ML20005F179
| ML20005F179 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/08/1990 |
| From: | Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Knighton G NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AGM-NUC-89-277, NUDOCS 9001160020 | |
| Download: ML20005F179 (5) | |
Text
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l D euun SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, P.o. Box 15830, Secremento CA 958521830,(916) 452 3211 AN ELECTRIC SYSTEM SERVING,THE HEART OF CAllFORNIA AGM/NUC 89-277 January 8, 1990 U. S. Nuclear Regulatory Commission
. Attn: Document Control Desk Washington,.DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO NOTICE OF VIOLATION 89-15 Attention: George Knighton On December 7,1989, the Sacramento Municipal Utility District received a Notice of Violation concerning-activities at the Rancho Seco Nuclear Generating Station.
In accordance with.10 CFR 2.201, the District provides the enclosed response to this violation.
This letter denies the violations cited and-describes the District's reasons for denial. Members of your staff with questions requiring additional information or clarification may contact Mr. Bob Jones at (916) 452-3211',
extension 4675.
Sincerely,
~
Dan R. Keuter Assistant General Manager Nuclear Attachment cc w/atch:
J. B. Martin, NRC, Halnut Crebk A. D'Angelo, NRC, Rancho Seco f
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l RANCHO SECO NUCLEAR GENERATING STATION O 1444o Twin Cities Road; Herald, CA 95638-9799;(209) 333 2935-I
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DISTRICT RESPONSE TO NOTICE OF VIOLATION 89-15 NRC STATEMENT OF VIOLATION' A.
10 CFR Part 50.59 and Rancho Seco Administrative Procedure'RSAP-0303, Plant Modifications, require in part that a written safety evaluation be performed for changes to a facility as described in the safety analysis.
report.
Contrary to the above, the auxiliary fuel handling bridge which is described in the licensee's safety analysis report, was-dismantled and removed from the reactor building in October, 1989, under Work Request ~No.
01650150-0.
This facility change was not controlled under RSAP-0303 and, as a result, no written safety-evaluation was performed.
This is a Severity Level IV Violation (Supplement 1).
B.
Technical Specification 6.8.1 requires, in part,' that procedures referenced in Appendix "A" of Safety Guide 33,: November 1972, be established and implemented.
Safety Guide 33, Appendix "A", paragraph I.5, references procedures for the control of maintenance and modification work.
Rancho Seco Administrative Procedure, RSAP-0803, R.5, Paragraph 5.5.14, states, in part:
"The work request shall be changed to reflect the work. required to be-l performed..."
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Contrary to the above, in October, 1989, Work Request No. 01650150-0 was not changed to temporarily relocate the auxiliary fuel handling bridge from the fuel transfer canal to the 60 foot level of the reactor j
building.
The work request only directed the equipment to-be dismantled and removed from the reactor building.
The increase in the scope of the j
work activity required to be performed was not prescribed by a change to i
the work request, j
This is a Severity Level IV Violation (Supplement 1).
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7 DISTRICT RESPONSE-Violation A-Admission or denial of alleged violation:
The District denies that the above is a violation.
Circumstances of the event:
In preparation for reactor defueling, Technical Services was preparing to:
conduct STP.1232 " Main Fuel Handling Bridge Operational Test." One of the prerequisites to the test requires that the Auxiliary Fuel Handling Bridge (AFHB) be parked at the east end of the refueling canal or that it be remover
.so as not to interfere with the test. Since the completion of the 1985 refueling outage, the AFHB has been parked between the reactor vessel and the Main Fuel Handling Bridge (MFHB).-
At the time STP.1232 was to be performed, a STOP HORK ORDER was:in effect to.
prevent the removal of the reactor vessel head and entering the Refueling Operation mode.
Because the reactor vessel head could not be removed, the AFHB could not be moved to the east end of the refueling canal.
To allow the test to proceed, the defueling project manager decided-to remove the AFHB, i
His intent was to remove the AFHB temporarily, complete STP.1232, and replace the AFHB restoring the plant to its previous configuration.
I On September 5,1989, Mechanical Maintenance initiated-Hork P.equest (HR) 165015 to remove the AFHB from the Reactor Building and place'it in the Interim Orsite Storage Building (IOSB). The work request further stated that the AFHB would be reinstalled at a later date, s
On approximately September 13, 1989, Mechanical Maintenance began removing the y
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AFHB. Several parts were layed on the deck grating on the +60 foot level of l
the Reactor Building for further disassembly, q
a Subsequent to removing the AFHB, management decided that the AFHB was no:
longer needed and that it should be. removed permanently;.Because' removing the AFHB permanently would constitute a modification to'the facility, a Design-Change Package (DCP) was required to control and document the-plant i
modification.- On October 20, 1989, the cognizant' design' engineer initiatedi DCP R89-0085 to remove the AFHB permanently.
1 On November 22, 1989, Mechanical Maintenance completed disassembly of the-AFHB. The fuel mast, fuel grapple, trolley, and other miscellaneous parts '
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were transferred to the IOSB.
The bridge was stored at the reactor building grade level pending decontamination.
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DISTRICT RESPQRSE (Continued)
Violation A L
l Procedural requirements
- RSAP-0803 "Hork Request" defines the requirements for using work requests for identifying, planning, testing, and documenting maintenance activities.
Temporary removal of the AFHB.(to facilitate testing of HFHB) was appropriately controlled under work request procedure RSAP-0803.
District position:
The AFHB was removed to facilitate testing of the MFHB in accordance with-STP.1232.
The intent was to remove the AFHB (this was necessary to satisfy a prerequisite to performing STP.1232), complete testing of the MFHB, and return the AFHB to its original position in the Reactor Building.
Using a work request to accomplish this is consistent with the Rancho Seco work. request and configuration control procedures.
After the AFHB was removed, management evaluated future use of the AFHB and concluded that permanent removal was in the long-term best. interest of the Plant.
When the decision was made to remove the AFHB permanently, the.
cognizant design engineer initiated a DCP and the associated 10 CFR 50.59 determination.
The 10 CFR 50.59 evaluation determined that removing the AFHB did not involve an unreviewed safety question.
Based on the circumstances and sequence of events, the District believes that.
removing the AFHB to facilitate testing of the MFHB was performed in a' manner i
consistent with Rancho Seco work practices and RSAP-0303.
Therefore, the l
District denies the alleged violation.
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DlSIBICT RESPONSE (Continued)
Violation B
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Admission or denial of alleged violation:
f The District denies that the above is a violation, l
Hork scope:
The scope of HR 165015 was to remove the AFHB (Equipment ID Y-202) from the Reactor Building and place it-in the IOSB for long-term repair.
The work l
request also stated that the AFHB would be reinstalled _at a later date..
Step 4 of the work request states:
" Dismantle the Y-202 Aux Bridge Crane using the manuals listed below, and place in the LSA boxes." This step began l
on approximately September 13, 1989, and was completed on November 22. 1989.
District position:
Although the work request did not specifically state that-the trolley and the bridge would be placed on the +60 foot "B" D-ring for further disassembly, this work was within the skill and training of the individuals performing the i
work and was documented in the work request.
Not specifying this interim step in the work request did not constitute a change'in the. direction,: scope, or intent of the work request.
The District denies the alleged violation because neither the work scope nor the description of the work requested in HR 165015 wer'e_ exceeded.
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