ML20247L922

Provides Revised Response to NRC 881228 Ltr Re Violations Noted in Insp Rept 50-312/88-33.Corrective Action:Portable Shield Walls Inspected Every 6 Months to Ensure All Safety Factors Met & Area Surveys Conducted on Weekly Basis

ML20247L922
Person / Time
Site:	Rancho Seco
Issue date:	07/26/1989
From:	Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Knighton G NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AGM-NUC-89-005, AGM-NUC-89-5, NUDOCS 8908010380
Download: ML20247L922 (3)

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,  %< s j; Q , l3 - , i f y g/R ES JSMUD 'YSACRAMENTO MUNICIPAL UTILITY DISTRICI O 6201 S Street, P.o. Box 1583o, Sacramento CA 958521830,1916) 452-3211

. AN ELECTRIC SYSTEM SERVING THE HEART OF CAUFORNIA j.;

,,AGM/NUC 89.-005 July '26', 1989 g.

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k U. S. Nuclear. Regulatory Commission 4

' Attn: Document. Control Desk' t ' Hashington..: DC: -20555 Docket No. 50-312 .

Rancho Seco Nuclear Generating Station'

.: License No. DFR-54 REVISED RESPONSE TO NOTICE OF VIOLATION 88-33 v

Attention: George Knighton.

"On December 28, 1988, 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 following revised response to this violation.

On. January.27, 1989, the District responded to Notice 'of.. Violation 88-33.

a' The response acknowledged all violations cited except. item 'a' of

-Violation A. Further'information uncovered since January 27 has persuaded l

- the District lto. submit this revised response acknowledging item 'r of

. Violation A'.. Our previous submittal acknowledging items 'b'i 'c., a d 'd' is

.not affected by this revised response.

Members' of your ' staff with questions requiring additional information Y or clarification may. contact Mr. Steven H. Rutter at (209) 333-2935,

. extension 14911.

. Sincerely, Lff .e -

~tb  ;

Dan R. Keuter Assistant General Manager Nuclear.

-Attachment-l cc w/atch: J. B. Martin, NRC, Halnut Creek A. D' Angelo, NRC, Rancho Seco INPO p

-8908010300 890706 PDR ADOCK 0500031%

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.Q PDC- p RANCHO SECO NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638 9799;(209) 333-2935

' NRC STATEMENT OF VIOLATION A {

I A. .10 CFR 50 Appendix B Criterion II, " Quality Assurance Program," requires tne licensee to implement a quality assurance program that "shall be  !

documented in writing, and carried out throughout plant life."

The licensee's Quality Assurance Manual,Section II, describes the licensee's Quality Assurance program. Attachment 2.1 of Section II incorporates ANSI standard N4.5.2.3, " Housekeeping During the Construction Phase of Nuclear Power Plants," and NRC Regulatory Guide 1.39, i

" Housekeeping Requirements for Hater Cooled Nuclear Power Plants" into the program.

Regulatory Guide 1.39 Section C.3 states that ANSI N45.2.3 is applicable for housekeeping re.quiremer.ts during the operations phase.

ANSI N45.2.3, Section 3.5 lists housekeeping inspection requirements and requires surveillance. over installed items to assure adequacy of protection from movement of materials or equipment and other factors which may result in damage to installed items.

The licensee's Quality Assurance Manual,Section II, Attachment 2.2, Exception No. 4, concerning housekeeping states that " Appropriate procedures will be written and implemented." <

Administrative Procedure AP-18, Plant Housekeeping and Inspection, Section 3.13 states:

"Hork carried over from one workday to another shall be cleaned up and tools, materials, and equipment stored in a neat manner at the end of the workday."

Contra.y to the above, on November 14, 1988:

a. Portable lead shielding on rollers was unsecured adjacent to vital equipment in the east and west decay heat system cooler rooms in the auxiliary building.

b. Several unsecured carts on rollers were unsecured adjacent to vital equipment in the "B" and "D" channel EFIC rooms in the NSEB and in the west 4160 volt switchgear room in the auxiliary building.

c. A strip chart recorder on a cart on rollers was tied to the "A" channel cabinet of the Emergency Feedwater Initiation and Control System (EFIC) with the cabinet door open in the NSEB.

d. A ladder was tied with a rope to a safety related electrical conduit A57042 in the Nuclear Service Electrical Building (NSEB).

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

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'a' DJISIRICT RESPONSE TO VIOLATION A. ITEM 7;

1.:(Admission or' denial =of alleged violation:

w The District acknowledges and admits the above occurred as stated.-

< 2.- Reason for violation:

n, ' Portable shield walls manufactured on site were-not fabricated with wheel locks as vere purchased shield walls.-

Plant workers failed to follow Administrative Procedure AP.305-30

" Temporary Lead Shielding" and did not realize they were in violation of

'AP.305-30 until NRC identification of the problem. - .

3. Corrective actions taken and results achieved:

following notification by th'e NRC Inspector, personnel tied-off the shield

vall to ensure no movement'would occur.

During the time between notification by the NRC' Inspector and when full co;np11aate was achieved, the Radiation Protection Department

, Superintendent held ALARA Briefings to discuss moving portable shield walls, and performing weekly area surveys and six month inspections for portable shield walls to ensure all safety factors such as wheel chocking.

and tie-offs, were still effective. These briefings were prompted' based upon Engineering's evaluation of temporary equipment and seismic'II/I interactive: concerns. .

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4. Corrective actions to preclude further violations:  !

Portable shield walls are inspected every six months to ensure all safety far: tors'are met, and area surveys are. conducted on a weekly basis.

5. -Date uhen full. compliance was achieved: i Full compliance was achieved on November 27, 1988, when the portable "

E shield wall was tied-off.

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