IR 05000312/1988014

Insp Rept 50-312/88-14 on 880425-28.No Violations or Deviations Noted.Major Areas Inspected:Licensee Plans for Coping W/Strikes & Nonlicensed Staff Training.Specific Weaknesses in Licensee Program Observed

ML20197E337
Person / Time
Site:	Rancho Seco
Issue date:	05/19/1988
From:	Ang W, Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20197E334	List: IR 05000312/1988014 ML20197E329
References
50-312-88-14, NUDOCS 8806080266
Download: ML20197E337 (9)

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U. S. NUCLEAR REGULATORY COM4ISSION

REGION V

Report No. 50-312/88-14'

. Docket No. 50-312  ;

License No. DPR-54 Licensee: Sacramento Municipal Utility District-P. O. Box 15830 Sacramento, California 95813 Facility Name: Rancho Seco Nuclear Generating Station Inspection Conducte - April 25-28' 19 M Inspection by: e, b /9-Y[

W4). ng, Proj'c .IpsVector -Date Signed Approved by: / / / b -N

'Date Signed L. Mfiler, chief, y ect Section 2 i Summary:

Inspection on April 25-28, 1988 (Report No. 50-312/88-14)

Areas Inspected: Routine, unannounced inspection by a region based inspector of licensee action on previously identified inspector items, licensee plans for coping with strikes, and non-licensed staff training. Inspection l Procedures 92701, 92709, 41400, and 30703 were used during this inspectio .Results: No general conclusions regarding the adequacy, strength or weakness of the areas inspected, nor any significant safety matters, were identifie ,

In the areas-inspected, lo violations or deviations were identified. -The f following specific weaknesses in the licensee's programs were observed:

.(1) The licensee was unable to provide any plans for coping with a strike (Inspector Follow-up Item 88-14-02).

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(2) The licensee continued to show weakness in the timeliness of licensed and non-licensed operator reading assignments and a dependency on contract ,

personnel staffing in the Operations Training Section of the training i departmen !

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DETAILS Persons Contacted ~ Licensee Personnel J. Firlit. AGM, Nuclaar Power Production

D. Keuter, Director, Nuclear Operations and Maintenance D. Brock, Acting Nuclear Maintenance Manager

• W . Kemper, Nuclear Operations Manager T. Tucker, Nuclear Oparations Superintendent

• S. Crunk, Manager, Nuclear Licensing P. Turner, Manager, Nuclear Training

• H. Harrell, Superintendent, Operations Training

• T. Khan, Supervisor, Mechanical Engineering

L. Pulley, Supervisor, Mechanical Engineering J. Rosing, Senior Human Relations Analyst ,.

G. Legner, Licensing Engineer , NRC Resident Inspectors A. D'Angelo

P. Qualls ,

Attended the exit meetin The inspector also held discussions with other licensee and contract ,

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personnel during the inspection. -This included plant staff engineers, technicians, non-licensed operators, administrative and clerical assistant . Follow-up (927031 i (Closed) Unresolved Item 86-18-05 and (Closed) Unresolved Item 86-18-06 - High Point Vent Piping Classification and Seismic Analysis On March 4,1986, NRR issued a Safety Evaluation Report (SER), '

"Rancho Secc High Point Vent Evaluation," and provided quality and seismic classifications for various portions of the high point vent piping. URI 86-18-05 and 86-18-06 identified discrepancies between the NRC SER classifications and the licensee's piping design. On September 16, 1986, the licensee submitted its response to the URI's and the identified SER discrepancies. In summary, the licensee's position was that the high point vent piping code and quality classifications were in accordance with the guidance applicable j during licensing and that upgrading to current day standards should t

, be reviewed as a backfit. The response, however, stated that the reactor coolant vent line from the first isolation valve to the i piping supports in the nitrogen supply line had been analyzed to ,

seismic Category I requirement :

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The installed piping, the piping stress analysis and the IEB 79-14 inspections performed on the subject piping were previously

inspected, determined to be adequate-and, the inspection documented in Inspection Report 50-312/87-36. The results of the inspection wer e provided to NRR.for inclusion in the evaluation of the licensee's respons The NRR Safety Evaluation Report dated March 28, 1988, stated the-following

"The staff has reviewed the information submitted by the licensee regarding the quality and seismic classification information for the high point vent and nitrogen supply piping and concludes that these systems are classified correctly considering the applicable regulations in effect when the plant was designed. The staff has also reviewed the adequacy of the seismic design of this piping and has determined that the design procedure used for this piping is in accordance with staff accepted methodology. Therefore, the staff considers the issues of the correct classification and seismic analysis of the high point vent and nitrogen supply piping closed for the purpose of plant restart."

Unresolved Items 86-18-05 and 86-18-06 were close NRR is still reviewing the licensee's piping analysis procedure in cases where piping systems are not analyzed between anchors (the use of so-called "effective" anchors). Pending further NRR review of the potential non-conservative modeling technique, the item was identified as inspector follow-up item 50-31?/88-14-0 No violations or deviations were identifie . .. -

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3. Licensee Plans for Coping with Strikes (92709)

An inspection was performed to determine if the licensee had a contingency plan for a possible strike and to determine the adequacy of the pla The licensee had no contingency plan for a possible strike at Rancho Seco. The licensee stated, however, that there was no known stated or rumored talks of an impending strike. The licensee further stated that recent management init',itives such as the new work schedule had received favorable response from the work forc Lastly, the licensee stated that since it was a utility district, it could obtain court injunctions against strike Notwithstanding this rationale, the licensee committed to initiate action to evaluate the need for contingency strike plans and develop one if appropriat The licensee contacted other utilities during the inspection, and requested copies of their strike contingency plan Pending licensee action to evaluate the need for strike contingency plans, this issue was identified as Inspector follow-up item 88-14-0 No violations or deviations were identifie . (Closed) TI 2515/73 - Follow-up of IE Bulletin (IEB) 85-03 - Motor Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings Inspection Report 50-312/87-44 documented inspections performed in accordance with the subject Temporary Instructions (TI) and closed both TI 2515/73 and IEB 85-03. On April 18, 1988, the Generic Communications Branch of the Division of Operational Events Assessment of the Office of Nuclear Reactor Regulation provided Region V with the following evaluation regarding the licensee's responses to IEB 85-0 "As requested by action item e. of Bulletin 85-03, "Motor-Or9 rated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settingh," the licensee identified the selected safety-related valves, the valves' maximum differential pressures and the licensee's program to assure valve operability in their letters dated May 16', September 5, and Novemtier 5,198 Review of these responses indicated the need for additional information which was contained in Region V letter dated September 22, 198 Review of the licensee's November 2 and 12, 1987, responses to this request for additional information indicates that the licensee's selection of the applicable safety-related valves to be addressed and the valves' maximum differential pressures meets the requirements of the bulletin and that the program to assure valve operability requested by action item e. of the bulletin is now acceptable."

No violations or deviations were identifie . ..

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. 4 5. Non-Licensed Staff Training (41400)

An inspection was performed to evaluate the effectiveness of the training programs for the non-licensed staf Non-licensed staff training had been previously inspected and the results of the inspection were documented in Inspection Report 50-312/87-0 Training Requirements Rancho Seco Technical Specifications (TS) Administrative Controls Section 6.4 provided training requirements for the operating staf Training was required by the TS to be in accordance with Section of ANSI N18.1-197 Non-Licensed Training Programs The licensee's Non-Licensed Operator (NLO) training program was outlinci in the Program Description (0D 23 Z 0000 Revision 0). The program consisted of classroom training, self-study and on-the-job trainin The classroom training included courses on plant orgar;szation and administrative procedures, power plant fundamentals, electrical theory, and systems and procedures. The self stu?y phase consisted of check sheets for familiarization with selected plant systems and procedures that were to be completed while working on shif The on-the-job training phase consisted of check sheets for familiarization and, in varying degrees of involvement, performance of specific plant evolution tasks while working on shift (for example, performing NLO functions related to filling and venting specific systems). The NLO training program was designed for three levels of NLO's - Power Plant Helpers (PPH),

Equipment Atter.dants (EA) and Auxiliary Operators (AO). The program also served as a preparatory program for entry into the Licensed Operator training progra The above described NLO training program was accredited by INP0 in April, 198 In addition to the NLO training program, the licensee also had training programs for Shift Technical Advisors (SA 21 Z 0000),

Health Physics Technicians (CR 21 Z 0000), Chemistry Technicians (CR

22 Z 0000), Instrument and Control Technicians (EI 21 Z 0000),

Electrical Maintenance (EM 21 Z 0000), Mechanical Maintenance (MM 21 Z 0000), and Electrical Technicians (ET 21 Z 0000). The program descriptions were reviewed. However, for this inspection, the inspector concentrated on the NLO training progra The licensee's training programs for non-licensed personnel appeared to meet the requirements of ANSI N18.1 - 197 NLO Training Program Evaluation The training related aspects of the following Rancho Seco events were selected to evaluate the licensee's NLO training program:

• November 19, 1986 Pressurizer Heater Damage Incident

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December 16, 1987 TDI Emergency Diesel. Generator (EDG) Reverse Power Incident The events were reviewed in conjunction with the review of the training program to:

Evaluate whether the classroom or on-the-job training received before the event / occurrence was sufficient to have either prevented the occurrence or mitigated its effects by recognition and proper operator actio ' Determine whether the responsibility was clearly assigned for administering and evaluating the related trainin *

Detennine whether any lessons learned from the event / activity were factored into the training progra . Licensed operator actions played a major role in both events. NLO and maintenance activities were involved to a lesser exten Applicable training provided to the licensed operators (Administrative Procedures and TDI EDG System Training) was also

, provided to the.non-licensed operators on the affected subject

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matter. The inspector determined that the licensee had clearly assigned responsibility for administering and evaluating the

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training program to the training departmen (1) Pressurizer Heater Damage The licensee's root cause analysis (86-34) for this event

determined the root cause to be the "failure of management to provide administrative controls with sufficient depth to enable or ensure that operators maintained a high degree of awareness of equipment status". The licensee determined also that a contributing factor was less than aggressive and thorough investigation by operations personnel of off-normal indications and/or events. The licensee's analysis appeared to be correc However, effectiveness or adequacy of training of the licensed and non-licensed operators, prior to the event, in relation to awareness of equipment status could not be determined since the management controls were not of sufficient depth to preclude or mitigate the even (2) TDI EDG Reverse Power Event The licensee's root cause analysis (87-10) for this event stated that "the licensed operator training on the TDI diesels was inadequate". This was based on a finding that "the TDI (E)DG training provided to the operators was not retained" (i.e. remembered) and that "system engineers are not involved in the development of training." Since similar training was provided to non-licensed operators, similar conclusions that the NLO training on this subject was less than adequate could be inferred. However, possible NLO involvement in the prevention or mitigation of this event could not be determined

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.' 63 by the inspector since the event _was largely licensed operator related. The licensee performed, licensed and non-licensed e9erator retraining on.TOI EDG procedure changes, TOI EDG test

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ou;1ine and TOI EDG annunciator procedures from January through April, 198 The training department has incorporated system engineer. input into the TOI EOG system training and is in the process'of doing the same for the other plant systems.

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The inspector confirmed that the Training Department had conducted special crew briefings for the TOI EDG reverse power event. The pressurizer heater damage event was included-in operator reading assignment The inspector concluded that the licensee was adequately addressing the training related aspects of these two event E. Follow-up on Weaknesses Observed in Inspection Report 50-312/87-06 Inspection Report 87-06 noted several weaknesses in both the licensed and non-licensed operator training prog"ams. The inspector followed-up on the following weaknesses as part of this inspectio (1) The previous inspection report noted that a significant number of contract personnel were being used as instructors by the training department. The inspector noted during the current inspection that the technical training section had 14 of 14 instructors that were SMUD employee' However, the inspector also noted that 13 of 20 instructors in the operations training section were still contract personnel. This indicated-dependency on contractors within the training program which could potentially compromise the continuity of the training program, and reduced the sense of ownership that the instructors could be expected to have with regard to the

, training program. This weakness was discussed with the l Training Department Manager, the Director of Nuclear Operations and Maintenance, and the Assistant General Manager (AGM) for Nuclear Power Production. The licensee reinforced its intentions to obtain a higher ratio of SMUD instructors but i also expressed its difficulties in obtaining qualified '

individuals to perform the instructor function (2) The previous inspection report noted a weakness in the l timeliness of completion of reading assignments by both l licensed and non-licensed operators. In response to the Inspection Report 87-06 concern, the licensee issued Operations Special Order 87-38 to reinforce the importance of timely completion of reading assignment During the current inspection, the inspector reviewed the April 21, 1988 listings for completion of reading assignments by NLO's and for completion of reading assignments-and technical specification revisions by licensed operators. The listings showed that 20 of 30 NLO's had 1987 and 1988 reading assignments that were either completed late or were overdu The listings also showed that 37 of 40 licensed operators had 1987 and 1988

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reading assignments and technical specification revision reading assignments that were either completed late or were overdue. The worst cases appeared to be a reading assignment completed by an NLO approximately 5 months overdue and several licensed operator who had only completed 3 of 12 reading assignments and TS revisions on time. The inspector also noted that two licensed operations department management personnel had 1987 and 1988 reading assignments and TS revisions that were completed Irte or that were overdu The observed continuing weakness regarding timeliness of completion of reading assignments by both NLO's and licensed operators was discussed with the Nuclear Operations Superintendent responsible for training, the Operations Training Department Superintendent, the Operations Manager, the Director of Nuclear Operations and Maintenance and the AGM Nuclear Power Production. The licansee agreed to reissue Special Order 87-38 with increased Operations Department Management Emphasi Interview of Non-Licensed Operators Six non-licensed operators were interviewed to determine if they received training for tasks they performe The persons interviewed were in the licensee's NLO training program. Several concerns were expressed regarding details of the performance of the on-the-job training portion of the progra However, the inspector noted that they had gone through classroom training, and were undergoing various phases of the systems hardware familiarization and task performance portions of the progra All the NLO's expressed concerns regarding the hiring of licensed operators directly into the licensed operator training program without going through the NLO program at SMU The concerns were of a personnel nature rather than a safety issue. The inspector informed the NLO's that SMUD Operations Department management would be made aware of their personnel related concerns and also informed the NLO's that if they wished to pursue their personnel related concerns, the Rancho Seco Ombudsman program would be a mechanism for review of them. The inspector informed Operations Department Management about the concerns. The licensee stated that it would review the NLO's personnel related concerns. The licensee also stated, in response to the inspector's question, that 30 of the 36 currently licensed SMUD operators had gone through the SMUD NLO progra No violations or deviations were identifie . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable, or may involve violations or deviation '

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9. Exit Interview (30703)

The inspection scope and findings were summarized on April 28, 1988,-with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding Licensee representatives acknowledged the inspector's fi-dings.