ML19309A218
| ML19309A218 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/06/1978 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| Shared Package | |
| ML19309A219 | List: |
| References | |
| NUDOCS 8003260921 | |
| Download: ML19309A218 (3) | |
See also: IR 05000312/1977016
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
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REGION V
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SUITE 202 WALNUT CREEK PLAZA
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1990 N. CALIFORNIA BOULEVARD
WALNUT CREEM, CALIFORNIA 94595
JAN
6 1978
Docket No. 50-312
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Sacramento Municipal Utility District
P.' O. Box 15830
Sacramento, California 95813
Attention: Mr. John J. Mattimoe
A sistant General Manager
and Chief Engineer
Gentlemen:
This refers to your letter (undated) which was received by this office
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on December 27, 1977, in response to two noncompliance items identified
in our letter dated December 5,1977. We have carefully evaluated the
comments provided by you regarding each of the items of noncompliance
cited in our Notice of Violation of December 27, 1977, and determined
that the positions stated in response to both of the items are inconsis-
tent with NRC requirements.
Our position with regard to each of the two items is as follows:
1.
Surveillance Intervals
Your letter contends that the technical specifications allow
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quarterly surveillance tests to be completed anytime within the
calendar quarter, with a tolerance of + 25%.
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Your technical specifications require certain surveillance tests
to be done either " quarterly".or "every three months." The term
" quarterly" is further defined as "a time period of three
calendar months spaced to occur four times a year." It is our
position that "three calendar months" or " quarterly" means that
each surveillance test is due approximately 90 days following
performance of the previous test.
Section 4 of your technical
specifications permits this interval to be "... adjusted plus or
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Sacramento Municipal Utility District
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M 6 1978
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minus 25 percent to accommodate normal test schedules." Therefore,
our position is that the interval of over six months between two
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three-month tests was excessive and was in noncompliance with
the quoted technical specification requirement.
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2.
Abnormal Degradation
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Your technical specifications and Paragraphs C.2.a(3) and C.2.b(4) of
Regulatory Guide 1.16 require " abnormal degradation" of systems "de-
signed to contain radioactive material resulting from the fission
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process" to be reported to the NRC. Examples of abnormal degradation
are given, and a note under each paragraph excludes leakage from
valve packing or gaskets (within the limits for identified leakage).
You contend in your letter that the cracked socket weld in the decay
heat system did not represent abnormal degradation since allowable
leakage for the system was not exceeded.
Regulatory Gude 1.16 does not indicate any exception from reporting
requirements for cracks observed in systems designed to contain radio-
active material resulting from the fission process, even though the
resulting leakage is within limits for identified leakage. To further
clarify the intent of this requirement, it is our postion that
" abnormal degradation" includes the following:
a. Leakage in any amount through a pipe wall, weld,
valve body, or other boundary designed to be
impermeable.
b. Detected cracking, deformation, or other defects-(e.g.,
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revealed by ultrasonic examination) which could be
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indicative of incipient failure, even if these defects
are not through-wall.
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Consistent with the above, it is our position that the cracked socket
weld in your decay heat system, which you discovered on October 28,
1977, should have been reported to the NRC. As noted in your
letter, paragraph C.2.b(4) of Regulatory Guide 1.16 relates to
this requirement.
Your failure to submit the required report is
in noncompliance with paragraph 6.9.1 of the technical
specifications.
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Sacramento Municipal Utility District
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JANj 5 1978
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Our notice dated December 5,1977 was sent to you pursuant to
the provisions of Section 2.201 of the NRC's "Rtiles of Practice,"
Part 2, Title 10, Code of Federal Regulations.
In view of the
above and in keeping with Section 2.201, we request that you
submit to this office, within twenty (20) days of your receipt
of this letter, a written statement or explanation in reply
including (1) corrective steps which have been taken by you with
regard to each of the two items of noncompliance and the results
achieved; (2) corrective steps which will be taken to avoid
further violations; and (3) the date when full compliance will be
achieved. Your corrective actions related to degradation of 'the decay
heat system described above should include submission of an appropriate
Licensee Event Report.
Should you have further questions concerning this matter, we will be
glad to discuss them with you.
Sincerely,
h,.gcG_b
R. H. Engelken
,
Director
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