Text

SALP Rept 50-312/88-39 for July 1986 - Dec 1988
	ML20244A802
Person / Time
Site:	Rancho Seco
Issue date:	03/28/1989
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	;
Shared Package
ML20244A790	List: IR 05000312/1988039; ML20244A788; ML20244A802;
References
	50-312-88-39, NUDOCS 8904180195
Preceding documents:	ML20247H555 (21 July 1989);
	Download: ML20244A802 (41)
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J H SALP BOARD REPORT i

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l l' U.-S.' NUCLE R REGULATORY COMMISSION

REGION V

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE.-

, 50-312/88-39 SACRAMENTO MUNICIPAL' UTILITIES DISTRICT-RANCHO SECO NUCLEAR CENERATING STATION

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JULY 1, 1986 THROUGH DECEMBER 31, 1988

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TABLE OF CONTENTS 0;.

Page j Introduction 1

' Licensee Activities 1 ' Direct Inspection and Review Activities 2

.I Summary of Results 2 Effectiveness of Licensee Managemen Results of Board Assessment 3 j < Changes in.SALP Ratings 4 III.' Criteria 4 IV.*-Performance Analysis Plant Operations 5' Radiological Controls 9 Maintenance / Surveillance' 13 Emergency' Preparedness 15

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. Sec.urity 16 F. " Engineering / Technical. Support 19 Safety Assessment / Quality Verification 21 Startup Testing 24

. Supporting Data and Summaries 25

" 25 Enforcement Activity '

.? Confirmation of Action Letters 26

' AEOD Events Analysis: 26'

Detailed Description of Licensee Activities

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., Table 1 - Inspection Activities and Enforcement Summary 19 i

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Table.2 - Enforcement Items 30'. ,

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? Table 3 - Synopsis of Licensee Event Reports 34 a j w y . ~A t tachment 1 - AEOD Review of Licensee Event Reports 35

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l s INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) is an NRC staff integrated effort to collect available observations and data on a periodic basis and evaluate licensee's performance based on this information. The program is suppleetntal to normal regulatory processes used to ensure compliance with NRC rules and regulations. It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the licensee's ;

management regarding the NRC's assessment of their facility's performance in each functional are An NRC SALP' Board, composed of the members listed belou, met in the Region V office on February 2, 1989, to review observations and data on the licensee's performance in accordance with NRC Manual Chapter 0515,

" Systematic Assessment of Licensee Performance," dated June 6, 1988. The Board's findings and recommendations were forwarded to the NRC Regional Administrator for approval and issuanc This report is the NRC's assessment of the licensee's safety performance !

at Rancho Seco for the period JuJy 1, 1986 through December 31, 198 )

The SALP Board for Rancho Seco was composed of: ,

- A. E. Chaffee, Acting Directar, Division of Reactor Safety and Projects, !

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Region V (Board Chairman)

- G. W. Knighton, Director, Project Directorate V, NRR

- G. P. Yuhas, Chief, Emergency Preparedness and Radiological Protection Branch

H. S. North, Acting Chief, Facilities Radiological Protection Section

M. D. Schuster, Chief, Safeguards Section

R. Fish,. Chief, Emergency Preparedness Section

- L. F. Miller Jr., Chief, Reactor ProjectsSection II

- R. P. Zimmerman, Reactor Projects Branch

- G. Kalman, NRR Project Manager

- D'Angelo, Senior Resident Inspector

- W. P. Ang, Project Inspector

C. Pendergast, Emergency Preparedness Analyst

D. Schaefer, Safeguards Inspector

n. Pate, Chief, Nuclear Materials Safety and Safeguards Branch

- Denotes voting member in all functional area Licensee Activities s

Rancho Seco was in an extended shutdown outage from the start of the evaluation period until March 30, 1988. After being granted Commission approval, a gradual approach to full power commenced with l plant startup on March 30, 1988 until the end of the evaluaticn l period. The gradual approach to full power included a rigorous power acension test progra In general, Rancho Seco operated satisfactorily from March 30, 1988 through December 31, 1908. A detailed discussion of the significant occurrences during the period is provided in Section V.D of this repor _ _ _ _ _ - _

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a Direct Inspection and Review Activities

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Approximately 15,427.on-site inspection hours were spent in performing a total of 100 inspections by resident, region-based, headquarters, and contract personnel. Inspection activity in each functional area is summarized in Table The unusually large number of-inspection hours was a result of the extended SALP interval and a large inspection program prior to restart on March 30, 198 II. SUMMARY OF RESJLTS Effectiveness of Licensee Management The licensee's management organization stabilized somewhat in mid-1987 with the appointment of a Chief Executive Officer (CEO),

Nuclear on May 4,1987, and the formation of a new organizational structure. Subsequent to restart, on June 16, 1988, a new CEO, Nuclear was appointed, and the organization's subordinate managers have changed assignments, in some cases, as wel During this SALP period SMUD senior management initiated several major programs for improvement of Ranche Seco performance. These included:

An Action Plan for Performance Improvement

A Systems Review and Test Program

An Engineering Action Plan

A Procurement Action Plan

Installation and Testing of a Safety Grade Emergency Feedwater Initiation and Control System

Installation and Testing of Two Additional Emergency Diesel Generators The improvements undertaken by management are reflected in the improved SALP ratings. However, numerous tasks remain to be completed by the current management to improve plant reliabilit Included in these are commitments to the NRC such as the establishment of design basis documents, and an effective engineering oversight. The need for increased involvement by the current senior plant management in important plant evolutions was evidenced by the December 12, 1988 feedwater transient. This senior management involvement should be in sufficient detail to assure greater caution and a more thorough understanding of plant activities. Management attention needs to be focused on assuring plant standards for performance established by the startup and test program for testing are not relaxed as was evident by the auxiliary feedwater overpressure event which occurred after the SALP perio Results of Board Assessment The SALP period was unusually long (July 1986 to December 1988) and covered a period of plant operationc that was characterized by

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f severalchangesinplantmanagementandorganizationandCby'[iverse ,

plant evolutions. associated with SMUD attempts to upgrade. Rancho Seco following an NRC imposed plant shutdown on December 26, 1985.:

The plant restarted in March 1988 and commenced a power. ascension program which was completed in December 1988. .This SALP focused on

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post-restart operations and on the current management and staf Discussions of pre-restart' evolutions and performances are included when these events appeared relevent to the evaluation of currently.-

existing plant conditions and personnel;

- Overall, the SALP . Board found the performance of NRC licer.aed activities by the licensee to.be acceptable and directed toward safe operation of Rancho Seco. The SALP Board has made specific-recommendations in most functional areas for licensee l management consideration. The results of the Board's assessment of the licensee's performance in each functional area, including the previous assessments, are as follows:

Rating Rating Last This Functional Area * Period Period ' Trend ** Plant Operations 3 2 B...

Radiological Controls- 3 2 Maintenance / Surveillance 3/2 2

. Emergency Preparedness 3 2 Improvin E.- . Security 3 2 Engineering / Technical Support 2 2 Safety Assessment / Quality 3- 2

' Startup Testing Not Rated 1

Maintenance.and Surveillance were separate functional. areas duringfthe last SALP period. Safety Assessment / Quality Verification is a new functional area this period. . It is similar to, but more comprehensive-than, the Quality Programs and Administrative Controls Affecting Safety functional area which it replaced. Other functional areas rated separately during the last SALP period, such as.. Fire Protection and

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Training, were evaluated as appropriate within the scope of the functional areas listed cbov ** The trend indicates the SALP Board's appraisal of the licensee's direction of performance in a functional area near i the close of the assessment period such that continuation'of this trend may result in a change-in performance leve Determination of the performance trend is made selectively and

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is rest.rved for those instances when it is necessary to . focus

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2 NRC and licensee attention on an area with a declining performance trend, or to acknowledge an improving trend in

,- licensee performanc It is not necessarily a comparison of-g

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s performance daring the current period with that in the previous

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, Changes in SALP Ratings i .

Performance during this SALP period has' improved from.that of the previous SALP period. These improvements occurredsbecause major changes were made to equipment, personnel, and programs during the extended shutdown. Satisfactory accomplishment of these changes was indicated by the Nuclear Regulatory Commission's approval of' plant-restart on March 22, 1988. The Plant Operations, Radiological Controls, Maintenance, Emergency Preparedness, Security, and Safety Assessment and Quality Verification-areas improved from Category 3 to Category 2 rating III. CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction or operational phas Functional areas normally represent areas significant to nuclear safety and the environment. In this evaluation, a special area of Startup Testing was added due to the large amount of testing which was conducted by the licensee prior to restart in March, 198 The following evaluation criteria were used, as applicable, to assess each functional area: Assurance of quality, including management involvement and contro . Approach to resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement histor . Operational events (including response to, analysis of, reporting of, and corrective actions for events). Staffing (including management). Effectiveness of the training and qualification progra However, the NRC is not limited to there criteria and others may have been used where appropriat On the basis of the NRC assessment, each functional area evaluated was rated according to three performance categories. The definitions of these performance categories.are as follows:

i Category 1: Licensee management attention and involvement are readily -l evident and place emphasis on superior performance of nuclear safety or I safeguards activities, with the resulting performance substantially exceeding regulatory requirements. Licensee resources are ample and effectively used so that'a high level of plant and personnel performance .

is being achieved. Reduced NRC attention may be appropriat l i

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Category 2: Licensee management attention to and involvement in the performance of nuclear-safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet regulatory-requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieve NRC attention may be maintained at normal level Category 3: Licensee management attent_fon.to and involvement in-the performance of nuclear safety or safeguards activities are not sufficient. The licensee's performance'does not significantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained.or not effectively used. NRC attention should be increased above normal level IV. PERFORMANCE ANALYSIS The following is the Board's assessment of the licensee's' performance in each of the functional areas, plus the Board's. conclusions for each area and its recommendations with respect to licensee actions and management emphasi Plant Operations Analysis During the SALP period, approximately 4029 hours0.0466 days 1.119 hours 0.00666 weeks 0.00153 months 'of direct inspection effort were applied in the Plant Operations are Plant Operations has improved significantly during this SALP period. The most important accomplishments were the improved professionalism of operators, and the reduction of operator errors during intricate plant manipulations. Other strengths were observed such as improved equipment control procedures and significant upgrading of procedures. However, improved communication among managers at different levels in the organization appeared warrante Prior to plant restart in early 1988, the licensee began a performance improvement program designed to enhance the quality of future plant operations. The program included:

(a) Plant Emergency Operating Procedures were completely rewritten in accordance with the latest Babcock and Wilcox and NRC guidanc (b) The Safety Parameter Display System (SPDS) was added to enable plant operators to quickly assess critical plant parameters. The system provided Rancho Seco operators with a useful, user friendly display and helped them to respond correctly to transient (c) The Technical Specifications (TS) were upgraded in format, Limiting Conditions for Operation (LCO) were added, and previously included LCO's were modified to clarify the i Rancho Seco TS.

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i (d) The licensee requested that Rancho Seco be a lead plant in i adopting the " Improved B&W TS" which are currently being '

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The resident' inspectors observed licensee operation daily, including random backshift observations. Operations staffing

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was observed to be correct, and operations personnel were consistently observed to be knowledgeable and attentive to plant conditions. Control room demeanor was always observed to .l 4 be professiona One negative observation was that during the event on December i 12, 1988, decision making on the appropriate actions to be taken was made by operations management without the involvement l of senior plant management for review. Senior plant management subsequently recognized this weakness in communications and decision making and established an action plan to improve in this are Management presence within the plant has steadily increased following the implementation of the licensee's management monitoring program. _ Frequent tours of the-power block by all j levels of plant management were observed by the, resident '

inspector !

A weakness existed in the oversight . ole which plant management performed in its control of the specific plant departments. An ,

example was identified which concerned the progress on near i term commitments made to the NRC prior to plant restart in early 1988. The commitments which wece made involved improvements to the plant which had ';een identified by the licensee's programs established as a result of the December 26, 1985 event. The inspectors noted that plant management was not !

knowledgeable of the status of some of the significant ;

commitments which had been made to improve engineering and

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procurement, in particular. The licensee responded to the issue in a timely fashion with goals established for the facility to complete previously identified item The licensee's approach to the resolution of operational safety issues was generally sound. Conservatism was routinely exhibited by the control room staff when the potential for safety significant failures existed. During the startup program, detailed tests such as the Loss of Offsite Power Test, Emergency Feedwater Initiation and Control System Test and the Steam Generator Secondary Pressure Test were properly conducted and performed. These tests used significantly abnormal valve-lineups of both the electrical and mechanical plant system The December 12, 1988 reactor trip was an exception to this overall tren In that event, the licensee kept the reactor operating despite a double failure in the controls for the steam supply to the main feedwater pump. Also, the AFW overpressure event demonstrated weakness in the conduct of post maintenance testin q

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Throughout this extended SALP period, the licensee's responsiveness to NRC initiatives has been rapid and thorough, particularly prior to the March 30, 1988 restart of Rancho Seco. This was evidenced by the implementation of several l major programs resulting from NRC observations or inquirie These included:

An Action Plan for Performance Improvement

A Systems Review and Test Program *

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An Engineering Action Plan

A Procurement Action Plan

Installation and Testing of a Safety Grade Emergency Feedwater Initiation and Control System

Installation and Testing of Two Additional Emergency ,

Diesel Generators (EDG)

Three Severity Level IV violations were issued during.the assessment period involving the failure to provide reports required by 10 CFR 50.73. Licensee management satisfactorily

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resolved the deficiencies through clarification of their

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'. procedure for controlling notifications to the NRC. , '

t A total of 36 LER's were submitted in this functional' are Most of the LER's were attributable to personnel error. Nine of these dealt with fire protection discrepancies that predominately involved missed fire watches. During these periods extensive modifications.and testing were in process with the plant in off normal configurations. The remaining LER's appear to be attributable to weak procedures and isolated events. Those LERs received additional management attention to ensure improved performance and procedures. The licensee developed an Operations Department Action Plan in December 1987 which resulted in improved performance and few LERs since have related to personnel error or procedural deficiencie In the early phases of the test program, a number of operational errors were committed during testing which ultimately lead to suspension of testing during the Loss of Offsite Power test In response to the difficulties experienced at the time, the Operations Department Action Plan mentioned above was developed. Operator performance since that time improved considerably with no significant operator errors being detecte The licensee conducted an extended power ascension program which included significant Integrated Control System (ICS)

tuning and two preplanned reactor trips. During this phase, the control room operators were also challenged by two unplanned reactor trips, one which led to the reactor coolant system being on natural circulation. During these events, performance by the control room personnel was sound and timely in response to the unexpected plant transients which had l occurred. In addition, the ICS and main feedwater system caused several plant transients which were correctly addressed

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by the plant operators who prevented a reactor trip by quickly identifying the condition and correcting the cause for the abnormal conditio The licensed operator training program was effective during the SALP period. This was evidenced by a high pass rate of 90 percent (9 passes of 10 candidates) on annual requalification examinations and a 100 percent pass rate (17 out of 17) on the 1987 and the 1988 replacement examinations. The licensee has started construction of an Engineering and Training Building during this SALP period with completion (ready for training)

. scheduled for the Summer 1990. Arrival and startup of the site specific simulator is scheduled for mid-1990. The licensee's operations staff has remained stable throughout this SALP period. 'All licensed operator positions are filled and only one vacancy occurred in the last yea During this SALP period, the licensee's overall fire protection program improved. Some deficiencies in fire barriers, fire alarm systems, fire suppression systems, fire brigade training and the performance of fire pumps continued; however, both a plan and resources for' correction of these deficiencies were established by the licensee.' . Routine and corrective maintenance activities appeared to be responsive to the need for safe.and' reliable performance of fire protection system V Conclusion Performance Assessment - Category 2 Board Recommendations The-Board recommends that the licensee continue to emphasize improving communication and decisionmaking among mid and upper level plant managers. Action should also be taken to enhance specific plant knowledge among the plant management staff to improve assessment and recognition of unusual or abnormal plant condition B. Radiological Controls Analysis A total of thirteen routine and four special inspections were conducted by the regional staff during this assessment period in the areas of organization and management, occupational radiation safety, radiological effluent control and monitoring, radioactive waste management, transportation of radioactive

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materials, training and qualifications, and confirmatory measurements. In addition, the resident inspectors provided continuing observations in this are For the last assessment period, the licensee was assigned a Category 3 rating. The board had recommended that the licensee i

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implement the reorganization of the Chemistry, Radiatio > : Protection and.the Technical Support group in a timely fashion, and fill,the vacant Chemistry Superintendent's position'as

- quickly as possible; improve the NRC commitment tracking system; amend the Technical Specifications to improve the Radioactive. Environmental Monitoring Program.to' assure compliance with'10 CFR Part 50, Appendix I; complete the

- installation and testing of the Post Accident Sampling System (PASS).

There has been significant improvement in management support in the' radiological controls area. During the beginning of this assessment period, management was slow in providing the needed support. However, changes in upper management during the'last two years'have resulted in increased support and improved performance. Specific examples include: . implementation of an effective NRC commitment tracking system; demonstration of an operable PASS prior to reactor restart (March 1988); revision of the Technical Specifications and Off-Site Dose Calculations Manual to improve the Radiological Effluent and Environmental Monitoring programs, and assure compliance with 10 CFR 50, Appendix The QA organization has been effective in ,

providing independent critical review, particularly, in the area of the radioactive effluent control and monitorin program. Surve111ances conducted by the Corporate Health Physics and Chemistry Services group have been effective in identifying deficiencies in the radiation protection and effluents programs. A monthly management observation program was instituted which resulted in increased involvement of site management in plant activities. Weekly supervisory plant valkdowns have been effective in identifying and correcting deficiencies and improvement in housekeeping practice A continuing concern involved the frequent changes in management personnel, organization, and assignment of responsibility for implementation of the radioactive effluent programs. During the latter part of 1987, the responsibility for offsite dose calculations was transferred from the Radiation Protection Department to the Environmental Monitoring

& Emergency Preparedness (EM&EP) Department, with liquid and gaseous effluent sampling being performed.by Radiation Protection, and sample counting by Chemistry. On July 15, 1988, responsibility for implementing the effluents program was transferred to Chemistry. By February 1, 1989, Chemistry will have responsibility for effluent sampling. The instability resulting from continuing changes in responsibility for management of'the effluent programs has inhibited the establishment of a program with well-developed procedures and experienced personnel. Due to these changes, the licensee has not always been timely in responding to and taking corrective action for deficiencies identified through internal assessments. During the last month of this assessment period, the Chemistry group appeared to be aggressively working to develop an effective progra k

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On February 4, 1988, the licensee experienced an event tha / resulted in a worker receiving a calculated dose to a small

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area of skin of whole body in excess of the quarterly limit

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of management oversight with respect to communication .

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training and implementation of the procedures to control hot f

, , particle Shortly after the incident, management recognized the seriousness of the problem and took prompt and extensive

- corrective actions to prevent recurrence. The licensee accelerated implementation of their hot particle program and completed training of all onsite workers on the hazards and ,

I controls related to hot particles by April, 198 The licensee resolved most technical issues with appropriate conservatism, technical competence, and supporting documentation. This was notably demonstrated in the licensee's response and corrective actions to the February 4, 1988 hot particle incident. With respect to the effluents program, in implementing their new Radiological Effluent Technical Specifications (RETS), the licensee identified counting times j required to meet new lower limit of detection (LLD)

requirements for radioactive liquid pre-batch releases and composite samples that were unattainable for certain gamma emitting isotopes. The long counting times (about 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months )

resulted in difficulties in making releases in a timely fashion. It appeared that the licensee had failed to properly evaluate their capabilities for meeting the LLD values prior to submission of the request for license amendment. After a more thorough review of this matter, the licensee submitted a proposed license amendment changing the LLD for specific ,

radionuclides, without affecting the bases of the LLD values, thereby reducing the counting time The licensee's responsiveness towards resolving the operational i aspects of the liquid effluent issue has not been fully satisfactory. While many plans have been presented, NRC j inspection findings, licensee audits and operational events '

continue to reveal the need for additional management attention. Changes which would allow operation within the j envelope of expected events without exceeding 10 CFR 50 Appendix I values should be complete During this assessment period, the licensee has been generally responsive to NRC initiatives and concerns. This included j implementation of the SALP Board's recommendations from the l previous assessment, management's continued support of the I radiation protection program and improvements in facilities and management of the dry radioactive waste program. Housekeeping ,

has been effective in minimizing contaminated areas. A number !

I of long outstanding items have been addresse One Severity Level III, nine Severity Level IV, and six Severity Level V violations were issued during this assessment period. The Severity Level III violation involved (1) an

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occupationaldosetoaimallareaoftheskinof-the'wholebody of'a worker t'aat' exceeded the regulatory limit, (2) the-failure to notify an individual in writing of his exposure,.(3)'a

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failure to properly instruct workers in precautions and procedures for_ minimizing exposures when working in a " Hot Particle Zone"', and (4) the failure of certain individuals to adhere.to procedures for. control.of personnel exposure. An enforcement conference s was held to discuss the apparent ~

violations and the license'e's corrective actions to prevent-recurrence. . Based on the' licensee's prompt and extensive corrective actions to prevent recurrence, a Notice Of Violation

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was issued without it civil penalty. The other violations identified during:this long assessment period as indicated in

- Table 2,' appeared:to.be isolated occurrences.that did not

indicate a programmatic breakdown in the management of the

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radiological controls program. In addition, prompt and effective corrective actions were taken to prevent recurrenc A' total of 22 LERs were submitted in this functional are Most:of.the LERs were' attributable to personnel error. One of the LERs was related to the Severity Level III violation and the others appeared to bet isolated events. It appears that additional management' attention is needed to reduce the number

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of personnel error During the early part of this assessment period, several weaknesses were identified in the ALARA program. The weaknesses were attributable to a lack of QA involvement, training for engineers and foremen, and poor plannin Management's support for the ALARA program, resulted in the implementation of an effective training program for supervisors,' engineering, and the design review staffs. The work planning procedures were revised to include ALARA planning in the initial phases of processing work requests. A new ALARA Policy was issued and ALARA procedures were revised to strengthen the program. For 1986, the licensee expended about 505 person-rem with a goal of 165 person-rem. In 1987, the goal was set at 350 person-rem with 299 person-rem expende For 1988, the licensee's initial goal of 250 person-rem was adjusted to 95 person-rem with about 79 person-rem expended as of November 30, 1988. The long shutdown time and consequent lower source term was a major contributor to the exposure reductio There has been significant instability in organization and staffing during this assessment period. During most of the assessment period, the. Radiation Protection Manager's (RPM)

position was filled on a temporary basis by several individuals. The Chemistry Superintendent's position was staffed with contract employees and experienced a high rate of turnover. The EM&EP group also experienced several management and organizational changes. The changes in responsibility for management of the effluent programs has been a major contributor to these changes. During the last six months, the

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Radiation Protection group appears to have stabilized with keyL positions staffed with permanent employees that included

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additions-to the technical staff.- In July 1988,.the RPM's .

position was filled with a permanent . employee, :and as of October 1988,.the'EM&EP Manager's position was staffed on a

. permanent basis. The Chemistry group continues to be staffed by contract employees in key supervisory and technical:

positions. The EM&EP Department also has a high number of contract employees filling positions. .-

The licensee has.made sigr_ificant improvements in the-traiEting

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program. During the last year, the licensee has received full accreditation of their training programs from.the Institute of Nuclear Power Operations. A new upgraded General Employee; Training Program will be. initiated in January,'1989. The licensee's training and qualification program also included'

contract employees. During this assessment period, there were several events where deficiencies in training were identified

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as causitive' factors. The licensee took prompt action to-correct the deficiencies to prevent recurrenc The licensee has established a satisfactory program for-performing radiochemical measurements. -Laboratory quality control and quality assurance activities were substantially-improved during this period due to improvements in procedure Inter-laboratory comparisons of radiochemical measurements were.-

also improved, as the licensee began participating in a new contract. laboratory intercomparison program. Onsite intercomparisons with NRC measurements were successfu .- Conclusion Performance Assessment - Category 2 Board Recommen'ations d The licensee'needs to continue their efforts in the staffing of Chemistry and EM&EP.with permanent employees,.in the identification and! correction.of deficiencies in the radioactive effluent programs, and in the control of liquid wast ,

, Maintenance / Surveillance; *

1. . ' Analysis During the SALP period,_approximately 2096 hours0.0243 days 0.582 hours 0.00347 weeks 7.97528e-4 months of direct inspection effort were applied in the area of Plant Maintenance and'Surve111ance. ' Strengths were observed in the work request system with the installation..of an automated computer based generation, tracking and retrieval system for work request documents. Preventive maintenance procedures were completely revised during this SALP period and included monitoring and trending of machine vibration, thermography, oil analyses and

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mean failure. times. A continuing weakness'during the SALP-

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[ D period. involved the failure to identify and document material ,/ .e L

deficiencies when. discovered during repair or. rework of plant'

p equipment. For example, repeated trips of.the feedwater heater drain pump were not aggressively investigate The licensee programs to ensure follow-up and trending of failed surveillance, clearance of! equipment performance of required maintenance and surveillance, Land quality control of safety related materials were found-to be adequate in this period. A strength was.noted in'the generation and revision of maintenance procedures for specific plant equipment. Such procedures had included extensive use of graphics with enlarged views of equipment showing internals. Some weakness was demonstrated in the control of post maintenance testing during

'the overpressurization of the AFW system after the SALP period ended. Staffing of maintenance and surveillance organizations-was considered adequat The licensee had some difficulty in maintaining' secondary dissolved-oxygen levels within procedural requirements late in this assessment period. On one occasion, feedwater oxygen concentration limits were exceeded with the consent of management. However, the need to exceed the procedural requirement was not recognized as a deficiency to be_ evaluated by the licensee's deficiency reporting syste Licensee management was actively involved in the-scheduling and coordination of maintenance and surveillance activities. The licensee was considered to be responsive in addressing NRC

. concerns. Maintaining and utilizing current day industry standards for prevenrive and predictive maintenance activities appeared to be a goal of the Maintenance Department managemen Action was also taken to reduce work request backlogs, to control and reduce valve packing leaks, and to successfully conduct a secondary side hydrostatic test of the Main Steam system following the large number of significant modifications t made to that syste The principal maintenance weakness observed during this SALP period was insufficient identification and documentation of deficiencies observed during the conduct of planned work f activities or plant evolutions. For example, as discussed above, difficulty in maintaining secondary side chemistry was

.> not documented as required. Another example was the licensee's

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used for the repacking of the auxiliary feedwater pump during a repair effort. Subsequent failure of the pump seal was

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noted above, after the SALP period, the overpressurization of

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AFW indicated post maintenance testing as another area of ,

significant concer >

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"An'industryLaccredited training program for maintenance and f; ifsu've111ance r personnel.was developed and initiated. However, if the -training of these personnel was: deficient on at least one l

i occasion' late in the period in that' maintenance personnel-and supervisors did.not' reject kinked hydraulic hoses that they were'avare of on;a feedwater~ valve controlle '

Ten Severity Level'IV'and two Severity Level V violations, and one deviation'were issued during the SALP period. The majority

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of the' enforcement' action was related to a failure to follow

/ ~ procedures or to have an adequate procedure for the wor activity in process. While none of the violations was individually indicative of'a programmatic breakdown, taken collectively ~it appears that additional management attention is needed to reduce the. number of maintenance personnel error During the SALP period, 20 LER's were issued in the area of maintenance and surveillance. Of these 20'LER's, six involved personnel error, 4 involved installation error, nine involved defective procedures and one involved a component failure., Th .LER's adequately described the major aspects of the events and the corrective actions taken or planned to prevent recurrenc Extensive maintenance program development (which included procedure revisions) appeared to have resolved the conditions which were~ reporte Conclusion Performance Assessment - Category 2 Board Recommendations Plant management should focus special attention on identification and documentation of discrepant material conditions and improvement in post maintenance testin Licensee management should continue to emphasize the development of-work procedures for specific plant equipment, and to improve personnel performance and procedure adherence, including the chemistry are Emergency Preparedness Analysis The area of emergency preparedness (EP) was the subject or.12 inspections, including the observation of three (3) exercises, during this.SALP period. These inspections represented approximately 590 hours0.00683 days 0.164 hours 9.755291e-4 weeks 2.24495e-4 months of direct inspection effort. The resident inspectors assisted the regional inspectors in accomplishing the inspections. The previous SALP assessment concluded that'the performance in the area of EP was a Category l 3. - Recommendations to improve management support and oversite

, in numerous. areas of'the EP program were made to Plant Management by the previous SALP repor i l

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There has been a significant improvement in the management support of the emergency preparedness program during the SALP period. At the beginning of the period management support was poor, reflective of the SALP 3 rating. The changes in upper management during the last two years have brought increased support for emergency preparedness to the extent that presentiv it is considered a strength, particularly with respect to devoting resources necessary to insure an adequate capability is maintained. Considerable contractor support was obtained to provide adequate support for the changes needed to be made in emergency preparedness. The required changes included a major rewrite of the Emergency Plan and implementing procedures and significant improvements in the records system and emergency preparedness training progra Technical issues associated with dose assessment and meteorology have been addressed during this SALP perio Needed improvements in the area of meteorology were identified and are being implemented. In the interim, the licensee has made adjustments to the dose assessment program to better address the uncertainties in the meteorological dat The licensee has displayed an increasing responsiveness to NRC initiatives. The changes to the Emergency Plan and implementing procedures that were made support this findin In addition, the responses to the violations identified during the SALP period have been more complete during the latter part of the perio Three minor violations of NRC requirements were identified during.the course of the assessment period. Two of the violations' appeared to result from a failure by aiddle management (EP managtement at the time) to assure identified deficiencies were corrected in a timely and thorough manne There was considerabia variation in the licensee's emergency preparedness staffing during the SALP period. At the beginning of the period the supervision and staffing was weak. Shortly thereafter, supervision was strengthened in an effort to correct the many problems that existed. In addition, a number of contractor personnel were hired to provide adequate staffing to accomplish the numerous tasks to be performed. During the last half of the SALP period supervision of emergency preparedness was in a state of flux due to several persons filling the supervisor's position. At the present time the staffing appears to have stabilized with the hiring of a new employee to the position of Manager, Environmental Monitoring and Emergency Preparedness. Also, permanent emergency preparedness positions have been established to eliminate most of the need for contractor suppor At the beginning of the SALP period the emergency preparedness training program was considered to be a significant weaknes During the last two years the licensee has expended

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considerable' effort to improve this training ~ program. The program is now well defined and lesson plans'have bee prepared.- The exercise results have demonstrated the 111censee's ability to. respond to emergencies and identified

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' Category 2, improving tren . Board Recommendations Continued management oversite to insure emergency preparedness continues to improve and that identified problems are corrected'

in a thorough and timely' manne E. Security Analysis t

During this SALP assessment period, Region V conducted seven physical security inspections at Rancho ~Seco. _ App oximately 480 hours0.00556 days 0.133 hours 7.936508e-4 weeks 1.8264e-4 months of direct inspection effort were expendeo by regional inspectors. In addition, the resident inspector s provided continuing observations in this area. There were no material control and accounting inspections conducted during this assessment perio The previous SALP report recommended that licensee management

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expand their support.to the overall security' program. Since the initial operation of Rancho Seco..the Security Department

, reported directly to Corporate Security, located approximately

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<35 miles from the site. In January.1988, the site Security Department severed their direct tie with Corporate Security!'

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and commenced reporting directly to plant management. This-change, together with a major reorganization of the security a- organization has improved the efficiency of the Security Department by realigning key security positions and responsibilities. The reorganization of the Security Department has also improved the licensee's ability to s implement remedial measures to correct deficiencies identified ,

in the course of both internal and NRC security inspection <

On March 7, 1986,.approximately four months prior to this SALP period, the licensee published a Security Performance Improvement Plan (SPIP) for security operations at Rancho Sec This SPIP identified 79 separate actions the licensee intended to complete in order to upgrade their security program to'

resolve earlier NRC concerns. Additionally, in response to the ;

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September 1987 NRC Regulatory Effectiveness Review (RER)

report,'the licensee identified 19 additional actions. The majority of these actions have been completed, and have provided the licensee with an increased capability to defend against the design basis threa _ - _ _ -

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The previous SALP$ report also identified problems'with security force training. During this assessment. period,as a~ result of .'o the Security Departments' reorganization, the Training ~Section.-

assigned a' permanent supervisor, increased their training staff, and acquired larger training support facilities.-

Increased management emphasis.resulted in development of a Special Weapons and Tactics (SWAT) security response force, and upgraded annual refresher trainin The previous SALP report also encouraged licensee management to increase the frequency of compliance monitoring-of the. security program. As a result of their SPIP, and the reorganization o their Security Department, the full-time security auditor

< (assigned to Corporate Security) coordinates his compliance-review with the licensee's Quality Assurance Department'.

Security management has continued to' demonstrate a coordinated effort with other plant staff in preventing safetylsecurity problems at Rancho Seco. Currently, a new site radio _-

communication system is being installed which will increase the overall communication ability'of the Operations and Security- -

Departments. The licensee anticipates initial operatian of-this new radio system by January, 198 During the assessment period, thirteen information notices

. related to security were issued. The licensee's actions, as reviewed to date, were found to be appropriat The enforcement history.for the period-of July 1, 1986 through December 31, 1988 includes-five Severity Level IV violation's for the licensee's failure to: . provide adequate illumination

'of an area inside the protected area; provide two physical barriers for the protection of vital equipment; provide proper storage protection for safeguards information; deny site-access to' unauthorized personnel; and, test access alarms for certain

,. vital-area portals. Additionally, tiue enforcement history included'one deviation for the licensee's failure'to adequatel . revalidate security badges every 31 day _s During"this SALP p3riod,. Rancho Seco reported 51 safeguards .

events. Three of these events. occurred after the October 1987 change (in the reporting requirements of 10 CFR 73.71(c), and

, thus were reported in the Licensee Event Report (LER) forma l These events reinted to: repositioning plant toggle switches !

' :(21); unauthorized (mistaken) entry into plant vital areas

'(14); loss of security computers (4); bomb threats and threatening telephone calls (4); unlocked vital area portals (2); inadequate compensatory measures (1); degraded vital area barrier (1); drugs found inside protected area (1); cutting of equipment wires (1); unescorted visitor inside protected area (1); and security-related document found on site (1); The '

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majority (94%) of these events occurred during the first half of the SALP assessment perio j

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In' response'to the August 1986, NRC! policy statement on' Fitnes for Duty of nuclear power plant personnel, licensee management; continues toisupport.their established Fitness for Dut Program. This program, applicable to all licensee and contract

. personnel, consists primarily'of: Pre-Enployment Drug Screening; Medical Clarification Examinations;~ Routine Testing ,

After. Employment; For-Cause Drug Testing;-and an Employee Assistant Program. The medical clarification examination is

. administered on 'a rardom basis, and. consists of a shor . physical examination designed.to: determine the presence o drugs and alcoho1~in the employee's system, plus a medical /

psychological. evaluation. Licensee employees who work'on or operate vital; equipment, and contract employees granted access to' site vital areas, qualify for this examination.. If, in the-judgement of the examining practitioner, the employeeLi considered to have indications of drug or' alcohol use, the employee is required to submit to.a drug and alcohol urine screen. ,The. routine testing after employment,.is required when a' physical ~ examination is. mandated by a' regulatory' agenc Additionally, the licensee's Program includes the random'.

unannounced use of' drug detection dogs inside the protected are '

' .' Conclusion-Performance Assessment - Categ'ory , Board Recommendation Licensee management is encouraged to continue their support to the overall security program, and to finalize ongoing improvements identified in the Security Performance-Improvement Plan, and the responses to the RER repor Eng,ineering/ Technical Support Analysis During the SALP period, approximate 1. 1902 hours0.022 days 0.528 hours 0.00314 weeks 7.23711e-4 months of direct inspection effort were applied to the Engineering / Technical Support are In addition to continuing coverage by the !

resident inspectors, a NRC Augmented System Review and Test Program (ASRTP) team inspection was performed along with enhanced observation by senior regional staff. The major weakness in this area involved the discovery of significant inadequacies in the control of. design and engineering work, largely resulting from'a poorly defined plant design basis and insufficient attention to plant design details. In contrast, a strength observed during the latter part of the SALP period involved the self-critical attitude demonstrated by senior SMUD management in acknowledging the need for improved' performance

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in this area, including engineering reorganization.

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'The initial findings of the NRC ASTRP inspection identified several weaknesses in engineering involvement in the resolution of problems identified by the licensee's . systems ' review and l test program. The team also identified.several deficiencies with some engineering analyses for ongoing system modifications. SMUD management subsequently developed and

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implemented an innovative Engineering Action Plan (EAP) to restore confidence in' the Rancho Seco engineering design and design process. The EAP included organizational, administrative, and cultural changes to provide a better definition of responsibility and authority for engineering activities. -SMUD also contracted with an independent group of technical consultants to perform an expanded ASTRP (EASTRP)

inspection similar to the NRC inspection on the. remainder of tha systems not previously inspected by the NRC.

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A revision to the EAP provided further technical aspects of th plan. This included:

Upgrading the engineering design change process to improve the control and quality of future wor ~* Review of calculations for technical accuracy and completenes Review of' technical work performed during the outage to assure design adequac *

Reestablishment of the plant system design base The EASTRP was performed and the EAP initiated prior to restar An evaluation of E.iSTRP by the NRC ASTRP inspection

. team concluded that the EASTRP' inspection process provided adequate confidence that any significant problems with the design of Rancho Seco were being identified before restar The NRC ASTRP team also assessed the EAP and concluded that the EAP appeared to improve the quality of calculations and analyses performed to support system design. Although many aspects of the EAP were completed prior to plant restart, many other portions of the EAP remain to be completed. The second revision'of the EAP, dated September 16, 1988, was issued to

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identify items completed and the long range items still to be '

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, finished. One of the more significant aspects of the EAP that remains to be completed is the establishment of system design basis documents. The licensee has agreed to complete the

. initial portion (14 systems) of this very extensive program by the'end of the next refueling outag )

- Plant restart was contingent on several major system additions and modifications. Engineering performance to support these

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projects.was excellent. Operational safety was enhanced

, significantly by the addition of the Emergency Feedwater Initiation and Control (EFIC) system and the Safety Parameter i

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Display System (SPDS). Hardware reliability and human engineering features associated with these, relatively complex, systems are indicative of SMUD's capacity for engineering excellenc The addition of two diesel generators and modifications to the emergency electrical distribution system are additional:

examples of excellent engineering capability and performanc Diesel engine vibrations and cable routing discrepancies, tasked the engineering organizations ability to respond to

, . unexpected problems. In both instances, these complex issues were resolved in a thorough and professional manne Three enforcement items were identified in this functional area. Specifically, one Severity Level IV violation was identified for failure to establish written procedures for radiographic inspections of decay heat removal pump drain lines; one Severity Level V violation was identified for an inadequate drawing - four different welds had two redundant weld number identifiers; and a deviation was identified for the use of silicone sealants in the essential HVAC syste During this SALP period 11 LERS were attributed to this functional area. All of the LERs resulted from technical discrepancies such as the lack of channel isolation devices for two channels of the Reactor Protection System power summing amplifie The extended outage during this SALP period required increased technical manpower to support the varied modifications that were initiated and completed. Licensee technical staff was heavily supplemented by contract personnel to' support the workload. The supplemental contractor work force was reduced following completion of the modifications and upon plant restar Despite the heavy workload, no significant discrepancies were attributed to the adequacy of technical

staffin Similarly, effectiveness of training and qualifications of the technical staff appeared to be sufficient for the technical tasks that were being performe '

The licensee has been very responsive to NRC initiatives and has taken extensive corrective action to improve the quality of

~ engineering's activitie For example, a new design control ,

process utilizing a design change package (DCP) approach was ,

established. Although the licensee's corrective actions c

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appeared to be extensive and complete, no new engineering ,

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products were available for audit to determine the

~e effectiveness of the licensee's revised design control proces f A number of significant weaknesses were identified by both the NRC and licensee in past procurement practices utilized by the licensee in the purchase of safety-related part Of specific concern to the NRC was the practices used to upgrade commerical

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grade parts for use in safety-related' systems. The practices utilized in procurement'before July,'1987 were not adequat The licensee revised their procurement program to incorporate improved practices to prevent use of substandard parts in safety related-system Afterithe SALP period, the overpressurization of the AFW system event revealed >two weaknesses:in this area as related to this event: weak engineering oversight of maintenance activities and continued weakness _in procure.,en Conclusion Performance assessment - Category 2 Board Recommendation Management attention is needed to maintain a permanent, stable site engineering staff. Engineering efforts to complete the design basis records' project should continue, and a review of the effectiveness of the current design change process should be conducted once a representative sample is availabl Management attention is needed to enhance engineering oversight'

of maintenance activities in light of the AFW overpressure even G. Safety Assessment / Quality Verification Analysis During the SALP period, approximately 5739 hours0.0664 days 1.594 hours 0.00949 weeks 0.00218 months of direct inspection effort were applied in the area of safety i assessment / quality verification. Significant strengths noted during the SALP period included the implementation of a root cause analysis process and an aggressive approach by management to involve outside organizations, mainly INPO, in reviewing problem areas and providing recommended corrective actio However, several significant weaknesses were also noted in this functional area. These included the need for more aggressive use of the licensee's nonconforming condition reports (termed potential devia: ions from quality (PDQs) by SMUD), and a lack of progress in the completion of several post-restart commitments such as the creation of design base Over the lengthy evaluation period, many technical submittals were reviewed by the staff. These included technical specification change requests, NUREG-0737 items, exemption and j relief requests, responses to generic letters, licensee j activities related to resolution of safety issues, and responses to other regulatory initiatives. The plant was shut down for a significant portion of the evaluation period because of major problems at the plant that required full technical resolution prior to restart. Several of these issues involved a substantial interface with the NRC technical staff. Issues

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included addition of two emergency diesel generators, environmental qualification, fire protection, upgrades to emergency feedwater and instrument air systems, addition of hydrogen recombiners, establishment of a minimum meteorological monitoring program, system review and test program, reactor trip system reliability modification, and other Licensee submittals were generally found to be adequate and responsive to the subject matter. Contractor assistance and licensee management ~ oversight of the contractors appeared to be adequate as reflected by the submittal A conservative approach to fire protection issues has been evident. However, two supplemental changes were submitted up to a year after the original amendment submittal. This was indicative of a lack of attention to detai Specifically, all parts of the technical specifications that needed to be changed-were not considered. These changes resulted from oversights that failed to incorporate original plant areas in tables and charts. .This oversight appeared to be inconsistent with other submittals and was considered to be an isolated cas "

Inspection activities during the SALP petiod resulted in the

' identification of twelve enforcement items. Specific enforcement topics included two Severity Level IV violations for inadequate closure of nonconforming condition reports; three Severity Level IV violations for inadequate control of safety related material in the warehouse; one Severity Level IV violation for not performing a 10 CFR 50.59 evaluation for

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gagging two decay heat removal (DHR) system relief valves; one Severity Level IV violation for failure to perform cable routing inspections; one Severity Level IV violation for performance of liquid penetrant inspections of the spent fuel pool liner plate without appropriate acceptance criteria; one Severity Level IV violation for numerous housekeeping violations; and one Severity Level V violation for failing to retain radiographic records of degraded DHR line The two violations identified for failing to write nonconforming condition reports were indicative of a persistant I hesitancy on the part of licensee personnel to report nonconformances properly. A preference to use work requests for identifying and correcting nonconforming conditions was noted on several occasions. This demonstrated the reed for greater management emphasis to enaure nonconformances are properly identifie No LERs were specifically attributed to this area. However, weaknesses in the licensee's safety assessment and quality verification performance contributed to numerous LERs such as the cable routing problems, the AFW pump packing material discrepancy, and non-inclusion of containment isolation valves in the local leak rate test progra _

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' On 'several ' occasions during this SALP. period, the licensee

demonstrated a willingness to review its own programs to

" identify weaknesses. These reviews included EASTRP, INPO readiness for operation evaluation, Babcock and Wilcox transient assessment team evaluation, and independent assessments of the QA program. These reviews demonstrated p' increased willingness by the licensee to be self-critical and to learn from the expertise of outside organization The licensee's qu'ality verification program has shown improvement in various areas such as increased on-the-job QC inspectAon of maintenance and modifications, performance of QA surveillance and the implementation of a new nonconformin condition reporting progra In March, June and August of 1988, an enhanced operational NRC inspection team evaluated performance of operating crews and supporting organizations during the plant's power ascension from the extended shutdown period. The team observed that the Plant Review Committee (PRC) did not include department level managers. This weakness has since been corrected by inclusion of several department managers on the PRC. During an extended inspection of the Augmented System Review and Test Program (ASRTP) between December 1986 and February 1987, it appeared that QA and the Management Safety Review Committee (MSRC) did not actively review closeout of audit findings. Additionally QA audit and surveillance programs were not providing plant ;

management with adequate feedback of safety activitie Subsequent inspections by the inspection team confirmed that these problems had been correcte Staffing, training, and qualifications of the licensee's

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Nuclear Quality Department and Licensing Department appeared to

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be adequate during the SALP perio Toward the end of the SALP period, Region V inspections observed that the licensee was not completing post-restart commitments as scheduled. Management meetings between the licensee and NRC Region V, on November 14, 1988, and December 12, 1988, were held to review SMUD's commitments.for work to be accomplished post restart, including the various aspects of the EAP that remain to be completed. During the meetings, the licensee agreed that numerous near and long term items still remained to be completed, but reaffirmed its original commitment to promptly resolve the near term item . Conclusion Performance Assessment - Category 2 Board Recommendations The licensee should ensure the full use of the established system to identify and resolve nonconformances. The licensee i

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is encouraged to complete action on the near term commitments as previously agreed upo H. Startup Testing .

Analysis During the SALP period, significant inspection of startup testing was performed. Strengths were observed in the integrated system functional testing approach and in the development of a system status report which documented known past problems with specific plant systems. A significant strength observed was an. initiative by the licensee to develop and implement an inspection technique which was patterned after the NRC's Augmented System Review and Test !

l Program (ASRTP) inspections that identified. plant system performance or documentation problems. A weakness identified during the early portion of the SALP period was the initial planning and completeness of the test progra The NRC inspected licensee startup testing activities during hot functional testing and power ascension, with particular attention to the adequacy of special test procedures and clearance boundaries,-

where used. Evaluations were made of the adequacy and depth of the testing to determine whether the specific system under test was performing according to the design bases of that system. A specific strength was noted in the licensee's responsiveness to NRC identified problems in the Auxiliary Feedwater system and the onsite electrical distribution system during the ASRTP inspectio Licensee management actively participated in the generation of the test program purpose and scope. An extensive program was undertaken to identify and document known past problems with the thirty-three selected systems which were determined by the licensee to be important to safety. This high integrity system was used as an input source to the test program developmen Specific system functions and test requirements were soundly and thoroughly documented within a system status report (SSR) documen Technical and management reviews were conducted by the Plant Review Committee and were effective in identifying potential underlying test problem CFR 50.59 reviews were conducted prior to the conduct of each test with adequate documentation of the test's technical rationale. The program was conducted slowly, methodically, with high management attention to ensuring preparation for each testing evolutio A weakness was observed in the identification and documentation of conditions which were potentially detrimental to qualit Specifically, during a portion of the loss of offsite power testing, a deficiency was identified with an emergency diesel generator. The deficiency was not reported on the Jicensee's nonconformance reporting system. Significant management attention was subsequently devoted to the identified problem with both the specific hardware

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deficiency being resolved and the programmatic > problem being resolve No enforcement action was issued during the SALP period in this fun'tional e area. 'Two LER's'were submitted documenting a start of the emergency diesel generator (emergency safety features -

equipment start) and a reactor trip following a preplanned turbine generator trip. The licensee's corrective action for these LERs was-appropriat During the period of significant testing, staffing was adequate and commensurate with testing in process. Expertise of the testing staff was adequate for both the management of the program and conduct of testin Conclusion Performance Assessment - Category 1 Board Recommendations The licensee's effort in this functional area has been completed except for some minor testing at the 100% power plateau. Lessons learned-from this program should be evaluated for application to routine post maintenance testing in light of the auxiliary feedwater overpressurization even SUPPORTING DATA AND SUMMARIES A.. Enforcement Activity Three resident inspectors were assigned to Rancho Seco during the SALP assessment period. 100 inspections were conducted during this lengthy SALP period that encompassed the extended shutdown of Rancho Sec Significant team inspections included:

Two NRC headquarters Augmented Systems Review and Test Program Inspection Teams during 1986 and 1987

NRC headquarters Operational, Readiness Inspection Team in 1988

NRC headquarters Procurement Inspection Team in 1988

Regional Enhanced Operational Inspection Team in 1988 A total of 15, 27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months of direct inspection were performed during this SALP period. A summary of inspection activities is provided in Table 1 along with a summary of enforcement items from these inspections. A description of the enforcement items is provided in Table Confirmatory Action Letters

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One Confirmatory Action Letter (CAL) was issued ouring this assessment period. The letter confirmed licensee corrective action activities for the December 12, 1988 main feedwater pump trip even Shortly after the appraisal period ended, a CAL was also issued concerning the licensee's planned actions following the January 31, 1989 auxiliary feedwater system overpressurization even AEOD Events Analysis The Office for Analysis and Evaluation of Operational Data (AE00)

reviewed the licensee's events at Rancho Seco and prepared a report which is included as Attachment 1. AE00 reviewed the LERs and

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significant operating events for quality of reporting and

effectiveness of identified corrective actions.

L Detailed Description of Licensee Ac.tivities -

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Before the December 26, 1985 transient, a number of criteria (performance level monitoring, plant performance statistics, ,

~ and systematic assessments of licensee performance had

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indicated that Rancho Seco was below the industry norm for similar plant This, plus a 1984 evaluation by a consultant,

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moved the licensee's Board of Directors to take action to

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improve the performance level at Rancho Seco. Before these ,

actions were implemented, a number of undesirable operating >/

experiences, culminating in the event of December 26th, further i demonstrated the need for performance improvement. On the

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besis of the review of the December 26th event by the NRC and the utility, the licensee developed the " Rancho Seco Action Plan for Performance Improvement."

The initial portions of that plan were implemented as the Plant Performance and Management Improvement Program (PPMIP). The PPMIP was designed to systematically evaluate the plant, its systems'and their operation, and the management programs and organization necessary to support the safe and reliable operation of Rancho'Seco. The specific goals of the PP&MIP were to: (1) reduce the numoer of reactor trips, (2) reduce challenges to safety systems, (3) ensure that the plant remains within allowed ranges of rea,: tor coolant system pressures and temperatures immediately follwing a reactor trip, (4) ensure compliance with license requirements, (5) minimize the need for operator actions outside the control room, and (6) improve the reliability and availability of the plant. On the basis of anticipated benefits from the PP&MIP, the licensee established near-term performance goals for retur ning Rancho Seco to power operations. Those goals included plant availability exceeding 60%, a forced outage rate of less than 10%, and fewer than three reactor trips per yea During the extended shutdown period, the licensee developed a system review and test program (SRTP) the objective of which ,

was to demonstrate, before plant restart, that systems f i

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important to safety were capable of performing their required function. The SRTP was performed by the licensee to provide a comprehensive review and functional demonstration of 33-selected systems that were important to safe plant operatio The licensee's SRTP identified the functional decription for the 33 systems, design changes or modifications required for the systems, testing necessary to demonstrate functions important to safe plant operations, and final acceptance of the L ,

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On November 21, 1986, while attempting to fill, vent and pressurize the primary system, approximately 11 of 35 pressurizer heater. bundles were damaged when the heaters were energized without sufficient water covering them. Operators disregarded correct pressurizer level indications due to'

incorrect status information for properly functioning level y chcnnels. The operators relied on the remaining level ~ channel, which had a drained reference leg caused by loosely controlled troubleshooting of the level channels (operators being Onaware of that condition).

On March 15, 1988 and on March 21, 1988, while the plant was in hot standby, letdown system relief valves PSV-22031 (March 15,.

1988) and PSV-22024 (Harch 22,1988) lifted and resulted in a ,.

discharge of water from the letdown system to the Reactor 4

"

Building sump. The cause of both events was a steam / water transient involving isolation of letdown system piping and heat exchangers, flashing of water to steam in the low pressure area, and rapid expansion of the stea *

On August 6, 1988, as part of a planned Emergency Feedwater Initiation and Control System (EFIC) test, the reactor was manually tripped from 80 percent power and EFIC was manually ;

initiated. Both auxiliary feedwater (AFW) pumps started as designed. Approximately one hour after both AFW pumps started, smoke was observed in the vicinity of the outboard packing gland of AFW pump P318. P318 was immediately secured and the EFIC test was completed using the other AFW pump, P31 Subtequent licensee investigation determined that an identical AFW pump packing overheating event had previously occurred on July 7, 1988. The event was attributed to the installation of incorrectly sized vendor supplied packin *

On December 12, 1988, while conducting a plant startup, with the reactor at 12 percent power, and one of two Main Feedwater (FW) pumps inoperable, feedwater flow to the Once Through Steam Generators (OTSG) was reduced significantly by fluctuations of the steam pressure to the operating FW pump turbine. The reduced FW flow resulted in low OTSG 1evels reaching the EFIC system actuation setpoint and initiation of EFIC. Proper OTSG 1evels were reestablished by EFIC. The operators subsequently manually tripped the reactor with the belief that main feedwater was no longer available. The initial response of the plant to the reactor trip was normal. However, the licensee

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soon became concerned that the reactor coolant system was cooling down more than expected, due to continued steaming from the?"B" OTSG, and, by procedure isolated AFW flow to the "B" OTSG. This resulteduin emptying the 'B' OTSG for approximately 15 minutes. The licensee located an unexpected steam demand from the auxiliary steam supply to the fourth point FW heater,-

~

isolated the auxiliary steam to the fourth point FW heater, and

- refilled the "B" OTS Subsequent licensee analysis attributed the initiation of the event to operator actions while manually controlling.two different auxiliary s, team pressure reducing stations for the steam. supply to the' low pressure FW pump turbine *

On January 31, 1989, after the SALP period, while testing a )

newly installed governor for the. dual-driven auxiliary ,,

feedwater pump, the steam turbine for the pump oversped. The auxiliary feedwater system pressure was estimated'to have reached approximately 3800 psig for about three minutes. The system design pressure is 1325 psig. The NRC and licensee investi'/ation of this event revealed weaknesses in post maintenance testing, communications, maintenance program, use of generic information, and procuremen ,

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TABLE 1 INSPECTION ACTIVITIES AND ENFORCEMENT SUKHARY_,(Gi/01/86 - 11/30/88)

RANCHO SECO Inspections Conducted Enforcement Items Functional Inspection * Percent Severity Lovel**

Area *** Hours . of Effert I II III IV V D Plant Operations 4029 2 Radiological 664 Controls Maintenance / 2096 1 Surveillance Emergency Pre .8 - - -

3 - - Security 407 Engineering / :1902 1 Technical Support Safety Assessment / 5739 3 .

12 2 -

Quality Veri __ _ _ _ _ _ Totals 15427 10 * Allocations of inspection hours to each functional area are approximations based upon NRC form 766 dat ** Severity levels are in accordance with NRC Enforcement Policy (10 CFR Iart 2, Appendix C).

- - Inspections hours for the special functional area of startup testing were not distinguished in the NRC Form 766 data. Those hours were included in the other functional areas and predominant 1v were included in the hours for plant operation , ,

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-Table'.2' .

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IRancho Seco I

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Enforcement Items" .,[. i

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Report > F , , ., Severity ~ Functional;

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Level ;Area ..;

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'86.27 FAILURE'TO REPORT TS TABLE 3.16-1*

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. RADIOACTIVE GASEOUS' EFFLUENT VIOLATIO :i y< >

G 8G.27 FAILURE TO POST'AND CONTROL HI RAD AREA 'B -

+4- B

'OTSG LOWER CHANNEL HEA .30 FAILURE T.O ESTABLISH WRITTEN PROCEDURES'FOR' 4, =F, RADIOGRAPHIC INSPECTION i 86.30 FAILURE TO RETAIN RADIOGRAPHIC RECORDS OF ' JG -

DEGRADED DHR DRAIN LINE t86.35.INADE UATE ILLUMINATION INSIDE PROTECTED 4 E ARE .m 86.37:PROCEDURESLNOT PROVIDED FOR TESTING AND -4' B CALIBRATING RAD MONITORS R15701 AND 1570 .37 CLEARLY VISIBLE LABELS FOR LICENSED 5 B MATERIAL NOT PROVIDED IAW l

10CFR20. 2 03 (F) (2) .

86.38 PROCEDURE:FOR FUNCTIONAL TESTING OF 4 SNUBBERS-DID NOT PROVIDE APPROPRIATE ACCEPTANCE = CRITERIA ~FOR LOCK-UP VELOCITY -

VELOCITY-NOT CORRECTED.FOR TEMPERATURE AS RECOMMENDED BY THE VENDO l 87.01 FAILURE TO SPECIFY CONTENT-OF EMERGENCY 4 D PROCEDURE NO. PROCEDURE FOR CRIMPING TOOL CALIBRATION 4 C

AND CONTRO " '

87.01 CR/TSC HVAC HI AIR FLOW RATE DURING 4 C 12-26-05 EVEN .02 UNUSUAL EVENT NOT.. DECLARED FOR SECURITY 4 D ALERT AND ESCALATED SECURITY MEASURE ~

87.03' INADEQUATE DRAWING'- REDUNDANT KELD 5 F IDENTIFICATION NUMBERS ON F.?E2 DRAWING FOR '

DIFFERENT WELD .

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87.05 FAILURE-TO PERFORM TS REQUIRED SR-89 AND 90

4 B

, ANALYSI .05 INADEQUATE YELLOW SHIPPING LABELS FOR 4 B RADIOACTIVE MATERIAL SHIPMEN .06 STORAGE OF EXPIRED SHELF LIFE ITEMS NOT 4 G CONTROLLE .06 FAILURE TO NOTIFY NRC OF ACTUATION OF 4 A l l

EMERGENCY DIESEL GENERATOR (EDC}. FAILURE TO REPORT CR/TSC HVAC MALFUNCTIO . 87.06 NO PROCBDURE FOR GREEN TAGGING PARTS IN 4 G

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WAREHOUS , i 87.06 ABNORMAL TAG NOT WRITTEN FOR TEMPORARY 4 C i MODIFICATION ON "A" TRAIN NUCLEAR SERVICE ~ I RAW WATER SYSTEM.

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87.0C VOIDING OF NCR WITHOUT DETERMINING CAUSE OF 4 '

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.i /- EMERGENCY DIESEL GENERATOR NONCONFORMING CONDITIO ,

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87.06 NCR NOT WRITTEN FOR NON-ISOLABLE PIPE 4- G LEAKAG .06 FAILURE TO PROVIDE 10 CFR 50.73 REPORT FOR 4 A MISCELLANEOUS CONDITION ,07 FAILURE TO PROVIDE TWO PHYSICAL BARRIERS 4 E l FOR PROTECTION OF VITAL EQUIPMENT.

! !

! 87.07 FAILURE TO PROVIDE PROPER STORAGE 4 E PROTECTION FOR .

87.11 SURVEILLANCE PROCEDURES NOT REVISED TO D C REQUIRE DOCUMENTATION OF CALIBRATION DATA IAW COMMITMENT ON PREVIOUS VIOLATION RESPONS .13 CLEANLINESS PROCEDURE NOT FOLLOWED FOR A 5 C CLASS 1 WORK REQUES .13 LIQUID PENETRANT INSPECTION OF SPENT FUEL 4 G POOL LINER NOT CONTROLLED BY PROCEDURE WITH APPROPRIATE ACCEPTANCE CRITERIA.

( 87.13 REPLACEMENT FILTER FOR CBAST ISSUED AND 5 C INSTALLED WITHOUT SMUD ACCEPT TA .14 FAILURE TO WRITE NCR FOR BROKEN REACTOR 5 G COOLANT PUMP CAPSCREW.

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87.14 FAILURE TO COMPLY WITH COMMITTED CODES AND D F

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STANDARDS, USE OF SILICONE SEALANTS IN ESSENTIAL HVA .16 STROKE TIME NOT MEASURED FOR TESTING OF 4 C-TV-1,2,3,4. SIM-19,20,21,22 NOT FULL STROKE TESTED EVERY COLD SHUTDOW .19 LICENSEE FAILED TO CORRECT DEFICIENCIES 4 D a IDENTIFIED DURING 1986 HEALTH l PHYSICS / MEDICAL DRIL .20 HEAT TREATING OF VALVE YOKE WITHOUT 4 C PROCEDUR .20 FAILURE TO PROVIDE REQUIRED CABLE BEND 4 C RADIUS AND CABLE TRAY EDGE BUMPER .21 FAILURE TO PERFORM CABLE ROUTING 4 G INSPECTIONS DURING 1983-1985 TIME FRAM .22 MISCELLANEOUS VIOLATIONS OF'ALARA PROGRA B 87.26 RADIOACTIVE MATERIAL INSIDE RV HEAD STAND 4 B NOT SURVEYE .26 DAILY SOURCE CHECKS NOT PERFORMED WHEN 4 B R15020 WAS OPERABLE, RHUT CONTAINED KNOWN ACTIVITY AND RELEASES MADE VIA THIS PATHWA B'7.26 RADIOACTIVE MATERIAL INSIDE RV HEAD STAND 4 B NOT POSTED AS HIGH RAD ARE .37 FAILURE TO FOLLOW MAINTENANCE WORK REQUEST 4 C INSTRUCTION .37 FAILURE TO WRITE AN NCR FOR CR/TSC 4 s G REFRIGERATION UNIT NONCONFORMING CONDITION OF AS BUILT WIRIN .44 NCR CLOSURE BY QE PRIOR TO COMPLETION OF 4 G WORK. CORRECTIVE ACTION INCORPORATED INTO "

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l ECN WITHOUT PRIOR CLOSURE OF ECN;

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88.04 FAILURE TO REVALIDATE SECURITY BADGES EVERY D E 31 DAY .04 FAILURE TO DENY SITE ACCESS TO UNAUTHORIZED 4 E SITE PERSONNE .06~ EXPIRED SHELF LIFE ITEMS IN STOCK. REPEAT 4 G VIOLATION.

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88.12 CR/TSC HVAC ACTUATION NOT' REPORTED'WITHIN 4 'A :

6* FOUR HR j

'88.13, LICENSEE DID NOT MAINTAIN ON FILE RECORD B'- ,

FOR RADIOACTIVE MATERIAL SHIPMEN l

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88.13 LICENSEE DID NOT OBTAIN WRITTEN 5 B CERTIFICATION FOR EMERGENCY SHIPMENT OF- ,

RADIOACTIVE MATERIA .17 FAILURE TO SUBMIT. REQUIRED' ANNUAL EXPOSURE' '5 Bf l

< REPOR r 88.20 FAILURE TO POST, MONITOR,~ CONTROL HOT- c 3 ', B PARTICLE ZON " r l

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88.23 TEMPORARY MODIFICATION'FOR AFW PUMP P318 , '4 C OUTBOARD SEAL WAS NOT CONTROLLED AND DOCUMENTED IAW PROCEDURE.- #, t j 88.24 INDIVIDUAL DID'NOT WEAR TLD IAW RW :

41 lB

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88.25TWO PORTABLE DOSE RATE METERS EXCEEDED 5 'B

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CALIBRATION: FREQUENC ,

88.29 ALARMS FOR CERTAIN VITAL AREA DOORS NOT 4 E TESTE ;

88.31' Calibration interval-:for EFIC. pressure 4 C j transmitters changed _without proper j

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approvals required by procedur .32 DHR RELIEF VALVES GAGGED WITHOUT ADEQUATE 4 G )

10 CFR 50.59-REVIE i 88.33 NUMEROUS HOUSEKEEPING VIOLATIONS'- '4 G .l a UNSECURED LEAD SHIELDING, UNSECURED ROLLER CARTS,~ LADDER TIED' TO SAFETY RELATED M CONDUI i 88.33 PDQ FOR FEEDWATER OXYGEN CONCENTRATION NOT 4 G' l

' DELIVERED TO OPERATIONS TECHNICAL ADVISOR-WITHIN 4 HOURS AS REQUIRED BY PROCEDURE.

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l TABLE 3

SYNOPSIS OF RANCHO SECO LICENSEE EVENT REPORTS (LERs)

l SALP Cause Code * l Functional Area A B C D E X Totals l Plant Operations 11 8 3 3 10 1 36 Radiological 11 4 - 4 1 2 22 Controls Maintenance / 6 4 -

9 1 -

Surveillance . Emergency Pre Security 2 -

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3 Engineering /

Technical Support 5 4 -

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11 Safety Assessment /

Quality Verification - - - - - - -

Totals 35 20 4 18 12 3 92

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The above data are based upon LERs 86-11 through 88-1 * Cause Code A - Personnel Error '

B - Design, Manufacturing or Installation Error C - External Cause D - Defective Procedures E - Component Failure X - Other

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Attachment 1

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AEOD Input to SALP Review for Rancho Seco ,

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i LER Revie '

' ' Duringithe assessment period, 84 Licensee Event Reports (LERs) were submitted to the NR a These reports, reviewed by AE0D, consisted of LERs 86-14 through

. 88-1 t . .

Significant Events Utilizing AEOD's screening process, the following 18 LERs were categorized as y safety significant:

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~86-14 Decay heat removal-(DHR) system train B rendered inoperable due to a-

.leakihg weld.on the pump casing drain line, while theit rain A

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emergency diesel generator was out-of-servic '

.- 86-16' Loss of DHR capability'for a period of3 1 minutes duringicold shutdown as' result of inadvertent closure of the DHR' system suction dropline isolation valve. Electrical arcisg from I&C technician troubleshooting activitie9 Caused the valve closur ,

86-25' "

Spent fuel. pool liner leakage while containing 316 spent fuel assemblies. Contaminated water seeped through<the concrete walls of-the fue11 storage building to an uncontrolled storm drain. About 275 gallons were released offsite, creating ansestimated whole body dose of,0.14 mrem.' r

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87-02 Fire ~ protection deficiency involving potential loss of alternate

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shutdown capability. A control room fire could cause an electrical short in the protective circuitry of a diesel generator's output breaker, causing the breaker to trip. A 1oss of offsite power is

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U assume'd to occur at the same time as.the control room fir Problems with safety related motor-operated valves identifed in response to IE Bulletin No. 85-03. Problems included over' thrust'

conditions, incorrect brake voltage ratings, undersized power-cables, lack of stem nut staking, valve internals damage, unqualified operator grease, and incorrect pickup / dropout voltage Inadequate automatic sequencing of the high pressure injection pumps onto the emergency diesel generator bus,-due to the pump lube oil pressure bypass circuits defeating a three second time dela Fire protection inadequacy whereby the reactor coolant system high l point vent valves were susceptible to opening from electrical

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shorts.

L 87-11 Safety related snubbers failed functional testing after temperature I considerations were factored into lock-up velocity and bleed rated acceptance criteri !

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l l 87-15 Fire protection carbon dioxide deluge system left deactivated l without appropriate compensatory measures.

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87-23

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Inadequate electrical isolation on the reactor protection system total nuclear power channels. Channel isolation devices required by IEEE-279 and General Design Criterion 20 were not provide Inadequate surveillance testing of unsupervised control room fire alarm annunication circuits. Required monthly testing was not performed since 197 High pressure injection (HPI) pump mini-flow recirculation lines were not seismically supported since original plant construction due to improper classification. Failure of the lines coincident with a LOCA would render HPI capability indeterminat Blockage of bearing cooling water system piping to both reactor buf1 ding spray pumps due to foulin Non-seismic level switches installed on nuclear service water pumps, which could prevent the pumps from starting on a safety features actuation signal (SFAS).

87-42 Failure of electrical connectors due to residual coating from cleaning solutions. Systems affected included the reactor protection system, integrated control system, SFAS, and non-nuclear instrumentatio Loss of nuclear services electric building essential heating, ventilation and air conditioning system, due to inadequately designed isolation dampers between Seismic I and Seismic II duct CFR 21 report regarding a manufacturing defect in undervoltage devices, causing improper operation of the control rod drive trip j breaker Auxiliary feedwater pump inoperability due to incorrectly sized vendor supplied packing in packing glan Other Events AE0D's review also identified the following events,.while not necessarily being individually categorized as safety significant, collectively represent adverse trends in plant performance worthy of additional plant management attentio Inadequate fire protection compensatory measures:

LER 86-18 Disabled smoke detectors in the reactor building with-out compensatory measures (fire watch) due to licensed operator erro LER 86-31 Hourly instead of continuous fire watch in 480 volt switchgear room due to licensed operator erro _ _ _ _ _ _ _ . _ _ . _ _ i

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LER 86-32 Missed fire watch in-the east nuclear services battery room due to nonlicensed personnel error. Additionally, LER 86-18 regarding missed compensatory measures, was not referenced in this LER.

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LER 87-01 Hourly rather than continuous fire watches on 1/17 f

and 1/27/87, due to licensed operator error. No reference to LER 86-18 include LER 87-03 Continuous fire watches not posted on_ 12/27/86, 12/29/86, 12/30/86, 1/2/87, 1/3/87, 1/5/87, and 1/20/8 LER 87-04 Abandoned continuous fire watch post in nuclear services electrical building (NSEB) due to nonlicensed personnel error. No reference to the above 1987 similar LERs was provide LER 87-15 Carbon dioxide fire protection systems were deactivated without establishing fire watches on 17 occasions in 1/87 and 2/87 due to nonlicensed personnel erro LER 87-19 Continuous fire watch posting not performed in the NSEB due to licensed operator erro LER 87-33 11 missed hourly fire watches in 77 inspection zones due to administrative problems. Previous LERs on this subject not referenced except for 87-0 I LER 87-35 Continuous fire watch ar fire alarm panel abandoned due to nonlicensed operator erro LER 88-09 Missed hourly' fire watches on NSEB fire barrier penetrations on 7/21/87 and 7/25/87 due to licensed operator erro LER 88-10 Missed fire watches on 7/14, 7/19, 7/25, 7/27, 7/28, and 8/10/88 due to nonlicensed personnel error, f Effluent monitoring deficiencies:

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LER 86-19 Missed auxiliary building noble gas grab sample due to nonlicensed personnel erro <.

LER 86-22 Missed continuous sampling of the auxiliary building !

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gas due to procedural inadequacie i

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LER 86-27 Lost data from reactor building duct particulate air sample filter due to nonlicensed personnel erro ,

LER 86-29 Sample valves open on auxiliary building stack exhaust sample line, rendering previous samples i inaccurat _-_______m

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LER 86-33 Failure of a continuous noble gas monitor on the reactor building exhaust duct on two occasions, due to loss of electrical power when non-safety related loads were applied to a safety related power suppl i LER 87-40 Required surveillance (daily source check) not performed from 8/84 to 8/87 on regenerant hold-up tank discharge monitor during periods of known tank activity due to procedural erro LER 87-43 Unmonitored releases from the auxiliary building during effluent monitor and ventilation system testing due to nonlicensed personnel erro 'LER 87-47 Missed continuous sampling of reactor building purge effluent on two occasions due to licensed operator erro LER 88-01 Reactor building effluent particulate filter lost prior to gross alpha activity analysis due to unknown cause Causes Root causes: associated with the 84 LERs, categorized on a yearly basis, were:

1986 1987 1988 TOTAL Licensed operator errors 3 7 3 13 Other personnel errors 'S 10 3 18 Maintenance errors 0 4 0 4 Design / installation / fabrication 6 13 2 21 Administrative control problems 15 12 2 19 Random equipmen't failures 1 1 2 4 Licensee Unidentified 0 1 4 5 Of the 19 administrative control problems identified,14 were ast;ociated with inadequate procedures, and 3 were related to programmatic deficiencie The licensee did not identify root causes on five LERs. . Additionally, the supplemental report specified in'LER 88-06 (event date 4/14/88) Las not yet been receive LER Quality LER quality has improved since the end of 1986, when the utility adopted a new LER format. LERs submitted adequately described the major aspects of each event, including identifying component or system failures that contributed to the event. .The reports were well written, easy to understand, and typically complete except for those with unidentified root causes. Corrective actions taken or planned to prevent recurrence were generally specified. However, in writing the LER text, the use of the word " operator" should be clarified to indicate nonlicensed or licensed operator, as requird by 10 CFR 50.73(b)(2)(ii) (J)(2)(iv) .

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Preliminary Notifications AEOD's review of preliminary notifications issued by Region V concluded that no additional LERs were required of the license ,

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v t e Inspection Report - Rancho Seco - 1988039
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \|
1988 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 7(0) 8(0) 9(0) 11(0) 12(0) 13(0) 14(0) 15(0) 16(0) 17(0) 19(0) 20(0) 21(0) 22(0) 23(0) 24(0) 25(0) 26(0) 27(0) 30(0) 32(0) 33(0) 35(0) 39(0) 40(0) 41(0) 42(0) Security Operator Exams Emergency Planning Other

IR 05000312/1988039

Text

REGION V

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