ML20133E264

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violations Noted:Design Basis for Quality Class 1,Seismic Class 1 Portion of Reactor Coolant Vent Sys Not Correctly Translated Into Design Specs

ML20133E264
Person / Time
Site:	Rancho Seco
Issue date:	09/26/1985
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	SACRAMENTO MUNICIPAL UTILITY DISTRICT
Shared Package
ML20133E255	List: IR 05000623/2008009 ML20133E264
References
EA-85-103, IEB-79-14, NUDOCS 8510090328
Download: ML20133E264 (4)

Text

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NOTICE OF VIOLATION o AND PROPOSED IMPOSITIDF 0F CIVIL PENALTY Sacramento Municipal Utility District Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 EA 85-103

'Ouring an NRC inspection conducted during the period of June 23 - August 9, 1985, violations of NRC requirements relative to engineering designs, modifications and quality assurance activities were identified by the licensee as a result of evaluations and actions taken in response to a crack in the high point vent line connected to the reactor coolant system. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:

A. 10 CFR 50, Appendix B, Criterion III states " Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in $50.2 and as specified in the license application, for those structures, systems, and components to which the appendix applies are correctly translated into specifications, drawings, procedures and instructions."

10 CFR 50, Appendix B, Criterion V requires that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Contrary to the above, in 1974, the design basis for the Quality Class I, Seismic Class I portion of the nitrogen supply and reactor coolant vent systems which connect to a one inch reactor coolant system vent located on the high point of the "B" hot leg was not correctly translated into design specifications and drawings in that the drawings and design specifications provided inadequate support for the nitrogen supply and vent header system. On October 7, 1981, after reanalysis of the design basis of the system, Bechtel Power Corporation advised the licensee that a spool piece should be put in during plant operations and that additional supports should be added to the "B" vent and purge line

! system. When the licensee went to make modifications to the system in 1983, although the drawings required installation of the spool piece, the Engineering Change Notice for the modifications did not require its installation and the piece was not installed. These deficiencies resulted i in a 17 gallon per minute non-isolable primary coolant leak on June 23, 1985.

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Notice of Violation .

B. 10 CFR 50, Appendix B, Criterion V requires that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

1. Contrary to the above, the design drawings referenced in Engineering Change Notice ECN-A-2934 issued in 1983 for the construction of the reactor coolant systems 3/4 inch high point vent lines on the "A" and "B" loops specified that seismic supports shall be in place between two specific valves used for system isolation. However, these supports were not installed in accordance with ECN-A-2934 as required, as was discovered in a June 1985 post I&E Bulletin 79-14 walkdown of the system, which resulted in the code allowable limits for a seismic design basis event being exceeded.

2. Contrary to the above, as of July 1985, about 223 other safety-related supports (identified in the licensee's August 6, 1985 letter) were not installed in accordance with instructions, procedures or drawings.

Collectively, these violations have been categorized as a Severity Level III problem (Supplement I).

(Cumulative Civil Penalty - $50,000 assessed equally among the violations.)

Pursuant to the provisions of 10 CFR 2.201, Sacramento Municipal Utility District is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region V, within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may issue an order to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, Sacramento Municipal Utility District may pay the civil penalty by letter addressed to the Director, Office of Inspection and Enforcement, with a check, draft, or money order payable to the Treasurer of the United States in the amount of Fifty Thousand Dollars ($50,000) or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Inspection and Enforcement.

Should Sacramento Municipal utility District fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an l

s Notice of Violation .

order imposing the civil penalty in the amount proposed above. Should Sacramento Municipal Utility District elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such' answer may: (1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed. In addition to protesting the

' civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. Sacramento Municipal Utility District's attention is directed to the other provisions of 10 CFR 2.205, regarding the proceoure for imposing a civil penalty.

Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to section 234c of the Act, 42 U. 2282.

fuW J. B. Martin Regional Administrator Dated at Walnut Creek, California this ggp day of September 1985 i

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