ML20207D272

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-312/86-30

ML20207D272
Person / Time
Site:	Rancho Seco
Issue date:	12/22/1986
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8612300363
Download: ML20207D272 (1)

See also: IR 05000312/1986030

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DEC 221986

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Docket No. 50-312

Rancho Seco Nuclear Generating Station

14440 Twin Cities Road

Herald, California 95638-9799

Attention: Mr. John E. Ward

Deputy General Manager, Nuclear

Gentlemen:

Thank you for your letter dated November 26, 1986, informing us of the steps

, you have taken to correct the items which we brought to your attention in our

letter dated September 18, 1986. Your corrective actions will be verified

during a future inspection.

Your cooperation with us is appreciated.

Sincerely, '

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Dennis F. Kirsch, Director

Division of Reactor Safety and Projects

bec w/ copy of letter dated 11/26/86:

Resident Inspector

Project Inspector

B. Faulkenberry

J. Martin

docket file

bec w/o copy of letter dated 11/20/86:

M. Smith

J. Zollicoffer

REGION V k.(w

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SACRAMENTO MUNICIPAL UTILITY DISTRICT C P. O. Box 15830, Sacramento CA 958521830,'(916) 452 3211' M

AN ELECTRIC SYSTEM SERVING THE HEART OF CALTQRNIAO'

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JEW 86-921 'O

November 26, 1986

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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 f

LICENSE NO. DPR-54

NRC INSPECTION REPORT 86-30, INSUFFICIENT QUALITY CONTROL OVER

THE PRODUCTION AND USE OF RADIOGRAPHS IN SAFETY REIATED

ENGINEERING WORK

The Sacramento Municipal Utility District hereby submits, in

Attachment 1, the response to Appendix A and B of the subject

Notice of Violation (concerning use and retention of radiographic

inspections of decay heat pump casing drain lines) in accordance

with 10 CFR Part 2.201. This supersedes our response on the same

subject and we regret any confusion that our previous response

may have generated.

If there are any questions concerning this response, please

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contact Mr. Ron Colombo at the Rancho Seco Nuclear Generating

l Station.

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HN E. WARD

DEPUTY GENERAL MANAGER,

NUCLEAR

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Attachment

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

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ATTACHMENT 1

DISTRICT REVISED RESPONSE TO NRC INSPECTION 86-30

NOTICE OF VIOLATION ,

NRC Violation A

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:

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).

District Response to Violation A

Admission or denial of the alleged violation.

The District concurs that the item cited is a

violation of the requirements 10 CFR 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.

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Reasons for the violation  !

Plant maintenance personnel considered their vendor's l

procedures adequate to determine p,ipe wall thickness.

However, subsequent investigation concluded that the

radiographic technique described in the procedures is

not adequate to accurately determine pipe wall

j thickness.

The design organization relied upon the early

" assurances of the maintenance personnel regarding the

radiographic technique and subsequently used input

' which was marked information-only for their design

calculations.

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Corrective steps which have been taken and

results achieved.

NEP 4106, Section 3.4 requires that a design

varification be performed for Class 1 calculations.

This is programmatically done at Rancho Seco.

, Corrective steps which will be taken to avoid further  ;

i violations. L

To prevent future occurrence, NEP 4106, Calculations,

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will be revised to emphasize that input data for safety

related calculations from other sources, such as

calculations or from NDE or other tests, are developed

in accordance with approved District procedures. This

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NEP revision is expected to be completed by December

I 31, 1986.

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In order to increase the District's confidence that

this is an isolated case of using information-only data

in a Class 1 design calculation, the District will

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sample a statistically significant number of mechanical

{ Class 1 design calculations that were performed during

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the past five years. ,

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The District will rectify any deficient calculations

and provide additional corrective action based on the

results of the survey.

Data full compliance will be achie'ved.

The District will revisa NEP 4106 as indicated by

December 31, 1986. After discovering the piping

degradation, an effort to permanently replace the

affected piping was completed. The design calculation

survey will be complete by February 5, 1987. The result

of the survey will identify what, if any, additional

corrective action is required.

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ATTACHMENT 2

DISTRICT REVISED RESPONSE TO NRC INSPECTION 86-30

NOTICE OF VIOLATION _

NRC Violation 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 l

circumstances and shall be accomplished in accordance l

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 or 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."

Contrary to the above, on February 18, 1986, written

procedures were not established to control the

radiographic inspection of the decay heat removal pump i

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).  !

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District Response to Violation B

Admission or denial of the alleged violation.

The District concurs that the item cited is a violation

of the requirements 10 CFR Part 50, Appendix B,

criterion V, " Instructions, Procedures and Drawings,"

which requires that activities affecting quality shall

be prescribed by documented instructions, among others.

Reasons for the violation

Maintenance personnel were not sufficiently aware of

the need for formal, proven techniques for use as

inputs to calculations being performed by the

Engineering Department. It should be noted that

subsequent to the Maintenance Department's initial

belief that the vendor procedure could determine pipe

wall thickness, formal and well documented techniques

for accurately determining wall thickness of a pipe

full of water using a radiographic examination were

found not to exist at Rancho Seco, or in the industry

as a whole.

Corrective steps which will be taken to avoid further

violations.

To determine piping adequacy in the future, the

District will use only approved and qualified

procedures employing ASME accepted techniques for the

determination of pipe wall thickness.

The District will determine the approximate magnitude

of the number of times radiographs were used as a

rationalization in declaring a pipe acceptable with

respect to its wall thickness. The District will

sample a statistically significant number of NCR's and

Technical Support Group evaluations written on the

subject of " pipe adequacy" during the past five years

to determine if pipe wall thickness via a radiograph

has been performed programmatically.

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The District will rectify any deficient NCR

dispositions and provide appropriate corrective action

based on the results of the survey.

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Data full compliance will be achieved.

The District is in' full compliance with the cited

maintenance commitment as of the date of chis response.

The " pipe adequacy" survey will be complete by

February 5, 1987.

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