ML20212K961

Responds to NRC Re Violations Noted in Insp Rept 50-312/86-38.Corrective actions:127 Snubbers Rebuilt & Functionally Tested Since Last Refueling Outage in June 1985

ML20212K961
Person / Time
Site:	Rancho Seco
Issue date:	02/23/1987
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20212K952	List: IR 05000312/1986038 ML20212K961
References
JEW-87-225, NUDOCS 8703090472
Download: ML20212K961 (5)

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$SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O P. o. Box 15830, Sacramento CA 95852-1830,(916 AN ELECTRIC SYSTEM SERVING THE HEART OF CALI El 3211 NIA JEW 87-225 l'/g FEB 2 31987 I J. B. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region V, Office of Inspection & Enforcement 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 Responseto Notice of Violation (NRC Inspection Reports No.

50-312/86-38)

Dear Mr. Martin:

By letter dated January 22, 1986, the Sacramento Municipal Utility District was transmitted a Notice of Violation concerning inadequately incorporating vendor information in the surveillance program, specifically for the Technical Specification listed snubbers. In accordance with 10 CFR 2.201, the District provides the enclosed response to the Notice of Violation.

This letter acknowledges the violation cited and describes our intended corrective actions for each specific item listed in your Notice.

Sincerely,

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h . Ward Deputy General Manager, Nuclear Attachment cc: A. D'Angelo S. Miner INPO l

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8703090472 870227 PDR ADOCK 05000312 ge'- 4 /

RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333-2935

ATTACHMENT 1 DISTRICT RESPONSE TO NRC INSPECTION 86-36 NOTICE OF VIOLATION NRC Violation As a result of the inspection conducted during the period of November 17-21 and December 8-23, 1986, and in accordance with NRC Enforcement Policy, 10 CFR Part 2, Appendix C, the

, following violation was identified:

10 CFR Part 50, Appendix B, Criterion V, Instructions,.

Procedures and Drawings,~ states in part, that " Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important- activities have been satisfactorily accomplished."

QA Procedure, Policy Section V, Instructions, Procedures and.

Drawings, Section 4.3, states " Instructions, procedures, or drawings require applicable quantitative and/or qualitative acceptance criteria for verifying that the activities have been satisfactorily accomplished."

Contrary to the above, on June 26, 1986, procedure SP 201.10B for functional testing of snubbers did not include appropriate acceptance criteria for lock-up velocity. Specifically, the velocity was not corrected for temperature as recommended by the respective vendors.

This is a Severity Level IV Violation.

District Response to Violation

1) Admission or denial of the alleged violation.

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

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2) Reasons for the violation The District did not adequately adopt the information supplied by the snubber manufacturers (Bergen-Patterson and ITT Grinnell). This vendor documentation reveals that, as the test temperature increases,. snubber lock-up velocity and bleed rates also. increase. There was insufficient documentation of the inter-action with the vendor in 1979 when the procedure was written originally. Additionally, the bi-annual review process for procedures during the period did not specifically require inclusion of new vendor information into the reviewed procedures. However, it should be noted that steps 4.7.7 and 4.7.18 of Enclosure 4.7 of AP.2 could have conscientiously been interpreted to include the review of vendor information as part of a bi-annual review of procedures.

The functional testing via surveillances or other tests is intended to demonstrate equipment operability and thereby reliability. The management system in control of snubber surveillance was changed to incorporate manufacturer'is recommendations and engineering / documentation based acceptance criteria for the allowable movement of snubbers.

Surveillance Procedure (SP) 201.10B previously did not:

1) provide any specific temperature prerequisites for functional tests; or

2) indicate if the limits set in SP 201.10B

, Enclosure 6.1 were based on a given functional test temperature or power operation temperature.

l Because lock-up velocity and bleed rate are temperature I dependent, the temperature at which the functional (SP i 201.10B) test is performed needs to be known in order to accurately assess the snubbers' operability.

The previous surveillances were less than adequate with respect to having realistic acceptance criteria

regarding inches-per-minute of movement allowed for the snubber application with respect to operating conditions, particularly temperature.

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These events are more extensively described in the District'Is Licensee Event Report 87-011, in a letter from J. E. Ward (SMUD) to J. B. Martin (NRC) dated

-February 18, 1986

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

Several Nonconforming Reports (NCR's) were written.

during 1986 and 1987 to identify snubbers which could not meet the improved acceptance criteria. The snubber failures were due to a variety of concerns, for example age related failure of seals, improper acceptance -

criteria and' variations in lock-up and bleed rates over time.

One-hundred-twenty-seven snubbers have been rebuilt and functionally tested since the beginning of the last refueling outage in June 1985. Most of those snubbers were rebuilt since the snubber refurbishment program

. began in June 1986.-

An engineering judgement as to the operability of the sixteen snubbers servicing the decay heat system trains was not performed until a February 2, 1987 ODR (87-125) was filed due to the planned rebuilding of these snubbers during the " imminent" Decay Heat System Outages. This

evaluation has since concluded that the Decay Heat l System related snubbers were either operable as-is, or the " Action" statement of Technical Specification 3.1.1.5 was entered to rebuild the affected snubber.

The remaining thirteen snubbers are used in the operable decay heat removal system trains and their required auxiliaries. Those snubbers in the Decay Heat related systems which needed to be rebuilt to address snubber expected seal service life will be rebuilt during the upcoming decay heat system train outages.

The refueling interval surveillance procedure was revised to incorporate the revised acceptance criteria (RE: Calculation Z-ZZZ-M2026) and the "ethod of temperature compensation was revised (test conditions versus operating temperature conditions based on manufacturer's curves) on January 19, 1987 (RE: SP 2 01.10B, Revision 11).

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l 4). Corrective steps which will be taken to avoid further i violations.

The use of vendor supplied information in the development and review of procedures (specifically acceptance criteria) for safety-related equipment supplied to the District, will be. included in the bi-annual review procedure (Ju?.27) via an update to its referenced Enclosure 4.7 of AP.2.

5) Data full compliance will be achieved.

The District will have rebuilt all safety-related snubbers (whose seals' expected life are due to expire prior to the next refueling outage) by the and of the upcoming decay heat system train outages currently scheduled to be completed by April 25, 1987. The corrected procedures for snubber preventive maintenance are already in place. The bi-annual review procedure's check list (Enclosure 4.7 of AP.2) will be revised per this response by March 23, 1987.

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