IR 05000312/1988032

Insp Rept 50-312/88-32 on 880919-1007.Violations Noted. Major Areas Inspected:Design Changes & Mods,Qa Audits,Pwr Moderator Dilution Requirements & Followup Items

ML20206B601
Person / Time
Site:	Rancho Seco
Issue date:	10/25/1988
From:	Ang W, Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20206B587	List: IR 05000312/1988032 ML20206B583 ML20206B589
References
50-312-88-32, NUDOCS 8811150500
Download: ML20206B601 (9)

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U. S. NUCLEAR REGULATORY COMISSION

REGION V

Report No. 50-312/88-32 Docket No. 50-312 License No. OPR454 Licensee: Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Facility Name: Rancho Seco Nuclear Generating Station Inspection Conducted: September 19-23, 1988 and October 3-7, 1988 Inspection by: b 10- U-88 W. P oje'ct Inspector Date Signed Approved by:

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i b' '" ( D ~lf' EI l L. Miller, Chief Date Signed Project Section 2 i l

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Summary ,

Inspection on September 19-23, 1988 and October 3-7, 1988 Areas Inspected: Routine, unannounced intpection by a region based inspector of licensee action in the areas of design changes and modifications, QA Audits PWR moderator dilution requirements and follow-up item Inspection procedures 37700, 40704, 92700, 25594, 92701 and 30703 were used.

f Results: No general conclusions regarding the adequacy, strength or weakness of the areas inspected, nor any significant safety matters, were identifie A specific significant weakness was identified in the performance of temporary modifications in that a 10 CFR 50.59 unreviewed safety question evaluation was not performed for the gagging of DHR System Relief Valves PSV 266101 end PSV 26110. Specific weaknesses were also observed in the QA technical specification audit program. Weaknesses regarding specific audit area qualifications of auditors and minimal programmatic audits of technical staff performance were noted. One violation was identified in paragraph 2, 8911150500 001026 2 PDR ADOCK 050

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! Persons Contacted l Licensee Personnel l

• • *D. Keuter, AGM, Nuclear Power Generation

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• B. Croley, AGM, Technical Services

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• • *J. Vinquist, Director, Nuclear Quality

• • *W. Kemper Nuclear Operations Manager

• • J. Meyer, Audit / Surveillance Supervisor, Nuclear Quality

• • D. Elliot, Audit Supervision, Nuclear Quality

• W. Foepke, QC Supervisor

• T. Redican, Manager, Material Control

• P. Turner, Manager, Plant Performance L. Pulley, Supervisor, Mechanical Engineering ,

Heckert, Surveillance Program Supervisor

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• G. Legner, Licensing Engineer

• • D. Swank, Licensing Engineer  ;

,  ! NRC Resident Inspectors l

• • *A. D'Angelo l

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l * Attended the exit meeting on September 23, 1988

• • Attended the exit meeting on October 7, 1988 ,

The inspector also held discussions with other licensee and contract j personnel during the inspection. This included plant staff engineers, :

technicians, licensed c;erators, administrative and clerical assistants, j Design Changes end Modifications (37700)

An inspection was performed to ascertain that design changes and i modifications, that were not required to be approved by the NRC, ss

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cetermined by the licensee, were in conformance with the Technical 1 Specifications (TS), 10 CFR 50.59, the Updated Safety Analysis Report I (USAR) and the Rancho Seco Quality Assurance Progra The Licensee's requirements for design changes and modifications were contained in the ;

l following procedures and various other implementing procedures that were ;

l referenced by these procedures.

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- Rancho Seco Administrative Procedure (RSAP) - 0303, Revision 2, l

"Plant Modifications" l

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Nuclear Engineering Pros dure (NEP) 4109, Revision 9 "Rancho Seco !

Configuration Control Procedure"  !

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- Administrative Procedure (AP) 44, Revision 14. "Plant Modifications I

"ECN Implementation" j i

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Nuclear Engineering Administrative Procedure (NEAP) - 4111, Revision l 0, "Design Change Package Control"  !

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Plant Perfo,1 nance Administrative Procedure (PPAP) - 0044, Revision j 0, "Plant Performance Requirements for DCP Process" At the time of the inspection, the licensee's design change and f modification program was in transition from the Engineering Change Notice t

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(ECN) process to the Design Change Package (DCP) proces The licensee !

l stated that new ECNs were no longer being issued but a number of [

previously issued ECNs still existed that had not been completed, i Additionally, the licensee stated that new design changes and  !

modifications were now being issued as DCPs bet few of these had been f completed. NEP 4109 and AP 44 provided the requirements for ECN RSAP !

l 0303, NCAP 4111 and PPAP 0044 provided the requirements for DCP The l l above noted procedures were reviewed and the inspector verified that they j i provided appropriate controls for- '

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l Design change / modification review and approval l l l

I TS required Plant Review Committee (PRC) and Management Safety [

l Review Committee (MSRC) review and approval when required (

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Performance of testing  !

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l Changes to plant procedures [

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Changes to the training program

• Revision of drawings to incorporate the modification and to ref1*%

the as-built condition

Changes to the preventive maintenance (PM) and Inservice Inspection (ISI)/!nservice Test (IST) programs The following completeu design changes and modifications were selected and reviewed:

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ECN R1994 Revision 1. Work Request (WR) 1353050 "Upgrade Make-up Pump and HP! Pump Minimum Flow Lines"

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ECN R1948 Revision 1. WR 1268730 "Auxiliary Feedwater Pump Bearing Temperature Measurement"

- ECN R3101, Revision 0, WR 148547 and 148550 "Replace Gould Transmitter with Rosemount Transmitter" EFIC system

- ECN R3109 Revision 0, WR 1418910 "Add additional piping supports and shims to fuel oil piping supports on the G-100B Diesel"

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ECN R3230 Revision 0, WR 1419360 "AFW Deluge System Nozzle Replacement" I

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The completed records for the sbove noted des ,n changes and i

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modifications were reviewed for the following:

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• Design change / modification review and approval

10 CFR 50.59 evaluations L t

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Test specifications and test deviations  !'

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Changes to plant procedures, if required

Changes to PM, 15!, and IST procedures, if required l t

Control Room drawings had been changed, 9r appropriately marked with a design change notice in the interi '

I i * Required r' ports to the NRC or FSAR changes had been made or were  ;

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j Completed work for ECNs R1948 R3109 and R3230 was visually inspected, j

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} In addition to the design chsnges and modifications, the licensees l programs for temporary modifications to the plant were also inspected to [

l verify licensee compliance with the TS and the USAR. The licensee's  !

J program for control of temporary modifications, including lifted leads l 3 and jumpers, was contained in Administrative Procedure (AP) 26A Revisi }

] 3. "Temporary Modification Control". Previous to the licenste's use of i 1 "Temporary Modifications", the licensee used "Abnormal Tags" for  ;

i temporary change At the time of the inspection, the licensee's rei.ords [

showed that approximately 60 abnormal tags, some as old as 1985, and  ;

j approximately 13 temporary modifications were in effect. The ifcensee t

! showed the inspecter an action plan, documented in memorandum MPP 88-647  !

dated September 12, 1988, to gradually reduce and clear all abnormal tags j j by November 1989 The licensee further explained that some abnereal tags

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could not be cleared until the plant was in certain modes such as Cold shutdown, ,

j AP 26A Revision 3 contained the requirements for the control of temporary modifications including requirements for: j

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• Review and approval ,

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l 10 C?R 50.59 evaluation f i i

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Plant Review Comittee (PRC) review l

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• Record keeping and logs t

• Independent verification of installation and removal I *

Functional testing ,

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• Periodic review and approval of outstanding temporary modifications I

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i As part of the v'eview of the licensee's program for temporary  !

modifications, the inspector and reviewed temporary modification 88-06 i which required gagging decay heat system relief valves PSV 26101 a !

PSV-2611 The action was required by Nonconformance Report (NCR) S7087 j due to discrepancies with the valve springs of PSV 26101 and PSV 2611 t A1tornate relief paths were established by the ,emporary modification by i red tagging open valves OH5-005, CBS-0004 and CBS-00 The "10 CFR 50.59 -

determination" form for temporary modifica tion 88-06 was performed on l March 28, 1988 and Plant Review Committee chairman review and approval  !

was performed on March 28, 1988. The 10 CFR 50.59 determination stated [

that the temporary modification did not require a technical specification  :

change nor did it result in any licensing basis document being no longer  !

true or accurate nor did it violate a requirement in any licensing basis  !

documen Consequently an unreviewed safety questiun detarmination was [

not performed. However, Updated Safety Analysis Report (USAR) Section [

9.5.2.1 refers to figure 9.5-1 of the USAR for a schematic description of i the OHR syste Figure 9.5-1 of the USxR shows valves PSV-26101 and l PSV-26110 as part of the OHR syste l i

i Coqsequently, the inspector concluded that an unreviewed safety question evaluation was rsquired by 10 CFR 50.59 but had not been performed. This l

was significant because a review of danger tag clearance  ;

request / authorization 35695, which was issued to red tag open valvus  ;

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CBS-003, CBS-004 and DHS-005 in accordance with temporary modification 88-06 and NCR 57807, showed that CBS-004 was closed for part of 7-21-88 and DHS-005 was closed for part of September 9, 1988 by clearance 36077, removing the alternate relief paths provided by leaving these valves ope The documentation for clearance 35695 and 36077, temporary i modification 88 06 and NRC S 7087 did not have any administrative l controls to assure that an alternate relief path was maintained while j relief valves PSV-26101 and PSV-26110 were gagged and while valves '

CBS-004 and OHS-005 were shu The failure to perform an unreviewed safety question evaluation was identified as an apparent violation of 10 CFR 50.59, Violation 88-32-0 . Audit Program Implementation (40704)

An inspection was perforneo to verify that the ticknsee was conducting I routine audits to ensure conformance with Technical Specifications (TS),  !

regulatory requirements, licensee comisitsents, and industry guides and j standards, the inspection also was performer'. to verify that the audits ,

were being conducted by qualified personne The Rancho Seco QA program was contained in Appendix 328 of its Updated l Safety Analysis Report (USAR). In addition, Rancho Seco TS 6. ;

provided QA Audit Requirements. Thd e were being implemented by the  !

Rancho Seco Quality Manual (RSQH) and the following procedures:

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RSAP 1306, Revision 2 "Audits and Surveillance" .

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- Quality Assurance Implementing Procedure (QAIP) - 1801, Revision 3 -

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QAIP 1803, Revision l', "TS Audit Program" ' '

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QAIP 1805, Revision 1, "Qualificatio'n Requiroments.For Auditors

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'and Surveillance Personnel" tbove noted documents committed to ANSI A45.2.23-1978, "Qualification

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slity Assurance Program Audit Personnel For Nuclear PoworcPlants" NRC Regulatory Guide 1.146, "Qualificatior, of. Quality Assurance agram Audit Personnel for Nuclear Power Plants." .

The QA Surveillance / Audits Supervisor established a matrix that assures TS and license condition requirements would be audited at least once during a three year perio The matrix wasLdocumented in memorandum SQA-88-065 to the Director of Nuclear Quality, dated February 18, 198 The matrix detailed the planned implementation of the QAIP 1803 paragraph 5.4.2 requirement to audit all TS and limiti ; condition requirements every thrse year The inspector informed sne Director of Nuclear Quality that TS 6.5.4.a required the performance of audits that encompass the conformance of facility operation to all provisions contained within i the Technical Specifications and applicable license conditions at least once per year. The Director of Nuclear Quality provided the inspector a copy of a NRC Region III March 29, 1983 letter to the Office of Inspection and Enforcement, Division of Quality Assurance and a January 30, 1984 response to the letter which agreed that an acceptable QA program would audit each TS area (not every item) annually and all TS line items within a specified period of time. The inspector informed the licensee that the interpretation appeared to be reasonable to the inspector but a TS 6.5.4.a change or interpretation should be submitted for NRC review and approval to more accurately reflect the audits being performed. The Director of Nuclear Quality agreed and committed to include the TS change / interpretation with a planned "improved TS" submitta QA Audit 08-A-135 was scheduled to be started during this inspection period and was selected for inspection by the inspector. The purpose of thu audit was to ovaluate the implementation of selected TS requirement The inspector reviewed the audit plan and checklists and discussed it with the load auditor. The inspector noted that the audit was primarily a prucodure, records and documentation audit. The lead auditor confirmed that the audit consisted of a significant amount of paper work review but also stated that observation of ongoir.g surveillance performance was also to be accomplished as part of the audi However, this observation of work performance was nos accomplished during this inspection period. A review of personnel records for the leac auditor and auditor for QA Audit 80-A-135 confirmed the qualifications of the QA auditors. However, the inspector noted that neither auditor had records of having completed any systems or TS Training. The QA Audit Supervisor and the lead auditor stated that the lead auditor had attended systems and TS training but cvuld not provide e completion record. Furthermore the QA audit supervisor stated that the lead auditor had approximately three years of previous auditing experience at SMUD under the direction of lead auditors / supervisors who had systems and TS experience or training. The apparent lack of record of training or experience in the specific audited area appearJd to be a weakness in the aucit progra The Director of

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y Nuclear Quality agreed and committed to improve auditor resumes and to j assure that future audits would include personnel with the necessary l experience or training for the area being audited.

1 A sampling of audits completed in the past year and a review of QA's d audit schedule confirmed that audits were being conducted within the C

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required time limit One of the completed audits, 87-A-138, was

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selected by the inspectr,r for further review. The inspector confirmed that QA auait 87-A-138 met the following:

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• The scope and results of the audit were clearly defined in the l repor The audit scope was TS 6.5.a.b - Performance, training and qualifications of the technical staf }

The audit was conducted by trained personnel independent of the activity being audite Chemlists were prepared and used, follow-up actions were schedule Responses to the audit findings were in writing and timel ..

[ The inspector noted during the review that the audit concentrated on the L ~

training and qualifications of tne technical staff but did not include

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observation of ,)erformance by the technicai staf The QA Audit Supervisor stated that the audit included a revi of personnel records for negative performance indicators. Furthermore the OA Audit Supervisor stated that QA surveillances routinely perform observations of work perforraant However, the lack of a programmatic audit of the f entire technical staffs perforraance other than the individual negative performance indicator review appeared to be a weakness of the QA audit pr3 gra The Director of Nuclear Quality committed to review the QA audit program to address the concer The inspector concluded, based on a limited sampling of QA audits and the QA audit program, that the intent of the TS and USAR concitments appeared to have been met. Weaknesses of (.e program, as noted above, were identified and commensurate licensee action were committed by licensee representatives to address the weaknesse i No violations or deviations were identifie Onsite Foi'ow-up of_ Writ *.en Reports of Non Routine Events (92700)

_ (0 pen) Licensec Evnit Report (LER) 87-046-Surveillance Procedures Not Perforrned by Technical Specificat;on (TS) Required Date Due to Personnel [.t'ror LER 87-016 reported that TS 4.2.2.1 surveillance requirements for Decay Heat Eysten Valves HV-20001 and HV-20002 was not performed during the required quarterly schedule since the valves were not in service but was also not performed when the valves were returned to service on November 26, 198 Subsequently, on December 15, 1987, F

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the valves were tested as part of the next normal quarterly surveillance. The Technical Spec <fication violation was discovered during an operational readiness review of surveillance procedure implementation. .The LER attributed the missed surveillance to personnel error and committed to establish a matrix of survelliance i procedures with plant modes and incorporate this matrix in AP 303 -

Surveillance Program by April 1, 198 An inspection of the licensee's corrective action was performe I The licensee had developed a matrix as stated in the LER. The  ;

matrix had been reviewed and commented on by the Operations i Department but had not been approved. The matrix was referred to by :

AP303 but had not been incorporated into AP303. The licensee '

committed to revise the LER commitment or perform the commitment by ,

October 23, 1988. Pending completion of licensee corrective action l the LER was left ope No violations or deviations were identifie . Follow-up of Inspector Identifled Items (92701)

i (Closed) Inspector Follow-up Item 88-06-02-Nuclear Engineering Evaluation for Material Replacements l

Follow-up Item 88-06-02 identified a concern regarding the need for Nuclear Engineering evaluation / acceptance of material replacement prior to use by the Maintenance Department. Rancho Seco Administrative Procedure 0706 Revision 1 was issued on March 8, 1988 i to require an engineering evaluation for material requests other than those that have had a standing material evaluatio The RSAP 0706 revision provided reasonable controls to assure proper engineering review and approval for material requests. The item was close No violations or deviations were identifie ! (0 pen) Temporary Instruction 2515/94 - Inspection for Verification l of Licensee Changes Made to Comply with PWR Moderator Dilution

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Requirements - Multi-Plant Action item B-03

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An unreviewed method of moderator dilution involving gravity draining of a Sodium Hydroxide tank through the Decay Heat Removal System and into l the Reactor Coolant occurred at an operating plan Subsequently NRR issued 00R Inf rmation Memorandum Number 7 to all licensees to inform >

them of the occurrence and to request an evaluation of similar potential occurrences at their facilitie .

An inspection was performed to verify actions completed by the licensee !

in response to the NRR letter. During the inspection, the licensee and the inspector searched records for receipt of the lotter by SMUD, for any .

SMUD response to the letter and for any NRC response or Safety Evaluation !

Reports resulting from the lette At the end of the inspection, the licensee and the inspector were unable to obtain any of the records noted abov The inspector contacted the NRR lead technical contact on the f

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subject temporary instruction to obtain any available record or information on the subjec At the end of_the inspection, the NRR lead technical contact was also unable to obtain any of the records. Region V has requested clarification from NRR by lette Pending availability of more definitive informat'on or record noted in the paragraph above, the TI was left ope No violations or deviations were identifie . Exit Interview The inspection scope and findings were summarized on September 23 and October 7, 1988 with those persons indicated in paragraph 1 abov The inspector described the areas inspected and discussed in detail the inspection findings.

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