ML20154L567
| ML20154L567 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 04/20/1988 |
| From: | Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20154L525 | List: |
| References | |
| GCA-88-249, NUDOCS 8805310347 | |
| Download: ML20154L567 (4) | |
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- hSMU-SACRAMENTO MUNICIPAL UTluTY DISTRICT O P. O. Bo t L83o. Sacramento CK 95853-183o (916) 452 3211 AN ELECTRIC SYSTEM SERVINti THE HEART OF CALIFORNIA GCA 88-249
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APR 2 01988 F.:) C
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U. S. Nuclear Regulatory Commission Attn:
J. B. Martin, Regional Administrator Region V 1450 Maria Lane, Suite 210 e
Halnut Creek, CA 94596 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO NOTICE OF VIOLATION 87-44
Dear Hr. Martin:
On March 25, 1988, the Sacramento Municipal Utility District received a Notice of Violation concerning improper closure of three NCRs at the Rancho Seco Nuclear Generating Station.
In accordance with 10 CFR 2.201, the District provides the enclosed response to this violation.
4 This letter acknowledges that two of the NCRs were improperly closed and describes the District's intended actions.
This letter denies that the third NCR was improperly closed, and provides justification for the denial.
Please contact me if you have any questions.
Members of your staff with questions requiring ?.dditional information or clarification may contact Mr.
Steve Rutter at (916) 452-3211, extension 4674.
Sincerely,
?>u n Carl Andognini Chief Executive Officer, Nuclear Attachment cc w/atch:
G. Kalman, NRC, Rockville A. D'Angelo, NRC, Rancho Seco F. J. Hiraglia, NRR, Rockville INPO
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8805310347 880525 PDR ADOCK 05000312 Q
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RANCHO SECo NUCLEAR GENERATING STATION D 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935
DISTRICT RESPONSE TO NOTICE OF VIOLATION 87-44 BC, STATEMENT OF VIOLATION 10 CFR 50 Appendix B, Criterion V, states, in part:
"Activities affecting quality shall be prescribed by documented instructions, procedures...and shall be accomplished in accordance with these instructions, procedures..."
Quality Assurance Procedure QAP-17, Revision 7, dated November 25, 1987, states, in part:
"5.2.9 Closure of NCRs 5.2.9.1 The Quality Engineer shall sign and date Block VIII to show evidence of completed rework, repair, released calculations, ECN or DCN (Transmittal No.) released for work, or Retest of System / Unit Complete.
The Quality Engineer's signature in Block VIII means that all required actions in Block II have been completed.
This verification may require Hork Request review, procedure review, drawing review, etc. Also, if applicable, the 10 CFR 50.59 Determination Form must be completed prior to NCR closure.
NOTE:
If an ECN/DCN has been issued in response to a NCR disposition, the ICN/DCN must be closed by site document control prior to NCR closure.
5.2.9.2 The QE shall perform a final review of the NCR to ensure the NCR was processed per this Procedure."
Contrary to the above:
1.
On July 2, 1987, NCR S6053 was signed and closed by a Quality Engineer without corrective actions in Block II of the NCR for wire 1H181808 being performed.
2.
On December 8, 1987, NCR S7295 was signed and closed by a Quality Engineer when the corrective actions proposed were incorporated into ECN R1590 without prior closure of the ECN by Site Document Control.
3.
On December 11, 1987, NCR S7272 was signed and closed by a Quality Engineer when the disposition in Block II of the NCR which required a hydrotest had not been performed.
This is a Severity Level IV violation (Supplement 1).
DISTRICT RESPONSE TO NOTICE OF VIOLATION 87-44 1.
Admission or denial of alleged violation:
The District acknowledges and admits that items 1 and 2 occurred as stated.
The District denies the basis of the violation for item 3.
2.
Reason for the violation:
a.
Premature closure of NCR S6053 was caused by personnel error.
The Quality Engineer signed the NCR as closed prior to completion of the revision to Drawing E-344, Sheet 10.
b.
Premature closure of NCR S7295 was caused by personnel error. The Quality Engineer, aware that all required actions necessary to satisfy the NCR disposition were complete, did not wait for ECN R-1590 to be closed prior to signing the NCR as complete.
c.
Justification for Item #3 Part of the disposition action for NCR S7272 was to perform a hydrostatic test on diesel fuel oil lines 10803-2-1/2"-HE7 and 10807-2"-HE7.
The actual test performed was a pneumatic test using nitrogen. A pneumatic test was used as a substitute for the hydrostatic test because it is acceptable per the ASHE Code and was preferable in this case.
The testing was done in accordance with established procedures and Work Request 139513.
While performing this work request per disposition of NCR S7272, it was acknowledged by Nuclear Engineering, Hodifications, and Quality Engineering that performance of a hydrostatic test was not practical for functioning diesel fuel oil lines. The pneumatic test was properly documented and included as part of the documentation packages for the work request and NCR.
Based on this condition, it was agreed by Nuclear Engineeering, Hodifications, the authorized Nuclear Inspector, and Quality Engineering that a pneumatic test, as an acceptable substitute, would be performed to satisfy the hydrotest requirement stated in Block II of NCR S7272 in accordance with ASHE Section 6113.2, Pneumatic Testing.
The pneumatic test was completed and closed prior to the closure of NCR S7272.
3.
Corrective actions and results achieved:
l a.
On December 16,1987, NCR S7535 was initiated to revise Drawing E-344, Sheet 10.
The next day, Drawing Change Notice (DCN) No. 24 was issued. On January 18, 1988, NCR S7535 was closed indicating completion of the drawing revision.
b.
On February 14, 1988. ECN R-1590 was closed indicating completion of the required actions for NCR S7295.
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DISTRICT RESPONSE TO NOTICE OF VIOLATION 87-44 (Continued) 4.
Corrective actions taken to avoid further violation:
a.
From December 17, 1987, to January 18, 1988, the Quality Assurance Department conducted 0A Surveillance 88-S-047.
This surveillance was to determine if NCRs were closed prematurely with respect to related ECNs. The surveillance examined a sample of 80 out of 663 closed NCRs. The results of this surveillance revealed that 79 NCRs were closed properly, one NCR was deficient. A surveillance finding was issued with respect to the deficient NCR. QA determined the problem to be minor and internal to the Quality Department.
This error was corrected using established procedures.
b.
On December 11, 1987, Quality Assurance Implementing Procedure QAIP-1502, "QE Review of NCRs" was issued.
This procedure provides specific guidance to the Quality Engineers on NCR closure.
c.
As a result of NRC observations, the Quality Engineering (QE)
Group suspended closure of all NCRs.
The suspension took effect on January 18, 1988, and remained in effect until sufficient QE and NCR desk personnel were trained on proper NCR closure and procedure QAIP-1502.
Training took place on January 21 and 22.
The NCR closure process was reinstituted on January 22, 1988.
Quality personnel not receiving the training were removed from the authorized NCR signature list until such time as required training was completed.
d.
During the period of February 1 through 5, 1988, the Quality Assurance Department conducted QA Surveillance 88-S-083.
This surveillance was made of Class I NCRs closed after October 1, 1987.
The surveillance examined a sample of 50 out of 452 closed NCRs.
Two surveillance findings were issued as a result.
These findings were considered to be minor and internal to the Quality Department. Appropriate corrective actions were taken for these findings.
e.
On February 9, 1988, a Procedure Change Notice (PCN) was made to Ouality Assurance Procedure QAP-17. "Nonconforming Material Control." This PCN allows the Quality Engineer to close an NCR if ail required actions necessary to satisfy the NCR disposition are coeplete, even if the related ECN is still open.
5.
Date when full compliance will be achieved:
l Full compliance was achieved on February 14, 1988, with the closure of
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ECN R-1590.
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