ML20196B502
| ML20196B502 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 05/20/1988 |
| From: | Cranston A SENATE |
| To: | NRC |
| Shared Package | |
| ML20196B484 | List: |
| References | |
| NUDOCS 8806300284 | |
| Download: ML20196B502 (8) | |
Text
ALAN CRANSTON
'uwmu Enited States Etnate WASHINGTON. DC 20510 May 20, 2988 Congressional Liaison To:
Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C.
20555 Ms. Barbara Moller Enclosure From:
Post Office Box 163306 Sacramento, California 95816 Please comment on Barbara Moller's letter regdrding Re: radioactive water releases from Rancho Seco Nuclear Power plant.
I forward the attached for your consideration.
l Your report, in duplicate, along with the return of the enclosure will be appreciated.
incerely Al n Cranston l
Please address envelope to:
l Senatc.r Alan Cranston Senate Office Building Washington, D.C. 20510 t
1 Att:
Jim Kohlenberger, 202/224-3553 I
l l
8806300284 880620 P D,7 ADOCK 05000312 H
PDH l
May 16, 1988 SENATOR ALAN CRANSTON HART SENATE OFFICE BUILDING ROOM 112 WASHINGTOH, D.C.
20510-0501
Dear Senator Cranston,
It is imperative that you take direct action on this now.
Please don't wait.
Thank you no much for your timely request that the NRC respond to the 10 CFR 2.206 notition concerning the 1) cable problen and 2) the ' problem laden' history of the Rancho Seco facility.
Your encouragement prompted review of the 14 year history of the plant, of wh4.ch, their files should be just stuffed.
In a separate package are the two books which cover the safety evaluation given by the NRC.
The current situation is critical.
The discretion displayed by the Sacramento Municipal Utility District, SMUD, Board and by the NRC magnify the criticality anc lack of discretionary fore-thought.
In their 18-page letter, related to the Rancho Seco 12/26/85 event, the DRC discusses areas of concern.
In the conclusion, which was been marked, the NRC states that the Rancho Seco facility does not present any health or safety hazard.
Based on this, they are allowing the Sacramento Mun-icipal Utility District to restart the Ranch.
This is dated March 18, 1988.
In April 1988, articles enclosed, you will note that an additional 1000 gallons of radioactive water was released.
SMUD defends that this release doesn't count because it was contained.
Whether it was contained or not is not the issue.
SMUD was just plain LUCKY.
The issue is that radioactive water was aaain released.
A Sacramento Bee article dated 4-14-84, recognizes the importance of radioactive water releases.
They identify over 2 billion gallons having been released from Rancho Seco.
The official federal limits, the NRC limits, and the limits set by SMUD are all different.
NO CONSISTENCY.
The Sacramento Municipal Utility District took it upon themselves to re-adjust the calibrations to account for the increased radioactive releases.
Essentially, SMUD is discharging radio-active waste, a TOXIC substance.
There are no vaste disposal sites within a feasible distance.
The radioactive waste stays onsite.
The concentration of radioactive vaste accumulates.
One of.the radioactive elements released in unstable quantities is CESIUM, It is scientific knowledge that no amount of Cesium should be considered safe to release.
In addition, nothing about the half life of these radioactive elements, or their accum-ulative ability is ever mentioned, leading one to believe SMUD and/or the NRC don't want the public to be concerned.
Senator, these releases go into the Consumnes which flows to the San Joaquin.
In a North-South direction the width is roughly 150-miles, with a net use in 1980 of 6,340,000 acre feet of water.
The San Joaquin flows into Suisun Bay which supplies the rich agricultural land of the Delta.
In a 12/83 California Water Plan, the projected use and avail-able water supplies to the year 2010 indicates a problem in the San Joaquin Valley.
The net water use by population is five (5) percent, with the rest going for agricultural purposes.
There is a four (4) percent increase in use projected by 1990.
Essentially we are taking more water out than putting in.
There is an overdraft which is a six (6) percent decrease in the vater table.
This water is used to produce the food both you l
and I eat.
I interpret this information along with what is known concerning radioactive releases of elements such as cesium to indicate increased concentration of radioactivity.
These radioactive elements have at the least a 30 year half-life.
With this increase going to agriculture, the NRC and SMUD are poisoning our food.
Agriculture is a necessity to life.
l In April 1988, articles enclosed, you will note that an additional l
1000 gallons of radioactive water was released.
Smud defends that this release doesn't count because it was contained.
Whether it was contained or not, radioactive water was released AGAIN.
Smud was just plain lucky.
l l
The Smud board has spent more than $400 million dollars thus far in their restart efforts.
Restart has been scheduled and then un-scheduled due to additional "problems" just discovered.
They hope to run the Ranch at 63 percent capacity.
If in fact it had restarted on any one of these ' schedules' the worst case scenario very possibly would have occurred.
Considering all the past problems and the problems they are continuing to disclose, including the.most current relating to pipe wall thickness, the Rancho Seco Nuclear Generating Station does indeed pose a very real health and safety problem.
Copies of other significant factors are included to show that YES indeed there are health and safety issues still unanswered at the Rancho Seco facility.
.M
Senator, an initiative will appear on the June 7th ballot, to allow the voters, ratepayers, to decide if they want the problem laden Rancho Seco facility to generate or attempt to generate electricity.
Until then, I feel it imperative that the Sacramento Municipal Utility District spend no more ratepayers money at attempts to restart. SMUD has already spent over $400 million dollars in their attempt.
TOO MUCH.
Yours truly, Barbara Holler k' 0 - bW /Co 33 c(,a fQ
%ws en 96/p cc Hike Remy, attorney for SAFE Congressman Robert Matsui SMUD Board SAFE State Assemblyman Lloyd Connelly State Senator David Roberti Nuclear Regulatory Commit:sion, Thomas Murley, Director l
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DD-88-4 NUCLEAR REGULATORY COMMISSION SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SECO 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, 1987, 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, the Director, Office of Nuclear Reactor Regulation (NRR),
acknowledged receipt of the Petition.
He infomed Ms. Holler that the Petition would be trected under 10 CFR 2.206 of the Comission's regulations and that appropriate action would be taken in a reasonable time.
In a letter dated 1
j.
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 associated 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 e
CFR 2.206" (DD 4), which is available for inspection and copyingAn'the Comission's Public Document Room,1717 H Street NW', Washington D.C. 20555 4MMMffw t
4 and at the Local Public Document Room for the Rancho Seco 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 Comissi n foritsreviewinaccordancewith10CFR2.206(c). Asprovidedin10CFR2.206(c),
the Decision will become the final action of the Commission twenty-five (25) days 4
after issuance unless tiie Comission on its own motion institutes review of the Decision within that time.
FOR,THE NUCLEAR REGULATORY COMMISSION Thomas E. Murley, Director Office of Nuclear Reactor Regulation Dated at Rockville, Maryland, l
this18th day of March 1988 f
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By Dan Bernstein minutes, was classifled as an "unuku-Bee Staff Writer al event"- the least severe of fqur emergency levels. Such a cleasifica-About 700 gallons of radioactive tion requires notification of_ federal steam spewed from a faulty valve in-officials, side the reactor buildtag at the Ran-Rancho Seco,15 miles soutbekst cho Seco nuclear plant late Tweeday, of Sacramento, has been shut doWn but authorities said Wednesday since December 1985 for extenspe there was no release to the environ-equipment repairs and worker re-meet.
training. The utility began beating i
' No worters were injured by the up the plant late last month an4 la 56S4egree steam or were overex. scheduled to begin nuclear opera-l posed to radiation during the spill, tions next week.
j according to Brad Thomas, spokes-Tuesday's incident, which began man for the plant that is owned and shortly before 11 p.m., occurred i
operated by the Sacramento Munici, whue plant workers were adjustin' a I
s pal Utility District..
valve on a water purificadon systpm
'nomas characterized the mishap connected to the primary coollag as minor and said it would not inter-system, which carries hea',ed water fere with the current schedule to re-from the nuclear vessel.
start the plant by tos end of the As the adjustments were being
- roonth, made, another tellef valve broke However. a spokesnan for the and began to release bot, radioact$ve federal Nuclear Regulatory Com-steam at a rate of about 100 gauens mission said he could not confirm per minute, according to officialsj that there would be no delay in re-The steam condensed before rein-starung the plant until the comple-Ing down on the reactor floor and Uon of a "root cause" analysis in the draining into the plant's liquid waiste next few days, bandling system, officials said. l
'You're going to get leaks and "This is not a big leak," said blow gaskets occasionally," said SMUD's Thomas. "Seven bundfed NRC spokesman Gregory Cook. "But gallons is not mucb."
you have to look at the maintenance The spill occurred nearly six history on the equipment and deter-weeks after another radioactive spill mine whether the valve was proper. dumped 1,100 gallons of redloact)ve ly adjusted."
water onto the reactor building The spill, which lasted for seven floor.
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j ut 700 gallans of slightly radiandive water spilled, water at Rancho Seco this year. On Feb. 7, workers Thomas said lannan' error prehably caused.the 6 pill.
.itained area at Fam-ha Seco, prosepting an internal inadvertently left a vahe open, causlag a 1,000-gallon spEl "It was probably a procedure or per-meaerror." O tigation a week before the melmar power plant was in the containment building.
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e started.
SMUD officials are investigating Tnewiay's heidant,.
But an NRC arricial said espalpenant'also may be to:
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The spill occurred Tuesday night when a relief valve' but do not expect to delay plans to yestart Fancha Seco ' _. Planr4in Seco section chief Lew Maler said it appears epened unexpectedly during a test, letting boding water next week Domas said.
. ' the relief valve faSed to pesform properly and a gasket di into the reactor containment building, said Brad During a meeting in Washington, D.C., with the ' hiew out, letting the 'weest spill as afaam, wh!ch con, 3omas, a spokesman for the Sacramento Municipal Nuclear Regulatory Commissloc top melaar otDelais dan==d into water and entiacend in Door draans.
Stility District which owns the plant 25 miles aranhenaf of from SMUD are expected to seex permf amian to restart the
. De spill enedanned ' gar 'about seven mtrndse until '
3scramento.
reactor Tuesday.
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operators cook!!aolate the valve and cut off the water.
No one was injured and none of the radianctive water If permission is granted, Thomas said the district will was released to the environment,"Ihamma said.
start the 913-megawatt plant late Tuesday or early
'/
e Messe see SPILL, A2 eeuru SPILL: Relief valve opened unexpectedlyinctssti e From At discuss safety concerns about Pancho Seco, past two years to maka the pland safer and dore Miller said the NRC is investigating "to see Bob Mulhollamt the organit.ation's pohtical reliable.
that all the causes of the leak are known "
director, said be wants to ask for a delay in the' Utility directors hope to havt.the plant produc~
c The spill prompted SMUD to declare an restart decision until commisslaners receive a ing power by June, when two ballot measures on "unusual event" at Rancho Seco. An unusual report frorn their safety committee.
Fancha Seco's future are acha&ded event is an incident at a nuclear plant; that That committee is investigating the compet-requires notification of emergency responsg offl. ence of Rancho Seco's managers but is not.
- 0uld C308e !!ae plant. De.
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cials, but is not considered an emerRency.
g expected to report to the commisshxa until April.
2UD operate the plant for to another development Wednesday, the poup For two year, operational and mechanical C
g Campaign Cahfornia requested permission to problems have shut Rancho Seco.
Voter approval would then h needed before.
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address the NRC at its Tuesday meeting to
. SMUD has spent more than 8400 million in the the plant could be refueled, a
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DD-88-4 NUCLEAR REGULATORY COMMISSION SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SECO 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, 1987, 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 shculd 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, the Director, Office cf Nuclear Reactor Regulation (NRR),
acknowledged receipt of the Petition.
He infomed Ms. Holler that the Petition I
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 associated with the plant cables were resolved.
l The Director has new detemined that the Petitioner's request should be denied for the reasors set forth in the "Director's Decision Pursuant to 10 CFR 2.206" (00 4 ), which is available for inspection and copying in the l
Com.ission's Fehlic Document Room,1717 H Street Mi, L'ashington D.C. 20555 l
sqg2MM-O I i[
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and at the Local Public Document Room for the Rancho Seco Nuclear Generating Station located at the Sacramento City-County Library, 828 I Street, Sacramento, California 95814.
l A copy of the Decision will be filed with the Secretary of the Comission 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 Comission twenty-five (25) days after issuance unless the Commission on its own motion institutes review of the Decision within that time.
FOR THE NUCl. EAR REGULATORY COMMISSION Thomas E. Murley, Director Office of Nuclear Reactor Regulation Dated at Rockville, Maryland, this18th day of March 1988 l
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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 (RanchoSecoNuclear Generating Station)
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DIRECTOR'S DECISION UNDER 10 CFR 2.206 INTRODUCTION On February 25, 1987, Ms. Barbara Moller submitted a Petition in accordance with 10 CFR 2.206. The Petition was referred to the Director, Office of Nuclear Reactor Regulation (NRR) for consideration.
The Petition asked the U. 5. Nuclear Regulatory Commission (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. Holler gave as the bases for the Petition (1) the "official investigation" concerning falsification of cable tray data and (2) the l
l In the Petition, Ms.
"problem-laden" history of the Rancho Seco facility.
Moller asserted that three forged signatures had been found at each level in l
the cuality centrol 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 rethod for checking cable work. Ms. Moller further asserted that 20C0 cables had been added to the plant since 1974, and she expressed 4;flC]:CDcAl1:f f' t
l
. concern regarding information that had indicated to her that a sample of only 215 cables was going to be checked.
On April 1,1987, the Commission'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.
The letter stated that a response to Ms. Moller would be made following the con.pletion of evaluations being performed by the licensee and the staff and that the NRC would not aJthorize restart of Rancho Seco until the cable routing discrepancies were resolved.
Cn April 27, 1987, Dr. Thomas E. Murley, Director, NRC Office of Nuclear Reactor Regulation (NRR), acknowledged receipt of the Petition.
He informed Ms. Foller 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.
hotice of receipt of the Petition was published in the Federal Reaister 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 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 permitted to restart until the safety concerns asscciated with the plant cebles were resolved.
. 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 1905, 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, implementation of requirements imposed on licensees after the accident at Three Mile Islard, implementation of rrodifications 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 equiprent.
In this period, approximately 7800 cables were either installed er 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 computeri:ed cable race.<ay and tracking system (CRTS) might be inaccurate.
Subsequent investigaticn by the licensee and review by the URC 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 licersee I
. integrated this inspection activity and reviews of other cable-related problemt 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 I following the event of December 26, 1985," and Supplement I to that report (NUREG-1286 and NUREC-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 belcw.
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 In the card as it shculo have been, according to established plant procedures.
l first case, which involved 14 cables serving equipment for remote plant shutdown, the cable installer's name was printed on the cards.
In the second case, which involved the inter'.11xing of 11 power ano control cables with instrumentation
. mentation cable trays, the field er.gineer's signature was in cables in ins The l
the signature block reserved for the signature of the c6ble installer.
safety implications of these cable discrepancies are discussed below.
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To understand the safety implications associated with the cable discrep-ancies and to detennine the appropriate corrective acticns, it was necessary for the licensee to understand the nature of the deficiencies in field engi-neering and quality control.
The licensee has deter.11ned the nature and extent of the cable discrepancies with formal programs for investigation of identified cable discrepancies and inspection of installed cable. The NRC staff has reviewed the licensee's programs 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 toreroutethecableswassimplynotdoneandthecablesremairedi[1anunaccept-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 Centrol Group (CCG) clerk were l
using an informal precedure developed by an engineering aide in the CCG.
It also appears that when the card centrol discrepancy was cetected, proper l
follow-up action was not taken. The NFC Office of Investigatiens is currently investigating whether or not wrongdoirs 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 Appendix A of NRC Inspection Report 50-312/07-21, 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.
3e11IntermixedCables The second instance involved 11 power and control cables that were to have been removed from seme of their original trays and rerouted so that the trays could be redesignated and used to house new instrumentation cable. This work was to have been done as part of a major modification in 1983 that involved the relccation and installaticn of a large amount of cable over a relatively shcrt time period. As in the first instance, the cable pull cards had been signed off indicating the work necesrary to complete the rercuting cf the 11 cables was done; but the work had not been done.
Thus, wh rumentation cables were pulled into the redesignated cable trays, intermixing of safety-related power /centrol and instrumentation cables occurred, which constituted a violation of design criterifr.
m
. The licensee's investigation also identifiad proceduraLviolations on the part of the field engineers and_QC_Jnspectors. The_ procedural v.iolations
[ included the signing of cable pull cards by the field engineer instead of by the craft foreman responsible for act_ually performing 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 of 10 CFR Part 50, Appendix B, Criterion X, for failing to conduct proper inspection of cable routing. The licens.a's corrective acticns in response to this violation _are discusse below.
Safety Implications and Corrective Actions Following the completion of the investigation of the 14 remote shutdown cable N
~.
discrepancies and the discovery of the 11 internixed cables, it became apparent to both the licensee and the NRC staff that the faulty practices, ocedures and controls that had al' owed cable routing problems to_ occur and go undetected could very well have affected other safety-related cables.
In a July 2, 1987
~
e letter from G. C. Andognini, SMUD, to Frank J. Miraglia, NRC, the licensee cornr.itted' to expanding the ongoing inspection of safety-related and safe shutdown cable to include all such cables in the pcpulation that had been rerouted since the beginning of comrrercial 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 cther work control errors were identified.
The results of the inspecticns 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 been based on the results and reconnendations derived from the licentee'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 reouires 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 formalized 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 grot.ps.
2.
Existing cable installation procedures (MP/IS 307) have been revised so that cable route inspection is specified as a "hold point" in the procedure. QC inspectors are new required to witness cable pulls so that routing can be properly verified.
Electrical QC inspectors have been trained regardinc 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 forms input to the CRTS. Changes to these documents resulting from route revisions will be treated as Drawing Change Notices (DCN). New installation documents will not be generated for i
repulls. The intent of this change is to ensure that field instructions for implementing route revisions are clear.
In addition to the specific changes described above, the licensee has made broad changes in the Rancho Seco quality assurance (OA) progran.
These changes were presented to the NRC staff in a meeting held Septerrber 23, 1987.
The more significant changes include:
reorganization of the QA departrent with the r.ew Director of Nuclear Quality reportir.g directly to the Chief Executive Officer;
. )
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 performance in h'$V
~
p quality activities to ensure that the changes are effective, p[
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.OY f,
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/ y B.
Inspection of Cable Routes v
. g F
The licensee's corrective action regarding inspection of ca le routes has p'g,T%
been (1) a complete (100%) inspection of all safety-related and safe shutdown )[4ff/ gg cables that have involved route revisions between the start. of commercial
<4
_ operation and the initiatien of the inspection _pregram on_ December 22, 19E6 d475 cables) and (2) a random sample inspection of cables installed between t,he gg
._startof commercial operation _artd_the_ initiation of e inspection program
[-/hh
.that layetnever undergone route revisions (142 of 1559 cables). The 14,000 pp4 cables installed during the 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 surveillarce testing.
2.
The original architect engineer (Bechtel) ht.d in place ard used a rigorous cuality control program for the design, installation, and inspection of the original cable population and folicwed a uniforr'ly consistent set of rules and procedures.
t
. 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 4.8.2.2 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 populatic: 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 intter 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 newly installed cables that had never been rerouted. A total of 19 significant cabla 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 sartple inspection of construction work is to detennine with reasorable assurance that tne nurber and significance of deficiencies in construction and quality assurance have not degraded safety n'argins to an unacceptable level.
In the case of r,isrouted electric cables at Rancho Seco, the following criterie were used:
1.
There is 95% assurance that at least 95% of the cables are correctly routed (95/95).
.. 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 conclJded in Section 4.8 of NUEEG-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 Supplemert 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 staff has concluded that (1) the likelihood of installed safety-related ard safe shutdown cables being in a configuration that violetes 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) i report on the December 26, 1985 overcocling event at Rancho Seco, it became apparent to both tFe staff and the licensee that the design and programnatic deficiencies identified during the staff's investigation were symptomatic of 1
l more serious problers than those associated with the overcooling event and would require a corrective action program that embedied more than the narrcw F
t
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, focus of the overcooling event. /ccordingly, in the spring of 1986, the licensee embarked on a comprehensive Plant Performance and Management Improvement Program (PP8MIP) 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 review of historical documents and recommenda-tions; interviews with a cross-section of the plant staff (180 interviews);
a deterministic failure analysis for the effect of loss of electrical power, instrument air, and control power on plant operations; incorporation of relevant Babcock and Wilcox (BhW) Owners Group Safety and Performance Improvement Program (SPIP) recommendations; NUREG-1195, the Incident Investigation Team (IIT) report of the December 26th event; and other miscellaneous information.
The resolution of cach problen was prioritized by the licensee as a restart, near-term, or long-term iten.
The problems identified 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 recommendations 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 the 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 decurented in Section 2.3.2 of the NRC staff's "Safety Evaluation Report related to the Restart of Rancho Sece Nuclear Gercrating Statien, Unit I following the event of December 26, 1985," and Su 'lement I to that report (NUREG-1286anoNUREG-1286, Supplement 1).
'... E.
Design Control Deficiencies T,he Petitioner also referenced "significant design contro_l___d_eficiencies" in safety-related pipelupplies. Problems _wh.ich r_eflect deficiencies in design control were identified by the NRC staff during its Augmented System Review
~
and Test Program (ASRTP) inspection conducted at Rancho Seco in early 1987.
The56 problems are discussed in Inspection Report 50-312/86-41 and sumarized in Section 3.7.2.2 of NUREG-1286.
To address deficiencies in design control the licensee has developed and implementeditsEngineeringActionPlan(EAP).
The purposes of this plan are to improve the quality of work involving design reviews and design changes andtodocument,indetail,thedesignbasesforkeysafetysystems.]heNRC 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 l
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 Ranche 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 Censolidated Edison Cercany of New York (Indian Point Units 1, 2, and 3),
CL1-75-E, 2 NRC 173, 175 (1975), and Washington Public Power System (WPPS I
, Nuclear Project No. 2), 00-84-7, 19 NRC 899, 923 (1984). This is the standard that I have applied to the concerns raised by the Petitioner in this decision _
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 of this Decision will be filed with the SIcretary of the Comission for its review.
FOR THE NUCLEAR REGULATORY COMMISSION Thomas E. Murley, Director '
Office of Nuclear Reactor Regulation i
Dated at Rockville, Maryland this18thday of March 1988 i
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Editoriah so Metro a.
Trae Sacram mio See Fana2 Frday November 13.1987 =
- 1
.4 Area called ill-prepared for Seco disasted By Ken Pay on they told members of a state senate Tash County emergency response coordinator.
There was no discussion Thunday on Ihr op nuclear emergency planning around the a si.it wri.,,
Force on Cahforena Nudear Emergency Re-Other hospitats have agreed to take emer. value of nuclear energy nor whether the state.
sponse.
gency patients if po.isibie.she srs shui <1own Rancho Seco snould he restarted.
Some 13.000 people hve to the three coun.
la the Chernobyl traitedy. more than 500 An addasonal 140 pancats less seriously The task force was estabhshed by a 5 cease I'",*'I"'",
Seco a rp w
g' g
,y g" '
peopk were hospatalized wath rad 6ataca sxk. ensured - 100 of mem na Sacrarrwato Coun-resolution after the Chernobyl casaster. The medical ce*tlers sa sacramcato. Amador and
,it wouw he one to fi.e boon irom 6,
*at.
i san Joa0u.a couanu, ope,u m d Thun.
"s=mo're** P"P" d'd
'"5' a"r *'d at **5
- -"'d*'""'""***'"'"
group e=wr =et = San un on=po *
- 2 d ed of radiation injuries and burns howitats about every two hours.
cuss emergency readiness at the Diablo Can.
um an alnt wue puW w,m o, dar la the months after the April 26.1986, acc6 "Anyttamg beyond that and we'd need me-en nuclear plant and the Saa Onofre plaats 13.000 be evacuated. saad Robert Stubcacttd.
In slech a *worslirase sCesario and umai onm.ts my mat ba,c,." County tual and fr,om other countaes,.",said H,,opwood.
dent, accordaag to a report pubitsbed as Am.
near San Clemate-y..,c.
,os,
- u. ca 0,,e,r,c,, 0,nc,a,,om
,e.,ce a $uuo consunam 1he ome wouw
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pie critically til wIth radsation sukmess The Unaverssty Medscal Center and Sutter countaes. admaantrators and health otractals The task force satt asue a report sa Febra. saad. dependaag on the serir nem of the se couw be samen care of at any one time by Hospaal have contracts wiin the county to outnaed their pians for emergency response ary on. hat it s found out ano t couary and cadeat t** *eatner aad tr*ff'( (**d"***5,
I hospstals la the three coualses. Sacramento care for four cntically majured people per to Inw task force that is explortag statewnde city readiness to meci a encicar mishap ti s hospaals could handle 39 of those paheats. hour, sand Carote Hopwood, the Sacramento readiness for nuclest accidents,.
expected to recommend legastainen so beef See DISA5TER, page Ir2 2
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