IR 05000312/1988033

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-312/88-33

ML20235L387
Person / Time
Site:	Rancho Seco
Issue date:	02/17/1989
From:	Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8902270503
Download: ML20235L387 (1)

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FEB 17 tu Docket No. 50-312

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~ Rancho Seco'Nuclea'r G 'enerating Station Sacramento Municipal._ Utility District

<14440 Twin Cities Road Herald, California 95638-9799 Attention: Mr. Joseph F. Firlit Chief Executive Officer, Nuclear Thank you for your letter dated January 27, 1989, in response to our Notice of Violation and, Inspection Report No. 50-312/88-33, dated December 28, 1988, informing us of the steps you have taken to correct the items which we brought to your attentio Your corrective actions will be verified during a future inspectio Your denial of one of the four examples for Violation A will also be evaluated at that tim Your cooperation with us is appreciate '

Sincerely, OYhM .Old @ ;

R.P.himmerman, Chief l Reactor Projects Branch bec w/ copy of letter 1/27/89:

docket file State of-California A. Johnson G. Cook B. Faulkenberry J. Martin l Resident Inspector Project Inspector l r Smith (p>

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SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, P.o. Box 15830, Sacramento CA:958sh830, (916) 452 3211 AN ELECTRIC SYSTEM SERVING THdHEARf OF CALIFORNIA i

U ?!]30 AfQ; 3g CEO 89-026 January 27, 1989 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Hashington, D.C. 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO NOTICE OF VI0lATION 88-33 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 enclosed response to this violatio This letter acknowledges the violations cited except for item 'a' of Violation A and describes the District's corrective actions. The temporary lead shielding described in item 'a' of Violation A was evaluated and controlled in accordance with procedure AP.305-30, " Temporary Lead Shielding."

Members of your staff with questions requiring additional information or clarification may contact Mr. Steven H. Rutter at (209) 333-2935, extension 491

Sincerely, f{ g'

Joseph F. Firlit Chief Executive Officer Nuclear Enclosure cc w/ encl: J. B. Martin, NRC,THalnut Creek A. D'Angelo, NRC, Rancho Seco INP0

\ f RANCHO SECO NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638-9799;(209) 333 2935

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NRC STATEMENT"0F VIOLATION A CFR 50 Appendix B Criterion II, " Quality Assurance Program," requires the 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,

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Housekeeping Requirements for Water Cooled Nuclear Power Plants" into the progra Regulatory Guide 1.39 Section C.3 states that ANSI N45.2.3 is applicable for housekeeping requirements during the operations phas 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 item 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."

Contrary to the above, on November 14, 1988: 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, Several unsecured carts on rollers were unsecured adjacent to vital equipment in the "B" and "D" channel EFIC rooms in the NSEB and the west 4160 volt switchgear room in the auxiliary buildin 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 NSE A ladder was tied with a rope to a safety related electrical conduit A57042 in the Nuclear Service Electrical Building (NSEB).

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

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DISTRICT. RESP 0NSE TO VIOLATION A I l Admission or denial of alleged violation: l The District acknowledges and admits that the above occurred as stated except for item 'a' of Violation i Temporary lead shielding is controlled in accordance with Administrative i Procedure AP.305-30 " Temporary Lead Shielding," which is part of the i Radiation Control Manual. Lead Shield Tag No. 85-07 and associated-Temporary Lead Shield file 85-07 provides Engineering evaluation for this installation, Operations concurrence, and Radiation Protection control and periodic inspection of the shieldin In addition, the mobile shield racks have in-place wheel locks for the roller . Reason for the violation:

Administrative Procedure AP.18 " Plant Housekeeping and Inspection" and Maintenance Administrative Procedure MAP-0002 " Control of Maintenance Activities" did not provide proper guidance to plant workers on securing temporary equipment, apparatus and tools within the vicinity of safety related equipment. Also, these procedures did not provide proper instruction forbidding the securing of temporary equipment, apparatus and tools to safety related components when there is a possibility of damage to the component Plant workers followed the above procedures as understood, but did not realize they were in violation of A).18 until explained to them following NRC identification of the proble . Corrective actions taken and results achieved:

The housekeeping problems were immediately corrected upon notification to plant personnel by the NRC Inspector on November 14. Following identification of a ladder secured to safety related conduit on November 27, plant personnel immediately removed the ladde The importance of good housekeeping and protecting safety related components from potential damage has been emphasized in the weekly maintenance meetings since identification of the housekeeping violatio . Corrective actions to avoid further violations:

Maintenance Administrative Procedure MAP-0002 will be revised to:

• Add a note stating that tools, carts, scaffolding, or other temporary apparatus shall not be lashed / tied off to safety related conduit, piping, or plant equipment which could be damaged as a result of such action * Add a step requiring workers to secure temporary equipment, apparatus and tools within the immediate vicinity of safety related plant components to prevent undesirable movemen l l

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b1STRICTRESPbNSETOVIOLATIONA (Continued)

The revision to MAP-0002 will be required reading for all members'of the Maintenance Department. .This will be completed by February 28, 198 Administrative Procedure AP. 18 " Plant Housekeeping and Inspection" will be revised to address temporary equipment left in the vicinity of safety related equipment. This revision will be issued by March 1, 198 The revision to AP.18 will be required reading for all members of the Maintenance Departmen In addition, a site-wide memorandum will be issued detailing the importance of good housekeeping. This memorandum will be issued by February 22, 198 . Date when full compliance was achieved:

Full compliance was achieved on November 28, 1988, when the ladder was removed from the safety related condui '1 l-3-

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NRC STATEMENT OF VIOLATION B- Technical Specification 6.8.1 states in part:

" Written procedures shall be established, implemented and maintained-covering. . . the applicable procedures recommended in Appendix "A" of Safety Guide 33, November 1972."

Safety Guide 33, November 1972, Appendix A states in part,that Administrative Procedures shall be developed to assure procedure adherence and temporary change methods when procedures can not be followe Procedure RSAP-1308, " Potential Deviation from Quality," Section 5.3.4, states:

"The originator shall deliver the Potential Deviation from Quality (PDQ) report to the Operations Technical Advisor (OTA) within four (4)

hours from the time of identification."

Contrary to the above,-on October 26, 1988, a PDQ reporting that the dissolved oxygen concentration in the main feedwater had exceeded the limit specified in licensee procedure RSAP-0222 was not delivered'to the OTA within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of identificatio This is a Severity Level IV Violation (Supplement I).

DISTRICT RESPONSE TO VIOLATION B Admission or denial of alleged. violation:

The District acknowledges and admits that the above occurred as state . Reason for the violation:

On October 25, at 1110 hours0.0128 days <br />0.308 hours <br />0.00184 weeks <br />4.22355e-4 months <br />, Chemistry noted that the feedwater dissolved oxygen concentration for the Reactor Coolant System (RCS) was above the limit specified in Rancho Seco Administrative Procedure RSAP-0222 " Rancho Seco Chemistry Control Commitment." Attachment 6 of this procedure was a chart of RCS Temperature vs. Dissolved Oxygen Concentration. This chart contained three zones. Zone 3 had an action statement that required a return to Zone 2 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Zone 2 had an action statement that required a return to Zone 1 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. At 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br /> on October 25, 1988, the action statement for returning to Zone 3 was violate Procedure RSAP-0222 requires a Potential Deviation from Quality Report (PDQ) whenever a chemistry limit defined in the procedure is violate Procedure RSAP-1308 " Potential Deviation from Quality" requires the PDQ to be delivered to the Operations Technical Advisor within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of identification of the proble The Chemistry Department was aware of the need to initiate a PDQ, but was not aware of the time requirements for writing a PD _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _

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f* DISTRI Q RESPONSE TO VIOLATION B (Continued) Corrective actions taken and results achieved:

On October 28, 1988, PDQ 88-1807 was initiated to report the dissolved oxygen concentration violation. This PDQ described the procedure violation noted above. The PDQ describes the remedial and preventive actions plant personnel took to resolve the dissolved oxygen concentration proble On December 12, 1988, Procedure Interim Change Notice PICN-04 was initiated to RSAP-0222 " Rancho Seco Chemistry Control Commitment." This PICN included guidance on preparing PDQs for Chemistry Limit violations and replaced Attachment 6 with revised dissolved oxygen concentration limits in Attachment . Corrective actions to avoid further violations:

On January 27, 1989, the Chemistry Department issued a memorandum to all department members emphasizing the need to write PDQs within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of identification of the problem. This memorandum will be required reading for all members of the Chemistry Departmen . Date when full compliance was achieved:

Full compliance was achieved on October 28, 1988, with the generation of PDQ 88-180 _ _ _ _ - . - _ _ - _ ___o