ML20033G510
| ML20033G510 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 03/21/1990 |
| From: | Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Knighton G NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AGM-NUC-90-098, NUDOCS 9004100138 | |
| Download: ML20033G510 (5) | |
Text
-
1 4.uun SACRAMtWTO MulelCDPAL UTIuTY DisThict C $20i s $tre.et P.o. Bem it430. sacramento CA Pt.Bf>21830 (916) 4s2 3211 i
AN cLECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA l
AGM/WDC 00-098 March 21, 1990 U. $. Nuclear Regulatory Commission Attn:
Document Control Desk Hashington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 SUPPLEMENTAL RESPONSE TO NOTICE Of VIOLATION 89-15 1
Attention: George Knighton l
Attached is additional information regarding the District's response to Notice 1
of Violation 89-15.
This supplement clarifies the District's position on Violatie A and provides additional information not included in the original response. Also, based on further clarification from the resident inspectors, the District has revised its position on Violation B.
I I
This information was discussed with the resident inspectors on March 5 and March 6, 1990.
i i
Members of your staff with questions requiring additional information or clarification may contact Mr. Bob Jones at (209) 333-2935, extension 4676.
t I
sincerely, i
i M
p /
,,/j n
Dan R. Keuter Assistant General Manager l
Niclear l
l t
l Attachments i
i ec w/atch:
J. B. Martin, NRC, Halnut Creek A. D'Angelo, NRC, Rancho Seco I
9004100138 900321 PDR ADOCK 05000312 l
\\
I l
RANCHO SECO NUCLEAR GENERATING STATION D 1444o Twin Cities Road, Hera.d. CA 95038-9799; tho9) 333 2935
1 l
DISTRICT RESPONSE TO IIOTICE OF VIOLATION 89-15 NRC STATEMENT OF VlQLElQN 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 ano, as a result, no written safety evaluation was performed.
This is s 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 reanst shall be changed to reflect the work required to be performed..
Centrary 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 builcing.
The work request only directed the equipment to be dismantled and removed from the reactor building.
The increase in the scope of the work activity required to be performed was not prescribed by a change to the work request.
This is a Severity Level IV Violation (Supplement 1).
I i 1 l
me
~
DISTRICT RESPONSE Y10lition A Admission or dental of alleged violation:
The District continues to deny that the above is a violation.
Clarification of the District's position:
The Auxiliary Fuel Handling Bridge (AFHB) was removed under Work Request 165015 because it interfered with testing of the Main Fuel Handling Bridge (MFHB).
The intent was to remove the AFHB, complete testing of the MFHB, and return the AFHB to its original configuration in the Reactor Building.
After the AFHB was removed, management evaluated its future usefulness and concluded that the ATHB should be removed permanently. When the ded.1on was made to remove the AFHB permanently, the cognizant design engineer initiated Design Change Package (DCP) R89-0085 to evaluate and implement the configuration change and to ensure the USAR would be updated to reflect the new refueling system.
DCP R89-0085 was initiated on September 21, 1989.
The 10 CFR 50.59 evaluation associated with DCP R89-0085 was approved on October 27, 1989, and determined that removing the AFHB did not constitute an unreviewed safety question.
In addition. Operating Procedure B.8 " Refueling Operations" was revised in August 1989, to delete any reference to the AFHB.
The associated 10 CFR 50.59 evaluation was approved on August 25, 1989, and determined that deleting reference to the AFHB did not result in an unreviewed safety question.
The District maintains that:
Removing the AFHB to allow continued testing of the HFHB was o
performed in a manner consistent with Rancho Seco work practices, Proper configuration controls were maintained during the entire o
- process, Because the 10 CFR 50.59 evaluations associated with DCP R89-0085 e
and B.8 were completed prior to moving fuel (reactor defueling began on November 28, 1989), all fuel-handling operations were performed using a fuel-handling system which was in conformance with the USAR. I 4
mm
Violation B Admission or dental of alleged violation:
The Olstrict acknowledges the violation in that the administrative controls referenced in Work Request 165015 were less than adequate with regards to the interim storage of the AFHB, Reason for the violation:
The scope of Work Request 165015 was to remove the AFHB from the Reactor Building and place it in the Interim Onsite Storage Butiding (IOSB) for long-term repair. As part of the removal process, the AFHB was placed on the
+60 foot "B" D-Ring for further disassembly prior to being placed in LSA boxes and shipped to the 1058.
Lifting the AFHB to the +60 foot "B" D-Ring was performed in accordance with Maintenance Procedure M.135. Revision 1 " Control of Heavy Loads." The procedure stated that the Mechanical Maintenance Superintendent is responsible for the interpretation and application of the procedure.
The procedure also stated that tie cognizant engineer shall provide written instructions under the following conditions:
... handling loads near irradiated fuel... over or near any redundant safe shutdown systems when both trains could become jeopardized by any single load drop.
The Mechanical Maintenance Superintendent determined that the conditions requiring written instructions were not met; therefore, no heavy loads evaluation was performed prior to placing the AFHB on the +60 foot "B" D-Ring.
Corrective actions taken and results achieved:
Technical Services performed an evaluation to determine the effects of setting the AFHB on the +60 foot "B" D-Ring.
The 14' X 25' AFHO did not overstress the structural beam members since the design live load h 250 pounds per square foot; however, the wheel loads (3500 pounds) did exceed the manufacturer's safe load of 3000 pounds for the 3 inch width of the grating.
The grating did not show any apparent damage when inspected visually.
This evaluation was documented in Potential Deviation from Quality 89-0793.
The Manager, Nuclear Quality and Industrial Safety initiated Corrective Action Request (CAR)89-005 requesting the Manager. Technical Services and the Manager Maintenance to thoroughly review the event and provide additional guidance regarding engineering reviews and seismic evaluations required for the storage or placement of heavy loads.._
. Violation B (Continued)
Corrective actions taken to avoid further violations:
M.135 has been voided and Maintenance Administrative Procedure MAP-0010
" Control of Heavy Load Lifts" has been revised to require a seismic evaluation for the storage or relocation of all loads over 1600 pounds, inside of Class 1 structures.
Training was provided via reading assignments for Engineers and Maintenance Superintendents on the revision to MAP-0010.
Date when full compliance will be achieved:
MAP-0010 was revised effective February 9, 1990.,
t