ML20151R025

Responds to NRC Re Violations Noted in Insp Rept 50-312/87-37.Corrective Actions:Personnel Involved Reinstructed in Requirements of Procedures RSAP-0803 & QAP-17

ML20151R025
Person / Time
Site:	Rancho Seco
Issue date:	03/07/1988
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20151Q998	List: ML20151Q994 ML20151R025
References
GCA-88-11, NUDOCS 8804270219
Download: ML20151R025 (6)

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i ON' - RECEJVED I SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, P.o. Box 15830, Sacramento C4 MQ521870, (916) 452 3211 l AN ELECTRIC SYSTEM SERVING THE HEART'OF CALIFORNIA l

1 GCA 88-111 E3 !!.t.R -S A 11: 09 MAR 0 71939 U. S. Nuclear Regulatory Commission ATTN: J. B. Martin, Regional Administrator Region V 1450 Maria Lane, Suite 210 Halnut Creek, CA 94596 l

Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO A NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-312/87-37)

Dear Mr. Martin:

On February 16, 1988, 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 responses to the violation.

The Notice of Violation received by the District cites two violations; Violation Al failure to conform to Regulatory Guide 1.33 and Procedure MAP-0002 and Violation A2 failure to Initiate an NCR per Procedure QAP-17. This event is of singular nature in that the corrective action taken was correct and in accordance with a documented procedure. The work performed is documented in an addendum to the work request. The addendum describes the work performed and designates the controlling document for performance. The District requests that the NRC consider the violations as a single violation, failure to revise a work request per Procedures RSAP-0803 and QAP-17. In view of the above the District requests that the severity level of the violation also be reconsidered as a '_evel V violation.

In addition, this letter contains the District's response to your request for discussion of an apparent weakness in the District's corrective action system.

8804270219 DR 880419 -

ADOCK 0S000312 PDR RANCHO SECO NUCLEAR GENERATING STATION D 1444o Twin Cities Road, Herald, CA 95638-9799;(209) 333 293

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GCA 88-111 J.B. Martin MAR 0 71333 Please contact me if you have any questions. Members of your staff with questions requiring additional information or clarification may contact Mr. Steve Crunk at (916) 452-3211, extension 4913.

Sincerely, abpm-

. Car Andogdini Chief Executive Officer,-

Nuclear Attachment cc w/atch:

G. Kalman, NRC, Rockville (2)

A. D'Angelo, NRC, Rancho Seco F. J. Miraglia, NRR, Rockville INPO I&E

DISTRICT RESPONSE TO NOTICE OF VIOLATION 87-37 INTRODUCTION The Notice of Violation received by the District cites two violations; j Violation Al failure to conform to Regulatory Guide 1.33 and Procedure  ;

MAP-0002 and Violation A2 failure to Initiate an NCR per Procedure l QAP-17. This event is of singular nature in that the corrective action '

taken was correct and in accordance with documented procedure. The work i performed is documented in an addendum to the work request. The addendum describes the work performed and designates the controlling document for performance. In view of the above the District requests that the severity level of the violation be reconsidered as a Level V violation. The District requests that the NRC consider the violations as a single violation, failure to revise a work request per Procedures RSAP-0803 and QAP-17.

NRC STATEMENT OF VIOLATION A1:

Technical Specification 6.8.1, states, in part:

Written procedures shall be established, implemented and maintained covering the activities referenced below:

(a) The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972. . .

Regulatory Guide 1.33, November 1972, Appendix A, Paragraph I.1, states, i in part: j Maintenance which can affect the performance of safety-related )

equipment should be properly preplanned and performed in 1 accordance with written procedures, documented instructions, I or drawings appropriate to the circumstances. . .

1. Maintenance Administrative Procedure, MAP-0002 "Control of l Haintenance Activities" Paragraph 5.6.4 states, in part 1

The assigned craftsman is responsible for completing l all safety related maintenance activities in i accordance with approved procedures or written instructions in the sequence written. . .

Contrary to the above, on November 11, 1987, Work Request (HR) ,

139613A, Step 4 was not performed while troubleshooting the refrigeration unit U-545B of the essential HVAC system for the control room / technical support center. The procedure step prohibited component rework from being accomplished within the scope of the troubleshooting work request. However, the unit was rewired to correct an observed nonconformance identified during the troubleshooting without revising the work request.

This is a Severity Level IV violation (Supplement 1).

DISTRICT RESPONSE TO NOTICE OF VIOLATION 87-37 NRC STATEMENT OF VIOLATION A2:

Rancho Seco Quality Assurance Procedure QAP-17 "Nonconforming Material Control" Paragraph 4.1, states:

System, 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 Attachrent 7.3 for guidelines on when to write NCR.

Attachment 7.3 states, in part: "Operational; If a discrepancy is fcund between as-built and drawing, an NCR shall be initiated.

Contrary to the above, on November 11, 1987, an NCR was not initiated to correct a nonconformance discovered between the as-built wiring of the refrigeration unit U545B of the CR/TSC HVAC system and Drawing Number E-342, Sh. 71, Rev. 4, DCN 11A, Sh. 1 & 2.

This is a Severity Level IV violation (Supplement 1).

DISTRICT RESPONSE:

It is the District's interpretation of procedures MAP-0002, RSAP-0803, and QAP-17 that the above cited violations constitute a singular occurrence and therefore should be considered as a single violation. Hith respect to Procedure MAP-0002 paragraph 5.6.4, the craftsman / foreman did reland the jumper to the correct terminal in accordance with an approved procedure or a written instruction. This action was in accordance with E-342-TlR4 ECN R-2090, DCN llc and was documented as work performed in Work Request (HR) 139613A. The craftsman / foreman failed to revise the HR as required by Attachment 7.3 of QAP-17 that states:

If an item is found damaged or is not working and can be reworked through replacement, reprocessing, or completion of the required operation, and be brought into conformance with drawing and specifications requirements, the HR shall be revised or a new HR initiated to accomplish the task. . .

Attachment 7.3 of QAP-17 also addresses requirements for initiating an NCR that states:

An NCR shall be initiated and processed if a component, structure or system cannot be returned to acceptable operational status by normal maintenance or replacement.

Under the District's QA Program, a nonconforming condition may be documented either on a NCR (if Nuclear Engineering action is required) or on a HR (if the condition can be reworked per existing design drawings or specifications). This program is being replaced with a simplified mechanism for documenting nonconforming conditions. The new program is described below per your request.

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s DISTRICT RESPONSE TO NOTICE OF VIOLATION 87-37

1) District Resoonse:

The District acknowledges and admits that a violation occurred.

Contrary to the direction contained in RSAP-0803 and Section 7.3 of QAP-17 the craftsman / foreman did not revise the work request prior to relanding the jumper on the correct terminal.

2) Reason for the Violation:

Personnel error in that the craftsman / foreman who was troubleshooting the refrigeration unit did not revise the work request (HR) prior to performing the work as required by procedures RSAP-0803 "Hork Request" and QAP-17 "Nonconforming Material."

3) Corrective Actions Taken and Results Achieved:

The District considers this to be an isolated case. The personnel involved have been re-instructed in the requirements of procedure RSAP-0803 and procedure QAP-17.

4) Corrective Actions That Hill be Taken to Avoid Further Violations /

Deviations:

Maintenance supervisors will receive additional training on procedures MAP-0002, RSAP-0803, and QAP-17. These procedures and a description of this event will be included in a required reading assignment to illustrate the need for completing all safety-related maintenance activities in accordance with approved procedures or written instructions in the sequence written.

5) Date When Full Comoliance Hill be Achieved:

Full compliance will be achieved by Harch 18, 1988.

DISTRICT RESP 0NSE TO PROGRAMMATIC HEAXNESS IN CORRECTIVE ACTION PROGRAM:

In response to the December 9, 1987 concerns expressed by the Commission regarding a programmatic weakness in the Corrective Action Program the District immediately began development of the Potential Deviation from Quality (PDQ) Program. The goal of the PDQ program was to develop a zero defect mechanism for documenting nonconforming conditior.s. Review of the existing program identified that the multiplicity of reporting instructions served only to obfuscate the reporting issue. The desired goal is a simple mechanism that would have no confusion with respect to reporting of nonconformances and deviations.

A simplified mechanism for documenting nonconforming conditions is being put in place prior to restart. Nonconforming Reports (NCRs) and Occurrence Description Reports (ODRs) are being replaced by a single deficiency document program, Potential Deviation from Quality (PDQ). The new corrective action program consists of PDQs in conjunction with Corrective Action Reports (CARS) which will be initiated as a result of individual PDQs or PDQ trends.

DISTRICT RESPONSE TO NOTICE OF VIOLATION 87-37 The major features of this new program are:

1. A single form is used to document hardware and non-hardware conditions which are potential deviations from quality

2. All PDQs (hardware and non-hardware) are reviewed for reportability

3. All PDQs (hardware and non-hardware) are logged, tracked and trended by the Quality Organization

4. All PDQs (hardware and non-hardware) require QE concurrence for closure

5. The Director, Nuclear Quality is responsible for program overview and initiating CARS, when necessary, for hardware and non-hardware concerns.

Under the new program, Engineering Action Requests (EARS), Field Problem Reports (FPRs) and Corrective Maintenance Hork Requests (CMHRs) will be reviewed to determine if a PDQ should have been written. To ensure timely response, the Shift Supervisor may request that a PDQ be completed by the individual identifying the problem within a specified time frame; otherwise, the initiator has four hours from the time of problem identification to deliver a completed PDQ to the Control Room.

Corrective maintenance can still be performed under a CMHR for cases of normal wear; however, "Degradation, damage, failure, malfunction or loss of plant equipment performing important functions" would require a PDQ. i Training in this new program will be performed prior to implementation of the program. As a minimum, plant personnel down to the first line supervision will receive training on the following:

• The new procedure

• The new PDQ form

• The criteria for initiating a PDQ

• The responsibilities of the originator and the originator's Supervisor.

In addition, personnel involved in the processing of PDQs will receive detailed training pertaining to their responsibilities.

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