IR 05000312/1986018

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-312/86-18

ML20207D367
Person / Time
Site:	Rancho Seco
Issue date:	12/22/1986
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8612300386
Download: ML20207D367 (1)

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DEC 221986

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Docket No. 50-312 Rancho Seco Nuclear Generating Station 14440 Twin Cities Road Herald, California 95638-9799 Attention: Mr. John E. Ward Deputy General Manager, Nuclear Gentlemen:

Thank you for your letter dated November 20, 1986, informing us of the steps you have taken to correct the items which we brought to your attention in our letter dated June 20, 1986. Your corrective actions will be verified during a future inspectio Your cooperation with us is appreciate

Sincerely,

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Dennis F. Kirsch, Director Division of Reactor Safety and Projects bcc w/ copy of letter dated 11/20/86:

Resident Inspector -

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Project Inspector B. Faulkenberry J. Martin docket file bec w/o copy of letter dated 11/20/86:

M. Smith J. Zo111 coffer W flik

REGION V

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fa 6" LMiller AChaffee DKirich 12/ /86 12/16/86 12/21/86 12/3N86 Y ] REQUEST Y]

REQUEST YES V/ N0 ]COPY YES / ] REQUES 2 ] YES /N0lY]

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esuu. SACRAMENTO MUNICIPAL UTluTY DISTRICT C P. O. Box 15830, Sacramento CA 95852-1830.(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA

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JEW 86 - 896 November 20, 1986 J B MARTIN REGIONAL ADMINISTRATOR REGION V OFFICE OF INSPECTION AND ENFORCEMENT U S NUCLEAR REGULATORY COMMISSION 1450 MARIA LANE, SUITE 210 WALNUT CREEK, CA 94596 DOCKET NO. 50-312 LICENSE NO. DPR-54 NRC INSPECTION REPORT 86-18, INSUFFICIENT CONTROL OVER TEMPORARY MODIFICATIONS The Sacramento Municipal Utility District hereby submits, in Attachment 1, the response to the subject Notice of Violation A (concerning PRC review of proposed plant changes) and Violation B (concerning temporary modifications without invoking the abnormal tag procedure) in accordance with 10 CFR Part 2.201. This supersedes our response on the same subject and we regret any confusion that our previous response may have generate If there are any questions concerning this response, please contact Mr. Ron Colombo at the Rancho Seco Nuclear Generating Statio W tTOHN'E. WARD DEPUTY GENERAL MANAGER, NUCLEAR

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

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ATTACHMENT 1 DISTRICT RESPONSE TO NRC INSPECTION 86-18 REVISION 1 NOTICE OF VIOLATION APPENDIX A VIOLATION A 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 safet Quality Control Instruction QCI-5 defines " Systems or equipment that affect nuclear safety" as those structures, systems or components necessary to assure:

(1)theintegrityofthereactorcoolantpressureboundary, (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 10 On December 9, 1985, reactor coolant pressure boundary valve SFV-22006 was modified to repair a body-to-bonnet lea Contrary to the above, the PRC did not review this modification performed under Noncomforming Report Number S-521 This is a Severity Level IV violation (Supplement I).

VIOLATION B Rancho Seco Technical Specification 6.8.1 states, in part, " Written procedures should be established, implemented and maintained covering the activities referenced below: The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972..."

Regulatory Guide 1.33, November 1972, Appendix A, Paragraph recommends administrative procedures for equipment control (e.g. locking and tagging).

Rancho Seco Administrative Procedure AP-26, Abnormal Tag Procedure, Paragraph 5.2, states, in part "In general, an Abnormal Tag is required anytime an electrical, mechanical, structural or pneumatic system is modified and placed in service without an approved DCN per NEP 4109 to document the chang "

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Attachment 1 (Continued)

Contrary to the above, on December 9, 1986, an abnormal tag was not hung on valve SFV-22006 after being temporarily modified and returned to service under NCR #521 This is a Severity Level V violation (Supplement I).

RESPONSE The District agrees with the NRC citation, parts A and 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, regar.dless of the Part 50.59 determination. This will formally be done by a revision to the NCR and Abnormal Tag procedures described belo 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 to conform to industry practice, including a questionnaire format and a PRC sign-off 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 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-2200 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 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

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connection is fixed and rigid. Hence, appropriate engineering reviews were performed which established that the USAR seismic analysis was unaffected

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by this maintenance modification. The temporary modification to the valve was removed as part of the valve repair on February 13, 1986.

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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 evaluatio This activity will be completed by February 2, 198 To address the programmatic issue of "non-Part 50.59" changes to Class 1 systems and components, the Quality organization will perform a revied of the District's procedures for the control of modifications with respect to 10 CFR Part 50.5 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, 198 .

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