ML20215C439
| ML20215C439 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/26/1986 |
| From: | Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| JEW-86-921, NUDOCS 8612150140 | |
| Download: ML20215C439 (7) | |
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s Reasons for the violation Plant maintenance personnel considered their vendorts procedures adequate to determine pipe wall thickness.
However, subsequent investigation concluded that the radiographic technique described in the procedures is not adequate to accurately determine pipe wall thickness.
The design organization relied upon the early assurances of the maintenance personnel regarding the radiographic technique and subsequently used input which was marked information-only for their design calculations.
Corrective steps which have been taken and results achieved.
NEP 4106, Section 3.4 requires that a design verification be performed for Class 1 calculations.
This is programmatically done at Rancho Seco.
Corrective steps which will be taken to avoid further violations.
To prevent future occurrence, NEP 4106, Calculations, will be revised to emphasize that input data for safety related calculations from other sources, such as calculations or from NDE or other tests, are developed in accordance with approved District procedures.
This NEP revision is expected to be completed by December h
31, 1986.
In order to increase the Districtts 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 Class 1 design calculations that were performed during the past five years.
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s The District will rectify any deficient calculations and provide additional corrective action based on the results of the survey.
Data full compliance will be achieved.
The District will revise 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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9 ATTACHMENT 2 DISTRICT REVISED RESPONSE TO NRC INSPECTION 86-30 NOTICE OF VIOLATION NRC Violation B 10 CFR Part 50, Appendix 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 circumstances and shall be accomplished in accordance 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 ccaform 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."
l Contrary to the above, on February 18, 1986,. written procedures were not established to control the l
radiographic inspection of the decay heat removal pump drain lines under Nonconforming Reports (NCR's) numbers l
5340 and 5343 dated February 18 and 21, 1986.
The radiographic inspections were used as the basis for the engineering evaluation of the structural integrity of the degraded pipe wall.
This is a Severity Level IV violation (Supplement I).
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4 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'ls and Technical Support Group evaluations written on the j
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.
Data full compliance will be achieved.
The District is in full compliance with the cited maintenance commitment as of the date of this response.
The " pipe adequacy" survey will be complete by February 5, 1987.
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SACRAMENTO MUNICIPAL UTtuTY DISTRICT C P. O. Box 15830, Sacramento CA 95852-1830,'(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALQQRNIA
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JEW 36-921 November 26, 1986 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 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 RELATED ENGINEERING WORK The Sacramento Municipal Utility District hereby submits, in, 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 concernina this response, please contact Mr. Ron Colombo at the Rancho Seco Nuclear Generating Station.
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WARD DEPUTY GENERAL MANAGER, NUCLEAR Attachment l
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,j RANCHO SECO NUCLEAR GENERATING STATION ^ 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 NOTICE OF VIOLATION 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:
10 CFR Part 50, Appendix B, 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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