ML20202D721

Responds to NRC Re Violations Noted in Insp Rept 50-312/86-13.Corrective Actions:Qa Implementing Procedure Qaip 10, QA 10CFR50.59 Review Procedure, Revised to Facilitate Timely Processing of Changes

ML20202D721
Person / Time
Site:	Rancho Seco
Issue date:	06/17/1986
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20202D699	List: IR 05000312/1986013 ML20202D721
References
JEW-86-109, NUDOCS 8607140203
Download: ML20202D721 (3)

Text

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$SMUD SACPAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, P.O. Box 15830, Sacramento CA 95852-1830.(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA JEW 86-109 June 17,1986 J B MARTIN REGIONAL ADMINISTRATOR -

REGION V 0FFICE OF INSPECTION & ENFORCEMENT '@ 't; V S NUCLEAR REGULATORY COMMISSION 6' f,&.

1 1450 MARIA LANE SUITE 210 ,, 'Tp

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WALNUT CREEK CA 94596 Jy 9

.c DOCKET NO. 50-312 LICENSE N0. DPR-54 Q

. 'i NOTICE OF VIOLATION FROM NRC INSPECTION 86-13, UNTIMELY SUBMITTAL OF h 10CFR50.59 SAFETY EVALUATION SUMMARIES The Sacramento Municipal Utility District hereby submits the 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. Colombo at the Rancho Seco Nuclear Generating Station.

N . ARD ASSISTANT GENER L MANAGER, NUCLEAR (ACTING)

Attachments 8607140203 860708 PDR ADOCK 05000312 G PDR I

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s. s ATTACHMENT I DISTRICT RESPONSE TO NRC INSPECTION 86-13 NOTICE OF VIOLATION As a result of the inspection conducted by Messrs. G. Perez and C. Meyers, between March 10 and April 21, 1986, the following alleged violation was identified:

10 CFR 50.59 (b) states, in part, "...the licensee shall furnish... annually or at such shorter intervals as may be specified in the license, a report containing a brief description of such charges... including a summary of the safety evaluation of each."

In addition, paragraph 6.9.3 of the Rancho Seco Technical Specifications specifies, in part, "... tabulation of fa-cility changes, tests or experiments required pursuant to 10 C R 50.59 (b), shall be submitted on a monthly basis..."

Contrary to these requirements, SA-516 plate material was used in 1983 for new containment penetration assemblies in lieu of the forged assemblies specified in the Updated Safety Analysis Report. This change was not reported un-til March, 1986. The report contained no summary of the 10 CFR 50.59 evaluation.

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

Response

The Notice of Violation accurately describes that modifications have been made to the facility, under the provisions of 10 CFR 50.59, which were not reported to the NRC within one year of acceptance by the operating staff.

The source of this apparent violation was a presumption by the District that the monthly reporting requirement of Technical Specification 6.9.3 took precedence over the annual requirement of 10 CFR 50.59(b) and that the modifications, tests, experiments or procedure changes should be re-ported after all the closing signatures for the changes had been obtained.

It was also presumed that only " tabulations" of changes, and tests or ex-periments were required, as stated in Technical Specification 6.9.3, and not summaries of the safety evaluations as stated in 10 CFR 50.59(b). It has become apparent that these presumptions are no longer considered acceptable.

The District has been engaged in a significant effort to reduce the backlog which has developed, as a result of this misunderstanding. As of January 1, 1986, there were 178 modifications, procedure changes, and tests or ex-periments which were awaiting closure by the QA Department in accordance with existing procedures. As of June 1, 1986, 169 of the 50.59 changes were closed and ready for review for inclusion in the monthly operating report. The remaining 9 items will be ready for review shortly thereafter.

. ..t Recognizing the need to improve 10 CFR 50.59 reporting, the District is revising procedures to ensure a report to the NRC of each change made pursuant to the provision of 10 CFR 50.59 within one year and normally much sooner. These changes will be made prior to plant restart from the current outage. It should be noted that there may be modifications which are in the process of installation for over a year which will not be reported until they are accepted by the plant operations organization.

In addition, Quality Control Implementing Procedure (QAIP) 10, " Quality Assurance 10 CFR 50.59 Review Procedure", has been revised and. implemented to facilitate the timely processing of changes made under the provisions of 10 CFR 50.59.

The process of evaluating approximately 180 changes to the plant, includ-ing a summary of each safety evaluation, will take some time and there-fore, the District will resolve the existing backlog by the August 1986 Monthly Operating Report.