ML20132G147

Corrected Pages 11 & 21 to SALP Rept 50-312/85-18,correcting Typos & Editorial Errors Re Performance Analysis

ML20132G147
Person / Time
Site:	Rancho Seco
Issue date:	09/25/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20132G141	List: ML20132G137 ML20132G147
References
50-312-85-18, NUDOCS 8510010483
Download: ML20132G147 (6)

See also: IR 05000312/1985018

Text

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Errata Sheet No; 1

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SALP Board Report'No.- 50-312/85-18' ,

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Part IV, Performance Analysis -

Section 4, Surveillance

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- Page 11, Paragraph 3, lines 1 th' rough 4 s

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Now Reads: -

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"In the surveillance areas, one notice of violation.was issued during this

- SALP period;-this dealt with the procedures for safety-related battery

testing. The procedures contained numerous errors and in certain cases data

had been incorrectly recorded."

{ Should Read:

"In the surveillance area, three violations were issued during this SALP

- period. One dealt with procedures for safety-related battery testing, which

contained numerous errors including incorrect data. A second violation

concerned incomplete calibration program records for plant gages. The third

'

violation identified a failure to test additional system valves-following a

valve operational failure during testing."

'

Basis:

l' SALP report tables 1 and 2 had been updated to include Inspection Report 85-23

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which added two additional Level IV violations in the area of surveillances.

.However, these additional violations were not discussed in the text of-

Section 4. The above change references the additional violations for

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completeness and consistency with the tables.

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4.,. Surveillance

'., The surveillance program has been inspected periodically by the

'

esident and regional inspectors throughout this evaluation period.

ring the previous SALP period the licensee exhibited a decreasing

pe formance in the surveillance program; the performance rating for

thi. area was a Category 3. This was mainly based on poor

mana . ment controls in the planning, scheduling, and performance of

surver lances required by the Technical Specification.

. During t 's SALP period, the licensee has effectively used the daily

managemen meetings to provide status of surveillance tests. This

increase in management attention has greatly reduced the amount of

missed surve llances and requests for Technical Specification

changes to de y surveillances.

In the surveilla c ae , one notice of violation was issued during

, this SALP period; t ealt with the procedures for safety-related

battery. testing. e cedures contained numerous errors and in

certain cases data h d een incorrectly recorded. The licensee has

begun a program to id tify a d correct the surveillance program.

The licensee identifie in run LERs that surveillance procedures

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did not provide the pro r ria or were missing equipment or

were basically improperly wr to satisfy the stated purpose.

Some of the.. corrective act ns the surveillance area include:

Technical specification eq ents to be provided in the

surveillance procedure,

A t,st developed to cross r erttgfeb surveillance requirements

by surveillance procedure, ,

• A review of all pertinent Ranch Seh cuments to develop all

licensee surveillance commitment

A surveillance procedure writer's g "deline,

A review of all existing surveillance rocedures against the

writer?s guideline.

These items are at different stages of completi n but are scheduled

to be completed late in 1985. .This program shou d identify areas ,

were some surveillance procedures have failed to clude all i

pertinent criteria from the Technical Specificatior and provide the j

licensee further assurance that the surveillances a testing the i

systems in a manner appropriate with the systems func ion. l

The licensee is also discussing the concept of system e ineering,

where one engineer is responsible for a given system. Th s would

include maintenance, modifications, operational requiremen s,

industry problems, and surveillance trending of the system. This

should enhance the surveillance program by providing addition 1

'

levels of assuring the systems operability.

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"0RIGINAL PAGE" 1

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11

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4. Surveillance

The surveillance program has been inspected periodically by the

resident and regional inspectors throughout this evaluation period.

During the previous SALP period the licensee exhibited a decreasing

performance in the surveillance program; the performance rating for

this area was a Category 3. This was mainly based on poor

management controls in the planning, scheduling, and performance of

surveillances required by the Technical Specification.

During this SALP period, the licensee has effectively used the daily

management meetings to provide status of surveillance tests. This

increase in management attention has greatly reduced the amount of

missed surveillances and requests for Technical Specification

changes to delay surveillances.

In the surveillance area, three violations were issued during this

SALP period. One dealt with procedures for safety-related battery

testing, which contained numerous errors including incorrect dcLt.

A second violation concerned incomplete calibration program r tocds

for plant gages. The third violation identified a failure to test

additional system valves following a valve operational failure

during testing. The licensee has begun a program to identify sad

correct the surveillance program. The licensee identified in ulr.e

LERs that surveillance procedures did not provide the proper

criteria or were missing equipment or were basically improperly

written to satisfy the stated purpose. Some of the corrective

actions in the surveillance area include:

Technical specification requirements to be provided in the

surveillance procedure,

• A list developed to cross reference surveillance requirements

by surveillance procedure,

A review of all pertinent Rancho Seco documents to develop all

licensee surveillance commitments,

• A surveillance procedure writer's guideline,

• A review of all existing surveillance procedures against the

writer's guideline.

These items are at different stages of completion but are scheduled

to be completed late in 1985. This program should identify areas

were some surveillance procedures have failed.to include all

pertinent criteria from the Technical Specifications and provide.the

licensee further assurance that the surveillances are testing the

systems in a manner appropriate with the systems function.

The licensee is also discussing the concept of system engineering,

where one engineer is responsible for a given system. This:would

include maintenance, modifications, operational requirements,

industry problems, and surveillance trending of the system'. -This

~

should enhance the surveillance program by providing additional

levels of assuring the systems operability. -

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" CORRECTED PAGE"

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Errata Sheet No. 2

• SALP Board Report No. 50-312/85-18

Part IV, Performance Analysis

Section 9, Quality Programs and Administrative Controls

Page 21, Paragraph 2, lines 1 and 2

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Now Reads:

"A total of eight violations (Level IV and V) were issued in this functional

area. An additional nine violations (Level IV and V) in...."

Should Read:

,

"A total of 10 violations (Level IV and V) were issued'in this functional

area. An additional 8 violations (Level IV and V) in...."

Basis:

SALP table 2 lists a total of 18 violations, eight of which were identified as

PAB findings, including one violation with two examples. The above change

corrects the text of Section 9 to be consistent with the tables.

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report's recommendations are su'fficient to ensure substantial

uality program improvement occurs at Rancho Seco.

A tal of eight'Vi_olations (Level IV and V) were issued in this

fun ional area. ,An3 additional nine violations (Level IV and V) in

this rea were issued as a result of.the Performance Appraisal

Branch (PAB) inspection performed in November 1983. These PAB

finding although~ issued as violations during the present SALP

cycle,1w e actually used to evaluate the previous SALP period and

thus were ot used for the present assessment. The violations

identified uring this period were all of a minor nature, but are an

indication-t t the need to follow the details of administrative ,

requirements eds em hasis.

One of the major we ss identified by PAB (and factored into the

previous SALP res t. > 'as in the area of administrative controls of

the safety review mm Ttees, that.is, the Plant Review Committee

(PRC) and the Manage ent Safety Review Committee (MSRC). The

inspectors have note erf mance improvement in both of these

committees,.not only f in administrative viewpoint but, more

importantly, from the v wpt(fht of. safety and the depth of

evaluating and resolving 'ssqm. Examples of the improved

thoroughness of these comm~tt were noted during recent problems

with reactor trip breakers. d nt concerns with the auxiliary

.feedwater system.

i The Quality Assurance organizat'on ' If has undergone a

!

reorganization and expansio'n dur g 's SALP cycle and appears to

have made some improvements and c tr tions in the area of

surveillances of daily routine act1 it such as health physics

practices and operations. In additi n,. Quality Control

organizations, which have previously een separate organizations

(one reporting to plant engineering an the o her to nuclear

engineering through construction) have en combined into one

organization which now reports to Qualit Assurance. This

reorganization has the potential for impro ing the independence and

effectiveness of quality control. However, notwithstanding these

changes, the staff considers that the Qualit Assurance organization

must-expand the scope of their activities and ecome more agressive

in areas'such as engineering, construction, an maintenance.

Management needs to continue to support the Qual ty Assurance effort

l and demand that it be a strong and viable tool to .nsure quality.

Close scrutiny of progress is needed.

A root cause program has been created in the regulato compliance

organization during this SALP cycle. The purpose of t 's group is

to determine the cause of plant events so as to minimiz the

l potential for similar future events. This program is co idered to

l

be extremely valuable and management should continue to su ort its

,

development and implementation. It is too early to tell if it will

! be effective.

j In summary, it is obvious that the management of Rancho Seco an the

l SMUD Board of Directors have made a change over the past several

"0RIGINAL PAGE"

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report's recommendations are sufficient to ensure substantial

quality program improvement occurs at Rancho Seco.

A total of 10 violations (Level IV and V) were issued in this

functional area. An additional 8 violations (Level IV and V) in

this area were issued as a result .of the Performance Appraisal

Branch (PAB) inspection performed in November 1983. These PAB

findings, although issued as violations during the present SALP

cycle, were actually used to evaluate the previous SALP period and

thus were not used for the present assessment. The violations

identified during this period were all of a minor nature, but are an

indication that the need to follow the details of administrative

requirements needs emphasis.

,

One of the major weakness identified by PAB (and factored into the

previous SALP results) was in the area of administrative controls of

the safety review committees, that is, the Plant Review Committee

(PRC) and.the Management Safety Review Committee (MSRC). The

inspectors have noted performance improvement in both of these

committees, not only from an administrative viewpoint but, more

importantly, from the viewpoint of safety and the depth of

evaluating and resolving issues. Examples of the improved

thoroughness of these committees were noted during recent problems

with reactor trip breakers and recent concerns with the auxiliary

feedwater system.

The Quality Assurance organization itself has undergone a  !

reorganization and expansion during this.SALP cycle and appears to

have made some improvements and contributions in the area of

surveillances of daily routine activities such as health physics

practices and operations. In addition, the Quality Control

l organizations, which have previously been two separate organizations

I (one reporting to plant engineering and the other,t'o nuclear

engineering through construction) have been combined into one

~

organization which now reports to Quality, Assurance. This

reorganization has the potential for improving the independence and

effectiveness of quality control. However, notwithstanding these

! changes, the staff considers that the Quality Assurance organization

must expand the scope of their activities.and become more agressive

in areas such as engineering, construction,'and maintenance.

I Management needs to continue to support the Quality Assurance effort

i and demand that it be a strong and viable tool to ensure quality.

Close scrutiny of progress is needed.

A root cause program has been created in the regulatory compliance

organization during this SALP cycle. The purpose of this group is

to determine the cause of plant events so as to minimize the

potential for similar future events. This program is considered to

be extremely valuable and management should continue to support its

development and implementation. It is too early to tell if it will

be effective.

In summary, it is obvious that the management of Rancho Seco and the

SMUD Board of Directors have made a change over the past several

" CORRECTED PAGE"

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