ML20129D519

Insp Rept 50-312/85-08 on 850314-0503.Violation Noted: Seven Drawings for Auxiliary Bldg HVAC Sys Not Identified for Updating on Ncr 4433,Rev 1 & Battery Testing Procedures Contained Errors & Incorrect Data

ML20129D519
Person / Time
Site:	Rancho Seco
Issue date:	06/17/1985
From:	Eckhardt J, Miller L, Perez G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20129D482	List: IR 05000314/2005003 ML20129D478 ML20129D519
References
50-312-85-08, 50-312-85-8, NUDOCS 8507160557
Download: ML20129D519 (8)

See also: IR 05000312/1985008

Text

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U. S. NUCLEAR REGLILATORY COMMISSION

REGION V

Report No.: 50-312/85-08

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 conducte .

March,4,-May},1985

Inspectors: ./ & 6) [/7[

J . vH~ Eckha rdt;, e

lor q9sident Inspector Date Signed

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Dat'e Signed

crez, i ntyspector

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Approved by: / / t- ol b/I7/1

Date Signed

L. f].' Miller Jri,/Cnief

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Reactor Projects, Section 2

Summary:

Inspection between March 14-May 3, 1985 (Report 50-312/85-08)

Areas Inspected: This routine inspection by the Resident Inspectors involved

the areas of operational safety verification, observation of refueling

activities, evaluation of the battery. maintenance program, surveillance,

maintenance observations, and procedure reviews. This inspection involved 330

hours onsite.by-two resident inspectors.

Results: Of the areas inspected, two violations were identified: one

violation in the area of battery maintenance and testing, and one violation in

the area of nonconformance reports.

Also, one unresolved item in the area of battery testing was identified.

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, , DETAILS

Persons' Contacted'

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a '.' "L'icdnsee Personnel -.

• P. Oubre', Manager of Nuclear Operations

• G. Coward, Plant Superintendent

• H. Canter, QA Operations Surveillance Supervisor

• R. Colombo, Regulatory Compliance Supervisor

• W. Spencer, Operations Superintendent

• S. Crunk, Regulatory Compliance Engineer

• J. Field, Engineering and Quality Control Superintendent

• R. Lawrence, Mechanical Maintenance Supervisor

• R. Miller, Chemistry and Radiation Protection Superintendent '

• S. Redeker, Shift Technical Advisor Supervisor

• J. Jewett, Site Quality Assurance Supervisor .

• J. ' Williams, Supervising I&C Engineer

• D. Yount, Electrical Superintendent

• J. Wheeler, Electrical Engineer

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• A. Lacy, Startup

• J.

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Irwin, Instrumentation & Control

, * Attended the Exit Meeting on May 3, 1985.

2. Operational Safety Verification

On March 15, 1985, the licensee commenced a ninety day outage. The

outage.will include:

Partial refueling of core.

Steam generator eddy current testing, tube pulling, and

plugging.

Auxiliary boiler tube replacement.

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Turbine inspection.

Main generator inspection.

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Heating ventilation ard air conditioning modifications for the

control room, technical support center, and nuclear service

equipment building.

Feedwater heaters inspection and tube plugging.

Reactor coolant pumps B and D seal replacement.

10 CFR 50, Appendix R modifications.

Letdown piping modification and cooler replacement.

During the report period, the inspectors observed control room

operations, reviewed applicable logs, and interviewed control room

operators. The inspectors verified that surveillance tests required

during the shutdown were accomplished, reviewed clearance records, and

verified containment integrity. Tours of the auxiliary building, turbine

building, fuel handling buildings, and reactor building, including

exterior areas, were made to assess equipment and plant conditions.

Also, the tours were made to assess the effectiveness of radiological

controls and adherence to regulatory requirements. This includeo reviews

of Radiation Work Permits (RWP) for ccmpleteness, protective clothing

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requirements, and verification that workers understood the RWP's

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requirements. The inspector monitored the administrative controls for

exposure, approval, and reviewed selective dosimetry cards for accuracy of

accumulative dose. During tours of controlled access areas for recalibration

, dates of selected portable radiation detectors and friskers were verified to

. be valid.

The inspectors observed plant housekeeping and looked for potential fire and

safety hazards. .The inspectors informed the licensee of cases of improper

safety eye-wear, and eight filled nitrogen gas tanks unrestrained, and left on

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their sides on-top of the Auxiliary Building. The licensee took immediate

corrective: action for all cases.

No violations or deviations were identified.

3. Refueling Activities

Refueling (fuel movement) commenced oa April 19, 1985 and was completed

on April 30, 1985. Prior to fuel movement the inspectors verified that l

the surveillance testing required for refueling had been completed.

During a review of Refueling Procedure B-8, prior to refueling, the

inspector noted an error in the procedure. This is further discussed in

Section 7 of this report. The licensee corrected this procedure prior to ,

refueling. Also, prior to refueling, the inspector reviewed the reactor

cavity seal plate design. The seal plate at Rancho Seco is a mechanical

type seal; a steel ring and gasket bolted in place.

The inspectors witnessed approximately fourteen hours of actual refueling

p activities. During these observations, the inspector verified:

• Containment integrity was maintained in accordance with the

Technical Specifications.

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Communications were as required.

• Refueling cavity water level was as required.

Boron concentration was in-accordance with Amendment 126 to the

Technical Specifications. -

The licensee',s staffing was as required.

, During refueling, the refueling equipment had reliability problems and a

plastic cover from an underwater light was lost. Numerous malfunctions

in the refueling bridge and.the fuel transfer mechanisms occurred both

prior ~to;and during fuel movement. The licensee's actions to correct

these problems appeared to be adequately controlled. During fuel

movement, an underwater' light was lowered into the refueling cavity with

the clear plaatic light cover not properly retained. The cover was lost

during the operation,-and was finally' located (with a camera) at the

bottom of the reactor vessel. The licensee has contracted with General

Electric to ascertain the effect of not removing the plastic cover.

The activities in the spent fuel storage area were also evaluated during

refueling. This included verification that the spent fuel area

ventilation system was operating, minimum water level requirements, and

radiation and airborne radioactivity monitors were operable.

No violations or deviations were identified.

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4. Battery Maintenance, Surveillance, and System Walkdown

The inspector reviewed the Technical Specifications surveillance

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requirements for the safety related station batteries. The surveillance

program was defined by procedure SP 206.04, Rev. 6, " Testing of Diesel

s Engine Batteries and 125 volt D.C. rystems," and implemented by

procedures EM. 104 Rev. 8, " Station Battery Pilot Cell Test", EM.105 Rev.

11," Station Battery I.C.V., Specific Gravity and Temperature Test,"'and

EM. 106 Rev. 4, " Station Battery Test Discharge and Equalize Charge".

The inspector identified errors or weaknesses in the procedures,

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exemplified by the following:

a'. EM.104 Rev 8: Section 5.2.1.,' pilot cell criteria for

performing equalizing charges, required a

comparison of specific gravity measurements of

the pilot cell, yet specified a difference in

cell voltage as the acceptance criteria, instead

of a specific gravity measurement.

b. EM.105 Rev. 11: Section 5.3 required an equalizing charge when

any battery cell's voltage fell below the

average voltage for the battery by .005 volts.

This was'apparently an error since recording of

cell voltage was only performed to two decimal

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It was noted.that the procedure listed,some but

not all criteria for an equalizing charge, e.g.

the procedure did not require an equalizing

charge when specific gravity of a cell was below

1.210 points.

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c. EM.106 Rev. 4 The procedure did not specify the step

which was to be used when starting an equalizing

charge (without' performing a test discharg~e

first). Thus the correct starting. step was

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ambiguous.

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'After an ' equalizing charge has been performed

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and completed, no confirmatory measurement of

}' pilot cell specific gravity or cell voltage was

- requi.r'ed to ensure.that the equalizing charge

was effectiv5.

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The' pro'cedure does not detail all the possible

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criteria for an equalizing charge.

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The resdits of the battery, tests from January 2, 1985 thru April 22,

1985,'eighty-four separate documents, were reviewed to verify that they

were in conformance with technical specifications and procedure

requirements. Also,athe results.were reviewed for indication of a second

level review by personnel other.than the individual directing the test,

to ensure that deficiencies identified during testing were properly

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reviewed and resolved. ;The inspector identified the following errors

'during this review:

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• Six instances of conflicting dates on the. weekly s

a storage battery report, so that the date on

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which the data was collected was ambiguous.

• Eight instances of arithmetic mistakss in

a calculating. temperature corrected ~ specific

gravity.

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Two cases of not recording the pilot cell number.

on the weekly report. ,

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Fourteen instances of the wrong pilot cell used

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for the weekly test.

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'* Three instances where an equalizing charge

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should have been applied but was not.

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• On'e instance of SP 206.04's weekly record sheet-

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^ - (week of;1-7-85) recording a weekly result-

3 twice,,opce as unsatisfactory and the other as-

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< satisfactory.

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Technical Specification 6.8 " Procedures" requires in part that: " Written

procedures ~shall be' established,-implemented and maintained covering'the

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. activities preformed below: .... c. Surveillance and test' activities of .

safety related equipment" Also Technical Specification 4.6.4 requires in

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. part that: " Batteries in the 125 volt DC systems shall be tested as

2follows': ...c." Eachitime data are? recorded, new data shall be compared

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- - - 'with old to-detect: signs of deterioration"

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Contrary to the'above,.the procedures for battery testing (SP 206.'04,

. EM. 104, EM. 105, and>EM'106)' contained numerous procedural' errors, and

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incorrect' data. In certain cases, these directly resulted in an

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. inaccurate comparison of the new test data to the_old. data.1This is a

Severity I,evel IV violation (50-312/85.-08-01).

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In accordance with procedure EM 106 the licensee performs a' duty cycle

discharge test on'a refueling outage' interval. This involve:: discharging

- the batteries-for a load *and. time period equivalent' to the time.and load

, experienced during the worst case design accident. The inspector

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reviewed a portion of the most recent test results and fou'nd the results

in' compliance with the procedures.- However, Technical Specification

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.4.6.4.D requires the 125 volt'DC. system be tested: . . . '.'During each

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refueling interval, the battery shall be subjected to;a rated load or

- equivalent test...." This test is explained in the Technical

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' Specification Bases.as a surveillance ..... which has been demonstrated

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over the years.to provide an indication of a cell becoming unserviceable

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long before it fails." It is not clear that the licensee's duty cycle

. discharge ~ test presently'provides information to determine whether the

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battery meets its specifications or rating and whether the battery rate

. of deterioration is increasing, even if there is ample capacity to meet

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the load requirements. The licensee has committed to address this

concern.

. This is considered an unresolved item. (50-312/85-08-01)

In addition to this evaluation of the battery surveillance and

maintenance program, the inspector performed a walkdown of the system

including the battery chargers. The physical and cleanliness condition

of the rooms and equipment was satisfactory. No violations or deviations

were identified during the walkdown.

5. NRC Headquarters Request

The inspectors were requested by NRC Headquarters to review the

licensee's actions involving a safety issue addressed in IE Information

Notice 84-06, " Steam Binding of Auxiliary Feedwater Pumps." The notice

dealt with the safety implications of back leakage into the auxiliary

feedwater (AFW) system from the main feedwater systems. This leakage

could constitute a common made failure that could lead to the loss of AFW

capability and, further, lead to the potential for water hammer damage to

the AFW system piping.

The licensee has never experienced any steam binding of the AFW pumps due

to back leakage, indicating adequate check valve reliability in the AFW

system. The licensee perfo,ms periodic check valve full stroke tests and

has started a' program.for visually inspecting the check valve intervals

by inserting a fiberscope through the drain valve. Furthermore, the

licensee also monitors the temperature of the AFW pump casing for

detection of potential back leakage. The Equipment Attendant is required

to physically touch the pumps casing and record the relative temperature,

(hot or cold), in the shift logs.

It appears, that the licensee's experience to date indicates adequate AFW

system check valve reliability, and the periodic surveillances and checks

provide early indication for assessing-main feedwater system back leakage

into the'AFW piping and pumps. This item is closed.

6. Maintenance Observations

The inspector evaluated or observed portions of the maintenance

activities listed below, verified that work was accomplished in

ed procedures, by qualified personnel, and that LCO

accordance with'approv,during

requirements were met the repairs:

Feedwater heater repairs.

• Main feed water pump overhaul.

• Main fuel handling bridge repairs.

' OTSG tube eddy current testing.

"A" Diesel Generator-biannual inspection.

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No violations or deviations were' identified.

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7. Independent Inspection' ,.

The inspectors reviewed the Technical Specification definitions for cold

shutdown, and discovered,that prior to Amendment No. 61 the definition

contained an incorrect reference. The definition referenced Technical

Specification 3.2.1, which should have been Specification 3.1.2. The

licensee was informed of this error, and took corrective action. The

inspector reviewed previous amendment changes issued from the NRC and

found no indication of the error. Therefore, it appeared that the error

occurred in the-licensee's process of preparing approved amendments for

issuance into the control copies of the Technical Specification.

The inspector also noted errors in the following procedures:

B-8 " Refueling" Rev. 12, contained errors in enclosure 5.3,

Containment Isolation Valve Lineup, regarding incorrect numbers

for penetrations.

Survellance Procedure SP 205.07 referred to a surveillance

procedure that had been deleted in 1981. This is discussed in

more detail in Section 6.c of Inspection Report 50-312/85-04.

The errors in the battery maintenance procedures as discussed

in Section 4 of this report.

The inspectors stated that the licensee should emphasize to the procedure

users to appropriately identify types of errors. This is considered an

open item (50-312/85-08-01).

8. Review of Nonconformance Report on HVAC System

The licensee is modifying the present Heating, Ventilation and Air

Conditioning (HVAC) for the control room and integrating the system with

the HVAC for the Technical Support Center. During the testing of the

refrigeration system, many leaking joints and valves were noted. NCR

4433, Rev. I was issued to' repair two cracked valves, HVS-012 and

HVS-005; the cracks were located at the socket joint area of the valve

bodies. The licensee believes the cracks were caused by temperature

transients due to brazing operaticas on the socket.

The licensee dispositioned this NCR for repair action involving the

removal of these valves from the system. The valves' function was to.

provide isolation of the external piping from the internal components in

the refrigeration units to minimize refrigerant loss during maintenance.

Therefore, the removal of these valves will not affect the operation of

the system.

In reviewing the NCR, the inspector-noted that the disposition would

involve the revision of approximately seven drawings. Quality Control

Instruction No. 1 (QCI 1) " Processing of Nonconforming Reports-NCRs"

states in part: " ...The assigned cognizant engineer is responsible for

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identifying ori the NCR all. associated drawings- that must be updated as a

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result of his disposition."'

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Contrary to the ab'ove, the dispositio'n of NCR 4433, Rev. I required

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removing valves HVS-012 and HVS-005 from the system piping of condensing

units U-545A and U-545B~for the Auxiliary Building's Heating, Ventilation

and Air Conditioning' System. This involved the update of seven drawings.

These drawings were_not identified as required on NCR 4433, Rev. 1..This

is a Severity Level V. violation (50-312/85-08-02).

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9. . Exit Meeting :

.The inspector met with licensee management personnel denoted ~ in paragraph

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. I at the conclusion-of the: inspection on May 3, 1985. The scope,

observations, and finding of the inspection were discussed.

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