ML20244B114

Notice of Violation from Insp on 890123-0217.Violations Noted:Nonconformance Rept Not Written After Determination That Debris Caused Failure of Two Instrument Air Sys Check Valves During Performance of Test Procedure STP-774

ML20244B114
Person / Time
Site:	Rancho Seco
Issue date:	03/27/1989
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20244B108	List: ML20244B105 ML20244B114 ML20244B116
References
50-312-89-01, 50-312-89-1, NUDOCS 8904190012
Download: ML20244B114 (2)

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i APPENDIX A-7,'+ '

NOTICE OF VIOLATION

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? Sacramento Municipal Utility District' ' Docket No. 50-312 License'No.

1 ' Rancho Seco Unit 1 DPR -

iDuring an'NRC inspection conducted during the period of: January 23 through February-17, 1989, violations.of NRC requirements were' identified. 'In-E accordance with the " General Statement of: Policy and Procedure for NRC

Enforcement Actions",10 CFR Part 2, Appendix C (1988), the violations are listed below: ,

L t 1 L A.' .10CFR 50, AppendixLB, Criterion XVI requires.that measures shall be-established to' assure that conditions. adverse to. quality, such as failures, malfunctions, deficiencies, deviations.-defective. material and-

, . equipment, and nonconformances are promptly identified and corrected.

, Rancho Seco proc'edure,-QAP.-17,."Nonconform'ing Material Control,"

9Revisionn7, requires that a:Nonconformance Report (NCR)'be written when

. a nonconformancecis' identified. It defines a nonconformance as a "de.ficiency in, characteristic, documentation'or procedure which renders e the(quality of antitem (materials,~ parts, components;or system)

' unacceptable oCindeterminate. Examples of nonconformance include:

physical' defects, test failures, incorrect or inadequate documentation, or deviation from prescribed processing, inspection or test procedures.

Nonconformances are hardware related."

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- Contrary to the above,! d'uring th'e period of November 8,1987 thru January 9,~1988 an NCR was not written when it was determined that .

p+ debris had caused the failure of two instrument air. system check valves during .the ' performance of special test procedure STP-774.

This is a Severity Level IV violation (Supplement 1).

B. ^10CFR 50,-Appendix B. Criterion III requires that measures be

. established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of their structures, systems and components.

e, Rancho.Seco procedure RSAP-0303, " Plant Modifications," Section 5.1.1 requires that Nuclear-Engineering has overall design responsibilities including development of the conceptual design and detailed design.

L .Section 4.8 of RSAP-0303 requires that the detailed design includes design definition. documents and design substantiation documents which present'the design and verification that the design is correct. Design substantiation documents include: design basis reports, design verification report, safety analysis report, calculations and interdiscipline document review notice. ,

Contrary to the above, as of February 14, 1989, conceptual or detailed

< design records did not include calculations to substantiate the design of:

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1. Two 1-inch diameter, non-safety grade, carbon steel pipelines, which connected to safety grade Auxiliary Feedwater System piping, as provided by Temporary Modification number TM-89-11. This piping was installed during the week of February 6,1989.

2. A gag mechanism, which was fabricated in SMUD shops and. installed on Main Steam safety valve PSV-20544. The gag mechanism was observed in place during the week of February 6, 1989.

f This is a Severity Level IV violation (Supplement 1).

C. 10CFR50, Appendix B, Criterion V, as implemented by the Rancho Seco Quality Manual (RSQM) Revision 2,Section V, Step 4.2, requires that.:

"... instructions, procedures, or drawings shall include applicable quantitative and/or qualitative acceptance criteria for verifying that the activities have been satisfactorily accomplished." Maintenance Administrative Procedure (MAP)-006 Revision 5, Step 6.2.6.3.(2) requires that a work instruction shall include acceptance criteria.

Contrary to the above, Work Request (WR) 01541360-1, issued on February 9,1989 for removal and detailed diagnostic inspection of the auxiliary feedwater pump governor valve linkage, did not contain acceptance criteria for critical measurements; neither minimum / maximum expected values, nor maximum measurement tolerances were included.

l This is a severity level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Sacramento Municipal Utility

• District is hereby required to submit a written statement of explanation to

[- the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region V, and a copy to the NRC Senior Resident Inspector, Rancho Seco Unit 1, 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 1 violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps 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 fo od cause shown, OR THE N LEAR REGULATORY COMMISSION

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,.8._ Martin Regional Administrator DatedatWalnut_ Creek,Cg'lifornia this % day of )#I , 1988