ML20132G147
| 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: |
| 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
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Section 4, Surveillance
- 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
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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11
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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
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
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.
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.
"0RIGINAL PAGE"
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t
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11
.
.
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
,
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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21
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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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21
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,
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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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