ML20215G050

Forwards Response to NRC Re Violations Noted in Insp Rept 50-312/87-14.Corrective Actions:Plant Personnel Trained in QAP-17 & Nonconforming Reactor Coolant Pump Capscrews Replaced

ML20215G050
Person / Time
Site:	Rancho Seco
Issue date:	05/27/1987
From:	Andognini G COMMONWEALTH EDISON CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20215G040	List: IR 05000312/1987014 ML20215G050
References
GCA-87-063, GCA-87-63, NUDOCS 8706230106
Download: ML20215G050 (5)

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esuu. SACRAMENTO MUNICIPAL UTILITY DISTRICT C P. O. Box 15830, Sacramento CA 95852 1830,(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA GCA 87-063 MAY 2 719g7 g J. B. Martin, Regional Administrator 3; D _

Region V Office of Inspection and Enforcement fg y ,j U. S. Nuclear Regulatory Commission in cv O td 1450 Maria Lane, Suite 210 5 s "M Halnut Creek, CA 94596 R ff4 $

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DOCKET NO. 50-312

RANCHO SEC0 NUCLEAR GENERATING STATION LICENSE NO. DPR-54 RESPONSE TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION (NRC INSPECTION REPORTS NO. 50-312/87-14)

Dear Mr. Martin:

By letter dated April 29, 1987, the Commission transmitted to the Sacramento Municipal Utility District a Notice of Violation and a Notice of Deviation concerning activities at the Rancho Seco Nuclear Generating Station. In accordance with 10 CFR 2.201, the District provides the enclosed response to the Notice of Violation. The District's response to the Notice of Deviation is also enclosed.

This letter acknowledges the violation and deviation cited, and describes the District's intended corrective actions.

If there are any questions concerning this response, please contact Mr. Ron H. Colombo at (916) 452-3211, extension 4236.

Sincerely,

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. Car And ini Chief Executive Officer, Nuclear Attachments cc w/atch: l G. Kalman, NRC, Bethesda A. D'Angelo, NRC, Rancho Seco J. B. Martin (2)

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8706230106 870608 i PDR ADDCK 05000312 I G PDR .

RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333-2935

ATTACHMENT 1 DISTRICT RESPONSE TO INSPECTION REPORT 87-14 NOTICE OF VIOLATION NRC Violation 10 CFR Appendix "B" Criterion XV, " Nonconforming Materials, Parts, or Components" states:

" Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations.

Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."

Quality Assurance Procedure OAP-17 " Nonconforming Material Control",

Revision 1, reads in part, " Systems, equipment and appurtenances, components, parts, or material which do not meet the specified j requirements of purchase orders, design drawings, operational / test documents, or construction documents shall be considered nonconforming." This procedure defines " Repair" as: "A disposition which permits the reprocessing of material or change to the system to bring it into an acceptable condition, although still departing from established requirements. This disposition requires Engineering l Review Board approval." This procedure specifies that the Engineering j Review Board must approve all " Accept" or " Repair" dispositions of  !

nonconforming material or systems. "The Board is composed of the j managers of Quality Assurance, Nuclear Engineering, and Nuclear i Operations or their designated representatives...."

Contrary to the above requirements, at the time of the Inservice Inspection of Reactor Coolant Pump (RCP) P-210B on April 15, 1985, capscrews for the bearing positioner on the RCP were found broken. This nonconforming condition was not reported on an NCR and dispositioned accordingly. As a result the required management review and approval were not completed.

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

District Response to Violation

1) Admission or denial of alleged violation:

The District admits this violation occurred as stated.

2) Reason for violation:

The violation was the result of inadequate training of the personnel who were responsible for implementing Quality Assurance Procedure QAP-17, " Nonconforming Material Control."

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. 3) Corrective actions taken and results achieved:

Plant personnel that have been idsntified as requiring additional training in the Nonconformance Report (NCR) process have been trained in QAP-17 as detailed in the District's May 7,1987, response to a similar violation (NRC Inspection Report No. 87-06).

Occurrence Description Report (ODR)85-285 describing the broken capscrews was initiated on September 4, 1985. Subsequent evaluation determined that this condition was not reportable.

The nonconforming Reactor Coolant Pump capscrews were replaced after management review determined that replacement was the prudent corrective action. This corrective action was reviewed by the PRC, MSRC, and upper plant management, including the Quality Department, through the ODR response review process.

4) Corrective actions which will be taken:

No additional corrective actions are planned.

5) Date when full compliance will be achieved:

The District considers that full compliance has been achieved.

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ATTACHMENT 2'

.m DISTRICT RESPONSE TO NRC INSPECTION REPORT 87-14 NOTICE OF DEVIATION NRC Deviation Rancho Seco FSAR, Section 9.7.3.6 - Codes, Standards, Tests, paragraph 4, states: "The essential air filtration unit is designed and constructed in accordance with the requirements of Regulatory Guide 1.52."

Regulatory Guide 1.52, March 1978, Section 5, paragraph 4. "The use of silicone sealants or any other temporary patching materials on filteis, housing, mounting frames or ducts should not be allowed."

< Contrary to the above, at the time of the inspection, the Essential Air Filtration System had silicone sealants applied to the housing, mounting frames and ducts.

Q13trict Response to Deviation

1) Admission or denial of alleged deviation:

The District admits this deviation occurred as stated.

2) Reason for deviation:

On November 5, 1984, and November 6, 1984, the District initiated Nonconformance Report (NCR) Nos. S-4163 and S-4164, respectively, to document excessive leakage from the Control Room (CR)/ Technical Support Center (TSC) Essential HVAC System. Corrective actions included sealing leaking joints with Dow Corning 732 Silicone Sealant in accordance with vendor drawing M13.15-59, Item 36.

The District did not seek the Commission's approval for this deviation from the recommendations of Regulatory Guide 1.52, Rev. 2, March 1978, because the use of this sealant was in accordance with vendor drawings.

Further, the use of Dow Corning 732 Silicone Sealant in the CR/TSC Essential HVAC System was found acceptable in a subsequent engineering evaluation.

3) Corrective actions taken and results achieved:

The District identified potential deficiencies in the use of silicone sealant in the CR/TSC Essential HVAC System on November 19, 1984, and requested Bechtel Power Corporation to evaluate the application of this sealant. By letter dated December 19, 1984, Bechtel concluded that the use of Dow Corning 732 Silicone Sealant in the CR/TSC Essential HVAC System was acceptable.

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.4) Corrective' actions.which will be taken:

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' The District will-provide the Commission with Bechtel Power u Corporation's evaluation of the use of Dow Corning 732 Silicone Sealant in the-CR/TSC Essential HVAC System by July.1, 1987. This evaluation will document'the District's deviation from the recommendations of Regulatory Guide 1.52, Revision 2, March 1978.

5) Date when full compliance will be achieved:

The' District' considers that full compliance will be achieved on  !

July 1, 1987.

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