ML20150B071
| ML20150B071 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 06/28/1988 |
| From: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| References | |
| NUDOCS 8807110253 | |
| Download: ML20150B071 (1) | |
See also: IR 05000312/1988012
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JUN 2 81988
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Docket.No. 50-312
Rancho Seco Nuclear Generating Station
Sacramento-Municipal Utility District
14440 Twin-Cities Road
Herald, California
Attention:
Mr. J. F. Firlit
Chief Executive Officer, Nuclear
Gentlemen:
Thank you for you letter dated June 21, 1988, in response to our Notice of
Violation and Inspection Report No. 50-312/88-12, dated May 23, 1988,
informing us of the steps you have taken to correct the items which we brought-
to your attention.
Your corrective actions will be verified during a future
inspection.
Your cooperation with us is appreciated.
Sincerely,
Ori (nnl SY ned
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R. Zimmerman, Chief
Reactor Projects Branch
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REQUEST 90P)Y ' . SEW .ST M Y ]
YES / NO
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YES / NO
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aesident Inspector
Project Inspector
G. Cook
B. Faulkenberry
J. Martin
J. Zo111 coffer
Docket. File
bec w/o copy of letter dated 6/21/88:
M. Smith
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REgED
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, SACRAMENTO MUNICIPAL UTILITY DISTRICT C P. O. Box 1583o. Sacramento CARfsat0H ddo. (916) 452 3211
AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA
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89 JUN23
Pl2 : 51
CEO 88-003
Director of Nuclear Reactor Regulation
U. S. Nuclear Regulatory Commission
Mail Station Pl-137
Hashington, DC 20555
Docket No. 50-312
Rancho Seco Nuclear Generating Station
License No. DPR-54
RESPONSE TO NOTICE OF VIOLATION 88-12
Dear Sir:
By letter dated May 23, 1988, the Sacramento Municipal Utility District
received a Notice of Violation concerning the failure to report an automatic
actuation of an ESF System within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required by 10 CFR 50.72(b)(2)(ii).
In accordance with 10 CFR 2.201, the District provides
the enclosed response to the violation.
This letter acu owledges the violation as cited and describes the District's
corrective acti vs.
Members of your s'aff with questions requiring additional information or
clarification may contact Steve Rutter at (916) 452-3211, extension 4674.
Sincerely,
N
Joseph F. Firlit
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Chief Executive Officer,
1
Nuclear
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Attachment
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cc:
J. B. Martin, NRC, Halnut Creek
A. D'Angelo, NRC, Rancho Seco
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RANCHO SECo NUCLEAR GENERATING STATION O 1444o Twin Cities Road. Herald. C A 95638 9799;(2o91 333 2935
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DISTRICT RESPONSE TO NOTICE OF VIOLATION 88-12
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NRC STATEMENT OF VIOLATIM
During an NRC inspection conducted on March 30 through May 2, 1988 a violation
of NRC requirements was identified.
In accordance with the "General Statement
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of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C, the violation is listed below:
10 CFR 50.72(b)(2)(li) states, in part:
"(b) Non-emergency events
....
(2)
Four-hour reports.
...the licensee shall notify the NRC as
soon as practical and in all cases, within four hours of the
occurrence of any of the following:
(ii) Any event or condition that results in manual or automatic
actuation of any Engineered Safety Feature (ESF)...."
Contrary to the above on April 11, 1988, at 2:38 p.m., the control room
essential heating, ventilation and air conditioning (HVAC) system, an
Engineered Safety Feature, was actuated and was not reported to the NRC within
four hours.
This is a Severity Level IV violation (Supplement 1).
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DISTRICT RESPONSE
1.
Admission or denial of alleged violation:
The District acknowledges and admits that the above occurred as stated.
2.
Reason for the violation:
District personnel responsible for determination of the 10 CFR 50.72
reportability did not realize that inadvertent actuation of the Control
Room / Technical Support Center (CR/TSC) Essential HVAC System was
reportable.
The appropriate personnel were not aware of the District's
determination that the CR/fSC Essential HVAC System is an Engineered
Safety Features (ESF) System.
The circumstances that led to the wrong
conclusion on the ESF status were:
Updated Safety Analysis Report (USAR) Chapter 6, "Safety Features"
states that safety features are designed to minimize the severity and
mitigate the consequences of a Loss of Coolant Accident by iolfilling
the following basic functions under accident conditions:
.
A.
Protect the fuel cladding
B.
Ensure Reactor Building integrity
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DISTRIid. RESPONSE (Continued)
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C.
Reduce the driving force for building leakage
D.
Remove fission products from the Reactor Building atmosphere
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None of the above functions require the CR/TSC Essential HVAC to be an ESF
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System; however, the system was designed and built to meet the
requirements of an ESF System per Regulatory Guide 1.70, Revision 3.
The CR/TSC Essential HVAC System was removed from Safety Features
Actuation System (SFAS) signal as part of a plant modification.
The CR/TSC Essentia'. ,iVAC System was in a "testing" status between
July 30, 1986 and February 27, 1988 ('
e., inadvertent actuations that
occurred during this period were not reportable).
3.
Corrective actions and results achieved:
"Red phone" notifications were made to the NRC at 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> on April 14,
1980, at 1249 hours0.0145 days <br />0.347 hours <br />0.00207 weeks <br />4.752445e-4 months <br /> on April 18,1988, and at 2250 hours0.026 days <br />0.625 hours <br />0.00372 weeks <br />8.56125e-4 months <br /> on May 6,1988.
The District submitted LER 88-06 identifying 50 spurious actuations of the
CR/TSC Essential HVAC System between March 16 and May 6, 1988.
This LER
detailed corrective actions taken and planned to prevent future
inadvertent actuations.
4.
Corrective actions to be taken to avoid further violations:
Administrative Procedure AP 23.08 "Reporting / Notification" shall be
revised to include 10 CFR 50.72 reporting responsibility, a reportability
matrix, specific criteria, time constraints, action steps, and applicable
forms. This procedure shall be revised by September 9, 1988.
The Nuclear Engineering Department will conduct an assessment of all plant
systems to confirm the District's understanding of which systems are ESF.
This assessment will review the present definition in the USAR against the
latest recommendations in Regulatory Guide 1.70, Revision 3.
Included in
this assessment will be an evaluation of the CR/TSC Essential HVAC System
to determine if it is actually required to be designated an ESF System.
This assessment will be completed by December 31, 1988.
5.
Date when full compliance was achieved:
Full compliance was achieved on May 12, 1988, with the submittal of
Licensee Event Report 08-06, "Spurious Actuation of Control Room / Technical
Support Center Essential HVAC," which reported 50 unplanned actuations.
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