ML20248D461

Responds to 890906 Request for Assessment of Util Compliance W/Ol & Associated Programs & Commitments,Per 10CFR50.54(f). Staffing Requirements for Emergency Preparedness Will Not Be Violated & Future Shortfalls Will Be Remedied

ML20248D461
Person / Time
Site:	Rancho Seco
Issue date:	09/13/1989
From:	Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
AGM-NUC-89-105, NUDOCS 8910040270
Download: ML20248D461 (3)

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$ACRAMENTo MUNICIPAL UTttlTY DISTRICT c) 6201 S Street. P.O. Box 15830 sacrame o C59385L1830. (916) 452-3211 AN ' ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA AGM/NUC 89-105 M M2 : 5 7 September 13, 1989 U. S. Nuclear Regulatory Commission Attn: J. B. Martin, Regional Administrator 1450 Maria Lane, Suite 250 Halnut Creek, CA 94596 j Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 10 CFR 50.54(f) LETTER DATED SEPTEMBER 6,1989

Dear Mr. Martin:

In your letter dated September 6,1989, you directed that, pursuant to 10 CFR 50.54(f), we provide an assessment of the District's compliance with the Rancho Seco Operating License and associated proarams and commitments and with the commitments in the District's letters dated oune 7, 21 and 30,1989, and in the August 29, 1989 meeting between members of the District and NRC staffs.

The scope and intent of your request with respect to the District's

" commitments in other program areas" is somewhat unclear. In our letter of Jtine 30,1989 and at our meeting with the NRC Staff on August 29,1989, we described the District's efforts to review its commitments as they might be affected by the potential alternatives of plant divestiture / restart and closure / decommissioning. While it was recognized and agreed that the ongoing uncertainty in plans for the plant makes commitment management difficult, we proposed to provide the NRC with our commitment evaluation and justifications for any deferrals and deletions. The District will evaluate its commitments accordingly and submit this evaluation to the NRC on or before November 30, 1989. In the meantime I have issued a Stop Hork Order on destaffing until this review is completed.

As a result of the action of the District's Board of Directors on September 11, 1989, the closure / decommissioning path is being pursued for Rancho Seco.

Because of this action, the District intends to submit an application for a Possession Only License Amendment.

I As Assistant General Manager, Nuclear, my ongoing assessment of the District's q compliance with its operating license and NRC regulations applicable to the j Rancho Seco Nuclear Generating Station must of necessity be based upon information provided to me from a variety of sources, covering a variety of activities and a range of time periods. My information, while sufficiently )

' redundant, diverse, and plentiful to enable me to form a judgment with j reasonable assurance, can never, as you must appreciate, be perfect at all i l times with respect to all things. 8910040270 a90913 l PDR ADOCK 05000312 l p PNV a i l

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, To ensure that you are not misled and that you do not inappropriately rely upon this response to your September 6, 1989,l letter, I want to be careful to

l. describe _ for you the bases upon which I have relied in reaching my conclusion.

First, since your letter states that it was inspired by an NRC staff emergency preparedness inspection completed on September 1, 1989, I have asked my staff to address the issues raised in NRC Inspection Report 89-14. My letter to you of September 11, 1989 on the Emergency Preparedness Action Plan describes the i District's program to investigate and correct the identified deficiencies. In

(. addition, on September 1, 1989, we issued a Stop Hork Order on head removal and fuel movement activities until it is demonstrated that the Emergency Response Organization is staffed with adequately trained and qualified personnel and that a plan is in place to assure proper staffing of the ERO will continue. Additionally, we will complete a makeup Health Physics drill before entering Refueling Mode. He will also withdraw our request for waiver on our annual exercise currently scheduled.for Dacember.

Second, I asked my Manager, Nuclear Quality and Safety, and my Manager, Nuclear Licensing, to review again available documentation of the results of recent QA audits and NRC inspections of the District's performance at Rancho Seco in order to identify any current noncompliance with the license or applicable NRC regulations which have not been addressed in our ongoing reporting system.

Third, I convened a special meeting of my managers to determine if they have any material information which would bear upon my response to your letter.

As a result of the above activities, I am not aware of any present violations of applicable NRC regulations or the operating license for Rancho Seco other than those noted in NRC Inspection Report 89-14 and those already reported.

He have identified, however, a reduction in the training program which is inconsistent with the current USAR description. As a result,'I have directed that the training program promptly be restored to an appropriate level. I must caution, of course, that assessment of compliance in many areas requires the exercise of judgment and interpretation, over which reasonable people may i differ.

I believe increased management awareness and emphasis on compliance with the license and regulations continues to assure the protection of the health and safety of the public. The recent NRC staff inspection appropriately points out that staffing requirements will present a continuing challenge for the plant. I can assure you that the District will not willfully or intentionally violate the staffing requirements for emergency preparedness, and that any future shortfalls will be remedied as promptly as practicable. In turn, it is our hope that the NRC will give prompt attention to the District's upcoming request to revise the emergency plan to permit staffing flexibility while not reducing effectfeeness, and to future requests to review emergency plans to meet the actual poteitial hazard present at the plant. In addition, I would lock forward to discussing these matters personally with you.

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' Members of' yourL staff. with questions. requiring additional .information.or clarification may contact Steve Crunk at (209) 333-2935, extension 4913...

Sincerely,

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Dan R. Keuter Assistant General Manager Nuclear cc: -G..Kalman, NRR, Washington, DC' A. D' Angelo, NRC,' Rancho Seco Document Control' Desk, Washington DC

' State of California SS County of Sacramento Dan R. Keuter, being ~first duly sworn, deposes and says: that he is Assistant Gene.ral Manager, Nuclear of Sacramento Municipal Utility District (SMUD),. the licensee herein; that he has executed the foregoing document; that the statements made in.this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to eaccute this document on behalf. of said licensee.

Dan R. Keuter

. Assistant General Manager Nuclear Subscribed and affirmed to before me on this I3 dayofkdlDbC4 , 1989.

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Traci L. Gordon Notary Public

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