ML20215N062
| ML20215N062 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 10/18/1986 |
| From: | Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| JEW-86-653, NUDOCS 8611040231 | |
| Download: ML20215N062 (4) | |
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SACRAMENTO MUNICIPAL UTILITY DISTRICT C 62o1 S Street. P.O. Box 15630, Sacramento CA 95852-1830, (916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF, CALIFORNIA Y;},
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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 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 Attachment 1, the response to Appendix A of the subject Notice of Violation (concerning maintenance of radiographic inspections of decay heat pump casing drain lines) in accordance with 10 CFR Part 2.201.
If there are any questions concerning this response, please contact Mr. Ron Colombo at the Rancho Seco Nuclear Generating Station.
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. WARD DEPUTY GENERAL MAN AGER, NUCLEAR Attachment 8611040231 861018 PDR ADOCK 05000312 O
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ATTACHMENT 1 DISTRICT RESPONSE TO NRC INSPECTION 86-30 NOTICE OF VIOLATION APPENDIX A VIOLATION 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:
A.
I 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).
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 cr 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."
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. Contrary to the above, on February 18, 1986, written procedures were not established to control the radiographic inspection of the decay heat removal pump -
drain lines under Nonconforming Reports (NCR's) numbers 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).
RESPONSE
The District concurs that the two items cited are a violation of the requirements 10 -
CPR 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. As mitigating evidence of the District's actions, a historical description of the problem is provided herein.
Romannt for the vinlatinn The decay heat removal system leak described in Licensee Event Reports 86-02 and 86-14 appeared to result from erosion of the drain line pipe wall from an unintended recirculation flow between the discharge and suction drain lines of the decay heat pumps.
According to the Inspection Report: "the [NRC) reviewed the use of a leak sealant (from a Company called " Leak Repair"] repair of the decay heat pump casing drain line in February 1986, per NCR 5340. The [NRC] found that the engineering review of the structural integrity of the existing drain line included evaluation of the eroded '
71pe wall and the additional weight of the clamp added to the line as part of the sealant] repair. The NRC determined that records of the radiographs which [were]
evaluated by engineering [were] retained, while the radiographs themselves were thrown away. The radiographs of the drain lines of both decay heat pumps [were]
taken by maintenance for information only in troubleshooting the cause of 12e original leak. However, the evaluation of the structural integrity performed by engineering used the same radiographs to quantitatively estimate the remaining _ wall thickness. "
The deficiency which occurred in the Decay Heat Pump casing drain line repair was that the radiographs were not retained.
The engineering deficiency which occurred was that data, used tor input to calculations, was not verified as originating from a controlled source. Specifically, the radiographs used to obtain the input for the actual pipe inickness calculations were not retained in accordance with approved procedurce.
The pipe wall thickness, as determined by the re-exammation in August 1986,.using -
controlled procedures, was the same as that determined by.the informal
. examination. Therefore, the conclustom, reached by Engineering remain valid and there was no reasonable concern that the public health and safety were in any way compromised by this violation, b
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Corrective stens which will be taken.
To prevent future occurrence, NEP 4106, Calculations, will be revised to require that input data for safety related calculations from other sources, such as approved calculations or from NDE or other tests, shall have been developed in accordance with the District QA Program. This NEP revision is expected to be completed by i
December 31, 1986.
Date when full comoliance will be achieved.
The District will take all of the necessary corrective actions as indicated by December 31, 1986. After discovering the piping degradation, an effort to permanently replace the affected piping was completed. Therefore, had any reduction in public health and safety occurred because of this violation, it no longer exists since the piping was replaced.
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