ML19338G087

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Responds to NRC 800410 Request for Amend Re Proper Definition of Term Operable.Discusses Tech Specs 3.3.2, Specifically Written to Prevent Safety Sys Single Failure Criteria
ML19338G087
Person / Time
Site: Rancho Seco
Issue date: 10/20/1980
From: Mattimoe J
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
TAC-43042, NUDOCS 8010280426
Download: ML19338G087 (2)


Text

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esuuo SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S Street, Box 15830, Sacramento, Cahfornia 95813; (916) 452 3211 October 20, 1980 Director of Nuclear Reactor Regulation Attention:

Mr. Darrell G. Eisenhut, Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D.-C.

20555 Docket 50-312 Rancho Seco Nuclear Gerterating Station, Unit 1

Dear Mr. Eisenhut:

Your letter to "All Power Reactor Licensees" dated April 10, 1980 requested the District to submit a license amendment concerning the proper definition of OPERABLE.

The problem identified the term OPERABLE as it applied to the single failure criteria for safety systems.

The purpose was to clarify the meaning of the term and to request licensees to take specific actions to assure that i t was applied to the facili ties.

During the licensing process, this problem was addressed for Rancho Seco and the Technical Specifications, Section 3.3.2, was specifically wri tten to prevent the stated problem.

Section 3.3.2 states:

" Maintenance shall be allowed during power operation on any component (s) in the high pressure, low pressure, nuclear service cooling and raw water cooling, Reactor Build-ing spray, or Reactor Building emergency cooling systems, the core flooding system pressure instrument channels er BWST level channels, which will not degrade safety features system A or B below the level of performance with the single subsystem removed from service.

In the context of this specification, a safety features system consists of the jplh following subsystems: high pressure injection, low pressure injection, Reactor Building emergency air cooling, Reactor Building spray, diesel generator, nuclear service cooling

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water and nuclear service raw water.

If the system being repaired is not restored to meet the requirements of speci-

/O fication 3.3.1 within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed i

in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

If the require-ments of specification 3.3.1 are not met within an addi tional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown cen-di tion wi thin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

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Darrell G. - Eisenhut October 20, 1980

'The key phrase in the specification is "...which will not degrade safety features system A or B below the level of performance with the single subsystem removed from service." The intent of the-restriction is to pre-vent removal of mui s' ole equipment or redundant components which your letter recognizes exists in other facilities or units that have STS.

Mr. R. Colombo on my staff originally contacted your office on May 23, 1980 and explained this compliance with Mr. D. Garner our Project Leader.

It was understood at tha t time that the NRC would study our posi tion and, if a license amendment was still required, we would be notified.

W Mr. Garner notified R. Colombo on October 3,1980 that a written response would be necessary to close out this issue.

I consider this letter to resolve your request of April 10, 1980.

Sincerely,

. )LL

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. J. Mattimoe Assistant General Manaler and Chief Engineer JJM:RWC:jr

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