ML20209B636

Forwards Request for Addl Info Re 860812 & 1017 Proposed Rev 1 to Amend 138 to License DPR-54 Concerning Organizational Revs & Changes to Responsibilities of Plant Review Committee.Description of NRC Concerns Re Changes Also Encl

ML20209B636
Person / Time
Site:	Rancho Seco
Issue date:	01/15/1987
From:	Stolz J Office of Nuclear Reactor Regulation
To:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
TAC-63084, NUDOCS 8702040088
Download: ML20209B636 (5)

Text

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h Docket No. 50-312 January 15, 1987 [)_ ( Q Mr. John E. Ward Sacramento Municipal Utility District Rancho Seco Nuclear Generating Station Post Office Box 15830, Mail Stop No. ?91 Sacramento, California 95852-1830

Dear Mr. Ward:

By letter dated August 12, 1986, and supplemented by a letter dated October 17, 1986, you submitted proposed Amendment No. 138. Revision 1, to the License for Rancho Seco Nuclear Generating Station. The proposed changes relate to the Administrative Controls Section of the Technical Specifications, and involve organizational revisions and changes to the responsibilities of the Plant Review Committee. The submittals of August 12, 19P6 and October 17, 1986,.do not contain adequate information for us to complete our review. Enclosure I is a request for additional information and Enclosure 11 is a description of those areas where the staff has concerns about the proposed chances. Please contact the assigned NRC Project Manager if you have any questions reoarding this matter.

Please communicate directly with the assigned NRC Project Manager if you have any questions regarding this matter.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than 10 repondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely,

/S/

John F. Stolz, Director PWR Project Directorate #6 Division of PWR Licensing-B Fnclosures:

As stated cc w/ enclosures:

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s Mr. John E. Ward Rancho Seco Nuclear Generating Sacramento Municipal Utility District Station cc:

Mr. David S. Kaplan, Secretary Sacramento County and General Counsel Board of Supervisors Sacramento Municipal Utility 827 7th Street Room 424

- ., District . Sacramento, California 95814

- .- 6201 S Street P. O. Box 15830 Ms. Helen Hubbard Sacramento, California 95813 P. O. Rox 63 Sunol, California 94586 Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.

Washington, D.C. 20037 Mr. Ron Columbo Sacramento Municipal Utility District Rancho Seco Nuclear Generating Station 4440 Twin Cities Road Herald, California 95638-9799 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Averue Bethesda, Maryland 20814 Resident inspector / Rancho Seco c/o U. S. N. R. C.

14410 Twin Cities Road Herald, California 95638 Regional Administrator, Peoion V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Director Energy Facilities Siting Division Energy Resources Conservation &

Development Commission 1516 - 9th Street Sacramento, California 95814 Mr. Joseph 0. Ward, Chief Radiological Health Branch State Department of Health Services 714 P Street Office Building AD Sacramento, California 95014

Enclosure I Sacramento Municipal Utilities District Rancho Seco Nuclear Generatino Station. Unit No. 1 Request for Additional Infomation In a letter dated August 12, 1986, and supplemented by a letter dated October 17, 1986 Sacramento Municipal Utilities District (SMUDI submitted proposed fmend-ment 138 Revision 1, to the License for Rancho Seco Nuclear Generating Station, Unit No. 1. Proposed Amendment 138. Revision 1 involves changes to the Adminis-trative Controls Section of the Technical Specifications for Rancho Seco Nuclear Generating Station, Unit No. 1. Following is a reouest for additional information with respect to these changes.

A. Request for Additional Infomation

1. Figure 6.2-1 With respect to each of the functional units under the Deputy General Manager, Nuclear provide a description of their functions and respon-sibilities. Is the responsibility for the Rancho Seco Security Pro-gram under the block " Security" that reports to the AGM Administration and Services?. If not, who has responsibility for that function?

You state that the AGM Engineering is not responsible for Nuclear Engineering. Does the AGM Engineering have any responsibility for engineering associated with Rancho Seco Nuclear Generating Station, Unit No. 17 Your Nuclear Pestart implementation Organization shows functional units titled Plant Modifications, implementation Manager, and Support Services Manager. Describe where these functions will be assigned in the organization shown in Figure 6 ?-1.

2. Fioure 6.2-2 The positions of Enaineering and Quality Control Superintendent.

Senior Power Plant Enoineer-Nuclear / Mechanical / Electrical, and Quality Control Personnel, have been deleted from the revised Figure 6.P-2. Describe where the functions associated with those positions have been reassigned.

,+ .

2,. Enclosure II

. Sacramento Utilities District Rancho Seco Nuclear Generating Station Comments on Proposed Revision 1 to Amendment No. 138 J

The following is our evaluation of proposed changes to the Rancho Seco Technical

. Specifications requested by letter dated August 12, 1986 and supplemented by letter dated October 17, 1986 that we find unacceptable or not acceptable as proposed.

1. Figures 6.2-1 and 6.2-2 -

Figure 6.2-1 should be changed to show position titles rather than functional

groups. Figure 6.2.2 should be expanded to show a staff under the department head and the shift staffino. In addition, the proposal to add the statement that changes may be made per 10 CFR 59 without prior NRC approval is not acceptable. All Technical Specification changes require prior NRC approval.

On a generic basis, the retention (or deletion) of organization charts in the Technical Specifications is under study as part of the Technical

! Specification Improvement Program. No position has yet been developed on this issue.

I

2. Section 6.2.2.c This section should be revised to reflect the requirements of 10 CFR 50.54(m)(2),

i 1.e., two licensed operators, one of whom shall be senior licensed, shall be present in the control room when the unit is in other than cold shutdown or refueling.

3. Section 6.5.1.4 This proposed section on the use of subcomittees is not required by the

' Standard Technical Specifications (STS) and should be deleted.

4 Section 6.5.1.6.f (current section) i Section 6.5.1.6.f of the current Specification has been deleted. This section should be reinstated as there is no basis for its removal.

5. Section 6.5.1.7.e and g The proposed changes to the current section e and q are not acceptable as they delete the actual review of the violations and events by the PRC, and i

Section 6.5.1.7.e deletes the reouirement for the preparation and distribution j of reports.

l 6. Section 6.5.2.1 i

This section, which currently is consistent with the Standard Technical l Specifications, has been revised to reduce the overall responsibility of I

the Management Safety Review Comittee (MSRC). Therefore, we find this proposed change unacceptable. ,

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7. Section 6.5.2.7.a The section has been changed to substitute the word analysis in place of evaluation. This is unacceptable since the wording " safety analysis" is inconsistent with the STS and 10 CFR 50.59.

8. Section 6.5.2.7.e This section has been revised such that the requirement for the review of internal procedures or instructions having nuclear safety significance has been deleted.

This change is unacceptable as it does not conform to the STS.

9. Section 6.5.3 This is a new section that provides for the independent review of many items by other.than the Plant Review Committee. While the concept is acceptable, several items need to be changed and/or expanded. These are as follows:

There has been no approval authority designated for proposed changes or- modifications to plant nuclear safety-related structures, systems and components, or proposed tests and experiments that affect nuclear safety. Additionally, the approval authority for procedures should be predesignated and assigned at a manager level. Approval for temporary changes to procedures should include an appropriate review and approval within seven days. -

10. Section 6.5.4.n This section which requires certain audits has been removed from the cognizance of the MSRC and placed under the Manager, Nuclear Quality. While we accept the audits being conducted by the quality assurance departments, audit reports resulting from Section 6.5.4 audits should continue to be forwarded to the Chairman of the MSRC within 30 days after completion of the audit.

11. Section 6.6.1 .

The revision to this section deletes the requirement that each Licensee Event Report (LER) be transmitted to upper level management. A statement needs to be added to the effect that the LER reports shall be submitted to the Deputy General Manager, Nuclear, i

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