ML20214M248

Insp Rept 50-312/86-22 on 860610-0725.Violation Noted: Records of Surveillance & Calibr Tests Stored in Metal Cabinet W/Fire Rating of Less than 2 H

ML20214M248
Person / Time
Site:	Rancho Seco
Issue date:	08/25/1986
From:	Andrew Hon, Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20214M228	List: ML20214M226 ML20214M239 ML20214M248
References
50-312-86-22, NUDOCS 8609110026
Download: ML20214M248 (6)

See also: IR 05000312/1986022

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+ U. S. NUCLEAR REGULATORY COMMISSION

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REGIONIkT,

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Report No. 50-312/86-22 , , j; ; .

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Docket No. _50-312 .,

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License No. DPR-54 m.

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Licensee: Sacramento Municipal Utility-District' s

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-P. 0. Box 15830 *

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Sacramento, Califor.nia,.95813 4

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Facility Name: Sacramentio Municipal Utility District (SMUD)

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. . Inspection Conducted: June 10 - Ju,y'25, 1986-

Inspected by: O' *d

A. Ron, Reactor Inspector

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Date Signed

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Approved by: rjpa J e N /d

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L. Miller, Chief, n'e actor Proj4 cts.Section Date Signed

Summary:

Inspection on June 10 - July 2'5,1986 (Report No. 50-312/86-22) ,

. Areas Inspected: Routine unannounced inspection by one regionally based

inspector-of licensee calibration program, licensee event reports and open

items. Inspection procedures 56700, 39701, 41400, 71707, 90712, 92701 and

92703 were performed.,

Results

.In the areas inspected, one violation was identified. This- ' '

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. violation concerned failure to store surveillance records according to Quality. 4

j. Assurance requirements.

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8609110026 860826

r- PDR ADOCK 05000312

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DETAILS

1. Persons Contacted (Licensec Personnel)

• J. McColligan, Assistant Manager, Nuclear Plant

• T. Tucker, Superintendent, Nuclear Operations

• M. Price, Superintendent, Nuclear Mechanical Maintenance

• F. Kellie, Superintendent, Radiation Protection

• C. Stephenson, Senior Regulatory Compliance Engineer

• C Linkhart, Superintendent, Electrical Maintenance

• L. Fossum, Superintendent, I&C Maintenance

J. Irwin, Supervisor, I6C Maintenance

N. Thibodaux, Surveillance Scheduling Engineer

R. White, Electrical Engineer

• D. Reese, Regulatory Compliance Engineer

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J. Jewett, Supervisor, Site QA

2. Calibration Program

The objective of this inspection is to ascertain whether the licensee has

developed and implemented a program for the calibration of plant-

instrumentation that is in conformance with license requirements,

technical specifications, and licensee commitments.

a. Frequency of Calibration

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In order to meet the periodic instrumentation and safety system

calibration requirements of'the Technical Specifications, the

licensee developed a Master Schedule for surveillance to plan and

track the calibration activities. The Master Schedule specified and

tracked individual,"SP" series procedures for'each item listed in

section 4 of the Technical Specifications. It is a manual system

maintained by the Technical Support Department. The inspector

reviewed this system for selected instruments and safety systems

listed in the Technical Specification and found~that the frequency

requirements for functional tests and calibrations were properly

, defined.

, No violations or deviations was identified.

b. Calibration Procedures

While the Technical Support Department assumed the overall

programmatic responsibility of the calibration program, the actual

calibration work was performed by other departments under different,

procedures. A typical calibration task was initiated by Technical

Support according to the Master Schedule frequency with a "SP"

procedure. The "SP" procedure in turn called for another procedure,

usually an "I" series procedure which was developed and maintained

by the Instrumentation and Control (I&C) group. The actual

calibration was performed by I&C under the "I" procedure. Upon the

completion of the calibration, the "I" procedure was reviewed by an

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I&C engineer. - This in turn satisfied the "SP". procedure and the

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calibration requirement was considered met by' closing out the "SP"

procedure. The inspector reviewed a sample of both type of

. procedures for selected systems:to verify that:

the test' documentation was complete,

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acceptance criteria had been met,

' . properand approved test procedure was used,

limiting conditions for, operations were recognized and~, met-

during the performance'of'the procedure,

. test instruments used'were ' documented, '

-proper controls were placed on the processes.by which

components are removed and return to service,

the pointe of' signal insertion and signal readout were

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The' technical content of the proceduresireview appeared to be

adequate. However,.some of the data sheet did not require "as

found" values to be recorded, whih.h could be useful for trending

instrument setpoint drifts. Furthermore,'the-use of two procedures,- 3

"SP" and "I", appeared to be cumbersome. .The licensee was in the

process of rewriting all surveillance and~ calibration procedures

according to the recently implemented procedure AP.-303A " Writer

Guide for. Surveillance Procedures." It is expected the above

weakness will be corrected.

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The licensee allowed for temporary changes to the procedure during

calibration, provided that the change was concurred in'by the shift

supervisor and approved by the. Plant Review Committee-in-7 days.

3, ime changes would later be incorporated into revisions to the

procedures as aecessary. Before the temporary changes.became a

permanent revision, it was attached only to the controlled copies of

the procedures at the control room and central procedure file.

, However, since controlled copies of the procedure existed in other

p ' places throughout the plant, until the. procedure was revised, other

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technician performing calibration might.not be aware of the

'cemporary changes and resulting work m'ai not be performed in

accordance with the latest specification. The licensee. agreed to

"G evaluate and' resolve this weakness.- This item will be followed as

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.[1r; an open item during future inspections (86-22-01).

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No violation or deviation was identified.

c. Record Retention

The inspector found that the completed "SP" procedures were kept in

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y, file drawers of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rating in the Administration Building,

and the completed "1" procedures which documented the details of the

calibration, were kept in metal office file cabinets in the I&C

shop. This p"ractice apparently violated the licensee's QA procedure

established to meet the 10 CFR 50 Appendix B Criteria XVII

requirement,on QA Records requirements. In addition, a deviation

for the same concern was identified during NRC Inspection

ll (50-312/80-34). The licensee responded to this deviation in a

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l'etter dated September 3, 1980. .In this. "esponse the licensee

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stated that surveillance records woul? ae stored in the to be

constructed Document' Control Center cecord storage facility by the

end of 1982. The above referenced space, a record storage vault, .

was constructed in the newly constructed Training and Record Building

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which has been in service for a year. However, the deviation of

not having surveillance records properly stored was still not

corrected in that the surveillance records were not being stored

in the new records vault.

This is an apparent violation (86-22-02).

d. ' Calibration of Safety-Related Instruments Not Specifically

Controlled by Technical Specifications

The Technical Specifications do not spec.ify calibration requirements.

for all instruments. Yet, in order for the plant to operate within

i technical specification requirements and respond to abnormal plant

conditions, operators are required to monitor various plant

parameters. Thus, a formal system to control and evaluate

calibration of these safety-related instruments is prudent.

During a previous inspection, the inspector found that the

licensee's preventive maintenance and calibration program primarily

covered only instruments identified in section 4 of the Technical

Specifications.- The licensee committed to establish a program to

identify thost instruments needed for technical specification

condition compliance and abnormal conditions, and to include them in

the master calibration schedule before restart (0 pen item 86-17-02).

During this inspection, the inspector found that the licensee

initiated an effort and identified 68 instruments listed in the

casuality and operations procedures not previously in the preventive

maintenance (PM) program that will be added to the PM program. The

inspector considered the licensee's effort to be responsive and will

further review this Open Item during future inspections.

No violation or deviation was identified.

e. Qualification Standards for Personnel Conducting Calibrations

The licensee's technical staff involved in calibration activities

appeared to have met the ANSI N18.1 qualification standards.

However, until recently the licensee training program for

technicians was mostly on-the-job training rather than a well

defined formal training program. The licensee recently developed a

training program and submitted it to INPO for accreditation. This

program was a combination of formal class and on-the-job training.

It appeared to be more well defined and standardized than the

current qualification program.

No violation or deviation was identified.

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Licensee Event. Report (LER) Followup-

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The following LERs_were reviewed for conformance with the 10 CFR 50.73

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LER 85-18, - Rev. 1. / ',' Emergency Diesel Generator,0utput Breaker

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LER 85-25, Rev..:1., '" Reactor l Trip:Following, Loss of.ICS Power"

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LER 86-01, Rev. 0 (" Emergency,DG.A.and B Declared Inoperable -

_( Closed) LDuring Cold Shutdown" '

LER86-02,Rev.-1["PinholeLeaksinCasingDrainLinefor-?B'

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.(0 pen) i Decay Heat Pump '

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LER'86-05, Rev. 0, ~" Seismic Spacing of Nuclea'r Service Batteries"-

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(0 pen)

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LER 86-06, Rev. O "FireProtectionSystembyerduefor

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(Open) Surveillance"

LER 86-07, Rev. O. " Control Room Emergency HVAC High Flow

(0 pen) Condition"

LER 86-08, Rev. O " Failure to Institute Fire Watch for Breached

(0 pen) Penetration"

LER'86-09, Rev. O " Spurious Engineered Safety Feature Systems

(Closed) Actuations"

LER 86-10, Rev. O " Redundant Cabling in the Same Fire Area"

(0 pen)

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The reporting requirements were generally met, Licensee's follow up

actions' addressed in these LER's will be reviewed during future

inspections.as necessary. LER 86-01 and LER 86-09'were closed-based on-

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in-office review only, the remaining LER's will be closed pending future

inspections.

The following LER's were also closed during in-office review previously-

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and are documented in this report for close out.

LER 84-17 " Core Flood Tank Vent Valve Not Disabled per Tech. Spec."

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LER 84-01 " PASS Ventilation System Fan Bearing Failure"

(Closed)

No violation or deviation was identified.

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L4. - Followup Items

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'a . Unresolved Item 83-17-01 (Closed) " Spent Fuel Pool Leakage"

Summary of Previous Inspection:

In 1983, borated water was found leaking through a spent fuel pool

weld' and backed up between the spent fuel pool stainless steel liner

and the concrete support structure.- This acidic water then, leaked

through-construction joints in the concrete and out of the west and

east walls to the environment. The contamination level on the

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concrete walls-was about 2000 dpm and not a serious radiological. -

p roblem. _ The cause of the-leaking through the concrete was

determined to be leakage through the' weld and lack of an operable -

drain line to divert the fluid accumulated between the lining and

the concrete wall. The licensee committed the following corrective

actions:

Diverting the leakeu water to some collcction system, such as

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the Reactor Ccolant System. Drain Tank (RCDT), rather than

allowing the water to back up in the space between the liner-

and the concrete structure.

As part of the spent fuel pool re-racking effort, inspect all

spent fuel pool welds an,d patch _ leaks. This would assure the

liner to be leak-tight.'

Install a flow meter in.the{ drain line to the (RCDT) so that

the amount of' leakage can be quantified and any increase to the

. leakage can be detected.

During this inspection,.the' inspector reviewed'the licensee's '

completed work package ECN No. A-3601 for spent fuel rack

replacement which 'also ' included th'e inspection 'and ' repair of leaks

in the stainless steel pool liner. The inspector also reviewed the

licensee's completed package ECN No. A-3198 for the installation of

flow glass FG 27209 and flow meter FQI 27209 on -the drain line.

Finally, the inspector verified that these flow indicators were

incorporated into the operator's logs. Based on these reviews, this

item is resolved and closed.

b. Followup Item 80-34-01 (Closed) " Permanent Record Storage Facility"

This item is closed as an open item because it has been addressed in

section 2.c of this report.as an apparent violation and the

licensee's corrective action will be evaluated (86-22-02).

c. IE Bulletin 83-08 (Closed) " Electrical Circuit Breaker With An

Undervoltage Trip Feature In Use In Safety-Related Applications

Other than the Reactor Trip System"

In~ response to the Bulletin's request, the licensee informed the NRC

by a letter dated March 22, 1984, that the electrical system was

reviewed to determine if Westinghouse type DB or DS breakers or

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General Electric type AK-2 breakers were in use in safety-related

functions, other than Reactor Trip Breakers. The. result of this

review was that there are no breakers of the type under concern,

except for the six GE AK-2 breakers .in use as Reactor Trip Breakers,

which were addressed in the licensee's response to Generic Letter 83-28.

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The inspector reviewed the licensee's response and considered this 1

item closed.  !

No violation or deviation was identified.

5. Exit Meeting

On July 10, 1986, an exit meeting-was; conducted with the licensee

representatives identified in paragraph 1.-.The inspector summarized the

scope of the inspection and findings as described in this report.

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