ML19341C719

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in IE Insp Rept 50-312/80-35. Revised Response Acceptance Limits for Empty Snubber Reservoirs Required
ML19341C719
Person / Time
Site: Rancho Seco
Issue date: 02/13/1981
From: Crews J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Mattimoe J
SACRAMENTO MUNICIPAL UTILITY DISTRICT
Shared Package
ML19341C720 List:
References
NUDOCS 8103040007
Download: ML19341C719 (2)


See also: IR 05000312/1980035

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION V

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1990 N. CALIFORNIA BOULEVARD

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SUITE 202, WALNUT CREEK PLAZA

WALNUT CREE K. CAllFORNIA 94508

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Docket No. 50-312

Sacramento Municipal Utility District

P. O. Box 15830

Sacramento, California 95813

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Attention: Mr. John J. Mattimoe

Assistant General Manager

and Chief Engineer

Gentlemen:

Thank you for your letter dated January 26, 1981, informing us of the steps

you have taken to correct the items which we brought to your attention in

our letter dated January 8, 1981. Your corrective actions with regard to

the items described in the Notice of Violation (Appendix A to our letter)

will be verified during a future inspection.

Your response to the Notice of Deviation (Appendix B to our letter), while

addressing most of our concerns regarding acceptance limits for snubber

visual inspection, does not, however, address one important condition

identified during the recent inspection and at the exit meeting. This is

the condition where the snubber fluid level is extremely low such that the

reservoir is completely empty (Grinnell type snubbers) or the indicator rod

is not visible (Bergen-Paterson type snubbers). For this condition, it is

our position that such a snubber is inoperable within the meaning of Technical Specification 3.12 until a functional test has demonstrated its operability

and the snubber has been reinstalled, or until an operable replacement of

appropriate design has been installed. The reason we assume such a snubber

to be functionally inoperable is because of the possible entry of air into

the operating cylinder.

Whether the snubber is inoperable for the purpose of determining the visual

inspection interval would depend upon the results of the functional testing

and when it was performed:

If it were determined by functional testing to

be fully operable in the "as found" condition, it would not have to be defined

as inoperable for the purpose of determining the visual inspection interval.

Conversely, if operability were established by functional testing following

any alteration of the "as found" condition, the snubber would be considered

inoperable for the purpose of determining the visual inspection interval.

In either case, however, as stated above, if the snubber reservoir is empty

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Sacramento Municipal Uti?ity District

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or the indicator rod is not visible it is our position that the snubber is

inoperable within the meaning of Technical Specification 3.12 until a

functional test has demonstrated its operability and it has been reinstalled

or an operable replacement of appropriate design has been installed.

Accordingly, with regard to the Notice of Deviation which was initially sent

to you on January 8,1980, please provide to this office within ten days

of receipt of this letter a revised response which incorporates appropriate

acceptance limits for snubbers where visual examination reveals an empty

reservoir or where the indicator rod is off-scale.

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Should you have any questions concerning this letter, we will be glad to

discuss them with you.

Si cerely,

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J L

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Reactor perations and Nuclear

Support Branch

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