ML19309H647
| ML19309H647 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 04/23/1980 |
| From: | Walbridge W SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8005130613 | |
| Download: ML19309H647 (7) | |
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'D 8005180 bb Ik eise:uo SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 15830, Sacramento, California 95813; (916) 452-3211 April 23, 1980 Mr. Victor Stello, Jr., Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Stello:
Re:
Operating License No. DPR-54 Docket No. 50-312 Response to Notice of Violation The Sacramento Municipal Utility District hereby submits this letter as its response to the notice of viola-tion appended to your letter of April 1, 1980, which we received on April 8, 1980, as Appendix A.
ITEM A (1)
The District admits the alleged item of non-compliance..One valve in the high pressure injection cross-connect line (SIM-038) was improperly closed from December 17, 1979, through December 27, 1979.
(2)
The noncompliance occurred because operating personnel failed to follow procedures for recording and processing for review a deviation from an established procedure (A.15).
(3)
The following corrective steps have been taken.
1 The Operations Supervisor has reviewed this occurrence with all shift licensed operators as part of a training program, emphasizing the importance of proper valve alignment.
The training program also emphasized the im-portance of the District's existing requirement that a tem-porary procedure change request be completed when any change to an operating procedure is performed.
Administrative Procedure AP.2, " Review, Approval and Maintenance of Procedures," has been revised to require that both licensed operators approving a temporary change be AN ELECTRIC SYSTEM S E R VIN G MORE 1HAN 600,000 fN THE HEART OF C Allf 0 R N I A
Mr. Victor Stello, Jr. Apt'l 23, 1980 individually responsible for initiating a temporary change form for submission to the Operations Supervisor and Plant Review Committee for review and approval.
Additionally, Administrative Procedure AP.23, " Control Room Watch Standing,"
has been substantially revised to require the off going shift to advise the on-coming shift of any valve manipulations of safety-related systems and of any temporary procedure changes performed by the shift.
A log checkoff of each safety system is required prior to shift turnover to assure that each system is reviewed by the oncoming shift.
(4) and (5)
The corrective steps set forth in (3) above were completed before April 17, 1980.
We believe that they brought us into full compliance and will prevent similar items of noncompliance.
ITEM B (1)
The District admits the alleged item of non-compliance.
The capability of the makeup pump, being used as a high pressure injection pump between December 17, 1979, and January 9, 1980, to function as a high pressure injection pump was compromised because manual valves in the nuclear service raw water suction and discharge lines for the makeup pump lube oil and room air coolers were closed.
(2)
The noncompliance occurred because a revision to the locked valve list (SP 214.03) was not reflected in the operating procedure used to place the makeup pump into a safety features system.
(3)
The following corrective steps have been taken:
The operating procedure, AP.15 " Makeup, Purification and Letdown System," was revised to agree with the revised valve configuration as specified in the Locked Valve List SP 214.03.
In addition, the Plant Review Committee Charter has been revised to require the Committee, when reviewing procedure changes, to consider any other procedures that may be affected.
Such considerations are to be documented in the minutes.
Administrative Procedure AP.2, " Review, Approval and Maintenance of Procedures," has been changed to reflect these requirements.
When a procedure change is reviewed, the senior person responsible for the procedure will be responsible for determining which other procedures are affected, and the chairman will specify a date upon which the additional changes must be submitted to the Committee.
Mr. Victor Stello, Jr. April 23, 1980 (4) and (5)
The corrective steps set forth in (3) above were completed before April 17, 1980.
We believe that they brought us into full compliance and will prevent similar items of noncompliance.
ITEM C (1)
The District admits the alleged item of noncompliance.
On January 9, 1980, an operator failed to make a change in a breaker position, thereby leaving a makeup tank isolation valve without a power supply.
(2)
The noncompliance occurred because one of the steps in an approved procedure was not completed.
(3)
The immediate corrective action was to properly position the breakers to supply power to the valve.
The following additional corrective action has been taken.
A review of the Operating Procedure, A.15 " Makeup, Purification and Letdown System", was made, and the procedure was found to be clear and correct.
A District directive was issued by the Nuclear Plant Superintendent on April 14, 1980, effective on that date, making it mandatory that when any safety related system or component, as defined in Chapter 6 of the Final Safety Analysis Report, is removed from, or placed into, service, the operator performing the work will verify the valving and equipment lineups.
- Moreover, as an additional precaution, the District has changed its procedures to require dual verification for safety-related systems and components.
The list of safety-related systems had previously included the High Pressure Injection System, the Low Pressure Injection System, the Core Cooling System, the Reactor Building Atmospheric Cooling System, the Reactor Building Isolation System, and the Reactor Building Spray System.
The Nuclear Service Cooling Water, the Nuclear Service Raw Water, the Diesel Generator, and the Auxiliary Feedwater Systens have now been added to this " safety-related" list.
In addition, the instrumentation associated with the Reactor Protection System and Safety Features System has been included in the " safety-related" list so that independent verification of valving lineups and operability 1
is now required when these systems are removed from, or placed into, service.
The new directive defines " operable" within the context of the Technical Specifications and l
Mr. Victor Stello, Jr. April 23, 1980 serves notice upon all personnel that the Limiting Conditions for Operations and Surveillance Standards, Technical Speci-fications Chapters 3 and 4 must be satisfied when systems are removed from, or returned to, service.
The operating procedures that require dual veri-fication lineups include:
High pressure injection (HPI) A.15 Low pressure injection (LPI) A.8 Core flooding (CFT) 2.4 Reactor building emergency cooling (HVS) A.14 Reactor building isolation A.70 and SP 214.03 (Locked valve list)
Reactor building spray (CBS) A.7 Nuclear raw water (NRW) A.25 Nuclear cooling water (NCW) A.24 Diesel generators (DGS) A.31 Each lineup includes dual signoff sections for the I&C Division to verify instrumentation required for SFAS operation which has been placed in service.
Completed copies of these linaups will be kept in the plant startup folder as a reccrd of proper system configuration.
The above procedures, which include dual verifica-tion of the valve / breaker / instrumentation lineups, were reviewed by the Plant Review Committee on April 19, 1980.
A Special Order explaining the directive and the procedure revisions was issued on April 10, 1980, to all licensed operators.
Training was conducted by the Opera-tions Supervisor on the procedure changes and the Order was explained to all licensed operators on each shift.
(4)
The following additional corrective steps will be taken:
Surveillance procedures will be reviewed and revised to include independent verification of valve / breaker /
i instruments when any safety-related system or component is J
removed from service for testing.
l Those surveillance procedures which require modi-fication are shown below.
The procedures are arranged in three categories:
Monthly, Quarterly, and Refueling Interval, l
together with the scheduled date for the next performance.
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Mr. Victor Stello, Jr. April 23, 1980 The necessary modifications to incorporate the dual veri-fication requirement will be completed prior to the scheduled performance date for all monthly and quarterly procedures listed.
The refueling interval procedures, although not scheduled for performance until 1981, will be revised by October 31, 1980.
1 Monthly Sequence SP No.
Description Date Due 203.02H Monthly HPI Venting P-230A 5/19/80 203.02I Monthly HPI Venting P-238B 5/19/80 203.02J Monthly HPI Venting P-236 5/19/80 203.05F Monthly DHR Venting P-261A 5/4/80 203.05G Monthly DHR Venting P-261B 5/11/80 206.03A Diesel Generator "A" Monthly Test 5/18/80 206.03B Diesel Generator "B" Monthly Test 5/18/80 208.04A Monthly Test of Reactor Trip from Gen /Turb Trips &/or Loss of Main FW 5/9/80 208.04B Monthly Test of Reactor Trip from Gen /Turb Trips &/or Loss of Main FW 5/16/80 210.03A Turbine Steam Stop Valves 5/31/80 Quarterly Sequence SP No.
Description Date Due 203.02A Quarterly HPI Sys.
"A" Loop (P-238A) 7/19/80 203.02B Quarterly HPI Sys.
"B" Loop (P-238B) 7/19/80 203.02C Ouarterly HPI Sys.
"C" Loop (P-236) 7/19/80 203.03 M.U.
& Purif. SFAS Valves
(>48 hr. Cold SD) 7/19/80 203.05A Quarterly DHR Sys.
"A" Loop (P-261A) 7/4/80 203.05B Quarterly DHR Sys.
"B" Loop (P-261B) 5/15/80 203.06A Quarterly DHR-A SFAS Valves 5/18/80 203.06B Quarterly DHR-B SFAS Valves 5/25/80 203.06C/D Quarterly DHR Valve Test
(> 48 hr. Cold SD) 5/15/80 203.07A NSRE Loop A (P-472A) 7/12/80 203.07B NSRW Loop B (P-472B) 7/11/00 203.07C NSCW Loop A (P-482A) 7/12/80 203.07D NSCW Loop B (P-482B) 7/11/80 204.03A Quarterly RBS-A Loop Surveillance (P-291A) 7/5/80 204.03B Quarterly RBS-B Loop Surveillance (P-291B) 7/5/80
Mr. Victor Stello, Jr. April 23, ILJO SP No.
Description Date Due 204.01D Quarterly CBS/NaOH Surveillance (Check Valves) 6/30/80 204.04A RB Cooling SFAS Fans Channel "A"
7/19/80 204.04B RB Cooling SFAS Fans Channel "B"
7/19/80 205.07A Isolation Valve Surv. (Quarterly) 7/11/80 205.07B Isolation Valve Surv. (>72 hr.
HSD or CSD) 7/12/80 205.07C Isolation Valve Surv. (>72 hr. CSD) 7/12/80 207.03A Quarterly Pressurizer Power Operated Valves Surveillance Test 6/30/80 207.03B Quarterly Surveillance of Electro-matic Relief Valve 6/30/80 210.06A Quarterly OTSG Sample Isolation Valve Surveillance 6/30/80 210.10 Quarterly Spent' Fuel Cooling Pump
& Valve Test 6/30/80 210.11 Concentrated Boric Acid System Quarterly Pump and Refueling Check Valve Surveillance 6/30/80 211.01A Emergency Control Room Filter System 7/11/80 Refueling Interval Sequence SP No.
Description Date Due 201.04 Sur. of Spent Fuel Cooling System Refueling 1981 203.01A SFAS Digital Channel lA Refueling Test 203.01B SFAS Digital Channel 1B Refueling Test 203.04A SFAS Digital Channel 2A Refueling Test 203.04B SFAS Digital Channel 2B Refueling Test 203.06E Refueling Interval DHS/CBS Suction Check Valve Surveillance 1
203.08 Core Flooding System 203.09 Decay Heat Removal System Leakage 204.01A R8 Spray System Loop A SFAS Test 204.01B RB Spray System Loop B SFAS Test 204.01C Refueling CBS "A" (B) Stop Check Valve Surveillance 204.02 RB Emergency Cooling System Air and NSCW Flow Verification 204.06 RB Spray Heads Air Flow Test 1983
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Mr. Victor Stello, Jr. April 23, 1980 SP No.
Description Date Due 205.01 RB Integrated Leak Rate Refueling 1981 205.02 Local Component Leak Rate Test 206.01A Biannual Diesel Engine Inspection 1982 206.01B Emergency Diesel Generator Inspection 1981 206.02A Diesel Generator "A" SFAS Start Test 206.02B Diesel Generator "B" SFAS Start Test 207.02A Leak Test of RCS Following the Open-ing of a Mechanical Joint 207.02B Hydro Test of RCS Following a Modi-fication or Wolded Repair 207.03 Testing of Pressurizer Code Safety Valves 208.03 CRD Program Verification 210.01F Refueling Interval Auxiliary Feed-water Check Valve Full Stroke Test 210.02A Main Steam Isolation Valves Sur-veillance Test at Cold Shutdown 210.03B Turbine Steam Stop Valves 210.04 FW Valve Trip on Steam Line Rupture 210.04A Cold Shutdown FW Valves Surveillance Test 211.01B Emergency Control Room Filter System 211.03A RB Emergency Filtering System Loop "A" 211.03B RB Emergency Filtering System Loop "B" (5)
The corrective action set forth in (3) above was completed prior to April 17,~1980.
The corrective action set forth in (4) above will be completed on the dates speci-fied therein or prior to performing the surveillance pro-cedure, as required in the Technical Specifications, whichever occurs sooner.
The District is committed to the safe operation of its nuclear facility.
It does not desire to contest the matters set forth in this Notice of Violation.
It does, however, point out that the violations were discovered through its own management controls, were promptly reported, and that corrective action was initiated prior to issuance of the Notice of Violation.
A check in the amount of $25,000 is enclosed herewith.
Respectfully submitted i
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.~c Wm. C. Waldridge j
U General Manager Encl.