ML20003C972

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Addl Response to NRC Re 810108 Notice of Deviation.Corrective Actions:Surveillance Procedure 201.10A for Safety Sys Hydraulic Snubbers Surveillance Insp Will Be Revised to Clarify Testing Requirements
ML20003C972
Person / Time
Site: Rancho Seco
Issue date: 02/27/1981
From: Mattimoe J
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Engelken R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20003C966 List:
References
NUDOCS 8103180954
Download: ML20003C972 (2)


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SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S Street, Box 15830, Sacramento, Cahfornia 95813; (916) 452 3211 g-x

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February 27, 1981 Mr. R. H. Engelken, Director Region V Office of Inspection & Enforcement U. S. Nucicar Regulatory Commission 1990 North California Boulevard Re:

J. L. Crews to J. J. Matticoe Letter, Dated February 18, 1981, Operating License DPR-54, Docket No. 50-312.

Dear Mr. Engelken:

In reply to your letter from Mr. J. L. Crews requesting an additional response to the Notice of Deviation (Appendix B of your letter dated January 8,1981), we offer the following explanations and corrective actions to assure full compliance with NRC requirements.

Appendix B of January 8, 1981, letter noted *he following deviation:

Section 6.2 of ANSI standard N18.7-1972, " Administrative Controls for Nuclear Power Plants", to which you are com-mitted by letter dated September 23, 1976 states, in part:

" Testing of safety-related... components shall be per-formed in accordance with approved written test proce-dures, 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 determin-ing the operability of hydraulic snubbers.

Such specific limits are needed to properly implement Technical Specifi-cations 3.12 and 4.14.1.

SMUD Reply:

In addition to those changes agreed to in our letter dated January 26, 1981, SP 201.10A, " Safety System Hydraulic Snubbers Surveillance Inspection",

will be revised to include clarification of functional testing requirements accessary to determine operability. This revision to the procedure will re-quire functional testing of any snubber where the 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), to deter-mine operability.

810s18 9 59 AN ELECTRIC SYSTE M S E D VI N G VORE THAN 600,000 IN THE HEART OF C A L UD P NA M d f

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Mr. R. H. Engelken, Director February 27, 1981 As stated in your letter, if it is determined by functional testing to be i'sily operable in the "as found" condition, it would not have to be de-fined as inoperable for the purpose of determining the visual inspection interval.

The procedure revision will be completed by March 14, 1981.

spect ully sub'itted, f

L' John Matti e,

Assistant Cen-1 Managec and Chief Engi' er WCW:HH: bks

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