ML19290D989

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Responds to Infractions Noted in IE Insp Rept 50-312/79-22 on 791029-1101.Corrective Actions:Temporary Changes to Training Program Procedures Initiated & Annual QA Audit Required
ML19290D989
Person / Time
Site: Rancho Seco
Issue date: 01/22/1980
From: Mattimoe J
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Engelken R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML19290D985 List:
References
NUDOCS 8002290618
Download: ML19290D989 (3)


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SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S Street, Box 15830, Sacramento. California 95813; (916) 452-3211 January 22, 1980 4

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Engelken, Director M " NN//;f [;d

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Nuclear Regulator'. Coumission Q

I *f 1930 North California Bou l e"ri rd g

Walnut Creek Plaza, Suite 202 M

Walnut Creek, California 94396 Re:

NRC Inspection 79-22 Docket No. 50-312 License No. DPR-54

Dear Mr. Engelken:

In replj to your inspec tion conduc ted by 'f r.

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Zwetzig on October 29 through November 1, 1979, we offer the following explanations and corrective actions which wi11 assure full compliance-with the NRC requirements.

Appendix A of your letter indicates three infractions A.

Technical Specification 6.8.1.c states that written procedures shall be established, implemented and maintained covering..survei.11ance and test

'te t ivi t ies o f saf ety re lated equipment.

Techn ica l Spec i f i ca t i on 6. 8. 3. c states that temporary changes to the procedures of 6.8.1 may be made provided (among other conditions) the change is documented, reviewed'by the PRC and approved by the Plant Super.intendent within 7 days of implementation.

Contrary to the above, a temporary change was made to SFAS Digital Channel IB Refueling Test Procedure (SP 203.01B) on November 18, 1978 and the tenporary change was implemented on December 18, 1973.

The temporary change was not reviewed by the PRC and approved by the Plant Superintendent until February 16, 1979, approximately 60 days after completion of the surveillance procedure.

SMID Repp This part icular procedure change was originally presented to the Plant Review Committee on December 22, 1978, during 'tecting No. 575 (Item 9).

At that tiue the committee approved the documented changes, but felt that the reasons for some of the changes needed further clari.fication for documenta-tion purposes As a result the procedure, rather than being forwarded to the Plant Superintendent for approval, was returned to Operations persennel for turther clarification.

Approximately 60 davs elapsed prior to the date the clarified changes were resubmitted to the Plant Review Committee on l'eb rua ry 16, 1979, during Meeting No. 589 (Item 6).

To minimi/m iimilar recurrences, t he Cha irnan of the Plant Review Committee e002290 6 $

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Engelken January 22, 1980 will follow up on temporary changes to assure that pRC recommendations are addressed quickly to insure that temporary changes complete the review through the Plant Superintendent with minimum delay af ter PRC review.

B.

Technical Speci ficat ion 6.8. 3.b s tates that temporary changes to the pro-cedures of 6.8.1 may be made provided (among other conditions) the change is approved by two members of the plant management staf f, at least one of whom holds a Senior Reactor Operator's License on the unit affected.

Con t r:1ry to the above, a temporary change was made to Quarterly fakeup Pump and Valves Inspection and Surveillance Test Procedure (SP 203.02C) on March 8, 1979.

One of the two required approval signatures was that of a control room operator who is not a member of the plant management staff.

SMUD Repl3 The training program for licensed personnel will be reviewed and modified to insure temporary changes to the procedures are adequately addressed during the annual retraining.

Specifically, the intent of temporary changes, time criteria associated with their review, and individuals authorized to initiate said changes will be emphasized.

Since all temporary changes require at least one Senior License signature, this corrective action should be adequate to assure compliance in the future.

C.

Technical Specification 6.5.2.8.b states that audits of facility activities shall be performed under the cognizance of the MSRC.

These audits shall encompass the performance, training and qua:ifications of the entire facility staff at least once per year.

Contrary to the above, the licensee had not audited the qualification of the f acility staf f during the year preceding the dates of the inspection (October 29-November 1, 1979).

SMUD Reply The implementing document used by the District's Ouality Assurance staff to perform audits under the cognizance of the MSRC is OCI No. 2, "SMUD Nuclear Ope cations Qua lity Assurance Audit program."

A specific quality element will ne added to this schedule requiring that the Ouality Assurance staff audit the qualifications of the facility staff at least once per year.

ANSI /ANS 3.1-1978 (Revision of N18.1-1971) will be used to define the audit scope; i.e., qualification of security and administrative personnel will be excluded, but nonlicensed personnel performing activities that affect quality will be included.

The audits related to qualifications of licensed operators and nondestructive

Mr.

R.

II. Engelken January 22, 1980 examination personnel will continue to be performed as scheduled per QCI No. 2.

The change to QCI No. 2 will be initiated inmediately and a personnel qualification audit will be condacted during this calendar ye.ir.

Respectful.ly submitted, t

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'fattimoe t.T J J.

Assistant Gene ral '-!ana ger and Chief Engineer JJM: RWC: JF:j r

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