IR 05000312/1987020

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-312/87-20. Corrective Actions Will Be Verified During Future Insp
ML20236P047
Person / Time
Site: Rancho Seco
Issue date: 11/12/1987
From: Chaffee A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Andognini G
SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8711170123
Download: ML20236P047 (1)


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Docket No. 50-312 NOV i 21987

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Ranch'o Seco' Nuclear Generating Station Sacramento Municipal Utility District l 14440 Twin Cities Road Herald, California 95638-9799 Attention: Mr.. G. ' Carl Andognini '

Chief Executive Officer, Nuclear Gentlemen:  !

i Thank you for your letter of October 20, 1987, in response to our Notice of Violation and Inspection Report No. 87-20, dated September 21, 1987, informing us of the. steps you have taken to correct the items which we i brought to your attention. Your corrective actions will be verified during a future inspection.

l Your cooperation:with us'is appreciated.

Sincerely,

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[ j A. E. Chaffee, Deputy Director Division of Reactor Safety and Projects bec w/ copy of letter dated 10/20/87:

Project. Inspector  !

Resident Inspector Docket File B. Faulkenberry State of California lu (? k

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1$suun SACRAMENTO MUNICIPAL UTIUTY DISTRICT C P. o. Box 15830, Sacramento CA 95852 1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA GCA 87-651 BCTt0tgn '

U. S. Nuclear Regulatory Commission Attn: J. B. Martin, Regional Administrator Region V office of Inspection and Enforcement 1450 Maria Lane, Suite.210 i Walnut Creek, CA 94596 Docket No. 50-312 Rancho Seco Nuclear Generating Station '

License No. DPR-54 RESPONSE TO NOTICE OF VIOLATION 87-20 Q

Dear Mr. Martin:

On September 21, 1987, the Sacramento Municipal Utility District received a Notice of Violation concerning activities at- the Rancho Seco Nuclear Generating Station. In accordance with 10 CFR 2.201, the District provides the enclosed responses to this j Violation.

q This letter acknowledges the violations cited, and describes the l District's intended corrective actions. t l

Please contact me if you have any questions. Members of your staff with questions requiring additional information or clarification may contact Paul Lavely at Ext. 4674.

Sincerely,

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f a6h Is,u I

G.' Carl'Andognini Chief Executive Officer, Nuclear l

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o .- y ar yin [J//DQ RANCHO SECO NUCLEAR GENERATING STATION ' 14440 Twin Cities Road. Herald, CA 95638-9799;(209) 333 2935

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ATTACHMENT l'

-DISTRICT RESPONSE TO NOTICE OF VIOLATION 87-20L a . . .

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~NRC Statement of Violation-A.

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10 CFR--50,. Appendix -B,: Criterion. IX,

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"Controll: .of Special Processes,'"' states, in part:

" Mea'sures- shall be established to assure. that. special~

- processes,. including . . . . heat treating, ' are controlled: and accomplished. by qualified . personnel- using. qualified.

l procedures in' accordance with applicable codes, standards,-

specifications,e criteria and.other special' requirements."-

Quality Assurance Policy Section IX, Revision 0, - " Control' o'f '

Special. Processes," Paragraph 3.O,

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states:

" Appropriate ~ procedure and methods shall be prescribed and'

implemented to assure that special processes,' equipment and.

personnel. are- controlled and - accomplished by qualified-L personnel and procedures".

Contrary to ' these requirements, on June 24, 1987, heat treating l .of the yoke of. safety. features valve SFV-25004 was not controlled i .- or . accomplished using. a qualified procedure. .This work; was L performed under- Work. Request #1133657 (sic) . with no specific

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-provisions for heat treating.

l. This is a severity level IV violation (Supplement 1).

District Response

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1) Admission or denial of. alleged violation:

The District acknowledges and admits-that the above occurred as stated.

'2) Reason for the violation: i Work Request #133657 was initiated to perform Penetrant Testing on the yoke of valve SFV-25004. The scope of this work request was expanded to include repair welding of the-yoke.

legs.

After welding, distortion was observed on the yoke q To remedy this problem, the distorted areas were heat treated. The welding engineer was informed of the intended I steps and concurred with the plan of action prior to heat I treatment. Work Request #133657 was revised to document the heat treatment. l I

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PAGE TWO ATTACHMENT 1 Although 1) the heat treatment was performed under the direction of a maintenance engineer and 2) the individual steps- were documented, the work was not performed in accordance with an approved procedure.

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

Nonconforming Report S-6790 was initiated on June 24, 1987 to address the affect of heat treating the valve yoke. The disposition action of the Nonconforming Report analyzed the impact of the heat treatment and stated that the valve yoke is suitable for its intended use.

4) Corrective action which will be taken to avoid further violations.

Procedure M.308 " Mandatory Welding Practices" will be revised to include instruction for heat treatment to eliminate weld distortion. The revised procedure will ensure that any future heat treating to eliminate weld distortion will be procedurally controlled.

5) Date when full compliance will be achieved:

Full compliance will be achieved by January 1, 1988.

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T, LATTACHMENTi2

' DISTRICT' RESPONSE-TO NOTICE OF' VIOLATION'87-20-

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NRC-Statement of Violation-B. '

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10. CFR : .50, L Appendix M.B, - i criterion

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X, . "Inspe'ction'," , states, in part::

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"A prcgram' for inspection of activitids' . affecti'n g quality a L shall be' establish'ed:and= executed by or for the organization i L performing the activity toc verify; conformance with the'-

documented .)

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instruction,- procedures ,and: drawings .for- ;

accomplishing the-activity ..."' j-i Quality 7. Assurance Policy Section X, Revision

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!. states,1 in paragraph 14.8:-' <

0, ' " Inspection, " j

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-A construction: inspection program ' will- be; performed on q

' Class I and: Environmental Qualified'(EQ)Lequipment to. assure construction and -installation activities are in conformance ,

to designf drawingsr and specifications ..'."

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'I Licensee construction.. procedure NPEM. 8304.7.C

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-(sic).section.

5.l'.27 requires that'the minimum bend c radius . for. 4 AWG triplex -

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cable be.l.6 inches.

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Licensee . construction procedure NPEM 5304.7.C - section 5.2

requires'.the: installation of cable tray' bumpers and' installation- 1 of: separation group color' markings. d

. Contrary:to these1 requirements, an el'ectrical cable-for essential-HVAC. air - handling unit 'AH-DG-1B had an . electrical' cable L bend =

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radius of 3/4"-in the motor' terminal box.- In cable trays-A57El.

and A57015 no cable tray edge bumpers existed. . Electrical 1 pull }

box'H7J2995, which contained an "A" channel. safety related cable, 4 was-color marked black rather than red, as required.

This is-a Severity Level IV violation (Supplement 1).

District Response I

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1) Admission or denial of alleged violation:

The. District acknowledges and admits that the above occurred  !

as stated.

2) Reason for the violation:

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The current procedures used to control the installation of I cables and cable trays were not in effect 'when this j

equipment was installed. Additionally, the present '

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i nspection: criteria were not: -in - .~ e f fect, when this construction:was performed.

i 3) corrective actions which have been 'taken' .and results-achieved'. -;

Nonconforming ' Report No. S-6843 was initiated on . Julyi 14,-

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1987, to address the = improper color marking of J electrical-junction box H7J2995. The incorrect .blackL marker 'on this box was replaced ' with a red diamond one. In addition, ' a '

sample inspection was made of ' 2 6 out of ~ the '32 class: I junction boxes associated with diesel generator: assemblies G-100A-and G-100B. All of the. junction boxes inspected were-correctly marked. Based on'the result of this survey, the incorrect Lcolor marking of junction box- H7J2995 is considered to be an isolated event.

-Nonconforming Report S-6844,- initiated on July 14, '1987,- l addresses the lack'of cable tray edge protection'on trays A-57El and L57B2. This protection has-been installed on the .

traysL in 'accordance with procedure 'NEP 5304.7C. In !

addition, the two cables impacted.by these trays have been-

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insulation ' resistance tested and.-found to be in acceptance condition.

4)' Corrective actions which will' be taken to avoid further  !

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violations.

..The planned corrective actions for.the improper bend radii of cables 121A412A and 121B412A 'are to resize! the appropriate terminal boxes and rework the cables to meet the  !

acceptance ~ criteria of' installation specification IS-E- l 5304.8. ' After the rework is completed the cables will be j insulation resistance tested to verify that the rework has ~

not' degraded cable performance. These activities should be completed by November 1, 1987.

To ensure that additional cables associated with TDI diesel construction work do not have improper bend radii, an inspection is being performed of all cables located inside i enclosures and equipment associated with the TDI diesels. l The acceptance criteria for this inspection is'specified in  !

IS-E-5304.8. This inspection will be completed by November j

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1, 1987.  ;

i 5) Date when full compliance will be achieved.

Full compliance will be achieved by November 1, 1987, i

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