ML20206R258

Notice of Violation from Insp on 870131-0227

ML20206R258
Person / Time
Site:	Rancho Seco
Issue date:	04/07/1987
From:	Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20206R212	List: ML20206R207 ML20206R258 ML20206R344
References
50-312-87-06, 50-312-87-6, NUDOCS 8704220133
Download: ML20206R258 (5)

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-APPENDIX A NOTICE ~0F VIOLATION Sacramento Municipal Utility District Docket No. 50-312 P. O. Box 15830 .

License No. DPR-54

.As a result of the inspection conducted between January 31.and i February 27, 1987, and in accordance with NRC Enforcement Policy, 10 CFR Part 2, Appendix C, the following . violations were identified:'

A. (1) '10 CFR 50 Appendix "B'" Criterion XVI. requires that " Measures shall be established to assure that conditions adverse,to. quality, such as failures, malfunctions, deficiencies," deviations, defective material and equipment, and nonconfonnances are promptly identified and corrected.- In the case of signifi. cant conditions adverse to

. quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

The identification of the significant condition adverse to quality, the cause of the condition', and the corrective action taken shall be documented and reported to appropriate levels of management.

Rancho Seco Quality Assurance Procedure QAP-17. Rev. 4, Paragraph 5.1 states,"AnNCR[NonconformingReport]shall.be initiated and processed if a component, structure or system

- cannot be' returned to acceptable operational status by normal maintenance or replacement.

.(a) . Contrary to the above, an NCR was not written for non-isolable pipe leakage in the "A" train of the nuclear service raw water (NSRW)systemasidentifiedinWorkRequestNo. 110755 dated 2/2/86.

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

(b) Contrary to the above, licensee measures did not assure that the cause of the significant condition adverse to quality identified by NCR-S6140 dated 12/09/86 (emergency diesel generator nonconfonning condition) was determined.

Licensee measures ~did not assure that corrective action to preclude repetition of the significant condition adverse to quality identified by NRC-56140 (emergency diesel generator nonconforming condition) was taken.

The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken for NCR-S6140 was not documented and reported to appropriate. levels of management. NCR-56140 was voided prior to determination of significance and performance of corrective action.

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

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'(2): 10 CFR 50,-Appendix B, Criterion III, " Design Control", states, in part..." Design changes, including field. changes, shall be subject c to design control measures connensheate with these applied to the original design.

Rancho Seco Administrative Procedure AP.26. " Abnormal Tag .

Procedure"; Paragraph 5.2, states, in' part, "In general, an Abnormal Tag is required anytime an electrical, mechanical, structural or

-pneumatic system is modified and placed.in service without.an approved DCN (Drawing Change Notice), per NEP 4109, to document the change.

Contrary to the above, an Abnormal Tag was not' written for the temporary modification of the "A" train nuclear service raw water (NSRW) pressure boundary as identified in Work Request No. 110755 dated 2/2/86. The "A" train NSRW was returned to service with a rubber patch clamped onto the exterior of a defective pipe section to control non-isolable leakage. This condition existed for over one year.-

ThisisaSeverityLevelIVviolation(SupplmentI).

B. .(1) 10 CFR 50, Appendix B Criterion V, states, in part, " 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..."

Quality Assurance Program Policy Section V, Rev. O, " Instructions, Procedures and Drawings", states, in part "3.0 Policy Activities affecting the operational safety or quality performance at Rancho Seco shall be prescribed by and implemented in accordance with documented instructions, procedures, and drawings for the operational life of the plant.

AP 605, Rev.'11, General Warehousing, requires, in part-

"3.4.2.6 All shelf life itemstand EQ items that have a shelf life are sorted such that the oldest items are in front or on top and the newest in back or on the bottom.

3.4.3.4.1 A manual or computerized tickler file system will be set up to ensure that specific storage control instruction... are followed.

3.4.3.4.5.7 The person responsible for reviewing the

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tickler will also be responsible for ensuring that the stock which has reached =it's expiration date is removed from the

-shelf on a monthly basis..."

Contrary to the above, on February 24 -1987, sorting of shelf life items such that the oldest items are in front or on top had not been.

implemented in accordance with AP 605.~ A manual or computerized tickler file system had not been implemented to control special storage .

requirements; for example shelf life of rubber components. Expired ' shelf life items were not being reviewed or removed on a monthly basis.

This'is a Severity Level'IV Violation (Supplement I).

(2) 10 CFR 50, App._B Criterion VIII, states, in part: " Measures shall be established for the identification and control of materials, parts, and

' components, including partially fabricated _ assemblies. These measures shall ' assure that identification of the item is maintained by... part number, serial number... on the item Quality Assurance Program Policy Section VIII,~ Rev. O, " Identification and Control of Materials, Parts and Components" requires, in part

, "3.0 Policy Appropriate procedural methods shall be prescribed and implemented to assure that materials, spare parts or components are properly identified and controlled to preclude _

the use of incorrect or nonconforming items..."

and paragraph 4.1 states, in part "4.1 Procedures are required to provide for appropriate identification of safety related materials, spare parts or components, including partially fabricated subassemblies and consumables, in such a manner that these items can be related to' it's ' applicable drawing, specification, purchase document and inspection record at any stage from initial receipt through fabrication / construction, installation, repair, modification or use Contrary to the above,,a system of " green tagging" used in the warehouse

.to_ issue safety related part,s was not described by an approved procedure.

This is a Severity Level V. violation (Supplement I).

C. 10CFR50.72(a)(1) states,inpart"Eachnuclearpowerreactor licensee... shall notify the NRC Operations Center via the Emergency Notification S paragraph (b)ofystem of ... those non-emergency' events specified in this section Contrary to the above, the licensee did not notify the NRC Operations Center as described below of the following events:

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a. Actuation of the "A" diesel generator on June 22,1985,(required under 50.72(b)(2)(ii) and later identified in LER 85-13).

b. Discovery on October 7,1985 of a failure of the essential control room HVAC system to function per design requirements and Technical Specification requirements. (Required under 50.72(b)(2)(iii) and later identified in LER 85-20.)

c. Discovery on January 7,1986 that insufficient voltage would be available to the essential control room.HVAC power supplies i followin a design basis LOCA. (Required within four hours under 50.72(b) 2) and later reported on November 1986 under ]

50.72(b)2)(111)andinLER86-23.)

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

l D. 10 CFR 50.73(a)(1) states, in part "The holder of an operating license ,

for a nuclear power plant (licensee) shall submit a Licensee Event Report.  !

(LER) for any event of the type described in this paragraph l

Contrary to the above, the licensee did not submit a LER as described below for the following events:

I l a. Discovery on January 7,1986, that insufficient voltage would be i

available to the essential control room HVAC power supplies L following a design basis LOCA, as required within 30 days after the discovery of the event under 50.73(a)(1) and later identified in LER 86-23.

b. On September 9, 1985, liquid effluent was released without an on-line radiation monitor or a dual verification of a chemical J analysis of the release sample as required by Technical l Specification 3.15. Therefore, the event was reportable under 50.73(a)(2)(1)(B).

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c. With the reactor in a cold shutdown condition on September 10, 1985, both emergency diesel generators were declared inoperable. This condition alone could have prevented the fulfillment of the safety function to remove residual heat and was therefore reportable under 50.73(a)(2)(v)(B).

d. On October 30, 1985, while the plant was in hot shutdown, the auxiliary feedwater pump, P-319, auto started on the safety feature signal of low feedwater pressure. This event was an automatic actuation of an engineered safety feature system and reportable under50.73(a)(2)(iv).

e. On December 16, 1985, the licensee discovered that Technical Specification 4.4.1.2.5 had been violated, in that the containment personnel hatch had not been tested at the required pressure on December 12, 1986. The identified violation has not been reported pursuantto50.73(a)(2)(1)(B).

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f. On September 23,1985:the (decay heat "dropline"/ suction isolation valve closed spuriously, removing the ability lof the system to. >

remove residual heat. This condition al_one could have prevented the-fulfillment of~the~ safety-function to. remove residual heat and was therefore reportable under 50.73(a)(2)(v)(B).

'This is a Severity Level IV violation (Supplement I). '

Pursuant to the provisions of 10 CFR 2.201,-the Sacramento Municipal Utility '

District'is required to submit to this office within thirty days of the date of this Notice a written statement'or explanation in reply, including:.(1) ,

corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance;. .

and, (3) the date when full compliance will be achieved. Consideration may be given-to'extt.rding your response time for good cause shown s

APR 071987 Date Signed

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