ML20214N154

Forwards Revised Response to Notice of Violation from Insp Rept 50-312/86-18.Corrective Actions:Plant Review Committee Will Review All Temporary Changes & Safety Evaluations of All Permanent Changes to Class 1 Sys or Components

ML20214N154
Person / Time
Site:	Rancho Seco
Issue date:	11/11/1986
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
JEW-86-394, NUDOCS 8612030560
Download: ML20214N154 (3)

Text

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r asuun SACRAMENTO MUNICIPAL UTILITY DISTRICT 'E 6201 S Street, P.O. Box 15830. Sacramento CA 9f 852-1830. (916) 452-3211 AN ELECTRIC SYSTEM SERVING THE fiEART OF CALIFORNIA m

h JEW 86-394 Nover.her 11, 1986 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 N0. DPR-54 REVISED RESPONSE TO THE NOTICE OF VIOLATION FROM NRC INSPECTION REPORT 86-18, REVIEW 0F PROPOSED FACILITY CHANGES The Sacramento Municipal Utility District hereby submits, in Attachment 1, the revised response to Appendix A of the subject Notice of Violation (review of proposed facility changes by the PRC) in accordance with 10 CFR 2.201.

If there are any questions concerning this response, please contact Mr. Ron Colombo at the Rancho Seco Nuclear Generating Station.

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. WARD DEPUTY GENERAL MANAGER NUCLEAR Attachment I

8612030560 861111 PDR ADOCK 05000312 G PDR 1 I -

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ATTACHMENT 1 DISTRICT RESPONSE TO NRC INSPECTION 86-18 REVISION 1 NOTICE OT VIOLATION APPENDIX A VIOLATION As a result of the inspection conducted between April 22 and May 31, 1986, conducted by G. Perez, C. Myers and W. Albert, the following violation was identified:

Rancho Seco Technical Specification 6.5.1.6(d) states that the Plant Review ,

Committee (PRC) shall be responsible for review of all proposed changes or modifications to plant systems 'or equipment that affect nuclear safety.

Quality Control Instruction QCI-5 defines " Systems or equipment that affect nuclear safety" as those structures, systems or components necessary to assure:

(1) the integrity of the reactor coolant pressure boundary, (2) the capability to shut down the reactor and maintain it in a safe shutdown condition, or (3) the capability to prevent or mitigate the consequences of accidents which could result in potential off site exposures, comparable to the guidance exposures of 10 CFR 100.

On December 9, 1985, reactor coolant pressure boundary valve SFV-22006 was ,

modified to repair a body-to-bonnet leak, i

Contrary to the above, the PRC did not review this modification performed j under Noncomforming Report Number S-5218.

] This is a Severity Level IV violation (Supplement I).

RESPONSE

The District agrees with the NRC citation.

To clarify the ambiguity of the technical specification cited by the NRC, the District commits to having the PRC review all temporary changes as well as safety evaluations of all permanent changes to any Class 1 systems or components in the plant, regardless of the Part 50.59 determination. This will formally be done by a revision to the NCR and Abnormal Tag procedures described below.

The NCR procedure will be revised so that a NCR requiring a temporary change will invoke the Abnormal Tag Procedure, AP-26. AP-26 will also be revised t to conform to industry practice, including a questionnaire format and a PRC sign-off 4

to the Abnormal Tag's Part 50.59 determination. The NCR form for the Part 50.59 determination will also be revised to a questionnaire format. The Abnormal Tag procedure will be revised by January 5, 1987. The additional revisions to the NCR procedure will be made by January 5, 1987.

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Dispositioning a Nonconforming Report (NCR) involves a significant amount of engineering review. This engineering work is done whether a change is 10 CFR Part 50.59 related or not. An example is the installation of a leak stopping clamp around valve SFV-22006.

On December 9, 1985, a reactor coolant pressure boundary valve SFV-22006 was modified by NCR S-5218 to stop a body-to-bonnet leak. The repair technique i

was reviewed by engineering with respect to the seismic impact of the clamp used to seal the leak and was determined to be minimal. The limiting seismic stress occurs at the connection of the motor operator to the valve which is farther from the center of the valve body than the bonnet. The vendor calculation for the combined valve and operator natural frequency was based on a cantilever approximation of the operator attachment assembly with the motor operator mass at the end of a lever arm. The addition of the clamp on the bonnet does not change the assumption that the motor operator connection is fixed and rigid. Hence, appropriate engineering reviews were performed which established that the USAR seismic analysis was unaffected by this maintenance modification. The temporary modification to the

, valve was removed as part of the valve repair on February 13, 1986.

In order to assure the technical adequacy of past modifications, the District will sample a statistically significant number of "non-Part 50.59" temporary changes made in the plant to Class 1 systems or components that were done via an NCR during the past five years. The District will examine those NCR's and where it is not apparent that the technical adequacy was established, will perform such an assessment and document the results of this evaluation.

This activity will be completed by February 2, 1987.

f To address the programmatic issue of "non-Part 50.59" changes to Class 1 systems and components, the Quality organization will perform a review of the District's procedures for the control of modifications with respect to 10 CFR Part 50.59.

This review will also include INP0 Good Practices. The Quality assessment of the District's procedures for the control of modifications with respect to 10 CFR Part 50.59 will be completed by December 8, 1986.

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