IR 05000312/1988021

Insp Rept 50-312/88-21 on 880711-15.No Violations or Deviations Noted.Major Areas Inspected:Licensee Action on Fastener Testing,Primary Coolant Sys Pressure Isolation Valves & Natural Circulation Cooldown

ML20151T058
Person / Time
Site:	Rancho Seco
Issue date:	07/27/1988
From:	Ang W, Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20151T016	List: IR 05000312/1988021 ML20151T011
References
50-312-88-21, GL-81-21, GL-83-28, IEB-87-002, IEB-87-2, NUDOCS 8808160238
Download: ML20151T058 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-312/88-21 Docket No. 50-312 License No. OPR-54 Licensee: Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Facility Name: Rancho Seco Nuclear Generating Station Inspection Conducted: July 11-15, 1988 Inspection by: kq 7-N'N W. P. Ang, Proje(t Inspector Date Signed Approved by: h 9 (w/

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j d7-ff L. Miller, Ch' Date Signed Project Section 2 Summary:

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Inspection on July 11-15, 1988 (Report No. 50-312/88-21)

Ac_eas Inspected: Routine, unannounced inspection by a region based inspector ,

of licensee action on fastener testing, primary coolant system pressure '

isolation valves, natural circulaticn cooldown, reactor trip breakers vendor recommended modifications, and quality assurance of emergency diesel generator fuel oi Inspection Procedures 25026, 25584, 25586, 25591, and 25593 were use Results: No general conclusions regarding the adequacy, strength or weakness of the areas inspected, nor any significant safety matters, were identifie In the areas inspected, no violations or deviations were identifie ,

8800160238 000720 PDR ADOCK 05000312 G PNU

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DETAILS

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1. Persons Contacted

' Licensee Personnel

• D. Keuter, AGM, Nuclear Power Production

• B. Croley,:AGM, Technical Services

• J. Vinquist Director, Nuclear Quality

• Kemper,' Nuclear Operations Manager

• Koepke, QC Supervisor

• T. Redican,. Manager, Material Control

• P. Turner, Manager, Nuclear Training

• Harrell, Superintendent, Training

• Felton, Operations Training Supervisor

• L. Pulley, Supervisor, Mechanical Engineering

• H. Heckert, Surveillance Program Supervisor j G. Legner, Licensing Engineer NRC Resident Inspectors F

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• A. D'Angelo

^P. Qualls

Attended the exit meetin The ,nspector also held discussions with other licensee and contrcct personnel during the inspection. This included plant staff engineers, technicians, licensed operators, administrative and clerical assistant . NRC Inspection Manual Temporary Instructions (TI) (Closed) TI 2500/26 - Inspection Requirements for NRC Compliance

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Bulletin (NRCB) 87-02, "Fastener Testing to Determine Conformance

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with Applicable Material Specifications" (25026) (BL-87-02) [ .

NRC Region V Inspection Report 50-312/87-37 documented initial i inspection of this TI and participation in the sampling of fasteners  ;

in accordance with NRCB 87-0 A follow-up inspection was performed '

to complete the remainder of the T The licensee's receipt inspection and warehouse issue and control program for safety-related and non-safety-related fasteners were ,

reviewed and compared with the licensee's NRCB 87-02 response. The ~

licensee's NRCB 87-02 response was provided in a January 22, 1988

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letter from the SMUD CEO, Nuclear to Region V. The letter described t'* licensee's program for receipt inspection and warehouse issue 4 1 ,ontrol of safety-related and non-safety-related fastener A n ,this inspection, the following licensee procedures were t re, . sed and compared with the January 22, 1988 SMUD response for ,

NRCB 87-0 r I

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(1) Quality' Assurance Implementing Procedure (QAIP) 1005, Revision 0, "Receiving Inspection" (2) Rancho Seco Administrative Procedure 0408, Revision 0, "Four Level Procurement System" (3) Material Control Administrative Procedure MMP-0023, Revision 2,

"Receipt of Items" (4) Material Control Administrative Procedure MMP-0024, Revision 1

"Identification and Marking of Items" (5) Material Control Administrative Procedure MMP-0025, Revision 1,

"Preservation Storage and Maintenance of Items in Storage" QAIP 1000 requires the preparation and use of a Receiving Inspection Data Report (RIDR) for all Quality Class 1 and Quality Class 2 purchase order The most recent bulk purchase order for restocking of fasteners was provided for by purchase order (P.O.) N RQ-87-08-55800. The P.O. was issued in conjunction with RIDR 4152-R1. A review of the above noted procedures, RQ-87-08-55800 and RIDR 4152-R1 confirmed the licensee's description of its receiving inspection and warehouse issue and control requirements for safety-related and non-safety-related fasteners contained in its January 22, 1988 response to NRCB 87-0 NRCB 87-02 action item 6 requires the following:

"Based on the results of the testing and review of current procedures, describe any further actions being taken to assure that fasteners used in the plant meet the requisite specifications and requirements and that the operability of safety-related plant components is not affected."

The licensee's NRCB 87-02 response identified four sample failures and provided an evaluation for specific applications for the failed samples. Tne evaluations indicated that despite the identified failures, the fasteners were determined to be technically acceptable for use. The licensee's response further committed to the following:

"All fasteners from stock codes that contained failed components have been removed from the warehouse shelves and placed in

"quarantine" awaiting dispositio Material control personnel will review the complete purchase and issue history for each stt ak code that produced a failure to determine why the improper grade materials were found in the bins. Based on this evaluation, a determination of additional sampling or other corrective actions necessary to eliminate this problem will be made. A program to remove all non-Class I fasteners is in progress and will be completed by June 30, 198 It is believed this program will correct this improper materials problem."

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The licensee's evaluation was still in progress and bott. the evaluation and corrective actions wera being controlled and tracked by Potential Deficiency to Quality Report Number 88-1101 and commitment tracking system item numbers T880726007 and T88072600 The controls on the licensee commitments provided reasonable assurance for the completion of the commitment Based on the above inspection findings TI 2500/26 was close Supplement 1 and 2 of NRCB 87-02 response was not due at the time of the inspection and the licensee response had not yet been subn.itte Pending completion of licensee action and NRC review, NRCB 87-02 was left ope No violations or deviations were identifie B. (Closed) TI 2515/84 - Verification of Compliance With Order for Modificatign_qf License: Primary Coolant System Pressure Isolation (Event V) Vaives (25584) (MPA-B-45)

On April 20, 1981, by letter from NRR to SMUD, an order modifying the Rancho Seco license concerning pr* mary coolant system pressure isolation valves was issued. The orc r included applicable additions to the Technical Specificat:ans (TS). The technical specifications regarding those valves are currently in specification 3.3.2, amendment 97 and 4.5.1.1.B.4, amendment 7 The valves are also included in the current Rancho Seco Inservice Test (IST)

program which was submitted to the NRC in a memorandum from SMUD CEO Nuclear to NRR on January 22, 1988. The IST program was reviewed by NRR and interim approval was provided by NRR on March 3, 198 The TS 3.3.2 and IST leak test requirements for the subject valves were contained in Rancho Seco Surveillance Procedure SP67 revision 1,

"Special Frequency Cold Shutdown Reactor Coolant / Decay Heat Removal / Core Flooding Systems Stop Check / Check Valve Seat Integrity Test."

The records for the performance of SP67 were obtained and reviewe The records for the last previous performance of the tests were specifically reviewe The test records contained major test data including upstream and downstream pressures, had provisions for determining leak volume per unit time and leakage rate adjustment calculations. The TS table 3.3-1 acceptance criteria was also contained in the procedure / test recor It included provisions for the necessary data for adjusting the acceptance criteria based on the trend of previous leakage rate For the last test, performed March 8, 1988, valves RCS-001, RCS-002, DHS-015, DHS-016, CFS-001 and CFS-002 were determined to have passed with no leakage. Te test was performed within the time frame specified by TS 4.5.1.1.B.4. The test procedure / record paragraph 6.7.3 required immediate notification of the Shift Supervisor if valve leakage does not meet the TS acceptance criteria and refers to the TS 3. Limiting Condition for Operatio _ _ _ _ . . _ .

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The inspector had the following observations regarding the procedure / test recor (1) SP67 Sc.ction 6.2.1 and 6.3.1 performs an initial determination of leakage for valves RCS-001 and RCS-002 by nieasuring the change in differential pressure across the check valve The procedure did not specify a time span for the observation nor did it require recording the time span for the differential pressure observatio For the test results reviewed, the NRC inspector noted that the telatively high differential pressures, 400 psid for RCS-001 and 720 psid for RCS-002, would alicw a 1 GPM valve seat leakage to be readily observable. The licensee committed to evaluate the inspectors procedure observation to determine the need for a procedure chang (2) The inspector noted that SP67 did not require and was not performed at normal system operating pressures and temperatures. Furthermore, the procedure did not require recording of system temperatures. The inspector recognized that the effects of temperature on the leakage rate would normally be minimal unless significant thermal expansion of the piping and the valve were occurring. The licensee committed to evaluate the inspector observation to determine the need for a procedure chang Based on the TS, Surveillance Procedure and test records noted above, TI 2515/84 was close No violations or deviations were identifie C. (Closed) T1 2515/86 - Inspection of Licensee's Actions Taken to Implement Generic Letter (GL) No. 81-21, Natural Circulation Cooldown (25586) (MPA-B-66)

NRR GL 81-21 requested licensee's to review and implement plant procedures and a training program which would enable operators to avoid (if possible), recognize and properly react to reactor vessel voiding during natural circulation cooldow The letter further required submittal of the licensee's assessment of its procedures and training program in relation to the same subjec On September 19, 1985 SMUD submitted to NRR its response to GL-81-21 providing procedure changes that would be implemented relevant to natural circulation cooldown and prevention of reactor vessel head formatien. The licensee had no record of a Safety Evaluation Report or an NRR evaluation / comments regarding the SMUD submittal. The licensee co:nmitted to obtaining a response to their submittal from NR The NRC inspector also informed the NRR Rancho Seco Project Manager of the noted conditio The licensee's September 19, 1985 submittal was used to verify implementation in its operating procedures. Rancho Seco Operating Procedure B.4, revision 45, Plant Shutdown and Cooldown contains a section that provides the plants Natural Circulation Cooling procedure. Emergency Operating Procedure E.03, revision 5, Loss of L

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Subcooling, and Casualty Procedure OP-C.95, revision 2, Loss of Offsite Power, both requiredverification/ check for natural circulation and provided the parameters to check. The procedures appeared to implement the licensee commitments in its response to GL 81-21, including parameters for prevention of voids in the reactor vessel upper head during natural circulation coolin However, the inspector noted the following conditions regarding the procedure (1) Procedures B.4, E.03 and C.95 contained parameters to verify that natural circulation had been established. The parameters varied slightly from procedure to procedure although none of them appeared to be incorrect. The licensee committed to establish the pirameters that were most appropriate and change the procedures to make them consisten (2) Procedure B.4 required verification of OTSG 1evel based on EFIC Hi range instrument in paragraph 6.3.2 (317") and paragraph 6.9.4.4 (381"). These levels correspond to previously required levels of 50 percent and 95 percent on the operate range for steam generator water leve The basis for 317" corresponding to 50 percent and 381" corresponding to 95 percent was not readily availabl The licensee committed to confirm the correctness of the 317 inches and 381 inches and have the basis '

availcble for inspectio The above noted inspector observations were identified as inspector follow-up item 50-312/88-21-0 The inspector interviewed three licensed operators, reviewed classroom and simulator training lesson plans and records to determine the adequacy of training provided regarding natural circulation cooling and prevention of formation of voids in the RCS :

and RV upper head during that process. The following lesson plans and training records were reviewed:

Lesson Plan 00 21 J 0300, Revision 0, Procedures, Plant Shutdown and Cooldown

Lesson Plan OD 24 K 5500, Revision 1, Loss of Offsite Power Simulator Training

Lesson Plan OD 24 K 7800, Inadequate Core Cooling

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The operator interviews and review of lesson plan and training records confirmed that classroom and simulator training had been provided regarding natural circulation cooling and prevention of voids in the RCS and RV upper head during natural circulation cooling. The inspector noted however that the simulator training was normcily terminated when natural circulation had been verified to have been established due to the length of time normally required to cooldown with this process. The inspector further noted that simulator training was not provided for switching to decay heat

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removal from natur ' circulation cooling. The licensee committed to evaluate the need f ur simulator training for the noted conditio , _ . _ _ __

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This was identified as an additional item for Inspector Follow-up Item 50-312/88-21-0 Based on the inspection of procedures, lesson plans, training records and operator interviews, TI 2515/86 was close No violations or deviations were identifie D. (Closed) TI 2515/91 - Inspection Follow-up to Generic Letter 83-28 Item 4.1 (25591) (MPA-8-80)

TI 2515/64, Revision 1, Near-Term Inspection Follow-up to Generic Letter 83-28, Item 04.03.C required verification that vendor recommended modifications to Reactor Trip Breakers (RTB) had been implemented. This item had been inspected and closed out by inspection report 50-312/85-1 The inspection report stated that the RT8s had been upgraded by GE, requalified by B&W and reinstalle In addition, on August 5, 1985, NRR issued an SER regarding item 4.1 of GL 83-2 The SER concluded that the licensee had satisfactorily completed the actions set forth in Item 4.1 of Generic Letter 83-28 and closed the item ou Based on the inspection documented in inspection report 50-112/85-17 and the August 5, 1985 SER, TI 2515/91 was close No violations or deviations were identifie E. (0 pen) TI 2515/93 - Inspection for Verification of Quality Assurance Request Regarding Diesel Generator Fuel Oil-Multi Plant Action Item A-15 (25593) (MPA-A-15)

A review performed by NRR at Arkansas Nuclear One, in 1979, found that diesel generator (DG) fuel oil was not on the Q-list for Units 1 and Subsequently, on January 7,1980, NRR issued by letter the following request to all power reactor licensee "You are requested to review your Quality Assurance Program ;6n regard to diesel generator fuel oi If you do not include diesel generator fuel oil in your Quality Assurance Program we request you include it within 90 days of receipt of this lette However, if you take exception to this position and do not comply, we request a response within 90 days of receipt of this letter which provides justification for your not complying with our position."

A follow-up inspection was performed at Rancho Seco to verify licensee action related to the NRR reques The licensee had received the letter on January 21, 198 However, the licensee had no record of a response to the January 7,1980 letter regarding QA requirements for DG fuel oi Rancho Seco TS 4.6.B.2, contain sampling and analysis requirements for specified chemical and physical properties for new DG fuel oi Rancho Seco Surveillance Procedure SP.941, revision 1, Variable Frequency Standby Diesel Generators (G-100 A/B and G 886A/8) Fuel Oil

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Analysis, provided the implementing procedure for TS 4.6. requirement A review of the procurement documents and QA program and procedures

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was performed to determine the QA requirements for DG fuel oi The review identified the following.

l (1) Purchase Requisition Worksheet 25641, dated July 13, 1988 provided a blanket purchase order for 4,000,000 gallons of diesel fuel oil to be delivered within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of notificatio The diesel fuel oil is purchased as Quality Class III - Balance of Plan The Diesel Fuel Oil is not purchased as safety-related materia No receiving inspection data report was prepared for the blanket purchase orde (2) No QA/QC receiving inspection was required for the Diesel Generator Fuel Oil. Performance of the SP.941 tests were required, however, prior to of f-loading the diesel fuel oi No QA/QC involvement was specifically required for sampling, analysis.. acceptance, or off-loading of the diesel fuel oi (3) No requirements or provisions for commercial grade dedication or upgrading of diesel generator fuel oil was availabl (4) The diesel generator fuel oil was not listed ire the master equipment lis The above noted inspector findings were discussed with the license The licensee committed to review its controls on diesel generator fuel oil and provide a response to the January 7, 1980 NRR lette Pending licensee submittal of its response to the NRR letter, NRR review and approval / comment, and verification of licensee compliance with its commitments, TI 2515/93 was left ope '

No violations or deviations were identifie . Exit Interview (30703)

The inspection scope and findings were summarized on July 15, 1988, with those persons indicated in paragraph 1 abov The inspector described the areas inspected and discussed in detail the inspection finding Licenseo representatives acknowledged the inspector's finding L l