IR 05000312/1979022
| ML19290D996 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/27/1979 |
| From: | Faulkenberry B, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19290D985 | List: |
| References | |
| 50-312-79-22, NUDOCS 8002290625 | |
| Download: ML19290D996 (8) | |
Text
U. S. NUCLEAR REGULATCRY COMMISSION OFFICE OF INSPECTION AND ENroRCEMEMI
REGION V
Report No.
50 11?/70-??
Docket No, en_glo License No.
nnn_r*
Safeguards Group Licensee:
Sacramento Municinal Utility District P. O. Box 15830 Sacraranto. California 95813 Facility Name:
Rancho Seco Inspection at:
Plav C h tinn Inlifnynin Inspection conducted: 0ctober 29-flovember 1,1979 b?
Inspecters: Nd WJ riedkn k' ^
I*l e/ 2
'I G.B.Zwetzig, Reactor _I'nspec[or Date S yned Date Signed i
)
Date Signed
,
i"1 7!7 W
Approved By:
'-
B. H. Faulkenberry, Chief / Reactor Projects Section 2 Date Signed'
Reactor Operations and Nuclear Support Branch Surrary:
Insnection on October 29-f'ovember 1,1979 (Report No. 50-312/79-22)
Areas Insoected: Routine, unannounced inspection of personnel qualification program, design changes and modification program, test and experiments program, and independent inspection effort.
The inspection involved 26 inspector-hours onsite by one inspector.
Results: Of the four areas insoected, no items of noncompliance or deviations were found in two areas; three apparent items of noncompliance were identified in two areas (infraction-failure to review temporary changes to procedures within 7 days-Para. 6; deficiency-failure to audit qualifications of plant g
operating staff-Para. 3; infraction-failure to have temporary changes in procedures approved by two members of the plant management staff-Para. 6).
RV Forrr 719 (?)
8002290 6 2 [.
.
DETAILS 1.
Persons Contacted J. Sullivan, Senior Quality Assurance Engineer
- R. Colombo, Technical Assistant
- P. Dubre', Plant Suoerintendent J. Price, Surveillance Scheduler
- L. Schwieger, Ouality Assurance Director
- W. Ford, Operations Supervisor
- R. Miller, Chemical and Radiation Supervisor
- G. Coward, Maintenance Supervisor The inspector also talked with and intervievied several other licensee employees, including members of quality assurance and the technical support staff.
- Denotes those attending exit interview.
2.
Licensee Action en Previous Insoection Findings (0 pen) Unresolved Item (79-20-01): QA classification of components not clearly identified.
Due to the short interval of time since this item was first identified (October 5,1979), the licensee had not yet implemented any corrective action.
In the course of this inspection the inspector detemined that the deficiency in definition of QA class was more serious than originally believed.
This was due to the fact that not only was the guidance given in Quality Assurance Procedure (QAP) t'o. 3 deficient, but it was found that Section 4.2.5 of Admini-strative Procedure (AP) I'o. 3, " Work Requests", references an unapproved and uncontrolled "flaster Equipment List" as the source which specifies QA classification.
In addition, examination of documentation attached to Audit tio. 0-190 indicated that the Maintenance Supervisor had been delegated the authority to specify the QA classification of com-ponents.
Hence, there are at least three possible sources of information concerning OA classification.
Only one of these sources (OAP) No. 3, however, contains a classification assignment which has been reviewed and approved by the licensee's management; and this source, as noted in Inspection Report fio. 79-20, is incorrplete.
The inspector described the observed deficiencies in the program to the licensee. This item remains open.
3.
Personnel Oualification Program a.
Statement of Minimum Qualifications
-2-The inspector verified that the minimum qualifications for facility personnel were stated in writing in general terms by Technical Specification 6.3 which references AflSI fl18.1-1971 and, with respect to the Chemical-Radiation Supervisor, references flRC Regulatory Guide 1.8, September 1975. Additional mininun qualification standards for onsite supervisory, operations, maintenance and radiation protection personnel are stated in FSAR Section 12.4.1.
The qualifi-cations of non-destructive examination personnel were also specified in the licensee's document QCI tio. 2, "SMUD fiuclear Operations QA Audit Program," Rev. 9, October 23, 1979.
The qualifications of members of the onsite and offsite safety review committees are not stated explicitly. f4embership on these conmittees is specified in the technical specifications by position in the organization and the minimum qualifications of these positions are required to be in conformance with the provisions of AflSI fl18.1-1971, as noted above.
The inspector determined by discussions with licensee representatives that the qualifications of plant craftsmen were specified by the licensee's personnel department. The inspector also verified, by examining current vacancy announcements for journeymen plant craftsmen, that these qualifications met or exceeded the require-ments of AflSI fl18.1-1971. The licensee also utilizes apprentice craf tsmen.
The inspector determined by discussions with licensee representatives that it was the li:ensee's practice that work of apprentice craf tsmen, involving safety-related systems, was always directly supervised by a journeyman.
" Senior apprentices" (those witn greater than 48 months experience and designated " senior apprentice" by the licensee may be permitted to work without direct supervision.
Inasmuch as AflSI fi18.1-1971 specifies a mini-mum of 36 months experience for repairmen, the inspector concludes this practice is acceptable.
b.
Audit of Personnel Qualifications The inspector determined by inspection of audit requirements (QCI flo. 2 referenced above) and by discussions with licensee represent-atives that audits of the qualifications of facility pc.rsonnel were limited to licensed operators and nondestructive examination personnel. Since this excludes most of the non-licensed personnel, this is contrary to the provisions of facility Technical Spec-ifications 6.5.2.8.b which requires performance of audits of the
"... qualifications of the entire facility staff at least once a
.
-3-year."
This is an apparent item of noncomplP e at the deficiency level (79-22-01).
Desicn Changes and "odifications Progran a.
Design Change Control With respect to this area of inspection, the inspector examined the applicable porti7ns of the following licensee documents:
(1) Quality Assurance Procedures (QAP):
QAP-2 " Design Review", Rev. 4, 11/15/78 QAP-3 " Quality Assurance Classification", Rev. 2,10/6/'i QAP-12 " Testing Inspection," Rev. 3, 8/1/79 QAP-18 " Documentation Control Center", Rev. 1, 12/16/77 QAP-26 " Test Control", Rev. 2, 8/1/79 QAP-28 " Fire Protection", Rev. 1, 8/1/79 (2) Quality Control Instructions (QCI)
QCI-5 " Design Review and Processing of 50.59 Changes", Rev.
4, 9/28/79 QCI-9 " Procedure for Logging, Filing and Retrievability of the SMUD Nuclear Operations Quality Assurance Documentation System," Rev. 1, 9/28/79 QCI-11 " External Architectural / Engineering Design Review Procedure", Rev. 0, 9/28/79 (3)
ECP-1 " Rancho Seco Configuration Control Procedure", Rev.
1, 3/1/78 (4) Administrative Procedure, AP-302 "Special Test Procedures",
Rev. 3, 7/5/79 Based on review of the above procedures and discussions with licensee representatives, the inspector determined that, except as noted below, the licensee had assigned responsibilities and implemented adequate procedures for: (1) controlling design and rudification change requests, including review of requests pur-suant to the provisions of 10CFR 50.59; (2) controlling the design and modification process; and (3) controlling changes to and issuance of design document.
.
-4-The inspector also verified that an implemented procedure (ECP-1)
provided for incorporation of facility changes into plant oper-ating procedures.
There was no formal procedure, however, for assuring that such changes were also incorporated in operator training programs.
The inspector was told that such changes were in fact being incorporated due to the existence of an informal notification procedure.
The inspector reconrended that the noti-fication be formalized and the licensee's representatives agreed to consider this. This natter will be examined further dt. ring a subsequent inspection.
(79-22-02)
The inspector determined that there was no mechanism for assuring that facility modifications would not degrade the NRC approved fire protection program.
In response to the inspector's comment regarding this observation the licensee agreed to add a note to the " Design Review Checklist" form (part of QAP-2) directing the reviewer to include consideration of the effect of the mod-ification on fire protection.
This item will be examined on a subsequent inspection.
(79-22-03)
The inspector also determined that although QAP-No. 28 states
"all fire protection material and equipment shall be classified in accordance with 0AP No.
3," that QAP No. 3 did not, in fact, explicitly address fire protection material and equipment, nor did the general guicance contained in QAP No. 3 appear to be appro-priate.
The licensee's representatives were advised of this problem area and agreed to take corrective action.
This item will be examined at a subsequent inspection.
(79-22-04)
Finally, the inspector verified that controls were implemented to assure that: (1) design documentation was collected and trans-mitted to records storage; (2) approved modifications Nere tested in accordance with approved acceptance procedures and (3) design changes / modifications are reported to the NRC in accordance with 10CFR 50.59.
b.
Temocrary tiodifications, Lif ted Leads and Jumpers With respect to this area of inspection, the inspector also exam-ined the applicable portions of the following licensee documents:
Administrative Procedures:
AP-2 " Review, Approval and flaintenance of Procedures", Rev.
8, 5/4/78
.
.
-5-AP-3 " Work Request", Rev. 15,6/5/79 AP-26 " Abnormal Tag Procedure", Rev. 3, 12/20/76
/
Based on review of the documents listed above (including documents listed in paragraph 4.a) and discussions with licensee representatives, the inspector deternined that, except as noted below, the licensee had no special procedures for temporary plant modifications.
Acco rd-ingly, temporary modifications would be subject to the same procedures and requirements applicable to pernenent modificaticns.
The exception relates to temporary lif ted leads and jumpers.
The inspector deternined this aspect of operations is governed prinarily by AP-3 " Work Request" which requires engineering eval-uation (and appropriate processing where safety-related equipnent is involved), and by AP-26 " Abnormal Tag Procedure". The inspec-tor concluded that the procedures in this area were in confonn-ance with regulatory requirements and the rec.omnendations of AflSI f118. 7-1976.
As regards conformance with section 5.1.6 of AfiSI f118.7-1976, the licensee's procedures do not require two man independent veri-fication (except in the case of the auxiliary feedwater systcm)
of temporary changes such as lifted leads and jumpers.
Instead, independent verification is provided by means of documentary controls including AP-26.
flo items of noncompliance or deviations unre identified.
5.
Test and Experiments Proorgp The licensee documents noted in paragraph 4 were also applicable to this area of the program.
Based on review of the applicable portions of these documents and discussions with the l'censee the inspector deter-nined that procedures had been established for: (1) requesting tests and experiments; (2) assuring that tests and experiments were reviewed, evaluated and reported in accordance with the requiremer.ts of 10CFR 50.59; and (3) assuring that acproved tests aid experiments were per-forned in accordance with reviewed and approv;d procedure,
..
.
-6-The inspector also reviewed the Soecial Tes'. Procedures (STP) and suoporting documentation associated with the following plant rodifi-catiens :
ECN No. A-2356, Installation cf Ionization Cetectors (STP-814)
ECN No. A-2506, Control Grade Reactor Trip (STP-827/829)
ECN No. A-2546, Keyswitch Bypass on Control Grade Reactor Trip (STP-828)
Based on a review of this documentation, the inspector determined that these modifications and special tests had been performed in con-formance with regulatory requirerents and the icensees procedures.
fio items of noncompliance or deviatians were identified.
6.
Indeoendent Inscection Effort a.
Organization The inspector examined Administrative Procedure (AP) flo.1,
" Organization" and found that it did not reflect the current facility organization.
When this was brought to the attention of the licensee's representatives, they stated that a revision which viould update AP fio. I was in the process of receiving final approval and would be issued in the near future.
This item will be exanined at a subsequent inspection.
(79-22-05)
b.
Temocrary Changes to Procedures The inspector examined the licensee's confomance to the provis-ions of Technical Specifications 6.8.1.c and 6.8.3, dealing with surveillance procedures and temporary changes thereto. As part of this examination the inspector audited the records of a number of completed surveillance tests.
In the course of this audit the inspector determired that contrary to the requirements of Technical Specification 6.8.3.c, temporary changes were made to procedure SP 203.01B, "SFAS Digital Channel 1B Refueling Test",
on f!ovember 18, 1979, and the procedure was comoleted on December 18, 1979, but the required review and approval was not obtained until February 16, 1979, which is in excess of the seven days pemitted by this specification.
- This is an apparent item of noncompliance at the infraction level (79-22-06)
\\
..
,
.
.
.
-7-The inspector also determined that contrary to the requirements of Technical Specification 6.8.3.b, temporary changes were made to procedure SP 203.02C " Quarterly Makeup Punp and Valves Inspec-tion and Surveillance Test", on March 8,1978, and only one of the approval signatures was that of a member of the plant nanagement staff. The other approval signature was that of a Cor. trol Rocm Operator who is not a member of the Plant management staff.
This is an apparent item of noncompliance at the infraction level.
(79-22-07)
7.
Exit Interview The inspector met with licensee representatives (denoted in Para.1)
at the conclusion of the inspection on f ovember 1,1979. The inspector sumarized the scope and findings of the inspection, #ncluding the apparent items of noncompliance noted in paragraphs 3 and 6.
The licensee representative stated that they would revise facility procedures as necessary to: (1) address the QA classification of fire protection material eauipment; (2) include consideration of the effect of modi-fications on fire safety; (3) provide the Training Coordinator with copies of completed ECft's; and (4) improve the method of specifying the OA classifications of comparents.