ML20236K495

Requests Expedited Interim Approval of Util Updated Inservice Testing Plan Submitted in June 1987 to Support Plant Restart.Concern That Util Will Have to Request Addl Relief Requests If Plan Not Approved Discussed

ML20236K495
Person / Time
Site:	Rancho Seco
Issue date:	11/02/1987
From:	Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Miraglia F Office of Nuclear Reactor Regulation
References
AGM-NPP-87-358, NUDOCS 8711090245
Download: ML20236K495 (2)

Text

,

I $$ MUD

' SACRAMENTO MUNICIPAL UT:LITY DISTRICT O P. O. Box '15830, Sacramento CA 95852-1830,(916) 452-3211 i

AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA

. N0l/ V 2 g

, AGM/NPP 87-358 3 g

.]

. U.- S. Nuclear Regulatory Commission  ;

Attn: Frank J. Miraglia, Jr.

Associate Director for Projects g Philips Bldg. 1 7920 Norfolk-' Avenue j' Bethesda, MD 20014 1 DOCKET 50-312 RANCHO SECO NUCLEAR GENERATING' STATION LICENSE NO.'DPR-54 ]

j INTERIM APPROVAL OF UPDATED INSERVICE TESTING (IST). PROGRAM.-

Dear Mr. Niraglia:

The District submitted the Updated IST Program in June 1987 for your review, We requested either interim approval of the updated program or a meeting with

.your staff to establish the IST requirements necessary to support plant '

restart. Your staff responded by instructing the District to continue the . j{

implementation of the first ten year program until the updated program can be j reviewed. We appreciate your astistance in expediting this review; however, j we feel it necessary to address some concerns.

The District completed a thorough review of the IST Program while developing i the Updated IST Program Plan. This effort was in conjunction with-the review ]

of selected plant systems as a part.of the System Review and Test Program 1 which reviews systems for operational readiness, similar to what is done by 1 the NRC for a_ NTOL plant. In developing .this program we identified.a number 1 of deficiencies in the first program.- We have asked for interim approval of  :

the Updated IST Program to allow the District to implement the necessary pump ~

and valve testing requirements and testing relief to comply with the code requi rements. If the District must continue to implement the requirements of ' ,

the first ten year program, a number of additional- relief requests will be l necessary. These. reliefs, as requested in the Updated IST _ Program, include three pump reliefs (PR-3, 8, and 10) which are necessary due to .

instrumentation limitations, two valve reliefs (VR-4,19) required for containment valve testing, and two additional valve reliefs (VR-17,- 20) for-individual valve stroking which cannot be reasonably tested per the Code requirements. In addition, all relief requests associated with the first' ten' year program must remain in effect.

Currently, the District is completely rewriting the. Surveillance Procedures-used to implement- the requirements of the IST Program. . We feel .it would be <

beneficial to implement the new requirements during this rewrite effort. .This -

would minimize any problems which may arise if ' major revisions are required -

8711090245 B71102 0 PDR ADOCK 05000312 I

.P PDR g RANCHO SECO NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638-9799;(209) 333- 935-

. _ _ _ ___ _ _a

)

e. ,

1 1

AGM/NPP 87-358 Frank J. Miraglia, Jr.  !

during plant heatup and power escalation. The delay in obtaining approval of the Updated IST Program will result in an additional resource commitment for both of our staffs. The additional relief requests would_ require review and approval by your staff prior to'startup. Revising' the newly rewritten Surveillance Procedures _ shortly after startup, when-the updated IST Program is approved, .will also unnecessarily require additional _ District resources.

Please _ contact ce if you have any questions. Members of your staff with questions requiring additional information or clarification may contact Masa Nakao at extension 4916.

Sincerely, J ,

seh F. Firlit Assistant General Manager, Nuclear Power Production cc: G. Kalman, NRC, Bethesda A. D'Angelo, NRC, Rancho Seco 1

l 1

i