IR 05000312/1987036

Insp Rept 50-312/87-36 on 871026-30 & 1116-20.No Violations Noted.Major Areas Inspected:Licensee Actions on Previously Identified Inspector Items & LERs

ML20238C785
Person / Time
Site:	Rancho Seco
Issue date:	12/14/1987
From:	Ang W, Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20238C784	List: IR 05000312/1987036 ML20238C781
References
50-312-87-36, NUDOCS 8712310214
Download: ML20238C785 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-312/87-36 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 Conducted: October 26-30, 1987 and November 16-20, 1987 lh DA /2-M- 8 7 Inspection by: R/ V gS% ,

W. P' ng, Proj6ct Inspector Date Signed Approved by:

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Miller, Chief, Project Section 2

/2-/N[7 Date Signed Summary:

Inspection on October 26-30, 1987 and November 16-20, 1987 (Report No. 50-312 87-361

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Areas Inspected: Routine announced inspection by a region based inspector of licensee action on previously identified inspector items, and Licensee Event Report Inspection Procedures 30703, 36100, 92700, 92701, and 92702 were used during this inspectio Results: In the areas inspected, no violations or deviations were identifie I

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8712310214 871215

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DETAILS Personnel Contacted

• G. C. Andognini, CE0-Nuclear

• B. Croley, Director, Technical Services J. Vinquist, Director, Nuclear Quality

• Cranston, Nuclear Engineering Manager D. Brock, Nuclear Maintenance Manager (Nu-Tek)

K. Meyer, Licensing Manager T. Fetterman, United Energy Services Corporation, Electrical Engineering Manager E. Gough, Bechtel, Nuclear Engineering Department, Supervisor J. Browning, Incident Analysis Group J. Robertson, Nuclear Licensing Engineer S. Wood, Nuclear Documents Supervisor

• Attended the exit meetin The inspector also held discussions with other licensee and contract personnel during the inspectio This included plant staff engineers, technicians, administrative and clerical assistant . Onsite Follow-up of Written Reports of Nonroute Events (92700) (Closed) Licensee Event Reports (LER) 86-10-L1, 87-13-L1, 87-26-L1

- Cable Raceway Tracking System (CRTS) Related Items The subject LERs reported various discrepancies related to cable design and installatio The CRTS reported discrepancies had been previously inspected and the inspection scope'and findings were documented in Inspection Reports 50-312/87-06 and 87-? On April 3, 1987, the licensee submitted to the NRC a Wire and Cable Program Description and Action Plan. Rev. 1 of the above noted LERs were submitted by SMUD via letter GCA 87-005 dated July 30, 198 The letter stated that a Wire and Cable Action Plan nanthly report will be submitted to the NRC, and revisions to the LERs will no longer be used unless significant changes to the LERs are discovere The acceptability of the licensee's wire and cable program is ,

identified as an open issue in the Rancho Seco Restart Safety l Evaluation Report (SER). Furthermore, the lack of quality control )

(QC) inspections regarding cable routing was identified as violation 1 87-21-01. On the basis of the open SER item and violation, the LERs will be administratively close (Closed) LER 87-28-L0 - Actuation of Emergency Diesel Generator (EDG)

Due to Switchyard Overvoltage Condition l

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The LER reported that during cold shutdown conditions, a high voltage on the electric power switchyard was sensed by the emergency

, power supply and resulted in the automatic actuation and start of l the "B" Bruce /GM EDG. The sequencer unloaded and reloaded the bus and the EDG operated satisfactorily.

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! The LER stated that its corrective action would be the proposed Technical Specification (TS) Amendment 147, Revision 2, which was submitted to provide enhanced control (alarm only instead of trip)

of bus voltage and prevents bus trips and spurious EDG actuation due to the over-voltage conditions. Proposed T5 Amendment 147 is being reviewed by NR LER 87-28-LO was close C. '(Closed) LER 87-32-L0 Inoperable Low Temperature Overpressure Protection The LER reported that the low temperature overpressure protection (LTOP) system was rendered inoperable due to surveillance testing of the power operated relief valve (PORV) isolation valve, contrary to Technical Specification (TS) 3.2.2.1. The LER attributed the TS violation to an incorrect interpretation of the T The LER further stated that as corrective action, the incorrect TS interpretation will be voided and the surveillance procedures (SPs) will be changed. The LER stated that evaluation of conditions at the time of the TS violation shows that the violation did not significantly increase the already low potential for a LTOP transient degrading plant safet An inspection of the licensee evaluation and corrective action indicated that the licensee had performed a reasoneble evaluation and had performed the corrective actions committed in the LE SP 207.03A was replaced by SP.60 which included limits and precautions regarding availability of LTO In addition, the incorrect TS interpretations had been voide The LER was close (Closed) 10 CFR 21 Report 85-02-P - Anacon Chlorine Monitors The .Part 21 report, submitted by the vendor - Anacon, stated that during environmental testing, epoxy, used to hold parts of its chlorine monitors probes, had lost its adhesive properties. The report further noted that chlorine monitors were supplied to Rancho Seco. The licensee's review of the Part 21 noted that Rancho Seco had three Anacon chlorine probes. The licensee called Anacon, informed Anacon of the model numbers of the probes, and were informed by Anacon that the probes currently at Rancho Seco had been previously modified at the factory to eliminate the problem with the epox This item was close (Closed) 10 CFR 21 Report 86-23-P - Stationary Sleeve on Thrust Bearing of Atwood and Morrill Main Steam Isolation Valve (MSIV)

Must Be Machined To Prevent Galling The Part 21 report was submitted by Trojan Nuclear Plant and identified a potential for galling of a stationary sleeve on the

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thrust bearing of Atwood and Morrill valves. The specific valves identified were reverse seated check valves that are held open by air pressure and are used as main steam isolation valves at Troja The licensee review of this Part 21 identified that Rancho Seco does not have MSIV's similar to Trojan. Furthermore, the review noted that although Rancho Seco has 30 Atwood and Morrill valves, none of them are of the design described in the Part 21 report, and none of them are installed in a safety-related application. This item was close '(Closed) 10 CFR Part 21 Report 86-26-P - Changes in Allowable:

Operating Repeatability Ranges of SOR Inc. 9, 8 and 1 Pre-Fixed Pressure Switches The Part 21 report was submitted by SOR Inc. and reported that its gauge pressure switches with 9, 8 or 1 prefixes had been demonstrated to yield a 5% of full scale repeatability in lieu of its design repeatability of 1% of full scal i The licensee review of this Part 21 report determined that Rancho l Seco does not have any of the models listed in the report. This item was close . Follow-up on Items of Noncompliance (92702) '(Closed) Violation 86-22-02 - Failure to Store QA Records in Vault The violation identified that surveillance and calibration records were stored in the I&C shop ANSI /ASME NQA-1 Supplement 175- On September 26, 1986 the licensee submitted its response to the violation. An inspection of the licensee's corrective action was performed and documented in Inspection Report 50-312/87-01. The report left the item open due to a corrective action completion date of December 1989, the need for a submitted QA plan that meets NQA-1 Supplement 175-1, and the need for the licensee to assess its own corrective action i On April 24, 1987 the licensee submitted its Records Management program including commitments to ANSI /ASME NQA- !

On June 26, 1987, the licensee revised its response to the Notice of Violation and committed to have all QA records indexed and protected in accordance with Rancho Seco procedures by September 1, 198 On August 24, 1987, NRR documented by memorandum to Region V its review and acceptance of the licensee's records management pla An-irspection of the Rancho Seco records management process was performed to verify licensee compliance with its committed corrective action. An inspection of the QA records storage area and discussions with records personnel indicated that the licensee was i complying with its QA records storage commitments. An inspection i was also performed on maintenance QA records in general and I&C i records in particular. The inspector noted that in process records )

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were being kept by the maintenance shops but were being well controlled and documented. Completed QA records were being sent to l the QA records vault. The inspector was informed that a QA records l audit was in progress during the inspection. The inspector l encouraged, and the QA Department acknowledged, utilization of its l audit to assure compliance with its QA records commitments. The licensee corrective action appeared to have complied with its

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commitments. The violation was close (Closed) Violation 87-13-03 - Special Process, Liquid Penetrant Inspection (P1) Was Not Performed With A Work Controlling Document The violation identified that PT was performed on the Spent Fuel Pool liner without an approved document or procedure which included an acceptance criteria. The licensee response to the violation was submitted to Region V on August 11, 1987 and acknowledged by Region i V on August 20, 198 Licensee review of the violation noted that the PT inspection cited was an "information only" PT rather than the code acceptance PT inspection, which was provided for in existing procedures. As a result, the licensee instructed both planning and QC personnel to specify and perform PT only when appropriate acceptance criteria are also specifie In addition the licensee committed to revise QC procedure NDEI 0901 to add a Level III NDE Examiner review of :

"information only" PT request to assure that appropriate criteria and technique are applied and that the achieved results would be meaningful . The commitment was entered by the licensee in its commitment tracking syste l The violation was close !

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f Violation 87-16-01 - Stroke Testing of Valves

The violation identified the licensee's failure to test Turbine i Throttle Stop Valves and Reactor Coolant Pump Seal Injection Valves );

in accordance with the licensee's approved Inservice Test (IST)

progrom and ASME Section XI. The licensee responded to the Notice l of Violation 'on June 26, 1987 and Region V acknowledged the response 1 on July 14, 1987. On June 25, 1987 the licensee submitted its second 10 year update for its proposed IST program. On October 26, 1987, NRR provided interim approval for the licensee's submitted IST progra The licensee's corrective action and close-out review for the violation centered on submittal and approval of its updated IST program. During this inspection, the NRC inspector noted that specific corrective action for the valves cited had not yet been l accomplished. Procedures for the surveillance had not been revised, J testing had not yet been performed and licensee corrective action i verification was not complete. Pending completion of licensee l corrective action, the violation was left ope No new violations or deviations were identifie ,

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4. Follow-up of previous Inspection Items (92701) (Closed) Inspection Follow-up Item (IFI) 85-14-02 - Implementation of Equipment Qualification (EQ) Procedures l

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A 1985 EQ program inspection (50-312/85-14) found the licensee's program to be acceptable. However, a problem was identified during the inspection regarding the failure to remove and lack of instructions ~for removal of drain plugs in Limitorque operator During the inspection, the licensee issued instructions and the plugs were remove The inspection report also noted that SMUD's E program implementation procedures was still in transitio IFI 85-14-02 was opened to provide for future monitoring and NRC

. inspection of the licensee's progra Licensee review, follow-up and closure of this item noted that Nuclear Engineering and Maintenance procedures have nc been issued to provide for EQ program implementation and contro A Region V inspection of the licensee's implementing program will be included in future routine inspections. On the basis of the licensee's review, follow-up and closure of this item, the IFI was

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close (Closed) IFI 86-25-01 - Clarification of QA/QC Procedures Addressing SAR QAP Description During a QA program inspection, the NRC inspector noted that QA program changes could be implemented prior to MSRC's review for reduction of commitments. The NRC inspector also noted that the licensee's SAR QA program had not been reviewed and approved by the NRC in accordance with 10 CFR 50.54(a) and identified the ..

observations as IFI 86-25-01. On May 1, 1987 and September 13, 1987, the licensee submitted the Rancho Seco Quality Manual (RSQM)

to Region V for review and approval. On October 13, 1987, Region V accepted Revision 2 of the RSQM. QA Implementing Procedure 0501 now requires any changes to the Rancho Seco Quality program to be reviewed for potential reduction to commitments to the NR It further requires that changes that reduce NRC commitments be approved by the NRC prior to implementatio Discussions with the NRC inspector who opened the IFI and subsequently reviewed and participated in the approval of the RSQM indicated that the current licensee program satisfied the IFI 86-25-01 concern The IFI was close ! (Closed) IFI 87-04-01 - Resolve Splices Which Were Not Properly Installed and Corrections to EQ File IFI 87-04-01 noted that the licensee was revising its Installation Procedure for Okonite Tape (EM-137) to include instructions for l inspecting and correcting splicts for burrs and sharp edges prior to l tape installatio The IFI identified a concern about previously l

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I completed splices that did not include a specific QC inspection for l burrs and sharp edge EM-137 Revision 4 added specific instructions for removal of burrs and sharp edges from splices and included a QC hold point. The licensee review for previously completed splices noted that:

(1) Although not provided for in the procedure, craft training did include inspection / removal of sharp edges and burrs from splice connection ;

(2) EM 137 required filling in irregular surfaces with small strips of tape prior to application of final layers of tape. This would minimize effect of sharp edges or burr (3) Should the electrician fail to remove sharp edges or burrs and damage the insulation tape and not correct it, QC witnessing of the splice work had been previously required and should have identified this conditio The NRC inspector reviewed revision 4 of EM-137 and previous revisions to the procedure. The NRC inspector concluded that the licensee had performed a reasonable evaluation of the noted

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I condition. In addition, the NRC inspector requested the observation of a performance of a splice with purposely induced sharp edges and burrs. The NRC inspector confirmed during the observation that the licensee's evaluation was reasonable because of the texture and composition of the okonite tape and because of the fill process used in the splic The IFI was close D. (Closed) IFI 87-06-09 - QAP 17 Concerns The IFI identified the following concerns regarding QAP-17 Revision 4, Nonconforming Material Control:

QAP 17 does not address potential 10 CFR Part 21 and 10 CFR Part 50.73 reporting requirement General Requirement paragraph 6.3 of QAP 17 allows the use of a 5-day memo for non-operational nonconforming conditions in lieu -

of a nonconforming report (NCR). QAP-17 does not provide any controls or requirements (record keeping, close-out controls etc.) for 5-day memo QAP 17 procedure paragraph 2.1 allows NCR's that are determined to describe a condition that was not a nonconforming condition, to be returned to the originator without a control numbe No auditable record of returned NCR's is require QAP 17 procedure paragraph 2.6 requires a copy of all

'" Operational NCRs" to be sent to the Unit Operations

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Superintendent for review and action to assure operations in compliance with license * requirements, however, QAP 17 does not  ;

require immediate NCR notification of the Unit Operations (

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Superintendent when the plant is operating to assure prompt license complianc QAP'17 procedure paragraph 3.1 requires NCR disposition action ,

to include determination of cause and action to preclude  !

recurrence but does not . consider potential generic nonconforming condition evaluation for significant conditions adverse to qualit QAP 17 procedure paragraph 13.0 allows NCR's with control numbers to be voided upon review and approval by the Engineering Review Board. No criterion is provided for ERB approval to void the NC The licensee's review and corrective action for the above noted concerns resulted in several changes, additions and deletions to QAP-17 and QAIP-1 The NRC inspector reviewed the licensee's corrective action and procedure changes. The NRC inspector concluded that the identified concerns had been adequately provided for. The item was close E. [ Closed) IFI-87-13-04 - Part 21 Deportability of LER 85-15-L0 RM-80 Printed Circuit Board Inspection Report (IR) 50-312/87-13 reviewed and closed LER 85-15-LO. However IR 87-13 opened IFI-87-13-04 due to a concern with regard to 10 CFR Part 21 deportability. IR 50-312/87-21 reviewed the licensee evaluation for IFI 87-13-04 and concluded that the item was not subject to Part 21 reporting requirements, no similar failures have occurred at Rancho Seco and that the item was close However IR 87-21 inadvertently closed LER 85-15-L0 (previously closed) in lieu of IFI 87-13-0 The IFI is now administrative 1y close F. (0 pen) Unresolved Items (URI) 86-18-05 and 86-18-06 - High Point Vent Piping Classification and Seismic Analysis On March 4, 1986, NRR issued an SER regarding Rancho Seco High Point Vent Evaluation and provided quality and seismic classifications for various portions of the high point vent pipin URI 86-18-05 and 86-18-06 identified discrepancies between the SER classifications and the piping design. On September 16, 1986, the licensee submitted its response to the URI's and the identified SER discrepancies. In summary, the licensee's position was that the high point vent piping code and quality classifications were in accordance with the guidance applicable during licensing and that L

upgrading to current day standards should be reviewed as a backfit.

l The response, however, stated that the RC vent line from the first I isolation valve to the piping supports in the nitrogen supply line had been analyzed to seismic Category I requirement The installed piping, the piping stress analysis and the IEB 79-14 inspections performed on the subject piping were inspected by the

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NRC inspecto Based on the above noted inspection, the.NRC inspector confirmed that the subject piping had been seismically analyzed and that the licensee had performed an adequate IEB 79-14 inspection on the subject piping. Furthermore the~ licensee had a configuration control procedure, NEP 4109, Revision 7, that requires-a walkdown for any engineering change notice affecting seismics category I piping to validate the piping stress analyses. 'The licensee noted that similar walkdowns was also being considered for maintenance activitie The inspector's findings were discussed with the NRR reviewer to clarify the issu The NRR reviewer indicated that the inspection findings would be considered for the final evaluation of the issue and that final resolution of the issue would be provided by -

mid-Decembe Pending NRR disposition of the issue, the URI's were left ope No new violations or deviations were identifie . Administrative Closure of Open Items The following LER's were administratively closed due to later revisions being issued:

86-10-L0 - Rev.1 issued 86-21-L0 - Rev. 3 issued 86-21-L1 - Rev. 3 issued 86-21-L2 - Rev. 3 issued 87-06-L1 - Rev. 2 issued 87-13-LO - Rev.1 issued 87-26-LO - Rev.1 issued

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6. Exit Interview The inspection scope and findings were summarized on November 20, 1987, 4 with those persons indicated in paragraph 1 above. The inspector f described the areas inspected and discussed in detail the inspection j findings. Licensee representatives acknowledged the inspector's j finding I I

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