ML19332B993

Responds to NRC Re Violations Noted in Insp Rept 50-312/89-13.Corrective Actions:Potential Deviation from Quality Initiated to Document Tripping of Emergency Diesel Generator on Overspeed

ML19332B993
Person / Time
Site:	Rancho Seco
Issue date:	11/17/1989
From:	Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AGM-NUC-89-226, NUDOCS 8911220166
Download: ML19332B993 (3)

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! SACRAMENTO MUNICIPAL UTIUTY DISTRICT D 6201 S Street, P.o. Box 15830 Secremento CA 95852-1830,1916) 452 3211-AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA 1

'AGM/NUC'89-2'26 b

LNovembsr 17,fl989

'U. S. Nuclear Regulttory Commission

-Attn:

Document Control Desk

Hashington', DC ?.0555 I

Docket No.a50-312-.

h Rancho Seco Nuclear Generating Station 4

License No. DPR-54L J

. RESPONSE TO NOTICE OF VIOLATION'89-13

' Attention': ' George'Knighton j

20n 0ctober 18, 1989'the Sacramento Municipal Utility District received a Notice of Violation concerning activities at the. Rancho Sete Nuclear Generating Station.. In accordance.with 10 CFR 2.201, the District provides

the' enclosed response =to this violation.

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This;1etter. acknowledges the violations cited and describes.the. District's 1

Lintended. corrective.a:tions. Members of your staff with questions requiring ~

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- additional information or' clarification may contact Mr. Bob Jones at (916) 452-3211', extension 4675.

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Sinderely,-

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Dan'R. Keuter M

4 Assistant General Manager l

Nuclear El R

Enclosure 1

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J. B. Martin, NRC, Walnut Creek A..D'Angelo, NRC, Rancho Seco j

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I220166.691117 9.

ADOCK 05000312 g

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, ; C RANCHO SECo NUCLEAR GENERATING STATloN D 14440 Twin Cities Road, Heraki, CA 95638 9799;(209) 333-2935-

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_, 3 DISTRICT RESPONSE,TO NOTICE OF VIOLATION 89-13 NRC-STATEMENT OF VIOLATION.

A.

Technical Specification 6.8.1_ states, in part:

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" Written procedures shall be established, implemented and maintained covering... the applicable procedures recommended in Appendix "A" of 8

' Safety Guide 33, November 1972."

Safety Guide 33, November.1972, Appendix A states, in part, that Administrative Procedures.shall be developed to assure procedure adherence h

and temporary change trethods when procedures cannot be followed.

Procedure, RSAP-1308, " Potential Deviation from Quality," Section 5.3.4, states:

-i "The originator shall deliver the Potential Deviation.from Ouality 4

(PDQ) report to the Operations Technical Advisor-(OTA) within four (4) hours from the time of identification."

Contrary to the above, on August 17,.1989, a PDQ reporting that the "B" Bruce GM Emergency Diesel Generator failed a surveillance test due to an

" unexpected malfunction of plant equipment" was not written and delivered

.to the OTA within 4' hours of identification.

This is a repeat Severity Level IV violation (Supplement I).

. DISTRICT RESEQNSI N

1.

-Admission or denial of alleged violation:

The District acknowledges that the above occurred.

2.

Reason for the violation:

On August 17, 1989, Operations declared the 'B' Emergency Diesel Generator (EDG) incperable while they conducted Surveillance Procedure SP.56B "'B Bruce GM Monthly Operability Surveillance." At approximately 2240 hours0.0259 days <br />0.622 hours <br />0.0037 weeks <br />8.5232e-4 months <br />, while conducting the test, the 'B' EDG tripped due to an apparent overspeed condition. The operating. crew conducting the test intended to initiate a PDQ;

'however, the PDQ was not processed.

With regards to the requirement to submit the PDQ to the Shift Supervisor within a hours of identifying the problem, the following consideration should be made. The intent of getting a PDQ to the Shift Supervisor within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is so that he can review the PDQ to determine the impact of the situation on the operability of equipment and determine whether the situation is reportable pursuant to 10 CFR 20, 10 CFR 50.9(b), 10 CFR 50.72, 10 CFR 50.73, l

10-CFR 73.71, 10 CFR.100, or 10 CFR 140.

In this case, the cashift operating crew was conducting the s'/rveillance test and, therefore, had immediate knowledge of the impact cf the 'B' EDG trip on the plant as well as the l

potential for meeting any reporting criteria.

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wa DISTRICT:RESPON$1 (continued) e 3.-

Corrective' actions taken and~results achieved:-

At, approximately 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> on. August 18, 1989,-the cognizant

. systems engineer initiated'a PDQ (PD0 89-631)'to document the 'B' -

EDG: tripping on overspeed. As part of the disposition to the_PDQ, the systems enginee'r initiated a work request to perform a visual-inspection of the overspeed trip mechanism._

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' The inspection iridibated that the overspeed switch actuator arm:

' roller ^was. worn and that;the pivot point of.the switch assembly had

_ appreciable play.

The interim corrective-action was to adjust' the

overspeedJassembly such that it will remain functional until the overspeed switch assembly is replaced.-

The DistrictLreviewed a similar violation identified in NRC Inspection Report 88-33.

In that situation, the cognizant individuals recognizea the need to initiate a PDQ but were unaware of the requirement to' submit the PDQ to the Shift Supervisor within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

In this case, the cognizant individuals. did not process-the PDQ properly in order to meet the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time requirement.

It does not appear that these two violations have a common cause or are indicative of a trend.

4. -

' Corrective actions to avoid further violations:

The Shift Supervisors have reviewed-this Notice of Violation (NOV)

-with their' crews. This discussion emphasized the requirement.and~

the'.importance of delivering PDQs to.the Shift Supervisor within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after identifying a problem.

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_The AGM,- Nuclear issued a site-wide memo emphasizing the importance of initiating.a PDQ to document potential problems.

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Date when full compliance will be achieved:

The NOV-was discussed with all operating crews by November 10, 1989.

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