IR 05000312/1987032
| ML20236S106 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/09/1987 |
| From: | Caldwell C, Coe D, William Kennedy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20236S105 | List: |
| References | |
| 50-312-87-32, GL-82-33, GL-83-31, IEIN-86-064, IEIN-86-64, NUDOCS 8711240226 | |
| Download: ML20236S106 (14) | |
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. {jhh D M I:6 MJ"tibn coriducted:... -</br>' September 28 - October 2, 1987 g</br>N.gggf</br>- jj</br>%</br>,</br>T. W. CaldvTell, Projei:t-Inspector -</br>Dat'e Signed</br>'</br>u f</br>- e JI$ spec ~ tor:</br>-</br>P_ -</br>//9!/f/</br>D.-</br>. Coe, Li ensing Examiner.</br></br>Dat6 Signed</br></br>'</br>i f., ..#</br>'</br>'</br>.</br>Of 1 c</br>/ bM[f7 Y</br>S In'spector':.</br>s W.- G. Kennedy, Seniot Operational Date Signed'</br>'</br>f</br>'</br>,</br>JSafe'</br>ineer</br>,t t,m f' " ",.</br>. LVF.' Miller, Chief '.</br>Date Signed s</br>E'</br>Reactor?ProjectsSection2':</br>'</br>s,</br>,</br>ar</br>.Y</br>: Inspect 1on" Sumary:"</br>i</br>'</br>'</br>,N:</br>.</br></br>? :, g</br>?Irispection on September 28'- October 2,1987 (Report No. 50-312/87-32)</br>-</br>T-LAreas' Inspected:.. Routine-inspection by a regional inspector and'a license</br>-</br>, examiner, and.an_NRR engineer of emergency operating procedures and quality-g</br>,</br>, assurance audits. ; Inspection procedures 25579, 35701, and 30703 were covered.</br></br>'</br>Results: = No violations or deviations were identified.-</br>-</br></br>(</br>i</br>. :-</br>-</br>.I b"</br>"</br>9)</br>i i</br>;</br>'</br>[ s711240224,97 M h 2</br>,</br>PDR ADOCK PDR;</br>'</br>-</br>'</br>e</br></br>s</br>.</br>.</br>R</br>'s</br></br>'</br>!</br>;u</br>,</br>~</br>DETAILS</br>"</br></br>n</br>></br>,</br>!</br>^</br>y-</br>. I '.1</br>" Persons Contacted</br>:</br>'"</br> Licensee Personnel I</br>,</br>K. Meyer, Licensing Manager</br>!</br>,</br>'</br>. S. Redeker, Assistant Nuclear Operations Manager -</br>I</br>',</br>_ P.LTurner, Nuclear Training Manager</br>*</br>,</br>'*D; Tipton Project / Procedures Operations Superintendent</br>;</br>T.' Tucker, Shift Operations Superintendent.</br></br>A</br>;</br>-</br>- T.~ Hunter, Operations Training Supervisor</br>*</br>*R. Colombo.. Regulatory Compliance Superintendent</br>'j</br>-</br>*P.'Lavely. IIRG Supervisor</br>'J. 'Vinquist,- Quality Assurance Manager</br>*J. Sullivan, Corporate QA Supervisor R. Cherba QA Engineering Supervisor</br>*D. Elliot, Quality _ Assurance Audit-Supervisor G.'Simmons,-STA' Supervisor</br>*F. Hauck,: Emergency Preparedness Specialist</br>*J. Hodges,-Licensing Engineer</br>*D.-Falconer,; Licensing Engineer</br>,</br>'</br>Denotes those attending the final exit meeting on [[Exit meeting date" contains a listed "[" character as part of the property label and has therefore been classified as invalid..
T LThe inspector also contacted licensee operators, engineers, technicians, i and other per'sonnel during the ' course of the inspection.
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Purpose and Objectives of.This Inspection , -The purpose of this inspection was to review the licensee's program for ' preparation of the Emergency Operating Procedures (EOPs), to assess the technical; adequacy of the E0Ps, and to determine the effectiveness of the i licensee's program for implementation of the E0Ps. The specific objectives of this inspection were:
t ' Review the licensee's technical guideline document and compare it to ' - the E0Ps.
Review the plant specific writer's guide (P-SWG) and compare it to - , the E0Ps.
Review the. licensee's method for inputting plant specific values into - the E0Ps.
Assess the E0Ps technical adequacy, including the Validation and , - Verification (V&V) Program.
j Observe the ability of operators to use the E0Ps in an effective ^ - manner and to determine the effectiveness of the operator training program with respect to E0Ps.
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' ya '39 i, , Review the1 quality assurance. department's involvement in" the , d%g ,"% ' Cdevelopme.nt and implementation'of the E0Ps.
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. , ' QM:p i t-c Review 1the District's Experience' Review Program.with regards to E0P-d@y;N / / deficiencies identified by_NRC'..
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, yw sw , ,([i* ly{}}) ;3. jTimeline',for Impleme'ntation of Rancho Seco E0Ps . -f . ,e .
~s {y ? "u lThe"inspectordeterminedthatthefollowing;timelinedescribed'the ? , , gy@, - evolution of theERancho'Seco.EOPs fromethe. issue of the draft technical ' ," , m guideline by thefvendor, through;the establishment of a formal requirement by;NRC,1 o the present dayLformat offthe'E0Ps.s - .t ' , (- , ' w -
a , cf.g 3' s @c.a ' 4-. LDecembsr 418,1981,; the Draft Rancho Seco Abnormal Transient Operating g nGuideline'-(AT0G)was: approved'andsenttothe'DistrictbyBabcockand . g1!1 LWilcoxi(B&W).
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-; ; LMarch 3,:19826the' NRC notified the B&W 0wners Group that the , g
ysymptomaticiapproach'ATOG was acceptable'(provided additional .
information or justifications were~ submitted) based-upon the Oconee L. M~* %. y "L 13 submittal', and that the individualelicensees should fashion their $o7g L LAT0Gs.after Oconee since it:appearedithati final approval was near.
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- October?8 h1982, the Final RancholSeco AT0G was sent to the District.
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- December 17,:1982,; Generic Letter 82-33 Shpplement 1 to NUREG 0737
& "JVi, Av wasuissued.which detailed:the requirements for; developing.a Mb .
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- ProceduresGenerationPackage..(PGP).
' e e w y . , < i ' jd ' [ April /15]> 1983,.the: District committed to provide' a PGP.
x-g y ., - V, ML " ' ', y ^ : September!19,zl983, GL 83-31'wasJissued.-iIt specified that the . 4~,'Mi , i !0conee:ATOG was, approved.'and that11t could'be.-used es a basis for i ' 4' ', / Limplementationfof the'other plant'AT0Gs.;;However, the NRC staff- ' s
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- restatedcthat'a plant specific lAT0G
- must be' submitted.-
' N' [, ! January"31,1984, the District submitted their'PGP that contained the y-JAT0G' plant specific writers guide.(P-SWG), description of the ' ,. o ~ ' ~ . training-for E0Ps, and description ~of -the validation and verification (V&V)Jprogram.. g ,g, February 21,n1984',iNRC: issued an Order that confirmed the District's >-c ' .. g - -commitments to provide a:PGP and to implement the items described in g,j e - ~' the attachments in-the manner" identified in the submittal no.later - M ' " lthan November'1984 or. prior to restart if in a refueling outage.
' ' + , ". p 7- ' 'JulyL 14,: '1984,'NRR requested the District to provide differences . r between the Rancho Seco AT0G and the Oconee 3 ATOG.
s.t, - . g w, e.x, .. De'cemberf 21,1984,:the District' identified and justified the , l differences between t.he January 31, 1984 submittal of a PGP and the '" '
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. . r ( April 1985 the first E0Ps were approved and issued by the District.
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September 3, 1985, B&W. issued the new " Technical Basis Document j - , (TBD)."
l > _ July.3, 1986~, the Dio,trict committed to Region V to verify the
> - / technical! correctness.of E0P changes made since 1985 and to compare the E0Ps to the "AT0G' Technical Basis" and incorporate identified l improvements into E0Ps.. This commitment was made in the Restart ! Action Plan, Revision 0, but SMUD did not indicate that the "AT0G Technical Basis" was the B&W "E0P Technical Basis Document."
~ August 14, 1986,. IE Notice 86-64 was issued, " Deficiencies In Upgrade - , Prog <ams for Plant Emergency Operating Procedures."
January-February-1987, the revised E0Ps, basedion the new TBD, were
issued-by SMUD.
-' ' April.20, 1987, Supplement 1 to IE Notice 86-64 was issued.
It , , = reiterated IE Notice 86-64 with additional examples.
June 16',1987,'per a verbal NRC request, the licensee submitted a - description'of changes to the PGP. This request was made due to the , -length of time between. submittal and final evaluation of the Rancho Seco AT0G..The only change identified in this submittal was a new P-SWG. The'new P-SWG was submitted as an attachment to the letter.
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' No referen'ce to the adoption by SMUD of-the TBD as the principal technical bases for the E0Ps was made in'this submittal.
'4.
.- Documents Reviewed The E0P development process. documentation. required to be submitted by Generic Letter 82-33 consisted of four parts: the technical basis for the , E0Ps,.the writer's. guide 'used to prepare the E0Ps, a description of the ( ' operator training on E0Ps, and a description of the verification and j validation process-for the E0Ps.
The inspectors reviewed the following procedures and documents during this ' inspection -
- Rancho Seco Abnormal Transient Operating Guidelines (AT0G)
- . AP.47, Revision 1, " Emergency Operating Procedures Writers Guide," - Superseded o X AP.2.24, " Emergency Operating Procedures Writers Guide" - Training Program for Implementation of E0Ps - - f AP.48, Revision 1, " Verification of Emergency Operating Procedures," - Superseded c F , AP.2.07, " Verification of Emergency Operating Procedures" - _ _ _ _ _ _ _ - _ _ -
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t N . . AP.49, "Validatio~n of Emergency Operating Procedures," Superseded - . AP.2.06, " Validation 'of Emergency Operating Procedures" - l# ' - AP.2.10 "Pancho Seco Procedure Writers Guide" . The E series Emergency-Operating Procedures -- The CP series Cooldown Procedures - ' The Emergency Operating Procedures Technical Bases Document - In" addition, the. inspector reviewed numerous correspondence.
The review'of these documents was performed both in the Region V office ! and at the site.
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' Review of' Technical Guidelines ' a.: Abnormal Transient Operating Guide (ATOG) The District's original. response to the Generic Letter was contained 'in a-letter dated January 31, 1984.
In this response, the District specified that'they were using the Abnormal Transient Operating Guideline.(AT0G) as-their technical basis document.
In addition, the differences between.the Rancho Seco ATOG and the NRC approved reference AT0G (prepared for Oconee 3) were provided by the licensee . in 'a letter dated December 21, 1984. The AT0G, prepared by B&W, ' described the philosophy behind the E0Ps and provided site specific information to be used in preparation of the E0Ps (e.g., setpoints
'for actuations)'. The inspector reviewed the ATOG and attempted to ! compare it to the current E0Ps to determine'if the philosophy and J plant specifics were correctly translated into the E0Ps. However, i the inspector.found many differences between these documents and was unable to make the comparison. The comparison was impossible since there was little or no justification provided for deviations from the AT0G in the preparation 'of the E0Ps. An example of a deviation from ! the AT0G is the'following: l In section III of the AT0G, step 4.4 specified that the reactor ' coolant pump seal return valves shall be maintained closed to ' isolate possible leakage paths during a lack of adequate subcooling' margin event. E0P E-03 had no such step requiring the operators -to maintain the seal return valves closed.
In the case of this example, a discrepancy form was prepared during s L , the verification process that found this deviation.
It indicated that this.was a significant deviation from the AT0G and recommended . that the seal return valves should be maintained closed. However,
the recommendation was not incorporated into the procedures and no justification was given.
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g- , Thetinspector qu'stioned the licensee as to the reason for the e differences between the ATOG and the E0Ps and found that the District had changed to a new guideline for the preparation of the E0Ps in
January and February,1987. The new guideline being used was the Emergency Operating Procedure Technical Basis Document.
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Emergency Operating Procedure Technical Basis Document The Emergency Operating Procedere Technical Basis Document (TBD), I also prepared by B&W, was a generic document for all B&W nuclear plants.
It was issued September 3,1985, to reflect enhancements and a new philosophy that was to be used in preparing the E0Ps. The licensee revised their E0Ps and issued revisions in January and j February 1987 to implement the TBD enhancements and philosophy. The ] '< , licensee alluded to this change in use of technical guidelines in { the Restart Action Plan, Revision 0, dated July 3,1986.
In this i
' Pian, they committed to verify the technical correctness of E0P changes made since 1985, to compare E0Ps to the "AT0G Technical , , Basis," and' incorporate identified improvements into E0Ps. However.
-it was not identified to the NRC that the "ATOG Technical Basis" - referred-to a new document t ather than the original ATOG. This , , ,' ' change in technical guidelines by the licensee was discovered during
, i-this inspection. The inspector will review the licensee's change in
technical guidelines with respect to the E0P implementation j requirements.specified in the February _21, 1984 Order in a
- subsequent inspection. This' item is identified as an unresolved item-(87-32-01).
As a. result of the change in guidelines, the inspector attempted a i ! comparison of_ several E0Ps to the generic Technical Basis Document since no. comparison of the E0Ps to the AT0G was possible. Although i some justifications existed for the differences between the TBD and the'E0Ps, the: inspector was able to review only a small sample of
. deviations.due to time limitations. The existence and acceptability ' of justifications for all. deviations was not evaluated.
As 'a result of the change from the plant specific AT0G to the generic TBD, < the inspector was. unable to review the licensee's method for inputting ' plant specific values into the E0Ps.
In addition, a full assessment of ' the:EOP-technical adequacy could not be performed. Further evaluation of these' items will be performed through review of the licensee's submittal of a revised PGP (discussed in paragraph 12) and verified in a future inspection.
Within this area inspected, no violations or deviations were identified.
'6. - Writer's Guide l l-The writer's guide submitted as part of the original PGP was AP-47, L " Emergency Operating Procedures Writer's Guide." This procedure was [ superseded by AP.2.24, " Emergency Operating Procedures Writer's Guide," E and was identified to the NRC in the June 16, 1987 letter which L identified program changes. The initial NRC staff review of AP.2.24 as . compared to Section 13.5.2 of the Standard Review Plan identified several concerns over the completeness of the writer's guide. Most of these concerns were resolved
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! ., during this site visit when the licensee identified that-AP.2.10, " Rancho
Seco Procedures. Writer's Guide," also was a source document'used in the preparation.of the EOPs. AP.2.24 was.the, controlling document in the , -event that differences should exist between the requirements specified in i 'the two writer's guides. After a review of AP.2.24 and AP.2.10, the , inspector identified the following suggestions for enhancement with ! regards. to' the writer's guides:-
The. writer's guides' could specify that action steps and cautions be l - ' completed on the same page they begin in order to reduce the ' ' potential for operator. confusion.
A. statement could be added to identify that the E0Ps will be written I . -for the minimum control room manning and will consider the division y of responsibilities among operators.
i A statement could be added that future copies of the E0Ps will be in -- -the.same physical quality as the originals.
i Licensee personnel indicated that these observations would be evaluated.
=The inspector compared samples of the following E0Ps to AP.2.10 and .' . AP.2.24 to determine if the requirements and guidelines of the writer's guides were properly, followed in the preparation of the E0Ps: E.01, Revision 2. "Immediate Actions" - ' 'E.02,. Revision 5, " Vital. System Status Verification" - E.03,' Revision'3, " Loss of Subcooling" -- E.04, Revision 7. " Loss of Heat Transfer" -
E.05, Revision 9, " Excessive Heat Transfer" ' - CP.101, Revision 4. "A'Large LOCA Has Occurred And The Core Flood - - Tank.is Emptying" ?CP.102, Revision 2,'" Normal Cooldown" ) - - ' CP.103, Revision 4, "Traasient Termination Following an Occurrence (That Leaves The RCS Saturated With OTSG(S) Removing Heat" ~
-CP.104, Revision 4. " Transient Termination Following an Occurrence - That Leaves The RCS Being Cooled by HPI Cooling" CP.105, Revision 3 " Transient Termination Following an Occurrence - That May Require Pressurizer Recovery Solid Plant Cooldown With OTSG . Removing Heat And RCS Subcooled" ! l During the inspector's' comparison of these procedures to the writer's { guides, performed on a sampling basis, the following discrepancies were identified with regards to writer's guides:
- a.
-Use of caution statements F .AP.2.10 paragraph 6.4.11.1.3 specified that "the text should not contain operator action steps." In addition, AP.2.24 paragraph .6.3.4.1, specified that "A caution cannot be used instead of an instructional step (it cannot contain an action step).
It should be used.to denote a potential hazard to equipment or to personnel associated with the subsequent instructional step."
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- However, the' following E0Ps used caution statements that could be
! understood to define required actions: , -(1) E.02, Revision 5, before step l'.0; "IF NNI POWER IS LOST, SPDS - AND.EFIC INSTRUMENTATION SHALL BE USED TO MONITOR PARAMETERS NOTED IN THIS PROCEDURE."
-(2) 'E.03, Revision.3, before step 1.0; "IF RCPS ARE NOT TRIPPED WITHIN.TWOMINUTES,THENONE(1)PERLOOPMUST.BELEFTRUNNING ' , UNTIL.SCM IS RESTORED."
, - a .; In addition,:the following E0P clearly used a caution statement that i defined an operator action: ! , , (1) JE.04, Revision 7, before step 5.0; "WITH N0 HPI/MU FLOW ' AVAILABLE DO NOT OPEN THE EMOV.
IF OPEN, IMMEDIATELY CLOSE THE EMOV AND ERUV BLOCK VALVE."-
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,x . , ,These examples were not written inaccordance with the guidance ! provided in AP.2.10 or AP.2.24.
[, b.. ' Construction of conditional steps: 'AP.2.10 paragraph 6.4.10.2 specified that "The logic word THEN should f .,
not be'used at' the end of an action to instruct the performer to ' perform another action within the same step, because it runs actions , together."
' , , The~following:EOP did use a "then" statement which caused actions to run:together: r 1(1).-:E.02, Revision 5, step 1.3;"De-energizebus3B(52-3805)AND (52-3C23) for 10 seconds THEN re-energize both."
U The following E0P'did'use "then"~in the wrong place in an "if-then" statement as identified in AP.2.10: , (1) E.02, Revisio'n 5, step 5.2.1.1; "IF any code safeties failed to ~ reseat', lower OTSG pressure in a C6NTROLLED manner to reseat valve, THEN return pressure to [ greater than] 975 psig."
! (2)' E.02, Revision 5, step 5.2.2.1; "IF any TBVs/ADVs are open, ' manually close or isolate, THEN return pressure to [ greater than] 975 psig."
These examples were not in accordance with the guidance provided in i AP.2.10.
c.. Consistency of terminology ) l AP.2.24, paragraph 6.3.1.8 specified that " Identification of components and parts should be complete. List the noun name, number and verify that they agree with Control Room labeling." In addition, J the Author's Checklist, Enclosure 8.5 to AP.2.2.10, paragraph 1.24.1 specified that the author check for consistent use of abbreviations, acronyms, and symbols.
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x 410 wever, the following E0P did not show consistency in the use of
terminology: (1). E.02,2 Revision 5, step 4.1 specified, "Run feedpumps to minimum speed;" step 4.2 specified, " Trip one Main Feed Pump;" and step ~4.3 specified -" trip both MFW pumps." The use of feedpumps, s Main feed Pump, and MFW pumps to denote the same equipment was .not consistent and could lead to operator confusion when
- performing these. steps. This Procedure was reviewed by the
. author, verified.(compared to the P-SWG and the TBD) by an independent reviewer, and approved.by the plant review committee without.anyone identifying this inconsistency.
This' example did not. follow the guidance provided in AP.2.24.
. These discrepancies were discussed with the licensee who indicated that they would review the E0Ps and assess the differences between them and the P-SWG from a gereric standpoint as discussed in paragraph 13. Resolution of.these discrepancies and their generic implications will be evaluated by the. inspector' and is identified as followup item (87-32-02).
' s . Within this area inspected, no violations or deviations were identified.
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Plant Specific Values k Generic Letter 82-33 specified that plants using generic technical guidelines shall submit a PGP which contains various items including the method for inputting plant specific values.. The inspector found that the licensee had changed from the site specific AT0G to the generic TBD.
^ 1However,' when the District changed-to the generic technical basis, they did not~ institute a formal program for ensuring that plant specific. values were. incorporated into the E0Ps.
Consequently, the inspector was unable to ' determine how plant specific values were incorporated into the E0Ps.
This item will be reviewed during a future inspection.
Within this area inspected, no violations or deviations were identified.
8., . Review of E0Ps'to Determine Technical Adequacy
- The inspector attempted to assess the technical adequacy of the E0Ps based upon the original PGP submittal. The inspector was not able to make an assessment of their adequacy due to the following:
1) the licensee changed from the AT0G to the TBD as the technical guideline, 2) deviations from the technical guidelines and their justifications were not . available for the inspector's review in many cases, and 3) no description .of the method of inputting plant specific values was available. However,
during this inspection, the inspector identified some inconsistencies while reviewing the E0Ps and during the discussions with operators. These inconsistencies were as follows: ..
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.The use of the word " throttle" did not strictly follow procedure
- AP.23.06. "Use of Operations Procedures," where throttle was defined to mean either increase or decrease flow as necessary.
In certain ! ' 'EOP steps (e.g...E.04 step 5.3) this definition, if used literally, 'could prevent operators from attaining full high pressure injection (HPI) ~ flow when required. Also, this definition was counter to the .one used in the TBD which was consistent with the colloquial use of the word to mean " decrease" flow only.
' In E0P E.04 step 2, a " Reactor Vessel Cooldown Pressure - i - ' Temperature" limit was used as an initiator for HPI cooling. This L limit was apparently described by a graph in the E0P, but the graph was labeled "T.S. curve 3.1.2-2 NDT LIMIT." This could' confuse the operators.:
Operators were inconsistent in their interpretation of step 1 of E.02 - for the condition of two stuck rods.. Half of the operators interviewed stated that they would attempt to free the stuck rods using.the methods intended for the ATWS condition. The other half stated that they would not do so (according to the explicit logic of ' this step) and continue with the procedure.
It appeared that the-difference in. interpretation was due to the' licensee's definition of the word " verify" during procedural usage to mean the following: if the condition being verified (i.e. all rods fully inserted) does l not exist, then action must be taken to.make it happen. Thus, the l step logic and the use of the word verify were not consistent.
Most operators interviewed stated that if only one rod was stuck out, they would not be required to borate as required by the strict logic of this step. They based this interpretation on a note located on a the page preceding this step (information page). Thus an occasion ! E-could have existed where the procedural action step was negated by an
informational ~ note. This was not consistent with the description of j the information page provided in-AP.2'.24 which specified that the information page contain " training material,... supplementary information about ' procedural steps,... applicable rules, and... figures which illustrate SPDS traces." Conditions under which emergency actions may be deleted must be formally contained within the body of the' action step.
Failure to follow this rule could j , ' result in operators modifying the emergency procedures based on interpretation of notational information not intended to be made a part of the action steps.
.The inspector considered that the inability to audit the E0P technical basis' and the. examples of. not following the writer's guides may be cause.
for~ concern with the verification process as described in AP.2.7.
In ' particular, the process may not have been fully successful in ensu.ng
that the E0Ps were based on the technical guidelines and written in } accordance with:the writer's guides. This will be further evaluated in a } future inspection.
Within this area inspected, no violations or deviations were identified.
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r ' - 9.. Evaluation of Operator Effectiveness Using the E0Ps/ Adequacy of Training on E0Ps- 'The inspector conducted interviews with licensed operators and reviewed u the training program description (detailed in the PGP submittal), training lesson plans, and simulator scenarios to determine the adequacy.of the < . ,; program for. instruction on the use of E0Ps and to assess operator ' knowledge of.the E0Ps.
The inspector reviewed the training program description provided in the ,' 'PGP and had the following suggestions for enhancement: ' A statement of training objectives and how these are to be - accomplished should be incorporated into the PGP.
The' District uses a generic simulator for operator training.
- Therefore, methods should be described in the PGP that will be used to compensate for: areas where the simulator differs from the control room, the simulator does not react like the plant, and the portions of the E0Ps'that cannot be run on the simulator.
The District should consider training operators on a wide variety of - scenarios-to fully exercise the E0Ps.
, LThe inspector. interviewed eight licensed operators consisting of four senior reactor operators (SR0s) and four reactor operators (R0s) in order , to achieve the following objectives: To-identify places in the E0P's which may be subject to varied , . Interpretation or confusion among the operators due to inconsistent - , ' application of the writer's guide, or lack of guidance therein.
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-. To spot check the licensee's validation process which ensured control I room layout was compatible with E0P use, j - ' To sample the knowledge level of operators with respect to their j responsibilities and required actions during emergencies.
' At the conclusion of these. interviews, the inspector determined that, in general, individual operators were knowledgeable of E0P philosophy.
-format, and use with regards to the postulated events.
In addition, a review of the licensee's lesson plans, learning objectives, and simulator scenarios indicated that a complete training effort was applied to the use i of EOPs. The. inspector found only one area of weakness that was common to most of'the operators. interviewed. This weakness was that not all operators were able to state all five E0P Rules from memory, even though ' the licensee's training program requires this of licensed operators.
'Although'past need for this knowledge was minimal due to shutdown plant in conditions, operators and licensee training staff should renew emphasis of these Rules in anticipation of the scheduled startup.
In addition, the i inspector found that some of the R0s were unsure if full HPI flow were L required (Rule 1) under conditions of a Safety Feature Actuation System ' (SFAS) actuation without an actual loss of subcooling margin. These J P . concerns are identified as inspector followup item (87-32-03).
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. ._ _ -_ - - _ _ ._ u% ! ' ,Q . i l t 'It should be.~noted that this evaluation of operator familiarity with the E0Ps could not alone. determine the effectiveness of operators in a ! real-time, team-oriented environment. A plant-specific simulation facility. has been used for a full evaluation of E0P's at other utilities.
, . Rancho Seco uses.the Power Safety International Simulator in Lynchburg, VA l ,for training purposes.. NRC Region V personnel observed a Rancho Seco ' i . requalification class for two days early in 1987 and documented this ! observation:in Inspection Report 50-312/87-06(para.6.C.3). Only one E0P event..that went beyond~ normal post-trip actions was exercised during that inspection. 'However,"the inspector evaluated operator performance for l . Jthose two days as satisfactory.
The present inspector considered that j satisfactory performance during the previous observation along with the M W- . evaluation of ' operator knowledge during this inspection indicated that i the operators are knowledgeable on the use of the E0Ps with the ! ~,
exceptions noted above.
~ Within this' are'a inspected,'no violations or deviations were identified.
. /' '10., Review of QA' Activities Involving the Development and Implementation - . E E0Ps TheLinspector reviewed the QA audit files for 1984 through 1987 and discussed the' audit function of the-QA organization with responsible
, vlicensee personnel. This was done in order to assess the amount and i adequacy of QA involvement with the preparation and implementation of the E0Ps.
- The-inspector's review of the audit files indicated that only one audit'
. was performed of E0Ps. This audit, 87-55, started September 3, 1987, was A performed per Technical Specification-requirement 6.8.1.a to determine j , that procedures had been prepared to satisfy Regulatory Guide 1.33 l Appendix A requirements. This audit only verified that E0Ps existed.
+ The inspector found one other audit report that addressed E0Ps. Rancho I Seco Audit. Report 0-812 was issued on September 19, 1986.
In this report the auditor identified that the audit addressed the requirements and
. implementation of procedure AP.48, Revision 1, and AP.49 for the , ' . validation and verification of.EOPs. The auditor recommended (item ,- VII.4) that a series of Quality Surveillance be conducted covering emergency procedures and casualty procedures against the requirements of ! the AT0G, including format and training requirements. This item was then j _ entered on the QA Followup Action History List.
In a response to this j recommendation dated November 20,1986, (NOM 86-538), the operations t 'departmentLstated that the discrepancies identified in the audit report I were not indicative of programmatic problems of the magnitude which would
suggest the need for a series'of Quality Surveillance.
l 1,, ! Subsequent' to the auditor's recommendation, the QA organization performed a QA' surveillance and issued QA Surveillance Activities Report 833 on
- March 5, 1987.
In this report it was identified that conversations with ! ' the ProDets Procedures Operations Superintendent revealed that the !
- requirements of the.ATOG were not' believed to apply to the Casualty
Procedurtis-since they were event oriented.
It was also identified that i the E0Ps had recently been reviewed by the STA Supervisor using the L L L > i
~~ y
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a'... validation and verification procedures, that training on the E0Ps was . i " adequately covered via simulator training sessions and requalification L'
-seminars,.and that the format of the E0Ps was governed by the E0P writer's i < . guide.; The.QA auditor stated in this audit that based on those items, i the Nuclear Operations response to item VII.4 of QA audit 0-812 was adequate and that this surveillance had fulfilled the auditor , recommendation's intent. The inspector observed that the auditors again i did not review the' E0P program or the E0Ps.
Instead, they had relied on l . the" statements of the operations personnel and the operations E0P review l program to act as.the quality function.
! The inspector questioned whether the limited Rancho Seco audits I ' performed on E0Ps were in accordance with the QA Manual or ANSI standard i requirements!that audits be conducted to determine the adequacy and ! ., ' effectiveness of programs for the operations of Rancho Seco..In addition, review of the audit files indicated that in-depth audits of i operating' procedures'also may not have been conducted. The requirements ! for performing QA audits'will be reviewed by the inspector to determine if the District has maintained a quality function that was capable of assessing the adequacy of Rancho Seco operational programs, in particular with regard to~the development and implementation of the E0Ps. This concern is identified as an unresolved item (87-32-04).
, Within the:are'a inspected, no violations or deviations were identified.
11.
Experienc'e Review Program Some of the types of. deficiencies. identified by the inspectors in the l preceding. paragraphs were previously identified in IE Notice 86-64, " Deficiencies in upgrade programs for plant Emergency Operating Procedures," that was issued =in August, 1986.
In addition, a Supplement 1 - to this. Notice was. issued April'20, 1987.
Since many of the types of discrepancies identified in this inspection were' also identified -in IE Notice 86-64,. the inspector questioned the . implementation of the licensee's Experience Review program and its ability to, factor in items identified ~in documents such as IE Notices. The , inspector..found that the Licensing section was responsible for passing on ' ' applicable IE Notices to the proper organizations and for entering action l items, identified in the Notice into the Coordinated Commitment Tracking - System (CCTS). The inspector reviewed the licensee's files and found f that the Notice land Supplement were received and that they were added to i the CC1S as items T860626005C and T870504303C respectively.
The inspector l found in the files that on July 2,1987 and August 3,1987, Operations ! acknowledged that they were responsible for actions on this Notice and i that corrective actions would be completed by December 1, 1987.
l However, no description of the proposed corrective actions was provided.
l The inspector was concerned that the there has been no licensee program ) >in place to: identify and correct discrepancies such as those presented in l this' inspection report. More than a year elapsed since IE Notice 86-64 was. issued, and the inspector considered that the deficiencies identified l
- in the Notice should have been considered and factored into the licensee's i
i " .
. ,y y , - - - - - _ - - , l th t e
s [ ' 71
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' .. ' o ~i program within that year. The inspector will continue to evaluate the ! clicensee's. Experience Review Program which is identified as inspector j ,fol.lowupitem(87-32-05).
> i Within'the area inspected, no violations or deviations were identified.
j H 12. ~ Sunmary f Further review of the Rancho Seco E0Ps and their bases is required in j order to assess the technical adequacy of the E0Ps and to resolve the - ' various concerns raised'in this inspection.
In a telephone conversation between Region V, NRR, and-SMUD on October 19, 1987, SMUD agreed to I submit a revised PGP that would describe how information from the generic TBD was incorporated into the E0Ps, how plant specific values were input into the EOPs,.and how changes to the E0Ps are to be controlled.
{ ~ SMUD also agreed to perform a detailed analysis of the deviations from 'the-TBD and to provide justifications for the deviations identified.
In addition,L SMUDLic'entified that the E0Ps.would be reviewed to assess conformance-tc the writer's guide. The-licensee agreed to attempt to complete the' un unentation.of E0P justifications within four weeks.
.The District rc,,resentatives stated that they did not intend to incorporate , their'cooldown procedures into the PGP prior to plant restart. The NRC ' representatives questioned this approach. This issue remains open pending .further review and is identified as inspector followup item (87-32-06).
> > I 13. ~ Unresolved' Items Unresolved items are matters'about which more information is required-in '
- order to ascertain whether they are acceptable, a violation, or a
' deviation. -Unresolved items: identified during this inspection are discussed.in Paragraphs 5.b and 10.
! 14. Exit Meetinq ! 0n October 2,1987, an exit meeting was held with the licensee representatives identified in paragraph 1.
The inspector summarized the inspection scope and findings as described in this report.
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