ML20149D730

Forwards Rev to 870518 Response to Open Item 87-03-01 Noted in Insp Rept 50-312/87-03 Re Inservice Insp Program.Rev Replaces Ref to Procedure QAP-21 W/Ref to QAIP-1804 QA Surveillance Program

ML20149D730
Person / Time
Site:	Rancho Seco
Issue date:	12/29/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
ECA-87-800, NUDOCS 8801130106
Download: ML20149D730 (3)

Text

. s p . . .

esuun SACRAMENTO MUNICIPAL UTILITY DISTRICT C P. O. Box 15830, Sacramento CA 958 h16) 452 3211 AN ELECTRIC SYSTEM SERVING THEg F CALIFORNIA GCA 87-800 G81 DEC 30 p n ;5, DEC 2 91987 J. B. Martin, Regional Administrator Region V Office of Nucitar Reactor Regulation U. S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Docket No. 50-312 Rancho Seco Nuclear Generating Stat'.on License No. DPR-54 REVISED ATTACHMENT II TO RESPONSE TO NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-312/87-03)

Dear Mr. Martin:

By our letter of May 18, 1987, we responded to the Notice of Violation in NRC Inspection Report Number 50-312/87-03. Included as Attachment II of the letter was a response to NRC Open Item 87-03-01. The Open Item concerned the District's Inservice Inspection Program. In the response we described our actions regarding procedure QAP-21 "Inservice Inspection and Inservice Testing Program." The attached submittal is a revision to our response to NRC Open Item 87-03-01. This revision replaces the reference to procedure QAP-21 with a reference to QAIP-1804 "Quality Assurance Surveillance Program." QAIP-1804 i is the correct reference. The response has also been revised for clarity.

Please contact me if you have any questions. Should members of your staff have questions or require additional information or clarification, please contact Mr. Paul Lavely at (916) 452-3211, extension 4674.

Sincerely, ,

Mb L j

. Carl Andognidi i Chief Executive Officer, Nuclear Attachmant l cc w/atch: l G. Kalman, NRC, Bethesda (2)

A. D'Angelo NRC, Rancho Seco i F. J. Miraglia, NRR, Bethesda l 8801130106 Y 1229 ADOCK 0500 gDR 2 Jf./>/

RANCHO SECo NUCLEAR GENEnATING STATION C 14440 Twin Cities Road, Herald, CA 95638 9799,(209) 333 2935 f <

V. .

ATTACHMENT II DISTRICT RESPONSE TO NRC INSPECTION 87-03 PAGE 1 0F 2 INSPECTORS COMMENTS CONCERNING THE ISI PROGRAM NRC Comment Ooen Item (87-03-01)

Rancho Seco's Quality Assurance Surveillance Program for the ISI contractor / program, as it is implemented, has not been effective in verifying the contractor's technical performance.

District Resoonse The original plant was constructed in compliance with quality requirements conforming to the applicable codes. This included provisions for Inservice Inspection (ISI) of piping components in accordance with 10 CFR Part 50, Appendix B Criterion IX, "Control of Special Processes." The ISI program was established to verify the conformance of piping components with applicable codes, documented instructions, procedures, and drawings.

The vendor contracted to perform the ISI Inspections is 10 CFR 50, Appendix B qualified. This ensures the quality of the inspections being performed.

The District maintains progrannatic control over the ISI program and ensures the technical adequacy of the inspections by 1) providing for program oversight and procedural reviews, 2) observing contract personnel (surveillance), and 3) verifying that equipment calibration and personnel qualifications are in conformance with 10 CFR 50, Appendix B Criterion X, "Inspections."

District surveillants assigned to observe ISI activities possess the technical knowledge and experience required to review and approve the procedures, personnel qualifications, and equipment associated with the special processes, as addressed in QAP-9. The assigned surveillants are qualified in accordance with QAIP-1804 and are capable of assessing observed performance, examination data, and evaluations provided by the subcontractor, including engineering evaluations and/or analysis of data where applicable. . .

The December 1987 issuance of QAIP-1804 amplified the QA Surveillance Program to ensure implementation of appropriate measures for adequate documentation and review of QA observations.

t

t ,

PAGE 2 0F 2 HRC_ Comment Ooen Item (87-03-02)

Review of ultrasonic inspection results for the pressurizer support lugs (report numbers85-006, 86-007,85-010 and 85-0014) revealed that additional indications have been detected since the 1983 outage. The inspection results show that some of the new indications are close to previously reported indications suggesting possible dimensional changes.

Fracture mechanics analyses have been performed by the site ISI contractor and the licensee has filed the reports. However, the reports do not address the following concerns:

1. Are these :ndications growing as reported and if they are, what is the rate or growth?

2. If these new indications are fabrication welding indications not detected before, do they require further evaluation to determine why these indications were not detected before?

NRC Comment Ooen Item (87-03-03)

ISI figure C2.1.136 for weld 26121-33-BH revealed that a 0*, 45' axial and 45' circumferential examination was performed. Section 2.1 of this report discussed limitations for the 0*, 45' and 60* ultrasonic inspections (note: no 60* report was available for this weld). It is not possible to determine from the report what volume of the weld was or was not examined and, therefore, it could not be determined if applicable code requirements had been satisfied. The foregoing is an example of sir 411ar deficiencies identified in other weld package reviews. Thus, this is a generic problem with the ISI ultrasonic data at Rancho Seco.

District Resoonse to Items (87-03-02) and (87-03-03)

The District contracted the Babcock & Hilcox Company (the ISI contractor) to review and resolve both of these open items. The District reported these findings to the NRC by letter on October 20,198,'.

t

, _ , , - _