IR 05000312/1982003
| ML20052B861 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 04/19/1982 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| Shared Package | |
| ML20052B862 | List: |
| References | |
| NUDOCS 8205040075 | |
| Download: ML20052B861 (42) | |
Text
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Docket No. 50-312 a -~ /c) 4, / .\\ IIECEIV=" Sacramento Municipal Utility District C s P. O. Box 15830 g gy 37982'_b Sacramento, California 95813 - L a arm ru.m;. --. L m a un ~ ;-" Attention: Mr. J. J. Mattimoe 1, d~ " j Assistant General Manager ,N and Chief Engineer
' j,. I Ontlemen: ! Subject: NRC Regional Evaluation of Licensee Perfonnance - Rancho Seco This refers to the meeting held at Sacramento Municipal Utility District offices in Sacramento, California, on March 23, 1982, between Mr. R. II.
Engelken and members of the Region V staff with Messrs. W. C. Walbridge, J. J. Mattimoe and others of the SMUD staff. The purpose of this meeting , was to discuss the results of NRC's regional evaluation of licensee perfor-mance for those activities authorized by NRC License No. DPR-54. A copy of this evaluation and supporting data, along with your connents on each ' functional area evaluated, are enclosed.
i Results of this, the second of NRC's planned Systematic Appraisal of Licensee Perfonnance (SALP) evaluations conducted with regard to the Rancho Seco facility, reveal areas which, although not of serious concern at this time, warrant an increase in the frequency and/or scope of our future inspection activities. We believe these areas, identified in the enclosed evaluation, represent areas where you should direct particular management I attention as well.
, l Based upon our SALP Board's assessment and its evaluation by regional l management, it is our conclusion that overall facility and corporate
performance regarding operational safety during the period June 1980 through June 1981 was Category 2.
Management attention to the several aspects of Quality Assurance, training,and maintenance have been evidenced in significant improvements observed since the previous assessment period. Your continued attention to these areas is encouraged.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2 Title 10. Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC's Public Document Room.
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~ APR 191982 - - Sacramento Municipal Utility District-2- ~ ShouTdyouhavequ'estionsregardingtheenclosedevaluation'andsup-
. porting data, we will be glad to discuss them with you.
,
Sincerely, , Ufps!'stres r3 i B.H.Engewen l R. H. Engelken Regional Administrator ,
Enclosures:
' 1.
Regional Evaluation of Rancho Seco~- June 1980 through June 1981, dtd April 13, 1982 2.
SMUD Response dtd April-9,1982 -
REGION V==
0, g 1460 MARIA LANE. SUITE 260 ' U o WAth0T CREEK, CAUFORNIA 94596
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April 19,1982 Docket No. 50-312 Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Attention: Mr. J. J. Mattimoe Assistant General Manager and Chief Engineer Gentlemen: Subject: NRC Regional Evaluation of Licensee Performance - Rancho Seco This refers to the meeting held at Sacramento Municipal Utility District offices in Sacramento, California, on March 23, 1982, between Mr. R. H.
Engelken and members of the Region V staff with Messrs. W. C. Walbridge, J. J. Mattimoe and others of the SMUD staff. The purpose of this meeting was to discuss the results of NRC's regional evaluation of licensee perfor-mance for those activities authorized by NRC License No. DPR-54. A copy of this evaluation and supporting data, along with your coments on each functional area evaluated, are enclosed.
Results of this, the second of NRC's plar ned Systematic Appraisal of Licensee Performance (SALP) evaluations conducted with regard to the Rancho Seco facility, reveal areas which, although n]t of serious concern at this . time, warrant an increase in the frequency and/or scope of our future inspection activities. We believe these areas, identified in the enclosed evaluation, represent areas where you should direct particular management attention as well.
Based upon our SALP Board's assessment and its evaluation by regional management, it is our conclusion that overall facility and corporate performance regarding operational safety during the period June 1980 through June 1981 was Category 2.
Management attention to the several aspects of Quality Assurance, training,and maintenance have been evidenced in significant improvements observed since the previous assessment period. Your continued attention to these areas is encouraged.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2 Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC's Public Document Room.
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- -- ' . . . , - . , Sacramento Municipal Utility District-2-April 19,1982 , s Should you have questions regarding the enclosed evaluation and sup-porting data, we will be glad to discuss them with you.
Sincerely, hm.$ e R. H. Engelken Regional Administrator
Enclosures:
1.
Regional Evaluation of Rancho Seco - June 1980 through. June 1981, dtd April 13, 1982 2.
SMUD Response dtd April 9, 1982
REGION V== Systematic Assessment of Licensee Performance SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SECO
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. , ' . ~ . -SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE SALP BOARD REPORT I.
GENERAL A.
Title SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE UTILITY NAME: Sacramento Municipal Utility District - FACILITY NAME: Rancho Seco EVALUATION PERIOD: June 6, 1980 to June 30, 1981 Prepared by the U.S. Nuclear Regulatory Commission Staff, Region V.
B.
Background The NRC staff has established a program for Systematic Assessment of Licensee Performance (SALP). This report provides our evaluation of the licensee's safety performance at Rancho Seco for the period June 6, 1980 to June 30, 1981.
The NRC staff's SALP Board met on September 23, 1981 to review performance data and develop.a preliminary assessment. ~ A meeting was held with licensee management on March 23,-1982 to discuss the preliminary findings. Then this final. report was developed and the licensee was provided an opportunity'to comment formally on it.
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, . Our evaluation is summarized in Section C bel'ow.
Further details and data are provided in Sections II, III, and IV. Section V describes the 11censee management meeting where preliminary findings were discussed.
Section VI provides the licensee's formal comments on this final report.- C.
Summary l Overall Licensee Management Evaluation f The licensee's performance in this period was marked by areas of l strength and weakness. The areas of corrective actions and reporting I were notably in Category.3.
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. . . At least three responses to items of noncompliance were not adequate and several Licensee Event Reports were repeat items.
The resolution of nonconformance reports and licensee event reports by the licensee appears to be slower than our experience indicates is prudent.
Items of noncompliance related to procedures have prompted the licensee to correct specific citations but have apparently not caused any deeper examinations by the licensee staff into the root causes for the identified items. Additional staff effort is needed to correct these weaknesses.
There are at least four areas where unfilled plant staff positions have occurred and are unfilled: Plant Health Physicist, plant Nuclear _ Chemist, Technical Assistant's engineering staff, and Senior Mechanical Engineer. The Senior Nuclear Engineer's position is filled by an individual in an " acting" status. The plant operation's staff currently has between four and five complete shift crows, which is less than experience has shown to be necessary to accomplish adequate training, with some allowance for time off. The staff positions described above should be filled as soon as' possible by qualified personnel either " acting" or in a permanent assignment. The operations staff should be encouraged and assisted to achieve and maintain at least five complete shift crews as soon as possible.
Two significant strengths are refueling operations and fire protection and housekeeping; both are Category 1.
The' utility has completed refueling operations and implemented the fire protection program requirements' in 'a professional'and timely manner. The housekeeping at the Rancho Seco plant is generally very good which appears to reflect a positive management attitude towards the facility.
During the evaluation period major improvements in the manning and effectiveness of the Quality Assurance (QA) organization , have occurred. The frequency and scope of QA audits appear to have substantially improved.
. Significant improvements have also occurred in the area of training due to improved staffing and record keeping for individual utility employees. However, full implementation of the training program management controls (i.e.: computerized record keeping) is still in progres. . . - e .
. . ,. Improvements to maintenance procedures and management of maintenance activities is also improving. These changes should become effective during the next SALP review cycle.
, , . Utility managers and personnel generally appear to be very j experienced and competent in their field.
Individuals appear dedicated to doing a good job ar.d general.y interested in the , safety and performance of the plant.
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- . . ' . . . ' . SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE TABULATION OF FlNCTIONAL AREA RATINGS Functional Areas Category 1 Category 2 Category 3 1.
. Plant Operations X 2.
Refueling Operations X 3.
Maintenance X 4.
Surveillance & Inservice Testing X 5.
Personnel, Training, & Plant Procedures X 6.
Fire Protection & Housekeeping X 7.
Design Changes & Modifications X 8.
Radiation Protection, ' Radioactive Waste Management, & ~ Transportation X 9.
Environmental Protection X -
, X 10. Emergency Preparedness < 11. Security & Safeguards X 12. Audits, Reviews, & Committee Activities X' 13. Administration, QA, & Records-X 14. Corrective Actions & Reporting X
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. . SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE II. LICENSEE PERFORMANCE EVALUATION Region V Facility: Rancho Seco Licensee: Sacramento Municipal Utility District Facility Information Unit 1 Docket No.: 50 '19 License No.: DPR-54 l I Date of Issuance: 8-16-74 NSSS: Babcock and Wilcox - MWt: 2772 Appraisal Period: June 6,.1980 to June 30, 1981 Appraisal Completion Date: September 23, 1981 Review Board Members: T. Young, P. Morrill, G. Zwetzig, H. Canter, J. O'Brien, G. Power, H. North, G. Hernandez, M. Padovan Attendees: Same as above . I s - _ _ _ _ _ _ _ _. _
r- . . - - . . - . . . Evaluation Criteria The various functional areas and the licensee's av rall performance were assigned a Category 1, 2, or 3 rating based upon the following - evaluation criteria: - Category 1.
Reduced NRC attention may be approp'riate. Licensee management attention and involvement are aggressive and oriented-toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
- Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate-and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.
- Cagetory 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
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. SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE - III. PERFORMANCE ANALYSIS ' 1.
Plant Operations ' A.
Analysis , The Resident Inspectors conducted daily inspections during the evaluation period.
Regional inspections touched on this area also. Two items of noncompliance and:one deviation were ' identified: _ ._ (1) Failure to maintain five full strength shift crews.
-(Deviation) ^ (2) Failure to reset nuclear power trip set point to 5 percent while plant in shutdown.
(Infraction) (3) Failure to follow procedure.
(Infraction) The facility lacked sufficient qualified operators to observe the TMI-related recommendations on overtime, so plant management authorized extra working hours. Management is making progress towards licensing more operators,however. The fact that.here are now and will soon be many new operators bears attention.
,, Not all important safety-related procedures are adhered to.
For example, the flux trip reset issue disclosed in IE Inspection Report 80-26 is a repeat issue and falls into the category of not following procedures. The licensee has taken a narrow approach to the procedure citations in that only the cited procedures have been corrected.
In-house reportable occurrences (items which do'not qualify for LERs) show a preponderence of procedure violations.
A strong point in this area is the Shift Supervisor's awareness of their safety responsibilities.
IE Report 80-34 documents a special inspection performed as a follow-up to a PAT inspection'which was performed in April /May 1980.
' B.
Conclusion ,
The Board rates this area Category 2.
C.
Board Recommendations i The Board recommends no change to the inspection effort in this ' area.
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District Response: Rancho Seco's Technical Specifications requires one Senior Reactor Operator and two Reactor Operators per shift.
presently, there are ' five operating crews. Two crews have a complement of two Senior Reactor Operators and two Reactor Operators whereas the remaining three crews have two Senior Reactor Operators and one Reactor Operator. Additionally, there are presently two individuals in the training program who have taken their examinations for a Senior Reactor License and are awaiting the results.
Predicated upon these individuals obtaining their SR0 license, it is intended that a sixth operating crew be instituted.
Each crew will meet or exceed the Technical Specification requirement of one SR0 and two R0s.
Five crews will have two SR0s and one R0; whereas, the sixth
crew will have one SR0 and two R0s. The District will continue to i make every effort to meet the schedule submitted in the November 3, 1980 letter discussing Interim Criteria for Shift Staffing.
' The NRC is aware of the effort the District is making in this area.
The training program used by the District is extensive and excellent.
The high percentage of personnel passing the licensee exaninations . reflects the competence of the program.
The District concurs with the NRC appraisal that the Shift Supervisors are Laenly aware of their safety resoonsibilities.
! 2.
Refueiing Operations A.
Analysis The Resident Inspectors conducted several inspections.of.
refueling operations. No items of noncompliance were identified. The 1981 refueling operations were performed satisfactorily.
B.
Conclusion The Board rates this area Category 1.
C.
Board Recommendations The Board recommends no change to the inspection effort in this area.
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. . District Reponse: The District has no comment.
3.- Maintenance A.
Analysis During this period, four region-based operations' inspections and monthly resident inspections were performed in this area. One item of noncompliance and one deviation were identified.
(1) Seal replaced without the use of a procedure that had Plant Review Committee (PRC) review and superintendent approval. (Level V) (2) Did not maintain the preventive Maintenance Schedule.
(Deviation) A significant amount of maintenance.was performed this cycle in the areas of letdown cooler repair, component cooling water system repair, peripheral secondary system pump motor and piping repairs and major turbine repairs.
The licensee has set first priorities on corrective maintenance and a lower priority on the preventive maintenance of mechanical components.
Consequently, preventive maintenance has been given a lower priority as seen by the deviation listed above.
In addition, there is a significant unresolved item concerning the licensee's lack of official designation of 0A Class I components.
The LER analysis (Chain 2) indicates a sequence of six events wherein various instrument settings were found to be outside specifications. This indicates the need for corrective action by the licensee in the area of instrument calibrations.
On the positive side, the licensee has implemented a program to upgrade maintenance procedures including (1) incorporation of additional inspection hold points, (2) developing improved control of vendor's technical manuals to assure that the latest revisions are utilized, and (3) shifting their maintenance scheduling and procedures to a computer system which should help in priority setting and manpower use.
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Conclusion The Board rates this area Category 2.
C.
Board Recommendations The Board recommends no change to the irspection effort in this area.
District Response: The District maintains that significant improvcments have been made in the tirea of maintenance. The LER analysis (Chain 2) is not a good indicator for definitive corrective action in the area of instrument calit, rations.
It does not address the large number of instruments being calibrated or the reasons for settings to be out of specifications.
In addition, over 30T,of the incidents did not involve safety related instrumentation. The District recognizes the need for a strong and a rigid calibration program.
Instrument drift is always a problem and requires much engineering time to find and correct instrument design and application errors.
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The District is replacing instruments when necessary. A large number of instances where instrument settings were outside of specification lie in the area of effluent water chemistry. They were not in safety related systems covered by the Technical Specifications mandated by the NRC, but lie in State of California imposed water chemistry restrictions prior to release of water (TS Appendix B).
The lack of an official QA.. Class I components list is now-being corrected. The District has dedicated the resources to solve this problem. The District acknowledges the need for a "Q" list.
Selected mechanical procedures are being upgraded to include inspection hold points, use of vendor's technical manuals and the use of a computer system to provide maintenance scheduling.
4.
Surveillance and Inservice Testing A.
Analysis Five inspections were performed by' region-based inspectors in the areas of surveillance, calibration, and inservice testing. The resident inspectors examined this area on a j monthly basis. As a result of these inspections one deviation was identified. The deviation related to failure to have clear acceptance criteria for use during visual inspection of hydraulic snubbers.
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. . . t On the positive side, although some surveillance procedures had not been upgraded to the latest requirements (ASME Section XI), the licensee's control and timely implementation of the surveillance program was excellent.
B.
Conclusion The Board rates this area Category 2.
C.
Board Recommendations The Board reconnends no change to the inspection effort in this area.
District Response: The District concurs with the SALP finding.
5.
Personnel, Training, and Plant Procedures A.
Analysis A number of NRC inspections were conducted in this area.
Two items of noncompliance were identified: (a) Failure to provide adeouate procedures.
(Level IV) (b) Procedure not properly reviewed and approved.
(Level V) Significant deficiencies had been identified in the areas of licensed and non-licensed personnel training during the previous evaluation period. While not all of the previously identified deficiencies had been fully corrected during the present evaluation period, the inspections indicated the' licensee was making a reasonable effort to implement the needed corrective action in an orderly manner.
There are Rancho Seco permanent staff positions which are unfilled. These positions include the Plant Health Physicist, the Plant Nuclear Chemist,' the Technical Assistant's engineering staff, the Senior Nuclear Engineer (position currently filled by an " acting" nuclear engineer), and the Senior Mechanical Engineer.
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- . _ , , . ' . .. There has been a concerted attempt to increase the operator staff. This effort appears to be progressing satisfactorily at the entrance level. Tha licensee has four full operating shift crews and relief personnel available.
Training was a subject of SALP activities last cycle. The record system is still informal, but computerization is on the way.
Management has provided the permanent training staff of three with help via a General Physics contract. The training program (AP700) is not completely implemented yet. However, Fire Brigade training is under good control now, with the hiring of a safety technician who specializes in fire fighting training.
The item of noncompliance (b) involved failure of the Plant . Review Committee to review the Inservice Inspection Program procedures.
Investigation of a LER led to the finding that the licensee was not performing inservice testing of the high pressure injection and makeup oumps as required by 10 CFR 50.55a(g) and Section XI of the ASME B&P'i Code. An item of noncompliance (a) was issued as a result of thir, finding.
B.
Conclusion The Board rates this area Category 2.
C.
Board Recommendations The Board believes continuing efforts are required by the licensee in the areas of manning and training.
No change to the existing inspection program is recommended.
District Response: The only staff position cited by the SALP Team for which an available candidate has not been found is the Plant fluclear Chemist.
The District is actively seeking a qualified candidate.
Five recent applicants failed in meeting the District's minimum requirements.
Status is covered in the Overall Licensee Management Evaluation section. The District recognizes the nead for an active recruitment program to fill vacant positions when they occur.
The District has dedicated considerable resources in the training area. Although the training program is not completely implemented, the District feels significant progress has been made since July 1981.
The next SALP review should document the significant progress in this a rea.
The great effort expended by the District in Fire Brigade training was acknowledge'd by the SALP Team and the District agrees with their appraisal.
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Fire Protection and Housekeeping A.
Analysis There have been no citations in this area. All inspections have included examinations of housekeeping and aspects of fire protection. New personnel have been hired to implement new programs.
B.
Conclusion The Board rates this area Category 1.
C.
Board Recommendations The Board recommends no change to the inspection effort in this area.
District Response: The District concurs with the SALP finding.
7.
Design Changes and Modifications A.
Analysis As a result of SALP concerns expressed during the previous evaluation period, additional inspections of this' area were performed by region-based inspectors.
A' portion'of the inspection concentrated on review of modifications of no'nsafety-related systems and the possible effects of ~these modifications on safety-related systems. Modifications of safety-related systems were also reviewed with emphasis ~on assuring that structural as well as functional effects of the modification were considered.
In general, the licensee appeared to have an acceptable system for controlling design changes.
' One item of noncompliance was identified in this area: Failure to make a valve-fail closed on loss.of DC power to a solenoid.
(Infraction)
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-- . . - - . . After lengthy discussions with the NRC the licensee 73 reed that the above issue needed corrective action. The interim action was satisfactory.
During this period, there has been a.high level of activity, due mainly to the large number of,Three Mile Island requirements.
The level will remain high at least for the rext two years. The licensee is aware of the large workload and is struggling'to complete the work as timely as possible. During this review period, the Security and Fire Protection' modifications were completed.
B.
Conclusion < _ . The Board rates this area Category-2.
' C.
Board Recommendations The Board recommends that the present level of effort in this area be maintained due to the large amount of. work being completed by the licensee.
' District Response: The large amount of design changes resulting from the Three Mile Island requirements has necessitated a significant increase in engineering staff, both in the area of District personnel and A/E support personnel.
Training programs, changes to control procedures and a number of audits have been performed to establish a confidence level that satisfactory controls are in effect on design changes.
The District anticipates difficulty in. meeting design and modification targets.
Considerable effort is being expended to have the available resources on-site to begin the TMI modifications at the next refueling scheduled for the Fall of 1982. The NRC is being continually updated on the District's progress in this area.
8.
Radiation Protection; Radioactive Waste Management and Transportation A.
Analysis Seven inspections have been preformed during the evaluation period: an Health Physics (HP) Appraisal and six by the Reactor Radiation Protection Section including two confirmatory measurement inspections.
The resident inspectors conducted daily' inspections in these areas. Two items of noncompliance were identified: (1) training provided to workers did f , . . - . .
not fully satisfy the requirements of 10 CFR 19.12, " Instructions to Workers," and (2) a retraining prograin for chemistry / radiation protection personnel had not been - fully iriplemented. No escalated enforcement actions were , taken.
The most significant radiological occurrence during the appraisal period was a steam generator tube failure while the plant was at full power. This resulted in the uncontrolled' release of less than 4.5 curies of noble gases during the first 15 hours after the event. A large quantity of secondary system water which was contaminated by the event was processed, analyzed, and released with dilution off-site under controlled conditions over a period of approximately one month. The gaseous and liquid releases did not exceed applicable Technical Specification or Regulatory limits.
During the appraisal period no personnel exposures in excess of regulatory limits were identified.
The plant health physicist resigned in October 1980 and had not been replaced by the end of the appraisal period. The licensee has qualified radiation protection personnel, able to substitute for such an individual, however, the continued staff vacancy impacts on the continued development and maintenance of the health physics program.
No specific inadequacies in the health physics area, attributable to this staff vacancy, have been identified.
During the appraisal period the licensee shipped significant quanities of packaged solid waste thereby redu'cing the potential for exposure of certain of the environmental TLDs located in proximity to the waste storage area. The LER Analysis and Conclusion identified a problem in this area as Chain 3.
The waste shipments offsite appeared to correct the problem.
B.
Conclusion The Board rates this area Category 2.
C.
Board Recommendations The Board recommends that the licensee should be advised that the failure to fill the health physicist postion appears to weaken the management of the Health Physics Program.
The Board recommends no change to the inspection effort in this are, ! , ' . , . + . , - . s - . District Response: The District concurs that staffing has been a continual problem in the radiation protection area. Contract personnel have helped to alleviate some of the concern.
It should be noted that no specific inadequacies were identified by the SALP Team.
As previously stated, the Plant Health Physicist position has been filled.
9.
Environmental Protection A.
Analysis During the evaluation period there have been four inspections by the Resident Inspectors to observe the collection of environmental media samples.
No regional office environmental inspections were conducted during the appraisal period.
The LER Analysis and Conclusion identifies as Chain 4 (Environmental Protection) a series of events concerning plant effluent pH limits. The LER reviewers' conclusion that the problem does not appear to have been solved is correct, however, the concern is not of direct NRC interest since the courts have ruled that NRC lacks jurisdiction to regulate in the area of nonradiological water quality.
B.
Conclusion The Board rates this area Category 2.
C.
Board Recommendations The Board recommends no change in the inspection program.
District Response: The District concurs with the SALP finding.
10.
Emergency Preparedness , A.
Analysis During this evaluation period the Resident Inspectors witnessed three emergency drills.and the regional inspectors witnessed one.
Weak areas were observed in communications and control of personnel at the assembly points during the drills.
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f? . - . " . ( . A special appraisal of the emergency preparedness program was performed in June 1981.
One item of noncompliance was identified during the appraisal. An Immediate Action Letter that identified 21 items needing timely corrective actions was issued. Additional items that need corrective action will be identified in the letter transmitting the appraisal report to the licensee. The areas needing-improvement included training / retraining, emergency plan implementing procedures, coordination with offsite groups and drills / exercises.
Some improvements in facilities and equipment and organization are also needed; however, these areas were found to be above the minimal level of acceptance.
By letter dated June 30, 1981, SMUD requested a temporary exemption from the requirements of Section IV.D.3 (notification of the public within 15 minutes after declaring an emergency) of Appendix E to 10 CFR Part 50. The letter describes the dates by which action was and will be taken.
A July 24,1981
letter to the NRC Region V Director states that the public notification system will be activated by May 1982.
The July 24 letter also says they will take evacuation support actions described in the FSAR (Section 12.4.5.4.4) and notes that the Sacramento County Sheriff's Department has a helicopter equipped with a public address system'available for use in alerting the population at risk. The NRC has not yet acted ~ upon the SMUD exemption request in the June 30,1981 -letter.
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Conclusion
' The Board rates this area Category 2.
C.
Board Recommendations
The Board recoamends.no change to the inspection effort in this area.
District Response: _ - The District recognizes improvement is needed in the area of Emergency Planning. This program is underway and will culminate.with an intensive full-scale test during June 1982. The District will. evaluate the results of the drill and make improvements on any identified areas of concern.. - . ' . a 11. Security and Safeguards A.
Analysis ~ During the evaluation period, five inspections were conducted by the Physical Security Section of the Safeguards Branch.
One of the inspections was accomplished with the assistance of the resident inspector. There was one item of noncompliance as reflected in Inspection Report 81-09 where'.1 the licensee failed to secure a vital area. As a consequence, this violation was assessed as a Severity Level III (with no civil penalty). This item of noncompliance appeared to be the result of an error in judgement on the part of the licensee's personnel in securing, or compensating for, an open vital area door.
During this period, SMUD significantly increased its site security by implementing all aspects of their security system to meet the physical security " upgrade" requirements. Their " upgraded" security system included but not limited tc,: (i) installation of an Uninterruptible Power Supply, (ii) modification of the protected area-lighting, (iii) completion and operation of the Personnel Access Portal (to include installed metal detectors, explosive detectors, and X-ray equipment), (iv) implementation of the computerized security subsystem (e.g., CRT terminal and keyboard; site and Vital Area Access Control with card readers and card-keys; alarm printer; etc.), (v) operation of a new Central Alarm Station and Secondary Alarm Station, (vi) utilization of closed circuit television cameras (with monitors) within the protected area, and (vii) ~ establishment of the perimeter microwave. intrusion alarm subsystem.
Additionally, IAEA visited to the plan't, site to conduct routine safeguards implementation inspections.
- B.
Conclusion ' , The Board rates this area Category 2.
. C.
Board Recommendations The Board recommends no change to the inspection effort in this area.
District Rr'.oonse: The Distri a concurs with the SALP finding.
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. . ~ . <t . 12. Audits, Reviews, and Committee Activities A.
Analysis . Nine inspections by regional and resident inspectors were-performed in these areas. Three items of noncompliance and one . deviation were identified.
' (a) Licensee did not conduct comprehensive planned periodic audits.
(Level IV) (b) No record of safety evaluation for unreviewed safety question.
(Level IV) (c) Failure to perform periodic audits.
(Infraction) (d) Failure to Review Audit Reports Auaquately.
(Deviation) Management's attitude towards Quality Assurance has improved during the evaluation period. Signific' 't changes in the Quality Assurance organization's methom of operation have been implemented. Staffing has been increased. The Quality Assurance department's onsite presence has significantly increased. Also, progress has been made in addressing the problems noted in the last SALP cycle.
The Quality Assurance and committee activities areas still need improvement, but a turn around has occurred B.
Conclusion The Board rates this area Category 2.
C.
Board Reconmendations The Board recommends that the inspection effort be returned to the routine effort.
District Response: The SALP finding as of July 1981 stated Quality Assurance and committee activities area still need improvement, but a turn-around has occurred. Since July 1981, the District has increased QA rianpower and improved the programrratic controls to eliminate the areas af weakness. The District now feels this area is in compliance to the desired objectives.
, % -- , k-2.
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Administration, QA, Records , A.
Analysis One regional inspection and several others by the Resident ' Inspectors were completed in these areas.
Four items' of ' noncompliance were identified.
(a) Work on quality class system was done without an equipment manual.
(Level V) ,
(b) NCRs were not promptly corrected.
(Level V) (c) Monthly reports did not include summary of safety.
evaluations.
(Level VI) (d) Failure to respond to alleged violation within allotted time.
(Deficiency) i The analysis on QA is in Paragraph 12. The analysis on Administration in contained in comments on Personnel in Paragraph 5.- The records retained by the licensee appear adequate, even though the records were not always easily retrievable by the licensee, licensee's auditors, or the NRC. A new records storage building is under construction.
A new records management supervisor has been hired.
"As noted in functional area 3, there is a significant unresolved item concerning the licensee's official designation of OA Class I components."
The OA organization is establishing letter controls on procurement practices.
B.
Conclusion The Board rates this area Category 2.
C.
Board Recommendations The Board recommends no change to the inspection effort in this area.
District Response: The SALP Team identified the progress that has been made in this area.
The complexity of providing an adequate records management system including proper storage, etc. has resulted in a delay of completion of the project.. Since July 1981, Phase I of the records indexing
_ _ _ _ _ _ _ _ _ _ _. . . . .
. e
. program has been completed, and in April the District will solicit proposals from qualified vendors for installation and startup of the records management system. An interim microfilming and startup of-the records management system. An interim microfilming and indexing office complex has been built under the Administration Building to provide the space resources for initial implementation of this program.
14.
Corrective Actions and Reporting A.
Analysis Six inspections were conducted in the area of corrective actions.
Numerous inspections were also performed on LER reporting, and seven inspections were performed on.IE Bulletin reporting.
No items of noncompliance were identified.
In most instances, the licensee's corrective actions proposed in response to Notices of Violations have been prompt, conservative and appropriate.
In a few instances, however, the licensee's responses.have not been conservative and have tended to rely on legal arguments rather than addressing the technical safety concerns involved.
Examples include the licensee's response dated March 26, 1981, to the Notice of Violation (involving a diesel generator fast start system) included in Inspection Report 50-312/81-04; and the licensee's response dated January 26, 1981, to the Notice of Deviation (involving hydraulic snubber surveillance) included in Inspection Report 50-312/80-35.
In addition, at least one response has been significantly technically inadequate. This instance involved the licensee's response dated July 1,1981, to the Item of Noncompliance (involving surveillance testing or the High Pressure Injection and Makeun Pumps) included in Inspection Report 50-312/81-15. These instances of inadequate or nonconservative proposed corrective actions raise a question as to either the licensee management's criteria for responding to Notices of Violation or the depth of management review of such responses.
Fifty-five LERs were submitted within this period.
Corrective action was not always adequate to prevent recurrence.
(See LER causally linked Chain 2.)
Corrective action on many items (e.g., LERs and NRC follow-up items) are not always prompt. 0A is pursuing prompt corrective action in items under their purview.
But, the TMI nodifications and resultant items requiring corrective actions are imposing a heavy work load on the licensee's organization.
.
f' . . ' . . . ~ B.
Conclusion < The Board rates this area Category 3.
C.
Board Recommendations The Board recommends an increase to the inspection effort in this area to confirm the effectiveness of future corrective actions.
Corrective Actions and Reporting District Response: The SALP Team identified this area as a Category 3 and recommended increased inspection. The District wishes to identify that six inspections were conducted by the NRC in the area of corrective actions and no items of noncompliance were identified.
The District particularly takes exception to the statement, "have tended to rely on legal arguments rather than addressing the technical safety concerns involved." The SALP Team further states that there were instances of inadequate or nonconservative proposed corrective actions.
The District acknowledges the right of the NRC to question the adequacy of a particular response, but reserves the position that alternate evaluations regardingaan item of noncompliance are possible.
It is the District's contention that where judgment with respect to degrees of conservatism are concerned, there is always the possibility of disagreement. The District is responsible for operating Rancho Seco safely. This responsibility is taken seriously by a competent staff.
The conclusions and actions taken by the staff are based upon technical evaluations tempered by the ever present requirement not to create undue risk to the protection of the health and safety of the general public. At no time are these attitudes ever substituted for legal arguments.
It is not the District's position to contend the citation, but to illustrate that legitimate differences of opinion can exist.
In the future, to address the concern raised by the SALP Team, the corrective actions will be: 1) Evaluated for concurrence to the NRC's finding 2) Action taken to correct deficiency 3) Corrective action to minimize the recurrence potential ! !- ,
( ' ~ ,. , - . . . < . The District will strive for providing prompt corrective action to items identified by the inspection and enforceneret organizations of the NRC. When differences of opinion are identified, the District will attempt to resolve the differences prior to correspondence being transmitted, if possible.
The District, as of September 1,1981,.has added a new QAP No. 27, Corrective Action, which defines the requirements and establishes the procedure for maintaining the control of corrective action requirements. A Quality Assurance Corrective Action Coordinator has been appointed whose duties and responsibilities - have been defined in a new QCI No. 7, Corrective Acticn Program.
The program will assure the following: 1) Programmatic conditions which require corrective action are promptly specified 2) Appropriate corrective action be promptly specified 3) The corrective action is properly implemented
- 4)
Those corrective actions which cannot be implemented will receive appropriate review and resolution ' 5) Appropriate interim measures are implemented until the corrective action is completed ' 6) There is a systematic method of documenting and tracking corrective actions 7) Corrective action data is incorporated into the Trend Analysis Program, as applicable This program should raise the perfornance level of the functional area.(corrective action) to an acceptable level.
>
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. ' . . . SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE IV. SUPPORTING DATA AND SUMMARIES 1.
Noncompliance Data See attachment 1.
2.
Reports Data a.
LER Nos. Reviewed: 80-28 through 81-32.
b.
LER Conclusions: See attachment 2.
3.
Licensee Activities See attachment 3.
4.
Inspection Activities See attachment 4.
5.
Investigations and Allegations Review See attachment 5.
6.
Escalated Enforcement Actions See attachment 6.
7.
Management Conferences held During Appraisal Period See attachment 7.
8.
Other i
I ~ . ~ . . ATTACHMENT 1 . I.
NUMBER AND NATURE OF NONCOMPLIANCE ITEMS - OPERATING REACTORS Facility Name Rancho'Seco Unit
Inspection Noncompliances Functional Area Manhours Severity Level Classification 1980 1981 I II III IV V VI Vio. Inf. Def. Dev.
1.
Plant operations 562 51 5
4 2.
Refueling operations
39 3.
Maintenance
115
17 4.
Surveillance & inservice testing 179 100
5.
Personnel, training & plant procedures
181 19 12 6.
Fire protection & housekeeping
13 0 7.
Design changes & modifications
183
8.
Radiation protection radioactive waste management, &
transportation 352 706
9.
Environmental protection
0 10.
Emergency preparedness 8 260 11. Security & safeguards 126 163 5* 12. Audits, reviews, &
committee activities 108 .l69 , _
6
13. Administration, QA
records, procurement
105 14 15
14. Corrective actions & reporting 294 300 1,960 2,866 This cycle Totals 4,826 Last cycle-Note: Numbers refer to attached sheets for each item of noncompliance.
- Noncompliance Number 5 did not result in a civil penalty.
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REPORT # ITEMS OF NONCOMPLIANCE 1.
80-19 Infraction ' Failure to provide adequate training.
2.
80-19 Infraction Failure to maintain retraining program for Chem / Radiation Division.
3.
80-20 Deficiency Failure to respond to alleged violation within allotted time.
4.
80-21 Deviation Failure to maintain five full strength shift crews.
5.
81-19 Level III Vital access not secured to control room.
6.
80-24 Infraction r ailure to perform periodic audits.
, 7.
80-24 Deviation Failure to review audit reports adequately.
8.
30-26 Infraction Failure to reset nuclear power trip set point to 5% while plant in shutdown.
9.
80-26 Infraction Failure to follow procedure.
10.
80-26 Infraction Failure to make valve fail closed on loss of DC power to solenoid.
11.
80-35 Level IV Licensee did not conduct comprehensive planned periodic audits.
, 12, 80-35 Level V Procedure not properly reviewed and approved.
13.
80-35 Deviation Specific acceptance criteria were not set forward for hydraulic snubber operability.
14.
80-36 Level V NCRs were not promptly corrected.
15.
80-36 Level VI Monthly reports did not include summary of safety evaluations.
16.
81-01 Level V Seal replaced without use of a procedure that .had PRC review and superintendent approval.
, 17.
81-01 Deviation P.M. schedule not maintained.
18.
81-04 Level IVE No record of safety evaluation for unreviewed safety question.
. + 19.
81-15 Level IV Failure to provide adequate procedures.
20.
81-24 Level V ' Work on Quality class system done without manual.
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E - . ' . .. . . ATTACHMENT 2 LER ANALYSIS AND CONCLUSIONS , The Ran:ho Seco LERs for this assessment period were evaluated in accordance with the techniques and acceptance criteria presented in the document " Guidance Manual for LER Analysis," dated November 26, 1980, and prepared for the Office of Inspection by Teknekron Research, Inc. A list and brief description of the LERs considered is given in Table 1.
The significant results of the analysis are summarized in Table 2 and described below.
Units and Criteria The basic unit used by Teknekron in analyzing LERs is the " causally linked event." Such an event is one having the same root cause as an event which has already occurred. The assumption is that proper management review of r and corrective action applied to an event will minimize or eliminate subsequent events due to that same root cause. Conversely, the inference is that if there are a large number of causally linked events, there is a question regarding management effectiveness.
Teknekron has developed three,1,ndices based on causally linked events.
These are: - (1) Total number of causally linked. events per month (TNE). This number is equal to the total number of causally linked events (excluding ~ the first event in each chain) divided by the number of months in the review period. Based on a limited number of studies Teknekron suggests that a TNE=0.7 per month may be taken as the border line between' acceptable and marginal performance.. (2) Largest number of~ linked events in a. chain (LNE). This number is the length of the longest chain of causally linked events (same root cause) less the initial event.
Based on their studies to date Teknekron suggests that an LNE of about four may be used to distinguish between acceptable and marginal performance.
(3) Average time between events (ATBE). This index is developed by calculating the average time between events for each linked chain (time between first and last event in months divided by number of events less initial occurrence) and then averaging these numbers for each chain to obtain an overall average.
In this case Teknekron suggests a mean ATBE of three months as a baseline indicator with larger values of ATBE being more desirable.
Results Table 2 presents the results of the LER analysis.
Four chains of causally linked events are seen to occur in the functional areas of Plant Operations, Maintenance, Radiation Protection, and Environmental Protection.
.
- , - .
. . Chain 1 (Plant Operations) consists of two events occurring a little over four months apart', involving difficulty in determining the status of the overspeed trip on the turbine driven auxilia;y feedwater pump. Thus far, the licensee's corrective action appears to have been effective.
Chain 2 (Maintenance) consists of six events covering a span of about seven months, wherein various instrument settings were found to be outside specifications. Whereas corrective action has been taken in each individual case, the number.of events which have occurred suggest the need for corrective action directed toward the root cause (e.g., greater allowance for drift or process' fluctuations between calibrations, more careful calibration, etc.). ' Chain 3 (Radiation Protection) consists of three events occurring over a period of about six months, involving environmental TLDs which recorded reportable doses. The cause appears to be the accumulation of solid radwaste in a storage area and'the possible exposure of the TLDs in the Security X-ray machine.
Continued attention to the timely shipment of radwaste will be needed to prevent recurrence.
Chain 4 (Environmental Protection) consists of five events spanning about 101/2 months, wherein effluent pH limits were exceeded. These events appear to be due to inadequate procedures for control of effluents combined with improper setpoint adjustment (overlaps with Chain 2, above).
Since the most recent event occurred near the end of this report period, it does not appear that the licensee has yet solved this problem (the reviewer acknowledges, however, that it is a very difficult problem).
The reviewer suggests that undue weight should not be given to Chain 4.
The basis for this suggestion is that the violations of pli limits were generally minor and of short duration and the violation did not affect the radiological safety of the public.
One series of linked events were identified which were not included as a chain. These were reports made in response to IE Bulletin 79-01B identifying components which were not fully environmentally qualified.
These LERs were not included as a linked chain because they resulted from a single initiating event rather than being a series of separate events caused by a continuing lack of effective management control.
Conclusions Referring to the summary of index values shown at the bottom of Table 2, it is seen that the licensee falls slightly outside the bounds of fully acceptable performance based on the present preliminary criteria. The range of index values observed.by Teknekron in previous studies is also shown to provide perspective.
If Chain 4, relating to effluent pH, is deleted due to its limited significance, it is seen that the licensee is still outside the bounds suggested by Teknekron for two of the three indices. Therefore, based on LER analysis and the foregoing considerations and criteria, the reviewer concludes the licensee's manajement effectiveness has been adequate but slightly below averag : . . . , . TABLE 1
' SUMMARY OF RANCHO SECO LERs REVIEWED JUNE 6, 1980 TO JUNE 30, 1981 ! LER NO.
(Cause) SUBJECT 80-28 (M) Deficiency in administrative controls on SFAS power supply _ ' > availability.
80-29 (0) Exceeded pH limits on plant effluent due to high pH in Folsom South Canal.
80-30 (F) Voltage regulator in bistable module failed.
' 80-31 (M) Failed to reanalyze discrepancy in "as built" piping drawing.
80-32 (F) Turbine-driven AFW pump failed to start - overspeed trip ' apparently mispositioned.
80<33 (0) High readings on TLDs on perimeter fence due to stored waste.
80-34 (0) See 80-29.
,
' i 80-35 (M) Exceeded pH limits on plant effluent due to time lag in - flow diverter.
80-36 (M) See 80-35.
80-37 (0) Exceeded total dissolved solids limit in plant effluent.
i 80-38 (P) Exceeded chlorine limit in plant effluent.
80-39 (P) Failed to lower high flux trip setpoint while shutdown.
80-40 (F) Flow tramsitter in RCS failed.
. , 80-41 (P) Diesel generator didri't achieve rated voltage due to improper , setting of rheostat cam.
. 80-42 (Mb , See'80-33, plus_ determined that TLDs subjected to Security X-ray - ' ~ machine.
80-43 (0) -IB79-01B review shows ASCO' solenoid values not environmental.
' qualified.- , 80-44 (0) IB79-01B review shows no environmental qualification o documentation.for Meletron pressure switches.
!
^ 80-45 (0) IB79-01B: review shows NAMC0 limit switches not environmentally < qualified.
'
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_ - . ' . . LER N0.
(Cause) SUBJECT . 80-46 (F) Turbine-driven AFW pump overspeed trip lever appeared to be in tripped position.
80-47 (0) IB79-01B review shows no environmental equalification documentations for Foxboro flow transmitter.
80-48 (M).
Missed schedule for surveillance testing of two valves.
80-49 (M) Diesel generator did not start' possible governor problems.
80-50 (M) See 80-33 plus difficulties in shipping stored waste.
81-01 (0) Starter coils will not work at new (lower) degraded voltage value.
81-02 (F) Radioactivity in CCW systeq due to leak in letdown cooler.
81-03 (P) RB Spray Pump failed to start in 5.5 minutes due to incorrect setting of timer.
81-04 (0) Isolation valve failed to close due to water in air line.
81-05 (P) Exceeded pH limits on plant effluent due to improper setpoint adjustment on pH monitor.
81-06 (0) Pressurizer code safety valve had improper lift pressure.
81-07 (0)- Instrument errors may be greater than assumed in FSAR.
81-08 (F) 'Sp.urious failure of CKT breaker.
81-09 (F) Spurious failure of CKT breaker.
81-10 (0) Followup on 80-31.
81-11 (M) B' lank flange installed;on both DHR suction lines from sump.
81-12 (P).
Pressure set points wrong.
81-13 (P)- Bypassed interlocks on personnel hatch during fuel movement.
81-14 (F) Valve failed to close due to loss of key from Keway.
81-15 (M) PH exceeded limit during diverter setpoint adjustment.
81-16 (M) Safety related lube oil cooler 80-90% clogged.
81-17 (M) Cable tray' support improper location.
t I.
I
7_ .___ _ - __ _____ _ _-___ -___ ______ - _ _ _ __ _ _._ ' . ' l - . - . . . LER'NO.
(Cause) SUBJECT 81-18 (F) Exceeded clorine limit due to defective pump operation.
81-19 (P) Radiation monitor suction line clogged.
81-20 (P) PH limit excegded due to instrument calibration error or operator error.
81-21 (M) Limitorque inoperable due to manual operation and wrong material.
81-22 (F).
Three inoperable snubbers.
81-23 (P) PH below limit.
81-24 (P) 4,000 gal of reactor coolant dumped to reactor sump stripped gear on valve operator.
81-25 (F) Caused valve to fail.
81-26 (F) Steam Generator tube leak.
81-27 (0) Breaker tripped during pump start.
81-28 (F) Inoperable snubber found.
81-29 (0) Pipe hanger found damaged.
81-30 (M) PH limit exceeded due to fluctuation in canal PH.
81-31 (M) Cable tray. fire barrier cc: promised.
81-32 (F) Snubber-low oil level because of seal leak.
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' . ~ -TABLE 2 ,' - , " LER ANALYSIS . . FROM 6/6/80 ~ TO 6/30/81 Facility Name Rancho Seco Unit-
,' Causally ***- Management-Personnel ' Functional Area Linked Events Error * Error * P.
m 1.
Plant operations (80-32,-80-46 [1, 80-39 .i, .
2.
Refueling Operations 81-11 ~ 81-13 , 3.
Maintenance 80-41, 81-3, 81-5 ' 81-6, 81-12, 81-2 81-16 81-19 4.
Surveillance & inservice testing 80-48, 80-49 81-24 5.
Personnel, training & plant procedures 6.
Fire protection & housekeeping 81-31 7.
Design changes & modifications 81-17 8.
Radiation protection, radioactive waste management & transportation h0-33,80-42,80-Sh3 9.
Environmental protection 80-35,80-36,81-1554 80-20, 81-30 80-38, 81-23 - 10.
Emergency 11. Security & Safeguards 12. Audits, reviews & comittee activities 80-28, 80-31 13. Administration,QA records, procurement 14. Corrective actions & reporting TOTALS
8' '6
- (Excludinglinked)
- (Excluding Ph_ Problem)
INDEX LIC.
CRITERIA LIC.** GBSERVED RANGE
- (Causally Linked TNE 0.9 0.7 0.6 0.3-2.2 Events Refers to -
LNE 5-
5 2.7-7.3 Chains 1-4) ATBE 2.8
2.8 1.9-5.6 L
__ ' . ' . . . ATTACHMENT 3 Licensee Activities During June and July the Unit operated at near full power except for three days at reduced power (53 percent) for condenser tube leak repairs.
During the middle of August, the unit went down for three weeks for repair of a main turbine thrust bearing.
From September to the end of January the unit operated basically at full power until the 1981. refueling outage on January 31, 1981.
For the months of February through the middle of May, the unit was shut down for refueling, turbine disc keyway cracking inspection and repair, and TMI modifications.
, From the middle of May through' June, the plant operated about 50 percent of the time at near full power. The plant was shut down the rest of the time for "B" 0TSG tube leak repair and feedwater controller problems.
~ a.
Condenser Tube Leak and Main Turbine Thrust Bearing Repairs L Tube failures occurred due to normal aging. A condenser was isolated, power was reduced, the repairs were made, and the plant returned to full power operations in July.
In August, the licensee developed high vibration in the main turbine and ended up performing thrust bearing repairs.
Outage lasted about three weeks.
b.
Keyway Cracking The Westinghouse Turbine at Rancho was susceptible to this generic problem, so SMUD decided to shut down and inspect for potential problems and refuel at the same time. This 1980 refueling outage came about five months early. The licensee removed eight blade rows on the No. 1 LP turbine. Baffles were installed to cause the correct pressure drop to occur within the remaining stages of the No. 1 LP turbine. The plant took a 100 MWe derating due to the use of these baffles.
, c.
TMI Modifications The January through June NUREG 0578 short term modifications were installed including: high range radiation monitors, PORV and safety valve position indicators, T sat meters, AFP flow indicators, pressurizer heater modifications, etc.... . -
r- ' . ' . . . . d.
Feedwater Controller Problems The licensee shifted from a Bailey Feedwater Pump control system to a Lovejoy system.
Final alignments could not be'made on the new system until at power. About a week of unstable feed flow occurred while maintenance was performed and the controller's function was made stable.
e.
OTSG' Tube Leaks-Rancho was the last of this generation of B&W OTSGs to leak. A number of " lane" tubes were inspected and four were plugged.
Extensive secondary system comtamination occurred and large amounts of processed water were discharged.offsite.
Significant media attention was focused on this event.
e . ( y I w h g : s %' sm a } S- ' . L-- , 's t a . 't - - -y y a + - - %,
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. o . , . . . . ATTACHMENT 4 INSPECTION ACTIVITIES No of Inspections Manhours A.
Regional Inspection (Operations)
447 i Routine Inspection ' 11 Reactive -Inspection 1 (special PAB iii Appraisal followup 210 B.
Resident Inspector
2027 ' C.
Health Physics i Routine
181 11 Reactive iii Health Physics Appraisal
336 D.
Environmental i Routine ii LER Followup
10 E.
Security and Safeguards
289 F.
Emergency Preparedness
268 , < s ' G.
Radioactive Waste Management, & - , Transportation --
1058 -- - 4826 -. - , , , ( i t S , ' _ - ,
s r
i ! l ' i r i & l . _ . ._ .- -, _ _ _ --_. -.... -, _ _,. -
. _ _.. _ ._ .
- . , . ' . , . ' ' ATTACHMENT 5 ' INVESTIGATIONS AND ALLEGATIONS REVIEW , Four allegations for the period were investigated: , , l.
HVAC not built to current codes. Unfounded, 24 inspector hours, ' 2 inspectors.
2.
Narcotics usage and sale on or about premises.
Founded, 60 inspector ! hours, 2 inspectors.
(Local law enforcement officials and the licensee . handled the case properly.)
3.
Security problem under-age man obtained brothers ID. Founded, 2 inspectors, 20 inspector hours.
4.
Cable tray anchors not torqued correctly. Unfounded, 2 inspectors, 50 inspector hours.
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" , . % - . , . ATTACHMENT 6 ESCALATED ENFORCEMENT ACTIONS . Civil Penalities . No civil penalities during evaluation period.
Orders , 4-20-81, Dual Verification and Primary Coolant Isolation Valves - revision to Technical Specifications.
. 8-29-80, Environmental Oualification of Equipment - required to submit by . November 1,1980, all information necessary to support safety evaluation of safety-related equipment subjected to a harsh environment.
Confirmation of Action None ATTACHMENT 7 Management Meetings Held 1980 SALP Review - 80.
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