IR 05000312/1986025

Insp Rept 50-312/86-25 on 860707-11.No Violations or Deviation Noted.Major Areas Inspected:Licensee Action on Inspector Identified Items & Implementation of QA Program Requirements

ML20212D151
Person / Time
Site:	Rancho Seco
Issue date:	07/22/1986
From:	Wagner W, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20212D149	List: IR 05000312/1986025 ML20212D145
References
50-312-86-25, NUDOCS 8608120402
Download: ML20212D151 (5)

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- s U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-312/86-25 Docket No. 50-312 License No. DPR-54 Licensee: Sacramento Municipal Utility District P. O. Box 15830-Sacramento, California 95813 Facility Name: Rancho Seco Nuclear Generating Station ,

Inspection at: Clay Station, California Inspection Conducted: July 7-11, 1986 Inspector: lh' $4tf/hV 7~/6~ 86 l Wagner eactor. Ins e tor Date Signed Approved by:

T. Young, Jr.,

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eering Section

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Date Signed Summary:

Inspection on July 7-11, 1986 (Report No. 50-312/86-25)-

Areas Inspected: Routine, unannounced inspection by regional based inspector of licensee action on inspector identified items and implementation of Quality Assurance Program requirements. NRC inspection procedures 92701, 92702, and 35701 were covered during this inspectio Results: No violations or deviations were identifie ,

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DETAILS Persons Contacted

'SMUD Personnel

• J. McColligan, Assistant' Manager, Nuclear Plant

• C.'Stephenson, Regulatory Compliance Engineer

• B.:Croley, Nuclear Technical Manager

• T. Tucker, Operations Superintendent

• Q. Coleman, Site' QA Supervisor

• C. Linkhart, Electrical Maintenance Superintendent

• D. Reese, Engineering Aid

• F. Hauck, Senior Engineering Technician

• T. Khan, Principal Mechanical Engineer

• Denotes those attending the exit meeting on July 11, 1986. Licensee Action on Previously Identified Items (Open) Notice of Violation No. 50-312/85-08-01 " Battery Maintenance Procedure and Data Errors" The inspector's review of procedures'for_. battery' testing (SP 206.4, EM.104, EM.105, and EM.106) identified numerous procedural errors, such as insufficient listing of criteria for an equalizing charge, no confirmatory measurement of pilot cell voltage, and incorrectly specifying cell voltage as an acceptance criterin. In addition, review of battery test records revealed errors which, in certain cases, resulted in an inaccurate comparison of new test data to the old data. The licensee responded by committing to upgrade the four battery testing procedures to decrease the potential for making errors during the running of these battery tests. The inspector reviewed the following procedures to assure that the errors or weaknesses identified were properly addressed: .i

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(1) EM.104 Revision 8: This procedure was replaced with EM.104 ~

The pilot cell criteria for performing equalizing. charges correctly specifies a difference in specific gravity ]

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measurements as the acceptance criteria, instead of a cell voltage measuremen (2) EM.105 Revision 11: Section 5.3 was revised in Revision 12 to read .05 volts instead of'.005 volts. Reason for the change was to correct a typographical error. The current procedure EM.105A requires the cells to have a-specific gravity of 1.205-1.225, and values less than 1.205 will require an

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equalizing charg (3) EM.106 Revision 4: Section 6.0 was revised in Revision 5 requiring the taking of hourly readings of charger and pilot cell (specific gravity and cell voltage) for a period of 8 ,

hours. This requirement provides confirmatory measurement-of *

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pilot cell specific gravity and cell voltage to ensure that the

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equalizing charge was effective. However, the procedure was not revised to address a weakness identified in NRC inspection 85-0 The procedure does not specify the step which is to be used when starting an equalizing charge without performing a discharge firs (4) SP 206.4: Section 4 of this procedure was revised to assure that all the possible criteria required for an equalizing charge addressed in procedures EM.104, EM.105, and EM.106 are satisfie This item will remain open pending the inspector's review of EM.106 and licensee's actions in response to errors identified on the battery test result (Closed) Unresolved Item No. 50-312/83-25-06 " Check on PORV Pointer Position and History" The inspector was informed by an anonymous source that the PORV pointer may have fallen off of the operating lever between May 1979 and August 1983. Technical Specification Table 4-1-1, Item 52, requires a monthly check of this indicato The inspector's review of this concern revealed that monthly surveillance checks were not a Technical Specification requirement until Amendment 31 of March 21, 1981. Prior to this date, the PORV (EMOV-PSV 2151) was being continuously monitored by a TV camera in the Control Room. Had the pointer fallen off the operating lever, it should have been reported by one of the Control Room operator Up until July:1981, this condition would have been reported on either a Work Request (WR) or an Occurrence Description Report (ODR); after July 1981, this would have been reported on a WR, ODR, or during the monthly surveillance check. The inspector reviewed the monthly Surveillance Log Sheets from July 1981 to July 1986, initiated a computer search for any Work Requests having been performed on the PORV, and reviewed the ODR records. This review-revealed no information regarding an incident involving the PORV point'er. However, the licensee did provide the inspector with a copy of LER No. 83-28 which might have contributed to this reason for this concern. LER No. 83-28 reported that on September 19, 1983, the PORV (EMOV-PSV 2151) system failed to open and could not be shut. A Technical Specification requirement for indication of power to the solenoid resulted in the addition of a metal pointer to the valve actuating lever to show position of the pilot valve plu Since the PORV is a completely enclosed valve, this pilot valve actuating arm was chosen, as it is virtually the only externally accessible feature that indicates whether the solenoid energizes properly., The corrective action was to " remove the pointer" from the actuating arm and to use the actuating arm itself as a pointer by providing a contrasting background behind the arm, suitably marked to indicate open and closed positions.

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Based on th'e above review, the inspector concludes that.the pointer did not fall off the operating lever but was intentionally removed as reported in LER NO. 83-2 This item.is close (Closed)i Followup Item No. 50-312/84-19-01 " Preventive Maintenance on Hydrogen Panel Alarm Not Being Performed" The inspector reviewed the recommendations for Preventive Maintenance (PM) to be performed on the hydrogen alarm panel. This matter was identified and documented in QA Audit 0-645 as Item-2.b.1.b., which requested Nuclear Operations (I&C) to determine what preventive maintenance, if any, should be performed on the alarm panel. The response, documented on office memorandum RPO 84-467, was to have the PM. of the' alarm panel . incorporated into the PM program by October 4, 1984. =The inspector verified by reviewing the

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PM work request for this panel that this item was added to the PM progra This item is close (Closed) Unresolved Item No. 50-312/85-17-02 " Class 1 Work Performed on a Class 2 Work Request" Work Request No. 89949 on the reactor trip breaker CRD-A was initiated as a QA Class I work request but later changed and worked as a QA Class 2 request. The licensee's review into the reason for this change is documented on an office memorandum from C. Linkhart to S. Crunk of November 2,1985. The work request was written against equipment CRD-A which is listed as QA Class 1; however, the engineer recognized that the problem was not on CRD-A but was actually on the voltage regulator and the current meters which are both QA Class 2. The engineer changed the QA class on the work request but did not change the equipment ID. The work request was

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subsequently revised to reflect this change along with an explanation for the chang This item is close No violations or deviations were identifie . Quality Assurance Program The inspector reviewed the following quality procedures established by the. licensee for control of the Nuclear Quality Program as described in the Safety Analysis Report: Quality Assurance Procedure No. Policy Section II, Revision 0, of January 1, 1986, " Quality Assurance Program." Quality Control Instruction (QCI) No.-15 Revision 0, of March 10, 1986, " Approval of Changes to the Quality-Assurance Program Described in the Safety Analysis Report."

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QCI-15, Section 3.0, states that it.is the responsibility of the Manager of Quality to review and. approve proposed changes to the Nuclear Quality Program, and that this review and approval is to be documented on a QA Procedure Review (Form - Enclosure No. 1). However, the Form indicates review and approval by the Management Safety Review Committee (MSRC).,

The Nuclear Quality Manual, QA Policy Section II, Section 5.4.5, requires changes to the Nuclear Quality Program to be reviewed by MSRC to determine if changes constitute a reduction in the QA Program commitments.- QCI-15 allows the Manager of Quality to approve the QA Program changes. This appears to imply that.a QA Program change could be implemented prior to MSRC's review to determine if QA Program coamitments are being reduce In Section 3, pages 3-8, of the licensee's " Action Plan for Performance Improvement", it states that the QA Manual was reviewed and approved by the NRC via the 10 CFR 50.54(a) requirement. The inspector, who, in this instance, is the Region V reviewer of SAR QA Program descriptions, is not aware that the QA Manual was reviewed and approved by the NRC. The clarification of the QA/QC proceduren and the issue of the QA Program review and approval per 10 CFR 50.54(a) is considered a followup item, number 50-312/86-25-0 ;

i j No violations or deviations were identifie ,

4. Exit Meeting The inspector met with the licensee representatives denoted in paragraph 1 on July 11, 1986. The scope of the inspection and the inspector's findings as described in this report were discussed, l

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