ML20236G088

Responds to NRC Re Violations Noted in Insp Rept 50-312/87-20.Corrective Actions:Nonconforming Rept S-6790 Initiated on 870624 to Address Affect of Heat Treating Valve Yoke

ML20236G088
Person / Time
Site:	Rancho Seco
Issue date:	10/20/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
GCA-87-651, NUDOCS 8711020411
Download: ML20236G088 (5)

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s I: $)SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O P. O. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA GCA 87-651 CCT t a sggy U. S. Nuclear Regulatory Commission Attn: J. B. Martin, Regional Administrator Region V Office of Inspection and Enforcement 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO NOTICE OF VIOLATION 87-20 h

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Dear Mr. Martin:

On September 21, 1987, the Sacramento Municipal Utility District received a Notice of Violation concerning activities at the

,g Rancho Seco Nuclear Generating Station. In accordance with 10 CFR 2.201, the District provides the enclosed responses to this Violation.

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

Please contact me if you have any questions. Members of your staff 'with questions requiring additional information or s

( clarification may contact Paul Lavely at Ext. 4674.

Sincerely, I a .,

Q

G4 Carl AndcIgnini Chief Executive Officer, Nuclear ih (5 8711020411 871020 PDR y ', ADOCK 05000312 G PDR '

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'i fb~~ Cl RANCHO SECO NUCLEAR GENERATING STATION '] 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333 2935 g

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y. ATTACHMENT 1 l DISTRICT RESPONSE TO NOTICE OF VIOLATION 87-20 NRC Statement of Vio1'ation A.-

'10 CFR ~50, ' Appendix. B, Criterion IX , - :" Control 'of- 'Special-

, Processes,"cstates,-in part:.

." Measures 'shall be established-to'..a'ssure .that special

-processes, including ...Eheat treating, are' controlled'and accomplished. ~by qualified . personnel using ' qualified. 4 procedures in , accordance with; applicable codes, ~ standards, .

specifications, criteriaLand other special requirements."-

' Quality Assurance ' Policy Section IX, . RevisionL 0, . " Control of i

-Special Processes," Paragraph 3.0, states:

" Appropriate procedure and ' methods - shall' be prescribed and

' implemented to assure that-special processes, equipment'and personnel. are controlled and accomplished by'. qualified personnel:and procedures".

Contrary to thess' requirements, on June 24,.1987, heat treating )

of the7 yoke of safety features valve SFV-25004 was not controlled.

or accomplished using a qualified procedure. This work: : was performed under Work Request - #1133657 (sic) with no specific provisions for heat treating.

This is a severity level IV violation (Supplement 1).

. District Resoonse

1) -Admission or denial of alleged violation:

The District acknowledges and admits that the above occurred as stated.

2) Reason-for the violation:- H Work Request #133657 was initiated to ~ perform Penetrant Testing on the yoke of valve SFV-25004. The scope of this

. work request was' expanded'to include repair welding of.the yoke. After welding, distortion was observed on the yoke legs. To remedy this problem, the distorted areas were heat ]

treated. The. welding engineer.was informed of.the intended )

steps and concurred with the plan of action prior to heat 1 treatment. Work Request #133657 was revised to document the heat treatment.

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i Although 1) the heat' treatment was performed under: the direction'of a maintenance engineer and 2) the individual steps were . documented, 'the work was 'not performed .in j accordance with an approved procedure. j 1 3) Corrective . actions which. have .been taken and- results -

achieved.

Nonconforming Report S-6790 was initiated on June 24,- 1987 to, address the. affect of heat treating the valve yoke.

The j

' disposition action of : the Nonconforming Report analyzed the i impact of the heat treatment and stated that the valve yoke ~ l is. suitable for its intended use. J l

4)- Corrective action which will be taken to ~ avoid further  ;

violations. i Procedure M.308. " Mandatory Welding Practices" will -be ,

revised' to include instruction's for heat treatment to l eliminate weld distortion. .The revised procedure will ensure that any future ' heat treating .to eliminate weld distortion will be procedurally controlled.

5) Date.when full compliance will be achieved:

Full compliance will be' achieved by January 1, 1988.

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ATTACHMENT 2 DISTRICT RESPONSE TO NOTICE OF VIOLATION 87-20 ,

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'NRC Statement'of Violation:B.

10 CFR H 50, . :Appendix B, - Criterion..? X, " I n s p e c t i o n , " s t a t e s ,.; i n ,

'part:.

." A . program for inspection ;of ' activities . affacting ~ quality.

shall be established and' executed by or for the_ organization.. a performing 'the activity to . verify ~ conformance with the

documented instruction,- procedures- and' drawings -for accomplishing'the activity ..."

Quality Assurance ' Policy Section X, . Revision 0, " Inspection,"

states, in paragraph 4.8:

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"A ' construction inspection . program will. be- performed on.

Class I and Environmental Qualified (EQ). equipment to assure ft ,, -construction andLinstallation activities.are in conformance-

,.- to design drawings and~ specifications ..." .

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' Licensee . construction, procedure NPEM 8304.7.C (sic) section '

5.1.27 requires that the minimum band radius .for - 4 AWG. triplex

' cable be 1.6 inches.

Licens'ee ' construction' procedure NPEM .5304.7'.C section 5.2 requires.the installation of cable tray bumpers'and installation -

of separation group color markings.

Contrary to these requirements, an electrical' cable for esse'ntial HVAC air handling : unit . AH-DG-1B had an ' electrical ' cable bend radius of 3/4"'in the. motor terminal box. In cable trays A57El and A57015'no cable tray. edge' bumpers existed. _ Electrical pull ,

, box H7J2995, which contained an "A"~ channel safety related' cable,. ~

.was color marked black rather'than red, as required.

This'is a Severity Level IV violation (supplement 1).

District Response

1) Admission or denial of alleged violation::

The District acknowledges and admits that the above occurred as stated..

2) ' Reason for the violation:

The current procedures used to control the installation of cables and cable trays were not in effect when this equipment was installed. Additionally, the present l

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I inspection criteria l were not- in effect- 'when this m construction was: performed.

3)- Corrective actions !which. have been Ltaken 'and results Lachieved.-

Nonconforming' Report ~ No. . S-6843 was initiated on July ~ 14, .

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1987, .to . address - the ' improper color:--marking of electrical ~

The incorrect black ' marker on :: this ,

junction box'H7J2995.

box was . replaced with ' a red diamond one.-

In' addition, a sample. inspection was made . of 26 ' out of the 32 - Class 11'  ;

-junctions boxes ' associated with diesel generator assemblies l G-100A'and.G-100B. All of the junction-boxes inspected were 'l correctly marked. Based onithe result of this ; survey, _ the - i incorrect- ~ color marking of - junction. box -H7J2995' is f considered'to_be an-isolated event. I m 1 Nonconforming: Report S-6844, initiated . on . July 14, 1987, addresses the. lack of cable tray edge protection on trays A-57El' and L57B2.. This protectior has been installed on~the trays in' accordance- with pro;edure -NEP 5304.7C. In ~

addition, . the; two cables impacted by- these' trays ' have < been insulation resistance tested and found to beLin acceptance condition.

- 4) Corrective actions which will be taken to avoid further violations.

The planned corrective - actions for the . improper band. radii of ' cables 121A412A and 121B412A are to resize the appropriate. terminal boxes and rework the cables to meet the acceptance criteria of installation specification IS-E-5304.8. After the rework is. completed the cables will be insulation resistance tested to verify that the rework'has not degraded cable performance. These activities should be completed by November 1, 1987.

To ensure'that additional cables associated with TDI diesel' construction work do not have improper bend radii, an inspection is being performed of all cables located inside enclosures and equipment associated with the TDI diesels.

The acceptance criteria for this inspection is'specified in IS-E-5304.8. This inspection will be completed by November 1, 1987.

' 5) .Date when full compliance will be achieved. ,

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Full compliance will be achieved by November 1, 1987.

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