ML20199A588

Responds to NRC Re Violations Noted in Insp Rept 50-312/97-01.Corrective Actions:Reviewed SFP Water Temp & Instrument Calibr Records,Generated Otr 97-001 to Document out-of-tolerance Instrument & Generated Pdq 97-0064

ML20199A588
Person / Time
Site:	Rancho Seco
Issue date:	11/10/1997
From:	Redeker S SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-312-97-01, 50-312-97-1, MPC&D-97-167, NUDOCS 9711180022
Download: ML20199A588 (5)

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• SAk:RAMENTo MUNICIPAL UTIUTY ttST.dcT O P. O. Box 15830, Sacramento CA 95852-183o, (916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA c

t MPC&D 97-167 November 10,1997 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk

- Washington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RESPONSE TO NOTICE OF VIOLATION 97-01 Attn.: Document Control Desk In NRC Inspection Report 50-312/97-04, dated October 21,1997, the Sacramento Municipal Utility District received a Notice of Violation regarding activities at Rancho Seco Nuclear Generating Station. In accordance with 10 CFR 2.201, we are providing t!.s attached response.

This letter acknowledges the violation cited, and descibes the corrective actions taken. If you, or members of your staff, have questions requiring clarification or additional information, please contact Bob Jones at (916)452-3211, extension 4676.

Sincerely, .

gg Steve Redeker Manager, Plant Closure and Decommissioning

~ cci Seymour Weiss, NRC, Rockville E.R. MerschotT, NRC, Arlington, Texas

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9711190022 971110 7

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-- o .c g . g RANCHO SECO NUCLEAR GENERATING STATION C) 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333-2935

. RepIy to Notice of Violation 97-01

$RC Statemo,nt of Violation 10 CFR Part 50, Appendix B, Criterion V, states that activities afTecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Rancho Seco Procedure 1.090, Revision 5, entitled " Instrument Calibration Instruction,"

Section 2.4.1, states out-of tc,:erance as found values require submittal of are out-of-tolerance report per Procedure MAP-0023. Rancho Seco Procedure MAP-0023, Revision 6, entitled " Maintenance Calibration Program," Section 6.4.2, states, in part, that the maintenance technician shall fill out Attachment 2, " Installed Instrument Out-of-Tolerance Report," for each equipment / instrument with out-of-tolerance as found conditions.

Contrary to the above, on August 6,1997, the thermocouple for the spent fuel pool temperature indicator was found to be out-of tolerance during annual calibration. No out-of-tolerance report was completed.

T his is a Severity Level IV violation (Supplement I).

District Responee Admission or denialof violation The District acknowledges that the violation occurred as stated.

Reason for the Violation The reasori for the incident is that, when evaluating the need to submit an Out-of-Tolerance Report (OTR), an I&C technician relied on his urderstanding of an administrative precedure rather than actually referring to the procedure. The technician concluded, erroneously, that he did not require an OTR.

Discussion of the Violation In accordance with Surveillance Procedure SI'.2 " Daily Instrument Checks and Systems Verification," Operations documents the spent fuel pool bulk coolant temperature on a daily basis. On August 5,1997, Operations recorded the spent fuel pool water temperature at 73* F. The following day, Operations recorded the spent fuel pool water i

Reply to Notice of Violation 97-01 temperature at 87* F, an increase of 14* F. Engineering analysis of the heat load in the spent fuel pool had previously concluded that if the spent fuel pool loses cooling, the water temperature would increase by approximately 2*F per day.

When the shin supenisor noticed the unusual inciease in temperature, he immediately verified the water level in the spent fuel pool. ARer confirming that the water level remained at an acceptable level, the shin supenisor contacted hiaintenance. hiaintenance informed the shin supenisor that they had just completed the annual calibration of spent fuel pool temperature indicator TISH-27205. During the calibration, a Maintenance I&C Technician noticed that an electrical connection on the thermocouple had been loose. The I&C technician tightened the connection during the instrument calibration.

The shin supenisor also notified the Operations Superintendent of the increased indication in the spent fuel pool water temperature. The Operations Superintendent, in tu.u, notified the plant manager. On August 7,1997, the Operations Superintendent raised the issue at the Plant Review Committee (PRC) meeting, while discussing general plant operational issues. The PRC assigned Technical Services to evaluate the abnormal rise in the spent fuel pool water temperature indication.

Technical Senices reviewed spent fuel pool water temperature and instrument calibration records. Based on their review, Technical Senices concluded that, accounting for the instrument error and previous calibration results, there had been no time when the spent fuel pool coolant temperature would have exceeded any Technical Specification action levels.

Review of the work request used to calibrate the instrument showed one "As Found" value out-of-tolerance. Plant Maintenance hianual procedure I.090 " Instrument Calibration Instruction," requires that out-of-tolerance As Found values require the submittal of an Out-of-Tolerance Report (OTR) per Maintenance Administrative Procedure MAP-0023 " Maintenance Calibration Program." l MAP-0023, Section 6.4.2 requires that if plant equipment used to verify the acceptance criteria in plant surveillance procedures is out-of-tolerance, then Maintenance must write an OTR. The intent of an OTR is to identify out-of-tolerance instruments and initiate corrective actions, as appropriate.

In addition, MAP-0023, Section 6.3.2.2 requires that Maintenance write a Potential Deviation from Quality (PDQ) for any As Found data that is out of tolerance on any operable system, as listed in Plant Operations Manual procedure B.10 "Defueled i Condition " A PDQ is the baseline document for the Rancho Seco Corrective Action Program. Rancho Seco stafTuse PDQs to identify, document, evaluate, and correct actual or potential deficiencies.

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Reply to Notice of Violation 9l-01 Because TISH-27205 is used by surveillance procedure SP.2 to verify that the spent fuel pool water temperature meets Technical Specification requirements, hiaintenance should have generated an OTR in accorc'ance with htAP-0023, Section 6.4.2. In addition, since TISH-27205 is part of the Spent Fuel Cooling (SFC) system, and SFC is defined as Operable in Plant Operations hianual procedure B.10, hiaintenance should have generated a PDQ in accordance with hiAP-0023, Section 6.3.2.2.

Contrary to procedural requirements, no one in hiaintenance generated an OTR or PDQ.

hiAP-0023 provides the criteria for the instruments that require an OTR or PDQ; however, hiAP-0023 does not list specific pieces of equipment or instrumentation.

Accordingly, I&C Technicians must evaluate all out-of-tolerance equipment against the criteria in hiAP-0023. The I&C Technician performing the instrument calibration did not refer to hiAP-0023 to evaluate the ir,trument against the criteria. Rather, he relied on his understanding of the criteria, and concluded, erroneously, that the instrument did not meet the criteria for generating a PDQ and OTR.

Corrective Steps Taken and Results Achieved On August 7,1997, the PRC assigned Technical Services to evaluate the abnormal rise in the spent fuel pool water temperature indication. The actions initiated by the PRC resulted in Technical Services taking the same actions they would have had hiaintenance initiated an OTR Technical Sersices reviewed spent fuel pool water temperature and instrument calibration records. Based on their review, Technical Sersices concluded that, accounting for the instrument error and previous calibration results, there had been no time when the spent fuel pool coolant temperature would have exceeded any Technical Specification action levels.

ARer becoming ante of the procedure violation, on September 25,1997, hiaintenance generated OTR 97-001 to document the out-of-tolerance instrument. hiaintenance also generated PDQ 97-0064 to document that they had not generated either a PDQ or OTR initially, as required by hiAP-0023.

Plant management determined that the incident constituted a Deviation from Quality.

Plant management assigned hiaintenance to determine the cause and extent of the problem, and determine appropriate remedial and corrective actions to p. event recurrence.

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4 Reply to Notice of Violation 97-01 Corrective Steps to Avoid Further Violations Maintenance conducted training for Mainterance personnel en the PDQ 97 0064 issues, including the reporting requirements in MAP-0023. The training emphasized the requirements for evaluating out-of-tolerance conditions, and OTR/PDQ requirements. In addition, the training stressed the need to comply with all procedural requirements, and to

- obtain and use procedures that are referenced rather than relying on one's memory of the procedure.

.r Although the current procedures are adequate, Maintenance is reviewing these procedures to determine if they can make enhancements to simplify the process for a technician to determine whether an OTR or PDQ is required.

Date When Full Compilance will be Achieved Maintenance conducted procedure training on November 6,1997, and achieved full compliance on that date.

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