IR 05000312/1987037
| ML20196E542 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/03/1988 |
| From: | Dangelo A, Miller L, Myers C, Perez G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20196E508 | List: |
| References | |
| 50-312-87-37, IEB-85-003, IEB-85-3, NUDOCS 8803010157 | |
| Download: ML20196E542 (17) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION V
Report No:
50-312/87-37 Docket No.
50-312 License No. DPR-54 Licensee:
Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Facility. Name:
Rancho Seco Unit 1 Inspection at: Herald, California (Rancho Seco Site)
Inspection conducted'
Inspectors:
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A.Ld. D' n elo, S i R sident Inspector Date Signed
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Approved By O -~ b /
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. N111er, Chi i: tor ProjectsSection II Date Signed Sumn.ary:
i Inspection between October 24 and December 4, 1987 (Report 50-312/87-37).
i Areas Inspected:
This routine inspection by the Resident Inspectors involved I
the areas of operational safety verification, maintenance, surveillance, and
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followup items.
During this inspection, Inspection Procedures 30702, 35701, t
37701, 61726, 62700, 62702, 62703, 70301, 71709, 71811, 71707, 72701, 92700, i
92701, 92702, 92703, 93702, 94702 were used.
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Results:
The inspection identified uncertainty in which part of the
corrective action systems to use amongst personnel contacted.
Two violations were identified (failure to follow work request instructions and failure to initiate a nonconformance report for an identified discrepancy).
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DETAILS
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1.
Persons Contacte'd a.
Licensee Personnel G. C. Andognini, Chief Executive Officer, Nuclear J. Firlit, AGM, 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, Nuclear Technical Manager G. Cranston, Nuclear Engineering Manager W. Kemper, Nuclear Operations Manager-
- J. Shetler, Director, System Review and Test Program i. Tucker, Nuclear Operations Superintendent J. Grimes, Nuclear Mechanical Maintenance Superintendent L. Fossom, Deputy Implementation Manager R. Colombo, Regulatory Compliance Superintendent
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J. Field, Plant Support Engineering Manager L. Conklin, Technical Assistant, AGM
S. Crunk, Technical Assistant, AGM F. Kellie, Radiation Protection Superintendent
- J. Vinquist, Quality Assurance Manager B. Daniels, Supervisor, Electrical Engineering J. Irwin,, Supervisor, I&C Maintenance R. Cherba, Quality Engineering Supervisor T. Shewski, Quality Engineer D. Ross, Security Other licensee employees contacted included technicians, operators,
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mechanics, security and office personnel.
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- Attended the Exit Meeting on December 9, 1987.
2.
Operational Safety Verification The inspectors reviewed control room operations which included access control, staffing, observation of decay heat removal system alignment, and revieti 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 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.
The inspectors also observed plant housekeeping and
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cleanliness, and looked for potential fire and safety hazards.
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During the inspection period, the licensee increased their management attention on operational matters.
Increased presence of licensee management present in the control room was observed.
No control room distractions were observed by the inspector.
The limiting conditions for operations were observed to be adhered to for the Decay Heat Removal System.
Electrical alignments for the decay heat system were also reviewed with no concerns identified.
Radiological Protection Radiological controls within the containment building appeared consistent with the ALARA program.
During tours made within the containment, the inspector observed low radiation area postings clearly displayed within the building.
The Radiation Protection (RP) staff were encouraging plant workers to perform their duties within the posted low radiation areas when their work activity permitted.
The Radiation Work Permit (RWP) for containment entry to perform inspection appeared to contain all the necessary ir. formation such as job description, radiation and contamination levels, aosimetry, protective clothing requirements and required signatures.
Plant personnel within containment were observed to be wearing personnel dosimetry adequately.
Physical Security Observations were made during the inspection period of licensee security personnel standing watch for access control.
Security personnel operating x-ray examination equipment were attentive and observed to inspect plant personnel carry-on baggage such as brief cases and boxes in a detailed fashion.
Matal detector and explosives detector's alarms were adequately responded to by licensee security personnel.
A walkdown of approximately three-fourths of the protected area barrier was conducted.
No erosion of, or openings within, the barrier were identified, nor was any proximity of vehicles or other objects which could be used to scale the barrier observed.
Vital area barriers and doors were observed to be operating correctly.
A security officer had been posted to control access to one vital door observed to not close correctly.
Visitor access control appeared adequate.
Visitor badges were displayed, and access authorizations were entered within the security computer.
On December 4, 1987 the inspector toured the reactor containment building and auxiliary buildirc to walkdown the steam generator drain system and spent fuel pool systems involved in spills which occurred on November 25 and 27, 1987.
During the walkdown within containment, the inspector observed an individual lying down on scaffolding next to the containment equipment hatch.
The inspector notified a nearby radiation protection technician, who also observed the individual lying down. The technician called to the i
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-individual and requested that he not lie down in containment.
The individual did respond quickly upon being called to by the-technician.
Licensee management was informed of the individual and immediately
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ordered increased tours of containment by plant management.
Licensee management stated they were developing a program to ensure increased management presence within the plant.
The inspector will monitor the progress and development of the licensee's program.
The inspector also noted a portable jib crane near the equipment hatch which appeared to be partially supported on the angle iron welded to the containment liner. The inspector was concerned that the liner ettachment was not analyzed for the potential loading of a jib crane.
In addition, it was noted that the crane was in close proximity to a safety related cable raceway.
The inspector was concerned that the crane could topple into the raceway.
(If the raceway contained DHR cable, the condition could affect the operability of DHR systems required to be operable.)
The inspector brought this concern to the attention of licensee management for resolution at the completion of the tour. The licensee initiated an invcstigation of the potential problem. The inspector will followup the licensee's review during a future routine inspection.
No violations or deviations were identified.
3.
Monthly Surveillance Observation / System Review and Test Program Inspection i
Several surveillance tests were observed and reviewed to ascertain that they were conducted in accordance with the applicable requirements.
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 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 was in agreement with observations made by the inspector, and deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.
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The following specific activities were inspected during this reporting period, a.
The IMO Delaval Industries (TDI) Diesel Generators were being modified to alleviate the excessive vibration problems that the units have experienced.
All work was being conducted in accordance with applicable procedures and work control packaget, b.
The inspector monitored portions of STP.778, "Integrated Control System (ICS) Cold Functional Test."
Several problems with the
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system were identified and corrected in accordance with licensee procedures.
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The inspector monitored the maximum delta-p flow testing of.
HV 20578, an auxiliary feedwater system flow control va've, being perfonned as a part of STP.1029.
This testing was performed in a sat-isfactory manner.
d.
The performance of STP.11308, "Diesel Generator G8868 Functional Test," on the Bruce GM Emergency Diesel Generator was monitored in part by the' inspector.
The testing was proceeding in an orderly fashion in accordance with the test procedures.
e.
On November 11, 1987 the licensee began the emergency feedwater initiation and control (EFIC) cold functional test, STP.667. The inspector observed the test briefing for the personnel involved in the test, and also attended the operator's briefing prior to the start of the test. The inspector observed a portion of the test.
During the test witnessing, the inspector observed five test deficiencies; the test deficiencies were noted appropriately in the test log. The inspector was concerned about the erratic operation of flow control valve FV-20531, an
'A train AFW control valve.
The licensee started to perform an engineering analysis of the erratic operation of FV-20531; the insp'ector will observe the operation of this valve and the system during the EFIC hot functional test and during retest of portions of STP 667.
f.
The Once Through Steam Generator (OTSG) Secondary Side Hydro Test, Special Test Procedure (STP) 1083 was performed on both OTSGs to verify material condition of the systems.
Both systems met all applicable acceptance criteria, all testing was performed in accordance with the STP, and all maintenance was documented on appropriate work requests. The inspector noted, however, that originally there was only a zero to fifteen thousand pound pressure gauge on the hydrostatic test rig and the operator was going to be maintaining less than fifteen hundred pounds pressure on the system.
The licensee proceeded to install an additional zero to three thousand pound gauge on the hydrostatic test rig after the inspector informed them of his concern.
The other concern the inspector
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identified was that during the initial pressurization of the
"A" system the control room operators did not have in their possession a
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marked up P&ID identifying the pressurized system boundaries.
In response to the inspector's concern, the licensee put a marked up P&ID identifying the boundaries in the ccntrol room, g.
The inspector observed the Emergency Feedwater Initiation and Control (EFIC) Cold Functional Test, STP. 667.
Retest of the portions of the system that had not originally passed the acceptance
criteria was reperformed, all test data was collected, and met all applicable acceptance criteria.
In addition to these observations, the inspector performed an audit and review of the licensee's test organization.
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The licensee appeared to have adequate documentation to establish lines of authority within the test organization and to identify which testing personnel were certified for each position.
The inspector noted that there had not been any formal training sessions scheduled or conducted for any of the test personnel, nor were any planned.
The licensce's explanation of this was that the test organization was a temporary organization, and therefore aid not require formal training.
The inspector concluded that the licensee's organizational requirements appeared to meet the minimum requirements of ANSI N45.2.6 and ANSI /ANS-3.1.
No violations or deviations were identified.
4.
Monthly Maintenance Observation 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 work; activities were accomplished using approved procedures and were
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inspected as applicable; functional testing or calibration was performed I
prior to returning components or systems to service; activities were I
accomplished by qualified personnel; radiological controls were implemented; and fire prevention controls were implemented.
a.
STP-1054, Maximum dP testing of SFV-23604 During perfctmance of STP-1054 to test makeup isolation valve SFV-23604 under maximum differential pressure (dP) conditions, the motor operated valve (MOV) failed to fully close when operated from the control room.
The valve had previously been refurbished under the licensee's program.
The licensee investigated the failure, and found that an Engineering Change Notice (ECN) to change the gear ratio in the operator had not been accomplished.
The new gearing l
was subsequently installed, and the licensee repeated the maximum dP i
test.
The valve successfully closed during the test and was declared operable.
Although the the new gear ratio modification appeared to solve the problem, the inspector observed that the originally calculated torque switch setting for the MOV had failed to ensure proper operation during the initial maximum dP test.
Discussions with licensee valve testing personnel indicated that only one in six MOVs that were required to close under max dP conditions had actually passed their initial testing using the originally calculated torque switch settings.
Therefore, the inspector was concerned about the adequacy of the original licensee determination of the required torque switch settings.
(This is discussed futher in paragraph 6 of this report.)
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STP-1029, Maximum dP Testing of AFS Control Valve HV-20578 The inspector observed testing conducted under STP-1029 on HV-20578 which was a MOV block valve downstream of the Air Operated Valve (A0V) control valve FV-20578 in the "B" train of the Auxiliary Feedwater System (AFS).
Although the valve had been refurbished under the licensee's program, it failed to close when tested under maximum dP conditions.
The inspector observed the readjustment of the torque switch and the
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repeat of the maximum dP test during which the valve performed satisfactorily.
As discussed above, the inspector was concerned that the test failures indicated a deficiency in the licensee's calculations used to establish the correct torque switch settings during valve refurbishment.
(This is discussed further in paragraph 6 of this l
l report.)
The inspector discussed this concern with licensee representatives.
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The licensee stated that the accuracy of the licensee's I
calculational method would be discussed in their final submittal in response to Bulletin 85-03.
No deviations or violations were identified.
b.
Auxiliary Feedwater System (AFS) Piping Replacement The inspector observed the modification of the discharge piping on both auxiliary feedwater pumps P-318 and P-319 under ECN-R2255. The sections involved were short sections of carbon steel piping which were being replaced with stainless steel piping.
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Installation of the piping witnessed was made in accordance with the work request and ECN requiretrents.
No deviations or violations were identified.
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Control Room / Technical Support Center Essential Air Conditioning l
System (CR/TSC HVAC) Hiswiring i
l The inspector followed up on an incident which occurred on 11/10/87 l
during testing of the essential control room / technical support center ventilation system (CR/TSC HVAC) in which the refigeration unit U245B failed to operate.
The inspector discussed the troubleshooting of the problem with the electrician who performed the initial investigation under work request #139613A. The electrician found 3 wiring error in the control circuitry for the unit which apparently caused a fuse to blow resulting in the failure to operate.
He corrected the wiring error and observed that the unit could be reset without any further blown fuses.
During subsequent testing after completion of the troubleshooting, the unit again repeatedly failed to operate successfully due to additional wiring errors later discovered.
During his investigation he also
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became aware that electrical maintenance procedure EM-192, Electrical Equipment Startup, had not been performed following l
modification of unit U245B to verify the as-built wiring.
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procedure was not required to be performed, but was routinely performed following such work.
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The inspector noted that the Train
"A" refrigeration had had procedure EM.192 performed when similar work had been completed on it.
The purpose of procedure EM.192 was to verify that plant electrical equipment wiring was installed per drawing requirements and ensure other electrical work activities, such as terminations, fuse installations and pressure switch installations are correct.
The inspector observed that the licensee might have identified the wiring error prior to operating the equipment if EM.192 had been
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performed, as it customarily was.
i The inspector identified several concerns in his review of the troubleshooting and rework activity:
1.
Work request #139613A specifically prohibited rework of observed deficiencies within the scope of the original work request. However, rework of the nonconforming wiring was performed without revising the original work request.
Maintenance Administrative Procedure MAP-0002, "Control of Maintenance Activities", purpose is control of maintenance activities.
Maintenance activities are required, by the procedure, to be in accordance with approved written instructions, such as the work request, and to be completed in the sequence written unless resolution of problems has been complete.
The failure to follow the work request maintenance instructions is an apparent violation. (50-312/87-37-01)
2.
The as-built wiring which was discovered to be nonconforming during the troubleshooting activity was not documented on an NCR contrary to the licensee's quality assurance procedure QAP-17, Nonconforming Material Control.
Quality Assurance Procedure QAP-17. "Nonconforming Material Control", defines criteria to identify nonconforming material and preperation of nonconforming reports (NCRs) to document nonconforming parts or components. Within QAP-17, instruction is given which states systems or equipment which do not meet specified requirements or design drawings shall be considered nonconforming.
This failure to follow the quality assurance procedure is an apparent violation. (50-312/87-37-02)
The inspector noted that licensee personnel had stated that in cases such as wiring errors where no engineering involvement is
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needed to correct the nonconformance, no NCR shall be generated.
The inspector discussed these specific observations with licensee management on 11/18/87.
The inspector expressed his concern that the problems indicated an apparent failure of the licensee's
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programs for identification of significant conditions adverse to quality.
(This is discussed further in paragraph 5 of this i
inspecticn report.)
5.
Corrective Actions The work control and deficiency reporting problems involved in the troubleshooting of the CR/TSC HVAC (discussed in paragraph 4 of this inspection report) were discussed with licensee management on 11/20/87.
During discussion of the deficiency reporting methods within the licensee's corrective action program, the inspector expressed his concern that the various methods of reporting did not appear to be coordinated and reviewed in an equivalent manner within the quality assurance (QA)
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program. The inspector observed that the licensee's QA department defined I
and controlled the NCR (nonconformance report) and CAR (corrective action l
request) processes for identifying hardware nonconformances which required engineering dispositioning.
However, other methods of identifying deficiencies (ODRs, WRs, etc.) were defined and controlled within other plant and departmental procedures.
As an example, the inspector identified that QAP-17, Control of Nonconforming Material, allows identification of nonconformances on a work request. However, the work request procedure, RSAP-803, does not (
incorporate specific instructions for identifying nonconformances on the work recuest form nor any instructions regarding dispositioning.
The inspector was concerned that nonconformances documented in this manner were not clearly identified for review, disposition and trending to preclude reoccurrence.
The inspector stated that the licensee's program in compliance with Appendix B, Criterion XVI, Corrective Actions, was confusing and disjointed to licensee personnel interviewed in connection with the troubleshooting activity discussed above.
The inspector observed confusion among the plant personnel as to which documents were appropriate for use in different cases.
The inspector was concerned that the difficulty in identifying the correct method for reporting deficiencies may obstruct attainment of the quality objective to promptly identify and correct conditions adverse to quality.
The inspector could find no guidance within any of the licensee's procedures for determining the "significance" of the conditions identified as adverse to quality.
The inspector was concerned that the licensee's program for corrective actions for conditions adverse to quality was biased principally toward dealing with hardware deficiencies requiring engineering disposition, giving considerably less control over administrative control deficiencies such as procedure problems, procedural adherence, personnel nrror, etc.
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The inspector reviewed audits performed by the quality assurance organization regarding corrective actions and found that recent audits had iaentified problems existing within the the lic"nsee's program.
These audits included:
87-24 Corrective Action 87-23 NCRs 86-02 Audit Implementation l
87-62 Western Region Joint Utility Program l
86-09 Corrective Action Furthermore, the inspector emphasized to licensee management that recent
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NRC inspections have pointed out programmatic weaknesses witnin their programs.
Inspection Report 86-41 identified that:
"...there was no mechanism to uniformly ensure that significant conditions adver,e to quality would be reported to appropriate l
levels of management. There did not appear to be any systemmatic method to identify from all sources problems that could be considered significant conditions adverse to quality..."
Inspection Report 87-06 discussed:
"... continuing weaknesses in the quality assurance program related to corrective action measures..."
In response to Inspection Report 87-06, the licensee had committed to undertake a comnrehensive review of their program within their management process review c,ganization.
That review was completed, resulting in the version of QAP-17 discussed above.
At the exit meeting, the inspector discussed the continuing observations of programmatic weaknesses in the corrective action program associated with the ambiguity and lack of integration of the many problem reporting methods.
The inspector emphasized that the duties of the persons and organizations performing safety related activities within the plant should be clearly established and delineated in writing.
The licensee acknowledged the inspector concerns and committed to complete the management process review of the corrective actions program prior to restart and also to initiate additional review of the corrective actions program within the QA organization to consolidate the deficiency reporting mechanisms.
results of the licensee's programmatic reviews will be addresseo..i a
re inspection.
(Followup Item 50-312/87-37-04)
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ca siolations or deviations were identified, e
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Followup of Response to IE Bulletin (IEB 85-03):
40V Torque Switch Setting Calculations (0 pen)
As discussed in paragraph 4A of this inspection report, the inspector observed two failures of newly refurbished HOVs to operate successfully under initial maxim"m dP testing.
The inspector questioned the adequacy
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of the licenseeis calculations of the required torque switch settings.
The calculations were developed as part of the licensee's program in response IEB 85-03:
Motor Operated Valve Common Mode Failures During Plant Transients Due To Improper Switch Settings.
The inspector discussed the basis for the analytical determination of the required torque switch settings with licensee engineering personnel.
The inspector found that B&W (Babcock and Wilcox) had been contracted in 1986 to develop and perform the required calculations as part of the licensee's IEB 85-03 program.
The method which B&W used to perform the calculations was based on stan<iard industry practice using the Limitorque Sizing Manual (LSM).
In April, 1987, the licensee's engineering department took over the development of the analytical technique and continued to use the LSM as the basis for their procedure NEAP-4801,
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Evaluation of Motor Operated Valves, which was issued in October,1987, i
for use in calculating the required torque switch settings.
The licensee stated that initial maximum dP testing following valve and i
operator refurbishment has shown that the analytical calculation of i
torque switch settings was inadequate for 4" and larger gate valves with
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greater than 1000 psi maximum dP.
It was further noted by the licensee
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that this occurred in particular on valves subjected to turbulent flow conditions such as in close proximity downstream of a throttle valve or elbow.
For the these cases, the appropriate torque switch settings were determined during testing, and the calculational method was revised to improve its correlation with the empirical data.
Applying the revised calculational metnod, the licensee determinec hat an additional 10 MOVs (safety related but non IEB 85-03 valves) required increased torque switch settings.
The non IEB 85-03 safety related valves were not planned to be tested under maximum dP conditions.
Rather, tha licensee would be relying on the test results of the IEB '15-03 valves in revising the calculational method for use in specif, ng the torque switch settings for all other HOVs.
The inspector questioned the adequacy of the licensee's calculational technique.
The licensee technique using in house test results appeared less broad than industry based test results.
The inspector observed that the licensee's calculational technique appeared to be still under development requiring continuing feedback of test results to establish confidence in the calculational technique.
The empirical determination of the required torque switch settings was only a one or two stroke demonstration of proper functioning with the equipment in a new or newly refurbished condition. There did not appear to be a conservative allowance built into the licensee's technique to account for statistical variability or non ideal in service conJitions such as packing gland tightness, lubrication, extended periods of inactivity or aging. The inspector was concerned that the empirical data which the licensee was using to qualify the calculational technique appeared to be limited and not representative of the range of service conditions.
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The inspector discussed these. concerns with licensee representatives who stated that the qualification of the calculational tect.nique woulo be discussed in their final submittal in response to IEB 85-03.
However the inspector was concerned that there did not' appear to be a program which would ensure that in service MOV performance would continue to be fedback to engineering for validation of the calculational technique. This will be followed up in a future inspection.
(TI 2515/73 0 PEN)
. 7.
Rancho Seco Restart Scope List (RSL)/Long Range Scope List (LRSL}
On November 30, 1987, the licensee submitted an update of the RSL and LRSL lists.
The submittal included the following lists:
(A) Previous Re. cart Items justifiec.a Long Range Items since October 13, 1987.
(B) RSL/LRSL total statistics as of November 20, 1987.
(C) LRSL open and closed items added since October 13, 1987.
(D) RSL, all open and closed items as of November 20, 1987.
The inspector resiewed the above.ist (A) for the adequacy of the justification for previcus restart items that have been downgraded to
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post-restart items.
The inspector's criteria for inspection of these new
post-restart items was whether all regulatory requiremento related to tae item and or system would be met even if the item was not completed prior to restart.
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The List (A), Previous Restart Items justifiea as Long Range Items, included 52 items; of these, 9 had already been closed.
The inspector reviewed the other 43 items.
The inspector agreed with the licensue's determination for post-restart on 26 items.
On 14 other items, the
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inspector had discussions with knowledgeable licensee representatives who were able to provide further details on the justification for post-restart determinatten.
The inspector slso agreed with these i+, ems.
The inspector identified three remaining isstes wnich appeared to require further justification for delaying these activities until after rest,a.rt.
The items are:
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MGT/EN 2292:
"Vendor Techt.ical Manuals are not being controlled in accordance with AP.461.
Training of personnel in vendor manual
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control has not been implemented and clear cut responsibility for control of vendor manuals has not been accepted."
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The inspector stated that the licensee must ensure that appropriate vendor information was used in all systems and plant procedures prior to restart.
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2.
MGT/EN 3138:
"Existing drSwings for battery chargers do not reflect as-built configuration. Without as-built drawings, it is difficult
i to enforce effective maintenance or to issue modification design package."
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The inspector stated that the battery chargers are Class 1 (safety related) equipment, and as such, drawings for them must reflect their as-built conditions prior to restart.
3.
MGT/PP 3670:
"Discrepancies in surveillance procedure SP.621 may affect reactor building purge system cperability."
The inspector stated that all known errors in safety related procedures were expected to be corrected prior to restart, iricluding these.
The above items will be considered as an open item for inspections prior to restart.
(0 pen Item 87-37-01).
No violatiors or deviations were identified.
8.
Followup on Previous Inspection Items
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Enforcement Items Violation 87-13-01, (CLOSED) "Class 1 Item Issued Without Appropriate Accept Tag" This violation involved the licensee issuing, from the warehouse, a filter element for i safety-related system without the filter element being appropriately "accept" tagged.
The licensee's precedure required that all Class 1 itera released from the warehouse have a "SMUD Accept Tag" unless otherwise exempted.
This filter had not been inspected to qualify for an Accept Tag nor had the filter been exempted from the requirement.
The inspector reviewed the response to the Notice of Violation and found that the licensee admitted that tne violation had occurred and stated that the reason for the violation was that the warehouse personnel issued the item without the appropriate Accept Tag.
The licensee has taken the following corrective actions a.
Training sessions were conducted for warehouse carsonnel on the list of items not req 1 iring an Accept Tag, b.
Training sessions wore conducted te review the Accept Tagging procedure.
In addition, the liceasee reviewed their list of items not requiring an Accept Tag (the "Extmpt List") and reviseo it to include filter elements.
The inspector had an further ques +. ions, therefore, due to the licensee's above actions, this item is cunsidered closed.
(Violation 87-10-01, CLOSED.)
Other Followup Items Temporary Instructions
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i TI 2500/26 (OPEN), "Inspection Requirements for NRC Compliance Bulletin 87-02 "Fastener Testing to Determine Conformance With Applicable
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Material Specification"
-The inspector participated in the licensee's selection of samples of I
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fasteners and nuts required by Bulletin 87-02.
From the warehouse
records available, the licensee identified the following types and grades
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of safety and non-safety grade fasteners and nuts in stock:
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Safety Grade Non-Safety Grade A193 Grades 87/88/816 A193 Grade B7/88
SAE J429 Grade 5 A307 i
A449 A563 A325 Type 1 A194 A354 Grade 80 A307 A563
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i A194 The inspector observed the selection of the above material types and
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tagging of the iteas.
The inspector reviewed a sample of the Fastener
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Testing Data Sheet and they appeared appropriate.
l t
.
The inspection of the results of the testing and procurement practices
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will be inspected in the future, therefore TI 2500/26 will remain OPEN.
t Part 21 Reports
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86-28-P (CLOSED), "Contromatics Actuator With Jackscrew Emergency
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Override Operator"
,
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Pacific Air Products Co. issued a Part 21 which identified some dampers with Contromatic actuators that under certain usuage can cause wearing or j
fouling of threads in the actuatnr.
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The licensee reviewed the heating ventilation and control systems and found that none of the actuators on site have the reported configuration.
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Therefore, the licensee reported that the Part 21 does not apply.
The l
inspector considers this item closed.
(Part 21, 86-28 (CLOSED).
i Licensee Event Reports f
LER 87-17-LO/L1 (CLOSED), "Local Leak Rate Test Program Discrepancies"
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The licensee reported that they had identified program deficiencies with
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their Local Leak Rate Test (LLRT).
The deficiencies included twelve containment penetrations that were not included in the local leak rate
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i surveillance procedure and found that twenty containment penetrations may
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. lot conform to current industry accepted test methods.
In addition, the
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j licensee identified discrepancies with the Updated Safety Analysis Report
j (USAR) and a Casualty Procedure for the Component Cooling M ter (CCW)
l system.
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.
The licensee identified the above deficiencies during a systematic review
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of the CCW system by the system engineer.
The additional USAR and
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casualty procedure deficiencies were identified during a programmatic evaluation of the LLP.T program by the licensee.
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The-licensee's corrective actions entailed the following:
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1.
An evaluation of the LLRT progra:n versus the 10 CFR 50, Appendix J requirements.
2.-
Revisfor.s to the LLRT procedures to upgrade the test method and add all appropriate penetrations to the program.
3.
Performance of LLRT on all revised valve lists prior to restart.
t
Documentation of the as found condition of the above penetrations.
I 5.
Submittal of a proposed Technical Specification amendment to include the appropriate containment penetrations in the Technical Specification.
6.
A revision of the USAR for the CCW system which will be submitted in o
the July 1985 annual revision of the USAR.
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7.
CCW procedures were revised.
i The inspector had no further questions.
Due to the extensive corrective
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actions taken, the inspector considers this item closed.
(LER 87-17-LO/L1, CLOSED).
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LER 87-23-LO/L1 (CLOSED), "B&W Total Neutron Power RPS Signal Channels
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Are Not Isolated"
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The licensee reported that for the Reactor Protection System (RPS), the I
total reactor power summing amplifiers in two channels had been combined
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in an electronic average power amplifier that did not have channel isolation as required.
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The licensee was contacted by B&W (Babcock and Wilcox) late in 1986.
B&W j
indicated that they were concerned with an unbuffered (non safety related) signal supply going to the RPS.
B&W later issued a Preliminary
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Safety Concern (PSC) 1-87 to the licensee on February 24, 1987.
The PSC l
was entered into the licensee's. Jystem as an Occurrence Description i
i Report (ODR) on March 10, 1987 and the ODR was determined as not an issue I
at Rancno Seco.
However, on March 30, 1987 while closing the paperwork
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for the above 00R, the licensee, in fact, determined that the PSC was a
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J reportable event, and an investigation of the concern was initiated.
t The potential failure identified in this LER is that the input to the RPS
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used for the average lir. ear power module in the RPS, is connected to the RPS upstream of an electronic signal isolation device.
Tnis connection i
could have allowed spurious signals to flow back into the total power
l portion of three trip functions of two channels of the RPS from a j
nonsafety relation portion of the integrated control system. This could
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have caused a possible degradation or loss of the total power portion of l
two RPS channels.
Those channels were used for nuclear overpower, power
to pump monitors and power-imbalance-flow trips.
In addition, this
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possible failure could have gone unnoticed to the plant operators due to
a lack of specific indication and auctioneering circuits, and would not I
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have been detected after the failure until the required monthly channel tests of the RPS.
The licensee's investigation has determined that the potential for this failure has existed since initial power operr. tion, 1974.
However, the
-
,
failure would have been detected during the roenthly RPS surveillance
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checks.
The licensee reviewed their safety analysis and found that if
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the failure had occurred, the following safety analyses could be invalidated:
a.
Startup Accident b.
Rod Withdrawal Accident at Rated Power c.
Loss of Coolant flow d.
Steam Line Failure e.
Control Rod Ejection Accident (The LER discusses these analyses in more detail.)
i i
For corrective action the licensee modified the RPS by installing isolation amplifiers to isolate the output of the neutron power detector
from each RPS channel.
The licensee also conducted a study of other RPS signals and the safety features actuation system (SFAS) signals and did
,
not identify similar unisolated signal inputs.
The inspector verified that the modification had been completed and that I
the additional study of the SFAS and RPS systems had been completed.
Therefore, the inspector considers this item closed.
(87-23-LO/L1,
CLOSED.)
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e LER 87-35 (CLOSED), "Continuous Fire Watch Missed During the Performance
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of a C0 Test" g
,
The licensee reported that on June 25, 1987 during system testing of the carbon dioxide system for the Nuclear Service Electrical Building (NSEB),
',
uncontrolled discharges of carbon dioxide occurred which prompted the abandonment of the continueus fire watch in the NSEB.
The event occurred due to the isolation of the carbon dioxide tank by an
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operator who was stationed at the tank.
Apparently, the operator was
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I concerned about the decreasing tank level and isolated the pilot operated valve controlling the tank isolation valve.
This had the opposite effect
,
from what was intended, and vented the tank by opening the tank isolation
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valve.
The tank discharged carbon dioxide into areas of the NSEB.
For
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personnel safety, the fi.e watches were abandoned until the atmosphere in
the NSEB was determined safe for breathing.
- The inspector determined that the abandonment of the continuous fire i
watch was appropriate for the situation.
In addition, hourly fire
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watches were performed by personnel wearing portable breathing apparatus until the CO, tive sctions needed to be taken.
system was restored.
The licensee has concluded that no
,
further corrEc The licensee stateil that t
i j
at the end of this inspection period, an in depth investigation of this
'
event was still ongoing and, if required, the licensee will update this LER.
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.
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The inspector discussed with the licensee that it appeared from the above event that the operator may not have been aware of the appropriate method to secure the carbon dioxide system.
The licensee committed to. review this' event in further detail and take appropriate actions to improve the conduct and briefing of special tests.
Therefore, LER 87-35 is considered CLOSED.
No violations or deviations were identified.
9.
Exit Meeting The inspector met with licensee representatives (noted in Paragraph 1) at various times during the report period and formally on December 9, 1987.
The scope and findings of the inspection activities described in this report were summarized at the meeting, Licensee representatives acknowledged the inspector's findings and violations identified.
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