IR 05000312/1987030
| ML20237B036 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/01/1987 |
| From: | Crews J, Dangelo A, Miller L, Myers C, Perez G, Wagner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20237B005 | List: |
| References | |
| 50-312-87-30, IEIN-87-008, IEIN-87-8, NUDOCS 8712150423 | |
| Download: ML20237B036 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION REG' ION V Report No:
50-312/87-30 Docket No.
50-312 License No. DPR-54 Licensee:
Sacramento Municipal Utility District P. O. Box 15830 i
Sacramento, California 95813 Facility Name:
Rancho Seco Unit 1 Inspection at:
Herald, California (Rancho Seco Site)
Inspection conduct d Inspectors:
//'3007-AM D'Ange Se ior Resident Inspector Date Signed-
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// 70d7 Cb/ J Myers sident Inspector Date Signed
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//-30-Q G."
P z Resident Inspector Date Signed
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Date Signed lE *l -$7
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~ Tor ' actor Engineer n
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/2 -/-M 7 a ner, onal Inspector Date. Signed Approved By:
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LV F. Miller, Chief, Reactor Projects Sectioh'II Date Signed i
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Summary:
Inspection between September 12 and October 23,'1987-(Report 50-312/87-30)
Areas Inspected:
This routine inspection by'the Resident Inspectors and two regional based individuals, involved the areas.of operational' safety
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verification, quality assurance program review, design changes and
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j modifications, maintenance,. surveillance,.and followup items.
During-this.
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inspection, Inspection Procedures 25573, 30702, 30703, 35701,137702, 62700, 62702, 62703, 71707, 72701,.92701, 93702 and 94702 were used.
Results: In the areas inspected, no violations or. deviations were identified.
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8712150423 871201
PDR ADOCK 05000312 G
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1.
Persons Contacted l
a.
Licensee Personnel G. C. Andognini, Chief Executive Officer, Nuclear J. Firlit, Assistant General Manager, Nuclear Power Production G. Coward, AGM, Technical and Administrative Services
- D. Keuter, Director, Nuclear Operations and Maintenance J. McColligan, Director, Plant Support D. Brock, Acting Nuclear Maintenance Manager-
- B. Croley, Director, Technical Services G. Cranston, Nuclear. Engineering Manager W. Kemper, Nuclear Operations Manager
- J. Shetler, Director, System Review and Test Program
- K. Meyer, Licensing Manager T. T<cker, Nuclear Operations Superintendent J. Grimes, Nuclear Mechanical Maintenance Superintendent L. Fossom, Deputy Implementation Manager R. Colombo, Regulatory Compliance Superintendent J. Field, Plant Support Engineering Manager
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L. Conklin, Technical Assistant, AGM
- S. Crunk, Technical Assistant, AGM l
F. Kellie, Radiation Protection Superintendent
- J. Vinquist, Director, Nuclear Quality
- C. Aycock, Engineering Restart Manager B. Daniels, Supervisor, Electrical Engineering J. Irwin, Supervisor, I&C Maintenance R. Cherba, Quality Engineering Supervisor T. Shewski, Quality Engineer -
- G. Legner, Licensing Engineer
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- H. Story, Supervisor, Health Physics Services t
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- D. Schumann, Licensing l
l D. Ross, Security l
D. K. Satpathy, Engineering Group Leader - NSSS D. P. Fadel, Systems Design Engineer B. E. Spencer, Nuclear Engineering Specialist (Operations)
B. L. Aley, System Design Engineer Other licensee employees contacted included technicians, operators, mechanics, security and office personnel.
- Attended the Exit Meeting on October 26, 1987.
2.
Operational Safety Verification The inspectors reviewed control. room operations which included access control, staffing, observation of decay heat removal system alignment, and review of control room logs.
Discussions with the shift supervisors and operators indicated understanding by these personnel of the reasons for annunciator indications, abnormal plant conditions and maintenance
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work in progress.
The inspectors also verified, by observation of valve and switch position indications, that emergency systems were properly aligned for the cold shutdown condition of the facility.
Tours of the auxiliary, reactor, and turbine buildings, including exterior areas, were made to assess equipment conditions and plant conditions.
Also the tours were made to assess the effectiveness of radiological controls and adherence to regulatory requirements.
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inspectors also observed plant housekeeping and cleanliness, looked for potential fire and safety hazards, and observed security and safeguards practices.
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No violations or deviations were identified.
3.
Monthly Surveillance Observation / System Review and Test Program (SRTP)
a.
Several tests were observed and reviewd to ascertain that they were l
conducted properly.
The following items were considered during this review:
Testing was in accordance with adequate procedures; test instrumentation was calibrated; limiting conditions for operation were met; removal and l
restoration of the affected components were accomplished; test results conformed with TS and procedure requirements and were reviewed by personnel other than the individual directing the test; the reactor operator, technician or engineer performing the test recorded the data and the data were in agreement with observations made by the inspector, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.
l Inspection and observations were conducted on test procedures that were being performed and maintenance activities being conducted in support of the restart effort.
b.
The emergency feedwater initiation control system (EFIC) Cold Functional Test (STP-666) was partially performed during this reporting period.
Testing was done in accordance with the surveillance test procedure.
Additional post maintenance testing was performed on a modification work request.
During the installation of noise suppression capacitors, three EFIC Initiate Modules were damaged.
This modification was being controlled through the use of a Field Problem Report.(FPR).
The addition of capp.citors to the modules constituted a design change to the system, however, the licensee chose to use a FPR to start the modification.
The inspector's concern was that the licensee's FPR system permitted a modification to be made without being checked in the design verification process.
The modification undertaken by the licensee had not correctly evaluated the applied voltage to the module and subsequently led to an over-voltage condition and failed the module.
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e The inspector noted that the FPR process did not require a design review similar to that used in engineering work performed in an Engineering Change Notice (ECN),
The engineering performed on the FPR had not been verified.
The licensee's administrative system to control modification work done on an ECN would have had the i
verification performed prior to the EFIC system turnover to the l
operations department, however, the EFIC system testing could pecceed without design verification being performed on the FPR.
The design which had been initiated on the FPR did not consider that an over-voltage condition would be created whenever a module was removed and power to the module wasn't removed.
This feature of the modified design would not have resulted if the modification had been made to the module itself instead of installing the capacitors on the terminal strips where field cables terminate in the EFIC cabinets.
The inspector concluded that design verification prior to concluding this modification could have discovered this oversight.
This entire design existed on an open ECN with the formal design l
verification review of the modification to be completed at a later date.
Since the EFIC system was not yet operable and the ECN was still open; and the design review would occur prior to the system being declared operable, no violation existed.
However, the licensee's system which permitted design work be done on an FPR l
without design review completed prior to ener
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concern related to maintaining safety system w grity.
The licensee's System Review and. Test organization has committed to
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review the above process and establish measures to prevent
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recurrence.
The inspector will review the licensee's actions during a future inspection.
(0 pen item 50-312/87-30-01).
c.
The inspector monitored the cleaning process the licensee had established for the cleanup of the Blue Ribbon Connectors that were previously contaminated by a cleaning fluid.
During the flushing of one of the cabinet connectors, it was determined, through analysis, that the Freon was deteriorating the plastic tubing being used to transport the flushing fluid.
This provided a possible new source
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of contamination to the connectors.
The inspector questioned the l
technical review of this process and the use of this particular j
plastic tubing for the flushing.
As corrective action to this
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finding, the licensee changed the contaminated tubing and resumed flushing.
A stop work order was issued by. Quality Management after the inspector requested to see the licensee's documentation of their review of this cleaning process and the documentation of review by-the Plant Review Committee (PRC) could not be established.
The stop work order was lifted after the required documentation was located I
and sent to Site Document Control (SDS) for proper filing and control.
Licensee management committed to review documentation of procedures which receive PRC review and approval and ensure that applicable documents are controlled by SD.
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d.
The inspector reviewed the System Functional Test Program documents l
to determine if the functions and testing requirements identified in
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the licensee's System Status Reports were also identified in these test outlines and special test procedures.
All of the systems were reviewed and the following inconsistencies were identified:
1.
480V Electrical Distribution System:
This system has a function to provide isolation switches for isolating control room circuitry, on 3A and 3A2 switchgear, in accordance with 10 CFR 50, Appendix R requirements.
The functional test overview for this system does not indicate that this isolation function is to be tested or verified.
The SSR requires this function be tested.
2.
Nuclear Service Cooling Water:
This system has specific functions including that the pumps start on a safety features actuation signal and the system be capable of containing primary coolant in the event of leakage into the system.
The functional test overview for this system does not indicate that these two particular functions are to be tested or
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verified as required by the SSR.
l The review performed by the inspector of the test program documents identified that these three functions identified in the System Status Reports (SSRs) were not documented in the test overview.
The concern relates to the incorporation of identified functions for systems into system test procedures where those functions are tested or verified.
Previously, all of the functior.s identified in the SSRs were committed by the licensee to be verified either by testing, analysis, or a combination of both.
The licensee committed during this inspection to review the identified omissions and will demonstrate that all functions as stated in each system's SSR will be verified by test, surveillance procedure, or analysis.
This item will remain open pending inspection of the licensee's review.
(50-312/87-30-02).
No violations or deviations were identified.
l 4.
Monthly Maintenance Observation l
l Maintenance activities for the systems and components listed below were observed and reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, industry codes or standards, and the Technical Specifications.
The following items were considered during this review:
the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the l
work; activities were accomplished using approved pror.edures and were l
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inspected as applicable; functional testing or calibration was performed-prior to returning components or systems to service; activities were-accomplished by qualified personnel; radiological controls were implemented; and fire prevention controls were implemented.
Potential Misoperation of Motor-0perated Valves.
During followup of a previous observation regarding restoration of motor-operated valves from manual operation, the inspector observed that short stroke automatic closure of a declutched M0V could produce valve stem thrust loads in excess of the torque switch setting.
When a closed MOV is declutched to manually operate the valve, the spring pack on certain models of Limitorque operators can spring back, resulting in the torque switch closing. With the torque switch closed, the operator control circuit is armed to close if actuated by manual push button or safety features actuation circuitry, i
During operation of a training MOV, the inspector observed the M0 VATS signature produced when a closed valve was declutched in the presence of a close actuation signal. The operator automatically energized when the
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torque switch closed, rapidly exerted a closing thrust and deenergized after opening the torque switch. The insnector observed that the closing thrust load was approximately 30% greater than the normal stroke closing load. Repeating the declutching operation from this condition resulted in a further increase of 10% in the closing thrust, i
The inspector noted that push button actuation to close an already closed l
MOV would produce a similar condition of short stroking with potential
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overthrusting of the valve stem. Under short stroke operation the torque switch did not appear to limit the resultant valve stem thrust as it did under normal full stroke operation.
The inspecto-identified that this operation produced a condition similar to the " hammering effect" previously identified in Information Notice IEN 85-20.
The inspector identified his observations to licensee representatives and expressed concern that misoperation of MOVs could result in unr%tected overloading of the valve stem.
The inspector's concerns resulted from previous discussions with licensee representatives in which short stroke closing of MOVs had been referred to as an occasional practice.
At the exit meeting, the inspector discussed his concern that l-misoperation could possibly result in undetected damage to the MOVs. The licensee acknowledged the inspector's concern and committed to investigate to determine whether short stroking operation of MOVs was a common practice and whether operations and maintenance personnel were aware of this potential condition (Followup Item 50-312/87-30-04).
No violations or deviations were identified.
Preventative Maintenance Proaram Review
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I The inspector reviewed the licensee's program for performing preventive maintenance (PM) on safety related equipment.
The inspector found that the licensee had established a PM program group within maintenance which was assigned to the upgrading of PM tasks within all maintenance disciplines.
This effort had been primari.ly centered on categorizing all the plant equipment within 23 categories of PM classifications and developing PM tasks based on vendor recommended maintenance.
The group consisted of 6 contractors and 4 licensee personnel at the time.
Licensee representatives estimated that 164 PM tasks were currently backlogged and that 500 Category 1 tasks would be performed.by restart, These PM tasks include newly generated tasks, previously performed tasks
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l which were again due and some long term layup tasks.
The inspector verified that all of the valves identified by operations as i
having operational significance following the December 26, 1985 event had
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been included within the PM program.
However, not all the PM tasks had yet been written.
For example, valve FWS-063 was identified as a Category 1 valve in the PM program, however, no PM task had yet been generated for the valve.
(FWS-063 is the manual maintenance valve which could not be operated during the December 26th event due to a lack of I
lubrication).
The licensee was working toward a commitment date of l
October 25 for identifying all PM tasks.
A substantial number of I
maintenance procedures had yet to be written to support the identified i
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Based on his review, the inspector found that the PM program appeared to adequately categorize and establish baseline PM tasks for the plant equipment.
Furthermore, the program appeared to incorporate adequate trend analysis using predictive maintenance techniques.
j In discussions with licensee representatives, the inspector identified several concerns regarding the PM program:
1.
The inspector noted the PM task frequency was designated to coincide with surveillance testing (SP), that the PM task was to be performed prior to the SP and that the predictive maintenance activities'were-being performed during the SP.
The inspector was concerned that preconditioning the equipment by performing the PM task may preclude identification of equipment degradation in the SP which supplies trending data.
The licensee indicated that the scheduling was designed to minimize repeated operation of the equipment.
The licensee indicated that they would review incorporating "as found" data in the PM task to capture equipment degradation below baseline performance.
2.
The inspector found that post-maintenance testing (PMT) was
currently specified by the Planning Department, however, no specific I
PMT procedure existed.
A licensee representative indicated that an l
INP0 good practice would be implemented as a PMT procedure by the l
end of Octobe.
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The review of the maintenance PM program is complete, however'one open item will remain pending reinspection of followup action by the licensee on the two above concerns (50-312/87-30-03).
No violations or deviations were identified.
5.
Quality Assurance (QA) Program Annual Review
The Rancho Seco QA Program is described in Appendix 128 of the Updated Safety Analysis Report (USAR) entitled, " Nuclear Quality Assurance Program Manual" or NQAPM.
Revision 1 to the NQAPM was submitted to NRC Region V on May 1, 1C87 and, due to the magnitude of changes involved, is currently in the review and approval cycle.
The significance of the changes submitted and the manner in which they are to be implemented were discussed with the licensee in the Region V of fice.
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Changes to the following implementing procedures were reviewed by the I
inspector and found to be in conformance with the QA program described in the USAR and applicable standards and regulatory guides:
Procedure Title Revision Effective Date QAP No. 2 Design Control
6/18/87 QAP No. 17 Nonconforming Material
3/16/87 I
Control QAP No. 19 Audits
1/9/87 QAP No. 27 Corrective Action
3/27/87 QAIP No. 1 Quality Assurance
11/17/86 Audit Procedure QAIP No. 2 Quality Assurance
6/12/87 Surveillance Program QAIP No. 14 Qualification and
3/19/87
Certification of Quality l
Department Personnel
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Performing Audits and Surveillance QAIP No. 18 Inspector Training and
7/31/87 Qualification l
Requirements l
The inspector _ also reviewed procedure RSAP-0902 entitled, " Rancho Seco Regulatory Correspondence and Commitment Control".
This procedure, i
currently under review, includes provisions for informing key supervisory personnel of new and existing regulatory requirements.
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letters, reports, notices, bulletins, etc., received from, or sent to, I
regulatory agencies.
The inspector reviewed the qualifications of the Acting Director of Quality Assurance.
The review revealed the
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qualifications to meet or exceed the minimum requirements recommended in
The licensee has made a number of organizational changes over the past few months.
These changes were sent to the NRC for review and approval in letter number GCA 87-034 on September 16, 1987.
The inspector observed that the licensee's organization was consistent with this submittal.
No violations or deviations were identified.
6.
Long Range Scope List (LRSL)
The purpose of this inspection was to review the licensee's Long Range Scope List (LRSL) for acceptable prioritization of the list's post-restart work items.
The inspector's criteria for inspection of a post-restart item was whether all regulatory requirements related to the item and or system would be met even if the item was not completed prior to restart.
l The inspector reviewed the October 13, 1987 LRSL submitted to the NRC.
j The list contained 1410 items.
The items on the list were categorized by l
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plant system and by management issues.
Each item had a unique item identifier, and statements for resolution, description, and comments.
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the comment section a justification statement for delaying the activity l
until after restart was made.
l The process for justifing the LRSL items was controlled by Rancho Seco l
Administrative Procedure, RSAP-0215.
Thic process used a flow chart analysis to aid in identifying items tha' should be completed prior to restart.
The justification statements, therefore, listed on the LRSL gave specific comments or used a statement "No justification required per RSAP-0215." This comment was a concern to the inspector because it presented insufficient information for the inspector to determine the acceptability of the item being placed on the LRSL.
The inspector addressed this concern during discussions with the licensee on the individual items.
This will be discussed later in this section.
The inspector randomly selected a sample of 203 items (14%) from the LRSL.
From that sample the inspector had questions on the justification statements of 72 items.
The inspector arranged for meetings with key licensee personnel to discuss each item.
Members of Region V management attended these meetings.
After a series of meetings the inspector resolved all NRC questions on the items except for two:
1.
MGT/EN 1224, NRC Inspectors were unable to conclude that the component files adequately document qualification of two types l
of Rockbestos (CERRO) Cable, Firewall SR and Firewall III, and 2.
MGT/MM 2030, The Management appraisal report contained specific recommendations for District implementation (Process of co-mingling Class I, II, and Commercial Grade Items).
These two items will be inspected further in a future inspection.
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NRC resolution of questions on the justifications could be categorized as follows:
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The inspectors agreed with the justification after further explanation of the item by the licensee and presentation of more documented evidence.
2.
The item had been already upgraded to the Restart Scope List.
3.
The item will be contained on other lists to be generated and justified, such as NRC Open Items, Wors Requests, and NonConformance Reports.
The NRC will review these lists _when issued by the licensee.
Therefore, based on the sample selected and reviewed, the licensee's Long Range Scope List appeared to contain activities that were reasonable to delay until after restart.
However, the list as submitted on October 13, 1987 was not a stand alone document and much effort was
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required to resolve the items of concern.
Also, items had been deleted from the LRSL to be put on other lists.
These other lists will be reviewed by the NRC and should contain appropriate justification for post-restart items.
Additionally, the LRSL is a growing document and it is expected that justifications will be provided for each item that is placed on the list.
Licer"ee representatives acknowledged these concerns.
No violations or deviations were identified.
7.
Design Change and Modifications Program / Development of Design Basis Documents As a part of the licensee's Engineering Action Plan, a program is being implemented to develop Design Basis Documents (DBD) for selected systems of the Rancho Seco plant.
The program is long range in nature, extending i
over a multi year period beyond plant restart.
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The objective of this program is to consolidate, into a single document for each selected plant system, current and complete information relating to the design basis of the system.
The documents are to include system functional descriptions and requirements (at the system and component levels) derived from analyses, calculations, license commitments, etc, For each design basis parameter or functional requirement specified, the source document (analysis, calculation, code or standard,.etc.) is to be identified by specific reference.
The status of this program was reviewed during the period of the current inspection.
Facility records were examined and discussions were held with licensee personnel involved in the program, from which the following information and findings resulted.
l The licensee's current plan, as reflected in the Engineering Action Plan,
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is to prepare " working drafts" of design basis documents, entitled System Description and Functional Requirements, for fourteen plant systems prior to plant restart.
Four such documents had been issued (as Revision A to DBD's) at the time of the current inspection.
The
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l licensee's project schedule calls for the preparation and issuance of l
similar working drafts for at least 10 additional systems by early l
January 1988.
The licensee's initial approach to the development of DBD's was to contract with the NSSS Vendor (B&W) and A-E (Bechtel) to prepare draft DBD's for selected systems within their original design scope.
It is also the current plan that DBD's for a number of plant systems will be prepared by system design engineers within SMUD's Nuclear Engineering l
Department.
In this regard, according to licensee representatives, l
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calculations / analysis results and other design basis source documents are j
to be provided to the licensee by design contractors for use by the
Nuclear Engineering Department staff in preparing DBD's.
The current System Functional Description and Requirements. documents are not intended to be issued as controlled documents for use outside the Nuclear Engineering Department until they have undergone extensive review and revision to insure their accuracy and completeness, according to licensee representatives.
Following such review and revision, they are to be issued as Revision "0" DBD's.
A part of this review, according to the Nuclear Engineering. Department Manager, will be an assessment of the impact on the system design basis of the results of other Engineering Action Plan programs such as the Expanded Augmented System Review and Test Program, Calculation Reviews, B&W System Reviews, and the SMUD QA Vertical Slice Audits.
The System Description and Functional Requirements document for the j
Auxiliary Feedwater System, issued as Revision "A" on September 9, 1987, j
was examined by the NRC inspector in an effort to assess the content and completeness of the document in a working draft status.
This review I
revealed the need for substantial revision to the document prior to its issuance and use as a source of complete and accurate design basis information for the Auxiliary Feedwater System.
The need for such l
revision was identified in an Appendix 0 to the document, entitled
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i Unresolved Issues.
This appendix included numerous comments by the I
assigned SMUD system design engineer and-others pointing out areas of i
incompleteness and needed enhancements to the document.
A particularly l
significant comment was that the system design parameters section of the
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document needs to be revised to be consistent with the latest revision to I
a Proposed Amendment (No. 152) to the plant's technical specifications.
l This amendment covers the installation and operation of a newly installed Emergency Feedwater Initiation and Control (EFIC;' system, and provides, for example, the technical basis for a' reduction in the minimum auxiliary feedwater flow rate from that presently specified (760 gpin) to 475 gpm.
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Licensee representatives stated that they recognized the need to revise j
the design basis to reflect the latest revision to Proposed Amendment No.
i 152, as indicated in Appendix D to the document.
They stated, however,
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that a decision had been made not to complete such revisions until the proposed amendment had been approved by the NRC.
A general observation by the NRC inspector was that the format of the document made it difficult to determine the applicability of specific references identified within the text of the document.
This difficulty I
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I was due to the fact that there were three separate lists of reference documents, without a unique reference numbering system to clearly indicate to which reference list a numbered reference within the text of the document applied.
Licensee representatives acknowledged the need to (
correct this format discrepancy.
Based upon the fact that significant revisions have yet to be made to the I
current " working draft" of the DBD for the Auxiliary Feedwater System, l
the NRC inspector concluded that the document had limited usefulness as a i
source of complete and accurate design basis information.
Licensee l
representatives concurred in this conclusion, and stated that the
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document was not to be utilized as such in the preparation of system operating and test procedures, operator training or other such purposes, pending the completion of needed revisions identified in Appendix D of the document.
No violations or deviations were identified.
8.
Allegation Followup
Allegations (87-A-0032 and 87-A-0040))
Characterization Improper administrative review and approval of surveillance test procedures was alleged.
Implied Significance The Technical Specifications (TS) define the. required review of various procedures.
Therefore, failure to review and approve a procedure, as required, could result in the use of unqualified procedures for testing, and improper conclusions regarding the operability of equipment.
Assessment of Safety Significance The licensee's Technical Specifications require that for surveillance and test activities of safety related equipment, each procedure and change thereto shall be reviewed by the Plant Superintendent prior to implementation.
The allegation was that a special test procedure was apparently approved without the appropriate signatures.
The inspector found that the special test procedure had been approved and signed by the appropriate management per the Technical Specifications.
However, the licensee had additional administrative procedures ~that addressed authorized alternate signatures for procedures.
In the case of the special test procedure above, the person who signed was not'
authorized to do so by the administrative procedure.
As a result of this allegation, the licensee revised their seministrative-procedures to address the organization structure set up at the time, and
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I to allow for additional qualified people to sign a procedure as part of
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N the review and approval process.
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Staff Position Since the Technical Specifications were not violated during the approval process for the special test procedure and the licensee has revised their l
controlling procedures for procedure approval and review, the inspector did not find any impact on safety for this allegation.
However, since the administrative procedure was not being followed completely, the
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allegation was substantiated.
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Action l
No further action planned.
No violations or deviations were identified.
9.
NRC Open Items Information Notices
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IN 87-08, (CLOSED) " Degraded Motor Leads in Limitorque DC Motor Operators"
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i This Information Notice was provided to alert licensees of potentially
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defective DC motors installed in Limitorque motor operators.
These Peerless-Winsmith motors manufactured between December 1984 and December i
1985 are susceptible to insulation degradation and subsequent short l
circuit failure.
The Information Notice also provided serial number l
information for the motors which are susceptible to this degradation.
In response to this notice, the licensee walked down their Limitorque Peerless DC motors.
There were.;o motors found with the serial number designation identified in the Information Notice.
The licensee will also review all purchase requests to exclude any future problem.
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actions should preclude any problems with these defective motors.
Based on the licensee's actions, this Information Notice is closed.
l Enforcement Items Violation 87-13-02, (CLOSED) " Cleanliness Procedure was not Followed J
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j for a Class I Work Request" l
This severity level V violation was issued due to a failure to maintain work area cleanliness while performing maintenance on the Borated Water l
System (BWS).
The Work Request (#125548) was written without providing for an inspection and the authorized inspector's signature on the work
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request.
The district admitted that the violation occurred.
Their corrective actions included the issuance and implementation of a new procedure, MAP-0011, " Foreign Material Exclusion".
This new procedure was issued July 2, 1987 and provides new instructions on foreign material exclusion.
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This new procedure has a step specifically requiring that the work area i
and replacement parts are clean. This is to be verified as appropriate, by the maintenance engineer's signature.
Based on the licensee's actions, this item is closed.
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Violation 87-06-07 (CLOSED) " Failure to Submit LERs per L
10 CFR 50.73 for Various Incidents" i
The violation involved six apparent incidents of the licensee's failure tc submit an LER (Licensee Event Report) for events which apparently re(uired a LER per 10 CFR 50.73. The licensee responded to the violation by letter dated May 7, 1987 in a timely manner. The licensee admitted that the violation occurred as stated, except for one item.
The licensee
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identified further information dealing with item (b) in the violation, j
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which involved an apparent lack of a liquid sample being taken as i
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required by Technical Specification.
The licensee was able to identify the information which showed that the licensee was in conformance with the Technical Specification. Therefore, the inspector concurred with the licensee's analysis and that this portion, item (b) is no longer considered part of the violation.
The licensee's corrective action included the revision of Administrative Procedure, AP-22, " Occurrence Description Reports (0DRs) Reporting and
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Resolution", to enhance the process of identifying and dispositioning
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ODRs in a timely manner.
In addition, the licensee had committed to l
issue LERs covering the items in the violation that had not been i
appropriately reported. The LERs that have been submitted are 86-23, l
l 85-16 Rev. 3, 85-26, 85-28, and 85-27.
The inspector had no further l
l questions, and concluded that the licensee's response was adequate.
This l
item is closed. 87-06-07(CLOSED).
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l-Followup Items l
Inspection Report 86-07, Item RV-MA-1, " Implement a Valve Preventive Maintenance Program" (CLOSED)
i It was evident from events during the December 26, 1985 transient that there was a need for an improved (PM) preventive maintenance program for valves. Various NRC inspections document the licensee's committment to develop a PM program to address all valves in the plant.
The licensee has issued and begun to ' implement their PM program outlined-in procedure MAP-0009, " Preventive Maintenance Program."
The inspector reviewed the criteria for the classification of valves in the PM program. The licensee has committed to perform or have current the PM tasks for " Category 1" valves.
It appears that the licensee's overriding requirement for selection of Category 1 valves was valves that were "... required for a safe controlled shutdown window, placing of the plant in cold shutdown and maintaining it there, and also to mitigate the consequences of a radiological release". The inspector sampled some safety related valves and found they had been properly characterized as Category 1 valves.
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In addition, the licensee categorized the remaining population of valves and is presently developing a schedule for the: implementation of'their respective PM task. Therefore, this' item is considered closed due to the performance of PM tasks on Catergory 1 valves prior to restart and the development of a PM program.
RV-MA-1 (CLOSED).
Followup-Item 87-17-02, (CLOSED) Program to Identify and Calibrate Instrumentation Needed for Abnormal Operations."
In previous inspection reports, the inspector had identified a concern that-there was no formal program to identify and calibrate instruments I
which operators might rely on during abnormal operations.
"l The licensee provided the inspector with their Preventive Maintenance _
Program, described in procedure MAP-0003, Revision 1, which states that.
Category 1 instruments include in part, "...those ' indicating instruments l
which are identified by equipment ID in Plant Emergency.and Casualty
'l Procedures". The licensee also has. committed to perform all Category 1 preventive maintenance (PM) tasks prior to restart.
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The inspector sampled a portion of Category 1 PM tasks for instrumentation and found that they did encompass equipment in the Emergency and Casualty Procedures..Therefore, because the licensee'had apparently identified the Category 1 items in the. casualty and emergency.
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procedures, and have committed and are in process of performing the
Category 1 PMs prior to restart, this item is closed.
Followup item 86-17-02 (CLOSED).
Licensee Event Reports LER 85-26-LO, (CLOSED) " Inoperable Diesel Generators" q
LER 85-27-LO, (CLOSED) " Containment Air Lock Seals Not Tested In
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Accordance With Requirements Of Technical Specifications" LER 85-28-LO, (CLOSED) " Auxiliary Feedwater' Pump (P-319) Automatically J
Started"
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l In' Inspection Report 87-06 a Notice of Violation was issued due to deficient reporting of licensee events.
The licensee subsequently issued various LERs to the NRC as required to document these events.
The above LERs were issued as corrective action to the Notice of Violation.
The.
inspector performed an in-office review of the'above LERs and found that'
they adequately documented the events, and contained appropriate corrective actions.
The timeliness of the reports were not inspected
since they were the result of corrective actions taken for the mentioned l
Therefore, the inspector considers the listed LERs closed.
LER 85-26-LO, 85-27-LO, and 85-28-L0 (CLOSED).
No violations or deviations were identified.
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Exit Meeting The inspector met with licensee representatives (noted in Paragraph 1) at various times during the report period and formally on October 26,' 1987.
The scope and findings of the inspection activities described in this.
report were summarized at the meeting.
Licensee representatives acknowledged the inspectors' findings.
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