IR 05000312/1986021: Difference between revisions

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{{Adams
{{Adams
| number = ML20206N631
| number = ML20214Q430
| issue date = 08/07/1986
| issue date = 09/18/1986
| title = Insp Rept 50-312/86-21 on 860602-0711.Violation & Deviation Noted:Auxiliary Feedwater Flow Indication in Control Room Not Powered by Class 1E Power Supply,Nor Built to Class 1E Requirements
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-312/86-21
| author name = Miller L, Myers C, Perez G
| author name = Kirsch D
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
| addressee name =  
| addressee name = Ward J
| addressee affiliation =  
| addressee affiliation = SACRAMENTO MUNICIPAL UTILITY DISTRICT
| docket = 05000312
| docket = 05000312
| license number =  
| license number =  
| contact person =  
| contact person =  
| case reference number = RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.1.2, TASK-TM
| case reference number = RTR-NUREG-0737, RTR-NUREG-737
| document report number = 50-312-86-21, IEB-85-003, IEB-85-3, IEIN-85-074, IEIN-85-74, IEIN-86-029, IEIN-86-29, IEN-86-29, NUDOCS 8608260330
| document report number = NUDOCS 8609240355
| package number = ML20206N592
| title reference date = 09-05-1986
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| package number = ML20214Q432
| page count = 15
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 1
}}
}}


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U. S. NUCLEAR REGULATORY COMMISSION
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==REGION V==
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Report No: 50-312/86-21 Docket N 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)
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Inspection conducted:  '
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Inspectors:  _
SEP 181986:
n r 'sident Inspector Y'7-[L Date Signed C. J{/Mpyr , Acti A Ok x G. P.(Pgf , Reside - nspector n  f(-7-%
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Date Signed
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  / /[I b L. F. Hillbr, Chief, Resctor Projects Section II 6 ate Signed Summary:
Inspection between June 2 and July 11, 1986 (Report 50-312/86-21).
 
Areas Inspected: This routine inspection by the Resident Inspectors involved the areas of operational safety verification, maintenance, surveillance, training, safety system walkdown, Bulletin review, management meetings, and followup items. During this inspection, Inspection Procedures 30702, 30703, 36700, 41400, 41701, 61725, 61726, 62702, 62703, 71707, 71710, 90712, 92700, 92701, 92702, 92703, 93702, 94702 and 94703 were use Resulta: Of the areas inspected, one violation and one deviation were identified. The violation concerned implementing NUREG 0737, Item II.E.1.2, safety grade auxiliary feedwater indicatioa in the control room. The deviation concerned the lack of continuous cleaning of the nuclear service raw water.
 
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DETAILS Persons Contacted Licensee Personnel J. Ward, Assistant General Manager G. Coward, Manager, Nuclear Plant
   *J. McColligan, Assistant Manager, Nuclear Plant D. Army, Nuclear Maintenance Manager
  *B. Croley, Nuclear Technical Manager D. Gillispie, Nuclear Engineering Department, Manager S. Redeker, Nuclear Operations Manager J. Shetler, Nuclear Scheduling Manager
  *T. Tucker, Nuclear Operations Superintendent M. Price, Nuclear Mechanical Maintenance Superintendent L. Fossom, I&C Maintenance Superintendent R. Colombo, Regulatory Compliance Superintendent Field, Nuclear Technical Support Superintendent Crunk Incident Analysis Group Supervisor Jurkovich, Site Resident Engineer Kellie, Radiation Protection Superintendent L. Schwieger, Quality Assurance (QA) Manager M. Hieronimos, Assistant to the operations Superintendent J. Jewett, Site QA Supervisor H. Canter, QA Operations Surve111ence Supervisor
  *C. Stephenson, Regulatory Compliance Engineer-B. Daniels, Supervisor, Electrical Engineering J. Irwin, Supervisor, I&C Maintenance
  *C. Linkhart, Electrical Maintenance Superintendent
  *Q. Coleman, QA Acting Site Supervisor Other licensee employees contacted included technicians, operators, mechanics, security and office personne * Attended the Exit Meeting on-July 11, 1986
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    > Operational Safety Verification The inspectors reviewed co'ntrol room operations which' included access control, staffing, observation of decay heat removal system alignment, and review of control room logs. Discussions with the Shift Supervisors and operators indicated understanding by these personnel of the reasons for annunciator indications, abnormal plant conditions and maintenance work in progress. The inspectors also, verified, by observation of valve and switch position indications, that emergency systems were properly aligned for the cold shutdown condition of the facilit Tours of the auxiliary building. turbine building, and reactor building, including exterior areas, were made to assess equipment conditions and plant conditions. Also the tours were made to assess the effectiveness
 
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of radiological controls and adherence to regulatory requirements. The inspectors also observed plant housekeeping and cleanliness looked for potential fire and safety hazards, and observed security and safeguards practice The inspector noted a series of recent events indicating a lack.of attention to detail in the performances of routine personnel activities: Two pipe snubbers were mistakenly removed for testing from.an operating train of the decay heat removal system (described in Paragraph 4B). The valve operator motor for the pressurizer EMOV was burned out when mistakenly operated for a surveillance prior to completion of maintenance testing and adjustment of the operator limit switche This item is unresolved pending further review (86-21-04). A train of the decay heat removal system was put into service without initiating operation of the nuclear service raw water system as required by plant procedures. This item is unresolved pendin; further review (86-21-08). A valve line-up error when sampling the Once Through Steam Generator (OTSG) secondary chemistry resulted in inaccurate analysis and _
excessive hydrazine addition . At the exit interview, the inspector emphasized the need for increased attention to detail in all areas of plant performance in light of the increase in maintenance activity that the plant is conductive restart activities. Licensee representatives acknowledged that lack of attention to detail was a concern of SMUD, and appropriate corrective action for each of these occurrences would be take , Maintenance Several maintenance activities for the systems and components listed below were observed and reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, industry codes or standards, and the Technical Specification The following items were considered during this review: The limiting conditions for operation were met while components or systems were removcd from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing or calibration was performed prior to returning components or systems to service; activities were accomplished by qualified personnel; radiological controls were
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implemented; and fire prevention controls were implemente Cabinet Work The inspector observed work in the safety cabinets at various timeo during thin report period. This work involved lug replacement, wire
 
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.p:   3 wrap, and soldering. The cabinets involved were the reactor-protection and the novi-maclear instrumentation cabinet y.
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Y",, No violations or deviations were identifie >
q(/ MOV Inspection'
The inspector observed portions of maintenance activities to determine the as-found condition of.30 Limitorque operators in response to IE Bulletin 85-03 (described in Section 9 of this report). Partial results of the licensee's inspection indicate several areas of deficiencies in the operator The licensee.will evaluate the data collected during these inspections to assess the significance of the deficiencies,'and whether it is appropriate to expand the' scope of the Limitorque operator inspection'and refurbishment progra The inspector noted that discrepancies found during the licensee's maintenance inapection were not documented on.a Nonconformance
  ; Report;(NCR), but rather were documented on the serialized work
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request.- This is a repeat of a'similar concern expressed by the inspector in review of maintenance activities involved in replacing cracked reactor coolant pump bearing cap screws during inservice inspection.(Unresolved item 85-25-02: OPEN). The inspector questioned whether this was an appropriate means of' control of the
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discrepant conditions to insure adequate review of the findings and
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proper disposition. The. inspector determined that the licensee's procedure AP.3 " Work Request" allows annotation of the work request for rework or replacement activities which are performed on Class 1
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Sacramento Municipal Utility District'  ,
systeme or components to restore proper functioning within specifications. 'This alternative to NCR procersing also requires-serializing of the work request by QA to provide audit capabilit Cognizant licensee Quality Department-personnel stated that th intent of the serialized work request was to allow minor changes to the scope of the approved work request to deal with unanticipated maintenance findings which do not require failure analysis in determining appropriate dispositions. A licensee representative stated that an Occurrence Description Report (ODR) would be written addressing all the findings documented on the serialized work
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  .requer,ts to insure that any generic consequences are appropriately evaluate This item will remain unresolved pending review of the licensee's ODR and evaluation of the equivalence of the use of serialized work requests in controlling non-conforming items of maintenance. Of particular concern is the lack of documentation of the cause and corrective action for nonconforming condition on serialized work request As a result of the December 26, 1985 overcooling event, several preventive maintenance program weaknesses discussed below have been addressed by the licensee. The inspector monitored the progress of
P. O. Box 15830.^.  -
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Sacramento,l California 95813
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changes to the licensee's maintenance program which were being implemented as part of the licensee's restart progra The licensee has consolidated their maintenance departments under a single Nuclear Maintenance Manager and authorized moderately increased staffing within the department to establish dedicated resources for preventive maintenance. To date, actual staffing has increased slightl The licensee is currently pursuing INPO accreditation of their maintenance training program. The inspector observed increased attention and emphasis in the area of maintenance training demonstrated in preparation for motor operated valve operator inspections as part of the licensee's program in response to Information Bulletin 85-0 Ongoing inspections of manual valves to insure operability under off-normal events has been expanded based on valve conditions revealed by these inspections and will provide the basis for defining selection criteria for expanding the scope of preventive maintenance on plant valve The inspector found that the changes underway were.significant improvements in the licensee's preventive maintenance program with the potential for achieving a demonstrated improvement in system and equipment reliability when fully implemente No violations or deviations were identifie . Monthly Surveillance Technical Specification (TS) required surveillance tests were observed and reviewed to ascertain that they were conducted in accordance with these requirement The following items were considered during this review: TestinE was in accordance with adequate procedures; test instrumentation was calibrated; limiting conditions for operation were met; removal and restoration of the affected components were accomplished; test results conformed with TS and procedure requirements and were reviewed by personnel other than the individual directing the test; the reactor operator, technician or engineer performing the test recorded the data and the data were in agreement with observations made by the inspector, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne V DC Station Batteries The inspector reviewed the 'A' battery discharge test conducted on June 23, 1986. No discrepancies were noted at the time. However, while the system was being aligned to its normal configuration the following occurred: The 'A' battery charger (H4BA) tripped and deenergized the SOA bus. This was unexpected because the standby battery charger (H4BAC) was powering the SOA bus prior to the occurrence; six panel annunciator lights burned'out on the 'A' and
'B' diesel generator panels; the 'A' battery charger subsequently
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was reset and tripped four more timas, but in these cases the standby charger still carried the bu The licensee in response to this occurrence declared both the 'A'
and 'B' diesel generatore inoperable because of the unexplained light failures. The normal surveillance tests for the diesel generators were performed, the diesel generators passed, and were declared operable. No cause for the light failures or the failures of the standby battery charger to carry the 'A' bus was determine At the end of this report period the licensee had developed a draft Troubleshooting Action Plan. The inspector discussed with the licensee at the report exit that timely troubleshooting of this event was considered important. Therefore, this item would,be considered an open item until the troubleshooting action plan has been developed, implemented and corrective actions accomplished for this event. This is an open item (86-21-01) Snubber Testing The inspectors observedIpertions of the snubber testing performed under SP 201.10B " Safety System Hydraulic' Snubber Functional Testing" and MT.020 " Snubber Functional Testing". On June 26, 1986 the inspectors observed the failure of the surveillance test of'
snubber #129 (1-SW-23822-7B). 'During'the extension test the snubber failed to lock-up., The next day, June 27 the inspector was informed that snubber #129 had been tested again and passed its surveillance test. The licensee declared the snubber operable. The inspector did not find,any written determination to justify a second test or to accept the resuite of the passed second test over the failed first test. In addition, Quality Assurance Procedure QAP 26
  " Test Control" provides the requirements for Acceptance and Surveillance Tests. The procedure required an NCR to be generated
.when an acceptance test result is not in conformance to the acceptance criteria, but it did not provide a similiar requirement for a failed surveillance test. QAP 26 appears to be incomplete in dealing with surveillance test After the inspector discussed his concerns with the licensee, the licensee issued a NCR on July 8, 1986 which documented the events of June 26 and 27. The NCR had not been dispositioned by the end of this report perfed. The inspector considers the occurrence discussed tbove as an Unresolved Item, 86-21-0 In further reviews of the snubber testing program by the inspector additional concerns had been raised. These concerns were the-following:
  (1) The licensee identified in a different NCR that the technical specifications required a snubber hydraulic seal replacemnt program, such that the snubber seals would be replaced before their expected service life is exceeded. At the end of this inspection, the service lifetime had not been defined. The-f quality assurance department had determined that the service
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-  life for the seals was five years, and had identified sixty-four safety-related snubbers with no documentation for seal replacement within the past five years. The NCR was awaiting disposition at the end of this repor (2) The refueling interval functional test requires that ten percent of the total of each type of snubber in use in the plant be selected. At the end of this report period, the inspector had not determined if the initial representative sample had been composed properl (3) A member of the licensee staff, when asked bp the inspector what the justification was for accepting snubber #129 as operable after it had failed its first test, replied that there existed a temperature dependency of the snubber's lock-up velocity. Therefore, the snubber reportedly failed due to high temperature conditions during the test. However, this  ;
justification was not documented nor was any explanation given for the possible effect of temperature on the snubber in operatio These items will be reviewed.and inspected in conjunction with the already discussed unresolved ite However, during this report period the licensee identified that on June 6 and June 9, 1986 two snubbers were removed from the operable
  'B' decay heat system (DHS) train. Technical Specification 3.12
  " Snubbers," requires, in part, during a Cold Shutdown condition
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  (which the plant was in during this report period) for snubbera located on systems required to be operable for nuclear safety, "With one or more snubbers inoperable, within 72 hours replace or restore
,  the inoperable snubber (s) to operable status and perform an
  - engineering evaluation per specification 4.14.c on the supported component or declare the supported system inoperable and follow the appropriate specification statement for that system." The licensee did not replace or restore the snubbers within the 72 hour period or
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perform the engineering evaluation or declare the 'B' DHS
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inoperable. This is an apparent violation of Technical Specification 3.12. The licensee did not recognize the conditien until June 26, 1986, at that time the snubbers were functionally I  tested and reinstalle The licensee performed an Incident Critique (#IC 86-04) of the above
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event and recommended specific actions to preclude recurrence of this type of event. The inspector reviewed'the recommendations and l  found them appropriate.
 
l The' inspector found that the licensee had identified the problem, it was reported, via 10 CFR 50.72, the condition was corrected, an l
Incident Critique was performed in a timely manner which included i  measures to prevent recurrence, and this occurrence apparently was l  not a repeat violation. Therefore, the violation is considered
. licensee identified. y y . - .r s , y _6_-.,,.3 g,.- _w-- ,_. . , . . , . , yy, _ , ,-m e-
 
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5. Safety System Walkdown The inspectors verified the operability of the following systems required in a cold shutdown condition: Decay Heat (DHS), Nuclear Service Raw Water (NSRW), and Nuclear Service Cooling Water (NSCW).
 
The inspectors performed system walkdowns and found that the system line-ups were in accordance with the licensee's operating procedures and matched the as-built drawings. The inspectors verified that the valves were in proper position, with power available, and the valves that were required to be locked were found locked. Control room indication of the system's equipment was compared to the local indication and was found adequat ,The inspectors assessed the equipment conditions and housekeeping of the DHS and the NSCW system and found it to be adequate. However, the material condition of the NSRW, including the spray ponds, was found to be degraded. The licensee's Updated Safety Analysis Report (USAR),
Section 9.4.2.1, " Nuclear Service Raw Water System," 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 feeding and filtering system for continuous cleaning of the water." 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 is a deviation to the USAR commitment for having continuous cleaning of the spray pond Deviation (86-21-03).
 
The inspector also found organic growth in the corner areas of the spray ponds, two partially-plugged spray nozzles on the east spray pond, deficiency tags on a circulating pump which indicated the pump was out-of-service, and a layer of crust on top of the east filter's sand bed, indicating the filter had not been in use for a period of time. The inspector brought these observations to the licensee's management. The licensee immediately began an investigation of the NSRW system. Their findings were as follows: Twenty-two open work requests on the NSRW system including vegetation growth in spray ponds, two partially-plugged spray nozzles, obstructed lines in one of the hypochlorite systems, an out-of-service circulating pump, a filter unit in continuous backwash, an ammeter out-of-service on a NSRW pump, and several minor leaks. The licensee, however, determined the NSRW systems to be operable. The inspector discuesed with the licensee the importance of maintaining the material condition of the NSRW system and other systems required for plant operation. It is apparent that a large backlog of work requests existed at the end of.this report-period, and that if the work requests
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are not accomplished in a timely manner it could eventually affect the operability of safety system The inspector identified one deviation (86-21-03) and various concerns about the NSRW system's material condition. These items will be reviewed with the licensee's corrective actions taken on the deviatio .
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6. Followup Itsms Enforcement Items 83-34-01/83-34-02 (CLOSED) - These violations were two examples of
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the licensee's failure to follow procedure In both cases a temporary change to a procedure was made which altered the intent of the procedure. This is prohibited by the licensee's technical specification The licensee agreed with the above violations, issued a memorandum for the staff on the' proper use of temporary changes, and revised the procedure for procedure control to clearly identify the proper use of temporary changes. ,The inspector reviewed these actions and found them adequate. In addition,' the inspector had conversations with operators and engineers about temporary changes and found their knowledge adequate. .Therefore, the above items are closed. CLOSED (83-34-01 and 83-34-02).
 
IE Information Notice IN No. 85-74: Station Battery Problems (Closed)
The notice described problems that have occurred with lead-acid station batteries at several nuclear power plants. The inspector has performed inapections of the licensee's station batteries (Inspection Reports 85-08 and 86-07) and has documented similar problems. The problems identified are being followed through the normal inspection program. The licensee is also in the process of replacing the station batteries. This will be completed prior to restar The inspector discussed IN 85-74 with a licensee representative. It appeared that the appropriate personnel at the site received and reviewed the Notice. The licensee's action to address the Information Notice appeared satisfactory, therefore, IN 85-74 is considered CLOSE Licensee Event Reports (LER)
LER 85-10 and 85-10, Revision 1, (CLOSED) - This report described the high point vent leak which occurred on June 23, 198 Inspection of this event was documented in Inspection Report 85-19 and a Notice of Violation was issued on September 26, 1985. The licensee's corrective actions were detailed in the LER and in the revised LER. The corrective actions appear to be complete and appropriate to prevent reoccurrence of this event. Due to inspections performed previously this LER 85-10 and 85-10, Revision 1 is CLOSE . Licensed and Non-Licensed Operator Training The inspector continued an inspection of the licensed and non-licensed operator training programs that had started and was documented in s
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Attention: Mr. John E.1 Ward Deputy Gene'al r Manager, Nuclear Gentlemen: +
 
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Inspection Report 86-07. The inspector reviewed records for a selection of senior reactor operators and control room operators and verified the records contained the following: Copies of the most recent annual written examination and the individual's responses, documentation of attendance at required lectures, documentation of control manipulations at the simulator, a copy of recent performance evaluation, and documentation that required readings had been received and complete The inspector also looked at the pass rates for requalification exams given by the license For the control room operators, the pass rates were 90% in 1984 and 100% in 1985, and for.the senior reactor operators, the pass rates were 94% in 1984 and 100% in 1985. During the same period the pass rates were calculated for initial licensed operator exams are as follows: 100% in 1984 and 75% in 1985 for the reactor operators and 100%
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in 1984 and 85% in 1985 for the senior reactor operator The inspector reviewed the training requireme'nts for a selection of non-licensed operators, and found the records to reflect the training given to the operators. Discussions were held at various times with the non-licensed operators to verify that training had been give The inspector verified that the licensee received INPO accreditation in April of 1986 for the senior reactor operator, reactor operator, shift technical advisor, and non-licensed operator training programs. The licensee's remaining training programs (maintenance, chemistry and radiological protection, technical support, and managers) have been submitted to INPO for accreditatio ~
Thank you for your letter dated' September 5,1986, informing us. of the steps .
The inspector reviewed a sample of training records and found that the licensee is meeting the regulatory requirements for qualification of various staff member No violations or deviations were identifie . NUREC 0737 Action Item. II.E.1.2 Followup Item II.E.1.2 required the licensee to install both safety grade automatic initiation of the Auxiliary Feedwater System (AFW) and safety grade indication of auxiliary feedwater flow to each steam generator in the control room. Item II.E.1.2.2 is described in NUREG 0737 as:
you have'taken to. correct the items which we brought to your attention in our letter dated August. 7, 1986. ..Your corrective actions will be verified during a future inspectio ,
" Position Consistent with satisfying the requirements set forth in General Design Criterion 13 to provide the capability in the control room to ascertain the actual performance of the AFWS when it is called to perform it's intended function, the following requirements shall be implemented: Safety-grade indication of auxiliary feedwater flow to each steam generator shall be provided in the control roo . The auxiliary feedwater flow instrument channels shall be powered from the emergency buses consistent with satisfying the g  - - - -
Your cooperation with us is appreciate ;
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emergency power diversity requirements of the auxiliary-feedwater system set-forth in Auxiliary Systems Branch Technical Position 10-l'of the Standard Review Plan,
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Dannis F. Kirsch, Director Division of Reactor Safety and Projects bec w/ copy of letter dated 9/5/86:
Eection 10.4.9."
RSB/ Document Control Desk (RIDS)
Project Inspector Resident Inspector G. Cook B. Faulkenberry J. Martin


In addition Criterion 13 of 10 CFR 50, Appendix A " General Design
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~;. Criteria for Nuclear Pcwer Plants" states in part: " Criterion 13 -
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Instrumentation and Control. Instrumentation shall be provided to
;  monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational. occurrences, and for accident  .
conditions as appropriate to assure adequate safety..."
The NRC issued an Order, 7590-01, confirming commitments to implement t
certain post-TMI items. The Order, 7590-01, dated March 14,~ 1983, stated in part:
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    "II.E.1.2 Auxiliary Feedwater (AFW) Initiation and Flow Indication Safety grade AFW initiation and flow indication is part of an expanded AFW system upgrade at Rancho Seco. The upgrade will
;    include modifications (safety grade control) that are beyond those suggested in NUREG-0737, and accordingly the expanded upgrade will not be~ completed until the 1984 RO. However, the safety grade 1    initiation and flow indication portioi will be installed during the
  !    February 1983 RO. Late delivery of equipment contributed to the
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delay.- Existing control grade AFW initiation and flow indication'
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provide adequate interim protection."
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The inspector reviewed Engineering Change Notice (ECN) A-3622, Revision 2, which was the work package for the AFW flow indication i   modification required by item II.E.1.2. The ECN package was signed as
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;  completed on July 8, 1983. In the Design Basis Report (DCN) of F
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ECN A-3622, Revision 2, the following was found: " PURPOSE OF DESIGN CHANCE:
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,    The purpose of this design change is to implement the requirements
!    of NUREG 0737 Item II.E.1.2.2 auxiliary feedwater flow indication....
This is further defined in NUREG 0737, II.E.1.2 Part 2, by stating that safety grade auxiliary feedwater flow indication is required to
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meet the 10 CFR part 50, Appendix A Criterion 1 . Safety-grade indication of auxiliary feedwater flow to each steam generator shall be provided in the Control Room...
I DESIGN CRITERIA USED:
~ Signals to control Room for indication will not be IE in interim modification during the 1983 outage, therefore, the indication in the Control Room is not Class IE..."
The inspector reviewed plant drawings (I-53, Sh.6, N25.01-33, Ravision 10, N28.02-2, Sh.1, Revision 0, I-647 and E-402, Sh.7, and 8.)
 
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. and interviewed; licensee representatives'from Nuclear Engineerin '
  : Nuclear Licensing, Compliance, and Quality Assurance and found :that the  ~
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indication of AFW flow in the control room was in fact not Class IE. Not having Class IE power to the APW indication in the control room does not I  provide the availability'of the instrument for anticipated operational occurrences, and'for ac'cident conditions; for example,. loss of offsite
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;  power.1 Therefore, it. appears that criterion.13 was not met;.furthermore,
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the TM1 iten II.E.1.2 was also not met. Therefore, it appears that from      ,
the time that the modification was completed,-July ~8, 1983, through the end of this report period, the licensee has been in vio.lation of NRC Order 7590-01. This is an apparent violation. (86-21-05) IE Bulletin 85-03 Followup
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  'The inspector monitored the licensee's test and corrective actions which were initiated during this inspection period in response to        4 [
IE'Eulletin 85-03 ." Motor-Operated Valve Common Mode Failures During        ~
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r _ Plant Transients Due to Improper Switch Settings," dated November ~15, 1985. In their response dated May 16, 1985, the licensee committed to develop and implement a two phase program to ensure that valve operator switches of motor operated valves (MOVs) were specified, i  set and maintained properly.. The first phase reviewed the" design basis 1  :for the operation of motor operated valves in the high pressure injection.
 
  (HPI) and auxiliary feedwater systems (AFS) to document the maximum ,
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differential pressure-expected on these valves during both normal and'      - _
,   ' abnormal events. <The second phase of the' licensee's program' involved six steps!.
e 1) Valve data collection to establish as-found conditions        -
 
2) Operator refurbishment      ~
3) Analytical determination of the valve stem thrust developed by the' motor-operator based.on manually. applied' torque 4) Setting of.the ' switches using4the analytical valves '
5) Testing to confirm the valv,e will perform.when required to mitigate an acciden i -
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6) Revision of procedures to ensure that the switches are correctly 4    set and maintaine In addition, the licensee's program committed to incorporate the items of
;  IE Notice 86-29, " Effects of Changing Valve Motor-Operator Switch    '
Settings."  t   ,
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!'  Atthetimeoftheinspectiob,the'licenseehadcompletedthefirstphase of their program and a training program for Maintenance and Quality      , ' Department personnel who would be involved in subsequent phase two motor operator work. The licensee identified 30 Limitorque operated MOVs in the HPI/AFS systems to be investigated under their program and determined
 
  -the maximum differential pressure under which each would be required to
,  operate in a design basis even The inspector reviewed the valve actuator training program conducted ~b Power Safety Internationalsfor the licensee personnel and.found the 1   program to be extensive and comprehensive, presenting instruction on
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,  maintenance, repair and troubleshooting of Limitorque design valve
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  , operator .
,  The inspector found that licensee's response to IEB 85-03 had been timely cnd that they were implementing their program in accordance with.their
  '
scheduled commitments.
 
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During the period of the inspection, the-licensee initiated phase two of their program to collect as-found valve data as input for their analytical determination of valve stem thrust force The inspe'etor discussed the. licensee's program with' cognizant licensee personnel, reviewed the licensee's work procedures controlling the implementation of their program and observed portions of the
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investigative activities performed and found them to be consistent with
;. the committed program (except as noted below).
 
  -  During this review the inspector made the following observations:
* No previous preventive maintenance program had been established
     'for control and maintenance of the Limitorque operators. A licensee procedure (EM.ll7,' Revision 5, " Functional Test of
>
Valve Motor Operators") provided instructions on-setting the
;-'    operator switches for use during corrective maintenance activities involving the operator . The load design data sheets (Drawing E1012, Revision 4,'" Motor Operated Valve Data"), specifying the required torque switch settings, were incomplete. The inspector reviewed the data for 160 Limitorque operated valves and found five instances of no specified torque switch setting (HV-20003, HV-23801, HV-23802, LV-36005, LV-36505). Three of these examples involved Class 1
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valves. This. item is unresolved, pending further review of the
;    . safety function of the valve operato (86-21-07)
  ~ The inspector noted that the licensee's approach to setting the torque switches involved application of a measured torque to the handwheel of the operator. As described in the May 16, 1986, submittal of their MOV program, Section III.4, "the torque switch settings will be input through the actuator handwheel and set to a specific value of handwheel torque."
 
'_
However, the inspector observed that the manual mode of operation of the smaller style Limitorque operators, SMB-000 and SMB-00, does not actuate the torque switche Consequently, the torque switches of these operators cannot be adjusted based on an applied handwheel torqu In this respect, the licensee's. implementation of'their MOV program appears questionable. The inspector determined that 24 of the 30 valve operators to be inspected were the smaller style l,    Limitorque operator which do not actuate the torque switches in
            '
the manual mod , Section III.4 of the licensee's MOV program describes that "the
;    open torque bypass switch setting will be'a fixed percentage of
        ,
  - -- ,. y . . _ , . . - . . , _ . , - . , , , , . . _ ~ - 1.,...,_,-._ , _ . - , , - - . _ . _ _ . , w.. _r,. ..
 
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+-      i dise (emphasis 'added) motion for all motor operated valves".
*
 
  . _ - . , .
The inspector noted the licensee's current procedure EM.117, Revision 5, specifies setting the torque bypass switch "to open as the valve stem (emphasis added) lif ts off the valve sea This position may be determined by noting a marked reduction in the force required to manually drive the stem open. If, for some reason, this condition is not detectable, the torque
     -  --
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switch bypass should be set to open at approximately 10 percent of total valve travel". The inspector noted that EM.117 did not address valve disc motion as committed in Section II since valve disc'and stem motion may not be equivalent. In discussion with-licensee maintenance personnel,-the inspector also determined that the torque bypass switch-was routinely set at 10 percent of total handwheel' turns to drive the valve stem
,  open, which is not necessarily equivalent with 10 percent of total valve travel (or disc motion).
 
The inspector discussed these concerns regarding the technical adequacy of the MOV program with licensee' representatives, who stated that the inspector's concerns would be addressed in the analytical determination of the valve stem thrust and an extensive revision of the EM.117 which is
     '
currently underwa ,
This bulletin followup will remain ope . Meetings On June 17 and 18, 1986, members of the NRC Regional and Headquarters office met with licensee representatives at the Rancho Seco site to-discuss the Rancho Seco Improvement Program. The licensee's presentation included discussions of the Program's various input phases (personnel interviews, precursor review, B&W Stop Trip Program, selected projects, deterministic failure analysis, and NUREG 1195); the responsibilities of the various committees (Recommendations Review and Resolution Board, Performance Analysis Group, Independent Analysis Group); and the structure of the system test program. The meeting was an information meeting onl Also, the licensee issued their Rancho Seco " Action Plan for Performance Improvement" on July 3, 198 No violations or deviations were identified.
 
'
1 Personnel Changes During this report period various changes have been made in the site and corporate managements. General Manager D. K. K. Lowe resigned after ten months, in his place the Board of Directors appointed William Latha William Latham has been with SMUD for 25 years and most recently held the Assistant General Manager, Consumers Services, positio The following changes have been mede with the site management: John Ward (Management Analysis Corporation, MAC) was named the Deputy General Manager, Nuclear; Dan Poole (MAC) was named Restart & Implementation
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      .. .
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^ Manager; Ray Ashley (MAC) was named Manager, Nuclear Licensing; and Stu Knight (MAC) was named site operations Quality Department Manage . Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, and open item, a deviation, or a violatio . Exit Meeting The resident inspectors met with license'e representatives (noted in Paragraph 1) at various times during the report period and formally on July 11, 1986. The scope and findings of the inspection activities described in this report:were summarized at the meetin l
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Latest revision as of 13:57, 18 December 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-312/86-21
ML20214Q430
Person / Time
Site: Rancho Seco
Issue date: 09/18/1986
From: Kirsch D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Julie Ward
SACRAMENTO MUNICIPAL UTILITY DISTRICT
Shared Package
ML20214Q432 List:
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8609240355
Download: ML20214Q430 (1)
v • d • e


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Sacramento Municipal Utility District' ,

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P. O. Box 15830.^. -

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Sacramento,l California 95813

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Attention: Mr. John E.1 Ward Deputy Gene'al r Manager, Nuclear Gentlemen: +

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Thank you for your letter dated' September 5,1986, informing us. of the steps .

you have'taken to. correct the items which we brought to your attention in our letter dated August. 7, 1986. ..Your corrective actions will be verified during a future inspectio ,

Your cooperation with us is appreciate ;

bEfn#8Ynedby -

D. F, Qsd1,,-

Dannis F. Kirsch, Director Division of Reactor Safety and Projects bec w/ copy of letter dated 9/5/86:

RSB/ Document Control Desk (RIDS)

Project Inspector Resident Inspector G. Cook B. Faulkenberry J. Martin

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