IR 05000312/1989001

Ack Receipt of Responding to Violations Noted in Insp Rept 50-312/89-01.Reasons for Denial of Violations a & B.2 Will Be Reviewed During Future Insp

ML20246E823
Person / Time
Site:	Rancho Seco
Issue date:	06/30/1989
From:	Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8907130011
Download: ML20246E823 (1)

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Docket No. 50-312' >

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~ Rancho Seco Nuclear Generating Station Sacraniento Municipal Utility District 14440 Twin Cities Road ,

Herald, California '95638-9799

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' Attention:' Mr. Joseph F. Firlit Chief Executive Officer, Nuclear; Gentlemen:

, Thank you .for your letter of A' pril 26, 1989, in response to our Notice o '

. Violation and Inspection Report No.-50-312/89-01, dated March 27, 1989. .Your

. letter admitted violations B.1 and C and informed us of the steps you have

, taken to correct the items' which we brought to your attention. Your-

' corrective actions will be verified during a, future inspectio In addition, your letter denied violations A and The reasons you. state-cfor denial of those violations will be reviewed during a future inspectio Your cooperation with us is appreciate

Sincerely,

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Roy Zinv6 an, Acting Director-

, Division f Reactor Safety and Projects

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SRic ards' MMendonca Zimmerman d@ Johnson 06/30/89 06/q/89g 06/3c/89 06/7//89-REQUES JP fA')EST

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. SACRAMENTO MUNICLPAL UTILITY DISTRICT C 0.201 S Street. PO. Box 15830. Sacramento CA 8 2 1830.(916) 452 3211 }

AN ELECTRIC SYSTEM SERVINGggEgRT OF CALIFORNIA CEO 89-196 89 3 27 A10 : D4

, April 26, 1989 U. S. Nuclear. Regulatory Commission Attn: ' Document Control' Desk Hashington, DC 20555' *

Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE.TO NOTICE OF VIOLATION 89-01 Attention: George Knighton On April 3,1989, .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 response to this violatio This letter acknowledges two'of.the violations and describes the District's corrective actions. Two violations are denied; the District's reasons fo denial are explaine The Inspection Team also identified the following concerns: Inadequate attention to detail in engineering analyses, generation of work instructions, control of documents, and consideration of industry experience and initiative . Absence of involvement of some organizational units in the review and performance of technica' work, especially post-maintenance testin . Weakness in communications between some organizational units, in the review and performance of technical wor These issues have also been. identified by the District through our reviews and investigations as areas of concern. The District is committed to quality and continues to improve the programs at Rancho Sec Through such programs as the Incident Analysis Program, the District evaluates events, identifies root causes and implements corrective actions. Deficiencies are also identified and corrective actions implemented through the Quality audit progra Industry experience from sources such as the B&W Cwners Group, INPO and the NRC is factored into our programs whenever possibl g g-.g..g h h }_

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' RANCHO SECO NUCLEAR GENERATING STATloN O 1444o Twm Cities Road. Herald CA 95638-9799;(209) 333 2935

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George Knighton

• [ -2- CEO 89-196 Recent improvements in our programs include: Involving the system engineers in the work request and post-maintenance testing processes, Establishing a closer working relationship for the working groups at Rancho Seco by putting on-shift representatives from Quality, Nuclear Engineering, Maintenance, and System Engineering in the same office in close proximity to the Contiol Room, Increased emphasis on shift turnover and pre-test and pre-job briefings, Enhancements in the Operating Experience Program through which operating experience from other plants is reviewed, corrective actions identified and implemented, and training performed, and Establishing the Management Review Board process whereby management reviews internal issues and events and identifies corrective personnel action Additional steps to be taken to improve our programs are discussed in the Notice of Violation responses. Further investigations will be conducted during the review and resolution of the open items identified in the inspection repor Members of your staff with questions requiring additional information or clarification may contact Harla Mueller at (209) 333-2935, extension 468

Sincerely,

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' Joseph F. Firlit Chief Executive Officer Nuclear Enclosure cc w/ enc: J.B. Martin,NRC;'HalnutCreek9 A. D'Angelo, NRC, Rancho Seco i

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. DISTRICT RESPONSE TO NOTICE OF VIOLATION 89-01 s

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.N_RC STATEMENT OF VIOLATION A CFR 50, Appendix B, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and correcte Rancho Seco procedure, QAP-17, " Nonconforming Material Control,"

Revision 7, requires that a Nonconformance Report (NCR) be written when a nonconformance is identified. It defines a nonconformance as a

" deficiency in characteristic, documentation or procedure which renders the quality of an item (materials, parts, components or system)

unacceptable or indeterminat Examples of nonconformance include:

physical defects, test failures, incorrect or. inadequate documentation, or deviation from prescribed processing, inspection or test procedures.

! Nonconformances are hardware related."

Contrary to the above, during the period of November 8,1987 thru January 9,1988 an NCR was not written when it was determined that debris had caused the failure of two instrument air system check valves during the performance of special test procedure STP-77 This is a Severity Level IV violation (Supplement 1).

, DISTRICT RESPONSE TO VIOLATION A Admission or denial of alleged violation:

The District denies that the above is a violatio Special Test Procedure STP.774, " Instrument Air Backup to TBV, CCW

Containment Isolation Valves, Feedwater System Control Valves, MFW, SFW, AFW, and ADV Using CLBB and ADVs Using APP "R" Bottles" was a preoperational functional test of the compressed air backup system During the performance of STP.774, two instrument air system check valves failed to seat. These valves were disassembled and a small amount of debri: was found in eac Failures of these valves to seat properly were identified as Test Deficiencies No. 2 and 10. Work Requests (No. 137177 and 138589) were written to resolve the deficiencies. Under the Work Requests the valves were removed, disassembled, internals cleaned, reassembled, pressure tested, and reinstalled into the system. The test engineer concluded that the debris found in the valves was from recent construction activitie STP.774 was performed and the valves functioned satisfactorily.

l Administrative Procedure AP.82, " Conduct Of Special Testing," Step 6.3.11.2 states: l

"If a test deficiency occurs, it shall be documented either on a f PICN, PTCN, WR, NCR or ODR in accordance with QAP-17 and the document I number noted in the test log."

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In'accordance with AP.82,'the valve failures were noted as Test'

Deficiencies: and documented in Work Request Nuclear Quality. Manual QAP-17 " Nonconforming Material . Control," Revision

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7, Step 5;1.1 states:

l " Systems, equipment and appurtenances, components, parts or material which do not. meet the specified requirements of purchase orders,.

design drawings, operational / test documents, or construction documents shall be considered nonconforming. Refer to Attachment 3 for guidelines on when to write 'iCRs."

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QAP-17, Attachment 3 states in the summary section:

"If'a test fails and the test results are toLbe submitted for review and approval with the failed step, an NCR. shall be initiated to document-the test failure."-

In' addition, AP.82, Step 6.3.11.3 states:

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"If a test deficiency which affects Acceptance Criteria occurs, an NCR shall be written if the intent is to accept the test results

'as-is'."

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The deficiencies were resolved and the check valves retested during the performance of STP.77 The original Acceptance' Criteria of STP.774 was me Based on the above procedural requirements, the fact that the deficiencies were documented on Work Requests, and all other procedural requirements were met, the District believes that the occurrences were adequately documented and denies the alleged violatio NRC STATEMENT OF VIOLATl0N B CFR 50, Appendix B, Criterion III requires that measures be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions.of their structures, systems and component Rancho Seco procedure RSAP-0303, " Plant Modifications," Section 5. requires that Nuclear Engineering has overall design responsibi'lities including development of the conceptual design and detailed desig Section 4.8 of RSAP-0303 requires that the detailed design includes design definition documents and design substantiation documents which peesent the-design and verification that the design is correct. Design substantiation documents include: design basis reports, design verification report, safety analysis report, calculations and interdiscipline document review notic Contrary to the above, as of February 14, 1989, conceptual or detailed design records'did not include calculations to substantiate the design of: Two 1-inch diameter, non-safety grade, carbon steel pipelines, which connected to safety grade Auxiliary Feedwater System piping, as provided by Temporary Modification number TP-89-11. This piping was installed during the week of February 6,198 _--___ . _ - _ _

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I '.' 2. 'A' gag mechanism, which was fabricated in SMUD shops and installed oni

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< Main Steam safety valve PSV-20544. The gag mechanism was observed in

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place during the week of February 6,19u .

'This is_a Severity Level'IV' violation (Supplement 1).

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DJ3JTEJfT RESPONSE TO VIOLATION . Admission or denial of alleged violation:

The District acknowledges and admits that the above occurred as state . Reason for the violation:

No seismic analysis was required for Temporary Modification 89-11 since the AFH System,was inoperable and the temporary piping was to be removed from the AFH System prior to leaving cold shutdown and declaring the System operable. The preparers of Temporary Modification 89-il did not l' clearly state when the temporary piping was to be disconnected and why no seismic analysis was required. In addition, the 10 CFR 50.59 evaluation

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did not clearly state that the modification was to be removed prior to leaving cold shutdown. However, the temporary modification tag report did

. state that the temporary modification was to be removed when the'AFH System was declared operable and failure'to temove the temporary modification would result in a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> LCO. .The planners and maintenance personnel involved planned to remove the temporary modification prior to leaving cold shutdow . Corrective actions taken and results achieved:

The temporary piping was removed under Work Request 154927 on March 3, 1989, prior to leaving cold shutdown on March 7. The 10 CFR 50.59 evaluation will not be revised since the temporary piping has been remove . Corrective actions to avoid further violations:

Qualified 10 CFR 50.59 reviewers will be notified through a memorandum of the need to document temporary modifications so as to be understandable to knowledgeable individuals unfamiliar with the particular modificatio The importance of adequately documenting temporary modifications will also be included in the 10 CFR 50.59 qualified reviewer training cours . Date when full compliance will be achieved:

Qualified reviewers will be notified by May 1,1989. The 10 CFR 50.59 Qualification Training lesson plan will be revised by May 15, 198 PlS_TRICT RESPONSE TO VIOLATION . Admission or denial of alleged violation:

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.g * ' A design calculation was not required because the installation of the gag

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mechanism on Main Steam Safety Valve PSV-20544 was not a design change e since the overall function of the system remained unchanged. Technical Specification 3.4.2 only required 17 out of 18 main steam safety valves to be operable. The gag was a temporary repair to solve the problem of the valve opening prematurely until the plant was brought to cold shutdown and the valve removed for repair. Since gagging the valve was not a plant modification as described in RSAP-0303, but a repair per RSAP-1310, the repair was~ documented under the Potential Deviation from-Quality (PDQ) process per RSAP-1308. This process' included a 10 CFR 50.59 analysis. Additionally, the gag' mechanism installed was a standard gag as described by the vendor in the vendor manual. The

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District had evaluated and approved both the manual and the gag which had been selecte tMC STATEMENT OF VIOLATION C 1 CFR50, , Appendix B, Criterion V as implemented by the' Rancho Sec Quality

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Manual (RSQM) Revision 2,Section V, Step 4.2, requires that:

... instructions, procedures, or drawings-shall include applicable quantitative and/or qualitative acceptance criteria for verifying that the activities have been satisfactorily. accomplished." Maintenance Administrative Procedure (MAP)-006 Revision 5, Step 6.2.6.3(2) requires that a work instruction shall include acceptance criteri .

Contrary to the above, Work Request (HR)L01541360-1, issued on February 9,.

1989 for removal' and detailed diagnostic. inspection of the auxiliary feedwater pump governor valve linkage, did not'contain acceptance criteria I

for critical measurements; neither minimum / maximum expected values, nor-maximum measurement' tolerances were include This is a severity level IV violation (Supplement I).

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DISTRICT RESPONSE TO VIOLATION C i Admission or denial of alleged violation:

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The District acknowledges and admits that the above occurred as state . Reason for the violation:

j The lack 'of acceptance criteria in Work Request 01541360-1 was due to lack i l

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of understanding of the procedural requirement to provide acceptance criteria for all Work Requests. Although-Maintenance Administrative f Procedure MAP-0006, " Work Request Planning," is the controlling document, L it does not provide sufficient direction to Maintenance Planners on the i

use of acceptance criteria.

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The engineer who evaluate'd the data obtained from Work Request 01541360-1 was involved in planning the Work Request, attended the pre-job briefing, and was in attendance when the measurements were take The data taken was adequate for the investigation of the as found conditions of the governor valve linkage. The results of the investigation are fully documented in PDQ 89-148, Revision . Corrective actions to avoid further violations:

Maintenance Administrative Procedure MAP-0006 will be revised to more clearly state the use of acceptance criteria for activities affecting quality. Maintenance Planners will be trained on the revised procedur . Date when full compliance will be achieved:

A temporary change to procedure MAP-0006 will be issued and Maintenance Planners trained by May 1, 1989. A permanent revision of procedure MAP-0006 will be issued by July 15, 198 .

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