ML20237B385

Confirms That Current Insp Issues Identified in 871120 Ltr Ack by Util & Being Resolved in Most Expeditious Manner Possible.Updates Will Be Provided to NRC of Progress in Resolving Selected Issues for Review

ML20237B385
Person / Time
Site:	Rancho Seco
Issue date:	12/09/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
GCA-87-808, NUDOCS 8712160228
Download: ML20237B385 (5)

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SACRAMENTO MUNICIPAL UTILITY DISTRICT C P. O. Box 16830, Sacramento CA 95852-1830,(916) 452-3211 i AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA l

I DEC 0 91937 3 l GCA 87-808' 3 MA mzo i

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U. S. Nuclear Regulatory Commission 20<

Attn: J. B.' Martin, Regional Administrator > < $ f Region V Office of Inspection Enforcement 's 1450 Maria Lane, Suite 210 w Walnut Creek, Ca 94596 (A DOCKET NO. 50-312 RANCHO SECO NUCLEAR GENERATING STATION LICENSE NO. DPR-54

SUBJECT:

TIMELY RESOLUTION OF CURRENT INSPECTION ISSUES

Dear Mr. Martin:

l This letter is written to confirm that the current inspection issues identified in your letter dated November 20, 1987 are acknowledged by SMUD and are being resolved in the most expeditious manner possible. It is our intention to provide periodic and timely updates to the NRC of our progress in resolving these selected issues in order to assure adequate time l is provided for your review.

Based on current status of the TDI Diesels, the projected plant restart date is January 20, 1988. Should any other issue arise that would further delay our restart, we will inform your staff promptly. Communication between our respective staffs regarding priority issues or other items of concern is essential for achieving our goal for a safe restart of Rancho Seco.

RESPONSES TO CU'RRENT INSPECTION ISSUES:

1. POST ACCIDENT SAMPLING SYSTEM: It is our understanding that performance problems experienced during testing of the PASS system are not expected to be resolved until January 7, 1988, one week prior to your current restart date. This raises serious concern whether we can perform our inspection to confirm PASS operability without causing a schedular impact.

8712160228 871209 PDR ADOCK 05000312 G PDR JFc/

RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935 xfg

. 3 J. B. Martin DEC 0 91987 GCA 87-808 RESPONSE: The District vould like to clarify the status of the PASS concerns. The testing conducted to date on the PASS has demonstrated its capability to obtain a Decay Heat System sample and a Reactor Building gas sample. Performance problems have been identified with the ability of the PASS to properly degas a pressurized reactor coolant sample. An upgrade to the degassing capability of the PASS is currently being installed. The present i PASS schedule forecasts the completion of this upgrade and l functional testing of the capability by mid-December 1987. I Performance of the six cycle operability tests are forecast to be completed by the first week of January 1988. This will complete i the performance testing on PASS with the exception of the final i

, high temperature / pressure test to be conducted at approximately l 15% full power.

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2. PROCUREMENT: Region V inspections, as well as the second ASTRP inspection in October, 1987, identified potential weaknesses in warehouse segregation of safety related material.

The NRC needs to better understand your perspective as to the extent quality assurance requirements for procurement, storage, and handling of safety related material were met at Rancho Seco from initial construction to the present. The potential for non-safety components to have been inadvertently used in safety-related applications in the plant is of primary concern.

RESPONSE: A presentation was made to Region V on November 24, i 1987 in Walnut Creek, California. The issues identified above i were addressed during this meeting with the Materials Management '

Agenda consisting of:

- A193 B7 Bolting Issue l

- Assessment of Past Practices

- Materials Management Action Plan I This presentation provided the District's response to the NRC l concerns noted in the subject letter. The presentation noted that, while there is much left to do, our investigation concluded that we have no indication of improper materials being utilized in safety grade applications that would jeopardize the safety of the plant. As part of our program to upgrade the procurement and materials controls program at Rancho Seco, we are remaining alert to any such indications.  !

3. EMERGENCY OPERATING PROCEDURES: NRC Inspection 87-34 determined that SMUD had not justified deviations from the latest generic technical basis document used for the emergency operating procedures, and that the NRC had not been kept informed of SMUD's changes in technical basis for cne confirmed by NRC to one unapproved by the NRC.

. s J. B. Martin E O9 C GCA 87-808 We understand that SMUD will provide justification for all deviations from the generic technical basis for the emergency operating procedures (less their associated transient cooldown procedures) by November 30, 1987.

It is also our understanding that SMUD intends on providing justification for the transient cooldown procedure deviations ,

promptly, but not necessarily prior to restart. The NRC is still l reviewing the acceptability of delaying this action until after restart at Rancho Seco, as well as the acceptability of the new l technical basis.

RESPONSE: The District provided in a November 20, 1987, submittal to the NRC a comparison of the Emergency Operating Procedures (EOP's, consisting of series rules) to the generic Technical Basis Document (TBD) and a justification of differences. The I submittal also included a comparison of the Cooldown Procedures (CP's) to the site specific ATOG, a justification of differences, l and an analysis which demonstrates proper interfacing of EOP's and CP's. CP's were compared to ATOG because they were written from ATOG and have been revised only slightly to assure proper interface and consistency with changes made to the EOP's procedures and rules due to TBD upgrades. The NRC has indicated that the TBD is an acceptable basis for the EOP's for restart of Rancho Seco. Additionally, any concerns relative to the TBD will be dealt with in a generic basis and would not be Rancho Seco restart items. This position was stated by NRR in a telephone conversation between NRR, Region V and SMUD on October 19, 1987.

It is also our understanding based on the October 19 conversation that the NRC (Region V and NRR) indicated that resolution of any restart EOP item would be required prior to criticality. We are tracking these items in our Restart Scope List.

4. TEST PROCCDURE AVAILABILITY: The NRC expects that a reasonable period of time be available for our review of major test procedures prior to performance. The procedures requested i include: the loss of off site power test; hot functional testing; l all integrated ICS and EFIC testing; initial criticality; and power ascension testing, including reactor trip testing.

Typically, for a new construction facility, test procedures are expected to be available for our review at least 30 days prior to use. SMUD provided only several days for NRC review of the loss of off site power test prior to its start. As a result, the NRC is currently commenting on this test while it is being l performed. It is possible that the NRC may find that certain additional loss of off site power testing may need to be performed after the procedure review is completed.

J. B. Martin DECO 9 im GCA 87-808 ,

We understand that in the future SMUD intends to provide a copy of the approved test procedures for the remaining tests indentified above at least five working days prior to the scheduled start of the test to Region V and NRR. This period is understood to be the time that the test procedure is in the possession of NRR and Region V. (The NRC recognizes that l additional minor editorial or technical changes to the procedure may occur in this interval.)

RESPONSE: The District recognizes the NRC's desire to have major test procedures available for review prior to their performance.

As discussed at the meeting held on November 24, 1987, the ,

District agreed to strive toward a goal of having approved 1 copies of the major test procedures available for NRC review at i least five days before their performance. As mentioned above, 1 our schedule is undergoing daily scrutiny to assure our restart is achieved on time. Although this may make meeting this request difficult for every test, every effort will be made to j assure you have sufficient time for your reviews. l i

5. RESTART SCOPE LIST CONCERNS: Region V recently reviewed a sample of the problems identified by SMUD on its Long Range Scope List. This review, documented in Inspection 87-30, concluded  ;

that SMUD has appropriately deferred these items until after l

restart. Since that review, Region V has learned that about 300 additional items have been added to the list which we reviewed.

This is of concern to the extent that some items may have been reclassified from the Restart Scope List to the Long Range Scope l List. In addition, Region V intends to review the actions taken l on the findings of the Expanded Augmented System Review and Test  !

Program conducted by SMUD as a special category, in greater I detail, in a future inspection.

We understand that SMUD will provide Region V with updates of the Restart Scope List and Long Range Scope List changes, including all additions and deletions, as substantive changes occur. In addition, Region V requests that SMUD clearly identify the status of all EASTRP findings as soon as possible so that we may review this status prior to restart.

RESPONSE: At the same presentation noted in Response #2, the issues identified above were addressed within the Scheduling and Outage Management Agenda. This agenda consisted of:

- Schedule Overview

- Restart Scope List Update

- Long Range Schedule

J. B. Martin GCA 87-808 In addition, the District agreed to provide Region V with a monthly update of the Restart Scope List and changes to the Long Range Scope List. This submittal was transmitted to Region V on Ncvember 30, 1987.

Our goal is a safe restart of Rancho Seco. As we approach our final milestones, interaction between the District and the NRC is recognized as critical. Please contact me if you have any questions on these or other matters. Members of your staff requiring additional information or clarification may contact Steve Crunk at (916) 452-3211, extension 4913.

Sincerely, Ypb kMn Gf Carl Andoghini Chief Executive Officer Nuclear cc: G. Kalman, NRC, Bethesda A. D'Angelo, NRC, Rancho Seco F. J. Miraglia, NRR, Bethesda l

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