IR 05000312/1980036
| ML19341D418 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/08/1981 |
| From: | Canter H, Faulkenberry B, North H, Obrien J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19341D403 | List: |
| References | |
| 50-312-80-36, NUDOCS 8103050575 | |
| Download: ML19341D418 (13) | |
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U.S. fiUCLEAR REGULATORY COMMISSION
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OFFICE OF IfiSPECTION AtJD Ef1F0P.CEMEtiT
REGION V
hortfio.
50-312/80-36 Docket fio.
50-312 License flo.
DPR-54 Safeguards Group,
Licensee:
Sacramento Municipal utility District P. O. Box 15830 Sacramento, California 95813 Facility flame:
Rancho Seco Unit 1 Inspection at:
Herald, California (Rancho Seco Site)
Inspection conducted:
flovember 3-28, 1980
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u Inspectors: ' n.~1,(' m A I-T-6(
H. L. Canter, Senior Resident Inspector Date Signed
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J. P.' 0' 3riep Unh Resident Inspector Date Signed p' /]h
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i[l, j H. S. Ilorth, Radiation Specialist (Paragraph 8, only)
Date Signed
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Approved By: ~T_f.3 \\g ki%$[
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_B. H. FIulkenberry, Qhief, Reactor Projects Section 2, Date Signed
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Reactor Operations and fluclear Support Branch Sunmary :
Inspection Between ilovember 3 and 28, 1980 (Report fio. 50-312/80-36)
Areas Inspected:
Operational safety verification; monthly maintenance observation; monthly surveillance observation; follow-up on regional requests; follow-up on items of noncompliance and deviations; "SALP" inspection activities; follow-up on Headquarters; and independent inspection effort. The inspection involved 122 inspector-hours by the resident inspectors.
Results:
Of the eight areas inspected, no items of noncompliance or deviations were found in seven areas; two items of noncompliance were found in one area (i!CRs which have not been promptly corrected and content of monthly report).
8103050 N RV Form 219 (2)-
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DETAILS 1.
Persons Contacted _
- R. Rodgriquez, lianager, !!uclear Operations
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- P. Cubre', Plant Superintendent O. Blachly, Operating Supervisor
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fl. Brock, Electrical /I&C Maintenance Suoervisor T. Cassidy, Dresser Corporation Technician R. Colombo, Technical Assistant
- G. Coward, Maintenance Suoervisor
- D. Comstock, Acting Operations Supervisor B. Daniels, Supervising Electrical Engineer
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J. Dawson, QC Coordinator
- H. Heckert, Engineering Technician J. Jewett, Acting Quality Assurance Supervisor F. Kellie, Plant Chemist V. Lewis, Site Project Engineer
J. ItcColligan, Mechanical Engineering Supervisor
- R. Miller, Chemistry / Radiological Supervisor R. Mcore, SMUD Special Agent T. Singer, SMUD Inspector
- J. Sullivan, Senior Quality Assurance Engineer
- D. Whitney, liuclear Engineer B. Uichert, Mechanical Engineer U. Wilscn, Senior Chemical & Radiation Assistant l
The inspectors also talked with and interviewed several other licensee l
erployees, including members of the engineering, maintenance, operations, j
and quality assurance (QA) organizations.
- Denotes those attending the Exit 7.iterview on December 1,1980.
j 2.
Operaticnal Safety Verification The inspector observed control rocm operations, reviewed applicable logs and ccaducted discussicns with control roca operators during the month of l
llovercber,1980. The inspectcr verified the operability of selected emergency
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systems, reviewed tagout records and verified proper return to service of affected ccmponents. Tours of the auxiliary building and the turbine building were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to
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i verify that maintenance requests had been initiated for equipment in need of maintenance. The inspector by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security plan.
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-2-The inspector observed plant housekeeping / cleanliness conditions and verified imolementation of radiatien orotection controls. During the month of November,1980, the inscector walked down the accessible portions of the makeup and purification systen and auxiliary feed system to verify operability. The inspector also witnessed nortions of the radioactive waste system controls associated with radwaste shipments and barreling.
These reviews and observations were conducted to verify that facility operations were in conformance with the recuirements established under technical specifications,10 CFR, and administrative procedures.
No items of noncomoliance or deviations were identified.
3.
"nn:11v "a.intenance Observation Station maintenance activities of safety-relatea systems and components listed below were observea anc reviewea to ascertain tnat they were conoucted in accorcance witn approvea procecures, regulatory guices and industry coces and stancards anc in conformance with tecnnical specifications.
The following items were considered during ti.is review: the limiting conditions ror operacion were met while components or systems were removed fron service; approvais were obtained prior to initiating the work; activities were acccmplished using approved procedures and were inspected as appiicable; functional testing and/or calibrations were performed prior to returning ccreponents or systems to service; quality control records '.,ere maintained; activities were accomplished by qualified personnel; parts and caterials used were properly certified; radiological controls sere ualemented; and, fire prevention controis were implemented.
- lork request
- Lere reviesced to determine the status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performance.
Maintenance activities were observed on the following components and activities:
a.
Feed pur.p "B" b.
HPI pump "3" c.
E:0V block vaive electrical lineup d.
Reset of pcwer to flow setpoints Folicwing ccrepletion of maintenance on the above the inspector verified that these systems and components had been returned to service properly.
No items of noncompliar.ce or deviations were identified.
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Monthly Surveillance Observation The inspector observed technical specifications required for surveillance testing on the "B" main feed pump. "B" high pressure injection pump and all RPS channels and verified that testing was performed in accordance with adequate procedures, that ter.t instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management corsennel.
The inscector also witnesseo por'ons of the following test activities:
a.
SP 213.01 (11/7/80) - Operational test of "B" feed pump.
b.
SP 203.02A (11/7/80) - High pressure injection system loop "B".
c.
SP207.03A(11/24/80)- Power operated relief isolation valve.
d.
SP 204.04A (11/13/80) - Reactor building emergency cooling system fans.
Ilo items of noncompliance or deviations were observed.
5.
Follexuo on Regional Requests Curing the month of November,1980, personnel from the NRC Region V office requested infomation from the Resident Inspectors regarding the operation and maintenance of the Rancho Seco power plant.
Inforration was obtained and transmitted to the Region V office concerning: OTSG manway cracking, diesel agastat relay, turbine driven auxiliary feed pumo trip, cctmunications plan, induced flux possibly higher than SAR allows. failure of piping attached to RCS, shutdown board indications, and post accident sampling system status.
In addition followup inspections were conducted on the following unresolved items which were addressed originally in IE Report 50-312/80-15. For convenience and continuity, each of the items are captioned with the unresolved item number used in the referenced report.
In each case the unresolved item is repeated and then the inspector's findings on the item is provided, a.
Unresolved item 50-312/80-15-11, Content of t'onthly Report 10 CFR E0.59(b) states that the licensee shall furnish to the appropriate NRC Regional Office, with a copy to the Director of Inspection and Enforceran, annually or at such shorter intervals as may be specified in the license, a report containing a brief description of such changes, tests, and experiments, including a sumary of the safety evaluation of each.
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-4-The licensee's Technical Specification 6.9.3 requires a monthly recort to be provided which includes a tabulation of the facility changes, texts,andexaerirentsrequiredpursuantto10CFR50.59(b).
The licensee reports of f4y, June, and July,1979, include a tabulation of facility changes and a brief description. The reports, however, did not include a summary of the safety evaluation of each change.
Insucctor's Findings (Ret IE Inspection Report flo. 50-312/80-34, dated December 16,1980, Page 59, Paragraph 10.b.)
Itam E0-34-09 is closed by virtue of this recort in that the ciscussicn wnich follows substantiates the upgrading of the criq1nai unresolveo item to an item of noncompliance.
IG CF2 50.59(b) requires tnat tne licensee annually, or at such stortar intervals as may ce specified in the license, submit a recort to tne tiRC containing a orief description of changes, tests ano experiments maoe pursuant to Inis regulation. The regulation also requires tnat tne report include a summary of the safety evaluation of each.
Tecnnical Speciaification o.9.3 requires a monthly report be srovide.c wnich includes a tabulation of facility changes, tast anc experiments made pursuant to 10 CFR 50.59.
TN2 PA3 Team iuentified that in i;ay, June, and July 1979 the monthly
- nor:s old not include tha summary of the safety evaluation for mch.::a tabulated. The Resident inspector noted also that this infernaticn was not submitted for 1979 on an annual frequence.
The inspector informed the licensee representatives that the Technicai :pecification requirement shortened the reporting time from annually to renthly, but did not change or otherwise modify the content of the report as required by the regulations.
In consideraticn of the above and in accordance with the provisions of 19 CFR 2.201, this item has been categorized as an apparent item of ncncompliance.
(80-35-01)
b.
pnrncolvac Item 50-312/E0-15-20, Precessino of f!onconformance
- Mnorts GiCR's)
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-5-10 CFR 50, Appendix B, Criterion XVI, requires measures be established to assure that nonconforrances are promptly identified and corrected.
CCI 1, Processing of Nonconformance Reports - (NCR's), Section 5.9, required the l'anager, Nuclear Operations to be responsible to insure orcept closure of I!CR's.
The f6110 wing nurber of flRC's were identified as open and awaiting action.
One NRC over 5 years old
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Two NCR's over 4 years old
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Six I:CR's over 3 years old
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Thirteen NCR's over 2 years old
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Sixty NCP.'s over 1 year old
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The Ouality Assurance Department had implemented a tracking system for ?:Ca's and had sent upper management a memo listing all open fiCR's, identifying the action required and the individual responsible.
The QA remo of April,1980, identified 254 NCR's still open.
Reportedly, the individuals ssigned the responsibility to take action maintained their own tickler system to ensure followup.
There appeared to be no overview by managercenc dra no time limits imposed to ensure prcrpt closure of liCR's.
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These ooen NCR's indicateu that adequate neasures to promptly correct noncontorcances were not effective; however, a clear definition of pro:rp; closure is necessary to determine licensee compliance.
Inscactor's Findings Iten 80-34-10 is closed by virtue of this report in that the discussion that folicws substantiates the upgrading of the original unresolved i um to an it s of noncompliance.
According to the status of SIGJD Nonconformance Report document dated November 10, 1980, the status of the NCR's as of November 7, 1930 is as follows:
There are 260 I!CR's open. The oldest open NCR is !!unter S-089 dated 10/25/74. itinety-five of the 260 NCR's are over one year old. These 95 NCR's which are outstanding for various reasons are broken dcun as follows:
One I:CR over six years old
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Two NCR's over five years old
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Cne fiCR over four years old
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Five ilCR's over three years old
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Twenty-eight NCR's over two years old
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Fifty-eight NCR's over one year old
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-6-The oldest (1974) open f;CR Involved the terperature of the concrete around the containment penetration for the "B" Main steam0 line.
On days of the year when the outside temperature reached 90 F, thecencretgte'rperaturearoundthepenetrationwasfoundtorange between 190 F and a naximum nf 207"F. Upon inquiry into the status of this item, the inscector found that no one including the resconsible engineer was certain of flCR status. The licensee immediately investigated the status and initiated action to resolve the matter. The inspector was later informed that during the week
of t!ovember 10, 1980, additional insulation was installed around the penetration.
The licensee stated that an engineering evaluation would be comoleted to assure that no deleterious effects to the concrete had c:: curred over the. years even tnougn sucn was considered unlikely.
(This item was identified in IE Report 50-312/80-34 and N111 be followed to completion by the Resident Inspector.
80-34-C6)
Based on the results of this inspection, the inspectors oetermined that inacequate measures were estaolished to assure that conditions adverse to quality such as nonconformances are promptly corrected.
This is ar apparent item of noncompliance against 10 CFR 50, Aepenuix B, Criterion XVI and Quality Control Instruction 1, Revisicn 7, Section 5.3.
(20-36-02)
6.
Followuo on Items of Nonconoliance and Deviations Follouuo in:pections were conducted on the following identified items of noncompilance and deviations which were originally addressed in IE Inscection Report 50-312/80-15.
For convenience and continuity each of the itec:s is captioned with the item of noncompliance or deviation item nud ar used in the referenced report.
In each case the item of noncompiknce or deviaticn is repeated and then the inspector's findings on the item is provided.
a.
Nviation E. 50-312/80-15-27, Anolicability of ANSI t!45.2.2-1972 to 2ncho seco The licensee comnitted in correspondence of July 22,1976, and September 23, 1976, to the provisions of WASH document 1284 and its attendant documents including Regulatory Guide 1.38, which states in part: "The requirements and guidelines....that are included in ANSI "45.2.2-1972 are generally acceptable and provide an adequate basis for complying with the pertinent quality assurance requirements of Acpendix B to 10 CFR Part 50."
ANSI M.45.2.2-1972, Section 2.7, requires the buyer to classify quality items into one of four levels with respect to protective measures to prevent damage, deterioration, or contamination of the
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items.
Section 6.4.2 specifies the requirements for care of
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items in storage.
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Contrary to the above, the licensee had not classified Class I items into one of the four levels identified in Section 2.7 of AtiSI !!45.2.2.
It was observed that items in storage did not have all covers, caps, plugs or other closures intact.
Two Class 1 valves, stock nur.bers 030342 and 033473, had protective covers partially or cor.pletely removed. Other Class I items were observed with no caps covering threads, welding surfaces uncovered, and flange faces unprotected.
In addition, there were no specific programs for limited-shelf-life items and for preventive maintenance on Class I items.
Insoector Findings By letter dated October 31,1980, !!attimoe to Engelken, the District took exceotion to tne necessity of having a classification system which defines specific levels for equipment as outlined in ANSI
!!45. 2. 2.
The licensee has stated they will perform written ecmunications with NRR and clarify their commitments regarding classification of Class I items.
This item is open pending clarification of the licensee's commitment.
(C0-06-03)
b.
Iten of iloncompliance L, 80-15-28, Followuo Training 10 CFR 73.55 requires the licensee to implement his amended physical security plan no later than February 23,1979.
The licensee's modified amended physical security plan, Section 1.3.3, states in part:
" Followup training v.hich will discuss significant changes and problems related to security will be held for all site
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l personnel at least every 12 months."
Centrary to the above, the last folicwup training was presented to site personnel during the period February 12-14, 1979. The next followup training was scheduled to be conducted May 27-30, 1980, uhich exceeds the 12-month requirement.
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This item is a deficiency.
Insnector Findings The inspector confirmed the information provided in the licensee's response to item L of the IE Notice of Violation dated July 16, 1980.
The inspector attended one of the training lectures as part of his yearly refresher training and he also verified that the referenced tickler file was in effect to assure that followup training is conducted within the prescribed 12-month interval.
This item is closed.
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7.
SALP Insoection Activities i
During the month of Novem.ber,1980, the inspector reviewed the following activities:
a.
Review and Audits
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On November 25, 1980, the inspector sat in on a safety review committee reeting. The insoector verified that provisions of technical specif1ations dealing with membership, review process, frequency, and qualificaticns were met.
The inspector also verified that decisions made were reflected in the meeting minutes and that
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corrective actions prooosed were taken.
b.
Traininn The inspector attenced one of the licensee's operator requalification l
lecture series anc verified that lesson plan objectives were met and that training was in accorcance with the approved operator requalification program scneaule ano cojectives.
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The inspector verified by direct questioning of one new, one
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existing, and one temporary empicyee that acministrative controls ar.c croceoures, radiciogical health and safety, industrial safety, controlled access and security procecures, emergency plan, and quality assurance training were provided as required by the licensee's technical specificaticns; verified by direct questioning of one
craftsnan and one technician that on-the-job training, formal
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tecnnical training commensurate with job classification, and fire fichting training wera provided.
"o items of acncompliance or devitations were identified.
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8.
Folicwuo on Headcuarters' Requests
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a.
Catenary "A" Recuirement Verification i '
By letter dated May 1, 1980, the NRC informed the licensee of the
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staff's evaluation for the Rancho Seco Nuclear Generation Station j
actions taken to satisfy the Category "A" items of UUREG-0578, "TMI-2
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Lessons Learned Task Force Status Report and Short-Term Recommendations."
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The referenced letter requires the Office of Inspection and Enforcement i
to verify rany actions taken by the licensee and to document the
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verificaticns in an appropriate inspection report.
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i Cn "ovember 7,1980, a member of the Regional Office staff performed a l'
special inspection to supplement information contained in the Health
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Physics Appraisal report (No. 50-312/80-32) and the May 1, 1980
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letter. The following is a summary of the inspection activity.
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continuity and tracking purposes each oaragraph and each item inspected is identified with the NUREG-0578 identification number.
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Item 2.1.6.a. - Intearity of Systems Outside Containment Likely to Contain Radioactive Materials IE Report 50-312/80-32 reported that three procedures had not
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been written at the time of the inspection. The integrity of the involved systems were evaluated during the last outage
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and the results reported to flRR. The procedures to be crepared include:
SP 201.21 Leakage Reduction Program (overall controlling procedure)
SP 201.12A Pre-refueling Leakage Identification Procedure
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SP 201.128 Maste Gas System Leak Test Surveillance Procedure SP 204.07 Reactor Building Spray System Leakage Surveillance
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Procedure
These procedures will not require implementation prior to the
next refueling outage.
However, the Plant Superintendent stated that it is the licensee's intent to have the procedures in place before the next refueling outage.
Itan 2.1.3.a. - Imoroved Post-Accident Samplino Caoability It yas determined that the reactor coolant sample valve had been i
instal:2d and tasted. Procedures fcr collection of 'a liquid sample had been prepared and personnel had been trained regarding the contents of the procedure and in the use of the sampling system.
Personnel have been trained in the collection and analysis of a post-accident reactor building atmosphere sample.
_Iram 2.1.3.c. - Improved In-Plant Indine Instrumentation j
Personnel have been trained in collection and analysis of i
in-plant fodine samples using silver ziolite cartridges and G-M detector and count rate meters.
ilo items of noncompliance or deviations were identified.
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b.
Procurement practices In response to a retorandum dated October 1,1980 Bryan to
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Crews, the Senior Resident Inspector examined information on
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procurement standards and requirements applicable to operating
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nucicar olants.
Part of this activity consisted of a procedure review of QAP 10, Receiving Inspection. The inspector noted that QAP 10 does not fully address the situation involved with the l
procurerent of reolacement parts from a nonoualified vendor when i
these parts are dispositioned with flCR's. The inspector stated
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that proper revisior of QAP 10 would alleviate possible future confusion when roolacement aarts are handled in this manner. The licensee
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ac",r.ouladcod the insocctor's statement ano during the exit meeting on Decemcer 1,1980, a licensee representative stated that Sf'.UD uill look into clarifying this item.
This is followuo item j
E0-35-C4
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.he S".UD procurement program is cerined in Ouality Assurance Procedure, QAP 4, Revision 6 Procurement Occument Control.
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l All 5:tD procurement for Rancho Seco is to be accomplished using either standard purchase orders or a SMUD contract.
Quality Assurcnce provisions are supposed to be incorporated into procurement
s ceci fications. These provisions are incorporateo after the supplier submus a written duscription of his quality assurance system and biore any caterial designated Class I is released for purchase i
i order e rd.
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Th cumty assurance sys;;cm su.,mitted by the supplier is reviewed
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hy tne licensee for proper design review; document control; purchase order review, cnd supplier evaluation; inspection; identification and control of catarials, parts, and components; control of special crecesses; calibration of measurement and test equipment; nonconforming raterials; quality assurance records; system auditing; and, others as damed appropriate.
All quality Class I and selected Class I procurement specifications aust be approved by Quality Assurance, fluclear Operations, and Grneration Engineering prior to release for procurement.
Muclear Oparations requisitions operating supplies, spare parts, and stock replacement items when they are adequately identified by a parts j
number and ray be purchased without detailed specifications when obtained as the original manufactured item.
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In the case of a diesel Agastat referenced in IE Report 80-15, Iten D.3, the 7012 PC Agastat was apparently part of the original
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ranufactured item. The inspector noted six 7012 PC Agastats in use in original diesel equiptrent. A review of machinery history files support the position that the 7012 PC Agastats were original
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equipment. The Quality Assurance files which exist on the diesel generators are apparently not specific enough to discuss Agastats, l
tut they discuss the panels in which the Agastats are mounted.
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Therefore, since there is documentation on the control panels, and machinery history shows no significant changes to the panel's makeup, one can ennelude that the 7012 PC Agastat is an adequate i
replacement part for the 2412 PN which is not ourchased as a soare part at Rancho Seco.
When procurement of Class I or selected Class II components, parts, or materials is necessary from an unapproved vendor, Generation Engineering / Nuclear Operations and Ouality Assurance jointly define
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the acccatance recuirements that must be met prior to use at P.ancho Seco. Aoain, in the case of the Aaastat which apparently was purchased as a scare part from an unapproved vendor, a Nonconformance Report (NCR) was written along with an Abnormal Tag and a Work Request.
The NCR was dispositionea by SMUD QA, the Plant Superintendent, and
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the Manager of Generation Engineering. The disposition was an " accept" dispositicn.
This means that the nonconformance was felt to not
l substantially affect safety, interchangeability, service life, or performance; and that the Agastat could be used for its intended
purpose, i
Ciscussions with SMUD engineers who are involved in purchasing electrical ccmponents and who determine whether or not specific seisnic/ environmental qualifications of reordered corrponents are
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necessary indicate that the Regulations in this area are not clear or definitive.
The engineers for Rancho Seco who make these deter-cinations appear to be knowledgeable in the codes and standards which
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apply.
j The inspector determined that the purchasing practices at Rancho Seco
are defined by an adequate program. The program 13 as adequate at the regulations are in the area of procurement of reordered
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i ccoonents. The inspector has found no significant breakdown in the licensee's implementation of their prcgram. The licensee appears aware of scisnic and environmental requirements for items they
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purchase and they do request certification of said requirements on
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original purchases if required.
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In sumary, the possible modification of OAP 10 is the only folicwup I
item on this issue (80-36-03). The original item, 80-15-26, is j
closed, l-9.
Indenendent Inscection Effort Discussions were held between the Resident Inspectors and operations, i
security and maintenance personnel in an attempt to better understand problems they may have which are related to nuclear safety. These discussicns will continue as a standard practice.
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On numerous occasions, during the month of flovember,1980, the Resident Inspectors attended operations status meetings. These reetinos are held by the Operations Supervisor to provide all disciplines onsite t
with an update on the plant status and ongoing raintenance work.
In addition to the above, indeoendent inspection effort was performed
on the following items:
a.
Folicwuo on unresolved items frem the Perfo c.ance Anoraisal Branch inspection (50-312/80-15).
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b.
Public media contacts.
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Construction hazards on site.
10. _ Exit Interview
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The Resident Inspectors met with licensee representatives (denoted in Paragrapn 1) througnout tne montn ano at the conclusion of the inscection
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on Deceroer 1,1980. The scope ano findings or the inspection activities were sumnarized.
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