ML20052B866
| ML20052B866 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 04/09/1982 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Sternberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20052B862 | List: |
| References | |
| NUDOCS 8205040082 | |
| Download: ML20052B866 (7) | |
Text
_-_
ENCLOSURE 2 esuun SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 15830, Sacramento, California 95813; (916) 452-3211 Ya
~
E'
., a,
-,3 s;
c, G
F. 0 5
M "rac 2
3 April 9, 1982 C
2 D li STERNBERG, CHIEF REACTOR OPERATIONS PROJECT BRANCH U S flVCLEAR REGULATORY C0!iMISSION 1450 i! ARIA LANE, SUITE 210 UALHUT CREEK CA 94596
SUBJECT:
RESPONSE TO SALP BOARD REPORT - RANCHO SECO Attached is a response to the SALP Board Report. The District has included comments on various sections of the report and provided a written explanation on the one Category 3 finding (Corrective Action) that covers steps which the District has taken, and will take, to raise the performance level of this functional area.
Yw John J iiattimoe Assistant General Manager and Chief Engineer 8 2 0 5 0 4 009 6L AN ELECTRIC SYSTEM S E R VI N G MORE THAN 600,000 IN THE HEART OF C Ali f 0 R N I A
~
SALP BOARD REPORT RESPONSE The NRC has conducted a Systematic Assessment of Licensee Performance (SALP) review of the Sacramento Municipal Utility District (SMUD). The report covers the period of June 6, 1980 to June 30, 1981.
Since this report was not pre-sented to SMUD until March 23, 1982, it is not current with regards to programs l
now in effect at the Rancho Seco Power Plant.
The. District wishes to establish the current status with regards to each functional area that was investigated by the SALP Team. The District will also address the Overall Licensee Managment Evaluation Summary that discusses j
l their appraisal.
i l
Overall Licensee Management Evaluation Summary L
District Response:
l The District contends that various responses to items of noncompliances, that i
the NRC judged to be inadequate, were in fact directed to explain in depth the technical background that led to certain judgments being made.
In no instance did the District intend to rely on a legal argument as contended in the SALP report. Differences of opinion regarding technical significance of how parts and components affect the system and its attendant safety signi-ficance are legitimate areas of disagreement. The District has always acknow-ledged when items of noncompliance are correctly identified.
The four areas where unfilled staff positions were identified in July 1981 needs clarification. The Plant Health Physicist position has now been filled; the Plant Nuclear Chemist remains open; the Technical Assistant's engineering staff now has a full complement; the Senior Nuclear Engineer position is filled by a technically qualified individual; and the Senior Mechanical Engineer duties have been apportioned among two mechanical engineers in the l
Engineering and Quality Control group. These individuals have the necessary technical expertise and are qualified technically to perform a Senior Engineer's responsibilities. However, the District has an administrative requirement that an engineer receive professional registration prior to being classified as a Senior Engineer. The District expects to appoint an individual fully i
L meeting its administrative requirement as a Senior Mechanical Engineer within the next two months.
Citing the Plant Operation's staff as being between four and five complete shif t crews is incorrect. Based upon the current Technical Specifications requirements the District has five operating crews and plans to institute a sixth crew in May. Additional information relative to shift manning is discussed under Section 1 of this report.
The two significant strengths identified by the NRC (refueling operations and fire protection and housekeeping) are acknowledged and concurred with. The District further agrees that major improvements have been realized in the manning and effectiveness of the Quality Assurance organization.
Ok^
r w
The bistrict has expended much effort in the areas of training, record keeping and specific improvements to maintenance procedures and scheduling of mainten-ance activities. Significant improvements have been realized in these areas since July 1981 and the District expects the next SALP review to concur with the District's appraisal.
The District's managers and personnel are keenly aware of their responsibilities and are dedicated and competent in their assignments.
To further clarify the many changes the District has made since July 1981, this report will address each separate functional area to reflect status as of March 23, 1982.
In particular, the District wishes to clarify. the corrective actions.
In certain cases, the District wishes to clarify and correct those items the SALP Team did not correctly interpret.
1.
Plant Operations District Response:
Rancho Seco's Technical Specifications requires one Senior Reactor Operatcr and two Reactor Operators per shift. Presently, there are five operating crews. Two crews have a complement of two Senior Reactor Operators and two Reactor Operators whereas the remaining three crews have two Senior Reactor Operators and one Reactor Operator. Additionally, there are presently two individuals in the training program who have taken their examinations for a Senior Reactor License and are awaiting the results. Predicated upor.
these individuals obtaining their SR0 license, it is intended that a sixth operating cre'w be instituted. Each crew will meet or exceed the Technical Specification requirement of one SR0 and two R0s.
Five crews will have two SR0s and one R0; whereas, the sixth crew will have one SR0 and two R0s.
The District will continue to make every effort to meet the schedule sub-mitted in the November 3,1980 letter discussing Interim Criteria for Shift Staffing.
The NRC is mire of the effort the District is making in this area. The training program used by the District is extensive and excellent. The high' percentage of personnel passing the license examinations reflects the competence of the program.
The District concurs with the NRC appraisal that the Shift Supervisors are keenly aware of their safety responsibilities.
2.
Refueling Operations District Response:
The District has no comment.
3.
Maintenance District Response:
The District maintains that significant improvements have been made in the-area of maintenance. The LER analysis (Chain 2) is not a good indicator
' i
r for definitive corrective action in the area of instrument calibrations.
It does not address the large number of instruments being calibrated or the reasons for settings to be out of specifications.
In addition, over 30% of the incidents did not involve safety related instrumentation. The District recognizes the need for a strong and a rigid calibration pro-gram.
Instrument drift is always a problem and requires much engineering time to find and correct instrument design and application errors. The District is replacing instruments when necessary. A large number of instances where instrument settings were outside of specification lie in the area of effluent water chemistry. They were not in safety related systems covered by the Technical Specifications mandated by the NRC, but lie in State of California imposed water chemistry restrictions prior to release of water (TS Appendix B).
The lack of an official QA Class I components list is now being corrected.
The District has dedicated the resources to solve this problem. The District acknowledges the need for a "Q" list.
Selected mechanical procedures are being upgraded to include inspection hold points, use of vendor's technical manuals and the use of a computer system to provide maintenance seneduling.
4.
Surveillance and Inservice Testing District Response:
The District concurs with the SALP finding.
5.
Personnel, Training and Plant Procedures District Response:
The only staff. position cited by the SALP Team for which an available candi-date has not been found is the Plant Nuclear Chemist. The District is actively seeking a qualified candidate.
Five recent applicants failed in meeting the District's minimum requirements. Status is covered in the Overall Licensee Management Evaluation section. The District recognizes the need for an active recruitment program to fill vacant positions when they occur.
The District has dedicated considerable resources in the training area.
Although the training program is not completely implemented, the District feels significant progress has been made since July 1981. The next SALP review should document the significant progress in this area.
The great effort expended by the District in Fire Brigade training was acknowledged by the SALP Team and the District agrees with their appraisal.
e 6.
Fire Protection and Housekeeping District Response:
The District concurs with the SALP finding.
7.
Design Changes and Modifications District Response:
The large amount of design changes resulting from the Three Mile Island requirements has necessitated a significant increase in engineering staff, both in the area of District personnel and A/E support personnel. Training programs, changes to control procedures and a number of audits have been performed to establish a confidence level that satisfactory controls are in effect on design changes.
The District anticipates difficulty in meeting design and modification targets. Considerable effort is being expended to have the available resources on-site to begin the TMI modifications at the next refueling scheduled for the Fall of.1982. The NRC is being continually updated on the District's progress in this area.
8.
Radiation Protection, Radioactive Waste Management and Transportation District Response:
The District concurs that staff.ing has been a continual problem in the radiation protection area. Contract personnel have helped to alleviate some of the concern.
It should be noted that no specific inadequacies were identified by the SALP Team.
As.previously stated, the Plant Health Physicist position has been filled.
9.
Environmental Protection District Response:
The District concurs with the SALP finding.
- 10. Emergency Preparedness District Response:
The District recognizes improvement is needed in the area of Emergency Planning. This program is underway and will culminate with an intensive full-scale test during June 1982. The District will evaluate the results of the drill and make improvements on any identified areas of concern.
- 11. Security and Safeguards 1
. District Response:
The District concurs with the SALP finding.
^ l
r i
e
- 12. Audits, Reviews and Committee Activities District Response:
The SALP finding as of July 1981 stated Quality Assurance and committee activities areas still need improvenient, but a turn-around has occurred.
Since July 1981, the District has increased QA manpower and improved the programmatic controls to eliminate the areas of weakness. The District now feels this area is in compliance to the desired objectives.
- 13. Administration, QA, Records District Response:
The SALP Team identified the progress that has been made in this area. The complexity of providing an adequate records management system including proper storage, etc. has resulted in a delay of completion of the project.
Since July 1981, Phase I of the records indexing program has been completed, and in April the District will solicit proposals from qualified vendors for installation and startup of the records management system. An interim microfilming and indexing off. ice complex has been built under the Adminis-tration Building to provide the space resources for initial implementation of this program.
- 14. Corrective Actions and Reporting District Response:
The SALP Team identified this area as a Category 3 and recommended increased inspection. The District wishes to identify that six inspections were conducted by the NRC in the area of corrective actions and no items of non-compliance were identified.
The District particularly takes exception to the statement, "have tended to rely on legal arguments rather than addressing the technical safety concerns involved." The SALP Team further states that there were instances of inadequate or nonconservative proposed corrective actions.
The District acknowledges the right of the NRC to question the adequacy of a particular response, but reserves the position that alternate evaluations regarding an item of noncompliance are possible.
It is the District's contention that where judgment with respect to degrees of conservatism are concerned, there is always the' possibility of disagreement. The District is responsible for operating Rancho Seco safely. This responsibility is takr.D seriously by a competent staff. The conclusions and actions taken by &_ staff are based upon technical evaluations tempered by the ever present requirement not to create undue risk to the protection of the health and safety of the general public. At no time are these attitudes ever substituted for legal arguments.
It is not the District's position to contend the citation, but to illustrate that legitimate differences of opinion can exist.
In the future, to address the concern raised by the SALP Team, the correc-
e tive actions will be:
i
- 1) Evaluated for concurrence to the NRC's finding
- 2) Action taken to correct deficiency
- 3) Corrective action to minimize the recurrence potential The District will strive for providing prompt corrective action to items identified by the inspection and enforcement organizations of the NRC.
When differences of opinion are identified, the District will attempt to resolve the differences prior to correspondence being transmitted, if possible.
The District, as of September 1,1981, has added a new QAP No. 27, Correc-tive Action, which defines the requirements and establishes the procedure for maintaining the control of corrective action requirements. A Quality Assurance Corrective Action Coordinator has been appointed whose duties and responsibilities have been defined in a new QCI No. 7, Corrective Action Program. The program will assure the following:
- 1) Programmatic conditions which require corrective action are promptly specified
- 2) Appropriate corrective action be promptly specified
- 3) The corrective action is properly implemented
- 4) Those corrective actions which cannot be implemented will receive appropriate review and resolution
- 5) Appropriate interimmeasures are implemented until the corrective action is completed
- 6) There is a systematic method of documenting and tracking corrective actions
- 7) Corrective action data is incorporated into the Trend Analysis Program, as applicable This program should raise the performance level of the functional' area (corrective action) to an acceptable level.
.