IR 05000312/1985027

Insp Rept 50-312/85-27 on 850918-1017.No Violations or Deviations Noted.Major Areas Inspected:Qa Program Changes & Followup of LER & Operations Program Open Items

ML20137A672
Person / Time
Site:	Rancho Seco
Issue date:	11/05/1985
From:	Miller L, Myers C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20137A651	List: IR 05000312/1985027 ML20137A646
References
50-312-85-27, NUDOCS 8511260067
Download: ML20137A672 (10)

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U. S. NUCLEAR REGULATORY COMMISSION

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. Report N /85-27-Docket N License N DPR-5'4 Licensee: Sacramento Municipal Utility District P. O. Box 15830 Sacramento,. California 95813 lacility Name: Rancho Seco' Nuclear Generating Station

. Inspection at: Herald, California (Rancho Seco Site) and Sacramento, California (SMUD Headquarters)

Inspection conduct d: Sypt mber 18, 1985 through October 17, 1985

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LI'nspector: (9 -l b $ ~

O/J Myers, { ,je'ct Inspector Date Signed

~ Approved By: i.L -

L. F. Miller /Jf., Chief l I:

Date Signed Reactor ProjMs Section 2 Summary:

Inspection between September 18, 1985 and October 17, 1985 (Report-No. 50-312/85-27)

Areas Inspected: Routine, unannounced inspection by a regionally based inspector in the area of Quality Assurance Program changes; follow-up of LER '

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and operations program open item IE Manual Modules used during this inspection: 35701, 92700, 92701, 92702 and 92703. This' inspection involved 101 hours0.00117 days <br />0.0281 hours <br />1.669974e-4 weeks <br />3.84305e-5 months <br /> onsite and in Sacramento by one regional based inspecto Results: Of the areas inspected, no violations or deviations were identifie .

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DETAILS Persons Contacted

• G. Coward, Nuclear Oper.; ions Department Manager

• J. Field, Technical Support Superintendent

• R. Roehler, Licensing Engineer

• R. Columbo, Regulatory Corpliance Supervisor

• M. Nicherson, Shift lechnical Assistant PRC Member

• N. Brock, I&C Maintenance Superintendent

• J. Jewett, Site QA Supervisor

• H. Canter, QA Operations Surveillance Superintendent The inspector also held discussions with several other members of the licensee staff including members of the maintenance, operations, quality assurance and crafts organization * Attended Exit Meeting on October 2, 198 . Follow-up of IE Bulletins IE Bulletin 84-02: Failures of General Electric Type HFA Relays (IB 84-02: CLOSED)

In their July 12, 1984, response to IEB 84-02, the licensee identified four applications of GE type HFA relays with LEXAN coils at Rancho Seco. The licensee committed to replace the LEXAN coil spools with " Century Series" TEFZEL coils an receipt of the new coil

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spool Through review of the licensee's documentation on NCR-S-3912 and discussions with responsible licensee personnel, the inspector determined that the LEXAN coils had been replaced with TEFZEL coils in each application previou;1y identified. Furthermore, the warehouse stock cards for the relays had been changed to insure that only the TEFZEL coils would be stocked in the futur This item is closed. No violations or deviations were identifie IE Bulletin 84-03: Refueling Cavity Water Seal (IB-84-03: CLOSED)

IE Information Notice 84-93: Potential for Loss of Water from the Refueling Cavity, (IN 84-93: CLOSED)

IE Bulletin 84-03, " Refueling Cavity Water Seal" was issued on August 24, 1984, following a failure of a pneumatic seal at the Haddam Neck plant which resulted in a rapid loss of water from the refueling cavit The inspector reviewed the licensee's bulletin response dated November 27, 1984, which identified that a one piece annular steel plate was utilized at Rancho Seco as a refueling cavity seal. The licensee determined that a gross, active failure of the seal was not

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possible with their design and that minor leakage was well within makeup capabilit The design of the refueling cavity seal was previously reviewed during preparations for the 1985 refueling outage (Inspection Report 85-08).

The inspector also reviewed the licensee's assessment for potential loss of water from the refueling cavity, spent fuel pool and fuel transfer canal in response to Information Notice 84-93, dated December 17, 198 In their review, the licensee identified that a pneumatic seal was utilized in the design of the spent fuel pool stop log, and that during some periods of time, the seal acts as the only barrier between:an empty fuel transfer canal and the spent fuel pool. To enhance the integrity of the seal, the licensee modified the air supply for the seal to hard pipe plant air as the normal air supply, with nitrogen bottles as a backup source to pressurize the seal bladde The licensee's evaluation also addressed the adequacy of emergency procedures, alarms, and water level indications monitoring the spent fuel pool and the refueling cavit This item is closed. No violations or deviations were identifie . Licensee Action on Previous Inspection Follow-up Items Licensed Operator Training (Follow-up Item 84-29-03: CLOSED, Deviation 84-29-02: CLOSED, Follow-up Item 84-29-01: CLOSED, Follow-up Item 84-29-04: CLOSED.)

The inspector reviewed the licensee's training programs for licensed operators, Topical Reports TI-80, Rev. I and T2-80, Rev. 1, and found that previously noted deficiencies had been addressed in the revised programs. A description of the Senior Reactor Operator Training program has been added as Appendix B to both topical report Instructor credentials have been revised to use instructors holding NRC Instructor Certification. Training staff participation in appropriate requalification programs has been added to assure that instructors are cognizant of current operating history problems changes to procedures and administrative limit Requalification requirements for reactor operators enrolled in the Senior Operator Training program have also been added to T2-8 These items are closed. No violations or deviations were identified, ISI Activities (1) ISI-350, Visual Examination of Welds and Surface Conditions (81-10-02: CLOSED)

Previous revisions of ISI-350 had allowed surface conditioning by mechanical processes such as machining or grinding prior to visual examinatio Such preparation could mask surface

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conditio~ns from visual detection. The licensee had committed to delete this reference to surface conditioning in subsequent revisions of ISI-350. The inspector determined that the licensee had deleted the surface conditioning paragraph from the current revision of ISI-350 (Rev. 18, dated February 7, 1985).

This item is closed. No violations or deviations were identifie (2) QA Involvement in ISI Activities (83-11-01: CLOSED)

A licensee QA representative stated that QA involvement has been increased in the auditing of B&W inservice inspections by the assignment of a designated QA engineer to follow ongoing ISI activitie This item is closed. No violations or deviations were identified, Control of Welding Activities (82-02-02: CLOSED, 83-05-01: CLOSED, 84-14-02: CLOSED, 85-02-01:

CLOSED, 84-14-03: CLOSED, UNR 85-02-01: CLOSED)

The inspector reviewed the changes in the licensee's procedures

' controlling welding activities and verified that the licensee's corrective actions were implemented and appeared to be effectiv Current tool room logs were reviewed and found to be complet Training for tool room personnel and welders had been given to emphasize compliance with new procedural requirement In discussions with licensee representatives the inspector determined

- that feedback from crafts personnel of procedural inadequacies to obtain interpretation of requirements had increased, and that additional procedures or corrections were being developed in response to improve the effectiveness of the control The licensee estimated that the improved procedural controls embodied in the Rancho Seco Welding Manual will be issued by December 31, 198 The inspector reviewed QCI-114, " Welder Performance Specifications" and determined that the licensee has implemented an improved program for welder recertification which appeared to accurately document welder proficienc These items are closed. No violations or deviations were identifie .

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E Procurement Documents did not Specify Part 21 Applicability (82-32-01: CLOSED)

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The inspector verified the licensee's corrective actions to revise

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five deficient procurement contracts to specify Part 21 applicability. The inspector sampled several subsequent Class I equipment contracts and found no instances of inadequate specification of Part 21 applicability. A licensee representative stated that additional training had been given to procurement personnel involved in the area of writing. contract requirements to insure that Part 21 applicability was adequately designated in the

, procurement document This item is closed. No violations or deviations'were identifie Storage of Electrical Equipment (82-32-02: CLOSED)

The inspector reviewed the licensee's controls for storage of

Class I electrical components to assure that receipt inspection handling and storage activities were being accomplished in accordance with licensee commitments. AP 605, Rev. 10 described the licensee's general warehousing procedures for Class I items in accordance with ANSI N45.2.2. The inspector determined that special storage conditions / environment were required to be specified on a Receiving Inspection and Data Report (RIDR) per QAP 10, Rev. Furthermore QCI-4, Review and Control of Material Requesitions, Rev. I had been updated for identification of ' shelf life information and storage requirement '

This item is closed. No violations or deviations were identifie CFR 50.59 Review Criteria (82-40-01: CLOSED)

The inspector reviewed QCI-5, Rev. O, Safety Review of-Proposed Facility Changes, QCI-1, Rev. 3, Processing of Nonconforming Reports

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and ECP-1, Rev. 7, Configuration Control Procedure, which described

the. licensee's program for control of changes to the facility as required.by 10 CFR 50.59. In discussions:with licensee personnel, the inspector. determined that the criteria used in the initial screening of ECNs and NCRs consisted of a conservative evaluation in the judgement of regeasible licensee personnel as to whether the change involves a change to the Technical Specifications or an unreviewed safety questio The inspector found that the criteria was further defined in the

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pertinent procedures for subsequent safety analysis and significant hazards consideration performed by cognizant licensing and review engineer This item is closed. No violations or deviations were identifie . t

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g. Control of Maintenance Work (84-14-04: CLOSED)

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The inspector reviewed Rev. 33 to AP 3, " Work Request" which incorporated additional review requirements for changes to work requests. The inspector found the controls adequate to assure that changes to the scope of previously approved work received reviews commensurate with the original work reques This item is closed. No violations or deviations were identifie h. Unauthorized Desiccant (84-14-05: CLOSED, UNR 85-02-02: CLOSED)

The inspector had preiiously requested additional information on the chemical composition of an unauthorized desiccant which he had observed in use during welding ope *ations. The licensee provided information which identified the contact cleaner as Freon TF (Trichlorotrifluoroethane) with a CO 2 Propellant, which was an approved cleaning material meeting MIL-C-81302B requirement Though additional review of the product technical data sheets and conversation with the manufacturer, the licensee determined that the contact cleaner was acceptable for weld joint cleaning, and that it would not leave any residue which would be a harmful contaminate in the wel The inspector reviewed the licensee's general welding procedure M 113, Rev. 24 and found that Freon TF had been added as an approved desiccan This item is closed. No violations or deviations were identifie i. Swagelok Tube Fittings (84-14-07: CLOSED, IN 84-55-01: CLOSED)

The inspector reviewed the licensee's follow-up of installation problems involving swagelok tube fittings highlighted in Information Notice 84-55, Supplement 1. Based on the licensee's corrective actions as described in their previous Special Report 84-10 and observed in previous inspections (84-14), the inspector considered that the licensee had adequately addressed the installation problems note This item is closed. No violations or deviations were identifie j. Quality Assurance Program Review (85-11-01: CLOSED)

The inspector followed up on previously identified concerns regarding changes to the Quality Assurance Program as described in the Rancho Seco Updated Safety Analysis Report (USAR).

1) The inspector reviewed USAR Amendment No. 3 and found that the QA program description had been updated to specifically reference the operations program as being the existing quality assurance organization, program and procedures (QAPs) described in the QA Manual, " Quality Assurance Program for Nuclear Operations."

. . 6 2) The inspector reviewed QAP-3, Rev. I dated May 17, 1985, and found that reference to a QA Class III had been added to maintain consistency with the equipment classifications defined in QAP-3 ) In 1983, pursuant to 10 CFR 50.54(a)(2), the licensee did not submit the current description of the QA program it was implementing for inclusion in the USAR, on the basis that there had been no changes to the description previously accepted by the NRC. As noted in 1) above, the operational QA program was described in the QAPs of the QA Manual. The previously accepted operations QA program was an extension of the construction and preoperational QA program described in Appendix 1B of the FSA ) The inspector reviewed a final draft revision of QAP-1 and determined that the licensee is incorporating a formal 10 CFR 50.54(a)(3) review of changes to QAPs to determine whether the change constitutes a reduction in the program commitments. The inspector noted that the previous lack of a formal 50.54(a)(3)

review was also identified in a QA Audit No. 723 dated July 31, 1985. In addition, a licensee representative stated that the MSRC charter will be changed to incorporate review of QAP changes for 50.54(a)(3) reportability. This item will be followed up in a future inspectio (85-27-01: OPEN)

5) Revision 1 to QAP-27, " Corrective Action" dated August 10, 1984, referenced a QCI-7 " Corrective Action" which was to define the QA controls established for corrective actions. The inspector had previously noted that QCI-7 had been cancelled and never issued. The licensee had indicated that this discrepancy would be resolved in an upcoming revision of the QA The inspector found that QAP-27 had still not been revised since Revision 1 of it and continued to reference QCI-7,-

" Corrective Action." A different QCI-7, " Training and Qualification Requirements for QC Inspector" was issued July 30, 1985, to establish the training and qualification requirements for QC inspector This item will remain open pending revision of QAP-27 to correct this discrepancy. (85-27-02: OPEN)

No violations or deviations were identified, k. Seismic Monitoring Instrumentation (DS-80-01: CLOSED, UNR 80-03-04:'

CLOSED)

This item remained open from previous inspections pending full operability of the seismic event monitoring system. Through review of ECN A-2982, which installed the new seismic instrumentation, and discussions with cognizant licensee personnel, the inspector

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determined that the system had been turned over to operations and has been in use since August 198 The inspector observed the installation of one of the eleven triaxial' accelerometers and verified the operational status of the recording cabinet in the control room. The magnetic tape recording instrumentation was supplemented with a portable strip chart recording unit used for data analysis. Previous problems with availability of the strip chart recorders have been resolved and the-system is fully operational. A licensee representative stated that no seismic events have been recorded since the new system was inaugurate The inspector reviewed the licensee's procedure C.30 Rev. 5,

" Earthquake", dated April 3, 1985, and verified that the procedure had been updated to reflect the new seismic monitoring system and that adequate instructions were included for operator actions to confirm spurious trip The inspector noted that the USAR had not been updated to reflect the new seismic monitoring system even through the system had been operational since 198 CFR 50.71.e.4 requies that the updated USAR (USAR) shall reflect all changes up to a maximum of six months prior to the date of filin Since ECN A-2982 was still open pending removal of some of the old system components, the licensee stated that the facility modification had not been submitted for update in the FSA At the exit meeting, the inspector pointed out that changes made to the facility or procedures described in the USAR should be included in a subsequent revision of the USAR within 18 months of the operational implementation of the chang The licensee acknowledged that lengthy delays in closing some ECN's after turnover to operations prevents timely updating of the USA The licensee committed to develop plans by December 1, 1985, for changing their procedures to improve processing of changes for USAR updatin This item will b'e addressed in a future inspectio (85-27-03:

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1. PRC Review of NRC Inspection Reports (UNR 80-13-03: CLOSED)

The inspector reviewed the charter for the PRC dated December 28, 1984, and determined that the licensee had revised the charter to specifically include review of NRC inspection reports to determine if any issues were of concern regarding plant safet In discussions with licensee representatives, the inspector determined that the PRC review focused almost exclusively on violations cited in the NRC inspection reports, while other concerns raised by the inspection were not always addresse _

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At'theexitmeeting,akicenseerepresentativestatedthatall issues identified as open items in NRC inspection reports would be i 4 <

tracked on the coordinated commitment list to insure appropriate review of all issues identified.

.This item is closed. No violations or deviations were identifie Part 21 - Brand Rex Defective Cable (82-01-21: CLOSED)

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The inspector reviewed the licensee's submittal dated April 9, 1985, which described the licensee's review of the 10 CFR 21 deficiency previously discovered with Brand Rex cable. An improper splice had been discovered during termination of a control cable which lead the licensee to suspect additional potential defects due to improper

manufacturing. The' licensee determined that the suspect cable had not been used in Class 1 applications at Rancho Seco. Furthermore, the licensee identified that the manufacturer.had procedures for splice marking and removal, and that a training program in splice shorting and marking had been implemented. The licensee concluded that the defective splice observed was an isolated incident.

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_ Based on the licensee's review and the corrective actions taken by t

the manufacturer, no further follow-up appears to be require This item is closed. No violations or deviations were identified.

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' Main Steam Line Break (MSLB) Pressure Switches (LER 80-44: CLOSED, LER 84-20: OPEN, LER 84-18: OPEN)

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The inspector reviewed ECN-A-4981, which relocated and replaced the

, MSLB pressure switches. The inspector observed the new installation outside the reactor building in the . tank farm. The inspector noted

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that the new installation changed the location of the pressure taps

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from the four individual steam generator headers inside the reactor building to the two main steam headers. A licensee representative stated that the MSLB instrumentation will be upgraded to Class I as part of the EFIC system to be installed during the Cycle 9 outage.

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Follow-up of LER 80-44 is closed. LER 84-20 and 84 '2 will remain open pending submittal of a follow-up LER addressic< the results of ICS trouble shooting during the 1985. refueling outag ,

No violations or deviations were identified.

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, . Unsecured Personnel Hatch (LER 85-12: OPEN)

p In_ light of four previously reported events, the inspector discussed the.recent failure of the Reactor Building personnel hatch interlock

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system with licensee representatives in the Incident Analysis Group '

who were conducting a root cause analysis of this repeat proble Of the four previc urrences, one had teen attributed to L personnel error, while three had been_ caused by mechanical problem l Initial evaluations indicated that the failure of the interlock

system appears tc,be a combined design and personnel problem

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resulting in the door rebounding from its seal when slammed. The licensee is investigating door snubbers used at other plants to prevent rebounding of the doo A follow-up LER will be submitted by October 31, 198 No violations or deviations were identifie Automatic PORV Isolation (GZ-80-03: CLOSED)

This TMI Action. Item was not required for Rancho Seco, based on a NRC letter to SMUD dated October 26, 1983. The Division of I

Licensing found that the requirements of NUREG-0737, Item II.K. were met by the existing PORV safety valve and reactor high pressure trip setpoints; consequently, an automatic PORV isolation system was not required to be-installed at Rancho Sec This item is closed. No violations or deviations were identifie . Exit Meeting The inspector met with licensee representatives on October 2, 1985, and summarized the scope and findings of the inspection. The licensee acknowledged the inspector's finding ,

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