ML20237H822

Responds to NRC 870714 Ltr Re Violations Noted in Insp Rept 50-312/87-13.Corrective Actions:Training Conducted for Warehouse Personnel,Providing step-by-step Requirements for Issuing quality-related Matl

ML20237H822
Person / Time
Site:	Rancho Seco
Issue date:	08/11/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20237H778	List: IR 05000312/1987013 ML20237H822
References
GCA-87-429, NUDOCS 8708250164
Download: ML20237H822 (5)

Text

-

A

~

6 NSMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O P. O. Box 15830, Sacramento CA 95852-1830, (916) 452-321'n AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA GCA 87-429 AUG 11 1937 U. S. Nuclear Regulatory Commission Attn: J. B. Martin, Regional Administrator Region V Office of Inspection and Enforcement 1450 Maria Lane, Suite 210 Halnut Creek, CA 94596-DOCKET NO. 50-312 RANCHO SECO NUCLEAR GENERATING STATION LICENSE NO. DPR-54 RESPONSE TO NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-312/87-13)

Dear Mr. Martin:

By letter dated July 14, 1987, the Commission transmitted to the Sacramento Municipal Utility District a Notice of Violation concerning activities conducted at the Rancho Seco Nuclear Generating Station. In accordance with 10 CFR 2.201, the District provides the enclosed response to the Notice of Violation.

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

If you have any questions concerning this submittal, please contact Mr. Ron H. Colombo at (916) 452-3211, extension 4236.

Sincerely, k M-G. Carl Andog ni Chief Executive Officer, Nuclear 8708250164 870820 PDR ADOCK ODOOO312 Attachment G PDR cc: G. Kalman, NRC, Bethesda A. D'Angelo, NRC, Rancho Seco  :

J.B. Martin, NRC, Halnut Creek (2)

MIPC (2)

INP0 RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333-2935

4 ATTACHMENT 1 DISTRICT RESPONSE TO NRC INSPECTION 87-13 NOTICE OF VIOLATION NRC Violation 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 I applicable codes, standards, specifications, criteria, and other special requirements."

Quality Assurance Policy Section IX, Revision 0, " Control of Special Processes," 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."

Contrary to the above, on March 26, 1987, the liquid penetrant test,'a 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.

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

District Resoonse to Violation A

1) Admission or denial of the alleged violation:

The District admits that the violation occurred as stated.

2) Reason for the violaticn:

Hork planning personnel dispositioned Work Request No. 131557 without specifying acceptance criteria for a special process. Subsequently, Quality Control personnel conducted liquid penetrant testing of spent fuel pool liner welds without appropriate acceptance criteria.

3) Corrective actions taken and results achieved:

Planning personnel have been instructed to recognize and to include the appropriate quantitative and qualitative acceptance criteria for all special processes. Quality Control personnel have been instructed to perform special processes only when acceptance criteria are included in the work request.

5 - - - _ _ - - - _ _ _ _ _ _ --_-----_ - _ _-_----_--_--_ --__-------_-_---.--___-.----_------,--,.----__a

4) Corrective actions which will be taken:

No additional corrective actions are planned.

5) Date when full compliance will be achieved:

The District considers that full compliance has been achieved.

NRC Violation B Technical Specifications (TS) Section 6.6, " Procedures," requires, in part:

"Hritten procedures shall be established, implemented and maintainad covering the activities referenced below:

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

Regulatory Guide 1.33, November 1972 requires, in part:

"I. Procedures for Performing Maintenance. 1. Maintenance which can <

affect the performance of safety-related equipment should be properly )

preplanned and performed in accordance with written procedures." '

In addition, Plant Maintenance procedure M.114, " Maintenance Cleanliness Control," Section 3.0, " Limitations and Precautions," requires, in part that:

"3.1 This procedure shall be used when opening any portion of the following systems. . .BHS. . .Use of this procedure is not required for activities such as replacing filter elements. . .provided that the component and area cleanliness and the replacement part/ parts cleanliness as detailed by the Cognizant Engineer is verified by an authorized Inspector's signature on the Work Request."

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

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

District Resoonse to Violatiqn_B

1) Admission or denial of the alleged violation:

The District admits that the violation occurred as stated.

2) Reason for the violation:

The procedure for cleanliness control was not specific in designating circumstances for which application was not required.

l

3) Corrective actions taken and results achieved:

Maintenance cleanliness control procedure M-114 has been replaced by Maintenance Administrative Procedure MAP-0011. Step 2.2 of MAP-0011 provides specific circumstances for which the requirements of MAP-0011 are not applicable.

4) Corrective actions which will be taken:

The District does not plan any additional corrective actions.

5) Date when full compliance will be achieved:

The District considers that full compliance was achieved with the implementation of MAP-0011.

NRC Violation 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 identification and control of materials, parts, and components. . .These identification and control measures shall be designed to prevent the use of incorrect or 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 and components are properly identified and controlled to preclude the use of incorrect or nonconforming items during the operational phase of the plant."

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

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 exempted per paragraph 5.6." Paragraph 5.6 states that the Quality 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). Hate: Exempt Items, as determined by QA, are excluded from this requirement."

.- I

• Contrary to the above, on April 9,1987, under Work Request #125548, replacement filter element (stock grade number #005617) was issued without 4 a SMUD ACCEPT tag and on April 11, 1987, the. replacement filter element, l stock code #005617 for the CBAST filter F-711 was installed without the l appropriate SMUD ACCEPT tag.

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

District Response to Violation C

1) Admission or denial of the alleged violation:

The District admits that the violation occurred as stated.

2) Reasons for the violation:

Harehouse personnel issued a non-green tagged component for a Class 1 installation. The " Exempt List" as required by QAP-6 and RSAP-0701 did not specify filter elements as being exempt from " green tagging" requirements for issuance.

3) Corrective actions.taken and results achieved:

Training was conducted for warehouse personnel on April 29, 1987, which provided the circumstances surrounding this event and the step-by-step requirements for issuing quality related material. Memo SRK 86-008, Rev. I was distributed on June 12, 1987, revising the " Exempt List" to include filter elements.

4) Corrective actions which will be taken:

a. A training session will be conducted for Material Handlers to review the current " Exempt List".

b. A formal training session will be conducted by Quality Assurance to review " green tagging" procedures.

5) Date when full compliance will be achieved:

The District considers that full compliance will be achieved upon the completion of the above training by August 31, 1987.

I t