ML20214P248

Responds to NRC 870416 Ltr Re Violations Noted in Insp Rept 50-312/87-03.Corrective Actions:Nonconformance Rept S-6335 Generated to Revise Drawing 20529-10-EA,Rev 22 (Dcn 3B). Nuclear Engineering Procedure Manual 5207.3 Will Be Revised

ML20214P248
Person / Time
Site:	Rancho Seco
Issue date:	05/18/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20214P223	List: ML20214P221 ML20214P248
References
GCA-87-042, GCA-87-42, NUDOCS 8706030268
Download: ML20214P248 (5)

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qauu, 1 SACRAMENTO MUNICIPAL UTILITY DISTRICT O P. O. Box 15830, Sacramento CA 95857-1S;30,(916) 452-3211 l AN ELECTRIC SYSTEM SERVING T@HEAFITf" 0F AllFORNIA MAY I 81987 " 6 II GCA 87-042  % ,.

J. 8. Martin, Regional Administrator Region V Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 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 REPORTS NO. 50-312/87-03)

Dear Mr. Martin:

By letter dated April 16, 1987, the Sacramento Municipal Utility District was transmitted a Notice of Violation concerning welds not positively identified on a system drawing. Also discussed in the inspection report were several comments concerning the District's In-Service Inspection Program. In accordance with 10 CFR 2.201, the District provides the enclosed response to the Notice of Violation.

This letter acknowledges the violation cited and describes the District's intended corrective actions for each specific item listed in the Notice of Violation.

Sincerely, Yb dpwN G. Car Andognini Chief Executive Officer, Nuclear Attachment 8706030268 870528 PDR ADOCK 05000312 G PDR cc w/atch:

G. Kalman, NRC, Bethesda (2)

A. D'Angelo, NRC, Rancho Seco J. B. Martin (2)

INP0 I&E JEfj' RANCHO SECO NUCLEAR GENERATING STATION C 1444o Twin Cities Road, Herald, CA 95638-9799;(209) 333-2935

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ATTACHMENT I DISTRICT RESPONSE TO NRC INSPECTION 87-03 PAGE 1 0F 2 NOTICE OF VIOLATION NRC Violation As a result of the inspection conducted on January 27 through February 5, 1987, and in accordance with the NRC Enforcement Policy 10 CFR 2, Appendix C, (Enforcement Policy 1986) the following violation was identified:

10 CFR 50, Appendix B, Criterion VIII requires that a systeni be established for the identification of materials, parts and components.

The facility Quality Assurance Manual, Section 2 invokes ANSI N45.2-1971 which further prescribes that the measures shall relate an item through fabrication to an applicable drawing or specification.

The Welding Manual, Section 6.12, Weld Numbering, requires that the weld identifier appears on the fabrication or construction drawing and positively locate the weldment.

Contrary to the above, welds are not positively located on Drawing No.

20529-10" EA, Revision 22 for the main steam piping which contains two weld identifiers designated "M" and two weld identifiers designated "N".

This is a severity Level V violation (Supplement 1).

l District Resoonse to Violation

1) Admission or denial of the alleged violation:

The District acknowledges and admits that this item occurred as stated.

2) Reasons for the Violation:

Drawing #20529-10" - EA Revision 22 on Engineering Change Notice (ECN)

A-5415-A1) Design Change Notice (DCN 3A) added valve HV-20521 and identified associated welds "M" and "N". The drawing review failed to

, recognize that existing field welds "M" and "N" were already on the drawing.

3) Corrective actions which have been taken and results achieved:

As a result of this finding, Non Conformance Report (NCR) #S-6335 was generated to revise drawing 20529-10"-EA Rev. 22 (DCN 3B). This revision was complete on March 11, 1987. The newly added weld identifiers "M" and "N", associated with the welding of motor operated valve HV-20521 into line 20529-10"-EA, were changed to welds "MM" and "NN" respectively. This NCR also required changing the weld identifiers on the weldments themselves.

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4) Corrective steps which will be taken ;t'o avoid further violations:

To facilitate the proper identification of weldments/brazements, the following procedural revisions will be made. Nuclear Engineering Procedure Manual (NEPM) 5207.3, " Preparation of System Isometric",

willRbe revised to reference the Rancho Seco Helding Manual (M.308)' ,

for the unique numbering of weldments/brazements. NEPH 5207.16,.

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" Procedures for Checking all Piping Drawings," will-be revised to

, .specifically include the verification of unique weldment/brazement identifiers as a specific checking practice. NEPH 5207.28, " Pipe i Support Design Manual," (paragraph.5.2.2.3) will be revised to reference the Rancho Seco Helding Manual (M.308) for the unique numbering of NF piping support weldments. Additionally, Rancho Seco-Helding Manual, procedure M.308, " Mandatory Helding Practices," has a

. revision in process to clarify the weldment/brazement numbering requirements.

. 5)- Date full compliance will be achieved:

NCR #S-6335, to revise the drawing,' revise the weld identifiers on the.

1 weldments, and correct the corresponding documentation will be closed by July 15, 1987. .The proposed procedure revisions will be completed

.by July 15, 1987.

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ATTACHMENT II DISTRICT' RESPONSE TO NRC INSPECTION 87-03 PAGE l'0F 2 INSPECTORS COMMENTS CONCERNING THE ISI PROGRAM NRC Comment Open Item (87-03-01)

Rancho Seco's Quality Assurance Surveillance Program for the ISI contractor / program, as it is implementsd, has not been effective in verifying the contractor's technical performance.

District Response The original plant construction ensured compliance with quality requirements in conformity with the applicable codes. This included provisions for Inservice Inspection (ISI) of piping components over the course of plant life. This is in accordance with 10 CFR Part 50, Appendix B Criterion IX, Control of Special Processes.

Similarily, the ISI program has been established to verify the acceptability of the piping components, at various times in plant life, in conformance with the documented instructions, procedures and drawings for accomplishing this activity. This is also in accordance with 10 CFR Part 50, Appendix B Criterion IX, Control of Special Processes.

The contract vendor for the performance of the ISI Inspections is a 10 CFR 50, Appendix B qualified vendor which ensures' the quality of the inspections which are performed.

In addition, the District maintains programmatic control over the ISI program, and ensures the technical adequacy of the inspections by providing for both the program oversight and procedural reviews, on the scene observation of contract personnel (surveillance), and verification of equipment calibration and personnel qualifications in conformance with 10 CFR 50, Appendix B Criterion X Inspections. The District observer is qualified and certified to meet the Level II requirements of SNT-TC-1A.

As such he is qualified to verify the contractor's technical performance.

The program procedure QAP.21 Inservice Inspection and Inservice Testing Program will be amplified to ensure documentation of the observatios performed by the District Level III.

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PAGE 2 0F 2 NRC Comment Ooen Item (87-03-02)

Review of ultrasonic inspection results for the pressurizer support lugs (report numbers85-006, 86-007,85-010 and 85-0014) revealed that additional indications have been detected since the 1983 outage. The inspection results show that some of the new indications are close to previously reported indications suggesting possible dimensional changes.

Fracture mechanics analyses have been performed by the site ISI contractor and the licensee has filed the reports. However, the reports do not address the following concerns:

1. Are these indications growing as reported and if they are, what is the rate of growth?

2. If these new indications are fabrication welding indications not detected before, do they require further evaluation to determine why these indications were not detected before?

NRC Comment Ooen Item (87-03-03)

ISI figure C2.1.136 for weld 26121-33-BH revealed that a 0*, 45' axial and 45* circumferential examination was performed. Section 2.1 of this report discussed limitations for the 0*, 45' and 60* ultrasonic inspections (note: no 60* report was available for this weld). It is not possible to determine from the report what volume of the weld was or was not examined and, therefore, it could not be determined if applicable code requirements had been satisfied. The foregoing is an example of similar deficiencies identified in other weld package reviews. Thus, this is a generic problem with the ISI ultrasonic data at Rancho Seco.

District Resoonse to Items (87-03-02) and (87-03-03)

The District is currently contracting with the Babcock & Hilcox Company (the ISI contractor) to review and resolve both of these open items. The District will report these findings and any required corrective actions to the NRC as soon as they are available but no later than August 14, 1987.

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