ML20009B963
| ML20009B963 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/01/1981 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| TAC-46692, NUDOCS 8107200089 | |
| Download: ML20009B963 (3) | |
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.s SACRAMENTO MUNICIPAL UTILITY DISTRICT tj 620hS5,dreet9s 15830, Sacramento, California 95813; (916) 452-3211 Q,-
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s R H ENGELKEN. DIRECTOR dt V,
pb to REGION V 0FFICE OF INSPECTION t, ENFORCEMENT 5g U S NUCLEAR REGULATORY COMMISSION 1990 N CALIFORNIA BLVD WALNUT CREEK PLAZA SUITE 202 WALNUT CREEK CA 94596 OPERATING LICENSE DPR-54 DOCKET NO. 50-312 NRC INSPECTION 81-15 in reply to the inspection conducted by Mr. H. Canter and Mr. J. O'Brien of your of fice on April 1 through 30, 1981, we offer the following explainations and corrective steps which will be taken to avoid 'urther items of non-compliance.
Appendix "A" of the June 8, 1981 Notice of Violation notes the following:
10 CFR 50.55a(g)(1) states, in part, "For a boiling or pressurized water-cooled nuclear power f acil i ty whose cons t ruction permi t was issued prior to January 1, 1971, components...shall meet the requi reroents of Paragr6phs (g)(4) and (c)(5) of this section to the extent p rac t i ca l."
(Note:
The construction permit for Rancho Seco was issued on October 11, 1968).
10 CFR 50.55(g)(4) states, in part, "Throughout the service life of a boiling or pressurized water-cooled nuclear power facili ty, coraponents which are classi fied as ASitE Code Class 1,
? lass 2, and Class 3, shall meet the requi rernents... set forth in Section XI of (applicable) editions of the ASME Boiler and Pressure Vessel Code..
By letter dated May 30, 1978, the Commission issued Amendment No. 20 to the fccility license, making the above provisions effective October 18, 1979 By letter dated October 17, 1979, the NRC issued a letter stating, in part:
"Durina the period between the date that the requirements of 10 CFR 50.55a(g) become ef fective for your f acility and the date we complete our detailed review of your submit tal you must comply with both your existing 8107200089 010701 y
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R. H. Engelken (2)
July 1, 1981 Technical Specifications and your proposed inservice inspec-tion and testing program.
In the event conflicting require-(
l ments arise for some components, you must comply with the l
more restrictive requirements (e.g., shorter inspection intervals, increased number of parameters measured)..."
The licensee's proposed inservice inspection and testing program is described in his letters to the NRC dated December 24, 1979, and April 17 and May 30, 1980. This program defines the components that are to be tested, the measurements that are to be made and the relief that has been requested from certain requirements of ASME Section XI.
Among the pumps to be tasted are the High Pressure injection and Makeup Pump.
One of the parameters to be measured is bea,-ing temperatuie.
i No relief was requested from this requirement.
i ASME Section XI, Subsection lWP-3500(b) states: "When measurement of bearing temperature is required, each pump shall be run until the bearing temperatures (IWP-4310) stabili7e, and then the quantities specified shall be measured or observed and recorded. A bearing temperature l
shall be considered stable when three successive readings I
taken at 10 min. intervals do not vary by more than 3%."
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ASME Section XI, Subsection IWP-1100 states in part, "This Subsection provides the rules and requirements for inservi:e testing of Class 1, 2, and 3... pumps that are.... equi red t )
j perform a specific function in shutting down a teactor or in mitigating the consequences of an accident and are l
provided with an emergency power source..."
Contrary to the above, the licensee's approved procedures for testing these pumps (SP 203 02A/B/C, Quarterly HPI System Surveillances) do not provide for achieving stabi-j lizing bearing temperatures.
Instead, the procedures allow cperation for as little ar 15 minutes and require only one measurement of bearing temoerature.
Ir adci t s ari, t nt.
procedure does not measure the capability of the pumps to operate following an accident which also includes a loss of offsite electrical power.
A review of the results of the surveillances performed between October 18, 1979, and April 3, 1981, by the Resident t
Inspector indicate that the above procedures were conducted as written and no supplemental measurements were recorded indicating achievement of stabilized bearing temperatures or capability to operate satisf actorily with only the safety-related lube oi! cooler in operation.
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R. H. Engelken (3)
July 1, 1981 As a result of the above, a degraded condition of the High r
Pressure injection and Makeup pumps safetv-related lube oil coolers was not detected by the surveillance procedures.
DISTRICT REPLY The Inservice inspection and Testing Program for the High Pressure injection and Makeup pumps utilizes a surveillance procedure established in June 1974. This procedure permits accepting the performance of the functional test af ter a 15 minute duration, in agreement with Technical Sp 'fication Section 4.5.1.2.D.I.
It was pointed out that this duration will not permit one of the six pump parameters required by ASME Section XI, Table IWP-3100-a, to be measured. This parameter, bearing temperature, is considered to be least critical as evidenced by the exception to test frequency stated in IWP-3300 of the Code, "...which shall be measured during at least one inservice test each year."
To eliminate this discrepancy, the surveillance procedures for the High Pressure injection and Makeup pumps will be revised to comply with the requirements of IWP-3500.
Further, the Decay Heat Removal, Spent Fuel Cooling, Reactor Building Spray, Auxiliary Feedwater, Nuclear Service Cooling Water, and Boric Acid Pumps will be tested in accordance with IWP-3500. This will be accomplished by September 30, 1981, to maintain full compliance with the ASME Section XI Code.
The Nuclear Service Raw Water pumps are exempt from bearing temperature measurement since all are within the main flow path.
The High Pressure injection and Makeup pumps need not be tested with only the Nuclear Service raw water supplying cooling to the lube oil coolers.
The performance test conductea for LER 81-16 assured proper operation of the HPl system independent of lube oil coolers, and the additional valve lineups and realignment are not prudent from an operational standpoint. The performance of these lube oil coolers has been covered in our March 30 and May 5, 1981 letters to your office.
)L}1 %L C/ohn E. Mattimoe J
Assistant General Manager and Chief Engineer Sworn toyand subscribed before me I ' * *.*d
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Pt.TFdCIA X. _GEISLER this jL day of July, 1981.
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l My Ccemissen Espes November 22.1933 i
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Notary Public
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