ML20237C007

Forwards Addl Info Re Emergency Operating Procedures,Per NRC 871201 Telcon Request.Info Discusses Issues Considered by NRC to Be Required for Restart & Issues to Be Addressed by Util After Reactor Criticality

ML20237C007
Person / Time
Site:	Rancho Seco
Issue date:	12/09/1987
From:	Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Miraglia J Office of Nuclear Reactor Regulation
References
AGM-NPP-87-431, NUDOCS 8712180040
Download: ML20237C007 (4)

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l-suun e*M SACRAMENTO MUNICIPAL UTILITY DISTRICT C P.

95852-1830,(916) O. Box 15l 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA l

DEC 0 91987 .]

l AGM/NPP 87-431 )

l U. S. Nuclear Regulatory Commission Attn: Frank J. Miraglia, Jr.

Associate Director for Projects ,

Philips Bldg.

7920 Norfolk Avenue Bethesd;, MD 20014 DOCKET 50-312 RANCHO SECO NUCLEAR GENERAfING STATION LICENSE NO. DPR-54 EMERGENCY OPERATING PROCEDURES (EOP) ADDITIONAL INFORMATION

Dear Mr. Miraglia:

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In a telephone conference with your Staff (12/1/87) additional information was requested to facilitate your review of our E0P submittal. Attachment 1  !

contains a discussion of those issues which are considered by the Staff to be l required for restart. Attachment 2 provides a discussion of long term issues which will be addressed by the District after reactor criticality.

Please contact me if you have any questions. Members of your Staff with questions requiring additional information or clarification may contact John Atwell at (209) 333-2935, extension 4917.

Sincerely, i N r.,

Joseph F. Firlit >

Assistant General Manager, Nuclear Power Production ,

i Attachments cc: G. Kalman, NRC, Bethesda A. D'Angelo, NRC, Rancho Seco J. B. Martin, NRC, Walnut Creek  ;

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87121800'40 871209 0..

PDR- ADOCK 05000312 3 g l

.DCD F,

l RANCHO SECO NUCLEAR GENERATING STATION 01444o Twin Cities Road, Herald, CA 95638 9799;(209) 333-2935 u_______1_.______________ - . _ _ _ _ _ _ _ _ _ . _ . _ . _ _ _ J

l DEC 0 9 W ATTACHMENT 1 RESTART ISSUES

1. Emergency Operating Procedures (E. Series and Rules) are being reviewed for compliance with the E0P Writers Guide (AP 2.24). Additionally, the Cooldown Procedures (CP's) are being reviewed for compliance with the applicable Writers Guide prior to startup. Differences which are identified will be corrected prior to startup or by the end of the next refueling outage. A few exceptions regarding E0P use and writers guide adherence were noted in Inspection Report 50-312/87-32 section 6 and 9.

These exceptions will be corrected prior to startup. Other exceptions will be corrected prior to startup if they meet the prestartup criteria of Rancho Seco Administrative Procedure 0215 "RSL/LRSL Development and Administration."

The District has confidence that the E0P/0perator interface is adequate because four weeks of simulator training per crew have been conducted with the procedures this year. Several crews were evaluated by the NRC staff and INPO ar.d it was concluded that the operators are knowledgeable on the use of the E0Ps.

1 It is our understanding that the NRC has accepted the District's position 2.

that the Cooldown Procedures (CP's) will be included in the E0P program

'after restart. The Cooldown Procedures will be formally included in the E0P program described by the Procedures Generation Package (PGP) by the end of the next refueling outage. This will necessitate changes to the writers guide to accommodate the format difference.

(Note: The CP's are being handled within the scope of the District's effort to establish the technical basis for the E0Ps as described in Attachments 1 and 2 to the District's November 20,1987 E0P PGP submittal. )

3. Plant specific setpoints in the E0Ps are derived from appropriate bases.

The symptom based E0Ps and cps were originally written from the Rancho Seco specific ATOG which included the plant specific setpcInts. Revisions to the procedures have been made based on the generic Technical Basis Document (TBD) which has some plant specific setpoints and setpoints applicable to all plants. The few plant specific setpoints not specified in AT0G or TBD are based on appropriate engineering or operational evaluations. The District considers this position to be acceptable.

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j DEC 0 0 16 ATTACHMENT 2 NON-RESTART ISSUES

1. The exit meeting of October 2,1987 and telephone conversations of October 19 and December 1,1987 identified several enhancements related to the E0P program. Many of these items are standard practice at the District, however, they are not described in the PGP. The District will incorporate / address these aspects in the PGP by the end of the next refueling outage.

Validation and Verification l a. E0Ps will be validated and verified using multiple failures I (simultaneous and sequential).

b. Criteria used to select scenarios used in the validation program and, for those aspects of the E0Ps that cannot be validated on a simulator as contained in the program, criteria for selecting additional validation methods will be described.

l c. Validation and verification will be accomplished as appropriate by using a team review with the appropriate disciplines represented versus separate reviews by individuals.

d. Validation and verification of revisions to E0Ps will be conducted.

Training Program

a. A description of how the learning objectives are developed and delivered will be provided,

b. Training methods used in areas where the simulator is not like the control room or does not react like the plant, or parts of the E0Ps that cannot be run on the simulator will be described.

c. Training will be as a team with each operator trained in the role expected to be taken in an emergency (e.g. including STA).

_W riters Guide Program

a. The use of tabs to support operator branching between procedures will i be a consideration,

b. Guidance will be provided to assure the E0Ps are written for the minimum shift crew and consider the division of responsibility between operators.

c. Controlled copies of the E0Ps will be the same physical quality as the originals.

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f. - DEC 0 91987 i

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ATTACHMENT 2 (Cont.) 1 1

2. The November 20, 1987 submittal enclosures 1 and 2 identified differences ,

between the E0Ps and the TBD which will be resolved prior to startup or I later. Those items not identified as prior to startup changes will be l accomplished as follew: )

The changes which do not require equipment modifications will be )

resolved prior to startup from the next scheduled refueling outage. .  !

(Note: That further evaluation of these changes may result in i reclassifying some to a permanent difference, with no change j requi red. )

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t Procedure changes which require equipment modifications will be ]

coordinated with their associated modifications. (Note: Plant modifications are scheduled for implementation by the Long Range Schedule process, Rancho Seco Administrative Procedure 1401.) 4 i

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