IR 05000312/1985011

Insp Rept 50-312/85-11 on 850424-30 & 0508-14.No Violation or Deviation Noted.Major Areas Inspected:Qa,Maint & LER & Part 21 Rept Followup

ML20128A254
Person / Time
Site:	Rancho Seco
Issue date:	06/13/1985
From:	Miller L, Myers C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20128A250	List: IR 05000312/1985011 ML20128A246
References
50-312-85-11, NUDOCS 8507020610
Download: ML20128A254 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /85-11 Docket N '50-312 License N DPR-54'

Licensee: Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813

. Facility Name: Rancho Seco Nuclear Generating Station Inspection at: Herald, California (Rancho Seco Site) and Sacramento, California (SMUD Headquarters)

Inspection conducted: April 24 through 30 and May 8 through 14, 1985 Inspector: JLA -a C. J. MQoje t Inspector Date Signed Approved By:  % A b-~ [Nb L. FUMiller, J(f! ' Chief Date Signed Reactor Projects, Se : tion 2 Summary: ,

Inspection between April 24-30 and May 8-14, 1985 (Report No. 50-312/85-11)

Areas Inspected: Routine, unannounced inspection by a regionally base * <

inspector in the areas of quality assurance, maintenance,LER followup and Part 21 report followup. 'This inspection involved 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> onsite and at SMUD

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headquarters by one regional based inspecto R esults: Of the areas inspected, no violations or deviations were identifie ,

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DETAILS Persons Contacted Sacramento Municipal Utility District (SMUD) Personnel

• L. G. Schweiger, Ma'n'ager,-Quality Assurance

.*I. Serre,-Quality Assurance Welding Engineer

• J. Jewett, Site-Quality Assurance Supervisor

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• W. Speight, Regulatory Compliance Staff

• H. Canter, Quality Assurance Operations Surveillance Supervisor Nuclear Regulatory Commission (NRC)

.1 *J. Eckhardt, Senior Resident Inspector

• G. Perez, Resident Inspector

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The inspector also held discussions with several other members of the licensee staff. including membere of the maintenance, operations, quality assurance and crafts organization * Attended Exit Meeting on May 14, 198 . Followup of Licensee Event Reports (LER's) Auxiliary Steam Line Isolation in High Pressure Injection Pump Room (LER 83-08-L1: CLOSED) ,

This LER had remained lopen from_ previous inspections pending f.ull

' operability'of the automatic isolation system for the auxiliary steam '(AS) line ,in .the high pressure injection (HPI) pump room "A".

The inspector observed the installe'd isolation valves HU-36050 and ASC-727, for the AS lin'e to the auxiliary building and the valve motor controllers'in the nuclear service electrical building (NSEB).

Through discussion with Bechtel Startup Group and licensee operations personnel, the inspector determined that the automatic AS isolation system to the HPI pump room had successfully completed

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startup testing and had been turned over to operation Section 3 of this report addresses the followup of a related.10

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CFR 21' report regarding a Westinghouse reversing contactor in the valve motor controlle This item is close No violations or deviations were identifie Incorrect Boron Concentration Technical Specification (LER 85-03: OPEN)

This LER reported that the licensee discovered a non-conservative error in Rancho Seco Technical Specification 3.8.4 regarding the required boron concentration during refueling operations with the

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reactor vessel head removed. The LER identified that a

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calculational. error had existed since June, 1983,'and was, caused by

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the improper use of outdated and uncontrolled copies of the Rancho

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Seco Technical Specifications by the fuel supplier (Babcock and

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.Wilcox) who' performed the calculations. The licensee implemented

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corrective actions to improve vendor control of documentation. .The licensee reviewed actual boron _ concentrations for the affected fuel

.' cycles ~and determined that despite'the error,~a; conservative

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suberitical reactiv ty margin had been maintaine ' The inspector. identified that'the corrective actions in the LER did >

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'not address'any of the required Technical Specification changes resulting from the calculational error. The inspector reviewed proposed Technical Specification Amendment No. 126, dated March 18,

, 1985, which the licensee had submitted to correct the Technical Specification 3. '

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'Throu'gh discussions with licensee representatives, the inspector identified' additional Technical Specification weaknesses which appear to have contributed to the root cause of the calculational error reported in LER 85-0 ~

s Technical Specification 3.8 assumes that refueling boron concentration'will be sufficient to maintain a Keff < 0.9 This assumption was, identified in the Basis for the Technical

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T' . Specification but not in' Technical-Specification 3.8.3 itself,

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as it is the. Standard Babcock and Wilcox (B&W) Technical

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, The required boro'n.c'ncentrationo of 1936, ppm ~ identified in the 1 k ' "

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LER differed from' the:1974. ppm concentration identified in

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proposed Amendment No. 126 and,did not appear to incorporate a ,

e l L) f 50 ppm ; conservative' margin as did the Standard B&W Technical-

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e ' Specifications'.~ ' The one percen't shutdown. margin identified in Rancho Seco Technical-Specification 1.2.6, which. defines'" Refueling

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Shutdown" is not;censistent with the five percent shutdow margin assumed by Technica1' Specification 3.8.3.

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, ,- The inspeEtor discussed these' observations with licensee representatives'

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. who committed to revise;the proposed Amendment No. 126 to correct.the

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inconsistencies noted and reflect the~ Standard B&W Technical Specification format.

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Thi's' item is Ope , ,

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INo violations or deviations were' identified.

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3. Followup of 10 CFR 21 Notification Westinghouse Reversing Starter Mechanical Interlock (CM-44-P0: CLOSED)

On February 15, 1984, the licensee submitted a 10 CFR 21 Notification informing the NRC of a potential deficiency with a Westinghouse supplied full voltage reversing starter assembly. The reversing starter assembly allows operation of an AC motor in either direction. Six of forty-one starter assemblies at-Rancho Seco control safety-related equipmen The deficiency involved the improper functioning of a mechanical interlock between the two direction relays in the starter assembly. The mechanical interlock is a backup to an electrical interlock designed to prevent a phase to phase short which would result if both directional relays were energize Rancho Seco had experienced two types of field problems with the mechanical interlock; one involving misalignment of the interlock between the starter relays due to its mounting on the " wrapper" in the motor' controller cabinet, and, the other involving interference with an internal assist spring which had became loos Initial investigation of the problem with the manufacturer indicated that a " backing plate" may not have been installed by the manufacturer

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allowing excessive flexibility of the wrapper and resulting in the observed. component misalignment and interferenc On April 9,1985,;the license'e reported that the manufacturer had

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verified that the " backing plate" was a temporary mounting plate for the starter subassembly and was not designed or qualified as part of the wrapper. .Furthermore, the manufacturer attributed the field problem experienced at Rancho Seco to have resulted from unauthorized adjustment of factory set mounting screws by Rancho Seco field personne Based on dimensional guidelines provided by the manufacturer, the licensee evaluated 34 Westinghouse reversing starter assemblies for proper alignment and returned two assemblies to Westinghouse for minor factory adjustmen The manufacturer will develop a warning label to alert field personnel that critical mounting screws are factory adjusted and should not be tightened in the fiel Based.on review of the licensee's evaluation and discussion with responsible licensee representatives, the inspector determined that the licensee had adequately resolved questions regarding the seismic integrity of the Westinghouse reversing starters and that no generic deficiency in the installation was indicate This item is close This item was initially followup in Inspection Report 50-312/84-04 and addressed in Inspection Report 50-312/85 "! in connection with the auxiliary steam automatic i d ation valve application (LER 83-08).

No violations or deviations were identifie . 4

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4. Quality Assurance Program Review No NRR approved changes to the Quality Assurance (QA) program as described in the Rancho Seco Updated Safety Analysis Report (USAR) had been made since the last inspection in this area (September 1981). The inspector determined that over 70 revisions to the Quality Assurance Program implementing procedures, i.e., Quality Assurance Procedures

[ (QAP's) and Quality Control Instructions (QCI's), had been made by the licensee during this period. The inspector sampled 15 of the revised procedures to determine whether the Quality Assurance Program being implemented was in conformance with the USAR QA program descriptio The inspector identified several concerns in examination of the sample procedural revision The Rancho Seco USAR does not specifically describe a QA program for the operations phase. Rather the construction and pre-operational testing QA program, which is described in the USAR, has been tacitly extended to the operations phase as the NRR approved QA program descriptio A licensee representative . indicated that the USAR description was currently under revision and would be updated by September, 1984, to specifically address the operations QA progra Revision 8 of QAP-3, " Quality Assurance Classification" dated August.17, 1982,. established only two QA classes for identification of equipment i.e., Class I and' Class I However, QAP-30, " Glossary of Terms and Definitions," Rev. O continued to define a QA Class II A licensee representative explained that some confusion had resulted due to the Revision 8 to QAP-3, which had been intended to delete only a " selected QA Class II" category. QAP-3 was currently been revised to clarify the QA classifications and would be completed by June, 198 Revision 8 of QAP-3, " Quality Assurance Classification" dated August 17, 1982, deleted QA participation in non-safety related QA Class II equipment. -Paragraph 1B.12 of the USAR states, in part

"The Quality Assurance Program covered all structures, systems and components classified as Class I or Class II." This reduction in the scope of the Quality Assurance Program, as committed in the USAR, was not identified in the current description of the NRR approved QA program as submitted in 1983 pursuant to 10 CFR 50.54 requirement The licensee was currently revising the USAR to update the QA program description of the operations phase, as noted in paragraph 4a abov The requirements of QAP-1, " Organization" regarding changes to the QAP's does not include a 10 CFR 50.54 review to determine whether

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thechangecon$titutesareductionintheprogramcommitmentsas described in the USAR.

L The licensee committed to address 10 CFR 50.54 review requirements in the upcoming QAP revisions in September, 198 Furthermore, the licensee committed to review the Management Safety Review Committee (MSRC) handling of 10.CFR 50.59 reviews to determined if additional MSRC review of QA program procedure changes for unreviewed safety questions and-10 CFR 50.54 requirements should be incorporate Revision 1, dated August 10, 1984, to QAP-27, " Corrective Action" added reference to a QCI-7 to define the QA control established for corrective actions. A licensee representative indicated that

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issuance of.QCI-7 had recently been cancelled. The inspector discussed this inconsistency with a~ licensee representative who indicated that the discrepancy would be resolved in the upcoming revision of the QAP.

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These items will be followed up in a future inspection (0 pen Item 85-11-01).

The inspector reviewed the computerized Coordinated Commitment List (CCL), which the licensee has implemented to track new and existing regulatory commitments to insure that key. personnel are informed of the commitments. The inspector reviewed Audit Report Nos. 617 and 632 which Quality Assurance had performed to assess the status of the system and eliminate problems with its usag In discussions with licensee

, representatives, the inspector determined that the CCL is currently

erational and in use by licensee personnel in tracking new regulatory

ommitments, and that the licensee has implemented an extensive program t) input all existing regulatory commitment ,

No violations or deviations were identifie , Maintenance Program The inspector reviewed the licensee's controls -for performing corrective maintenance as defined in Rancho Seco Administrative Procedure AP.3. The -

inspector verified that controls for the review and-approval of work requests were established.which included criteria for determining whether the work involved safety-related. equipmen The inspector identified a weakness in the licensee's control of equipment classification for plant modifications performed under Nuclear Engineering work requests. The " Master Equipment List" (MEL) which was maintained by Nuclear Operations was not updated for modifications or new-equipment until the system or equipment had been turned over for Operations from Nuclear Engineering. As a result, the MEL could not be used to-identify ~the QA classification during review and approva Reference to the controlling engineering document, an Engineering Change Notice (ECN),swas not established as an alternate identification since

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only the highest QA. classification of the scope of the EC'N was identified

'in the EC The inspector identified Work Request 83892 as an example of this weakness. .The work request involved a system modification to install safety-related dampers in a.non-safety related ventilation system;

however,-_the work request was designated QA Class II rather than-QA Class In discussions with licensee personnel, the inspector

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. determined that the work request did receive the required review prior to

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_ issuance, but no QA classification had been available at.the time in the MEL. As.a result,-a QA Class III default classification (RS-1) had been) q assigned to initiate the work and computer tracking _until-Nuclear Engineering could be contacted to identify the correct QA clas The inspector discussed this weakness with licensee representatives who indicated that an interim listing of equipment quality classification was being implemented as part of AP.42 Maintenance Information Management System (MIMS). control to supplement the MEL prior to equipment turnover

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.to' operations. The licensee acknowledged the weakness in their program and agreed to consider the inspector concern lThe inspector also noted a additional weakness in the licensee's control l

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of maintenance activities evidenced in. Work Request 83892. The Work Request was originally issued correctly as QA Class II. However, when'

the scope of. work was expanded to , include QA Class I components, the work request.hadsnot.been upgrade'd to; identify the higher QA clas t Chahges to the scope of work of th'e ECN were issued by a separate ECN ', '

> which received;the,same review as.thel original ECN referenced in WR8389 '

.However,,WR83892'itself was n'ot reissued'or. re-reviewed, but pen and ink changed ~to'ad,dLthe1 additional, work.,

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In -discusbions'with ' licensee irepresentatives, the inspector pointed out

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this' weakness in the review}of changes to work requests which expanded the scope'of work andinoted that this weaknes's was identified in previous

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' inspections. ' This itiem-will be ~ continue to be open (0 pen Item 84-14-04:

OPEN). # m ',

The inspector reviewed the licensee's trending programs to assess'the

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adequacy of maintenance programs and to identify repetitive failures and-

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de' sign deficiencies. Existing provisions in the licensee's control of s maintenance activities had been established to review completed work e, requests for input into an industry based information data system i.e.,

Nuclear Plant Reliability Data System (NPRDS). However, the industry information was not formally utilized as a reference resource for design or purchasing of new equipment or maintenance activities. An annual

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trend analysis report was prepared for the MSRC per QCI-13, which provided management information related to the safe operation of the plant. - Furthermore, a Specialized Operational QA Program (S0QAP) was

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implemented centering on control room operation, HP operations, chemistry operations and management; contro In addition, a licensee representative indicated that a new computer

, based Trend Oriented QA Program (T0QAP) was currently being implemented

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r which would incorporate (a) micro-trending of plant equipment

!  : characteristics as a precursor for preventative maintenances (b) industry

~ trend analysis reports e.g., Nuclear Utility Management and Human Resources Committee.(NUNHRC) as a management information resource, and (c). quarterly MSRC trend analysis reports as a more timely management information-too "

No violations or deviations were identifie . Exit Meeting The inspector met with licensee representatives on May 14, 1985, and summarized the scope and findings'of the inspection'.

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