ML20212E951

Forwards General Comments on Util 860703 Action Plan for Performance Improvement.Prior to Scheduled 860814 Working Meeting W/Util,Staff Will Provide Addl Comments to Be Addressed in Meeting Agenda

ML20212E951
Person / Time
Site:	Rancho Seco
Issue date:	07/29/1986
From:	Harold Denton Office of Nuclear Reactor Regulation
To:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
TAC-61635, NUDOCS 8608130193
Download: ML20212E951 (4)

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July 29, 1986 i

Docket No. 50-312 DISTRIBUTION Qocket File >

JPartlow NRC PDR RIngram L PDR SMiner Mr. John E. Ward PBD#6 Rdg RWeller Assistant General Manager, Nuclear FMiraglia Gray File Sacramento Municipal Utility District OGC, MNB 9604 NThompson 6201 S Street ACRS-10 HDenton P. O. Box 15830 EJordan JTaylor Sacramento, California 95813 BGrimes R:V

Dear Mr. Ward:

By letter dated July 3,1986, you forwarded the Sacramento fiunicipal Utility District (SMUD) Action Plan for Performance Improvement at the Rancho Seco l

Nuclear Generating Station. The NRC staff has performed a preliminary review l

of the SMUD Action Plan to assess the general adequacy, scope and content of the Plan. A preliminary version of your Action Plan was discussed at a meeting with you on June 12, 1986.

The Action Plan appears to be comprehensive and goes beyond the issues and deficiencies related to the December 26, 1985 overcooling transient. However, as your Plan preser.tly indicates, there are many elements or items in your program which are needed to provide an adequate basis for the staff's review.

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We will need a schedule for your submittal of the information as soon as possible to plan the staff's review and evaluation.

l The staff has met with SMUD several times since the December 26, 1985 l

overcooling event to discuss SMUD's proposed program for restart of Rancho Seco. During these meetings, and in related correspondence, the staff has provided guidance regarding the scope and content of your restart report and the issues which will require resolution in your corrective action progran.

Based on our preliminary review of the SMUD Action Plan, we are enclosing general comments which should be considered in the preparation of your supplement to the Action Plan. Most of these comments involve issues that were raised in our previous meetings. Specifically, the si comments from our June 12 meeting (sent to you on June 20,1986)gnificant regarding the lack of necessary details, discussion of restart items and longer term items, and the systems review and test program still need to be addressed.

Prior to the scheduled August 14, 1986 " working" meeting with your staff to discuss the detailed aspects of your plan, the staff will provide additional comments that should be addressed in your meeting agenda.

Sincerely, Oripalaleneng l

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PDR Harold R. Denton, Director I

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Office of Nuclear Reactor Regulation

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i 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 027 7th Street, Room 424 District Sacramento, California 95814 6201 S Street P. O. Box 15830 Ms. Helen Hubbard Sacramento, California 95813 P. O. Box 63 Sunol, California 94586 Thomas Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C.

20036 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 Avenue Bethesda, Maryland 20814 Resident Inspector / Rancho Seco c/o U. S. N. R. C.

14410 Twin Cities Road Herald, California 95638 Regional Administrator, Region 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 #8 Sacramento, California 95814

D Enclosure

GENERAL COMMENT

S ON THE RANCHO SEC0 j

ACTION PLAN FOR PERFORMANCE IMPROVEMENT 1.

The action items to be implemented prior to completion of the restart test program or to the restart of the plant need to be described in detail. Similarly, insofar as practicable, actions in the near tem and long term require greater specificity.

Near term and long term should be defined in the time domain. The bases for categorizing actions as near term and long tern should be described.

2.

The plan is not clear with regard to schedt.les for completion of the various elements. Schedules for actions to be.taken prior to plant restart or prior to completion of the restart test program are not clearly defined (e.g., Appendix F). Where evaluations are to be performed to define corrective actions, schedules for performance and completion of the evaluation and implementation of any identified corrective actions should be provided. We recommend a separate section be included which deals with schedules and clearly indicates what actions will be complete and implemented by restart, the following refueling outage, and other future dates.

3.

The Action plan is deficient in that it fails to cross reference, in most instances, the elements of the program that address the NUREG-1195 findings as enumerated in Appendix B.

4.

There are many action items which are similar to areas in the B&W0G plan. A detailed interface requirement should be provided to discuss how the two programs are intertied.

5.

The action plan does not provide sufficient information regarding the review to be performed in the following areas:

a.

S.G. overfill protection system b.

Makeup /high pressure injection system c.

Remote and local indication d.

Containment isolction e.

Interaction between ICS, NNI and other safety related systems; and f.

Partial loss of ICS and NNI.

6.

The Action plan should include reevaluation of the transient and accident analyses assuming partial or full loss of the non-safety grade ICS and NNI systems used for event mitigation.

7.

It is not clear from the Rancho Seco Action Plan how the systems to be reviewed as part of the Systens Review and Test Program (SRTP) will be selected.

For example, will the tentative list of systems in Section 4D be submitted to the PAG for approval and then adjusted from the input received from the PP&MIP or will the initial selection of systens be

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-2 based on preliminary output from the PP&MIP? Clarification of the system selection process is required including how the output of the PP&MIP will be used in that process. We would also like clarification as to how the Rancho Seco SRTP is modeled after the Davis-Besse SRTP, and how the results of a review of the Davis-Besse SRTP will be factored into the Rancho Seco plan.

8.

It appears that contract personnel are playing a major role in assisting to implement the improvement program.

Please indicate the organization and personnel who will be responsible for Rancho Seco during startup, power testing, and subsequent power operation.

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