ML20236D863

Notice of Violation from Insp on 870418-0529.Violation Noted:Liquid Penetrant Test Performed on Spent Fuel Pool Liner Not Controlled by Work Document or Procedure Which Included Quantitative or Qualitative Acceptance Criteria

ML20236D863
Person / Time
Site:	Rancho Seco
Issue date:	07/14/1987
From:	Chaffee A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20236D845	List: ML20236D841 ML20236D863 ML20236D873
References
50-312-87-13, NUDOCS 8707310090
Download: ML20236D863 (3)

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a APPENDIX A NOTICE OF VIOLATION Sacramento Municipal Utility District Docket No. 50-312 P. O. Box 15830 License No. DPR-54 During an NRC inspection conducted on April 18 to May 29,1987, violations of NRC requirements were identified. In accordance with the " General Otatement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:

A. 10 CFR 50, Appendix B, Criterion IX, " Control of Special Processes,"

states, in part:

" Measures shall be established to assure that special processes, including... nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."

Quality Assurance Policy Section IX, Revision 0, " Control of Special Process," states in part:

" Appropriate procedural methods shall be prescribed and implemented to assure that special processes, equipment and personnel are.

controlled and accomplished by qualified personnel and procedures." i l

Contrary to the above, on March 26, 1987, the liquid penetrant test, a l special process, performed on the Spent Fuel Pool Liner was not (

controlled by a work document or procedure which included quantitative or qualitative acceptance criteria for determining that important activities had been satisfactorily accomplished.

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

B. Technical Specifications (TS) Section 6.8, " Procedures," requires, in part:

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" Written procedures shall be established, implemented and maintained covering the activities referenced below:

"a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972."

Regulatory Guide 1.33, November 1972 requires, in part:

"I, Procedures for Perfcrming Maintenance. 1. Maintenance which l can affect the performance of safety-related equipment should be properly preplanned and performed in accorounce with written procedures."

8707310090 a70714 PDR ADDCK 05000312 G PDR

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2 In addftion, Plant Maintenance procedure M.114. " Maintenance Cleanliness '

Control," Section 3.0, " Limitations and Precautions," requires, in part "3.1 This procedure shall be used when opening any portion of the following systems...BWS.,..Use of this procedure is not required for activities such as replacing filter elements...provided that the j

component and area cleanliness and the replacement part/ parts  ;

cleanliness as detailed by the Cognizant Engineer is verified by an j authorized Inspector's signature on the Work Request."  ;

i Contrary to the above, on April 11, 1987, Work Request #125548 was written for replacement of a filter element in the Borated Water System (BWS) without providing for inspections for area cleanliness and an authorized inspector's signature on the Work Request.

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

l C. 10 CFR 50, Appendix B, Criterion VIII, " Identification and Control of Materials, Parts, and Components" states, in part:

" Measures shall be established for the ioantification and control of .

materials, parts, and components....These identification and control I measures shall be designed to prevent the use of incorrect or I defective material, parts, and components."

Quality Assurance Policy Section VIII, Revision 0, " Identification and Control of Materials, Parts and Components," states, in part:

"3.0 Policy. Appropriate procedural methods shall be prescribed and .

implemented to assure that materials, spare parts or components are j properly identified end controlled to preclude the use of incorrect i or nonconforming items during the operational phase of the plant."  !

In addition, Quality Assurance Procedure 6, Revision 3, "QC Inspection,"

j states, in part:

" Class 1, EQ and commercial grade items shall be released from the warehouse only if they have "SMUD ACCEPT" tag unless otherwise i exempted per paragraph 5.6." Paragraph 5.6 states that the Quality l Manager shall issue a list of items which are exempt from the "SMUD  !

ACCEPT" tag policy.

AP.605, Revision 12, " General Warehousing," states, in part 3.5.2.1:

"Any item released from the warehouse for Class 1 and EQ use shall have a SMUD Accept Tag (shown in QAP-16) installed by Quality Control (QC). Note: Exempt Items, as determined by QA, are ,

excluded from this requirement."

] i Contrary to the above, on April 9, 1987, under Work Request #125548, i replacement filter element (stock code number #005617) was issued without

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a SMUD ACCEPT tag and on April.11, 1987, the replacement filter element, stock code #005617 for the CBAST filter F-711 was installed without the-appropriate SMUD ACCEPT tag.-

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

Pursuant to the provisions of 10'CFR 2.201, the Sacramento Municipal Utility District is hereby required to. submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy.to the NRC Resident Inspector, Anthony D' Angelo, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include' for each violation: (1) the reason for the violation if admitted. (2) the corrective steps that have been taken and the results achieved, (3) the corrective steg that will be taken to avoid-further violations, and (4) the date when full compliance will be' achieved. If an adequate reply is not received within.the time specified in this Notice, an order may be issued to show cause why the license should'not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown.

FOR THE NUCLEAR REGULATORY COMMISSION

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g A. E. Chaf ee, Deputy Director Division of Reactor Safety and' Projects i

Dated at Walnut Creek, California this 14th day of .1,,q,.1987 i 4

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