ML20148L985

Responds to Recipient Expressing Concerns Re Implementation of B&W Owners Group Recommendations at Plant. NRC Has Not Found Any New Info in Ltr Which Could Alter NRR Recommendation to Commission That Plant Ready for Operation

ML20148L985
Person / Time
Site:	Rancho Seco
Issue date:	03/29/1988
From:	Murley T Office of Nuclear Reactor Regulation
To:	Pollard R UNION OF CONCERNED SCIENTISTS
Shared Package
ML20148L989	List: ML20148L985 ML20148M008
References
NUDOCS 8804050083
Download: ML20148L985 (8)

Text

UNITED STATES i $, NUCLEAR REGULATORY COMMISSION j j WASHINGTON, D. C, 20555

\,+...+/ gag 1 0 1988 Mr. Robert D. Pollard Union of Concerned Scientists 1616 P Street, NW Washington, DC 20036

Dear Mr. Pollard:

We have reviewed the concerns expressed in your March 17, 1988 letter to the NRC Comissioners regarding the implementation of the Babcock and Wilcox Owners Group (B&WOG) recommerdations at the Rancho.-Seco Nuclear Generating Station. The recomendations were developed as part of the B&WOG Safety and Performance Ir.provement Program (SPIP). The NRC staff is evaluating both the B&WOG Program and the implementation of the Program recommendations by the utilities. The implementation of the recomendations at Rancho Seco has received particular attention as part of the plant restart evaluation by the NRC staff. The con-clusions reached by the staff, as they relate to the Rancho Seco restart evalu-ation, are included in Section 4.10.2 of the restart safety evaluation report, NUREG-1286, Supplement 1. An additional, more detailed discussion of these issues will be included in a forthcoming inspection report from the NRC regional office.

The SPIP was developed to accomplish two objectives: (1) reduce the number of inadvertent reactor trips, and (2) reduce the complexity of post-trip transients.

Clearly, the SPIP objectives have inherent safety implications. However, the SPIP recoimendations, both the total number and the "key recomendations" were developed to improve the operation of Babce-k and Wilcox reactors. There was never an intent by the B&WOG nor the NRC to use the recomendations as criteria to detemine whether or not a nuclear station should operate.

The restart program at Rancho Seco included a review process to evaluate whether perfomance improvement recomendations which were received from various sources had sufficient safety merit to: (1)beimplemented implemented in the long tem (post restart), or (3) be prior to restart,Tne disregarded. (2)NRC be staff evaluated the SMUD review process and observed the process at work.

Both phases of this evaluation by the staff were completed with the conclusion that the SMUD evaluations and dis recomendations were acceptableNUREG-1286, (position of the perforrance Supplement improvement 1 Section 2.3).

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R. Pollar! Your letter states that, based on a January 5,1988 B&WOG report, only two of 203 SP1P recomend6tions were implemented at Rancho Seco. The SPIP is an ongoing process and since the data quoted by you was compiled, both the number of SPIP recomandations and the status of implementation at Rancho Seco has changed.

According , January 1988, Recomendation Tracking System Report from the B&WOG f report stuus tables included as Enclosure 1), there were 215 recomendations, bued on information provided to the Comission by the Sacramento Municipal Utility District (SMUD) during a public meeting on March 22, 1988, 169 of the 210 recomendations were determined to be applicable to Rancho Seco and 71 of these have been implemented by SMUD (sMUD implementation status slide included as Enclosure 2).

All 215 SPIP recomendations were entered into the SMUD performance improvement rcconvendation disposition review process and processed accordingly. The NRC staff reviewed the disposition of each SPIP recomendation which was not included in the SMUD list to implement prior to restart. The staff concurred with SMUD on the l appropriateness of the conclusion for each of these recomendations. Additionally, {

following the receipt of your March 17, 1988 letter, the NRC Region V Administrator '

personal'.y reviewed the rationale used for each of these issues. The Regional Administrator also agreed that SMUD's disposition of the SPIP reconnendations was appropriate. Onsite NRC inspect'ons audited the actual implementation of the SPIP recomendations et Rancho Seco. No discrepancies were identified in the SPIP related issues, l l

Your letter identified specific examples of B&WOG recomendations which you I felt were safety significant but which apparently were not being implemented by l SMUD prior to restart. The staff reevaluated these issues following receipt of your letter. Our conclusions following this reevaluation are sumarized belcw.

Comunication Problems: The comunication problems between the  ;

cor. trol room and other parts of the plant have been evaluated by the staff. The staff bas concluded that existing deficiencies in this area are not significant and should not adversely impact safe plant operationt.

Inverter Overcurrent Protection: SMUD has implemented this B&WOG recomenda tion.

Instrumentation Power Supplies: Extensive modifications have been completed on the Rancho seco KS and NNI systems and their power l supplies. Althouch additional modifications may be incorporated in the future, the systems and their associated cower supplies have been evaluated in detail by the sta'f and found to be acceptable to  !

i s"pport plant operat%. The staff evaluation Of these systems is included in Section *. .2 of NUREG-1286 Supplement 1.

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R. Pollard l l

Motor-0perated Valves: SMUD has completed refurbishment of l motor-operated valves and the staff has verified that this work was

! completed.

Compreesed Air Systems: Compressed air system deficiencies were l Identified by SMUD during the course of the performance improvement l evalustions. Modifications, which included the addition of a dieel l driven air compressor and backup air bottles for critical air operated components, were made to correct the identified deficiencies. The staff concluded that the modified air systems are acceptable. The staff evaluation of the compressed air systems is included in Section 3.1.2.4 of NUREG-1286, Supplement 1.

The criteria used by SMUD (as reviewed and approved by the NRC staff) for deter-mining which recorrrrendations need to be completed prior to restert, were not limited to deficiencies attributable directly to the December 1985 overcooling transient. The goal of the program was to identify problems, beginning with the plant design bases through managen.ent and operations, which if corrected, would improve Rancho Seco overall performai.ce (NUREG-1286 Section 1). The B&WOG SPIP recce endations were an integral part of the evaluation but the Owners Group recomendations were not, in themselves, intended to be restart criteria.

In conclusion, your concerns for safe operations at Rancho Seco, as ex 3ressed in the letter dated March 17, 1988 were considered as part of the Rancio Seco performance irprovement program as described in NUREG-1286. We have not found any new information in your letter which would alter the staff's recomendation to the Commission that Rancho Seco is ready to resume operations.

Sincerely, originni nicned by]

Thown c . 'sY Thomas E. Murley, Director Office of Nuclear Reactor Regulatien DISTRIBUTION .

DDCKET FILE D. MOSSBURG (EDO #003587)w/eiecd- 5' NRr & LOCAL PDR PDV GT FILE W/ INCOMING EDL RDG. 3 587 D. CRUTCHFIELD T. MURLEY/JSNIEZEK G. HOLAHAN F. MIR/4 GLIA OGC/MURRAY G. KALMAN G. KNIGHTON F. GILT.ESFIE T. MARTIN, NRR J. MARTIN, RV -

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• PREVIOUSLY CONCURRED

• PDV:PM *PDV:PD

• TECH ED OGC* AD:DRSP35D* D:DRSP*

GKALMAN:mk GKNIGHTON RWEISSMAN GHOLAHAN CCRUTCHFIELD 03/25/85 03/25/88 21/25/88 3/25/88 03/25/88 03/25/88 IA M Y 34URj88 3 q88

i 1 E2JCIOSURE 1

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TABLE 7-6 IMPLEMENTATION STATUS SUfetARY TRIP REDUCTION RECOfGEENDATIONS Total Number in System - 215 Number Superseded / Deleted - 4 Total Number Valid - 211 Evaluating Evaluating for for closed closed Not Closed No Total Applicability Implementation Implementing Operable Applicable Rejected Hold Report Valid AFSL 68 60 11 32 32 0 0 8 211 DPCO

• 12 37 40 48 55 11 0 3 211 FPC 61 39 22 41 36 4 0 3 211 GPUN 50 30 35 64 20 1 0 8 211 SMUD 0 88 16 44 54 1 0 8 211 TVA. 111 23 23 12 29 1 4 8 211 TED 76 7 23 53 43 1 0 8 211 i

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2 ENCIOSURE 1 TABLE 7-7 IMPLE3ENTATION STATUS SUfetARY KEY TRIP REDUCTION REC 000ENDATIOPS

- Total Number in System - 74 .

Number Superseded / Deleted - 4 Total Number Valid - 70 Evaluating Evaluating for for closed closed Not closed No total Applicability Implementation Implementing Operable Applicable Rejected Mold Report Valid AP&L 3 40 8 18 1 0 0 0 70 DPCO 1 16- 21 23 3 1 0 0 70 FPC 10 19 17 18 5 1 0 0 70 GPUN 7 12 23 24 4 0 0 0 70 i .

SMUD .0 30 10 24 6 0 0 0 70 TVA 32 5 -

11 7 11 1 3 0 70 TED 24 1 16 24 5 0 0 0 70 l

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ENCIOSURE 2 C 3-

! SAFETY AND PERFORMANCE IMPROVEMENT PROGRAM (SPIP) SUMM^RY a 215 ITEMS ISSUED BY B&WOG FOR CONSIDERATION I -

74 KEY ITEMS; 1 41 NON-KEY ITEMS m 169 ITEMS APPLICABLE TO RANCHO SECO

-66 KEY ITEMS; 103 NON-KEY ITEMS

a 71 ITEMS ALREADY IMPLEMENTED BY RANCHO SECO

! -36 KEY ITEMS; 35 NON-KEY ITEMS l 5 29 ITEMS PARTIALLY COMPLEE l -19 KEY ITEMS; 10 NON-KEY lTEMS 4

m 69 ITEMS ARE BEING FURTHER EVALUATED FOR IMPLEMENTATION Ar- it.M RESTART

-11 KEY ITEMS; 58 NON-KEY ITEMS i

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ACTION EDO PRINCIPAL CORRESPONDENCE CONTROL FROM: DUE: EDO CONTROLS' 003587

' DOC DT: 03/17/88 i ROBERT D. POLLARD FINAL REPLY:

UNION OF CONCERNED SCIENTISTS TO:

COMMISSIONERS FOR SIGNATURE OF: ** GREEN ** SECY NO:

DESC: ROUTING:

URGES THE COMMISSION NOT TO PERMIT RANCHO SECO JMARTIN TO RESUME OPERATION UNTIL ALL SAFETY CHANGES MURRAY RECOMMENDED BY THE BWOG HAVE BEEN MADE DATE: 03/22/88 ASSIGNED TO: NRh CONTACT: MURLEY 1

)

SPECIAL INSTRUCTIONS OR REMARl;S:

FOR APPROPRIATE ACTION i

l NRR RECEIVED: MARCH 23, 1988 ACTION: DRSP:CRUTCHFIELD NRR ROUTING: MURLEY/SNIEZEK MIRAGLIA MARTIN GILLESPIE fDSSBURG l

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OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER: CRC-88-0238 LOGGING DATE: Mar 19 88 ACTION OFFICE: EDO AUTHOR: R.D. Pollard AFFILIATION:

UCS (UNION OF CONCERNED SCIENTISTS) .

LETTER DATE: Har 17 88 FILE CODE: ID&R-5 Rancho Seco

SUBJECT:

Opposes the operation of the Rancho Seco plant without a demonstrable basis for finding that it can safely operate ACTION: Appropriate DISTRIBUTION: RF, Docket, Cmrs, Secy, OGC i SPECIAL HANDLING: None NOTES:

DATE DUE:

SIGNATURE: . DATE SIGNED: -

AFFILIATION:'  !

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i Rec'd Olf. E00 Date - _1 - @ W l Time - A9  ;

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