05000312/LER-1986-021, Responds to NRC Re Violations Noted in Insp Rept 50-312/87-16.Corrective Actions:Revs 1 & 2 to LER 86-21 Submitted to Rept Discrepancies in Inservice Insp Program

Responds to NRC Re Violations Noted in Insp Rept 50-312/87-16.Corrective Actions:Revs 1 & 2 to LER 86-21 Submitted to Rept Discrepancies in Inservice Insp Program

ML20235T619
Person / Time
Site:	Rancho Seco
Issue date:	06/26/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20235T608	List: 05000312/LER-1986-021, Responds to NRC Re Violations Noted in Insp Rept 50-312/87-16.Corrective Actions:Revs 1 & 2 to LER 86-21 Submitted to Rept Discrepancies in Inservice Insp Program IR 05000312/1987016 ML20235T635
References
GCA-87-244, NUDOCS 8707220203
Download: ML20235T619 (6)

LER-2086-021, Responds to NRC Re Violations Noted in Insp Rept 50-312/87-16.Corrective Actions:Revs 1 & 2 to LER 86-21 Submitted to Rept Discrepancies in Inservice Insp Program

Event date:
Report date:
3122086021R00 - NRC Website

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L gySMUDSACRAMENTO MUNICIPAL UTILITY DISTRICT O P. O. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA g,

JUN 2 61987

'J. B. 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 REPORT NO. 87-16)

Dear Mr. Martin:

By letter dated May 29, 1987, the Sacramento Municipal Utility Di n rict was transmitted a Notice of Violation concerning the failure to test certain -

safety /related valves in accordance with the NRC Safety Evaluation Report for the Inservice Testing Program, dated September 25, 1984. As required by 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 the items listed in the Notice of Violation.

In addition,~a statement concerning the effectiveness of the Manual Valve Maintenance program has been included.

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

Sincerely, f

. Car And ini m M" W Chief Executive Officer, 'J.]

Nuclear p 'S g_.$]

Y. > $ 1 Attachment @

o cc w/atch: m G. Kalman, NRC, Bethesda (2)

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

INP0 I&E 1

8707220203 870714 PDR O ADOCK 05000312 PDR ff'1c /

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

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-* ATTACHMENT I -

DISTRICT RESPONSE TO NRC INSPECTION 87-16 l NOTICE OF VIOLATION-NRC Violation During an NRC inspection conducted on May 4-8, 1987, a violation of NRC requirements was identified. In accordance with the " General Statement  ;

of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, l Appendix C (1987), the violation is listed below:

A. Technical Specification 4.2.2, Inservice Inspection, requires inservice testing of ASME Class 1, 2, and 3 components to be performed as closely as design permits in accordance with'Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50.55a(g) except where specific relief has been granted by the Commission.

1. The NRC Safety Evaluation Report for the Inservice Testing Program, dated September 25, 1984, provides relief from certain aspects of ASME Section XI for the Turbine Throttle Stop Valves TV-1, -2, -3, and -4 (Relief Exemption PV-14) but requires full fast stroke testing during each cold shutdown, including stroke time measurement.

ASME Section XI, Article IHV 3410, provides requirements for measurement and analysis of power operated valve stroke tiines and implementation of increased testing frequency and/or corrective action for specific increases in measured stroke time, even'though such stroke times may be less than the allowable maxima.

2. The NRC SER, Relief Exemption PV-3, provides relief from certain testing requirements for Reactor Coolant Pump Seal Injection Isolation Valves SIM-019. -020, -021, and -022 but requires that the valves be full stroke tested at each cold shutdown.

Contrary to the above:

1. Actual stroke times for Turbine Throttle Stop Valves TV-1, -2,

-3, and -4 have not been measured, documented and evaluated in accordance with ASME Section XI Article IHV 3410 during each cold shutdown since September 25, 1984.

2. Reactor Coolant Pump Seal Injection Valves SIM-019, -020, -021 and -022 have not been full stroke tested at each cold shutdown since September 25, 1984.

This is a Severity Level IV Violation.

l

ATTACHMENT 1 (Continued)

DISTRICT RESPONSE TO NRC INSPECTION 87-16 NOTICE OF VIOLAIIDH District Resoonse to Violation  !

1) Admission or dental of the alleged violation:

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

2) Facts related to the violation, and reasons for the violation:

On October 24, 1986, Licensee Event Report (LER) 86-21 " Failure to Implement Inservice Testing of Certain Safety Related Valves" reported that safety /related valves had not been properly surveillance tested in accordance with the Technical Specifications required Inservice Testing Program. Since that time LER 86-21 has been twice revised. The revisions describe additional examples of safety /related valves that were not tested in strict conformity with the Inservice Testing Program or the NRC letter from J.F. Stolz to R.3, Rodriguez dated September 25, 1984.

The valves cited in this violation (87-16-01) had already been addressed in the September 25, 1984, NRC iettcr. Recognizing the possible existance of further discrepancies in compliancc with the September 25, 1984, NRC letter, a commitment was made in LER 86-21 to comply with the provisions of the September 25, 1984, NRC letter prior to restart."

The reason for the violation was a failure to ensure detailed compliance between the requirements of the Inservice Testing Program and the Surveillance Procedures which test those requirements. With regard to the inspector's note at the bottom of Page 8 of Inspection Report 87-16 that the "IST Program had apparently expired on April 17, 1985, (as stipulated in the NRC SER above) and that the licensee was operating without an approved program," a May 7, 1984, NRC letter from J. Stolz to R. Rodriguez confirmed that the end of the first ten-year interval for Rancho Seco was June 18, 1986.

3) The corrective steps that have been taken and the results achieved:

LER 86-21, 86-21 Revision 1 and 86-21 Revision 2 have been submitted to report discrepancies in the Inservice Inspection Program, as they were discovered, in accordance with 10 CFR 50.73(a)(2)(i)(B). The commitment to complete the provisions of the September 25, 1984, NRC letter was included in each of the above LERs in anticipation of ,

possible further discrepancies. Corrective actions which resulted from the above LERs included surveillance procedure revisions, preparation of supporting calculations for testing, and a relief request addressing commitments in the September 25, 1984, NRC letter.

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6LTACHMENT 1 (Continued) I i

DISTRICT RESPONSE TO NRC INSPECTION 87-16 NOTICE OF VIOLATION I The need for a comprehensive Inservice Testing Program update has been recognized and an updated program was drafted in June 1987. The plant for the submission and review of the updated program is discus ed in section 4) of this response.

The firsi section of this violation (87-16-01) concerned the fact

. that the a..tual stroke times for the Turbine Throttle Stop Valves TV-1 through TV-04 had not been measured, documented or evaluated.

As mentioned by the inspector in this Inspection Report (87-16),

Surveillance Procedure SP.213.03C " Turbine Throttle Stop Valve Fall Safe Test" provides for full stroke testing of the valves. While the requirement to " measure" valve closure times was not specifically met, SP.213.03C as well as other surveillance procedures demonstrated the functioning of the valves under varying conditions and provided a high level of confidence that the valves would have performed their safety function during the period following September 1984.

Similarily, the second section of this violation concerning the failure to full stroke test the Reactor Coolant Pump Seal Injection Valves SIM-019 through SIM-022 (check valves) resulted from not meeting the correct valve testing requirements of the September 25, 1984, NRC letter. However, Surveillance Procedure SP.205.02 " Local Leak Rate Testing" did test these valves in the closed position and provided a high level of confidence that the valves would have performed their safety function.

A discussion of the proposed future testing for both the Turbine Throttle Stop Valves and the Seal Injection Makeup Valves is included in the proposed Inservice Testing Program Plan. This plan Qs described in section 4) of this response. ,

4) The corrective steps that will be taken to avoid further violations:

As a result of the findings of NRC Inspection Report 87-16, a third revision of LER 86-21 will be prepared and submitted to the NRC in order to address and document concerns regarding the safety related valves identified in the report.

As a result of the specific problems identified in LERs 86-21 and its revisions and the Notice of Violation 87-16, the District recognized the need to perform a comprehensive review and then to update the Inservice Testing Progre. A draft of the Inservice Testing Program Update was completed in June of 1987, and was in final management review as of June 23, 1987.

1 ATTACHMENT 1 (Continued)

DISTRICT RESPONSE TO NRC INSPECTION 87-16 NOTICE OF VIOLATION As stated in Licensee E;cr.t Raport 86-21 and its revisions, the District plans to continue to implement the commitments specified in the previous 10 year IST program, including the specific code reliefs granted by the NRC staff in the September 24, 1984 NRC letter, until the updated IST Program Plan, including appropriate reliefs, have been formally accepted by the NRC staff.  :

1 The upcoming submissions of the updated Inservice Testing Program to l the NRC is expected by June 30, 1987. The submission will include a request that the NRC Staff review the updated IST Program Plan and either 1) provide at least interim approval by September 1, 1987, or

2) allow scheduling of a meeting bttween the District and the NRC Staff prior to July 17, 1961, to resolve what testing must be accomplished prior to restart.

5) The date when full compliance will be achieved, full compliance will be achieved prior to restart by either implementing the update IST program, after NRC approval, or by obtaining NRC staff approval of specific variations from the September 25, 1984, code reliefs and fully implementing the previous 10 year interval program until NRC approval of the update IST program is received.

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ATTACHMENT II DISTRICT VIENS REGARDING THE MANUAL VALVE MAINTENANCE PROGRAM NRC Comments:

1 Your attention is invited to the results of our inspection of your Critical Manual Valve Maintenance program contained in paragraph 3.A of the attached inspection report. He identified discrepancies in four of seven valves that had been inspected and accepted by your Maintenance Department and sampled by us. He would appreciate you views regarding these.results and how they may reflect on the effectiveness of the maintenance program.

District Resoonse:

The original program on Manual Operated Valves developed in early 1986, called for verification of valve operability i.e., stroking, adequacy of the packing and repair of any. identified problems such as broken operators or body to bonnet leakage. At that time, there was no Quality involvement required in those activities. Through procedural changes within the Maintenance and Quality Departments, there is now Quality involvement in both the preparation of work packages, and the inspection / verification of valve operability.

Of the seven valves inspected, while all seven stroked satisfactorily, there were two major areas of concern; valve position indication and incomplete thread engagement. The packing leaks, while requiring corrective action, are not unexpected after one year. However, the position indication and thread engagement questions pointed out a weakness in the original inspection check lists.

As a result, we have reinspected all 142 valves as well as inspecting an additional 108 Limitorque manual operators. All thread engagement concerns have a been evaluated by Engineering and found to be acceptable. Valve position indication discrepancies have been identified and corrective actions are planned and scheduled for those activities.

Programmatically, we have included steps in the Preventive Maintenance check lists to address both thread engagement and position indication.

It is our. feeling that this will strengthen our existing program for manually operated valves and make it even more effective.

,