ML19344B386
| ML19344B386 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 09/03/1980 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML19344B385 | List: |
| References | |
| NUDOCS 8010090187 | |
| Download: ML19344B386 (6) | |
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' SACRAMENTO MUNICIPAL UTILITY DISTRICT-O 6201 's street, Box 15830. sacramento, Californir 95813; (916) 452-3211
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. Ud k September 3.1980
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%f Mr. R. H. Engelken, Director U.S. Nuclear Regulatory Commission Region V-1990 N. California Boulevard Suite 202, Walnut Creek Plaza Walnut Creek, CA 94596
Dear Mr. Engelken:
NRC Management Inspection of Rancho Seco Docket No. 50-312 l-The District on August 6,1980 submitted a response to the
-apparent items of noncompliance as requested by your letter of July 6, 1980. The District requested additional time (45 days) because of the magnitude and complexity.of the corrective actions.
We are now submitting the items that were deferred. 'The five items of apparent noncompliance are submitted as Attachment No.1.
They are--identified in relation to your alpha numerical identification-system. The item under Notice of Deviations is included as Attachment No. 2.
With the submittal of this letter, all ~ items identified in your July 16, 1980 letter are addressed.
Should you have any questions concerning our response we will provide clarification regarding our position.
t Sincerely yours, b.. fh S J. Mattimoe
- Assistant General Manager and Chief Engineer Attachments - 2
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ATTACHMENT NO. 1 NOTICE OF VIOLATION B.
Technical Specification-6.5.1.6.e states that the PRC be responsible for " investigations of all violations of the Technical Specifications and shall prepare and forward a report covering evaluation and recom-mendations to prevent recurrence...."
Contrary to the above, as of this inspection the PRC did not review or investigate, or have under their cognizance a subgroup or some other group review or investigate NRC reported violations of Technical Specifications. An example is the three violations reported in IE Inspection Report 50-312/79-22 of December 27, 1979.
Resconse The District had interpreted Technical Specifications 6.5.1.6.e to involve all internal violations of the license.
The Plant Review Comnittee through internal procedures investigates reported violations.
The Management Safety Review Committee has pre-empted the PRC to review the NRC and Quality Assurance reported violations because of the seriousness contributed to such audits. This review is conducted as specified under TS Section 6.5.2.7.e and is the vehicle to the MSRC to be informed of NRC cited violations and require such corrective action to De dictated from upper management. The District is in full compliance with this interpretation of the operating license.
E.
Technical Specification 6.8.1 requires written procedures be established and maintained covering designated activities including the applicable procedures recommended in Appendix A of Regulatory Guide-1.33, November 1972.
2.
Appendix A of Regulatory Guide 1.33,Section I, recommends proce-dures, instructions, or drawings for performance of maintenance which can affect the performance of safety-related equipment.
Contrary to the above, at the time of this inspection, the licensee performed safety-related maintenance activities without approved procedures.
Work Request 47323. RPS Channel 3 Power / Imbalance / Flow Function Generator Module. Adiusted break points and slopes.
Work Request 47445, S-lC, Inverter C l_ow Voltage.
As an alternative to written procedures the licensee utilized vendor /
technical manuals; however, these manuals were uncontrolled and did not receive management review and approval.
This item is an infraction.
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Response
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Regulatory Guide 1.33 Appendix A, Section 9a states " Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented-instructions, or drawings _ appropriate to the circumstances. Routine maintenance activities that require skills normally possessed by qualified personnel may not require detailed-step-by-step delineation in a procedure but should be subject to general administrative procedural. controls as discussed i
in pa'ragraph e of this section. The following types of activities are among those that may not require detailed step-by-step' written procedures:
i (1) Gasket replacement (2) Trouble-shooting electrical circuits (3) Changing chart or drive speed gears or slide wires on recorders" The work performed under work requests 47323 and.47445 were performed by qualified technical personnel and do not require step-by-step l
procedures. The work request is a general administrative procedure and is reviewed and approved.by a plant engineer after completion ~of the testing requirements. The District contends that routine main-tenance such as performed under these work procedures are sufficient to. safely control -the activities described and contrary to the NRC finding is in full compliance with Regulatory Guide 1.33.
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3.
Administrative. Procedure 8, Records fianagement, required records be maintained in accordance with ANSI N45.2.9-1974 for temporary and permanent records,-includi.ng storage.
Contrary to the above, operating ' log books, surveillance test results, administrative, maintenance, and testing proceduresi and changes made thereto since.the beginning of facility operations were stored in the administration building.in standard file cabinets which did not meet
-the requirements of Section 5.6, ANSI N45.2.9.
t This item is a deficiency.
Respons_e
- T_ e District was aware of this item prior to the NRC/01E PAB Team h
inspection and has been actively. engaged.in obtaining a solution.
Arthur Young and Company has completed a compr'ehensive study for the overall records management program at Rancho Seno which considered
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- all'requireme'nts of ANSI N45.2.9 plus~other Federal and State regu-l.
lationslgoverningithe identification, storage and retrieval of quality assurari~ce records. This' study has been translated'into a Request for Proposal which-has-been, submitted to thirteen'(13) companies E
- engaged in Records fianagement work. These companies have been l
. instructed to submit proposals for a Records Management System no later than :12 August.1980.' ' Selection of a Records Managemen,t System e
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is to be made no later than 16 October 1980. The successful vendor will be required to begin work on a records system which will satisfy l
Section 5.6 of ANSI N45.2.9 af ter award of a contract. The Records ilanagement System is expected to be in operation during the last quarter of 1981.
l Final compliance will be attained when a new building complete with l
an operational record retention system in conformance to ANSI l
N45.2.9 is constructed. Completion of the building and vault is anticipated to be by July 1982.
It will take an additional 90 days to transfer the records, set up the system and make the integrated system operational.
I We anticipate compliance on this item will be the fourth quarter of 1982.
t H.
Technical Specification C.8.2 recuires the applicable procedures recommended in Appendix A of Regulatory Guide 1.33-1972 be periodically l
reviewed.
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Administrative Procedure'27. Internal Auditing, Section 3.4, specified that procedure reviews are required, at a minimum, within 24 months from the date of last review.
l Contrary to the above, fourteen administrative procedures had not been l
reviewed within time requirements. One example was AP-28, Post Trip Transient Report, which had not been reviewed since February 27, 1975.
This item is an infraction.
Response
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The accelerated corrective actions required to satisfy NRC regulations has caused increased emphasis on safety related procedures.
Safety l
related procedures are being reviewed and revised at a schedule much less than the two year requirement. The fourteen administrative procedures have received decreased emphasis which will be corrected.
The post trip transient report is a simple procedure that states what data will be gathered during transients. The requirements within this procedure have not changed and no revision has been found necessary to modify this procedure. Therefore, it remains unchanged from the February 27, 1975 issue.
The-two year cycle will be updated and all procedures designated within Administrative Procedure 27 will be reviewed.to specification by the end of 1981.
K.
Technical' Specification 6.4.2 requires the licensee to maintain a train-ing program for the Fire Brigade which includes refresher classroom training on a quarterly schedule.
Contrary to the above, seven nembers of the Fire Brigade did not partici- '
pate in fire drills, which included classroom training, during the 4th quarter 1979 and/or the 1st quarter 1980.
This item is an infraction.
Response
The 4th quarter of 1979 and 1st quarter of 1980 placed unusual opera-tional demands on the Fire Brigade personnel.
The drills were scheduled by the Safety Technician but preparations were underway for refueling operations and the brigade missed the drills. When the accelerated work schedule was completed during the 2nd quarter of 1980, the training was completed on schedule. The 3rd quarter training drills are being conducted and will be completed on schedule.
The District is in full compliance with this requirement.
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ATTACHMENT fl0. 2 NOTICE OF DEVIATI0flS B.
Contrary to the licensee's commitment in the FSAR, Appendix B, Para-graph 18.14, a Documentation Control Center was not maintained on site for qua!ity related records of plant operating activities, and QA per-sonnel did not review all quality-related documentation for completeness.
Response
This finding is correct. We do not have an adequate Documentation Control Center (DCC) to store all the required records.
QA usually does not review recrods until they are sent to the DCC. We do not routinely review operating records for completeness. This review is accomplished by fluclear Operations personnel and the records are stored in their facilities. When the new records center is built, Quality Assurance will audit records for completeness prior to' storage. The records storage center is estimated to be completed by the fourth quarter of 1982. At that time we will be in compliance.