ML20214Q442

Responds to Violation & Deviation Noted in Insp Rept 50-312/86-21.Corrective Actions:Auxiliary Feedwater Flow Indicators Will Be Upgraded to Safety Grade Prior to Restart,Per NUREG-0737,Item II.E.1.2

ML20214Q442
Person / Time
Site:	Rancho Seco
Issue date:	09/05/1986
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20214Q432	List: IR 05000312/1986021 ML20214Q442
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.1.2, TASK-TM JEW-86-436, NUDOCS 8609240359
Download: ML20214Q442 (6)

Text

$ SMU - "$l*

SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S Street. P.O. Box 15830. Sacramento CA 95852-1830.(916) 452-3211 AN ELECTRIC SYSTEM SERVING {TgE ART OF CAllFORNIA JEW $6-436 O flf D 50 September 5.1986 qq J B MARTIN REGIONAL ADMINISTRATOR REGION V 0FFICE OF INSPECTION AND ENFORCEMENT U S NUCLEAR REGITLATORY COMMISSION 1450 MARIA LANE. SUITE 210 WALNUTCREEE.CA 945%

DOCKET NO.50-312 LICENSE N0. DPR-54 NRC INSPECTION REPORT 86-21. AUXILIARY FEEDWATER FLOW INDICATION VIOLATION AND NUCLEAR SERVICE, RAW WATER DEVIATION The Sacramento Municipal Utility District hereby submits. in Attachment 1. the response to Appendix A of the subject Notice of Violation (concerning non-safety auxiliary feedwater flow indication)in accordance with 10 CFR 2.201. -

Additionally,in Attachment 2 is the District's response to Appendix B of the subject Notice of Deviation (concerning nuclear service raw water spray pond filters) in accordance with 10 CFR 2.201.

If there are any questions concerning this response, please contact Mr. Ron Colombo at the Rancho Seco Nuclear Generating Station.

JOHN E. WARD DEPUTY GENERAL MANAGER.

NUCLEAR Attachments (2) 2

$$[ $o0$ $$

O

[5 ~0

ATTACHMENT _1.

DISTRICT RESPONSE TO NRC INSPECTION 86-21 MOTICEOF VIOLATION APPENDII A VIOLATIDB As a result of the inspection conducted between June 2 and July 11.1%6. and in accordance with NRC Enforcement Policy,10 CFR Part 2. Appendix C. the following alleged violation was identified:

NRC Order 7590-10. dated March 14.1933. required in part that:

For NUREG-0737 (Clarification of TMI Action Plan Reauirements) Item li.E.1.2. the safety grade initiation and flow indication of the auxiliary feedwater system will be installed during the 1983 ref ueling outage.

NUREG-0737. Item 111.1.2. further describes that the auxiliary feedwater system flow rate indication must be consistent with satisfying the requirements of 10 CFR 50. Appendix A.

General Design Criterion 13; General Design Criterion 13 states in part:

Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation for anticipated operational occurrences, and f or accident conditions as appropriate to assure adequate safety.

Loss of off site power is an anticipated operational occurrence which will result in prolonged loss of power to instrumentation which is not provided with a Class IE power supply.

Allegedly, the auxiliary feedwater flow indication in the Control Room is not powered by a Class IE power supply, nor is it built to Class IE requirements.

This is a Severity Level IV violation.

RESPONSE

The District concurs that this is a violation of the requirements of NUREG-0737. Item 11I.1.2 in that the Auxiliary feedwater flow indicators are not currently Class 1. although their power supplies and transmitters are Class 1. As mitigating evidence of the District's actions. a historical description of the system design is provided herein.

i i

i The Auxiliary feedwater ( AFW) flow indication provided at Rancho Seco was installed with the 4 intent of satisfying the requirements of NUREG-0737. Item 111.1.2. The design which was -

i submitted to the NRC on September 18.1%1. met the requirements for safety grade (Class 1) instrumentation that existed when the plant was licensed. This design was described as part of

.'. the proposed AFY system upgrade which included the Emergency feedwater Initiation and-Control (EFIC) system. Additionalinformation was provided on July 27,1982, which committed to provide an "A" and "B" channel flow indication for each AFW line in the Control Room. The

. design,. as committed to was reviewed and accepted by the NRC's Safety Evaluation Report on

September 7.1%2. Further clarification of the District's Clas I design for the AFW flow

!- indication was provided by telecon between John F. Stoltz of the NRC and D. G. Raasch on September 16.1%2. durina which it was indicated that the District would install Class I flow indication, but that the indicators, which are the plant computer (referring to the strip chart ,

i- recorders and the current Interim Data Acquisition and Display System - IDADS) and a vall

. (back panel) indicator, all of which are located in the Control Room. would not be Class 1. Based on these assurances of the design acceptability, the District paceeded with the proposed AFW flow indication design independent of the EFIC upgrade to meet Item III.1.2 as subsequently -

ordered on March 14,1%3. The acceptability of this position was further reinforced by the post

? implementation review that was conducted and documented in NRC Inspection Report 85-21 dated August 7,1%5.

The District feels that it had taken appropriate steps to ensure that the proposed design for the

.~

safety grade AFW flow indication was acceptable to the NRC in order to meet the requirements of NUREG-0737 Item II.E.1.2.

i

}

-With regard to General Design Criterion (GDC) 13 and the ability to provide AFW flow indication during a toss of off site power (LOOP) event, AFW flow to Once-Through Steam Generator ((TISG)

- "A" and "B" are displayed in the Control Room by back panel indicators FI-31802 and F1-31902 ~

j and strip chart trend recorders. Indicators FI-31802 and FI-31902 are both powered from the '

Channel "B" vital battery backed bus. SIB. The strip chart trend recorders which trend FI-31803

and FI-31903 are powered from the channel "A" vital battery backed bus, SI A. Therefore, a loss .

J.

of off site power event would not result in the loss of AFW flow indication in the Control Room.

1 ,

j Both channels "A" and "B" of AFW flow are displayed on the Safety Parameter Display System

(SPDS) in the Control Room. ' Signals from ET-31803 (shown as computer point F%61) Channel

! "A." and from FT-31%2 (computer point F%62) Channel "B " are used to indicate AFW flow to

, each steam generator. The SPDS was originally designed to Class 1 standards (except the CRT due

. to equipment availability) since its purpose is to provide information to assist Control Room

! personnelin evaluating the safety status of the plant and is ot relied upon for automatic i actuations for plant protection. However,later NRC requirements did not require that the SPDS

be Class 1, therefore, it was installed with power from a reliable non-vital battery backed power 1

source (SIN 1). This power source is independent of the power for the wall displays and strip chart recorders in the Control Room and would be available durin g a loss of off site power event l for a finite period since these power supplies are not backed by a diesel generator.

l L

i i

P 1

---

- . .- ,_ _ _ _ .,_._ _ .-.. , - .- _ _ .__ _ _ . - _ _ _ , _ _ _ _ _ .~_ _ __-

f i In addition, all four indications of AFY flow are displayed on the non-Class 1 IDADS computer

- system in the Control Room. The IDADS computer was. designed to meet the requirements for

, data acquisition and transmission to the Technical Support Center and Emergency Operations -

Facility. It too,is powered from a reliable non-vital battery backed power supply (SIGB) which is independent of power to the wall displays and strip chart recorders in the ControlRoom and would be available during a loss of off site power event for a finite period since these power supplies are not backed by a diesel generator.

In summary, display of redundant AFW flo r indication to each OTSG is provided in the Control Room by a combination of back panel meter displays, strip chart recorders. SPDS, and IDADS computer displays. The flow instrumentation that provides the signals to these displays is Class 1 and the power supply for the displays are reliable battery backed sources that will be available durin g a loss of off site power event by either being backed by a diesel generator or being fed for a finite period by the batteries, therefore meeting the requirements of GDC 13 for Loss of Off Site Power.

The District planned from the outset of NUREG-0737, to enhance the AFW flow indication by the installation of EFIC. As part of the District's efforts to instal 16IC.the AFW flow indicatorswill '

~

be upgraded to safety grade prior to Restart. Therefore, the District feels that the design will ,

conform to the requirements of GDC 13 and will satisfy the requirements of NUREG-0737 Item 11I.1.2.

Full compliance will be achieved prior to Restart, currently scheduled for early 19E7.

ATTACHMEN11 DISTRICT RESDNSLID_MRC_INSPEIl0B_8ftZ1 NOTICE OF DEVIATION APPENDIIB DEVIATIQN As a result of the inspection conducted between June 2 and July 11,1956, and in accordance with NRC Enforcement Policy.10 CFR Part 2. Appendix C, the following alleged deviation was identified:

The licensee's Updated Safety Analysis Report Section 9.4.2.1 states in part:

Nuclear service raw water is treated with hypochlorite to prevent algae, slime, and bacterial growth, and with corrosion inhibitor, Each of the ponds has a separate chemical f eeding and filtering system ior continuous cleaning of the water, Contrary to the above, on various occasions and specifically on June 23,24. and 25,1986 the two spray pond filters were found not operating and not providing continuous cleaning.

This in a deviation. ,,.

RESPONSE

The District agrees that the cited lack of use of the filtering system constitutes a deviation from the intent of the Updated Safety Analysis Report (USAR). The administrative controls for the filtration system did not indicate that the filtration pump was to be run continuously, and those administrative controls were revised to correct that deficiency.

The District performed a special walkdown of the spray pond area as a follow-up to the NRC raised concern. There was a small amount of vegetation visible in one corner of one of the spray ponds, the water was green with algae and a thin layer of foam existed on the surface of both ponds on the down vind side. The filtration systems of both ponds were in service and were observed to automatically start and stop backflushing: however,it was noted that there was greater turbulence at the point where the east filter effluent re-enters the spray pond than existed at the corresponding location in the west pond. This indicated less flow through the west pond filter. A test was performed and the "A" recirculation pump was determined to need a new impeller and the filter media needed a fresh replacement. This work is presently scheduled to be completed during the "A" decay heat train outage in November 1986.

The NSRW systems were considered operable at the time of the walkdown of the system per Technical Specification 3.1.1.5 as a required auxiliary of the Decay Heat System.

i l

t

The District has taken several actions as a result of the walkdown to improve the operation of the spray ponds.

Administrative control and management review of the check lists (informally called the " Blue Book") used by the operators to conduct routine shift operations was formalized and upgraded by Revision 20 to AP.23 on May 8.1%6.

The Blue Book checklist was modified. since the NRC inspection. to provide a separate sign-off for recirculation and chemical addition to each spray pond. A Special Order was written which requires that the filtration system be operated on a continuous basis unless there is a high level of chlorine.~ 0perating procedures will be revised by September 30,1%6 to reinforce the administrative control of the Blue Book so that the filtration system, for both spray ponds. is operated routinely enough to keep the system clean and ready for use and to provide additional '.

guidance on conditions to observe at the spray ponds. This usage is consistent with the USAR.

Appropriate management attention is being given to the revised AP.23 to assure that the procedure is being properly implemented.

The chemical. limits which were established for the spray ponds are under evaluation. The limits will be upgraded by December 29,1986, so that there is enough chlorine present to control the algae and still comply with the Water Quality Board requirements.

As part of the corrective actions taken by the District, an investigation of other open systems -

that require chlorination to control algae was performed. Only the Plant Cooling Water and Circulating Water Systems are designed to receive chlorination as an algal control measure.

. Plant Cooling Water is adequately chlorinated by the observation that no biological growth was found in any of the heat exchangers serviced by that system. Circulating water has a chlorination schedule geared to operating conditions; the successful elimination of algae is observed by operating personnelinvolved in the chlorination procedure. Long term biological fouling of these water circuits by Asiatic Clams is prevented by inspection under a surveillance procedure (SP 212.01 A).

A review of the outstanding work requests on the NSRW was performed in the week of June 30 1986 and those that could be completed without a system outage were worked off. The remaining work requests are being factored into the upcoming decay heat outages, which are scheduled for November 5 through December 29,1986.

1 i

i l <

i i

i

- -_-.- - -..