ML20214U551

Forwards Response to NRC Re Deviation Noted in Insp Rept 50-312/87-11.Corrective Actions:Surveillance Procedure Rewrite Effort Proceeding & 67 Procedures Revised

ML20214U551
Person / Time
Site:	Rancho Seco
Issue date:	05/18/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20214U500	List: ML20214U497 ML20214U551
References
GCA-87-033, GCA-87-33, NUDOCS 8706110236
Download: ML20214U551 (4)

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SACRAMENTO MUNICIPAL UTILITY OtSTRICT U P. O. Box 15830. Sacramento Cd 5552-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA GCA 87-033 MAY I 8 1987 J. B. Hartin, Regional Administrator Region V Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 1450 Haria Lane, Suite 210 Halnut Creek, CA 94596 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO NOTICE OF DEVIATION (NRC INSPECTION REPORTS NO. 87-11)

Dear Hr. Hartin:

By letter dated April 20, 1987, the Sacramento Municipal Utility District received a Notice of Deviation concerning the failure to meet a commitment to the NRC to revise all surveillance procedures by January 1, 1987 (RE: Response to Inspection Report 85-23 dated September 3, 1985). In accordance with 10 CFR 2.201, the District provides the enclosed response to this Notice of Deviation.

This letter acknowledges the deviation cited and describes the District's intended corrective actions for each specific item listed in the Notice of Deviation.

If there are any questions conccrning this report, please contact Mr. Ron H. Colombo at (916) 452-3211, extension 4236.

Sincerely, i ~) 'N Kr A

. Car Andog i Chief Executive Officer, Nuclear Attachment 0706110236 070603

{DR ADOCK 05000312 cc w/atch: PDR G. Kalman, NRC, Bethesda (2)

A. D'Angelo, NRC, Rancho Seco J. B. Hartin (2)

INP0 I&E RANCHO SECO NUCLEAn GENERATINo STATloN I 14440 Twin Cities Road, Herald. CA 95038-9799;(209) 333 2935

, c ATTACHMENT I District Response to NRC Insoection 87-11 Notice of Deviation NRC Deviation As a result of the inspection conducted on March 23 to April 3,1987, and in accordance with NRC. Enforcement Policy, 10 CFR Part 2, Appendix C, the following deviation was identified

A. In the SMUD response dated September 3,1985, to a Notice of Violation regarding the testing of class I equipment with instruments not calibrated in a controlled calibration program, the licensee committed to revise all surveillance procedures to require the documenting of calibration data for all instrumentation, other than control room instrumentation prior to January 1, 1987.

Contrary to the above, on April 3, 1987, not all surveillance procedures had been revised to satisfy the licensee's commitments regarding corrective actions for the previous violation.

This is a deviation.

District Response to Deviation

1) Admission or denial of the alleged deviation:

The District acknowledges and admits that this item occurred as stated.

O 2) Reasons for the Deviation:

In response to the violation finding of NRC Inspection Report 85-23 dated September 3, 1985, the following commitment was made. "All Surveillance Procedures will be revised to require the documenting of calibration 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 than 200 procedures) and will require at least one year to complete. This task will be completed and full compliance achieved prior to January 1,1987."

As a result of the plant transient which occurred on December 26, 1985, and the subsequent large scale restart effort undertaken by the District, completion of the revision of all surveillance procedures was delayed beyond the commitment date. Many plant systems have been selected for a complete engineering review and extensive functional testing as part of the System Review and Test Program (SRTP). The SRTP and other efforts related to the restart program necessitated revisions to the allocation of resources that were originally designated for the surveillance procedure rewrite effort. Additionally the byproduct of the ongoing system evaluation process has resulted in changes to surveillance requirements and the surveillance writers guide, thereby expanding the scope of the original rewrite project.

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The District tas aware of the subject commitment and was tracking this item en the Coordinated Commitment Tracking System (CCTS). The responsibility for not informing the NRC Regional Office of the District's internal change to the commitment date is shared by personnel within the plant who were responsible for the commitment and by the Licensing Department which tracks the commitments and issues NRC notifications.

Actions to correct this incident and to prevent its recurrence are described in sections 3 and 4 of this response.

3) Corrective actions which have been taken and results achieved:

The surveillance procedure rewrite effort is proceeding. To-date, 67 procedures have been revised. The revised procedures include the required documentation of instrument calibration data in accordance with the Writer's Guide for Surveillance Procedures, AP.303A. The present focus of the rewrite effort is intended to ensure that those surveillance procedures required for startup and to maintain oparable ,

status during power operation will receive an engineering review and '

be revised to assure technical adequacy prior to plant restart.

Instrument calibration data will be included in these revisions.

To ensure that commitment deadlines are not changed or missed without proper notification to the NRC, the Licensing Department is drafting instructions to strengthen the current procedures by which CCTS personnel focus on highest priority, i.e., regulatory and other external, commitments. These instructions will enhance the effectiveness of the CCTS and involve:

. Issuing to the responsible groups biweekly computer printouts which list commitments by priority and due date.

. Following up with groups responsible for commitments to ensure timely completion or appropriate notifications.

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. Forwarding to the CEO Nuclear, copies of high priority commitments (both QTS Priority 1 and otherwise) which fail to be completed ontime, with an identification of the cognizant manager.

The CCTS group will not revise regulatory commitment due dates without the proper notifications to the NRC.

4) Corrective steps which will be taken to avoid further deviation:

As indicated in section 3 above, surveillance procedures required to support restart will be reviewed and revised to assure technical adequacy prior to plant restart. The remaining procedures will ,

continue to be revised to assure technical adequacy as the procedures are required to be performed. The procedures will be revised to reflect the format requirements of the writers guide no later than the first blannual review of the procedure following restart.

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• To ensure that additicnal priority commitments have not been everlocked, Licensing is reviewing the current open commitment data base and, as appropriate, will notify the NRC of commitment dates which require revision.

5) Date full compliance will be achieved:

Due to the large number of changes, including equipment modifications, Technical Specification amendments, and SRTP evaluations of selected system surveillance requirements, it is not possible to estimate a

(. 4 specific commitment date by which all surveillance procedures will be y( '

revised. However, the District can commit to the following:

. Those procedures required to support plant restart will be in full compliance prior to restart. ,

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'i - Following restart, the remaining procedures will be in full compliance prior to their use.

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