ML20214P163

Responds to NRC Re Violations Noted in Insp Rept 50-312/87-06.Corrective Actions:Qa Procedure QAP-17 Re Nonconforming Matl Control Revised & Nonconformance Rept S-6140 Reopened & Processed,Per Rev 5 to QAP-17

ML20214P163
Person / Time
Site:	Rancho Seco
Issue date:	05/07/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20214P150	List: IR 05000312/1987006 ML20214P163
References
GCA-87-001, GCA-87-1, NUDOCS 8706030234
Download: ML20214P163 (15)

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g"SMU= SACRAMENTO MUNICIPAL UTILITY DISTRICT C P. O. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CAllFORNIA GCA 87-001 MAY 0 71987 J. B. Martin, Administrator U. S. Nuclear Regulatory Commission Region V Office of Inspection and Enforcement 1450 Maria Lane, Suite 210 Walnut 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. 50-312/87-06)

Dear Mr. Martin:

By letter dated April 7, 1987, the Commission transmitted to the Sacramento Municipal Utility District 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 the Notice of Violation.

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

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

Sincerely,

/I w4 h

(. Carl Andoghini Chief Executive Officer, Nuclear 8706030234 870526 Attachment DR ADOCKOSOOg2 cc w/atchm:

G. Kalman, NRC, Bethesda A. D'Angelo, NRC, Rancho Seco INP0 I&E jf O/

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

ATTACHMENT 1 DISTRICT RESPONSE TO NRC INSPECTION 87-06 NOTICE OF VIOLATION NRC Violation A(1)(a) 10 CFR 50 Appendix "B" Criterion XVI requires that " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

Rancho Seco Quality Assurance Procedure QAP-17, Rev. 4, Paragraph 5.1 states, "An NCR [ Nonconforming Report] shall be initiated and processed if a component, structure or system cannot be returned to acceptable operational status by normal maintenance or replacement.

Contrary to the above, an NCR was not written for non-isolable pipe leakage in the "A" train of the nuclear service raw water (NSRW) system as identified in Work Request No. 110755 dated 2/2/86.

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

District Response to Violation A(1)(a)

1) Admission or denial of alleged violation:

The District admits this violation occurred as stated.

2) Reason for violation:

Lack of adequate training in QAP 17. " Nonconforming Material Control,"

of the persons involved resulted in the violation.

3) Corrective actions taken and results achieved:

NCR S-6480 was initiated on February 27, 1987 to address this non-isolable pipe leakage.

A revision of QAP 17 was made concerning this item on March 16, 1987.

As part of the revision process, plant personnel identified as requiring training have been trained on QAP 17.

4) Corrective actions which will be taken:

No further corrective actions are planned.

5) Date when full compliance will be achieved:

The District considers that full compliance has been achieved.

ATTACHMENT 2 DISTRICT RESPONSE TO NRC INSPECTION 87-06 NOTICE OF VIOLATION NRC Violation A(1)(b) 10 CFR 50 Appendix "8" Criterion XVI requires that " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

Rancho Seco Quality Assurance Procedure QAP-17, Rev. 4, Paragraph 5.1 states, "An NCR [ Nonconforming Report] shall be initiated and processed if a component, structure or system cannot be returned to acceptable operational status by normal maintenance or replacement.

Contrary to the above, licensee measures did not assure that the cause of the significant condition adverse to quality identified by NCR-56140 dated 12/09/86 (emergency diesel generator nonconforming condition) was determined.

Licensee measures did not assure that corrective action to preclude repetition of the significant condition adverse to quality identified by NCR-S6140 (emergency diesel generator nonconforming condition) was taken.

The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken for NCR-56140 was not documented and reported to appropriate levels of management. NCR-56140 was voided prior to determination of significance and performance of corrective action.

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

District Response to Violation Afl)(b)

1) Admission or denial of alleged violation:

The District admits that this violation occurred as stated.

2) Reason for violation:

A lack of communication between the individual requesting the voiding of NCR S-6140 and the initiator resulted in the violation. Under normal circumstances NCR(s) are voided only when no nonconforming condition actually existed. In this case, it was initially thought that no nonconformance existed. However, during a reevaluation subsequent to the voiding of NCR S-6140, Quality determined that the actual as-found condition was nonconforming.

3) Corrective actions taken and results achieved:

To preclude further miscommunication, Quality Assurance Procedure QAP-17, Nonconforming Material Control has been revised to read "For

' VOIDED' NCRs the QE Supervisor, or his designated representative, will. stamp, sign and date the NCR. The originator or his supervisor must concur (sign and date) with the voiding. The Manager Quality can

' VOID' an NCR without concurrence of the originator."

Also, NCR S-6140 has been reopened and processed in accordance with the requirement of QAP-17, Revision 5, above.

4) Corrective actions which will be taken:

This is considered to be an isolated case based on a thorough review of the specifics of this event. Therefore no additional corrective actions are planned.

5) Date when full compliance will be achieved:

The District considers that full compliance was achieved upon Revision 5 to QAP-17 on March 16, 1987.

ATTACHMENT 3 DISTRICT RESPONSE TO NRC INSPECTION 87-06 NOTICE OF VIOLATION NRC Violation A(2) 10 CFR 50, Appendix B, Criterion III, " Design Control," states, in part,

" Design changes, including field changes, shall be subject to design control measures commensurate with these applied +a the original design.

Rancho Seco Administrative Procedure AP.26, " Abnormal Tag Procedure",

Paragraph 5.2, states, in part, "In general, an Abnormal Tag is required anytime an electrical, mechanical, structural or pneumatic system is modified and placed in service without an approved DCN (Design Change Notice), per NEP 4109, to document the change.

Contrary to the above, an Abnormal Tag was not written for the temporary modification of the "A" train nuclear service raw water (NSRW) pressure boundary as identified in Work Request No. 110755 dated 2/2/86. The "A" train NSRW was returned to service with a rubber patch clamped onto the exterior of a defective pipe section to control non-isolable leakage. This condition existed for over one year.

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

District Response to Violation A(2)

1) Admission or denial of the alleged violation:

The District admits that this violation occurred as stated.

2) Reason for violation:

Lack of adequate training in AP.26 of the person involved resulted in the violation.

?! Corrective actions taken and results achieved:

ODR No.87-241 and NCR S-6480 were written to document the discrepancy.

NCR S-6480 was dispositioned and the pipe-tee replacement has been complete.

4) Corrective actions which will be taken:

The person responsible for failing to write the Abnormal Tag will be retrained in the requirements of AP-26, by June 1, 1987.

Interviews will be held with personnel involved in performing corrective maintenance to attempt to uncover other cases of failing to issue an abnormal tag by June 1, 1987.

5) Date when full compliance will be achieved:

The District expects that full compliance will be achieved by June 1, 1987.

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ATTACHMENT 4 DISTRICT RESPONSE TO NRC INSPECTION 87-06 NOTICE OF VIOLATION NRC Violation B(1) 10 CFR 50, Appendix B Criterion V, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circuastances and shall be accomplished in accordance with these instructions, procedures ..."

Quality Assurance Program Policy Section V, Rev. O, " Instructions, Procedures and Drawings", states, in part "3.0 Policy Activities affecting the operational safety or quality performance at Rancho Seco shall be prescribed by and implemented in accordance with documented instructions, procedures, and drawings for the operational life of the plant.

AP 605, Rev.11, General Warehousing, requires, in part "3.4.2.6 All shelf life items and EQ items that have a shelf life are sorted such that the oldest items are in front or on top and the newest in back or on the bottom.

3.4.3.4.1 A manual or computerized tickler file system will be set up to ensure that specific storage control instruction ... are followed.

3.4.3.4.5.7 The person responsible for reviewing the tickler will also be responsible for ensuring that the stock which has reached it's expiration date is removed from the shelf on a monthly basis..."

Contrary to the above, on February 24, 1987, sorting of shelf life items such that the oldest items are in front or on top had not been implemented in accordance with AP 605. A manual or computerized tickler file system had not been implemented to control special storage requirements; for example shelf life of rubber components. Expired shelf life items were not being reviewed or removed on a monthly basis.

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

District Response to Violation B(1)

1) Admission or denial of alleged violation:

The District admits that this violation occurred as stated.

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2) Reasons for violation:

Rotating stock so that the oldest stock.is in the front or on top of the most recently purchased stock is a normal practice. This violation resulted from deficiencies in the training of personnel on

-AP 605.

Concerning the lack of a manual or computerized " tickler" system to.

identify special storage requirements and shelf life expiration data:

l- ~Although an integrated, on-line, computer-based system, NUCLEIS (described below), was implemented to support all activities of the Rancho Seco material management organization,-the application of.

1 NUCLEIS has not been backfitted for all material purchases prior to Ii April, 1987.

'3) Corrective action taken and results achieved:

.An integrated on-line computer-based system,'(NUCLEIS) and a Materials Management Information System (MMIS) support all activities of the Rancho Seco material management ogranization. NUCLEIS/MMIS has addressed shelf life since April, 1987. Since that period, all material purchases having special storage requirements, are flagged in the database for shelf life information. Further, the pertinent data, including expiration date, are identified and displayed on the label affixed to the material.

MMIS program RSMM0330 produces a routine report, " Stock Items with-Expiration Date This Quarter", which is regularly distributed to warehouse supervision personnel. This report provides the following j information: Bin Location, Expiry Date, Stock Code Number,.

Description, Quantity, and-Responsibility Center. This report is

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reviewed and the'necessary action is then taken to remove material

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with_ expired shelf life to the appropriate quarantine hold area for disposition.

4)= Corrective action which will be taken:

' Additional training in procedure AP 605 will be provided to warehouse

, personnel. The District will implement a color-coded " chrono flag"

. system which will require that colored flags be fastened to the material indicating how the material is to be rotated. This practice ,

l will make the warehouse personnel who are responsible for putting the material away more conscious of the need to rotate the material in compliance with AP 605.

The District is backfitting the application of these labels to

materials purchased before April 1987 as priorities and available resources permit. It is expected that this activity will be completed by September 1988. ,

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C:ncerning expired shelf life items not being reviewed or removed en a monthly basis: In addition to this activity, a material reverification / stock baseline task is being implemented. Those materials with shelf life, or those materials which are suspected of being short shelf life candidates, will have hold tags placed on them until the materials analysts can verify the status of the materials.

Depending on that determination, material with valid shelf life i.e.,

not yet expired, will be so marked and the corresponding information will be entered into MMIS for future control of those items.

Materials having expired shelf lives will be removed to a quarantine area for final disposition.

This program is expected to be completed by September 1988.

In the interim, all requested stock items, which have not been verified in the reverification / stock baseline program, will be evaluated for shelf life expiration prior to issuance. This administrative control will be implemented by June 1, 1987

5) Date when full compliance will be achieved:

The District considers that full compliance will be achieved by September 30, 1988.

ATTACHMENT 5 DISTRICT RESPONSE TO NRC INSPECTION 87-06 NOTICE OF VIOLATION NRC Violation B(2) 10 CFR 50, App. B. Criterion VIII, states, in part: " Measures shall be established for the identification and control of materials, parts, and components, including partially fabricated assemblies. These measures shall assure that identification of the item is maintained by ... part number, serial number ... on the item Quality Assurance Program Policy Section VIII, Rev. O, " Identification and Control of Materials, Parts and Components" requires, in part "3.0 Policy Appropriate procedural methods shall be prescribed and implemented to assure that materials, spare parts or components are properly identified and controlled to preclude the use of incorrect nonconforming items ..."

and paragraph 4.1 states, in part "4.1 Procedures are required to provide for appropriate identification of safety related materials, spare parts or components, including partially fabricated subassemblies and consumables, in such a manner that these items can be related to it's applicable drawing, specification, purchase document and inspection record at any stage from initial receipt through fabrication / construction, installation, repair, modification or use Contrary to the above, a system of " green tagging" used in the warehouse to issue safety related parts was not described by an approved procedure.

This is a Severity Level V violation (Supplement I).

District Response to Violation B(2)

1) Admission or denial of alleged violation:

The District admits that the violation occurred as stated.

2) Reasons for the violation:

The formalization of inventory control procedures was delayed due to the evolving nature of the Materials Management organization.

3) Corrective actiCns taken and results achieved:

Quality Assurance Procedure QAP 6. Revision 3 was issued on February 27, 1987, and General Warehousing Procedure AP.605, Revision 12 was issued on March 13, 1987. These procedures describe the green tagging system used to issue safety-related parts and are presently being used.

4) Corrective action which will be taken:

No additional corrective actions are planned.

5) Date when full compliance will be achieved:

The District considers that full compliance was achieved March 13,1987.

ATTACHMENT 6 DISTRICT RESPONSE TO NRC INSPECTION 87-06 NOTICE OF VIOLATION NRC Violation C 10 CFR 50.72(a)(1) states, in part "Each nuclear power reactor licensee...

shall notify the NRC Operations Center via the Emergency Notification System of ... those non-emergency events specified in paragraph (b) of this section Contrary to the above, the licensee did not notify the NRC Operations Center as described below of the following events:

a. Actuation of the "A" diesel generator on June 22,1985,(required under 50.72(b)(2)(ii) and later identified in LER 85-13).

b. Discovery on October 7, 1985 of a failure of the essential control room HVAC system to function per design requirements and Technical Specification requirements. (Required under 50.72(b)(2)(iii) and later identified in LER 85-20.)

c. Discovery on January 7, 1986 that insufficient voltage would be available to the essential control room HVAC power supplies following

( a design basis LOCA. (Required within four hours under 50.72(b)(2) and later reported on November 1986 under 50.72(b)(2)(iii) and in LER 86-23.)

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

District ResDonse to Violation C

1) Admission or denial of alleged violation:

The District admits that this violation occurred as stated.

2) Reason for violation:

Administrative procedures established to control the reporting of plant occurrences did not adequately define the responsibilities and process for evaluation and reporting of events in accordance with the requirements of 10 CFR 50.72.

3) Corrective actions taken and results achieved Administrative Procedure AP-22, " Occurrence Description Reports (00R's) Reporting and Resolution" has been revised to amplify the reporting requirements of 10 CFR 50.72. Personnel identifying an unsafe, atypical, or off-normal condition are now required to promptly notify the Shift Supervisor and to provide an ODR to the Shift Supervisor within one hour.

The Shift Supervisor has bsen clearly dssignated as having the responsibility for evaluating 10 CFR 50.72 reportability and initiating 10 CFR 50.72 reports. As part of Senior License training and requalification training, the Shift Supervisor receives instruction on the requirements of 10 CFR 50.72. The Shift Supervisor also has prompt access to the Licensing Organization on an as-needed basis for interpretations of 10 CFR 50.72.

Since revisions to AP-22 have been implemented, there have been no additional deficiencies in the reporting of 10 CFR 50.72 occurrences.

4) Corrective actions which will be taken:

No additional corrective actions are planned.

5) Date when full compliance will be achieved:

The District considers that full compliance was achieved with the approval of AP-22, Revision 12 on January 16, 1987.

ATTACHMENT 7 DISTRICT RESPONSE TO NRC INSPECTION 87-06 NOTICE OF VIOLATION NRC Violation D 10 CFR 50.73(a)(1) states, in part "The holder of an operating license for a nuclear power plant (licensee) shall submit a Licensee Event Report (LER) for any event of the type described in this paragraph Contrary to the above, the licensee did not submit a LER as described below for the following events:

a. Discovery on January 7, 1986, that insufficient voltage would be available to the essential control room HVAC power supplies following a design basis LOCA, as required within 30 days after the discovery of the event under 50.73(a)(i) and later identified in LER 86-23.

b. On September 9, 1985, liquid effluent was released without an on-line radiation monitor or a dual verification of a chemical analysis of the release sample as required by Technical Specification 3.15. Therefore, the event was reportable under 50.73(a)(2)(1)(B).

c. With the reactor in a cold shutdown condition on September 10, 1985, both emergency diesel generators were declared inoperable. This condition alone could have prevented the fulfillment of the safety function to remove residual heat and was therefore reportable under 50.73(a)(2)(v)(B).

d. On October 30, 1985, while the plant was in hot shutdown, the auxiliary feedwater pump, P-319, auto started on the safety feature signal of low feedwater pressure. This event was an automatic actuation of an engineered safety feature system and reportable under 50.73(a)(2)(iv).

e. On December 16, 1985, the licensee discovered that Technical Specification 4.4.1.2.5 had been violated, in that the containment personnel hatch had not been tested at the required pressure on December 12, 198(6). The identified violation has not been reported pursuant to 50.73(a)(2)(1)(B).

f. On September 23, 1985, the decay heat "dropline"/ suction isolation valve closed spuriously, removing the ability of the system to remove residual heat. This condition alone could have prevented the fulfillment of the safety function to remove residual heat and was therefore reportable under 50.73(a)(2)(v)(B).

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

r-District Response to Violation J1

1) Admission or denial of alleged violation:

The District admits that this violation occurred as stated, except for item b.

2) Reasons for violation:

The administrative procedure which was established to control the 10 CFR 50.73 reporting of plant events apparently did not ensure that these events were either properly identified, or dispositioned.

Subsequent evaluation of the September 9, 1985, event involving releases of liquid effluent, as cited in event b of this violation, revealed that dual samples of the 'B' Regenerant Holdup Tank were taken on September 9, 1985, as required by Technical Specification 3.15, during the time the on-line process radiation monitor was inoperable. Apparently, the Occurrence Description Report originally identifying this potential event was not updated to reflect the results of additional investigation by the Shift Supervisor.

3) Corrective actions taken and results achieved:

The District identified programmatic weaknesses in the 10 CFR 50.73 reporting process prior to the issuance of this violation and l implemented the following revisions to Administrative Procedure AP-22,

" Occurrence Description Reports (00RS) Reporting and Resolution":

• Rancho Seco personnel identifying an unsafe, atypical, or off-normal condition must promptly notify the Shift Supervisor and provide the Shift Supervisor with an ODR within one hour. This ensures that 10 CFR 50.73 reportable events are identified for timely disposition.

The original 0DRs are picked up from the Control Room each working day by the organization responsible for evaluating and dispositioning 10 CFR 50.73 reports. This prevents losing ODRs in the transmittal process.

• The DDR reviewer is required to document his evaluation of the reportability of the condition and to provide written justification of his evaluation and disposition of the ODR. This accountability ensures that the evaluation process is thorough and traceable.

In addition, copies of the dispositioned ODRs are provided to the Resident NRC Inspectors, as a courtesy.

l Although late, the District provided the NRC with an LER 86-23 regarding item a, as required.

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4) Correctivefactions which will be taken:

The' District will provide.the required reporting of events c through f

.of this violation by July 31, 1987.

To correct the lack of timeliness concern identified, AP.22 will be

' issued site-wide as RSAP 1301 by June 30, 1987.

5) Date when full compliance will be achieved:

The District considers that full compliance will be achieved with the reporting of events c through f by July 31, 1987.