ML20245E985
| ML20245E985 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 10/20/1988 |
| From: | Chandler L NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20245E989 | List: |
| References | |
| 2.206, NUDOCS 8902090208 | |
| Download: ML20245E985 (6) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION o
h WASHINGTON, D. C. 20555 October 20, 1988 MEMORANDUM FOR:
i[TbiidiilE Muhlif,"DUedtEr 0 C_
e Office. ofJ Nuclear : Rea c, to rr Regulation,:-
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FROM:
Lawrence J. Chandler Assistant General Counsel for Enforcement Office of the General Counsel
SUBJECT:
2.206 PETITION FILED BY B. M0LLER REGARDING RANCHO SECO Enclosed please find a copy of a Petition dated August 30, 1988, filed by Barbara Moller, requesting, pursuant to 10 C.F.R. 6 2.206, that the Nuclear Regulatory Commission (NRC) direct that Sacramento Municipal Utility District (SMUD) to shut down its Rancho Seco Nuclear Generating Station (RanchoSeco). Your office should treat the Petition pursuant to 10 C.F.R.
s 2.206 and prepare a response. Ms. Moller alleges the following bases for her current request: 1) SMUD management has criminally (willfully) disre-garded public health and safety as shown by incidents between 1980 and 1984, and again in 1988, in which SMUD released excessive amounts of water contain-ing radionuclides; 2) indications on the pressurizer support lugs demonstrate embrittlement as a result of rapid cooldown events at Rancho Seco; 3) pipe wall thinning has occurred; and 4) in March of 1988, while starting the reactor, SMUD lost control of Rancho Seco and was unable to shut the plant down. Ms. Moller also reiterates her concerns about SMUD's drug detection program that she raised in another Petition dated August 3,1988.
Insofar as the instant Petition makes allegations related to illegal drug use at Rancho Seco, it may be treated as a supplement to the August 3 petition to which the staff is currently preparing a response. Ms. Ptoller also requests the proposed location of the low-level waste repository California is developing in order to comply with the Low-Level Waste Policy Act, 42 U.S.C. 6 2021b-d.
California's development of its low-level waste facility appears to have no direct relevance to SMUD or Rancho Seco, as explained in a letter dated June 20, 1988, from Victor Stello to Senator Alan Cranston.
You may wish to include Mr. Stello's answer to Senator Cranston concerning this matter in your Decision.
I have enclosed a draft of a letter of acknowledgement to its. Moller for your signature and a draft Notice of Receipt of the Petition for publication in the Federal Register. Please note that Victor Stello's letter to Senator Cranston, referred to above, also addresses the water release issue. You may wish to use that letter as a framework for your decision on this issue. Also, Region V requested an investigation into'this matter. The Office of Investi-gations has completed its inquiry, and the staff is considering the results of S]
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.2-that investigation in deciding on an appropriate enforcement action.. The letter requires substantive input from your staff regarding the California Llow-level waste disposal facility. My staff will work with your staff to develop an appropriate response in this regard..The OGC attorney assigned to this matter is Robert Weisman (x21696).
If you would like SMUD to respond to this matter, you may solicit information
-from SMUD pursuant to 10 C.F.R. 6 50.54(f) and 6182 of the Atomic Energy Act.
Please inform my staff which technical staff: member will. prepare a response to the. Petition. Also, please provide me with. copies of all correspondence
.related to the Petition and please send all staff correspondence to me for concurrence.
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i Lawrence. Chandler Assistant General Counsel for Enforcement Office of the General Counsel
Enclosures:
1.
Copy of Petition 2.
Draft Letter of Acknowledgment 3.
Draft Federal Register Notice cc: w/ enc 1:
J. Martin, RV J. Scinto, 0GC J. Lieberman, OE l
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Ms. Barbara Holler P.O. Box 163306 Sacramento, CA 95816 4 c M /
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Dear Ms. Moller:
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This letter acknowledges the Nuclear Regulatory Comission's (NRC). receipt of your Petition dated August'30, 1988. Your Petition requests' the NRC to shut down the Sacramento Municipal Utility District's (SMUD) Rancho Seco Nuclear:
GeneratingStation(RanchoSeco).
You allege the following bases for your current request:
- 1) SMUD management has criminally (willfully) disregarded public health and safety as. shown by incidents'between 1980 and 1984, and again in 1988, in which SMUD released
. excessive. amounts of water containing radionuclides; 2) indications on the,
pressurizer support lugs demonstrate. embrittlement as a result of rapid cool-down events at Rancho Seco; 3) pipe wall thinning has occurred; and 4) in March of.1988, while starting the reactor, SMUD lost control. of Rancho Seco and was. unable to shut the plant down.
I note that Mr. Victor Stello, Executive Director for Operations, NRC, addressed the water release concern in
~a-letter dated June 20, 1988, to Senator Alan Cranston, which was prompted by your inquiry to the Senator.
For your convenience, I have enclosed a copy of that letter.
I also note that NRC Region V requested an investigation into this matter and that the staff is considering escalated enforcement action in light of the results of the investigation.
You further inquired about the location of California's proposed low-level waste repository site.
For your informaHan. this site v'1 k at #
y anntvinn, no 7n vue at TraunT!'!E, NRR nAi w15H "O RETEft-MS. "nLEER TG CvhPEiENT STATE AUTil0RITIE5 RATHER THAW Ah5wEkimriiER QUESTION.]
Also, your Petition repeats the allegations of drug problems at Rancho Seco of another Petition you submitted dated August 3,1988, as well as that Petition's requests, which included your request for immediate suspension of the license.
I will treat this portion of the instant Petition as a sup)1ement to the. August 3 Petition, and will issue a decision on these issues wit 11n a reasonable time.
Inasmuch as I have ciready denied your request for immediate suspension of the license based on ttis issue, [0 ATE OF LETTER OR DECISION] and because you have alleged no new facts that might bear on this issue, I again deny your request for immediate relief.
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The NRC will continue to' review the Petition in accordance'with 10 C.F.R. 6 2.206 and I will issue a formal decision with regard to it within a reasonable time. A copy of the notice that is being filed for publication with the Office of the Federal Register is enclosed for your information..
Sincerely yours, Thomas E. Murley, Director Office of Nuclear Reactor Regulation cc: Sacramento Municipal Utility District l
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t f NUCLEAR REGULATORY COMMISSION-DOCKET N0.'50-312
- S'ACRAMENTO MUNICIPAL UTILITY DISTRICT RANCH 0'SECO NUCLEAR GENERATING STATION RECEIPT 0F PETITION FOR' DIRECTOR'S DECISION UNDER 10 C.F.R. 5 2.206 Nntice ti hereby given that by Petition dated August 30,.1988, Ms.
l Barbara Moller (Petitioner) sought the Nuclear Regulatory Commission (NRC or -
Commission)toinitiateenforcementactioninvolvingtheSacramentoMunicipal Utility District's (SMUD) Rancho Seco Nuclear Generating Station (Rancho Seco). The Petitioner requested that the NRC shut down Rancho Seco. - Peti-
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. tioner, based.this request. in part, on allegations concerning the use of illicit drugs at Rancho Seco. The Petitioner submitted an earlier Petition, dated August 3, 1988, which also made allegations of drug problems at Rancho Seco. The NRC is treating the August 3 Petition pursuant to 10 C.F.R. 5 2.206 of the Commission's regulations [ citation to Fed. Reg.] and will treat the portions of the instant Petition that concern SMUD's program to detect the
.use of illicit drugs at Rancho Seco as a supplement to the August 3 Petition.
The Petitioner further based this request on allegations that 1) SMUD manage-ment' has criminally (willfully) disregarded public. health and safety as shown by incidents between 1980 and 1984, and again in 1988, in which SMUD released excessive amounts of water containing radionuclides; 2) indications on the pressurizer support lugs demonstrate embrittlement as a result of rapid cooldown events at Rancho Seco; 3) pipe wall thinning has occurred; and 4) in March of 1988,'while starting the reactor, SMUD lost control of Rancho Seco and was unable to shut the plant down.
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The request is being treated pursuant to 10 C.F.R. 5 2.206 of the Commission's regulations.
The NRC will take any other appropriate action on the Petition's request within a reasonable time. A copy of the Petition is available for inspection and copying in the Commission's Public Document Room, i
2120 L Street, N.W., Washington, D.C. 20555 and at the local Public Document Room for the Rancho Seco Nuclear Generating Station at the Martin Luther King Regional Library, 7340 24th Street Bypass, Sacramento, California 95822.
FOR THE NUCLEAR REGULATORY COMMISSION Thomas E. Murley, Director Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this day of i
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UNITED STATES 8.
NUCLEAR REQULATORY COMMISSION
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WASHWGTON, D. C. 20555
-t JUN 2 01988 The Honorable Alan Cranston United States Senate Washington, D.C. 20510 1
Dear Senator Cranston:
In rerponse to your letter dated May 20, 1986 to the U.S. Nuclear Regulatory Comission (NRC), you requested that the NRC coment on concerns expressed by one of your constituents, Ms. Barbara Holler, in her letter to you dated Nay 16, 1988 regarding radioactive liquid releases from the Rancho Seco Nuclear Generating Station.
Ms. Moller referred to an April 14, 1984 newspaper account of radioactive liquid releases from Rancho Seco that occurred between 1980 and 1984. The newspaper article described radioactive liquid releases from Rancho Seco that appeared to.
have exceeded the Federal regulatory limits as set by the Environmental Protection Agency (EPA) in Title 40 Part 190 of the Code of Federal Regulations (CFR). Ms. Moller stated that there was no consistency between Federal and utility radioactive liquid release limits.
The EPA limits are given in terms of exposure to offsite personnel. Each nuclear power station is required to develop an offsite dose calculation manual that converts quantities of cesium isotopes and other radionuclides released from the site into a corresponding exposure to offsite personnel.
In the case of liquid releases, the conversion takes into account, in addition to the types of radionuclides and their half-lives, the amount of dilution provided'by onsite and offsite water sources. Between 1980 and 1984, the conversion calculations performed by Rancho Seco personnel were incorrect and Rancho Seco releases created dose conditions offsite which could have exceeded regulatory
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exposure limits to the public.
Investigations by Brookhaven National Laboratory personnel showed that even though conditions for exposure in excess of regulatory limits existed offsite, no person was exposed to a dose in excess of the EPA limits.
In addition to the EPA radioactive release limits which are given in terms of public cxposure limits, the NRC in 10 CFR Part 20 prescribes release limits in terms of concentration cf each radioisotope, including cesium isotopes. The NRC limits can be applied by utility personnel directly, without the use of a dose calculationmanual,andserveasabackuptothemore. stringent (site-specific)
EPA limits.
The utility develops release limits based on offsite exposure design objectives publish'ed by the NRC in 10 CFR Part 50, Appendix 1.
The limits based on design objectives are substantially more conservative than the EPA or NRC limits to ensure that (assuming utility personnel perform calculations correctly) plant releases will not approach Federal limits.
The miscalculations by Rancho Seco personnel between 1980 and 1984 prompted an extensive NRC evaluation of the Rancho Seco radioactive liquid release program.
,, awr 7
The Honorable Alan Cranston -
The results of the evaluation are described in the Rancho Seco restart safety evaluation, NUREG-1286, Supplement 1, Section 4.3.
Following the NRC evaluation, Rancho Seco liquid waste handling systems were modified and calculational techniques to determine permissible liquid release levels were revised. The Rancho Seco liquid release limits are based on arid conditions in the imediate vicinity of the plant with minimal water available for dilution.
As a result, permissible liquid discharge levels from Rancho Seco are much lower than those applicable to most plants in the United States which typically have a large body of water to serve as a dilution source in the imediate vicinity of the plant. Ms. Mo11er's concerns that radioactive releases from Rancho Seco may contaminate major California water systems and agricultural lands are not realistic. The small amounts of radioactive liquid releases from Rancho Seco, when eventually diluted by the major water systems referenced by Ms. Moller, would make a virtually indistinguishable contribution to naturally occurring radiation in the water and soil.
In a separate concern, Ms. Moller implied that radioactive waste disposal sites are not available to Rancho Seco.
Rancho Seco waste continues to be shipped to the low level waste disposal sites at Beatty, Nevada, and Richland, Washington.
In compliance with the Low Level Waste Policy Amendment Act, Califnrnia is developing an in-state low level radioactive waste disposal site that is expected to begin operation in 1992.
All U.S. nuclear utilities, including Rancho Seco, store high level waste (spent fuel) on site while a high level waste repository is being developed.
A high level waste repository is expected to begin operation in the year 2003.
Ms. Moller elso expressed concern over newspaper accounts of radioactive water releases at Rancho Seco that occurred inside the reactor building. The reactor building is a water and airtight structure which houses most of the radioactive
)lant systems. Liquid and gaseous releases from these systems occasionally occur; 10 wever, the reactor building is designed to contain and collect the releases.
The collected radioactive material is processed by plant systems for reuse or for disposal as radioactive waste.
The radioactive releases referenced by Ms. Moller, although not significant in terms of public health and safety, were evaluated by the NRC staff for indication of problems which could adversely impact future operations. The releases occurred during restart related tests which were part of an overall program to test plant components, systems and system interfaces. The tests associated with the releases identified some problems with plant hardware and procedures. These were corrected and the tests were subsequently completed with satisfactory results. The staff did not consider that these problems were significant in terms of overall operational capability.
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,The Honorable Alan Cranston,
There are numerous additional technical issues, including the pipe wall thickness concern mentioned by Ms. Moller, which the NRC staff is evaluating at Rancho Seco and at other nuclear power plants. The number of open issues at Rancho Seco is comparable to that of an average nuclear power plant. Should any of the open issues develop into safety concerns, the NRC will take appropriate steps to resolve the problem.
At the present time, there are no safety concerns identified at Rancho Seco which change the staff's conclusions as stated in the restart safety evaluation, NUREG-1286, regarding operational readiness at Rancho Seco. The staff will continue to monitor the plant to ensure that future operations are conducted safely and in compliance with applicable Federal safety standards.
Sincerely, (SignM) T. A. Rehm htor Stello, Jr.
Executive Director for Operations e
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UNITED STATES OF AMERICA
-NUCLEAR REGULATORY COMMISSION i
0FFICE OF NUCLEAR REACTOR REGULATION Thomas E. Murley, Director In the Matter of i
SACRAMENTO MUNICIPAL UTILITY
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DISTRICT Docket No. 50-312 j
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'(Rancho Seco Nuclear GeneratingStation)
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DIRECTOR'S DECISION UNDER 10 CFR 2.206 INTRODUCTION l
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.
l The Petition asked the U. S. Nuclear Regulatory Commission (NRC) to order l
the licensee of the Rancho Seco Nuclear Power Plant to show cause why the plant
- j should not be prevented from restarting until a complete check of all cables I
was undertaken or, in the alternative, why the plant should not be completely 1
shut down. Ms.'Moller gave as the bases for the Petition (1) the " official investigation" concerning falsification of cable tray data and (2) the
" problem-laden" history of the Rancho Seco facility.
In the Petition, Ms.
Moller asserted that three forged signatures had been found at each level in I
the quality control hierarchy on at least seven cable installation cards and that this indicated that proper cross-checking had not been done. Ms. Moller fu'rther asserted that in light of the falsification of cable data, sampling was not an effective method for checking cable work. Ms. Moller further asserted that 2000 cables had been added to the plant since 1974, and she expressed 1
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j 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 i
received a letter from United States Senator Alan Cranston requesting that the l
f Commission staff respond to the concerns raised in Ms. Moller's Petition. The
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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 completion of evaluations being performed by the l
licensee and the staff and that the NRC would not authorize restart of Rancho Seco until the cable routing discrepancies were resolved.
On April 27, 1987, Dr. Thomas E. Murley, Director, NRC Office of Nuclear ReactorRegulation(NRR),acknowledgedreceiptofthePetition. He informed Ms. Moller 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.
I Notice of receipt of the Petition was published in the Federal Register on May 6, 1987, (52 FR 16967).
f 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 associated with the plant cables were resolved.
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j 1 I BACKGROUND The Rancho Seco Nuclear Generating Station, operated by the Sacramento l
L Municipal Utility District (SMUD, the licensee) is a 916-MWe Babcock and Wilcox 1'
(B&W) designed pressurized-water reactor located in Clay, California, about 25 1
l-miles southeast of Sacramento. The plant received an NRC operating license in 1974.
In the years 1983 through 1985, 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 Island, implementation of modifications 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 equipment.
In this period, approximately 7800 cables were either installed or 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 computerized cable raceway and tracking system (CRTS) might be inaccurate.
Subsequent investigation by the licensee and review by the NRC 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 licensee a
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y integrated this inspection activity and reviews of other cable-related problems into a single program under a single program manager.
Th'e 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 NUREG-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 below.
DISCUSSION A.
Falsification of Cable Pull Cards Investigations of cable discrepancies, including inspections, have been performed by the licensee. The results showed that in two separate instancer l
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 card as it should have been, according to established plant procedures.
In the first case, which involved 14 cables serving equipment for remote plant shutdown, the cable installer's name war, printed on the cards.
In the second case, which involved the intermixing of 11 power and control cables with instrumentation cables in instrumentation cable trays, the field engineer's signature was in the signature block reserved for the signature of the cable installer. The safety implications of these cable discrepancies are discussed below, i
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5-To understand the safety implications associated with the cable discrep-ancies and to determine the appropriate corrective actions, it was necessary for the licensee to understand the nature of the deficiencies in field engi-neering and quality control. The licensee has determined the nature and extent of the cable discrepancies with formal programs for inv!stigation 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 to reroute the cables was simply not done and the cables remained in an unt.ccept-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 Control Group (CCG) clerk were using an informal procedure developed by an engineering aide in the CCG.
It also appears that when the card control discrepancy was detected, proper follow-up action was not taken. The NRC Office of Investigations is currently investigating whether or not wrongdoing was involved in this matter.
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The failure of the. qualitycontrol(QC)inspectortodetectthework 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 ompleted.
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 j
be detected. As discussed in Appendix A of NRC Inspection Report 50-312/87-21, 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 l
CFR Part 50, Appendix B, Criterion X, which governs inspection of activities I
involving quality. The licensee's corrective actions in response to this-
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violation, are discussed later in this document.
i The 11 Intermixed Cabics l
The second. instance involved 11 power and control cables that were to have j
been removed from some of their original trays and rerouted so that the trays could be redesignated and used to house new instrumentation cable. This work i
was to have been done as part of a major modification in 1983 that involved the
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relocation and installation of a large amount of cable over a relatively short l
time period. As in the first instance, the cable pull cards had been signed l
I off indicating the work necessary to complete the rerouting of the 11 cables was done; but the work had not been done. Thus, when the new instrumentation cables were pulled into the redesignated cable trays, intermixing of safety-related power / control and instrumentation cables. occurred, which constituted a violation of design criteria.
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e, The licensee's investigation also identified procedural violations on the l
part of the field engineers and QC inspectors.
The procedural violations included the signing of cable pull cards by the field engineer instead of by the craft foreman responsible for actually 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 licensee's corrective actions in response to this violation are discussed below.
Safety Implications and Corrective Actions Following the completion of the investigation of the 14 remote shutdown cable discrepancies and the discovery of the 11 intermixed cables, it became apparent to both the licensee and the NRC staff that the faulty practices, procedures and controls that had allowed cable routing problems to occur and go undetected could very well have affected other safety-related cables.
In a July 2, 1987 letter from G. C. Andognini, SMUD, to Frank J. Miraglia, NRC, the licensee committed'to expanding the ongoing inspection of safety-related and safe shutdown I
cable to include all such cables in the population that had been rerouted since the beginning of commercial 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
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performed by QC inspectors. Those inspections have since been completed and no other work control errors were identified. The results of the inspections are discussed below under item C.
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In response to the cable installation deficiencies described above, the licensee has developed new procedures and controls and has made improvements to f
existing ones. The changes have been based on the results and recommendations derived from the licensee'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 requires 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.
Formal 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 groups.
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 regarding 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 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 (QA) program. These changes were presented to the NRC staff in a meeting held September 23, 1987. The more significant changes include:
reorganization of the QA department with the new Director of Nuclear Quality reporting directly to the Chief Executive Officer; i
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increased staffing with people who have mult1 disciplinary backgrounds; organi-
.zationa1' independence from production organization; and increases in the scope and frequency of audit activities.
l The NRC staff considers both the specific and broad changes in procedures and quality control to be acceptabic. However, in the course of the normal inspection program the staff will continue to closely monitor performance in l
quality activities to ensure that the changes are effective.
B.
Inspection of Cable Routes The licensee's corrective action regarding inspection of cable routes has been (1) a complete (100%) inspection of all safety-related and safe shutdown cables that have involved route revisions between the start of commercial
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l operation and the initiation of the inspection program on December 22, 1986 (475 cables) and (2) a random sample inspection of cables installed between the start of commercial operation and the initiation of the inspection program
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that have never undergone route revisions (142 of 1559 cables). The 14,000 cables installed during the original construction of the plant, which have l
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 surveillance testing.
2.
The original architect engineer (Bechtel) had in place and used a rigorous quality control program for the design, installation, and inspection of the original cable population and followed a uniformly consistent set of rules and procedures.
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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 population 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 letter 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 cable 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 1
In the staff's view, the objective of a sample inspection of construction work is to determine with reasonable assurance that the number and significance l
of deficiencies in construction and quality assurance have not degraded safety margins to an unacceptable level.
In the case of misrouted electric cables at Rancho Seco, the following criteria were used:
1.
There is 95% assurance that at least 95% of the cables are correctly routed (95/95).
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The defects have no significant potential for.a loss of redundancyL 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 concluded in Section 4.8 of NUREG-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 Suptlement I to NUREG-1286 that the 95/95 acceptance criterion 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 and safe shutdown cables being in a configuration that violates 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)alsoisacceptablylow.
D.
" Problem-Laden History" of the Facility Following issuance of the NRC staff's Incident Investigation Team's (IIT) report on the December 26, 1985 overcooling event at Rancho Seco, it became j
i J
apparent to both the staff and the licensee that the design and programmatic deficiencies identified during the staff's investigation were symptomatic of more serious problems than those associated with the overcooling event and would require a corrective action program that embodied more than the narrow l
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focus'of the overcooling event. Accordingly, in the spring of 1986, the
. licensee embarked on a comprehensive Plant. Performance and Management-Improvement' Program (PP&MIP) that responded to a broader range of issues.
Th'e 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 (B&W) Owners Group Safety and Performance Improv'ement Program
.(SPIP) recommendations; NUREG-1195, the Incident Investigation Team (IIT) report '
of the December 26th event; and other miscellaneous information. The resolution of each problem was prioritized by the licensee as a restart, near-term, or long-term item.
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 documented in Section 2.3.2 of the NRC staff's " Safety Evaluation Report related to the Restart of Rancho Seco Nuclear Generating Station, Unit 1 following the event of December 26, 1985," and Supplement I to that report (NUREG-1286 and NUREG-1286, Supplement 1).
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Design Control Deficiencies The Petitioner also referenced "significant design control' deficiencies"
-in safety-related pipe supplies. Problems which reflect 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 1937.
i These problems are discussed in Inspection Report 50-312/86-41 and summarized 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 and to document, in detail, the design bases for key safety systems.
The NRC 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 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 Rancho Seco facility. The institution of proceedings pursuant to 10 CFR 2.202 is app _ropriate only where substantial health and safety issues have been raised.
See Consolidated Edison Company of New York (Indian Point, Units 1, 2, and 3),
CJ.1-75-8,2NRC173,175(1975), and Washington Public Power System (WPPS
___.-_____.,____m_______.____m._.
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Nuclear Project No. 2), DD-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 to determine 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 I
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 Secretary of the Commission for its review.
FOR THE NUCLEAR REGULATORY COMMISSION Thomas E. Murley, Director Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this18thday of March 1988 f
l
BARBARA MOLLER'"
i P.O.
Box 163306 -
j
.P.,
Sacramento, CA 95816 (916) 444-3390 August 30, 1988 NUCLEAR REGULATORY BOARD WASHINGTON, D.C.
20555
Dear Nuclear Regulatory Board:
This petition a 10 CFR 2.206 is intended to show cause why the Rancho Seco Nuclear Power Plant located in Clay, California, just twenty-six miles southeast of Sacramento, California should be closed down as a Nuclear Generating Station.
The original petition submitted February 25, 1987 was denied.
As basis for denial the Nuclear Regulatory Commission cited an absence of health and safety issues.
This petition will show the reprehensible and crimminal conduct of the Sacramento Municipal Utility District management, and the flagrant disregard the Nuclear Regulatory Commission imposes on the public citizen when they try to be heard.
On June 24, 1988, I wrote Senator Cranston and expressed my deep concern regarding the poor attempts at management of Rancho Seco; and the utilities continued disregard for the health and safety of their ratepayers and the surrounding communities.
Newspaper articles were sent detailing the continued mismanagement and dis-regard for health and safety.
A 1984 Sacramento Bee article identifies over two billion gallons of radioactive water having been released to that date. (enclosed 7 The records will show that conversion calculations were readjusted by the Rancho Seco personnel between 1980-1984.
The Brookhaven National Labratory was in charge of the investigation.
Neither SMUD nor the Brookhaven National Labratory can honestly say how much radioactive water was released in the period from 1980-1984.
An extensive evaluation by the NRC was done regarding this release, MUREG 12-86, Supplement 1 Section 4.3.
Following this,there came a revision of calculational techniques to determine permissable liquid release levels.
In Mr. Victor Stello's opinion that radioactive releases from Rancho Seco do not contaminate major waterways and agricultural land is only an ooinion.
Radioactive releases are based on a number of l
factors, one of them being, arid terrain.
As water evaporates radioactivity concentrates, basic rule.
The radioactive radionuclides and cesium isotope releases are accumulative.
They have half life, indicating strength and l
length of toxibility.
These facts are verifiable.
l Prior to the March 1988 restart attempt, seven hundred, (700),
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1 gallons of radioactive water was released by a SMUD employee, George Coward.
He was the Assistant General Manager, Nuclear Technical Services.
George Coward was discharged, but he did i
receive a sizable severance pay, $204,000 if terminated on or i
before April 30, 1988.
A copy of his contract with the area
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dealing with severance pay highlited.
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l Under conditions issued by the State Department of Water Res-j ources'there is a drought in California.
The long range forecast does not indicate any change in site.
In a 12/83 California Water Plan, the projected use and available water supplies to q
the year 2010 indicate a problem in the San Joaquin Valley.
The I
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 back.
There is a six (6) percent decrease in the water table, by the year 2010, the overdraft will be 11 percent, almost double.
These waters feed r-ime agricultural land as well as people.
i I interpret this information along with what is known concerning radioactive releases of elements such as cesium and now Tridium I
to indicate increased concentration of radioactivity.
These radioactive elements have a least a thirty (30) year half life.
Victor Stello, in answering one of my letters concerning the purposeful miscalculation, writes directly to Senator Cranston and defended that even though calculations performed by Rancho Seco personnel were incorrect between 1980 and 1984, the Brookhaven National Labratory, in charge of the investigation, stated according to Victor Stello, "that even though conditions for exposure existed offsite, no person was exposed to a dose in excess of EPA limits.
How do they know who svam in Clay Creek or the Consumnes river during the period from 1980-1984.
From the Consumnes the water flows into the San Joaquin in a North-South direction, the width is roughly 150 miles.
The Environmental Protection Agency provides that radioactive release limits are given in terms of public exposure limits, the NRC prescribes release limits in terms of concentration of each radioisotope,and between 1980-1984 the SMUD utility usec' their own dose calculation method.
Mr. Stello defends the utility by stating that the NRC limits can be applied by utility personnel directly, without use of a dose calculation manual.
Please be aware we are talking about radioactive water, cesium isotopes, tridium and other radionuclides, and NOT SMUD, NOR THE NRC, OR THE BROOK-
)
HAVEN NATIONAL LABRATORY CAN SAY FOR SURE HOW MUCH RADIOACTIVE WATER WAS RELEASED.
It was also indicated by Mr. Stello of the NRC, that a low level radioactive vaste disposal site is being developed in California in compliance with the Low Level Waste Policy Amendment Act.
I asked the location of this proposed site, but the only response I received was from a Mr. Kalman, the Project Manager for Rancho Seco.
He told me that the nuclear testing grounds in Nevada was being considered for the dump site.
The purpose of Mr. Kalman's visit was to reassure me the NRC was doing all possible, and they discretion on thep4Rf of could be trusted.
Well I term this a lack of the NRC.
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-r Mr.'Stello-identifies: numerous additional technical 1s, sues, including pipe vall. thickness concerns which are still being. evaluated at Rancho Seco.
He also compares.a number of open issues at Rancho Seco to other nuclear power plants.
PLEASE REMEMBER THAT Three Mile Island, TMI, a nuclear power plant which also had OPEN ISSUES which were not implemented to the date of the accident at TMI..
I will also state that-there is a definite parallel between-Rancho Seco and Three Mile Island.
There are. additional safety flaws 1vhich still plague Rancho Seco.
On initial restart in March of 1988, as SMUD started to warm-up the plant, just-the warmer, and as indicated my a Sacramento Bee article, SMUD couldn't get the plant shut off.
NEXT, was ANOTHER REACTOR LEAK.
Smud defended, the radioactive water was contained, so therefore, nothing was jeopardized.
History shows this is not an isolated incidentc I suggest-SMUD was only LUCKY.
An. increase in pressure caused the leak.
Attachments dated March 11, 1987 indicate dimensional changes.
There are tables of thickness readings of examined pipe.
In this report, letter to John Ward, March 11, 1987, Docket #50-312, are the results of one ultrasonic inspection for the pressurizer support-lugs (report #85-006,85-007, 85-010, and 85-0014) revealed additional indications detected since the 1983 outage.
The in-spection results showed indications close to previous reported dimensional' changes.
The following concerns were unanswered to date of this letter:
1)
Areithese indications growing as reported and if'they are, what is the rate of growth?
2)
If these new indications are fabrication welding indications not detected before, do they require further evaluation to determine why these indications were not detected before.
- This-was an unresolved item pending licensees action relating to the.above concerns and NRC review (50-312/87-03-02).
I would suggest, that dimensional changes have-occurred at Rancho Seco because of l} the history of rapid cooldowns and 2) the theory-and facts concerning the phenomena of embrittlement.
I call your attention to the Sacramento Bee Article, March 17, 1988.
Radioactive steam leak at Rancho Seco.
About 700 gallons spewed from a faulty valve.
l THEY DID A $400 MILLION OVERHAUL, and a NRC spokesman Greg Cook said, "Your going to get leaks and blow gaskets occasionally".
BUT YOU HAVE TO LOOK AT THE MAINTENANCE HISTORY ON THE EQUIPMENT AND DETERMINE WHETHER THE VALVE WAS PROPERLY ADJUSTED.
L i
h *. e? 3.
I will call the Boards attention'to a Sacramento' Bee article of August 1988 which identifies a ROCK COCAINE find at Rancho Seco I
Nuclear Power Plant.
The results of this find was drug testing of the people working where it was found in the warehouse.
Nine people.
ONLY NINE PEOPLE.
My senses are enraged at this LIMITED j
ACCOUNTABILITY.
More than nine people have access to the warehouse area where it was found.
This is not the only drug related incident, either.
The results of the test were (8) people tested negative and (1) tested positive, but not for cocaine.
You can bet the rock cocaine did not get there by itself, and to think these people are attempting to operate a NUCLEAR POWER PLANT.
Drug testing is not an alternative, because the expense would be passed on to the ratepayers.
The SMUD board has already' spent $400 Million dollars of the ratepayers money trying to make Rancho Seco work, and they still have problems.
PLEASE REMEMBER...in 1979, the President's Commission on the accident at Three Mile Island, after study and investigations into the events of that accident and the conditions existing up to the accident, finds and concludes:
"To prevent nuclear accidents as serious as Three Mile Island, fundamental changes will be necessary in the organization, procedures, and practices--and above all in the attitudes of the Nuclear Regulatory Commission and, to the extent that the institutions we investigated are typical of the nuclear industry.
The Commission stated, "The utility that operates a nuclear power plant, must be held responsible for the basic fundamental design and procedures that assure nuclear safety."
There was drug testing, but for only nine people.
THIS IS LIMITED ACCOUNTABILITY, especially for a nuclear power plant.
With the potential of the worst case scenario, and in this case defined
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crimminal activity involving cocaine, and this not being an isolated drug incident, I am petitioning the Nuclear Regulatory Board to put an immediate halt to the operation of Rancho Seco Nuclear Power Plant.
Yours truly, Y
kk
%Uw Barbara Moller
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