ML20207D272
| ML20207D272 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/22/1986 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| References | |
| NUDOCS 8612300363 | |
| Download: ML20207D272 (1) | |
See also: IR 05000312/1986030
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DEC 221986
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Docket No. 50-312
Rancho Seco Nuclear Generating Station
14440 Twin Cities Road
Herald, California 95638-9799
Attention:
Mr. John E. Ward
Deputy General Manager, Nuclear
Gentlemen:
Thank you for your letter dated November 26, 1986, informing us of the steps
you have taken to correct the items which we brought to your attention in our
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letter dated September 18, 1986.
Your corrective actions will be verified
during a future inspection.
Your cooperation with us is appreciated.
Sincerely,
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Dennis F. Kirsch, Director
Division of Reactor Safety and Projects
bec w/ copy of letter dated 11/26/86:
Resident Inspector
Project Inspector
B. Faulkenberry
J. Martin
docket file
bec w/o copy of letter dated 11/20/86:
M. Smith
J. Zollicoffer
REGION V
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8612300363 861222
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SACRAMENTO MUNICIPAL UTILITY DISTRICT C P. O. Box 15830, Sacramento CA 958521830,'(916) 452 3211' M
AN ELECTRIC SYSTEM SERVING THE HEART OF CALTQRNIAO'
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86-921
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November 26, 1986
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J B MARTIN REGIONAL ADMINISTRATOR
REGION V OFFICE OF INSPECTION AND ENFORCEMENT
U S NUCLEAR REGULATORY COMMISSION
1450 MARIA LANE, SUITE 210
WALNUT CREEK,' CA
94596
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DOCKET NO. 50-312
LICENSE NO. DPR-54
NRC INSPECTION REPORT 86-30, INSUFFICIENT QUALITY CONTROL OVER
THE PRODUCTION AND USE OF RADIOGRAPHS IN SAFETY REIATED
ENGINEERING WORK
The Sacramento Municipal Utility District hereby submits, in
Attachment 1, the response to Appendix A and B of the subject
Notice of Violation (concerning use and retention of radiographic
inspections of decay heat pump casing drain lines) in accordance
with 10 CFR Part 2.201.
This supersedes our response on the same
subject and we regret any confusion that our previous response
may have generated.
If there are any questions concerning this response, please
contact Mr. Ron Colombo at the Rancho Seco Nuclear Generating
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Station.
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HN E.
WARD
DEPUTY GENERAL MANAGER,
NUCLEAR
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Attachment
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RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935
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ATTACHMENT 1
DISTRICT REVISED RESPONSE TO NRC INSPECTION 86-30
NRC Violation A
As a result of the inspection conducted between July 14 and
August 22, 1986, and in accordance with NRC Enforcement Policy,
10 CFR Part 2, Appendix C, these two alleged violations were
identified:
Criterion XVII, " Quality
Assurance Records," states, in part: " Sufficient
records shall be maintained to furnish evidence of
activities affecting quality.
The records shall
include at least the following: (the results of
inspections]"
Contrary to the above, records were not maintained of
the radiographic inspections of degraded pipe wall
conditions of the drain lines for the decay heat
removal pumps.
The inspections were performed to
support the disposition of Nonconforming Reports
(NCR's) numbers 5340 and 5343 dated February 18, and
21, 1986.
This is a Severity Level V violation (Supplement I).
District Response to Violation A
Admission or denial of the alleged violation.
The District concurs that the item cited is a
violation of the requirements 10 CFR Part 50, Appendix
B, Criterion XVII, " Quality Assurance Records," which
requires that sufficient completed records be
maintained to furnish evidence of activities affecting
quality such as tests.
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Reasons for the violation
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Plant maintenance personnel considered their vendor's
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procedures adequate to determine p,ipe wall thickness.
However, subsequent investigation concluded that the
radiographic technique described in the procedures is
not adequate to accurately determine pipe wall
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thickness.
The design organization relied upon the early
assurances of the maintenance personnel regarding the
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radiographic technique and subsequently used input
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which was marked information-only for their design
calculations.
Corrective steps which have been taken and
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results achieved.
NEP 4106, Section 3.4 requires that a design
varification be performed for Class 1 calculations.
This is programmatically done at Rancho Seco.
Corrective steps which will be taken to avoid further
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violations.
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To prevent future occurrence, NEP 4106, Calculations,
will be revised to emphasize that input data for safety
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related calculations from other sources, such as
calculations or from NDE or other tests, are developed
in accordance with approved District procedures.
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NEP revision is expected to be completed by December
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31, 1986.
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In order to increase the District's confidence that
this is an isolated case of using information-only data
in a Class 1 design calculation, the District will
sample a statistically significant number of mechanical
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Class 1 design calculations that were performed during
the past five years.
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The District will rectify any deficient calculations
and provide additional corrective action based on the
results of the survey.
Data full compliance will be achie'ved.
The District will revisa NEP 4106 as indicated by
December 31, 1986.
After discovering the piping
degradation, an effort to permanently replace the
affected piping was completed.
The design calculation
survey will be complete by February 5,
1987.
The result
of the survey will identify what, if any, additional
corrective action is required.
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ATTACHMENT 2
DISTRICT REVISED RESPONSE TO NRC INSPECTION 86-30
NRC Violation B
Criterion V,
" Instructions,
Procedures and Drawings," states, " Activities affecting
quality shall be prescribed by documented instructions,
procedures, or drawings of a type appropriate to the
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circumstances and shall be accomplished in accordance
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with these instructions, procedures or drawings.
Instructions, procedures or drawings shall include
appropriate quantitative or qualitative acceptance
criteria for determining that important activities have
been satisfactorily accomplished."
Policy Section II of the Rancho Seco Quality Assurance
Program endorses ANSI 18.7-1972.
Paragraph 5.1.6.1 of ANSI 18.7 states, in part:
" Maintenance that can affect the performance of safety
related equipment shall be properly preplanned and
performed in accordance with written procedures,
documented instructions or drawings appropriate to the
circumstances ... which conform to applicable codes,
standards, specifications and criteria ... Means for
assuring quality (e.g., examinations, measurements,
tests, heat treatments, radiography, inspection and
worker qualifications in accordance with applicable
codes and standards) shall be established, and measures
to document the performance thereof shall be
incorporated in the procedures."
Contrary to the above, on February 18, 1986, written
procedures were not established to control the
radiographic inspection of the decay heat removal pump
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drain lines under Nonconforming Reports (NCR's) numbers
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5340 and 5343 dated February 18 and 21, 1986.
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radiographic inspections were used as the basis for the
engineering evaluation of the structural integrity of
the degraded pipe wall.
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This is a Severity Level IV violation (Supplement I).
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District Response to Violation B
Admission or denial of the alleged violation.
The District concurs that the item cited is a violation
of the requirements 10 CFR Part 50, Appendix B,
criterion V, " Instructions, Procedures and Drawings,"
which requires that activities affecting quality shall
be prescribed by documented instructions, among others.
Reasons for the violation
Maintenance personnel were not sufficiently aware of
the need for formal, proven techniques for use as
inputs to calculations being performed by the
Engineering Department.
It should be noted that
subsequent to the Maintenance Department's initial
belief that the vendor procedure could determine pipe
wall thickness, formal and well documented techniques
for accurately determining wall thickness of a pipe
full of water using a radiographic examination were
found not to exist at Rancho Seco, or in the industry
as a whole.
Corrective steps which will be taken to avoid further
violations.
To determine piping adequacy in the future, the
District will use only approved and qualified
procedures employing ASME accepted techniques for the
determination of pipe wall thickness.
The District will determine the approximate magnitude
of the number of times radiographs were used as a
rationalization in declaring a pipe acceptable with
respect to its wall thickness.
The District will
sample a statistically significant number of NCR's and
Technical Support Group evaluations written on the
subject of " pipe adequacy" during the past five years
to determine if pipe wall thickness via a radiograph
has been performed programmatically.
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The District will rectify any deficient NCR
dispositions and provide appropriate corrective action
based on the results of the survey.
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Data full compliance will be achieved.
The District is in' full compliance with the cited
maintenance commitment as of the date of chis response.
The " pipe adequacy" survey will be complete by
February 5,
1987.
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