Document Room for the Rancho Seca Nuclear Generating Station located at the Sacramento City-County Library, 828 I Street, Sacramento, California 95814 A copy of the Decision will be filed with the Secretary of the Commission for its review in accordance with 10 CFR 2.206(c). As provided in 10 CFR 2.206(c),
the Decision will become the final action of the Commission twenty-five (25) days after issuance unless the Commission, on its own motion institutes review of the Decision within that tice.
FOR THE NUCLEAR REGULATORY COMMISSION N
Thomas E. Murley, Director l Office of Nuclear Reactor Regulation Dated at Rockville, Maryland, this18th day of March 1988 l
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BARBA'RA MLLLER P.O. BOX 163306 SACRAMENTO, CA 95816 (916) 457-3340 February 25, 1987 U.S. NUCLEAR REGULATORY COMMISSION Region 5 1415 Maria Lane Suite 210 Walnut Creek, CA 94596-5368
Dear Commission,
This petition, 10 CFR part 2.206 is incended to show cause why the problem laden Rancho Seco Nuclear Power Plant in Sacramento, CA should not be restarted until a complete check of all cables is undertaken, or the Nuclear Power Plant completely: shutdown.
The official investigation concerning the falsification of cable tray data combined with the problem laden history of Rancho Seco' support the intent of this petition. Three forged signatures found at each level in the quality control hiearchy, on each of at least seven pull cards indicate a failure in the three step process of procedural check. This process was established to eliminate error and to insure safety. This reinforces the need for a complete walk-down of the entire cable system.
Because the data cards are designed with a three step procedural check, the results of the Commission's investigation indicate no O cross checking was done. The resul unte the culpability of an integral,tspart of this investigation of SMUD ' accent-management, failure of overall review, a key point in effective management, the t
- We are dealing with NUCLEAR ENERGY. Up to this point it is SMUD'S l
responsibility to ensure these key procedures are followed. Pres-
) ently, at this point, the NRC is the objective body, has the resp-onsibility, and is charged with ensuring that SHUD fulfills its l, role and commitment of providing a SAFE plant. .
l The results of this investigation exhibit how work is submitted without ever being checked, and failure of backup system checking.
It is irrational to say ' sampling' is an effecient method when there is definite falsification of key data relating to power cable em electro magnetic field data which could induce a stray signal to the control panel, thereby initiating a signal to open or close key valves which in all probability would cause a catastrophic disaster.
REMEMBER: We are dealing with a proven faulty Nuclear Power Plant and the lives of at least 500,000 people in the immediate vicinity prime agricultural land used to feed the country plus many par,ts of the world, and a major area of U.S. defense, Mather and McClellan l Air Force Bases are involved.
Contamination would continue to spread through the water supply which flows south and helps to supply the city.of Los Angeles and the
( Orange County area. The Northern Sacramento Valley which is a number one agricultural area would also be affected, by the prevailing winds carrying radiation up through the Sacramento Valley and Nortkast through the Sierras and other states. I will remind the Commission n ,, , ...n fJ l " pyofp0 / T 5 _ (T- .
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.. Re.neto'Soco cont
,,rge a 2 of the recent Chernobyl disaster and the global effects radiation took and will continue to exhibit for at least a minimum of one hundred to one.thousand years.
I know for a fact that approximately 2000 cables have been added since 1974, It has been reported to me that 80 out of 163 cables have been sampled, and only 215 are going to be sampled. Management is an essential aspect of safety, and the results of the latest investigation by the NRC demonstrates a deficient and insufficient method of review and overall management.
Among the countless weaknesses which have been noted at Rancho Seco other than the overcooling event which brought the plant to its present standstill were "significant design control deficiencies"
$n safety-related pipe supplies. It is illogical to say a nuclear power plant with the exceedingly high number of reportable events whidh"plague Rancho Seco is indeed safe.
In view of the continual uncertainty of Rancho Seco's history has presented and particularly emphasizing recent falsification of cable data facts, PLEASE, mandate the Sacramento Municipal Utility District's Rancho Seco Nuclear Power Plant do a complete walkdown of ALL cables.
If the Commission intends to allow Rancho Nuclear Power Plant to restart, PLEASE provide a detailed written response to the concerns raised in this letter.
O4' Thank you so much.
Yours truly,
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- Barbara Holler cc: Honorable Congressman Robert Matsui Honorable Senator Allen Cranston l
Michael Remy, Environmental A tty., Sacramento for Safe Energy Union of Concerned Scientists Nuclear Information and Resource Service O
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The Honorable Alan Cranston United States Senate Washington, D.C. 20510
Dear Senator Cranston:
This is in response to your letter of April 1,1987, forwarding a petition by Ms. Barbara Holler that requested that the Rancho Seco Nuclear Generating Station "not be restarted until a complete check of all cables'is undertaken."
In my letter to you~ iated April 24, 1987, I stated that the )(uclear Regulatory Comission (NRC) would respond to Ms. Moller's request once'the various NRC staff and licensee efforts that were in progress had been/ completed. I also indicated that the NRC would not authorize restarc of Rancho Seco until the cable routing discrepancies were resolved.
The NRC Office of Nuclear Reactor Regulation has no completed its safety review of cable discrepancies. For the reasons set' forth in the enclosed Director's Decision under 10 CFR 2.206, Ms. Molle'r's request has been denied.
A letter has been forwarded to Ms. Moller informing her of the denial. A copy of the Director's Decision and the Federal Register Notice regarding the Director's Decision are enclosed with that etter.
In accordance with 10 CFR 2.206(b), a copy of the Decision will be filed with the Office of the Secretary of the Commission for its review. The Decision will constitute final action of the Conwiission 25 days after the date of issuance unless the Comissicn, on its/own motion, institutes a review of the Decision within that time.
For your information, I am enclosin'g with this letter a copy of the Notice regarding this Decision that was, filed with the Office of the Federal Re01 star for publication. As requested in your letter of April 1, 1987, I am also enclosing a copy of the letter from Ms. Moller that was attached to your letter.
Sincerely,
/
/ Victor Stello, Jr.
/ Executive Director
/ for Operations
Enclosures:
- 1. Director's/ Decision
- 2. Federal Register Notice 'v
- 3. Letter from B. Holler to NRC dated' Februa ry 25, 1987
- See prevfous concurrence
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, The Honorable Alan Cranston United States Senate Washington, D.C. 20510
Dear Senator Cranston:
This is in response to your letter of April 1,1987, forwarding,a' petition by Ms. Barbara Holler that requested that the Rancho Seco NucleaVGenerating Station "not be restarted until a complete check of all cab,Ms is undertaken."
In my letter to you dated April 24, 1987, I stated that 3he Nuclear Regulatory Comission (NRC) would respond to Ms. Holler's request,once the various NRC staff and licensee efforts that were in progress had,been completed. I also indicated that the NRC would not authorize restart7ef Rancho Seco until the cable routing discrepancies were resolved. /
/
The NRC Office of Nuclear Reactor Regulation)tas now completed its safety review of cable discrepancies. For the reasons set forth in the enclosed Director's Decision under 10 CFR 2.206, Ms. Moller's request has been denied.
A letter has been fonvarded to Ms. Mollef informing her of the denial. A copy of the Director's Decision and the Fedsral Register Notice regarding the Director's Decision are enclosed with that letter.
/
Inaccordancewith10CFR2.206(tI),acopyoftheDecisionwillbereferredto the Office of the Secretary of/the Comission for its review.
For your information, I anfenclosing with this letter a copy of the Notice regarding this Decision,that was filed with the Office of the Federal Register for publication. As requested in your letter of April 1,1987, I am also enclosing a copy of h'e letter from Ms. Moller that was attached to your letter.
Sincerely, Victor Stello, Jr.
Executive Director for Operations Enclop res:
- 1. Director's Decision
- 2. Federal Register Notice 3 LetteTfrom B. Moller to NRC dated February 25, 1987 A
/**See previous concurrence
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s i
Docket flo. 50-312
/
The Honorable Alan Cranston linited States Senate
..ashington, D.C. 20510
Dear Senator Cranston:
This is in response to your letter of April 1,1987, forwarding a ition by Ms. Barbara Moller that requested that the Rancho Seco Nuclear Ggnerating Station "not be restarted until a complete check of all cables it undertaken."
In my letter to 24, 1987, I stated that the Nudlear Reculatory Commission'(NRC)you dated Aprilwould respond to Ms. Moller's request once the vario staff and licensee efforts that were in progress had been,c,ompleted. I also indicated that the NRC would not authorize restart of R ncho Seco until the cable routing discrepancies were reso'ved.
The NRC Office of Nuclear Reactor Regulation has completed its safety review of cable di;crepancies. For the reascns yet forth in the enclosed Director's Decision under 10 CFR 2.206, Ms. Mo)1er's request has been denied.
A letter has been forwarded to Ms. Moller inforniing her of the denial. A copy of the Director's Decision and the Federal, Register Notice regarding the Director's Decision are enclosed with that letter.
In accordance with 10 CFR 2.206(b), a f py of the Decision will be referred to the Office of the Secretary of the C urnission for its review.
f For your infomation, I am enclos ng with this letter a copy of the Notice regarding this Decision that was filed with the Office of the Federal Register for publication. As requested .- n your letter of April 1,1987, I am also enclosing a copy of the lette 'from Ms. Moller that was attached to your letter.
Sincerely, l
l Victor Stello, Jr.
Executive Director j for Operations
/
l inclosures:
- 1. Director's . cision
- 2. Federal Register Notice
- 3. Letter from B. Moller to NRC dated F4bruary 25, 1987 I
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Letter to A. Cranston 2.206 Director's Decision - Rancho Seco ISTRIBUTION
/ Docket File w/ incoming ltr. only Docket No. 50-312 NRC POR Local PDR ED0 #002732 EDO Reading T. Murley/J. Sniezek F. Miraglia D. Crutchfield G. Holahan G. Knighton J. Lee G. Kalman GPA/PA D. Mossburg, PMAS (ED0#002732)
PDf5 Reading D. Hagan V. Stello Bill Clements, SECY, H-1149 (E)
OGC J. Lieberman, 000 ASLAB ASLBP ACRS(10)
J. Resner (2) (K-501) l l
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