ML20052G753
| ML20052G753 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 04/27/1982 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20052G748 | List: |
| References | |
| NUDOCS 8205180639 | |
| Download: ML20052G753 (5) | |
Text
.
PICENED
$ SMUD SACHAMENTO MUNICIPAL UTitlIY DISTRICT C 6201 S Street. Box 15830. Sacramento. Cat,i,forpf a, {813; (916) 452 3211 p u m --
h t-a April 27, 1932 R !! 1.NGEl.EEN, REGIONAI. AD!!INIST RATOR RICION V 0FFICE OF INSPECTION & ENFORCF'!ENT 11 5; NUCLEAR REGULATORY COM!flSSION 1450 MARIA I.ANE SUITF. 210 WALNUE CREEK CA 94596 OPERATING LICENSE DPR-54 DOCKET NO. 50-312 REPl.Y TO IE INSPFCTION REPORT 82-02 in respense to the In?.pection conducted by ifr.
G.
Hernandez during the period of,laouary 12-15, 1982 we offer the following infornation.
Appendix A of your letter notes the following Severity Level V (Supplement II)
Violations:
A.
10 CFR 50, Appendh B, Critvion V, st ates, in part, that " Activities affecting qua1ity shalI be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances...
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative ar-eptance criteria for determining that irportant activities have been satisfactorily accomplished..."
1.
Qualit. Assurance Procedure Number 9, Revision 4, of the SMUD qualit y Assurance !!aqual states in paragraph 5 of the general requirements that, " Procedures for special processes are prepared by the contractors performing the work and are submitted to Ouality Assurince for approval.
Al1 specla1 process procedures shall be appioved Ouality Assurance. These shall include, but not he 1imited to:
a.
Wel ting procedure specificat ions b.
Weld material control procedures c.
Detailed welding procedures S'U Carporation Welding Filler Material Control procedure Specification (WFMCPS) states in part, in paragraph 4.3.2(b) that, " Low hydrogen type covered electrodes (EXX16 and EXX18) and stainless steel type covered electredes shall be stored in vented electrode holding ovens at 250 F and 350 F;"
in paragraph 4.3.4 that, "when low hydrogen covered electrodes are to be used, they shall be removed f ron scaled containers and stored in local storace ovens at 250"F to 350"F for at least one hour prior to use;" and in paragraph 5.2 that, "Whenever practical, a quantity 8206 WofoM AN ELECTRIC SYSiEu ERVING MORE THAN iOO,000 IN THE EART OF CALIFOENlA 4
e
e
, of covered electrodes sufficient for four hours of work shall be issued to the welders at the beginning of the shift.
Unused electrodes shall be returned to the issuing area at the end of the shift, af ter completion of the weld, or destroyed."
2.
Quality Assurance procedure Number 27, Revision 0, of the SMUD Quality Assurance Manual states in paragraph 6 that, "A system for periodic calibration shall be established to assure accuracy of instruments, gages and measuring devices used in construction and operation of Rancho Seco No. 1.
Any deviations require prompt corrective action."
Contract Specification C22.2 states in paragraph SC-12A(7), " Calibration of Measurement and Test Equipment", that, "A system of control will assure that all instruments, measuring equipment, and test equipment are properly calibrated and perform accurately."
Contrary to the requirements identified above, on January 13. 1982, the inspector found that:
(1) the electrical supply for the welding oven had been de energized; (2) an uncalibrated thermometer was being used to mainte.n the required oven temperature; (3) three full containers of E7018 weld filler material were found open; and (4) the weld rod disbursement log did not indicate the time of issuance or return of weld rod making it impossible to determine whether the weld rod had been out longer than four hours.
This is a Severity Level V violation (Supplement II).
B.
10 CFR 50, Appendix B, Criterion XVI, " Corrective Action", states in part that, " Measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations...
are promptly identified and corrected.
In the case of significant con-ditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude re-petition."
Quality Assurance Procedure Number 27, Revision 0 of the SMUD Quality Assurance Manual states in paragraph 2 of the general requirements that,
" Measures shall be established to assure that conditions adverse to quality are promptly identified and corrected."
l Contrary to the above, though SMUD Quality Assurance audits performed on October 27, 1981 and November 17, 1981 identified significant deficiencies in SMF's welding filler material control program, the licensee failed to take appropriate measures to identify the cause of discrepancies and take l
appropriate corrective action to preclude repetition.
The inspector identitled similiar deficiencies in the SMF welding filler material program on January 13, 1982 (See Item A).
I This is a Severity Level V Violation (Supplement II).
C.
10 CFR 50, Appendix B, Criterion XIII, states in part that, " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment in accordance with nork and inspection instructions to prevent damage or deterioration.
'The licensee committed to WASH document 1284, Guidance on QA Requirements During the Operations Phase of Nuclear Power Plants, in letter to the NRC/ DOR of July 22, 1974 and September 23, 1976.
WASH document 1284 con-tains Regulatory Guide 1.38, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-cooled Nuclear Power Plants, which states in part:
"The requirements and guidelines...
that are included in ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants...are generally acceptable and provide an adequate basis for complying with the pertinent quality assurance requirements of Appendix B to 10 CFR 50,..."
ANSI N45.2.2, paragraph 6.1.1 states in part that, " Levels and methods of storage are defined to minimize the possibility of damage or lowering of quality due to corrosion, contamination, deterioration or physical damage from the time an item is stored r.pon receipt until the time the item is removed from storage and placed in its final location."
Contrary to the above, on January 12, 1982 containers of high strength bolting material to be used in the erection of the structural steel for the Nucicar Service Electrical Building were found open, sitting on the ground, and the bolting material corroded to such an extent that most bolts and nuts could not be freely moved by hand.
This is a Severity Level V Violation (Supplement II).
l e
l e
District Reply A.
(1) The de-energization of the oven was determined to have been caused by the inadvertent removal of the power cord from its supply re-cepticle. As of January 18, 1982 the power cord has been labe]ed to identify that it is to remain in continuous service. The power cord is checkoda minimum of twice daily and logged. Since the above actions were taken, the oven has not been de-energized.
Upon completion of this construction, the aven will be removed from the site by the contractor. We are in full compliance with this citation at the present time.
A. (2) The thermometer was checked and found to be within +50 F in the specification required temperature range of 250 r to 300 F.
The temperature of the oven is within the requirements of C22.2 Section SC 12 A (7) when energized. As of January 18, 1982 a calibrated thermometer is being used to monitor the oven temperature. The Quality Control Department requires semi-annual calibration of this instrument and maintains records of calibration. We are in full compliance with this citation at the present time.
A.
(3) No veld rod was used from the open containers. The weld rod was scraped and removed from the site on January 18, 1982.
Detailed discussions were held with the contractor's supervisory personnel on January 18, 1982 to assure their complete understanding i
and compliance with the Welding Filler Material Control Procedure Specification (WFMCPS). The construction superintendent has taken the responsibility to insure that the appropriate personnel have been informed of and fc110w the prescribed procedures of the WFMCPS.
We are in complete compliance with the procedure at the present time.
A.
(4) Weld rod which was issued in the morning was always returned at the lunch break, and weld rod issued in the afternoon was always returned at the end of the shift. This precluded excer ding the required 4-hour time Ifmit. As of January 18, 1982 the weld rod disbursement log has been revised to include the time of issuance and return. We are presently in full compliance with this revised log.
B.
The District agrees that appropriate corrective action was not taken promptly. The contractor corrected specified deficiencies, but action taken to prevent similar deficiencies was lacking. Quality Assurance identified the deficiencies during routine surveillance activities and not via a formal audit. To eliminate similar circumstances from being improperly handled, a monthly review will be made of all surveillance reports to ensure proper corrective action has been taken. When warranted, a formal audit will be performed to correct any program-matic problems uncovered.
C.
Each bolt installed had been checked by Quality Control Inspectors to assure that no deficient bolts were used. The non-conforming bolts were scrap, but had not been placed in an identified scrap area. The 1
k
e
. bolts were removed from the site on January 18, 1982. The scrap storage area has been defined and signed to preclude inadvertent use of materials there-in, As of January 18, 1982 the storage of all high strength bolting material for use has been inside an air conditioned weather tight structure which meets the require-ments of ANSI N45.2.2.
Detailed discussions were held on January 18, 1982 with the con-tractor's supervisory personnel to assure their complete understand-ing of and compliance with the storage requirements of ANSI N45.2.2.
The construction superintendent has taken the responsibility to insure that the appropriate personnel have been informed of and adhere to the storage requirements.
6 L
fjdohn'dMattimoe i
Assistant Cencral Manager and Chief Engineer i
l l
l l
.