ML19316A868
| ML19316A868 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 05/02/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| References | |
| NUDOCS 8005280004 | |
| Download: ML19316A868 (42) | |
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1 BEFORE THE UNITED STATES DEPARTMENT OF ENERGY 2
NUCLEAR REGULATORY COMMISSION 3
THE OFFICE OF INSPECTION AND ENFORCEMENT 4
5
X 6
Meeting to Discuss Correction of Violation at Rancho Seco 7
--_______________x 9
Room W-ll40 10 Sacramento Area Office Federal Building 11 2800 Cottage Way Sacramento, California 12 Friday, May 2, 1980 13 14 The above-entitled matter came o.. for public 15 hearing pursuant to notice at 1:05 p.m.
16 BEFORE:
17 ROBTRT H. ENGELKEN, Chairman 18' R!. CHARD C.
DE YOUNG 19 BOBBY H. FAUKENBERRY 20 APPEARANCES:
21 DAVID KAPLAN, Legal Counsel WILLIAM WALBRIDGE 22 JOHN MATTIMOE RON RODRIGUEZ
'23 Representing Sacramento Municipal Utility District 24 25 O
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INDEX 2
Pace
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3 Proceedings 3
4 Opening Statement by Chairman Engelken 3
5 Description of Violations by Harvey Canter, 4
Resident Inspector 6
Description of Corrective Measures by Company, 7
William Walbridge, SMUD General Manager 12 Ron Rodriguez, Manager Nuclear Operations 13 8
Staff Questions and Comments 20 9
Public Session 41 10 Adjournment 41 11 Certificate of Reporter 42 12 13
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14 15 16 17 18 19 20 21 l
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24 25 l
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I EESSEEE1EEE 2
CHAIRMAN ENGELKEN:
Ladies and gentlemen, I'd like 3
to call the meeting to order, please.
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4 I'll begin with an introduction of the principal 5
NRC staff members at the table.
On my immediate left is 6
Mr. Richard C. DeYoung, the deputy director, Office of 7
Inspection and Enforcement from our headquarters in 8
To his left if Harvey Canter, the resident 9
inspector of the Rancho Seco nuclear power plant.
To my 10 right, Bobby Faukenberry, chief of the operations section 11 in our regional office in Walnut Creek.
12 I'm Robert Engelken.
I am the director of the 13 Region V office in Walnut Creek.
14 The purpose of the meeting today is to discuss 15 corrective measures taken at the Rancho Seco nuclear 16 generating station to correct violations that took place 17 at the plant in the months of December and January.
There 18 was an order issued on April the 4th in response to the 19 violations.
20 The order calls for modification of the Rancho 21 Seco license to require implementation of new procedures 22 for verifying the alignment of valves and equipment 23 operability following modification and maintenance.
It also 24 requires the. revision of existing administrative procedures 25 to assure that operating procedures updated and maintained
4 1
to reflect changes in safety-related systems.
2 The civil penalty was in the amount of $25,000.
3 Within the last week or two there was a response from the 4
Sacramento Municipal Utility District and they acknowledged 5
the vio., cions, and payment of tue fine was made.
6 The civil penalty action resulted from three 7
violations of technical specifications of the operating 8
license of the plant.
Two involved misalignment of valving 9
in emergency cooling systems and one involved the lack of 10 Power to a valve, an electrically controlled operated valve, 11 in one of the emergency core cooling systems.
12 The meeting this afternoon will consist of two 13 separate sessions.
The first session will consist of a 14 description of the violations by the resident inspector, 15 Harvey Canter, and then following that, the company will 16 be asked to respond to describe corrective actions.
17 The second session after that beginning at three 18 o' clock will consist of a session open to the public for 19 their questions if any questions are forthcoming.
20 Unless there are questions at this point, we will 21 proceed with a description of the violations by the resident 22 inspector, Harvey Canter.
Harvey?
23 MR. CANTER:
Thank you, Bob.
24 I'll attempt to speak up without the use of a 25 microphone so if you have any problems,please speak up and
e 5
1 I will try to raise my voice.
2 One of the reasons we called this meeting is to 3
allow the public and the press a chance to understand what 4
happened at Rancho Seco, and if you do have any questions, 5
please do speak up.
6 First let me describe, by way of background, a 7
little bit of the basics of the nuclear power plant at 8
Rancho Seco basically, and that's what we have shown here 9
in the green area of this diagram.
The reactor containment 10 building is 225 feet tall, three feet thick, represented 11 right here, reactor vessel in the center of this structure, 12 a hot leg.
13 Hot pressurized water goes down to the reactor 14 through the candy cane section that falls down through 15 steam generator two.
There is another steam generator, 16 another hot leg, and cold leg.
All this stuff I am 17 explaining here as part of the primary system is repeated 18 in two places.
For the sake of brevity, I will show one 19 frame.
20 This hot pressurized water falls through the. steam 21 generator tubes and is now cooled.
22 We have what are called cold legs.
This cold 23 water goes through the reactor coolant pumps and is injected' 24 back into the reactor where it regains heat.
That's 25 basically the primary reactor cooling system.
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1 There is a secondary system.
The secondary reacto:
2 cooling system -- there is a secondary system.
Excuse me.
3 Steam is generated in the rhell side of this ste'am 4
generator, comes off the top, falls down into the turbine, 5
provides the motor force for this turbine, causes the turbine 6
to rotate, causes electric power to be generated.
7 That steam is turned into water in the condenser s
and fed back into the steam generator through the feed pump.
9 We have a feed pump into the steam generator on the other 10 side.
It A tertiary system, if you will, a third system 12 which causes the steam in the turbine to become water is what's represented here.
These cooling towers, 425 feet 14 tall -- I think a lot of people have seen these before --
15 take water out of the cooling tower into the shell side of 16 the condenser and actually causes the steam to turn into 17 water.
18 Then the tertiary water is fed back to the cooling 19 tower and that heat is given up in the cooling tower. And 20 you see a plume coming out of these towers.
That's this 21 water giving up its heat.
This basically, then, is a 22 standard type power plant -- the primary system, secondary 23 system, and a' tertiary system.
24 Are there any questions on that?
25 (There was no response.)
7 1
Now, let's discuss this yellow portion of the 2
diagram.
There are several emergency core cooling systems 3
and pressurized boiling water reactors.
There is something 4
called a core flood tank at B & W plants which supplies water 5
to the primary cooling system in case of a major break and 6
a low pressure injection system which also does the same 7
thing but at a lower pressure.
8 What we have depicted here is a high pressure 1
9 system and it's in this system that the three errors, the 10 three problems, existed that caused the civil penalty.
11 First, I'd like to discuss a little bit of the 12 formal operation, if you will, of a few of the components.
13 The make-up pump takes water out of the primary system, 1
14 which is normal operation, through the make-up tank, and 15 its valve injects water back into the reactor cooling system 16 through a loop that just provides demineralization, cleaning 17 up of the primary cooling water.
That's normal operation.
1 18 That's always occurring and that's what I have depicted 19 here.
20 During the safety injection, due to an emergency ~
21 core cooling system initiation because of a line break, this 22 valve right here will shut therefore isolating this path 23 into the reactor cooling system.
During safety injection 24 system function, normal function for this high pressure 25 injection, a borated water storage tank which consists of i
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1 highly borated primary reactor coolant and supplies water to 2
this section of the high pressure injection pumps.
3 These four valves right here open up when there u
4 is a line break and this highly borated water is injected 5
through these power valves into the primary cooling system 6
keeping water on the core, keeping the core cool.
7 In 1978 something that has not been analyzed 8
before came to light and this dealt with a small break, a 9
loss of power to the operative side.
In other words, if 10 there was a break in the reactor coolant system right here 11 and a loss of power on the opposite side, this pump and 12 these valves would not operate.
There was a potential there 13 for not having enough coolant to the reactor cooling system; 14 consequently, we issued an order to the Sacramento 15 Municipal Utility District to operate the plant with this 16 valve shut, this valve open, and these valves open.
17 In case of a break, let's say in this line right 18 here and loss of power to these valves and this pump here, 19 this high pressure injection pump would inject half of its 20 water into the floor of the re' actor containment through the 21 break,-the other half into a loop which eventually went to 12 the reactor vessel.
23 That would not supply enough cooling to the 24 primary cooling system o that the primary cooling system 25 would start heating up.
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1 So the licensee had approximately 20 minutes to 2
open this valve manually.
They would send an operator down 3
to the location of this valve, open this valve, this valve, 4
and this valve there by supplying a source of water into 5
the other loop.
This was enough cooling to keep the system j
6 cool until the problems could be handled.
7 It's exactly this -- being the first problem 8
labeled up here as problem A.
That procedure is called for 9
to make this make-up pump operate as a high pressure injec-10 tion pump and the reason for that is massive fire protection 11 modifications had to be performed at the power plant.
And 12 that required rerunning cables such that this pump had to l
13 be taken out of service.
14 The plant was designed to allow this pump, the 15 make-up pump to operate as a high pressure injection pump.
16 When you line up this pump, there are auxiliary coolers 17 and air coolers that have to also be lined up so that the i
18 problem was in making this make-up pump a high pressure j
19 injection pump.
20 The procedures were not followed and some errors 21 were made.
The first one was this valve right here. -An 22 operator was told by the shift supervisor to line up the 23 system to make the make-up pump the high pressure injection 24 pump.
Instead of leaving this one open and this shut, both
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25 were left shut.
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10 1
The problem with that, if there were a small 2
break and attendant loss of power, the operators would not 3
be able to take the ten minutes necessary to open both of
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4 these valves and these valves.
5 The plant has run tests to show that in about 6
four and a half minutes they could open this valve and 7
these valves, and it's possible that even with both of these a
valves shut they still could open these valves within ten 9
minutes.
The problem being that in the heat of battle it 10 may be that the. operators could have missed opening both 11 of these valves.
12 They may have just gone to the one they though.
13 would be shut and opened it.
So that's problem A.
This 14 valve was closed when it should have been opened.
15 The procedure was not followed in that case.
16 The procedure calls for this valve to be opened.
17 Problem B deals with the procedure that called 18 for putting the make-up pump in as the high pressure 19 injection pump, did not call for four valves in the nuclear 20 raw water service system to be opened.
In the past, prior 21 to 1978 and the initiation of these fire protection modifica-22 tions, these valves were always open but due to the fire 23 Protection modifications, the valves were placed in a shut TE 24 position unless you were operating the make-up pump as a 25 high pressure injection pump.
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1 The procedure that lined this system up did not 2
have those four valves in place as being lined up properly, 3
so the operators followed their procedures and did not shut 4
those valves because they weren't on the procedure.
5 The final problem dealt with this valve here.
6 (Indicating.)
During a break in the primary cooling system, 7
this valve normally gets a signal, an electrical signal, to a
shut allowing, again, the borated water to come into the 9
suction of these high pressure injection pumps and initiate 10 cooling.
11 The procedure called for this valve when, in 12 turning the make-up pump to a make-up pump and putting the 13 high pressure injection pump back into service, the procedure
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14 called for this valve to be shifted around.
The operator 15 did not supply power to the safety feature of this valve.
16 This valve could have been shut from the control 17 room had an operator realized there was a problem.
18 But, again, in the heat.f battle we don't know 19 what the operator would have done.
This valve would not 20 have received an automatic signal to shut.
21 That, then, summarizes the three problems that 12 initiated the civil penalty.
23 Are there any questions?
24 (There was no response.)
25 MR. CANTER:
Thank you.
12 1
CHAIRMAN ENGELKEN:
Mr. Walbridge, at this point 2
it's appropriate for you to explain the corrective measures 3
taken both in the response to the immediate actions taken 4
to correct those problems and then the more long-term 5
corrective measures taken with respect to the changing of 6
procedures indicated as necessary.
7 MR. WALBRIDGE :
Thank you, Mr. Engelken.
8 I am William Walbridge, general-manager of the 9
Sacramento Municipal Utility District or SMUD as we are more 10 generally know, at least in this area.
11 By letter of April 23rd, 1980, we responded to 32 the Nuclear Regulatory Commission's Notice of Violation, 13 which is the subject of this public hearing.
In that letter 14 we acknowledged the three items of noncompliance, which Mr.
15 Canter has just outlined, and we set forth the immediate 16 corrective actions taken to put us into compliance.
17 In that letter we also set forth the corrective 18 actions which have been taken to prevent similar items of 19 noncompliance from occur:;ing in the future.
20 I'd like to emphasize SMUD's commitment at all 21 levels -- from our e lected board of directors through manage-12 ment, supervision, and the operational personnel at Rancho 23 Seco -- to the safe operation of the Rancho Seco nuclear 24 plant.
As a consumer-owned, customer-owned utility, we do 25 feel that we have an added responsibility to our customers i
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and the public to provide them with a safe source of 2
electrical energy.
s 3
I would also like the emphasize that it was SMUD's 4
own management controls that discovered the items of non-5 compliance, that SMUD reported, promptly reported, these 6
noncompliance items to the NRC and to the public.
We took 7
immediate action to return to compliance.
8 Additionally, further actions were initiated to 9
prevent similar occurrences from happening in the future.
10 All of these actions were taken prior to the ij issuance of the Notice of Violation by the NRC.
12 At this time, I'd like to call on Mr. Ron Rodriguez, 13 who is the manager of nuclear operations for SMUD, who will i
l 14 now go over in detail the specific corrective actions which 15 we implemented at Rancho Seco.
16 MR. RODRIGUEZ:
I'm Ron Rodriguez, the manager 17 of the nuclear operations for the Sacramento Municipal 13 Utility District.
19 With reference to problem A, the noncompliance 20 occurred because operating people failed to follow procedures 21 for recording and processing for review the deviation from 22 an approved operating procedure.
The following corrective 23 steps have been taken with regard to that:
24 The operation supervisor responsible for the 25 operating people at Rancho Seco has reviewed this occurrence i
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i with all shift licensed operators as part c+f a training 2
program emphasizing the importance of a proper valve 3
alignment.
4 The training program also emphasized the importancq 5
of the district's existing requirement that temporary 6
procedure change request be completed when any change to an 7
operating procedure is deemed necessary and performed.
8 In addition, administrative procedure AP2 for 9
review approval and maintenance of procedr.res has been 10 revised to require both licensed operaters approving a gj temporary change be individually repsonsible for initiating 12 a temporary ~ change form for submission to the operation 33 -
supervisor and the Plant Review Committee for their review 14 and approval.
15' Additionally, administrative AP23 entitled 16
" Control Room Watch Standing" has been revised to require 17 the off going shift to advise the on-coming shift of any is valve manipulations on the safety-related system and have 19 any temporary changes performed by that shift.
20 In addition, a log check-off sheet of each safety 21 system.is required prior to stift turnover to assure that 22 each system has been reviewed by the on-coming shift.
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23 The corrective steps that I have described were jE 24 completed prior to the 17th of April and we believe that 25 this will bring us into full compliance and will prevent
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similar items of noncompliance.
2 With regard to problem B, this noncompliance 3
occurred because the revision to one procedure dealing with 4
locked valves was not reflected.:in the corresponding 5
operating procedure used to place the make-up pump into.s 6
safety features system. position.
The following corrective 7
steps have been taken here:
8 The operating procedure involved, AP15 entitled 9
"Make-up Purification and Letdown System," was revissd to 10 a degree with the revised valve configuration as specified 3;
in the locked valve procedure.
12 In addition, the Plant Review Committee charter 13 has been revised to require the committee, when reviewing 14 procedure changes, to consider any other procedures that 15 may be affected by that change.
Such considerations are 16 to be' documented in the Plant Review Committee minutes of 17 the meeting involved.
18 Administrative Procedure AP2 again has been changed 19 to reflect these requirements as well.
When a procedure 20 change is reviewed, the senior' person responsible for the 21 procedure will be responsible for determining what other 12 procedures are affected and the chairman of the Plant Review 23 Committee will specify a date upon which any additional 24 changes identified must be submitted to the committee.
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25 The corrective steps that I have described for 6<
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problem B were also completed prior to April 17th and we 2
believe will prevent similar items of noncompliance.
3 With regard to problem C, this item of noncompliance 4
occurred because one of the steps in an approved operating 5
procedure was not completed.
The immediate corrective 6
action was to properly position the breakers involved in 7
this error to supply power to the valve.
8 The following additional corrective action has 9
also be,en taken:
A review, again, of the operating procedure 10 A15 was made and the procedure was found to be clear and 11 correct.
A district directive was issued by the nuclear 12 plant superintendent on April 14, 1980, effective on that 13-date making it mandatory that when any safety-related system 14 or component, as defined in chapter six of the final safety 15-analysis report is removed from or.placed into service, the 16 operator performing the work will verify the valving and 17 equipment lineups.
18 Moreover, as an additional precaution, the 19 district has changed its procedure to require dual verifica-20 tion for safety-related systems and components.
The list 21 of safety-related systems had previously included the high 22 pressure injection system, the low pressure injection system, 23 the core cooling system, raactor building, atmospheric cooling
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24 system, reactor isolation system, the reactor building 25 isolation system, and the reactor building spray system, the
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nuclear service cooling water system, the nuclear service 2
raw water system, the diesel generator, and the auxiliary 3
feed water systems have now been added to this safety-
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4 related list.
5 In addition, the instrumentation associated with 6
the reactor protective system and safety features system 7
has been included in the safety-related list so that 8
independent verification of. valving lineups and operability 9
is now required when these systems are removed from or placed 10 into service.
11 The new directive defines " operable" within the 12 context of technical sections and serves notice upon all 33 personnel that the limiting conditions for operation and h-i4 surveillance standards.
15' Technical specifications, chapters three and four, 16 must be satisfied when systems are removed from or returned 17 to service.
Specifically, the procedures that require dual 13 verification include high pressure injection in procedure A15, 19 low pressure injection in procedure A8, core flooding in 20 procedure A4, reactor building' emergency cooling in 21 procedure A14, reactor building isolation procedure A70, and 22 surveillance procedure 214.03, which is the locked valve one, 23 reactor building spray in procedure A7, nuclear raw water
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24 in procedure A25, nuclear cooling water in procedure A24, 25 and diesel generators in procedure A31.
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Each lineup includes dual sign-off sections for 2
the instrument control division to verify instrumentation 3
required for the safety features operation wnich has been 4
placed in service.
Completed copies of these lineups will S
be kept in the plant start up folder as a record of proper 6
systems configuration.
7 The above procedures, which include the dual 8
verification of valve breaker instrument lineups were 9
reviewed by the-Plant Review Committee and approved by 10 April 19th.
A special order explaining the directive and 11 the procedure revisions was issued on April 10th, 1980 to 12 all licensed operators.
13 Training was conducted by the operation supervisor 14 on the procedure changes, and the order was explained to all 15 licensed operators on each shift.
16 In addition to those procedure changes which have 17 been completed, the following additional steps will be 18 taken:
19 Surveillance proceudres will be reviewed and 20 revised to include independent verification of valve breakers 21 and instruments when any safety-related system or component 12 is removed from service for testing.
23 The surveillance procedures whien require 24 modification are arranged in three categories -- monthly, 25 quarterly, and refueling interval.
The necessary modifica-
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tions to incorporate the dual verification requirement will 2
be completed prior to the scheduled performance date for all
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3 monthly and quarterly procedures.
4 The refueling interval procedures, although not 5
scheduled for performance until 1981, will be revised by 6
October 31st, 1980.
The corrective action which I have set 7
forth above will be completed prior to performing these 8
surveillance procedures.
9 Completion of this effort will assure us that 10 repeat problems of the nature that we had in January and --
December and January of this year will be limited -- a 12 repeat of those problems will not be forthcoming.
13 MR. WALBRIDGE:
That completes our reply.
We w.'l 14 be happy to respond to any questions you may have.
15 CHAIRMAN ENGELKEN:
I have a question of Harvey 16 Canter.
17 Harvey, I recognize that the plant.has been shut 18 down since these corrective actions were taken but have 19 you had the opportunity to review the corrective measures 20 to see or to verify the proper ~ implementation of those 21 corrective actions that have been taken to this date?
22 MR. CANTER:
Yes, I have done that and,.as stated 23 in their response, they have taken the corrective actions.
24 CHAIRMAN ENGELKEN:
Thank you.
25 Are there any other questions?
20 1
I have a few questions on page one 2
of your letter.
First, I'm surprised that it took a week 3
for our letter to get out here to you.
I'm not really 4
surprised.
It's disturbing.
5 Near the bottom of the page when you talk about 6
the training program, you also emphasize the importance of 7
the existing requirement that a temporary procedure change 8
request be completed when any change to an operating 9
procedure is performed.
10 It seems that that may be reversed.
You would 11 expect a request to be completed before you make the change.
12 Is that what you meant?
Before you make the change you are 13 going to put in a request?
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14 This says when you make the change.
15 MR. WALBRIDGE:
I think what we're referring to 16 here is the request for total review and finalization of 17 the procedure change.
18 MR. RODRIGUEZ:
Our administrative procedures 19 provide for two members of the management to make a 20 temporary change to a procedure, that does not change the 21 intent of that procedure, and Unplement that change prior 12 to going through the PRC approval.
PRC?
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24 MR. RODRIGUEZ:
Is the Plant Review Committee.
25 And the plant supervisor.
When that does occur, there was
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a maximum of seven days to complete that approval change.
2 For those procedure changes which clearly change 3
the intent of a procedure, then what you said earlier, the 4
change must be approved prior to implementation.
Right.
6 On the following -- I think you answered the 7
question at the top.
How long does this procedure take for 8
the review and approval by the operating supervisor and 9
plant review committee?
Is that a week?
10 MR. RODRIGUE2 :
For the complete carry through it through the plant review committee and the plant supervisor 12 is seven days maximum.
It does not necessarily take that 13-long.
Also at the top-you refer to the IS' changing of the shifts and they will check the valve and 16 the changes that were made to increasing the shift.
Do they 17 do this as a shift or one individual on each shift?
18 MR. RIDRIGUEZ :
The requirement is that the shift 19 supervisor alert the on-coming shift supervisor of changes 20 to valve positions on that locked valve list which included 21 a related safety valve.
So it could be two supervisors
~23 together or individually?
24 MR. RODRIGUEZ:
That's correct.
At the bottom of the page, again, l
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on item B, I make the same questirn.
When a change is 2
reviewed, the senior person responsible for the procedure 3
will be responsible for the determination of which other
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4 procedures are affected, and the chairman will specify a 5
date upon which the additional changes must be submitted 6
to the committee.
7 Is there a date required for when the committee 3
must complete its review?
Is that the same time span, one 9
week?
10 MR. RODRIGUEZ:
In the temporary change area, ij that's one week.
Most of the changes that are reviewed by 12 the plant review committee are changes that occur prior to i3 their implementation and there is no specific time, just 14 that you need the change approved before you can use the 15 procedure.
On page three, the large paragraph, 17 dual verification.
How is that defined?
13 MR. RODRIGUEZ:
Dual verification?
Well, I'll 19 tell you how it's implemented and I would expect that would 20 answer your definition.
21 An operator with a list of valves will go out and 22 conduct a valve lineup checking off the proper position of gg the valve.and' initialing opposite its position verification i
Ih 24 that it's in the required position.
That change will come 25 back to the control room, be reviewed and signed off by the j
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shift supervisor or another senior control room operator.
2 And another operator will take another copy of the 3
same procedure and then go out and do the same thing.
It will not be the same operator?
5 MR. RODRIGUEZ:
It's not the same operator.
You added some new compliance 7
systems to the list of what we call the safety-related a
system.
Why did you do that?
9 MR. RODRIGUEZ:
Those systems -- nuclear service 10 cooling water, nuclear service raw water, support the 11 emergency core cooling systems.
The systems in the descrip-12 tion of the FASR are in there but they were not in there as 13 safety-related.
14 The diesel generator system, likewise under 15 safety features actualization condition and loss of offset 16 power, come into play and we included those since it is a 17 safety features actuated system.
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18 Auxillary feed water systems were included in 19 there.
We had already had a requirbment for dual verifica-20 tion.
What about the hydrogen control 22 system?
Is that in there?
'23 MR. RODRIGUEZ :
No, it isn't.
Why is that?
25 MR. RODRIGUEZ:
It is not a safety-related system.
24 1
Don't you think it might be one 2
of those systems that you might want to add in that list?
i 3
MR. RODRIGUEZ:
No.
Why not?
5 MR. RODRIGUEZ:
Because it's not a safety actuated.
6 Our hydrogen system is not needed for some number of days 7
afterwards.
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But it is needed.
Why do you say 9
"some number of days"?
10 MR. RODRIGUEZ :
The FASR in a description of when 13 the hydrogen purge is brought on specifies some number of 12 days after the --
Three mile island also had the 14 same-type of number of days for the amount of hydrogen to 15 build up in the containment system, but I think the experienc e
16 we have seen indicates that perhaps we ought to relook at 17 some of these things.
Is Perhaps the timing of the build up of the hydrogen 15 containment build-up system might have been underestimated.
20 Perhaps you might look again to see if that 21 system might well be included in the safety-related systems 22 to get the dual verification.
It might be needed..
It might 23 be needed very quickly in view of some of the things that 24 can go wrong.
25 For example, is the PRV system also included for w
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dual?
The pilot-operated relief valve system?
2 MR. RODRIGUEZ:
Well, the pilot-operated relief 3
valve has a valve that's operated right from the control b^
4 room for either using -- allowing that valve. to operate or 5
blocking its ability to operate.
I think I'll come back to this 7
later, but I think you did a good thing by going through and 8
adding some systems that weren't in there.
I think it's 9
excellent.
10 I don't know if we agree that you have gone far gj enough.
Perhaps there are some other things that should be added.
I think you did an excellent thing by changing that 12 list.
13 14 On page four near the middle of the page, who was 15 on the plant review committee?
16 MR. RODRIGUEZ :
The plant review committee is 17 comprised of the operations supervisor, the engineer, and 18 quality control supervisor, the maintenance supervisor, 19 the chemistry and radiation supervisor, and the chairman 20 of the plant review committee is the secretary of the 21 Management Safety Review Committee and the technical 22 assistant to the nuclear operations department manager.
All engineers?
24 MR. RODRIGUEZ:
No, not all are engineers.
The majority of them?
26 I
MR. RODRIGUEZ :
The majority of them.
How many of these people must be 3
there to hold meetings?
4 MR. RODRIGUEZ:
There must be a quorum of three.
At that same place it said they 6
meet on the 19th of the month to review the above procedure.
7 The next paragraph says you sent out a special order on the 8
10th of the month.
9 It seems you would want to have had their review
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10 done very quickly on that before you sent the order out to il implement that procedure.
12 MR. RODRIGUEZ:
We implemented a dual verification 13 requirement prior to getting the words " dual verification" 14 into the procedures, 15 MR. DE YOUNG:
You implemented the directive part 16 of it?
17 MR. RODRIGUEZ :
That's right.
Rather tha,n the --
19 MR. RODRIGUEZ:
And then came back through and 20 put the words into the procedures and reviewed and approved 21 the procedures.
On page --
23 CHAIRMAN ENGELKEN:
Excuse me.
While we're on 24 the subject of the committee, what is the frequency of 25 meetings of the plant review committee, approximate l
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frequency?
2 MR. RODRIGUEZ:
The plant review committee in the 3
first four months of this year has met 3.67 times per week.
4 CHAIRMAN ENGELKEN:
Can you give me some feeling 5
for the length of the meetings and the number of items that 6
are considered at a typical meeting.
7 MR. RODRIGUEZ :
The typical meeting will last two 8
to three hours and probably cover from a half a dozen to a 9
dozen items.-
I might add that since the initiation of the 10 plant review committee there have been some 750 meetings.
11 CHAIM0W ENGELKEN:
Thank you.
Minutes are kept of the meetings?
13 MR. RODRIGUEZ:
Yes, sir.
On the next page I see the first 15-completion date on the fourth item.in the list.
It was due 16 in two days.
How is that coming?
Is it being -- are you 17 going to meet these dates?
There is no doubt about your 18 ability to meet the dates?
19 MR. RODRIGUEZ:
We will have that procedure 20 approved prior-to the next time we have to use it.
21 SPecifically where that procedure stands today, I can't 12 tell you.
On page six on the second listing 24 there, what's the meaning of the first abbreviatinn, Sur.?
25 MR. RODRIGUEZ:
Oh.
Surveill'ance of the spent l
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fuel cooling system.
About halfway down the list I see 3
203.06E.
What's DHS?
4 MR. RODRIGUEZ:
Decayed heat removal.
So DHS is decayed heat removed?
6 MR. MATTIMOE:
Decayed heat system.
7 MR. RODRIGUEZ:
It's the same as low pressure 8
injection.
I guess I have some general to comments to make.
Before I do that, I'd like to ask you a 11 few more questions about the event.
12 Who are the people involved?
Were they the same 13 people in all three problems?
Was it one individual, two 14 individuals?
15 MR. RODRIGUEZ:
No, they were different crews 16 involved at different times.
First, I guess that was the same 13 crew?
19 MR. RODRIGUEZ:
Well, the first one occurred on 20 December the 7th and then the next one, I believe, occurred 21 about January the 9th.
22 MR. CANTER:
I think it was December 17th.
l 23 MR. RODRIGUEZ:
Okay.
December 17th through
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24 December 7th was the A problem.
Problem B started on the same date.
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It was terminated 23 days late so it must have been the same 2
shift that started the problem.
3 MR. RODRIGUEZ:
No.
The shifts are rotating 4
shifts.
I can't tell you specifically which shift it was.
But they were different shifts?
6 MR. RODRIGUEZ:
Different shifts involved.
Could you explain to most of the 8
people here what technical specifications are and how you 9
view the technical specifications?
What are they?
They have 10 been violated and you have been fined for the violation.
11 What are the technical specifications?
12 MR. RODRIGUEZ:
The technical specifications are 13' the rules of the license under which we operate Rancho Seco.
14 This is part of the final safety analysis report which 15' established specific operating requirements in which the 16 Nuclear Regulatory Commission specified details of what we 17 do within the plant.
Are they all of the same weight, 19 the same importance?
Do they vary in their importance?
20 Let me try to answer that.
I think they do.
If j
21 you violate one of them, you may have to shut the plant down 12 instantly, just bring it to a shutdown.
23 Some of the other violations you can correct in l
24 continuing operation.
So they do have some different levels 25 of importance to safety.
30 1
But I think you quoted it right or defined it 2
correctly that they are a distillation of all the safety 3
requirements that we have agreed to together, that if you 4
follow these procedures, the plant will be operated safely.
5 Everything we do, we don't expect absolute 6
perfection.
We know that violations will occur and that 7
individuals will make some operating mistakes, that equip-8 ment may fail.
So we don't really require that a complete 9
adherence within these technical specifications is necessary 10 to continue the plant operation.
11 Things will go wrong -- we recognize this -- that 12 can be corrected.
Many of the things that do go wrong are 13' mild', what we consider mild violations -- a valve that is 14 closed and it should not be closed.
And qcickly the 15 individual realizes what he has done and opens the valve 16 again.
17 Some mild violation.
He did something and he 18 recognizes that the valve should not be closed and he opened 19 it.
It becomes more serious if the length of valve closure 20 extends from day to day or it can be more serious if the 21 mistake made involves a more significant safety matter.
22 The ones I'm talking about now when we view them 23 collectively, we consider them more than mild.
They are 24 serious.- They extended over a long period of time, 20 days.
25 Twenty-three days for problem B.
31 1
So we do consider them rather serious and that's 2
why the fine.
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3 Our general action on a mild event, we just cite 4
you for viola ^ ton and reprimand you.
A part of the thing 5
that we do when we do something wrong is that we usually 6
try to train ourselves better.
We go back and retrain so 7
we won't do it again.
8 When I get a violation -- infrequently, but I do 9
get them for driving carelessly -- there is a training course 10 they send me to.
The reprimands in this case, we reprimand 11 you.
We require you to change your conditions.
12 What have you done within your.own organization
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to do the same type of thing?
Have you been reprimanding, 14 have you been training, have you done the same type of thing 15 that we have done to you to yourselves?
Have you looked to 16 see perhaps there is someone who should be reprimanded?
17 Have you given any reprimands to anyone for these violations?
18 MR. WALBRIDGE:
I might respond to that in a 19 general manner.
Perhaps Mr. Rodriguez would like to be 20 more specific as to actions taken at the plant.
21 We took these extensive reviews not only of the l
12 particular violations but also the underlying conditions lt3 which allowed that to occur and not be detected as rapidly 24 as would have been desirable, as you point out, and have 25 existed for some period of time and to'see what changes we
32 1
could make to our management control that would catch 2
these.
3 I think we recognize, as you do, that personnel 4
like equipment is not one hundred percent fail-safe.
5 We all, in spite of our own intentions and best 6
training, will err and so what we have to do is set up 7
provisions which will catch these errors or prevent them 8
actually from occurring.
9 And I think the measures we have taken here in 10 terms of new management control, dual verification, hard 11 copy sign off, and so forth, are measures to accomplish 12 this.
13' Shift turnover is another device which should the 14 error occur, it would be another matter, another means which
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15 we could detect this error at a much earlier date.
And 16 there has been a great deal of in-house investigation, 17 should I say, and soul searching as to how to accomplish 18 this.
~
19 Certainly at the plant the importance of these 20 changes, the importance of the actions reported about the 21 tech specs have been emphasized through some additional 22 training.
As I say, I defer to Ron to give you the
'23 specifics of it.
)
24 As to fines or suspensions levied against the 25 personnel involved, no, we did not do that.
We felt that it O
33 1
was much more appropriate to provide them with appropriate 2
training and emphasize the necessity of the procedure j
3 approach to these problems rather than putting them all on i
4 suspension or fining the individual.
Ron, do you want to add anything?
6 MR. RODRIGUEZ:
Only that these errors, as I 7
indicated earlier, were committed by more than one or two 8
individuals.
And in problem A the circumstances that 9
surrounded that, the individuals involved made a very 10 deliberate attempt to analyze what the situation was and 11 the choice that they chose to follow was wrong.
12 But these two senior licensed operators involved 13 in that have been with the unit from its inception and
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14 operated well for years and years, and they made a mistake 15 after five or six years of operation.
16 They felt bad enough about the mistake.
Reprimand 17 and disciplinary action wasn't going to correct what had 3
18 transpired.
19 What's more, as part of our management controls 20 depends on people reliably pointing out problems that they 21 find,'and I feel very confident that the staff will do that.
22 And part of that is because if an individual makes a single
-23 mistake, he is not severely disciplined for it provided it's
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24 an honest mistake and wasn't just a hurried-up case of him
)
25 deliberately violating concepts and procedures that he knew i
34 I
were in existence and felt that they just didn't apply to 2
him.
3 And I think there is a difference between the 4
individual that purposefully goes ahead and he knows it's 5
wrong as opposed to the individual that makes an honest 6
mistake.
One of tie things that I did note 8
about the three events is that they all occurred within a 9
short period of time around the holiday season.
I don't 10 know about some other people, but when we run our round-the-11 clock matters, we are always concerned about the holiday 12 season.
13 People tend to perhaps get less sleep and do more 14 t hings.
There are more things to be done.
There are more 15 things on their minds.
They are perhaps taking a vacation 16 next week and they think about it.
17 We all have this problem around the holiday season.
i 13 Did you look into this and do you have a change procedure 19 around next December?
Let's be alert.
The holiday season 20 is coming.
21 Last year we had three events, violations.
Have 12 you looked into that, this short period of time?
It seems
)
23 to jump out at you right around the holiday season, and I l
'E 24 don't know if it had any bearing, but I don't know anybody 25 that has any round-the-clock service who are not always l
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35 1
alert to the holiday seasons.
2 People tend to be less involved in the business 3
they are supposed to be performing.
Have you examined it 4
in your discussions?
5 MR. RODRIGUEZ:
The holiday season did not come 6
into our review.
I don't know if it did to anyone at the 7
plant.
I know in our management review it was not under 8
consideration.
9 It is something worth looking into, whether there 10 is any record of that in the past to indicate that might be 13 a factor.
12 MR. DE YOUNG: One of the big lessons that we 13 learned from Three-Mile, from all of the investigations into 14 the Three-Mile, one of the main lessons learned is that 15 lessons are not learned.
We don't. learn our lesson.
16 I think there is a lesson to be learned here.
I 17 think that things do happen perhaps because of growing 18 complacency to a good operating record.
People become 19 assured that they can continue to do it and they slip a 20 little bit in their concentration or something.
Whatever 21 it is..
12 But there is a strong lesson to be learned here, 23 and I don't know whether or not you are going to learn it.
ji:
24 But we are going to learn it.
We feel just as wrong as you 25 do about how this -- perhaps if we had-detected some of I
36 i
1 these things sooner and alerted you to the fact that, gee, 2
it seems to be that your high cuality performance may be 3
slipping a bit, we would have prevented it.
4 The Three-Mile Island things are precursors that 5
precede every bad operation, every bad event, and they are 6
there to be seen and the industry missed them.
7 Are there any here?
Is this a precursor of 8
something that's going on?
We fixed the three problems.
9 We have retrained the people about the three problems.
10 Is it a more general thing? 'Should we be 11 examining the entire safety aspect of this plant again, you 12 and us together, you through your inspections and through 13 the inspection of the hydrogen control system, other 14 systems.
15 This is only a limited thing.
There are other 16 things that you should examine, too, instead of just looking 17 at the one small part of your entire operation.
This may 18 be a precursor.
It's telling us things are going wrong 19 with the operation system, not only the small aspect.
20 I can't see anything wrong with what you have done 21 except I'd like to see the list examined to see if perhaps 12 there are things.
But you corrected that problem.
What
'23 about -- is there something more that -- I mean is there 24 something dee'per than we have seen so far?
Have you looked 25 at that or do you know at all?
Have you thoucht perhaps
i 37 1
we ought to look further?
2 MR. WALBRIDGE:
I think we did as we were reviewing, 3
this.
And I guess in particular as I was reviewing it.
I 4
am not a nuclear engineer and not versed in the intricacies 5
of Rancho Seco.
6 We are looking for corrective actions and modifica-7 tions to procedures which were going to do more than just 8
assure that we did not have.a duplication of the valve in 9
the clo, sed portion rather than en open position on the DCCS.
10 Rather, we are looking for corrective actions that would -
11 prevent these human errors or would minimize the likelihood 12 of the human errors that took place here and, secondly, 13' which would enable us to review and consequently catch a-14 human error should it occur..
15' And I think that some of.the actions that have 16 been taken here had much broader significance than just to 17 the specific situations that have led us to these violations.
18 In other words, it will have a much broader application in 19 reducing the human errors and catching them if they should 20 occur at an earlier date.
Do you think you have done that?
)
22 MR. WALBRIDGE:
I don't think we have ever done
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23 enough but I think we have made a great deal of progress 24 here.
I think that's the correct answer.
38 1
We can speak of quality.
We are talking about quality of 2
operation.
Just as soon as we think we have done enough 3
and we are performing in a quality way, as soon as you think 4
you have a program that's going to do the job you think it's 5
going to do, you make a mistake and it doesn't.
You become 6
complacent.
7 I would like to talk about the staff, the people 8
who do the operations, the licensed operators.
They have 9
a treme,ndous burden.
There are a lot of things that they 10 have to do.
We continue to burden them with more and more 11 procedures and more and more requirements and documentation.
12 Dual verification.
13' They have more things to do.
And I think we have 4?
14 to be very careful that we don't overburden them with 15 ^
procedures and documentation that have to be done.
Perhaps 16 another operator would -- I think from the individuals that 17 I have talked to, some of them believe they are being driven J
18 to the point that the' job is not that -- becoming less 19 attractive than they initially thought.
The bureaucratic 20 requirements, and records, and documentation are becoming too 21 much for-them.
22 They feel as if they are as much a paper pusher 23 as they are a true reactor operative.
And then we have to lb 24 be very careful that we don't leave too much to the operators j
25 to the point where we get -- where people that apply for the l
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39 1
job and obtain the position that are less qualified than the 2
very good people I see there now.
3 And you have to be careful.
To put on a lot more 4
things -- they have to check this; they have to do this; 5
they have more forms to fill out.
I don't know where the 6
point is, where you say, " Gee, that's enough and I need 7
another man.
I should get another man to make sure these 8
people have enough time to think what they are doing instead 9
of just. making notes and writing down and filling forms out.
10 I don't know when you reach that time.
I think it we are doing reviews on the overall problems, but I think 12 you should look, too.
When you feel you get to that point, 13 it's a wise investment.
14 I don't know whether you know it, but I read in 15 the paper this morning that the enforcement level, the fines 16 that we can impose have been approved by one group within 17 Congress.
It's new legislation that will raise the penalty is significantly for events of this type perhaps.. And it's 19 not worth it. to get penalized for this type of thing.
20 With training and good people on your staff, 21 perhaps you can avoid it.
I think whether or not we have 12 learned our lesson at Rancho Seco will become clear during
'23 the next months or the year.
24 If this happens again around next December, we 25 will not have learned our lesson, or at any time.
The l
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40 1
proof of the pudding is in the quality of operation that 2
you have available, and I think that's going to be the true 3
proof and if something does happen, if another violation of 4
tech specs occurs of this same type of significance, 5
perhaps you ought to relook at the entire thing that you 6
have done and go deeper and broader and get help.
7 Perhaps your operation is becoming degraded slowly 8
but surely.
We will be doing more inspections.
We will be 9
looking at you closely for a while to try and help you to 10 try to detect anything that we see, to try to inform you, it to aid you in improving the operating system you now have.
12 I have nothing else to say, Bob.
13 CHAIRMAN ENGELKEN:
I have no further comments.
14 Are there any other questions?
Other staff 15 questions?
16 (There was no response.)
17 CHAIRMAN ENGELKEN:
If there are no further is questions, we will adjourn until three o' clock.
We have 19 a commitment to the public.
I don't see many, if any, l
l 20
. members of the public present; however, there was a public 1
21 announcement indicating ~that we would be here at three 22 o' clock for public questions.
23 I think we will have to meet that commitment; so j
24 we will meet again at three o' clock.
j 25 (The session was adjourned at 2:10 p.m.)
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41 1
PggLlg EEgglQg 2
CHAIRMAN ENGELKEN:
I would like to call the 3
meeting to order.
3.:.
4 This is the portion of the meeting that has been 5
set aside for the public te ask whatever questions they 6
choose to ask.
I don't know whether there are any members 7
of the public present who would care to ask some questions.
8 If there are, I would like to have them come up to sit in 9
this chair at the table and use the microphone.
Please 10 identify yourselves and state your questions.
11 (There was no response.)
12 CHAIRMAN ENGELKEN:
There ic no response from the 13 ~
audience.
With that I see no further need to continue the 14 meeting.
We will close the meeting.
Thank you.
IS' Incidentally, I would like to announce that the 16 copies of this transcript will be placed into the public 17 documents' room and will be available for a review by the is public.
And where is the location?
19 Sacramento City -- County Library on I Street?
20 I would guess that would be in two weeks.
21 (The hearing was adjourned at 3:02 p.m.)
22
--o0o--
'23
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CERTIFICATE OF REPORTER 2
3 I,
CLARA MAE MATHIS, a Certified Shorthand 4
Reporter of the State of California, do hereby certify:
5 That I am a disinterested person herein; that the 6
foregoing Nuclear Regulatory Commission hearing was reported 7
in stenographic shorthand by me, Clara Mae Mathis, and theer-8 after transcribed into typewriting.
9 I further certify that I am not of counsel or 10 attorney for any of the parties to said hearing nor in any 11 way interested in the outcome of said hearing.
12 13 IN WITNESS WHEREOF I have hereunto set my hand 14 this Sti. day of May, 1980.
15 16
[' t.., - - h i..
/ L&L.,
17 Clara Mae Mathis 18 Certified Shorthand Reporter Certifi'cate No. 2832 19 20 21 22
'23 24 25 l
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