ML20234F291

Responds to NRC Re Violations Noted in Insp Rept 50-312/87-21.Corrective Actions:Verification of Cable Routing Being Conducted Under Wire & Cable Corrective Action Program & Listed Procedures Revised

ML20234F291
Person / Time
Site:	Rancho Seco
Issue date:	08/28/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20234F218	List: ML20234F216 ML20234F291
References
GCA-87-513, NUDOCS 8709230081
Download: ML20234F291 (4)

Text

. _ _ _ __. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

. . cf

$)SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O P. O. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 'j AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFOHNIA GCA 87-513 August 28, 1987-

.o 5

U. S. Nuclear Regulatory Commission Attn: J. B. Martin, Regional Administrator

$gg w can .

5$$

-~

Region V l Office of Inspection and Enforcement y 2g q 1450 Maria Lane, Suite 210 l Halnut Creek, CA 94596 @

DOCKET NO. 50-312 RANCHO SECO NUCLEAR GENERATING STATION LICENSE NO. DPR-54 RESPONSE 10 NOTICE Of VIOLATION (NRC INSPECTION REPORT NO. 50-312/87-21) l l

Dear Mr. Martin:

By letter dated July 30, 1987, the Commission transmitted to the Sacramento l . Municipal Utility District a Notice of Violation concerning activities j 1 conducted at the Rancho Seco Nuclear Generating Station. In accordance with  ;

l 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. ,

If there are any questions concerning this response, please contact Mr. Ron H. Colombo at (916) 452-3211, extension 4236.

Sincerely, h $$$

f,G.CarlAndognini Chief Executive Officer, Nuclear '

l .

Attachment g 92 M $ h 2 G

cc w/atch:

l G. Kalman, NRC, Bethesda (2)

A. D'Angelo NRC, Rancho Seco F. J. Miraglia, NRR, Bethesda INPO I&E gf.6/

RANCHO SECO NUCLEAR GENERATING STATION 's a 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333-2935

\: s

'. 'y X' \

]; ll ,

< (

y ' >

ATTACHNENT . )

DISTRICT RESPONSE TO NRC INSPECTION J j ,

, REPORT NO. C7 .f.1 NOTICE DE VIOLATION 3

t

) ( (

WQ'LOMIIDS o '

1 10 CFR 50 Appendix "B" Criterion X requires that a program for inspection i of activitics,affecting quality shall be established and executed to l verify conformance witn the documented instructions, procedures, and

' drawings for accocolf shing the activity and that the ir.spections shall be p.rfonned by individuals other than those who performed the activity being k~ ' inspected. .NRC letter fron R.H Reid to J.J. Mattinoe (SMUD) dated Detedbar 13, 1976, confirmed SMUD's September 23, 1976, letter to the NRC

, sut%that SMUD's Quality Assarance (QA) Prsgma for plant operations

' ii ' j at Rax.ho Seco complied with the guidance contained in the WASH document

< Ne.1284, "Guioance on Quality Assurance Requirements During the Operation

' - - Phase of Nuclear Power ' Plants", dated October 26, 1973. HASH M84 specifies NRC Safety Guide 30, August 11, 1972, and ANSI N45.2.4-1975

/ ', (IEEE Std 33649?l), " Installation,,lInsoection, and Testing Requirements

.for Instrumentation and Electric Equipment During the Construction of huclear Power.. Plant Generating Stations" for QA requirement for the

', insta11attor% inspection, and testing of instrumentation end electric g equipment. ANSI N45.2.4-1972 Para.grr.ph 5.1.1 requires that " Inspections

, shall be made to verify that equipraent is being located, installed, cassembleri, and/or connected to comply with htest approved-for-construction drawing, manufacturers instruc<lons, and installation specifications. Such inspections shall include, M appropriate,

. verification.of: . . . .(3) proper location and routing of cables and sensing lines."

s Co9trary to 11h ese requirements, independent inspection for proper location and routing af approximately 1100 safety-related cables installed during tNe'1993 to 1935 timeframe was nyt oorformed. Of those cables,10 power /

. contre' cabins intermixed with ir.strumentation cables and 14 cables

' violating. Appendix "R" separation criteria have been identified to date fr' ora a sample of approximately 247 cables.

DriTUCLBESPONSL10J10LATION

, 't . Mminipr..pdenial of Alleged Violation:

t The District admits that this violation' occurred as stated.

2. Re1JmLfEXio.La11oni.

Independent inspection was not performed for procer location and routing of approxir ately 1100 safety-related cables installed during y - the-1933/85 outage because:

a. Inspections of cable pulls occurred after the cables were term.ina ted This occurred Secause the Construction Quality Contro' Group (CQCG' was not notified of the work in progress and did not. receive information aboat the work until after it had been completed. This, in turr , w3s caiisep by a change in the

/

f

-_____L

processing of cable installation (pull). cards which resulted in field engineers storing the pull cards after pulling the cables and only transmitting'the cards to the Card Control Group after cables were. terminated. This resequencing and storage of the pull cards resulted in the Card Control Group notifying the Construction Quality Control Group to inspect cable after the pull and' termination were completed.

b. The Lead Electrical QC Inspector directed the Electrical QC Inspectors to inspect cable routing "as far as possible from each end".

3. Corr ntive Actions Which Have Been Taken:

a. NEP 6307, Initial Issue, dated 12/28/85, superseded EII No. EC-11 for cable installation ard inspection. It specifically required verification that " cable has been installed in the correct raceway," and since that time it has been clear to inspectors that inspection of cable routing (i.e., " vias") is required.

More recently, MP/IS 307, Attachment 1, " Inspection Report Cable Installation Record", has been revised by Procedure Change Notice 4 dated June 30, 1987, to clearly state that " Verification shall consist of witnessing the installation of the cable". Also, the Cable Inspection Record of MP/IS 307 has been changed to show

. Item 5, " Cable Routing," as a Hold Point.

b. The verification of cable routing is being conducted under the Hire and Cable Corrective Action Program. The status of this program is being reported separately.

c. NEAP-4127 "CRTS" (Cable Raceway and Tracking System) was issued June 15, 1987. This procedure shows the flow of pull cards from the CRTS Coordinator to Maintenance / Modifications and Quality Control for work and inspection. After work and inspection are completed, the pull cards are forwarded to the CRTS Coordinator.

This card flow and the revisions to MP/IS 307 ensure that Quality Control verification of cable routing will occur during the cable pull.

d. In late 1985, the construction and maintenance inspection functions were transferred from the construction and plant organizations to the Quality Assurance Department. This programmatic change placed Quality Control in an organization independent of the organization performing the work. This independence has improved the ability of Quality Control inspectors to identify problems and for the site to achieve corrective action. In addition, the current program enables the Quality Organization to insert inspection points into work instructions.

l N

4. Corrective Actions Which Hill be Taken:

Completion of the cable walkdown portion of the Hire and Cable Corrective Action Program will complete the corrective action for this violation.

5. Corrective Action Comoletion Datn

.The cable walkdown portion of the Hire and Cable Corrective Action Program is scheduled for completion by September 30, 1987.