ML19339B793
| ML19339B793 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 10/04/1980 |
| From: | Dodds R, Elin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19339B790 | List: |
| References | |
| 50-312-80-28, IEB-79-01B, IEB-79-1B, TAC-42507, NUDOCS 8011100076 | |
| Download: ML19339B793 (7) | |
See also: IR 05000312/1980028
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U. s. NULLEAR RECULAToRY COMMISSION
OFFICE OF INSPECTION AND ENFoRCEMEhT
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REGION V
Report No.
50-312
50-312
Docket No.
tt,,ns, go,
safeguards croup
Licensee:
Sacramento Municipal Utility District
P. O. Box 15830
Satramento, California 95813
Facility Narre:
Rancho Seco
Inspection at:
Rancho saco Site and S"UD M9adouarters
Inspection conducted: September 2-5, 1980
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/d - 3 - TTO
Inspectors:
/
d6hn 0. Elin, Reactor Inspector
Date signed
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Date signed
Date Signed
Approved By:
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R. T. Codds, Reactor Engineering Support Branch
D'a t e 's i gned
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Reactor Construction and Engineering Support Branch
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surrma ry :
Inscection on September 2-5,1980 (Report tio. 50-312/80-28)
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Areas Insoected: Routine announced inspection by a regional based inspector
of the licensee's activities performed in response to IE Bulletin 79-01B,
" Environmental Qualification of Class 1E Equipment." The inspection involved
26 inspector-hours onsite and at SMUD Headquarters by one NRC inspector.
Resul ts:
fio items of nonccmpliance or deviations were identified as a result
of the inspection.
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0ETAILS
'1.
Persons Contacted
a.
Sacramento Municipal Utility District (SMUD)
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- R. Colombo, Technical Assistant
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- L. G. Schwieger, Quality Assurance Director
D. Tucker, OPS Supervisor
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- H. Heckert, Nuclear Engineering Technician
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- G. Coward, liaintenance Supervisor and Acting Plant Superintendent
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- Q. Coleman, Q.A. Auditor
B. Daniels, Electrical Engineering Supervisor
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J. Jewett, Acting Site 'QA Supervisor
H. Knieriem, Electrical Engineer
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b.
Other Persons
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- H. Canter, NRC Senior Resident Inspector
- J. O'Brien, NRC Resident Inspector
- Present at exit meeting on September 5,1980.
2.
Summary of Licensee's Resoonse to IEB 79-01B
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a.
NRC Reauirement (45 day response)
IE Bulletin 79-01B of January 14, 1980, Environmental Qualification
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of Class 1E Equipment, required submission within 45 days of (1)
a "flaster List" of all engineered safety feature systems required
to function under postulated accident conditions, (2) written evidence
of environmental qualification of class 1E electrical equipment
to function during LOCA conditions and (3) service condition profiles
for Loss of Coolant Accident (LOCA), main steam line break inside
containment (MSLB), and High Energy Line Breaks inside and outside
containment.
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(1) Licensee's 45 day submittal
The licensee s'ubmitted a response to the above requirements,
on March 3, 1980. A "Itaster List" of systems and components
required to operate in harsh environments was provided.
Thirteen
systems were identified in this listing and the required component
evaluation sheets for equipment inside containment were included,
- .owever these evaluations for equipment inside containment
were largely incomplete. The required " written evidence" of
environmental qualification of equipment inside containment
was not provided per IEB 79-01B.
Completed component evaluation
sheets for equipment outside containment were not supplied.
The licensee indicated that the missing or incomplete information
was primarily data within the scope of their equipment vendors.
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The licensee stated that the missing information and supporting
qualification data would be supplied with the 90 day response -
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required by IEB 79-01B.
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Also included in the fiarch 3,1980 submittal were service condition
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profiles for LOCA conditions per the FSAR. The licensee stated
that service condition profiles for MSLB and HELB environments
would be included in the 90 day response.
(2) flRC verification of 45 day response
During April 1980, an inspection of the Rancho Seco facility
was made to insure a complete listing of components on the
master list as submitted on March 3,1980, and to verify) correct
component identification (Inspection Report 50-312/80-12 .
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The inspector was unable to verify correct manufacturer and
model number listing of all the components of the one. system
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audited, containment isolatio1. -Additionally the inspector
identified several components within the scope of IEB 79-01B
which were not included on the master list provided with the
45 day submittal, such as solenoid air pilot valves and limit
switches used for position indication on containment isolation
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valves.
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b.
flRC Requirement (90 day resoonses)
IEB 79-01B of 14 January 1980, also required further evaluations
to be made and submitted within 90 days of the bulletin.
These
evaluations included (4) an examination of all safety related electrical
equipment both inside and outside containment for qualification
to harsh environment per the Division of Operating Reactors Guidelines
(00R Guidelines) and (5) an evaluation of equipment location witn
respect to expected flood levels.
(1) Licensee's 90 day submittal
On 5 May, 1980 the licensee made a submittal of information
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in accordance with the raquired 90 day response. This response
had significant deficiencies in the licensee's evaluation of
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equipment qualification to harsh environments (as detailed
in paragraph 3). A schedule for completion of this environmental.
qualification review was provided whic;i extended through the
summer of 1981.
(2) License modification of August 29. 1980
On August 29, 1980, the fluclear Regulatory Commission, Operating
Reactors Branch, Division of Licensing issued an order for modification
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of license which provides that "information which fully and
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completely responds to the...(IE 79-01B)...shall be submitted ~
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...not later than flovember 1,1980.
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3.
Current Status of Licensees Review of Environmental Qualification
a.
The five requirements of IEB 79-01B (detailed in paragraph 2) were
reviewed with licensee's representatives:
(1) Master List of Systems and Equipment
The May 5, 1980 response details 22 rather than 13 systems
required to function during accident condition % and almost
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500 electrical components.
The inspector reviewed the containment
isolation system component listing and note'i that, although
non-electrical air operated containment isolation valves were
inclut'ed, position switches which indicate isolation valve
position to operators were not listed.
The licensee indicated
that walkdown of the 22 systems listed had not been coe.pleted
to verify the accuracy of this listing and that the listing
would be modified to reflect necessary changes for the i:ovember
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1, 1980 submittal.
These changes were not detailed to the
inspector. The inspector was unable to obtain from the licensee,
a list of class 1E designated components to compare to this listing.
(2) Written Evidence to Support Qualification of Class IE Comoonents
Inside Containment (Review of Component Evaluation Worksheets)
The licensee submittal of May 5, 1980 includes component evaluation
worksheets for equipment inside containment. These worksheets
are largely inccmplete and do not provide evidence of qualification
in accordance with D0R guidelines. Typical is the limitorque
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valve SFV-24004-L. The workshee~t for this component does not
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detail the class insulation used for comparison to the identified
qualification report.
Additionally the qualification documentation
listed shows only qualification to a steam and chemical environment
for 24.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
It is not clear to the reviewer that the qualification
profile specified on the component evaluation worksheet envelopes
the required temperature / steam profile.
Radiation environment
qualification and documentation references were not provided
and the equipment specified radiation level was two orders
of magnitude below the D0R guideline requirements. There was
no evidence that aging was addressed in accordance with D0R
guidelines.
Finally specific location of the component was
not provided to show evaluation of possible submergence.
(Al though
this valve was not on the 1!st provided in the May 5,1980
response of equipment subject to submergence, the licensee's
evaluation of this possibility was not clear as the specific
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location information was not provided.)
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The items noted on the evaluation worksheet for this component
were typical of the problems with component evaluation worksheets
for components located inside containment.
(3) Environmental Profiles
Environmental profiles for temperature and pressure are provided
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for the LCCA condition and are the same as those specified
in the FSAR.
Profiles have not been provided for MSLB or HELB.
Data has not been provided for area where fluids are recirculated
from inside containment to accomplish long term core cooling
following a LOCA in accordance with paragraph 4.3.2 of the
D0R guidelines.
It was not apparent that the radiation effects
of such recirculation on nearby equipment had been assessed.
(4) Written Evidence of Oualification of Eouioment Sub.iect to HELB/
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MSLS Accidents
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Equipment evaluation worksheets for equipment outside containment -
are blank. No evidence to support qualification of this equipment
was provided in the May 5, 1980 submittal.
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(5) Evaluation of Equipment Location with Respect to the Mr.ximum
Flood Level
A list of some 29 components which are subject to submergence
during LOCA was provided, however individual component location
on the component evaluation worksheets was not provided to
allow NRC audit of this evaluation.
Justification for continued operation with instrumentation
below flood levels was not provided.
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b.
At the time of the insoection, the licensee had assigned 2-3 engineers
from the SMUD generation engineering staff to work on this evaluation.
In addition, the licensee has the assistance of a contractor (NUS)
and the. original architect / engineer (Bechtel) in completing qualification
reviews and defining environmental parameters.
A. total of approximately
12 engineers are working on this project.
No quality assurance
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coverage was being provided at the time of the inspection. The-
licensee stated that quality assurance coverage'in accordance with
the requirements of 10 CFR 50, Appendix B, would be provided by
November 1. 1980.
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The inspector reviewed a draft of one system review recently prepared
for submittal on November 1.
The inspector identified no major
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flaws in this draft as to equipment qualification evaluation. However,
justification for continued operation with equipment not meeting
the DOR guidelines had not been provided,
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4.
Review of Oualification Documentation
The following equipment test documentation was reviewed.by the inspector:
(a) Limitorque Valve Actuators for PWR Service Project No. 600456
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The titled test report details the qualification of limitorque type
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SMB-0-40 motor operated valves with class RH insulation to high
temperature, steam, chemical, and radiation environments. Class
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RH insulation is used on limitort ue valves inside containment.
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(b) Linitoroue Valve Actuators for PWP Service Project No. 600461
This test report details the qualificution of limitorque type SMB-0-15
motgr operated valves with class B insulation to temperatures of
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250 F.
Class B insulation is used on limitorque valves outside
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containment.
(c)
Limitorque Valve Control Test Report No. 600198; Franklin Institute
Researcn Labs Report F-C2232-01
This report details the qualification of type SMB limitorque operators
with class H insulation to a 24.8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> chemical and steam environment
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(no radiation testing).
(d) Franklin Institute Test Report F-C4927 Terminal Block Oualification
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This report provides the results of. steam and chemical spray exposure
tests for KULKA terminal blocks in a steam and chemical spray environment
for 24.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (no radiation testing).
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The inspectors' review cf these test reports will be used in the evaluation
of the licensee's final submittal responses to IEB 79-01B due on 1 November,
1980.
No items of deviation or noncompliance were noted at this time.
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5.
Review of LER submittals as required by IEB 79-018
fio equipment has been identified by the licensee as not_ being capable
of meeting environmental qualification requirements for the service
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intended as of this inspection.
However, most of the equipment has not
been fully evaluated. The licensee submitted LER 80-20 on April 17, 1980
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detailing unoualified Namco limit switches providing indication of
containment isolation. This LER was deleted by the licensee on April
23, 1980 because the. switches only provide operator indication, and do
not provide control of actuation, position or other interlock functions.
This appears contrary to NRC positions taken on these indicators at other
utilities. This matter was referred to IE Headquarters by memo on May
20, .980.
6.
Exit Interview
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The inspector met with the licensee representatives (denoted in paragraph
-1) at the conclusion of the inspection on September 5, 1980 and summarized
the inspections purpose, scope and findings. Particular emphasis was
placed' on the " order for modification of license" of August 29, 1980
and further NRC inspection efforts to be performed prior to the issuance
of the Safety Evaluation Report of environmental qualification of electrical
compone1ts by the NRC staff. The inspector _ expressed concern about the
vo ume of work remaining to be accomplished as compared to the facilities
the licensee has committed to this task. The inspector pointed out that
the licensee' submittal of May'5,1980 was largely incomplete and if left
to stand alone would result in a negative safety evaluation report. The
inspector emphasized that the time requirements for submittal were fixed
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and could not be waived or extended. The lack of quality assurance
involvement in this task at this time was discussed.
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