ML20049H670
| ML20049H670 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/19/1982 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20049H662 | List: |
| References | |
| NUDOCS 8203030427 | |
| Download: ML20049H670 (4) | |
Text
c jSMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 15830, Sacramento, California 95813; (916) 452-3211 M?l February 19, 1982 g
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R H ENGELKEN, REGIONAL ADMINISTRATOR E3 REGION V 0FFICE OF INSPECTION & ENFORCEMENT 1,
U S NUCLEAR REGULATORY COMMISSION 1450 MARIA LANE SUITE 210 WALNUT CREEK CA 94596 OPERATING LICENSE DPR-54 DOCKET NO. 50-312 REPLY TO IE INSPECTION REPORT 81-36 In response to the inspection conducted by Messrs. H. Canter and J. O'Brien during the month of December we offer the following information.
Appendix A of your letter notes the following Severity Level IV Violation:
Section VI of Appendix B to 10 CFR 50 states, in part:
" Measures shall be established to control the issuance of documents, such as... drawings, including changes thereto, which prescribe all activities affecting quality.
Quality Assurance Procedure 7, Revision 8, Configuation Control, states, in part; " Changes to drawings are made in accordance with Rancho Seco Configuration Control Procedure ECP-1...."
Section 4.3 of ECP-1 states in part that it is the respon-sibility of the Supervising Engineer to:
" Review DCN and correct as necessary or return to Design Engineer for corrections, additional DCN's, etc."
Contrary to the above, on December 16, 1981, the inspector discovered a series of drawings which did not accurately reflect plant conditions for portions of the Reactor Protec-tion System. On December 24, 1981, the drawings were formu-lated into a Drawing Change package number A-3807 which consisted of 15 drawings. This package was not accurate and was sent back to the cognizant engineer for corrections.
8203030427 920226 PDR ADOCK 05000312 G
PDR AN ELECTRIC SYSTEM SERVING MORE IHAN 600.000 IN THE HEART Of CAllF0RNiA
R. H. Engelken February 17, 1982 The drawings in A-3807 were as follows:
N15.01-28 Revision 2 N.I. & Protection System N15.01-29 Revision 4 N.I. & Protection System N15.01-30 Revision 2 N.I. & Protection System N15.01-31 Revision 3 N.I. & Protection System N15.01-32 Revision 2 N.I. & Protection System N15.01-33 Revision 3 N.I. & Protection System N15.01-34 Revision 3 N.I. & Protection System N15.01-36 Revision 4 N.I. & Protection System N15.01-45 Revision 2 N.I. & Protection System N15.03-9 Revision 0 Schem. Diag. - R.C. Pressure N15.03-14 Revision 2 Schem. Diag. - R.B. Hi Pressure N15.03-24 Revision 0 Schem. Diag. - R.B. Hi Pressure N15.03-29 Revision 0 Schem. Diag. - R.C. Pressure N15.03-34 Revision 2 Schem. Diag. - R.C. Pressure N15.03-43 Revision 0 Schem. Diag. - R.C. Pressure District Reply The District's Generation Engineering and Nuclear Operations Departments have recognized for two years that the original Reactor Protection System (RPS) drawings provided by Babcock and Wilcox (B&W) were not sufficient and could not be modified as they were drawn at that time. Therefore Generation Engineering hired additional drafting personnel to produce a new set of drawings for the RPS. The new drawings were provided by compiling information available on the RPS.
These drawings were com-pleted and issued as DCN's in January 1981.
The new drawings were issued with the knowledge that there were some inaccuracies. The new drawings had less errors, were more readable than the pre-existing B&W drawings, and had information not shown on those B&W drawings.
Therefore, the intent was to issue the drawings as DCN's, and obtain correction data from the Nuclear Operations I&C group to pick up the inaccuracies and then make a re-issue. The Nuclear Operations I&C group provided the correction information and this was recorded on a marked-up copy of the drawing in the drafting group. These marked-up drawings had picked up the change of the Foxboro transmitter to a Westinghouse transmitter mentioned in the Notice of Violation.
When the NRC Resident Inspector noticed the problem with the errors on the newly issued drawings, he indicated that there would be no citation if the District quickly corrected the drawings.
In the attempt to quickly correct the drawings, proper checking procedures were not fol-lowed and the drawings were re-issued with the errors mentioned in the Notice. These errors have since been corrected and the drawings re-issued.
R. H. Engelken February 19, 1982
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The following measures will be taken to prevent similar events from occurring:
a.
The entire set of new RPS drawings will be reviewed, field comments incorporated, properly checked, and re-issued by August 1, 1982.
b.
Any other drawing errors that are identified will be quickly cor-rected using the procedures outlined in ECP-1.
c.
All new construction work done by the District at Rancho Seco will be rigorously inspected to ensure that the equipment installations agree with the drawings. This is covered in the following Engineering and Inspection Instruction (EII) procedures used by the District:
EII Number Title EC-2 Inspection of Raceway System EC-4 Electrical Equipment Installation During Construction and Major Modifications EC-7 Inspection of Underground Duct Bank EC-9 Installation Inspection of Distribution Panels EC-11 Cable Installation Inspection During Construction and Major Modifications EC-13 Installation Inspection of Pulling Cable and Wire EC-14 Electrical Equipment Installation (General)
EC-15 Cable Tenninations and Connections EC-18 Installation Inspection of Grounding Systems During Construction and Major Modifications All of the above procedures are approximately one year old, so the District has had an adequate system of drawing contol/ installation inspection in place for some time. This system provides control of the work and assurance that the installation and drawings agree, d.
Proper checking procedures will be followed prior to issuing any drawing or DCN.
During the construction of the plant a strong inspection program was also enforced.
This program is defined in Appendix 1B of the FSAR.
This program, coupled with the pre-operational test program, ensures that the Rancho Seco drawing system accurately describes the plant.
The fact that the District initially had identified the problem with the RPS and decided to redraw all the drawings indicated the success of this system.
R. H. Engelken February 19, 1982 Therefore the inspection program used during initial construction assures that there are accurate drawings for existing plant equipment, and a strong drawing control system as provided by ECP-1 will ensure any isolated errors are corrected. This, coupled with the inspection program for all new construction, provides the basis for a gcod drawing control system.
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k1 (ohn J. Mattimoe Assistant General Manager and Chief Engineer