ML20004B061
| ML20004B061 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 05/07/1981 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20004B060 | List: |
| References | |
| NUDOCS 8105270173 | |
| Download: ML20004B061 (2) | |
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u SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT CJ 6201 S Street Box 15830, Sacramanto, California 95813; '916) 452-3211 b
May 7, 1981
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R. H. ENGELKEN, DIRECTOR
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REGION V 0FFICE OF INSPECTION & ENFORCEMENT
-1 U. S. NUCLEAR REGULATORY COMMISSION
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1990 NORTH CALIFORNIA BLVD WALNUT CREEK PLAZA SUITE 202 S.
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.u OPERATING LICENSE OPR-54 DOCKET NO. 50-312 RESPONSE TO YOUR LETTER DATED APRIL 14, 1981 RE: NOTICE OF VIOLATION DATED FEBRUARY 27, 1981 In reply to your letter dated April 12, 1981, requiring the District to submit a further written statement or explanation in reply to your Notice of Violation dated February 27, 1981, we offer the following explanations and corrective steps which will be taken to avoid further i tems of noncompiiance.
Appendix "A" of the February 27, 1981 Notice of Violation notes the following:
10 CFR 50.59(b) states, in part, "The licansee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that such changes constitute changes in the facility as described in the safety analysis report....These records shall include a written safety evaluation which provides the basis for the determination that the change, test or experiment does not involve an unreviewed safety question."
Section 8.2.3.1 of the Final Safety Analysis Report describes a quick starting feature of the emergency Jiesel generators, in part, as follows:
"DC-motor driven....hyd rcul i c governor oi l pumps are provided for starting. After the en,ine is up tc speed, direct driven governor oil pumps take over."
Contrary to the above, on April 18, 1980, the licensee discovered that the piping for the B" Diesel Generator DC-driven governor oil booster pump was improperly routed, thereby causing the quick start starting feature to be disabled. This apparently corati-tutes a change in the facility as described in the FSAR. Although
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r R. H. Engelken May 7, 1981 i
Nonconforming Report 5-1910 authorized postponement of corrective action until the next refueling outage (several months later),
there is no record of a written safety evaluation showing that the postponement did not involve an unreviewed safety question.
DISTRICT REPLY (1) The District concurs with the findings that the "B" Diesel Cenerator did not have the DC-motor driven hydraulic governor quick start system as described in Section 8.2.3.1 of the FSAR. Additionally, the District concurs with your determination that continued operation of the "B" Diesel Generator without the DC-motor driven hydraulic governor quick a written safety start system operable constituted a change requiring evaluation in accordance wi th paragraph 50.59(b).
(2)
The determination that a 50.59 evaluation was unnecessary was an over-sight by Management, possibly influenced in part by the fact that tests had veri fied that, although the governor was plumbed differently, the "B" Diesel Generator started well within the 10 second time criteria and performed within the definition of " operable" as stated in Technical 2
Specifications Section 1...
(3) As stated in our initial reply dated March 26, 1981, the "B" Diesel Generator governor was replaced early in the present refueling outage with a governor which is plumbed properly with respect to the quick start system. To perform a safety evaluation at this point in time, after the fact, would be ineffectual and of questionable benefit to either the District or your office.
(4)
It is the District's contention that this occurrence is an isolated Systematic controls are in effect (i.e., QAPs and QCis) which case.
are considered adequate to preclude future recurrences, These controls have proven to be adequate in the past. At the present time. to revise the existing systematic controls due to an i solated case i s' ~ cons idered unnecessary.
Additionally, those individuals who perform the 50.59 eview determina-tions are cognizant of this particular occurrence and are even more attuned to the requirements of 10 CFR 50.59 as a resul.
(5)
It is the District's conte,ntion that we are presently in full compliance with the applicable regulations.
t LQ WQ v#ohn 3. Mattimoe J
Assistant General Manager and Chief Engineer e
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