ML20128G437

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Responds to Violations Noted in Insp Rept 50-312/85-01. Programmatic Weaknesses Listed in Encl Will Be Corrected by 851001.Corrective Actions:Implementation of New Design Guides,Improved Training & Reorganization of QC Groups
ML20128G437
Person / Time
Site: Rancho Seco
Issue date: 06/03/1985
From: Reinaldo Rodriguez
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
RJR-85-282, NUDOCS 8507090189
Download: ML20128G437 (3)


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$ suun '%P SACPAMENTO FAUNICIPAL UTIUTY DISTRICT O 6201 S Street. P.o. Box 15830, sacramento CA 95852 1830,1916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA 1365 JW 10 Fl!12: OE RJR 85-282 REGICN VlM June 3, 1985 J B MARTIN, REGIONAL ADMINISTRATOR REGION V 0FFICE OF INSPECTION AND ENFORCEMENT U S NUCLEAR REGULATORY COMMISSION 1450 MARIA LANE SUITE 210 WALNUT CREEK CA 94596 DOCKET 50-312 LICENSE N0. DPR-54 RESPONSE TO NOTICE OF VIOLATION INSPECTION 85-01 FOLLOW-UP As a result of the NRC team inspection 85-01 performed on January 7-11, 1985, a notice of violation was issued due to discrepancies in the as-built con-figurations with respect to design drawings for HVAC supports in the Nuclear Services Electrical Building (NSEB).

As an immediate action in response to the above notice of violation, the District performed a walkdown on all visually accessible HVAC supports which were of the same type as those investigated by the NRC team in the NSEB. It was determined by this inspection that minor discrepancies (i.e., deviations which did not jeopardize the intended function of the support) did exist.

The engineering evaluation of those discrepancies revealed no adverse effect on the safety of the plant. In addition, a root cause evaluation was perfor-med which indicated that one temporary quality control inspector had been involved in all the discrepant cases identified by the NRC.

To assure that no safety concerns existed, a further investigation was planned for the supporting systems of HVAC and other systems within the NSEB and other buildings to ensure that this was the case. In a meeting with NRC representatives on March 12, 1985, the District's plan for further investigation was presented to ensure that the Commission was kept informed of the District's intentions.

Further investigations have been performed on randomly selected samples per internationally accepted statistical sampling technique MIL-STD-105D. This investigation involving the efforts of 20 engineers and QC inspectors with an approximate total expenditure of 3000 manhours, was concluded on May 30, 1985. The random samples covered the supporting systems of HVAC, piping, cable trays, and conduits in the NSEB, Auxiliary, and Diesel Generator Buildings. All results are available for NRC review.

8507090189 850603 PDR O

ADOCK 05000312 PDR h

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RJR 85-282 June 3, 1985 The District's further investigation confirmed the preliminary finding that no safety problems exist even though minor discrepancies were observed

.and documented on NCRs. Engineering evaluations of all discrepancies indicated sufficient design safety margin existed to assure the operability of plant supports under all' operating conditions. This evaluation provides adequate confidence that no safety concerns exist and no further investigation is warranted.

As a result of this. investigation, the District has identified programmatic weaknesses which are listed in Attachment 1 along with their corrective actions. These corrective actions will be accomplished by October 1, 1985.

Please contact Mr. Ron W. Colombo at the Rancho Seco Nuclear Generating Station to discuss any questions or comments you may have concerning this issu R. J. Rodrigue Assistant General Manager, Nuclear Attachment

Attachment 1 IDENTIFIED WEAKNESS CORRECTIVE ACTIONS

1. Design personnel are not consis- 1. Implement Design Guides (new tently indicating sufficient Nuclear Engineering Procedures) installation tolerances on design and improve the training for drawings. the design personnel to empha-size need to indicate tolerances on design drawings.

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2. Craft personnel occasionally 2. Improve training of craft super-install supports with discrep- vision with respect to installa-ancies. tion in accordance with design drawings and properly receive instructions.
3. Field engineers are not consis- 3. Assure that the training for field tently identifying configuration engineers addresses verification discrepancies during installation of the installation prior to QC and prior to inspection. inspection.
4. Some instances were noted concerning 4. Ensure that training is provided QC inspectors failing to document for QC inspection personnel em-discrepancies. phasizing that inspection and acceptance of work must be per-formed to approved design documents.

(Initial training for QC inspectors was accomplished during initial phase of Inspection 85-01 Investiga-tion.)

5. Insufficient number of permanent 5. The District will reorganize to SMUD QC inspectors to adequately combine two separate plant QC oversee the temporary / contract groups into a single department inspectors. and improve the supervision for temporary / contract inspectors.
6. Construction surveillance program 6. The QA surveillance program was re-was not completely implemented, emphasized in the first quarter of 1985 with the issuance of scheduled QA surveillance.
7. Construction Inspection Data 7. Implement new Construction Engineering Reports (CIDRs) have lacked suffi- Procedures / Inspection Standards cient inspection requirements in (NEPs) and provide training to some instances, appropriate personnel.

l 8. = Difficulty in determining if'the 8. The District will investigate methods l

noted discrepancies had previously to enhance the retrievability of l been documented on an NCR. information about NCRs.

i Provide additional procedural

' 9. Bracing members removed to facilitate 9.

maintenance and new work was not re- controls for removed bracing members.

placed.in a few occasions.

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