ML19341C722
| ML19341C722 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/26/1981 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML19341C720 | List: |
| References | |
| NUDOCS 8103040016 | |
| Download: ML19341C722 (4) | |
Text
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@ suun SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Streei, Box 15830, Sacramento, California 95813; (916) 452 3211 January 26, 1981 Mr. R. H. Engelken, Director O
Region V Of fice of Inspection and Enforcement G@
U. S. Nuclear Regulatory Commission 1990 North California Boulevard b ('
4 Walnut Creek Plaza, Suite 202 Walnut Creek, CA 94936 Re: NRC Inspection (80-35)
Operating License DPR-54 Docket No. 50-312
Dear Mr. Engelken:
In reply to the inspection conducted by M. G. Zwetzig of your office on December 8 - 12, 1980, we offer the following explanations and corrective actions to assure full compliance with NRC requirements.
Appendix "A" of your letter notes the following violations:
A.
Section XVlli of Appendix B to 10 CFR 50 states, in part:
"A compre-hensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program t
and to determine the effectiveness of the program."
Contrary to the above, the licensee had not, prior to this inspection, conducted comprehensive, planned and periodic audits in the areas of Control of Special Processes, inspection and Preventive Maintenance i
and had not conducted periodic audits in the area of Document Control to assure that current drawings were maintained at reference locations and that obsolete drawings were removed. Although some audits, such as inservice inspection, dealt with control of special processes and inspection for that area, these quality factors were not regularly l
audited in other areas such as general repai rs and me 'I fications.
l SMUD Reply l
l The District's Quality Assurance Program includes a system of planned and periodic audits to cover all aspects of Appendix B,10 CFR 50 l
requirements.
Currently, there are thirty-eight (38) separate audits to collectively meet the eighteen criteria of Appendix B,10 CFR 50.
The last audit added on November 24, 1980 was Preventive Maintenance.
l 810804 00N q
l-AN E L E C T ft l C SY3TtM S E RVIN G MORE THAN 600,000 IN THE HEART OF C A LIFO R 4
l R. H. Engelken 2
January 26, 1981
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The NRC inspector concluded that specific audits should be con-ducted to clearly identify each criterion. On this basis, the District agrees to add three (3) additional audits specifically dedicated to inspec-tion, Special Processes and Document Control. They are scheduled for completion in the second quarter of 1981.
Full compliance will be achieved by July 1, 1981.
B.
Section 6.8.1 of the Rancho Seco Technical Specifications states, in part:
" Written procedures shall be establis'hed, implemented and maintained covering the act ivi t ies referenced below:
The applicable procedures recommended in Appendix "A" of Regulatory a.
Guide 1.33, November 1972."
Section H.2.a of Appendix "A" of Regulatory Guide 1.33 (Safety Guide 33),
November 1972 recommends preparation of the following procedures (among others):
(20) Infrequent inspection of Reactor Coolant System Pressure Boundry (21) Inspection of Pipe Hanger Settings Section 6.8.2 of the Rancho Seco Technical Specifications states, in part:
"Each procedure...of 6.8.1 above, and changes thereto, shall be reviewed by the PRC. Those matters pertaining to items 6.8.la, b and c, above shall be approved by the Plant Superintendent prior to implementation..."
Contrary to the above, the Inservice Inspection Program for Rancho Seco (B&W Construction Company 1980 Inservice inspection Manual fo r Rancho Seco Unit No.
1, Rev. No. 1, January 15, 1980) which includes procedures for inspection of the reactor coolant pressure boundary and pipe hangers and which had been implemented during the Spring 1980 refueling outage, had r:ot been reviewed by the PRC or approved by the Piant Superintendent.
SMUD Reply The B&W Company inservice inspection Manual for Rancho Seco Unit No. 1 is an integrated inservice inspection Program for the first ten years, supplied by the NSSS vendor. The same basic document, with the latest revisions, is utilized each refueling outage to implement the inspection program.
Prior to 1980 the Cognizant District engineer wrote a Special Test Procedure as the controlling document which outlined and implemented the program.
However, as stated in your audit, this was not done in 1980.
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Mr. R. H. Engelken 3
January 26, 1981 To cssure compliance in the future, rather than utilize a Special Test Procedure each time, a Surveillance Procedure has been written. This surveillance procedure will be the controlling document for the 1981 outage and will be revised as necessary for subsequent inservice inspections. This procedure has been reviewed by the PRC and approved by the Plant Superintendent. We are presently in full compliance with NRC requirements.
Appendix "B" of your letter notes the following deviation:
Section 6.2 of ANSI standard N18.7-1972, l'Administ rative Controis for Nuclear Power Plants", to which you are committed by letter dated September 23, 1976 states, in part:
" Testing of safety-related... components shall be performed in accord-ance with approved wri tten test procedures, which set forth the requirements and acceptance limits."
Contrary to the above, Rancho Seco procedure SP 201.10A, " Safety System Hydraulic Snubbers Surveillance Inspection", does not set forth specific acceptance limits for determining the operability of hydraulic snubbers.
Such speci fic limi ts are needed to properly implement Technical Speci fi-cations 3.12 and 4.14.1.
SMUD Reply The statement " Testing of safety-related... components..." is specifying testing of hydraulic snubbers. The Rancho Seco procedure related to testing is MT 020, " Snubber Functional Testing" and SP 201.108,
" Safety System Hydraulic Snubber Functional Testing", These procedures do have specific acceptance criteria as required in Section 6.2 of ANSI standard N18.7-1972.
Procedure SP 201.10A, " Safety System Hydraulic Snubbers Surveil-lance inspection" is, as stated in the title, an inspection procedure.
The inspection is the mechanism to determine the operability of a snubber.
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In order to clarify SP 201.10A, the procedure will be revised to incorporate the following limits to determine operability.
- 1) The reserve fluid is greater than specified in a table.
- 2) The reserve fluid is lower than specified but the snubber is removed and passes i ts functional test and fluid is added to specifications to assure continued operability.
3)
The reserve fluid is below the specified level, fluid is added to speci fications to assure continued operability, and the inspection frequency increased according to the Technical Specifications.
o.
Hr.
P,. H. Engelken 4
January 26, 1981 Full compliance will be achieved by February 28, 1981.
Respectfully submitted,
. btA.
J. J. Mattimoe Assistant General Manager and Chief Engineer JJM:RWC:rm Sworn to me and subscribed before me d
thisj/
day of January' 1981-
" " " * " ' * " " * " " "L SEAL OFFICIA PATR:CI A K. GEISLER "b.,.
NOTAwf H,:3UC-Calif M:A e
y VRINCIFt.l t$FICE lN 8
sAcRAr.ic Nro county My Commission Empires f4ovember 22.1983 l
Notary PubfIc
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