ML20138J366

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Responds to Violations Noted in Insp Rept 50-312/85-23. Corrective Actions:All Surveillance Procedures Will Be Revised to Require Documentation of Calibr Data for All Instrumentation,Except Control Room Instrumentation
ML20138J366
Person / Time
Site: Rancho Seco
Issue date: 09/03/1985
From: Reinaldo Rodriguez
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
RJR-85-426, NUDOCS 8512170502
Download: ML20138J366 (3)


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esuun SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, P.o. Box 15830 Sacramento CA 958521830,1516) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF dAllFORNIAf>

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September 3, 1985 D

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-e J B MARTIN REGIONAL ADMINISTRATOR REGION V 0FFICE OF INSPECTION AND ENFORCEMENT U S NUCLEAR REGULATORY COMMISSION 1450 MARIA LANE SUITE 210 WALNUT CREEK CA 94596 DOCKET NO. 50-312 LICENSE NO. DPR-54 NOTICE OF VIOLATION FOR NRC INSPECTION 85-23 The Sacramento Municipal Utility District hereby submits in Attachment A to this letter, a response to the subject Notice of Violation in accordance with 10 CFR 2.201.

If there are any questions concerning this response, please contact Mr. Ron W.

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ASSISTA T GENE L MANAGER, NUCLEAR Attachment gj21 0502 850903 DOCK 0500g2

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RANCHO SECO NUCLEAR GENERATING STATION T i 1444o Twin Cities Road, Herald, CA 95638 9799;(209) 333-2935

E ATTACIM NT A DISTRICT RESPONSE TO NRC IhSPECTION 85-23 NOTICE OF VIOLATION As a result _of the inspection conducted between May 16-18 and May 20-23, 1985 by Mr. R. Compton (NRC consultant), the following two (2) violations were identi-

.fied.

Each violation is followed by the District's response to the violation.

1.

Paragraph 6.8.1 of Rancho Seco Unit 1 Technical Specification states, in part:

" Written procedures shall be established, implemented and maintained cover-ing the activities referenced below:

a.

The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972.

c.

Surveillance and test activities of safety related equipment."

Paragraph'H.1 of Regulatory Guide 1.33 Quality Assurance Program Requirements (operation) states:

1 "H.

Procedures for control of measuring and test equipment.

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1.- Procedures of a type appropriate to the circumstances should be provided to assure that tools, gauges, instruments, controls and other measuring testing devices are properly controlled, calibrated, and adjusted at specified periods'to maintain accuracy."

l Contrary to the~above requirements, at the time of the inspection, two plant l

gauges [PI-26103 and PI-26143] for the Low Pressure Injection Pumps were

-not in the site calibration program.

In addition, two gauges [PI-23804 and PI23848]inthesitecalibrationprogramhadnocalibrationrecords.

DISTRICT RESPONSE:

l As a result of these findings, all Surveillance Procedures have been reviewed and all instruments used to obtain data have been included in the Preventive Maintenance Calibration program.

Instruments added to the program and instru-ments due for calibration are presently being calibrated.

This work will be completed prior to January 1, 1986.

All Surveillance Procedures will be revis~ed to require the documenting of cali-bration data for all instrumentation, other than control room instrumentation.

The calibration data will be taken as part of the performance of the Surveillance Procedure. The revision of the Surveillance Procedures is a large task (more l

.than 200 procedures) and will require at least one year to complete.

This task l~

will be completed and full compliance achieved prior to January 1, 1987.

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Paragraph 4.2.2 of Rancho Seco Unit 1 Technical Specifications states, in part:

i "An inservice inspection shall be made conforming as closely as design permits to the rules of the ASME Boiler and Pressure Vessel Code Section XI,..."

ASME Section IX, subsection IWV-3513 additional tests states; in part:

"When any valve in a system fails to function properly during a regular test, additional valves in the system shall be tested..."

Contrary to the above, in February 1980, valves PSV-50015 and PSV-50016 failed test, in March 1983, valve 26030 failed tests and in May 1983, valve 31800 failed tests and additional valves were not tested in accordance with IWV-3513 requirements.

DISTRICT RESPONSE:

As a result of these findings, the test records for the valves listed above were reviewed.

It is apparent that a lack of proper review and corrective action was L

responsible for these and other violations.

The Safety and Relief. Valve Setpoint Verification Test Procedure will be revised to require additional Technical Support review. This review will include a provision to specify additional valves to be tested when required.

This procedure will also be revised to specifically state the requirement to obtain "as-found" setpoint data. These changes will ensure that additional valves will be tested when required due to inservice testing failures. These change will be completed and full compliance achieved by September 15, 1985.

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