IR 05000312/1980009
| ML19318B203 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 05/19/1980 |
| From: | Faulkenberry B, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19318B195 | List: |
| References | |
| 50-312-80-09, 50-312-80-9, NUDOCS 8006250124 | |
| Download: ML19318B203 (9) | |
Text
idAY ls 50
.
h U. S. NUCLEAR RECUL\\ TORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT RECION V Report No.
50-312/80-09
.
Docket No.
50-312 License No.
DPR-54 Safeguards creup Licensee: _
Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Facility Name:
Rancho Seco Inspection at:
Clay Station, California Inspection conducted:
Aoril 7 to 11,1980 Inspectors:
Lk I[/b b
$. B.'-Zwetzi4, Reactor Inspector Date Signed Date Signed
.
Date Signed
,
Approved by:
dh&w
[ /f ff B. Ji Faulkenberr[, Chief, Reactor Project
'Datd Signed Sec ion 2, R actor Operations and Nuclear Support Branch Date Signed Summary:
Inspection on April 7 to 11, 1980 (Report No. 50-312/80-09)
Areas Inspected:
Routine, unannounced ir g ection of the status of completion of selected fire protection modifications; status of completion of other
~
required modifications; changes in the onsite organization or staffing; the program for receipt, storage and handling of equipment and materials; followup on IE Bulletins and Circulars; and followup on previous inspection findings.
The inspection involved ?' :nspector-hours onsite by one inspector.
(
Results: No items of noncompliance or deviations were found.
l
-
,
A 8006250l%
_ _.
.
_ _ _ _ _ _ - _ _ _ _
.
.
DETAILS
- 1.
Persons Contacted
- R. Colombo, Technical Assistant J. Sullivan, Senior Quality Assurance Engineer
- H. Heckert, Nuclear Engineering Technician M. Young, Electrical Engineer F. Lopez, Warehouse Foreman M. Maltby, Senior Materials Handler C. Gittens, Materials Handler T. Tucker, Shift Supervisor
- J. Jewett, Senior Quality Assurance Engineer
- R. Lawrence, Site Project Engineer
- J. McColligan, Supervisor, Quality Control and Engineering L. Smith, Mechanical Engineer
- Denotes those attending exit interviev:.
2.
Licensee Action on Previous Inspection Findings a.
(Closed) Noncompliance (50-312/79-20-01):
Failure of the Management Safety Review Committee (MSRC) to review the minutes of the Plant Review Committee (PRC). The inspector verifed by review of the minutes of Meeting 93 of the MSRC, held on February 18, 1980, that the committee was now reviewing the minutes of the PRC.
PRC minutes reviewed at this meeting were those for the meetings held in January _1980 (meetings nos. 691 to 706).
b.
(Closed) Noncompliance (50-312/79-22-07):
Failure to have two members of the plant management staff approve temporary changes in procedures.
Because of the absence of a definition for the term " plant management staff" as used in Technical Specification 6.8.3.b, the inspector and the Senior Resident Inspector agreed with the licensee representatives that authority for such approval shall be as stated in the licensee's Administrative Procedure (AP) No. 2, Revision 8, Section 3.2.2.
This section states that approval may be given by the Shift Supervisor and a Senior Control Room Operator or by the Shift Supervisor and a Plant Engineer. This definition of authority is consistent with ANSI 18.7-1976, Section 5.2.2.
c.
(0 pen) Noncompliance (50-312/79-22-06):
Failure to obtain review and approval of temporary changes in procedures within seven days.
By letter dated January 22, 1980, the licensee stated that in order to minimize recurrences, the Chairman of the PRC will followup on temporary changes to assure PRC recommendations are addressed quickly to insure completion of review through the Plant Superintendent with minimum delay. The effectiveness of this measure will be evaluated at a subsequent inspection.
(70-22-06)
s
- -
.
L
&
,
_. - -
-2-
.
.
d.
(0 pen) Noncompliance (50-312/79-22-01):
Failure to audit qualifi-cations of all. facility personnel.
By letter dated January 22, 1980, the licensee comitted to revise the applicable document (QCI-2)
and conduct a personnel qualification audit during 1980.
This item will be followed up at a subsequent inspection.
(79-22-01)
e.
(0 pen) Unresolved Item (50-312/79-20-01):
Inadequate definition of quality classification of components, systems and structures. The inspector reviewed the latest revision of the licensee's Ouality Assurance Procedure No. 3,." Quality Assurance Classification." The inspector raised several questions and comments regarding the classification table and the footnotes thereto.
The licensee's representative agreed to consider these comments. This matter will
.
be followed up at a subsequent inspection.
(79-20-01)
f.
(Closed) Followup Item (79-22-05): Administrative Procedure (AP)
,
No.1, " Organization" did not reflect the actual facility organization.
The inspector determined that Revision 4 of AP-1 had been issued and that this satisfactorily resolved to the previous observation.
3.
Onsite Organization and Administration The inspector determined that revision of the Technical Specifications to reflect the current-facility organizational structure was requested by the licensee on February 21, 1978.
It was also determined that this revision was implemented by Amendment No. 2t. on November 14, 1978.
Review of the licensee's Administrative Procedure No.1 (AP-1) " Organization", Revision 4, indicated that the licensee's onsite organization conformed to that defined
,
~in the Technical Specifications and that the authorities and responsibilities i
were suitably delineated. Based on the statements of qualifications given
'
in the licensee's letter of July 30, 1979, the inspector concluded that the management and supervisory personnel in the current onsite organization are qualified in accordance with licensee commitments and regulatory require-ments.
~ No items of noncompliance or deviations were identified.
4.
Fire Protection Modifications The inspector reviewed the engineering records for the fire protection modifications required by Amendment No.19 to determine the status of completion as of the close of the inspe tien. Based on this examination, l
open Work Requests were still outstanding against the following Engineering Change Notices (ECNs):
Item No.
ECN Table 3.l*
Modification 2308 3.1.39 Radio communication with inside of containment 2704 3.1.36(5)
Fire door supervision 2798 3.1.21(4)
Fire stops
- Table 3.1 'in the Fire Protection Safety Evaluation Report - See Amencments 19 and 25.
.
t
-3-
.
With regard to these open Work Requests, the licensee's representative stated that the work outstanding against ECil-2308 consisted of testing communication quality wt11e the reactor is in operation -
as opposed to the tests which have been completed with the reactor shutdown. Regarding ECN-2704, this ECN covers not only fire door supervision, but also work on security door supervision. The licensee's representative stated that in this case the work outstanding against the ECil related to security functions and that all fire protection work required by Amendment flo.19 and specified in this ECf1 had been completed. Work outstanding against ECil-2798 (fire
-
stops) consisted of repairing stops which had been breached to effect plant modifications. The licensee's representative stated that this woulo probabb be a long term condition inasmuch some modification work involving cable installation or removal was usually in progress.
In such cases where fire barriers are breached the licensee intends to utilize a fire watch as provided in the technical specifications.
Based on the above and the results of previous inspections the inspector concludes that the licensee has fulfilled the requirements of Amendments Nos.19 and 25 to the facility license.
No items of noncompliance or deviations were identified.
5.
Other Modifications Required to be Comoleted during the 1979-1980 Refueling Outage *
a.
Small dreak LOCA Modifications The inspector reviewed the status of the small break LOCA modifications and procedure revisions required ** to be completed prior to operation following the current refueling outage.
The review included examination of the applicable engineering package-(ECN-2174) to verify that the modifications were to be implemented as proposed; verification of the seismic and
~
environmental qualification of the D.C. powered valve operators which were to be installed, examination of the results of Special Test Procedure (STP) 865-E, " Installation of D.C. Operators" and STP 083, "iiPI Flow Balance and Flow Verification," and examination of the installed D. C. motor operators.
.
The review of the results of STP 865 indicated that improper setting or drift in the setting of the limit switches that position the valves at their Safety Features position
'
could lead to operation in a cycling mode which would diminish the intended protective action. This observation was communicated to the secretary of the Plant Review Committee (PRC) prior to the PRC's review of the test results. As a result of the subsequent PRC review of this manner, the inspector was told that the cognizant engineer was directed to modify the design to preclude the possibility of cycling.
- Excluding TMI-2 " Lessons Learned" modifications.
- For requirement, see NRC Exemption dated December 15, 1978.
-4-
.
.
The review of the results of STP 083 indicated that the licensee
'was not satisfied with the results obtained with the reactor coolant system at atmospheric pressure. As a result, the licensee plans to repeat the test when' the reactor coolant system pressure reaches
'600 psig during plant heatup. This matter will be followed up in a subsequent-inspection.
(80-04-02)
Based on the above, the inspector concluded that the components being utilized in the modification were properly qualified and were being installed in the manner committed to by the licensee.
The inspector also examined a representative sample of the procedures affected by this modification to verify that appropriate modifications were incorporated and were properly reviewed and approved.
Procedures examined were the following:
A.15, Makeup, Purification and Letdown System, Revision 9, 3/10/80 A.59, 480 Volt Electrical System, Revision 4,3/17/80 A.70, Safety Features Actuation System, Revision 3,3/18/80 D.5, Loss of Reactor Coolant / Reactor Coolant System Pressure, Revision 15, 3/18/80 SP 214.03, Locked Valve List Based on review of the above procedures, the inspector concluded that the procedures had been appropriately modified and had been reviewed and approved as required by regulatory requirements.
b.
Alternate Water Sources for Auxiliary Feedwater System Procedures requiring revision to meet the commitments made by the licensee in his letter of December 17, 1979 were identified at a previous inspection. These revisions involve adding appropriate references in the procedures to alternate sources of auxiliary feedwater.
The inspector verified that the procedure revisions identified below contained the appropriate changes and had been reviewed and approved in accordance with regulatory requirements:
A.51, Auxiliary Feedwater System, Revision 12 B.4, Plant Shutdown and Cooldown, Revision 14 D.10, Loss of Reactor Flow and RCP Trip, Revision 8 D.14, Loss of Steam Generator feed, Revisicn 12 fio items of noncompliance or deviations were identifie.
.
6.
Receipt, Storage and Handling of Equipment and Materials Appropriate sections of the current revisions of the following licensee documents were reviewed as part of this inspection.
QAP* 4, Procurement Document Control QAP 6, Inspection Planning QAP 8, Identification and Control of Material, Parts and Components QAP_10, Receiving Inspection QAP 15, Handling, Storage, Shipping and Preservation QAP 16, Inspection Status QAP 17, flonconforming Material Control AP* 5, Safety fianual AP* 605, General Warehousing
- QAP = Quality Assurance Procedure, AP = Administrative Procedures.
Based on review of the above documents, plus others, the inspector determined that administrature controls for receipt of safety-related
,
items were in accordance with FSAR commitments. These controls included
'
provisions for establishing written requirements for conducting receiving inspection of such materials, for the use of " approved" and " unapproved" vendors, for examination for conformance with requirements stated in the original procurement document and for documentation of the receiving.
inspection. The inspector also verified that appropriate controls had been established for the identification and storage of acceptable and nonconforming items and for the conditional release and disposition of nonconforming items.
No formal requirements had been established, however, for providing feedback concerning nonconforming items to the supplier evaluation audit group. The licensee's representative stated there was no need for such a procedure because the same QA personnel were involved in both areas.
The inspector determined that the licensee's storage and handling programs were in conformance with FSAR commitments. These programs provided for identification and inclusion of special storage and handling measures in inspection planning, and for periodic auditing to verify conformance with the requirements. The program did not include, however, provisions for establishment of defined levels of environmental storage, as recommended by ANSI 45.2.2-1972, nor for formal control of items of limited shelf life.
Failure to follow the recommendations of ANSI 45.2.2-1972 appears to violate the licensee's commitment to WASH-1284 as stated in the licensee's letter to the NRC dated September 23, 1976.
This apparent deviation was also noted by the Performance Appraisal Branch (PAB) in their inspection of Rancho Seco during April and May of 1980. This matter will be addressed _further in the report of the PAB inspection.
The inspector examined the documentation related to the purchase of six safety-related items (gaskets, weld rod, incore neutron detectors, a nuclear service transformer, valve operators and vent valve parts)
and verified that receiving inspections and dispositions had been performed in accordance with established control. - _.
-6-
.
.
The inspector selected three of the above safety-related items and verified that they were stored in accordance with warehouse records and could be traced back to original purchase documents.
In touring the warehouse, the inspector observed two large items prominently marked with yellow " Hold" tags (indicating they were in " quarantine") that were not located in the designated Quarantine Area.
In each case the items were too large for convenient retention in the Quarantine Area.
It is noted that such exceptions are permitted by ANSI 45.2.2 and the licensee's commitments in the FSAR.
The inspector also examined recent receiving records to identify any items for which a noncomfonning report had been prepared. Only one such item was identified and it appeared to have been properly dispositioned.
No items of noncompliance or deviations were identified.
7.
Administrative Controls on Defeat of Safety Actuation Signals During Containment Purging By letter dated November 29, 1978, NRR requested the licensee to review the design of all safety actuation signal circuits which incorporate a manual overide feature to ensure that overiding of one safety actuation signal does not also cause the bypass of any other safety actuation signal. The question was asked particularly in the context of the potential capability to disable the containment isolation system during purging of the containment.
By letter dated January 4,1979, the licensee responded to this request by stating that the safety features actuation system incorporated in Rancho Seco Unit No.1 does not contain any override or bypass features except when the primary system pressure is below the trip point for the reactor protection system. Therefore, the licensee states, administrative controls are not required to prevent improper manual defeat of any safety actuation signals. The inspector verified these statements by discussions with a licensee representative and review of the FSAR.
No items of noncompliance or deviations were identified.
8.
Followup on IE Bulletins and Circulars The inspector examined the licensee's actions with respect to the following bulletins and circulars as indicated.
ia)
IE Bulletin 79-13 ( Closed)
v Evaluation of the licensee's July 13, 1979 response to this bulletin indicated that their emergency operating procedure for a steam line rupture did not clearly address the possibility of a feedwater line rupture outside containment. When this was brought to the licensee's attention, the licensee responded by letter dated December 19, 1979 stating that the procedure had been revised to address this matter. The inspector verified that the appropriate changes had been made in the affected procedure D.13, " Steam Line/ Feed Line Rupture."
-
.
-
-
-7-
,
'
.
h IE Bulletin 79-14 (open)
t At the inspector's request the licensee furnished the inspector with the engineering documentation used by the licensee in his validation of Stress Problem 73. This problem involved the safety related fluclear Service Raw Water return line (line no. 47360) from the "A" diesel ~ generator to the system main return line. Because the licensee's contractor (Bechtel) had identified significant deviations between the original stress model and the "as-built" system, the contractor had revised the stress isometric sketch and reanalyzed to system to verify the acceptability of the "as built" system. Using this rc/ised stress. isometric sketch, the inspector performed a walkdown observation of the piping to verify the accuracy of the sketch. As a result of this walkdown the inspector identified two 120 lb.
flanges that v.ere not shown on the stress isometric even though sixteen similar flanges were shown. The locations of the two sets of flanges which were apparently missing were between data points 90 and 95 and between data points 105 and 106. This matter was brought ta the attention of the cognizant licensee representative who was asked to provide the following information:
(a) Does the omission of these two flanges affect the validity of the revised seismic analysis?
(b) What are the implications of the omission of these two flanges on the quality of the Bulletin 79-14 review effort?
This matter is considered unresolved.
(80-09-01)
ci IE Bulletin 79-18 (Closed)
The inspector verified implementation of the commitments relating
'
to the emergency evacuation alarm, made in the licensee's September 12, 1979 response to this bulletin. Accordingly this item is considered closed.
'd[
IE Bulletin 79-25 (Closed)
By letter dated November 26, 1979 the licensee stated that there were no Westinghouse type BFD/NBFD relays in use at Rancho Seco and that there were no plans to install such equipment in the future.
Accordingly, this bulletin is considered closed.
je;.'
IE Circulars 79-18, 79-20 and 79-23.
(Closed)
By discussions with a licensee representative and review of internal documents the inspector determined that the licensee does not utilize the components which were the subjects of these circulars. Accordingly, these circulars are considered closed.
IE Circular 80-1 (Closed)
By discussion with a licensee representative and review of a licensee internal memorandum, the inspector determined that the licensee had cleaned the relays used in safety related applications in accordance with the instructions supplied with the Circular. Accordingly, this circular is considered closed.
-
_ - _ _ _ _ _ _ _ -.
.
-8-
.
.~
.
}f 'IE Circular '80-02 (Closed)
The inspectorfverified that this circular had been received by the
- licensee.
It was also determined that Administrative Procedure 23,
" Control Room Watchstanding".had been revised to limit the work hours of reactor operators and auxiliary operators 'n general
. agreement with the recommendations contained in the circular.
No formal. licensee limits are imposed, however, on the work hours of-health physicists.and maintenance personnel-although, according to the licensee's representative, less restrictive limits are imposed on these personnel by the union contract.
In addition, work in excess of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by reactor operators or auxiliary cperators merely requires prompt notification of the Operations Supervisor rather than approval of the Station Manager as recommended by the circular.
This circular is considered closed.
No' items of noncompliance or. deviations were identified.
9.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether.they are acceptable items, items of noncom-pliance, or deviations. An unresolved item disclosed during the inspection is. discussed in Paragraph 8b.
'
10.
Exit Interview The inspector. met with licensee representatives (denoted in para.1) at the conclusion of the inspection on April 11, 1980.
The inspector summarized the purpose and the scope of the inspection and the findings.
The findings were acknowledged by the licensee.
.