ML19317G885

Requests Util Revise Wording of Tech Specs 4.4.1.3 Re Surveillance Testing of Valve Operability.Time Interval Between Successive Surveillances for Each Surveillance Interval Should Be More Clearly Defined

ML19317G885
Person / Time
Site:	Rancho Seco
Issue date:	04/01/1978
From:	Reid R Office of Nuclear Reactor Regulation
To:	Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8004020545
Download: ML19317G885 (3)

Text

'

~

7 i

s

• Y_

• i=.

DISTRIBUTION:

k..._.[.

April 1, 1978 fiRC PDR L PDR

?

ORB #4 Reading

==i Docket lio. 50-312 VStello

=i KRGoller RWReid GZwetzig ram Sacramento Municipal Utility District ATTit: Mr. J. J. flattimoe OI&E(3)

=-

Assistant General Manager DEisenhut and Chief Engineer TAbernathy -

=

6201 S Street JBuchanan E"

P. O. Box 15830 ACRS(16)

==

Sacramento, California 95813 Gray file

~

^

Gentlemen:

By !!RC Inspection Report dated December 5,1977, you were notified of a violation of Rancho Seco Unit !!o.1 Technical Specification 4.4.1.3 dealing with surveillance testing of valve operability.

T@

As a result of subsequent discussions and correspondence between

~~

S!?JD and the Office of Inspection and Enforcement (01aE), P,egion V, basic resolution of the problem and mutual acireement as to the

==

interpretation of surveillance interval requirenents has been achieved.

In addition, it appears that with the exception of

~

====,

this violation, there has been good agreement in the past between SMUD and GI&E inspectors on the interpretation of surveillance

=

interval requirements.

An issue arising out of the discussion af this violation, however.

is the susceptibility of misinterpretation of the Rancho Seco

=:......

Technical Specifications dealing with surveillance intervals.

E ""

particularly in view of the definition of Time Periods given in F=

Section 1.9.

Specifically, the problem appears to arise because frequency of surveillance is defined in terms of blocks of time rather than in tems of time intervals between successive tests.

E is F

~

Thus, if a given test is required monthly, by the present defini-tion it must be done once during each month; and tests that were i

done on the 30th of one month and one day later on the 1st of P"

=

the followfag morth could be interpreted as meeting the literal technical specification requirements. This, of course, would be

=

clearly defeating the intent of monthly testing - particularly if the next test were perfomed on the 30th of the following month

3..

so that the interval between the 2nd and 3rd tests was almost

((r f j).

two months.

NN

.=

• • h-0 L

= = " =.

=

u.. - ~

i

=

?

D

. u. :: 'in g

ahh O

==

wwawg

'!.Z

..Z.1

i

..;= 1,

['=@

It is noted that Section 4 of the technical specifications states

MQ

~ ~ ~

that Specified intervals may be adjusted plus or minus 25 percent to accomodate norr:a1 test intervals." liowever, even here it is t-not clear how this adjustment would be applied to the Time Periods Wll.l";.

defined in specification 1.9.

It is clear, however, that the f""

present specifications relating to surveillance intervals are ambiguous and susceptible to misinterpretation.

. =...

p This is not to say that the latitude pemitted by the definition has been abused. On the contrary, as noted earlier, with the exception of the noted violation, it appears that the operating staff at Rancho Seco has an excellent record in meeting the intent C-

'l.:.==

of the surveillance schedule. Nevertheless, the possibility of l;;=Z s

misinterpretation remains.

e_..

Accordingly, in order to eliminate the opportunity for misinter-

'i.?.==

pretation, you are requested to propose revised wording for your E

technical specifications which clearly defines the allowable time eu

.=1 interval (+ 257,) between successive surveillances for each surveillance

...==

! ='

frequency., This, of course, would be applicable only to those portions of your technical specifications where the surveillance

!==.

interval is not already explicitly defined.

It is requested that F ="

ycu subait your proposed revised technical specifications within 60 days of receipt of this letter.

J.i:liis

!. :.J....

Sincerely,

[;E cc.egiy r=:==

[?.==

Robert 11. Reid, Chief

=

[

Operating Reactors Branch #4 4E=

Division of Operating Reactors

.... g cc: See next page t:==:=j Ei

=$

).=.

D

"[]

D 9

U

~T.T.?

"0D ~9"T

- - = -

r i

. s J A.

a o

.=:

I9 r

.M ORB 4NR C':N M OR.

l

=

GZwetzia:dn RPAjd

..N..,,

- 311?l1.8...

Thl.l Il.8.--

ouaw NRC TOrat 31s (9 76) Nno! 0240 W un s. oOVERNMENT PRINUNG OFFICES 1,78 = S28 934

.. ~...

...,... ~

t

i....

.c_

Sacramento Municipal ' Utility District

. ;=

k+ ::.;;;_

cc: David S. Kaplan, Secretary and

[

~

General Counsel

"

6201 S Street Post Office Box 15830

=

Sacramento, California 95813

=

Sacramento County

=

Board of Supervisors-827 7th Street

^

Sacramento, California 95814

=

==p

;-+;-.

. ^.';:::f

=

=

j

=

i e

j

.O 1

e Ei!

5 J.~

{l"l,.

=

..... : C;;;

Yl:. ^ ~ ~.

==

• 4:*:

[..h

!"a*.

..J.

=.1:

. iiE}:.

I e.-

,....l.:'e..:::

n.,e C5513.).:

D 11,0.1 DJ

s Y!:......

......-:: =..

2 I

. S

. k f.ru 3

h: E-a

. g...

Ei

- - ^ ~ - - - " ~ ' ~

= - -.. :=::

==

~

q-;;;;;;;:.:

'~-

=. -..

_.. +..

3.;;;,

r

. +.

.-