ML20248B661

Ack Receipt of 890427 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-312/89-04

ML20248B661
Person / Time
Site:	Rancho Seco
Issue date:	06/02/1989
From:	Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8906090138
Download: ML20248B661 (1)

See also: IR 05000312/1989004

Text

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-Docket No. 50-312

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b Rancho Seco' Nuclear Generating Station

Sacramento Municipal Utility District .

14440 Twin Cities Road l

Herald, California 95638-9799 l

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Attention: Mr. Joseph ~ F. Fir 11t

Chief Executive Officer, Nuclear

Gentlemen: 1

Thank you for your letter of April 27, 1989, in response to our Notice of-

Violation and Inspection. Report No. 50-312/89-04, dated March 31, 1989,

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informing us of the steps you have taken to correct the items which we brought

to your attention. Your. corrective actions will be verified during a future

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inspection.

-Your cooperation with us is appreciated. I  !

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Sincerely, ,

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. R . ' P. IZinim'e'rman, Acting Director - '!

Division of Reactor Safety-and

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April 27,'.-1989

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~U. S. Nuclear Regulatory Commission-

Attn: -Document Control Desk:

Washington, DCL.20555

Docket No. 50-312

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.. Rancho Seco Nuclear Generating Station

License No. DPR-54

RESPONSE TO NOTICE OF VIOLATION 89-04

Attention: George Knighton-

On March 31. 1989, the Sacramento Municipal Utility District received a

Notice of Violation concerning activities at the Rancho Seco Nuclear

' Generating Station. In accordance with 10 CFR 2.201, the District provides

the. enclosed response to this violation.

-This letter' acknowledges the violations cited and describes the District's-

corrective actions.

In a meeting on March 2,1989, the District provided a detailed list of

process. procedure and program improvements to be'made based on lessons '

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learned from the-January 31,.1989 Auxiliary Feedwater-(AFH)

Loverpressurization event. An update to the commitments made.in the meeting

will be provided undercseparate cover. These commitments address the post

maintenance testing program and the replacement parts equivalency program

as requested in your, March 31, 1989 letter.

Members of your staff with questions requiring additional information or

clarification may contact Mr. Dan Muth at (916) 452-3211, extension 4025.

Sincerely,

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f^ephF.Firlit

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Chief Executive Officer

Nuclear

Enclosure

cc:w/ enc: J. B. Martin, NRC,' Hainut Creek

A. D'Angelo, NRC, Rancho Seco

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-RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638 9799UlYo9) 333-2935

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DISTRICT RESPONSE TO NOTICE OF VIOLATION 89-04 I

NRC STATEMENT OF VIOLATION A.1

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A. 10 CFR, Part 50, Appendix B, states, in part:

" Activities affecting quality shall be prescribed by documented

instructions, procedures, or drawings, of a type appropriate to the

circumstances and shall be accomplished in accordance with these

instructions, procedures, or drawings,"

1. Rancho Seco Adminir,trative Procedure (RSAP) 0703, Revision 0,

SUPPLIER DISPOSITION REQUEST (SDR), Section 5.2, Review and

Processing of Supplier Proposed Changes, states in part:

"5.2.7 If the item being evaluated is for a Work Request

(HR) (replacement part) an ECN is required."

Contrary to the above, an ECN was not initiated for a replacement

part, a rebuilt governor, for Auxiliary Feed Pump (P-318), which was

installed on January 31, 1989 in response to SDR #88-26893-304.

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

DISTRICT RESPONSE TO VIOLATION A.1 ,

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1. Admission or denial of alleged violation:

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

2. Reason for the violation:

The ECN process was replaced by the Design Change Package (DCP) process.

A DCP was not initiated for this work because of inconsistencies in the

procedures governing the Supplier Disposition Request (SDR) and the DCP

processes.

The engineer performing Section 5.2.7 of procedure RSAP-0703 did not

consider the section applicable to the SDR/ Parts Equivalency Evaluation

Requirements (PEER) review because the item being evaluated was for an

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SDR rather than a Hork Request. The Work Request was initiated a month

later.

Nuclear Engineering Procedure NEAP-4202, " Procurement Document Review,"

Attachment 3 requires the following:

" Verify an ECN has been initiated for items being evaluated as a

replacement part (Corrective Maintenance Activities)."

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Corrective: actions taken:and'results achieved:

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The~ District iriitiated Potential' Deviation. from Quality (PDQ) 89-0148:to

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' document the resolution of the AFW pump' turbine governor overspeed.

' event. .The PDQ included a 10 CFR 50.59 Safety Evaluation' determination-

on.the modifications'made to...the Woodward governor by the vendor.

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A review of the procedures that control the DCP, SDR and PEER, processes:

3 has been completed. . The-following procedures-_were reviewed to determine-

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when a.DCP is required:

RSAP-0302, " Configuration Identification," defines the' equipment and

structures that require modifications..

RSAP-0303, " Plant Modifications," presents .the processes by which

modifications are made as well as the definitions that govern the

selection of a process.

NEAP-4112. " Drawing Change Notice, describes the situations in

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which a drawing change only (DCO) type'DCN may be used' to reflect. an

Las-built configuration on a drawing.

Based.on this' review,-.the. District concluded that, at the time, a DCP for

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the' replacement'of-the gov'ernor was not procedurally required. However,

procedural.; enhancements have been initiated that will ensure that the

. design . bases for material substitutions are maintained.

Revisions to RSAP-0703 and NEAP-4202 have been initiated that will

require a 10.CFR 50.59 determination. for each PEER that authorizes a .

substitution.-

'4. Corrective actions to avoid further viola'tions:

Procedures will be revised to remove inconsistencies and provide clear

guidance on when a DCP is required. Training on procedure-revisions will

be'provided to affected departments as required-by RSAP-0502, " Rancho-

.Seco Procedure Control." Training will be completed by June 15, 1989.

5. Date when full' compliance will be achieved:

Full. compliance will be achieved on June 15, 1989.

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3 NRC STATEMENT OF VIOLATION A.2'

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Aux.-feed' Pump Turbine (Terry Turbine) Operation and Maintenance

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Manual.(M5.06-57) Section-IV ." Starting", states,-in part:  !

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"... 0 pen the throttle ' valve gradually to' increase turbine

speed, checking the-speed frequently with a speed indicator; 'f

and.as the turbine approaches full speed, the governor should -

come into action smoothly'and partially close the governor.

valve to control-the speed. . When the governor apparently has '!

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control, continue to open the throttle valve _ slowly. .This-

should not increase the speed. Now, ~ fully open the. ihrottle -

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. valve, . and the turbine i s ready. for load. .'. . "

and Section 2, states in part:

"Before making any adjustment to an operating governor on a

p prime mover, check that the overspeed shutdown system is

operating' properly."

Contrary.to:the above, on January'31, 1989:

. Maintenance Work Request, MHR-0145212-0,

whicn controlled the

post-maintenance testing of the Terry Turbine, did not contain these

= applicable instructions.for performing the test.-

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

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' DISTRICT RESPONSE TO VIOLATION'A.2

1. Admission or. denial of alleged violation:

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

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2. Reason for'the violation:

The failure to include the vendor warnings in Hork Request 145212D-0 was

due to insufficient detail in the procedure governing post maintenance

testing.

Maintenance Administrative Procedure HAP-0006, " Work Request Planning,"

Attachment 15, Maintenance Verification Testing Guide, provides guidance

- to maintenance work planners' on maintenance verification testing

requirements to be included in work plans.

the attachment did not provide sufficient detail to assure that theAt the time of the

planners

Work would include necessary precautions and instructions within the

Request.

.Hork Request'145212D-0 was developed based on a 1987 Work Request which~

did not include warnings or caution notes regarding possible turbine

overspeed.

Individuals involved in both the phnning and implementation

process

overspeed. had no anticipation of and hence no contingency for a turbine

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Corrective actions taken and results achieved: i

' Procedure MAP-0006, Attachment 15 has been revised to ensure that

warnings provided in vendor manuals are included in test' plans.

Procedure RSAP-0803, " Work Request," has been revised to require reviews

that ensure all special limits, conditions and precautions are included

in Work Requests. i

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4. Corrective actions to avoid further violations:

In accordance with commitments made on March 2, 1989, the District will

have a revised Post Maintenance Testing (PMT) program in place by

September 1, 1989. This program will ensure that special precautions are

included in test plans.

5. Date when full compliance will be achieved:

Full compliance will be achieved on September 1, 1989, with

implementation of the revised PMT program.

NRC STATEMENT OF VIOLATION A.3

3. Rancho Seco Quality Manual (RSQM),Section XI, Revision 3. " Test

Control" states, in part:

"4.3 Test Procidures and Instructions, shall be reviewed by the

applicable organizations for technical content."

Contrary to the above, on January 31, 1989 MWR 0145212-0 was not

reviewed-by the applicable organization (Plant Performance

Engineering) for technical content prior to performance of the test.

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

DISTRICT RESPONSE TO VIOLATION A.3

1. Admission or denial of alleged violation.

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

2. Reason for the violation:

The Plant Performance Department did not review Maintenance Work Request

(MWR) 0145212-0 because procedure RSAP-0803 did not provide adequate

guidance for the review of post maintenance testing (PMT) related Work '

Requests. Neither RSAP-0803 nor MAP-0006 require affected departments to

review PMT Work Requests.

Work Request 1452120-0 was based on a 1987 Work Request which was written

by representatives from the Plant Performance Department, Maintenance

Department and the Woodward Governor Company. At the time of the

violation, a review of the new Work Request by all affected groups was

not procedurally required.

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Corrective actions taken and results achieved:  !

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Procedures RSAP-0803 and MAP-0006 have been revised to explicitly require j

the Plant Performance Department to review all PMT Work Requests. 1

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Corrective actions to avoid further violations-

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In accordance with commitments made on March 2,1989, the District will

have a revised PMT program in place by September 1, 1989. This program

will~ ensure.that an adequate review is performed for all PMT Work

Requests.

5. Date when' full compliance will be achieved:

. Full compliance will be achieved on September 1, 1989, with

implementation of the revised PMT program.

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