ML20155D330

Responds to NRC Re Violations Noted in Insp Rept 50-312/88-05.Violation Denied.Based on Listed Procedural Requirements & Fact That Occurrence Description Rept Was Written,Util Feels Occurrence Was Adequately Documented

ML20155D330
Person / Time
Site:	Rancho Seco
Issue date:	06/08/1988
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Office of Nuclear Reactor Regulation
References
GCA-88-352, NUDOCS 8806150115
Download: ML20155D330 (4)

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SMUD SACRAMENTO MUNICIPAL UTIUTY DISTRICT O P. O. Box 1683o, Sacramento CA 95852-183o,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA JUN 0 81988 GCA 88-352 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 88-05

Dear Sir:

On May 13, 1988, 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 violation cited, and describes the District's reasons for denial.

Members of your staff with ciuestions requiring additional information or clarification may contact Mr. Steve Rutter at (916) 452-3211, extension 4674.

Sincerely, G AarVAndo ' nf' Chief Executive Officer, Nuclear Attachment cc w/atch:

J. B. Martin, NRC, Halnut Creek A. D'Angelo, NRC, Rancho Seco INP0 8806150115 880608 3g6/

PDR ADOCK 05000312 a nnn f//

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

RESPONSE TO NOTICE OF VIOLATION 88-05 I I

1 NRC STATEMENT OF VIOLATION A 10 CFR, Part 50, Appendix B, Criterion V, states in part that:

"Activities affecting quailty shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these i instructions, procedures, or drawings."

Procedure QAP-17, titled "Ncaconforming Material Control," Revision 7, states in part that:

5.1.1 "Systems, equipment and appurtenances, components, parts or material which do not meet the specified requirements of ...

operational / test documents, ... shall be considered nonconforming."

Special Test Procedure 961, Loss of Offsite Power, required the "A2" emergency diesel generator to hot restart actomatically when it received

, a Safety Features Actuation System (SFAS) start signal from the control j room as part of the test.

Contrary to the above, on February 28, 1988, STP 96i was performed and the failure of the A2 diesel generator to hot start automatically when it received a SFAS start signal from the control room was not considered nonconforming.

This is a Severity Level IV violation (Supplement 1).

DISTRICT RESPONSE Admission or denial of alleged violation:

The District denies that the above is a violation.

On February 28, 1988, during the performance of Special Test Procedure STP.961 "Loss of Offsite Power Test," the "A2" diesel l generator failed to start when it initially receivea a Safety Features Actuation System (SFAS) start signal. Imn ediate troubleshooting discovered that the pneumatic shutdown system had not reset. The pneumatic shutdown system was manually reset and the "A2" :ilesel generator started. In accordance with Administrative Procedure AP.82 "Conduct of Special Testing," this occurrence was documented as Test Deficiency No. 16.

AP.82 states:

6.3.11.2 "If a Nst deficiency occurs, it shall be documented either on a PICN, PTCN, HR, NCR or ODR in accordance with QAP-17 and the document number noted in the test log."

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DISTRICT RESPONSE (Con.inued)

QAP-17 states:

5.1.1 "Systems, equipment and appurtenances, components, parts or material which do not meet the specified requirements of ...

opera +1onal/ test documents ... shall be considered nonconforming. Refer to Attachment 3 for guidelines on when to write NCRs."

QAP-17, Attachment 3 states:

"If a test fails and the test results are to be submitted for review and approval with the failed step, an NCR shall be initiated to document the test failure."

The initial failure of the "A2" diesel generator was not considered a test failure since the diesel generator did start when the pneumatic shutdown system was reset.

AP.82 states:

6.3.11.3 "If a test deficiency which affects Acceptance Criteria occurs, an NCR shall be written if the intent is to accept the test results 'as-is'."

The Acceptance Criteria required the "A2" diesel to restart within 5 minutes of being stopped. Since the "A2" diesel restarted within 5 minutes, the occurrence did not affect the Acceptance Criteria; therefore, an NCR was not generated. To document the occurrelce as required by AP.82, ODP.88-147 was generated. The ODR documents the occurrence as follows:

"During the performance of STP.961 Step 6.17.2.9. the TDI Diesel Generator G-100A failed to start on a LOOP!SFAS initiation signal. The cause was a failure of the pneumatic shutdown system to reset following the normal shutdown. The pneumatic logic was reset manually by an Operator as directed by the Test Engineer and the diesel started within 5 minutes of the shaft being stopped. STP.961 was then continued to Section 6.17 completion and Test Deficiency #16 was written. HR

1. 142455 already addressed this problem and is still open awaiting parts."

RSAP-1302 "Occurrence Description Reports" states:

"This procedure describes the responsibilities for report'ing and resolving any unsafe, atypical or off-normal occurrences that are related to the operation of Rancho Seco Nuclear Generating Station. These occurrences may include ... failed or unacceptable test results ..."

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DISTRICT RESPONSE (Continued)

RSAP-1302 further states:

1.2.3 "Notify the responsible organization of occurrences and track their correction."

Based on the above procedural requirements, and the fact that an ODR was. written and all other procedural requirements were met, the District feels that the occurrence was adequately documented and denies the e.11eged violation.

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