ML20137N437

Mgt Appraisal Rept

ML20137N437
Person / Time
Site:	Rancho Seco
Issue date:	11/30/1984
From:	LRS CONSULTANTS
To:
Shared Package
ML20137N417	List: ML20137N414 ML20137N437
References
NUDOCS 8509190100
Download: ML20137N437 (93)

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$$ 407 W4 9 l~ l Management Appraisal Report l November 1984 ~ Sacramento l Municipal l Utility D. tr. t is ic t l By LRS Consultants I \\ L hoj9190100e41130 ADOCK 05000312 i p PDR i R S LiERAR'

.= MANAGEMENT APPRAISAL REPORT 1 FOR THE 1 1 SACRAMENTO MUNICIPAL UTILITY DISTRICT BY LRS CONSULTANTS 355 West 14th Street Idaho Falls, Idaho 83402 4 i i NOVEMBER 1984 l f i i f I sim

J TABLE OF CONTENTS '.= Section Title

fag, 1.0 Introduction 1

2.0 Organization and Management 12 3.0 Engineering 32 j 4.0 Licensing 41 l 5'. 0 Operations 46 6.0 Maintenance 3 51 7.0 Quality Assurance 55 3 i 8.0 Training 61 9.0 Planning Scheduling and Outage Management 66 10.0 Chemistry and Radiation Protection 71 l i 11.0 ALARA 80 12.0 Emergency Planning 82 i 13.0 Environmental 83 1 14.0 Procurement and Stores 86 15.0 Records Management and Document Control 88 j e ,_m --.,e%-- d -. _...-,.~.,_-..--.m_

1.D INTROD0CTION .c o o o o o v v ~ u v -m v v i Assistant General Manager, Nuclear s Licensing and Compliance 4 1 l Nuclear & NRC Regulatory Non-NRC State and Comitment Analysis Compliance Federal Regulatory Control Compliance 1..i-Chart 2-4 Licensing and Compliance Department

i Assistant General Manager. Nuclear t Rancho Seco Plant i Operations Maintenance Outage Planning Radiation Chemistry & Management Protection I sal' [ Chart 2-5 Rancho Seco Plant Department 9 6 e i a

e Assistant General Manager. Nuclear Technical i Support S Training Security Emergency Warehouse Plant Quality Planning Engineering Control i... - 1 Chart 2-6. Technical Support Department e e

4 Assistant General Manager. Nuclear Ad.ninistrative Support g Word Document Control & Personnel Facilities Budget & Library Cost Control Processing Records Management & Payroll t l 1 i... - Adr.inistrative Support Department i Chart 2-7 1 e W M w-.- ,.n.,e.

3.0, ENGINEERING IB There are three separate and distinct engineering functions that 1 the Nuclear Engineering Department o - support Rancho Seco. These are: Nuclear; the Engineering ~(NED) that reports to the Ex?cutive Director. and Quality Control group (E&QC) that reports to the Nuclear Operations s,l Department (NOD) Manager; and the Maintenance Engineering groups that report to the Plant Superintendent through their respective electrical-I&C and mechanical supervisors. l In broad terms, the NED engineering group handles the larger, more complex engineering tasks and bears the prime responsibility for the The E&QC group configuration management of the Rancho Seco plant. provides operational engineering support to the plant in the context of reactor engineering support for fuel loading and in-core physics con-siderations, administers the Technical Specifications related surveillance test procedures, is the administrative home for the Shift Technical i t Advisors (STAS) and is. charged sith monitoring the performance of the The naintenance plant and systems from an engineering point of view. engineering function perfonns short term engineering tasks aimed primari1) at keeping the plant in an operational state although the line is not always clear where maintenance engineering stops and NED engineering takes over. The inter-relationships of the engineering groups among themselves This and with other groups they support is best described as poor. appears to be due mainly to the complexity of the organization and the lack of organizational procedures that define how the groups are to Also, there appear to be some marked personality differences op,erate. l among key personnel in the groups. l r - ) 5 \\ r

The new E&QC program of rotating the new engineers through several organizations including QA on a six month basis over a two year period is an innovative idea that will have positive results over the long term, if the organization can afford to be without those personnel for that period of time. I 3.1 Nuclear Engineering Department NED was separated from the SMUD central generation engineering group in mid-1984. All engineering activities that related to Rancho Seco moved into the new department with the exception of the drawing control program administered by the Engineering Configura-tion Control Center (ECC), which has been stated will transfer in the near. future. NED is composed of an engineering design group that contains the classical engineering disciplines, a const'ruction group, a nuclear fuel management / health physics group and a yet to be staffed cost engineering group. Only activities relating to the design process are discusse'd in this section. As of June 30, 1984 the department was composed.'of 80 full-time and 7 part-time employees with authorized vacancies of 32 and 5 respectively, for a total complement goal of 124 engineering personnel. The department is augmented hy some 300 equivalent full-time contractor / consultant engineers with Bechtel Power Corp. providing approximately 250 personnel and others being supplied by B&W, IMPELL, Sierra Tech and Stone & Webster. The NED design engineering group is located outside the secured area at the Rancho Seco site in a trailer complex known as " design city." As was the case with most utilities having operating nuclear , plants on-line at the time of the TMI-2 accident in March of 1979, the involvement of the centralized engineering groups with the operating plant was minimal. When the avalanche of NRC-directed D 4 -

post-TMI engineering analyses and modifications hit, most utilities were totally unprepared and they were forced to rely almost totally on the architect engineer and consultant firms for both the_ tech-SMUD was nical direction and accomplishment of the required work. not unusual in this regard and is just now in the process of recovering from that avalanche..and is attempting to put together an engineering organization that can, at least project manage the engineering work while accomplishing some work totally in-house. Since the Nuclear Engineering Department was formed in the sumer of 1984 there have been somt steps taken to formalize and put the engineer,ing/ modification process under more manageable control. Key among these are the development of engineering department procedures, pursuit of the Integrated 1.iving Schedule concept with the NRC and the formation of a cost engineering group. Present plans are to have the engineering department proceduras in three manuals: Manual A - Design Criteria, Standards and Specifications Manual B - Administrative and Design Control (this manual will incorporate existing design control procedures. ECP-1, 2 and 3) Manual C - Design Bases (the accumulation of historical plant design basis data and establishment of a design basislibrary) id-1985 and ., The present schedule calls for fianual A preparation by m The generation of a skeleton of Manual B by the same time period. these design and administrative control documents is an excellent The concept and, when completed, should eliminate two problem areas. l first is that all modifications to the Rancho Seco plant are not at present being accomplished using a consistent set of design stal The second is that Manual B, which in part will discuss how the f various engineering groups do business, should aid in eliminating confusion that exists in this area. f

se for an The fomation of the Cost Engineering group makes good sen / improvement organization embarked upon a multi-year modification program at the proposed $40 million level. henviewed . The proposed staffing level of NED appears appropriate wlit l against other engineering organizations of uti ll number of nuclear units; however, with the' exception of a sma the plant-supervisors who were at pancho Seco during startup,Althoug specific experience level of the group is low. will receive stated policy of the Manager. NED, that all engineersll for INP plant-specific training, and future plans ca very little tion in the engineer and technical manager area, 4 specific training has been accomplished to date. l d with a To a large degree, the glut of TMI modifications coup e are the major rapidly expanding, inexper'ienced engineering group the factors in generating the ill will that is evident between l t ent per- " design city" engineering group and the o f* d did not have TMI mods hit, engineering was a small organization an sonnel. i l manage the the personnel and procedures in place to effect ve y board. We sent out multitude of contractors / consultants brought on-some bad designs." i support by i Contributing also to this perception of poor engineer ng ff vacancies l " design city" to operations are the large h I lack of analog engineering expertise in the I&C group. in NED. ction), NED and the Station use a system of " pink" (for constru i so that " yellow" (as constructed) and " white" (as-built) draw n f the current status of any drawing being used l 1 h o 35-D o O ,.,74 ,__..._,,..y 7 ,.,__-,m...,,w,., ..-..-,._,m,,,-,...e,,

readily determined visually. NED has embarked on a program to = l , expedite incorporating the many yellow sheets onto the origina s. At present there are 6529 yellows outstanding, of which 3090 require actual drawing revisions, and they are being incorporated Jt a rate of approximately 450/ month. As of the end of 1983, the goal was to If this is still a have only 400 DCN's outstanding at any one time. a goal, the current rate of 450 yellow sheets per month being incorporated is not adequate. The " critical" drawings are flagged and, when changes to them occur, they get first priority. 3.2 Engine; ring and Quality Control The E&QC group is presently staffed with 22 engineers and 13 student engineer / student technicians, excluding the quality control These engineers cover nuclear, mechanical, electrical function. and STA functions as well a's the surveillance test procedure area. By recent direction, the group is to divorce itself from prime responsibility for any plant modification. The major mission of the' group is to provide operational engineering support to operations. This is accomplished by administering the Technical Specifications ' related surveillance program, by conducting the in-service inspection l program, by providing nuclear engineering support for plant startup and reactivity changes, and by initiating an expande'd plant performance l Individual members of the group are assigned monitoring program. as NODES (nuclear operations designated engineers) that follow for the operations department modifications that are being designed by the Nuclear Engineering Department. f The STA function, in addition to standing shifts, is responsible for review of all INP0 significant operating events reports (50ERs) and other relevant nuclear industry reports, such as the B&W TAP In addition reports on significant transients at other B&W plants. to writing some Trip Reports for plant shutdowns, the group also t P

l writes "near miss" reports to inform all operators of significant This events in the plant that did not result in a plant trip. appears to be an excellent use of the talent in the STA pool and could significantly contribute to a reduction of plant trips by analyzing and disseminating information on "near misses." i t The major emphasis of.the engineering arm of the E&QC group appears to be that of analyzing plant perfomance with a goal of maximizing plant capacity factor. If properly managed and not drawn into the everyday plant maintenance type problems, while concentrating on root causes and longer rang,e solutions, this group could make a signifi. cant contribution. This, of course, will require that the maintenance engineering function be staffed adequately to handle the daily problems and, equally important, that the plant be properly instrumented to allow for meaningful diagnostic work to be accomplished. 3.3 Maintenance Engineering The maintenance engineering function is split into two groups, electrical-I&C and mechanical. Both groups report through the maintenance superintendents to the plant superintendent. The electrical-ISC group is composed of 8 engineers and 7 student engineers / technicians. The group's major function is to prepare calibration procedures and to perform engineering design and analysis as the need arises in support of the operations and the maintenance groups. Normally, the group will not perform engineer-ing design modifications of Class I systems or major modifications; , - however, that ground rule is not clearly defined. The mechanir:al group is composed of 5 engineers and 3 technicians. The group's major function is to review and coordinate work requests, prepare procedures and perform engineering analyses to support moJifications., ,.___..,,__-_,,.,,m--._,,,,,,.,m,__m

Y Although the groups do a significant amount of engineering for design modifications, NED, having configuration management res-This _ approval ponsibility for the plant, must approve the design. requirement causes some conflict in that the maintenance e'hgin ~ group feels that the NED engineers do not know the plant and there-fore question whether the outside group's approval of the design This conflict is very really provides any check and balance. apparent in the, mechanical and I&C/ electrical area and relates ba LRS believes the to the perceived weakness in NED in these areas. design engineering function does not belong in maintenance eng To further exacerbate this situation, the Senior I&C Engineer in the maintenance group resigned in June of 1984 and has not been In addition to providing direction to the I&C engineering replaced. group, the Senior I&C Engineer provided management direction to The Nuclear Electrical-instrumentation and controls technician groups. I&C Superintendent is attempting to provide direction to the individ in the I&C engineering group and manage the technician groups in, However, the superintendent level addition to his normal duties. of management is almost totally occupied with Plant Safety Review i Comittee (PRC) meetings, daily scheduling meetings and a host of. Consequently, there does exist a definite administrative duties. management vacuum in the I&C maintenance area. The inability of SMUD to acquire experienced individuals in the I&C and electrical engineering area should be of serious concern. l ~ 3.4 Engineering Sumary s b Like most nuclear utilities in this post-TMI period, the engineer-ing function at SMUD has been heavily overloaded with required ~ SMUD is now in enginee' ring analyses and facility modifications. the process of organizing its engineering function tn allow for a more orderly engineering process to accomplish regulatory mandated modifications and internally generated plant improvements. { P 38 I, i l'*

This revitalization of the engineering function is being somewhat hampered by the. persistence of a "them" and "us" attitude between the nuclear engineering and operating departments. Eve'n though the NED engineering group has moved to'the Rancho Seco site. it is eutside the fenced secured area and that tends to perpetuate the-disharmony. It is not unusual to have a certain amount of discord, in this interface, because operations always seems to want a quick fix, while engineering must pay attention to codes, standards and traceability. The SMUD situation is also hampered by the apparent inability of both NED engineering and NOD maintenance engineering to replace experienced personnel that have been lost in the elec-tricaJ and IAC area. Given that in the early days of the TMI modifications the engineer-ing department was not staffed and not always on top of the situation, there seems to be a reluctance on the part of senior plant personnel to put that behind them a'nd concentrate on improving the situation. It is a plus that the NE engineering group is now at the site and is trying to take the reins and become more independent of the 1 original Architect / Engineer contractor. This will allow ! MUD to more effectively project manage the work and foster healthy com-petition for new work among an enlarged group of design firms. The i E&QC charter to move more into the area of active plant perfonnance engineering is also a positive move. 3.5 Reconenendations 5-1 NED engineering should expedite the generation of departmental procedures and these procedures should be reviewed and concurred in by the Nuclear Operations Department. The Executive Director. Nuclear should play a strong role in these nuclear engineering / nuclear operations discussions to assure timely resolution of f issues and a clear understanding by the complete nuclear organiza-tion of how the engineering process at Rancho Seco is to function. f ..,. -~

Consideration should be given to. rotating senior nuclear personnel E-2 ietween NOD and NED to both broaden their individual experience le base and bring new perspectives to the engineering / operations ~ interface. 8 Plans should be developed to remove the design engineering function E-3 from the raintenance engineering organization as soon as NED can obtain or develop engineers with plant experience. The. efforts in training in the engineers and technical nanagers area E-4 should be expedited, especially in providing training on Rancho Seco plant systems. Key personnel vacancies should be filled promptly, especially E-5 the lead I&C engineer in maintenance, those in the NED electrical and I&C area and those in'the cost control group. Since it could take many months to eliminate the existing backlog E-6 of " yellow" drawings, it is recommended that progress in this area 5 be carefully monitored to assure that a timely schedule is maintained. Q <e I a 'O I ~ n { ~ t 50 i las -40. l

e 4.0 LICENSING _ i The licensing function for Rancho Seco is split between the-Nuclea Engineering Department (NED Licensing) and Nuclear Operation m This split' dictates that the problem resolu-Compliancegroup(NORC). l tion level on licensing issues is at the Executive Director, Nuc ear Also, coordination of licensing issues is further made difficult by the fact that the licensing function within NED is itself split level. between the Plaza 50 annex and " design city" at the Rancho Seco s The NED licensing group has primary responsibility for emergency preparedness p1'anning, licensing support for the engineering de ~ process, and a technical secretariat function that makes assignmen licensing issue follow up and coordinates the Coordinated Comitme Future plans are to strengthen the analytical capability of the (CCL). group in order to interact with regulatory and industry groups on pro-The group is composed of a l posed studies and other analytical issues. f supervisor and four engineers with five approved vacancies. The NORC group is the main interface with I&E and Region V on These include inspection report inspection and enforcement items. responses, research and writing of 'LERs I&E Bulletin responses an In addition, the group has the primary respons-dissemination, etc. ibility for interfacing with the NRR group of the NRC on Technical Specification changes and providing safety impact analyses to th The group also provides a Chaiman and f for Sho11y amendment purposes. .SeEretary for the PRC and membership on the MSRC. The group is composed of a supervisor, two nuclear engineers, an engineering aide with an approved vacancy for a nuclear enginee I The latter position is currently filled by a contractor I technician. technician. 1 0 ) g : o t +

1 Overall, the effectiveness of the NED licensing function has been

• l The most recent SALP report downgraded judged by the NRC to be weak.

the group to the lowest category' rating of III and based that poor rating on alleged unresponsiveness and poor technical quality of-sub-These negative findings were attributed by the mittals to the NRC. me reviewers to be mainly due to the fact that SMUD had a small technical staff in licensing and was forced to rely heavily on contractors for It is also clear that an attitude problem these technical efforts. exists in the licensing area. SMUD is. attempting to upgrade the technical capability in the NED licensing area and offers have been made to experienced licensing engin

Also, from cancelled Near Term Operating License (NTOL) nuclear plants.

SMUD is attempting to improve the timeliness of submittals by tracking

However, commitments utilizing the Comitment Control Log mechanism.

LRS feels that inadequate management emphasis has been applied in both of these areas. For an organization to perform effectively in a heavily regulated 1 environment, the licensing function should be staffed and chartered to operate in a mode that is at least abreast, if not ahead, of current The term pro-active is used to describe this cap-regulatory issues. ability and simply means that the utility is out in front of the issues I A pro-and does not simply react as new regulations are promulgated. active licensing group will interact strongly with the design engin-eering and analysis function to develop possible design solutions. These design solutions will form the basis for a licensing strategy that will be developed with management to define the best course for SMUD to j pursue in accomodating new regulatory requirements, f Unfortunately,.at the present time SMUD is very weak in the licensing The two engineers in the NED licensing engineering and analysis area. group have approximately 3 years of experience each. The two engine One administers are devoted to mainly technical secretariat functions. the CCL and it appears the other's primary duty is to produce the,

i bi-weekly " Rancho Seco Modification Tracking and Status Report / Licensing i Change Status Report." ~ The only evidence of what would be considered pro-active-licensing ~ ~ activity was being provided by a contract licensing engineer, who was interacting strongly with engineering in developing SMUD's Appendix R program. With regard to the NORC group, both the SALP and PAS teams com-mented that the group appeared to be overloaded. LRS concurs with that observation. t As nosed earlier, the group is heavily involved in upgrading and maintaining the Technical Specifications and, at the time of this evaluation, there were some 15 major Tech Spec changes that had to be written, processed through the safety review comittees and iterated with NRR for final approval prior to startup from the next outage in early 1985. In addition to the Tech Spec changes and the concomitant Sho11y amendment submittals, two of the engineers in the group are heavily engaged in PRC and MSRC review comittee work. The supervising engineer l is both the chairman of the PRC and a member of the MSRC, while the second engineer is the secretary of the PRC. The chainnanship and f secretarial functions of the PRC both take an inordinate amount of the individual's time, estimated roughly between 60 and 80 per cent. This. of course, leaves very little time to conduct the normal business of the Regulatory Compliance office. As a consequence, although the majority 'of the regulatory compliance work is completed on time, the quality of the work has been judged by the group itself, and by its peers, to be p i deteriorating. 6 D o 5 e I L i

a a l As noted in the training section, there is no formal program for 3 training of technical staff. As an example, the junior engineer in the compliance section has been with SMUD for 7 months and bearsIthe primary ~ ~ responsibility for drafting the Tech Spec changes. In that 7 months time period he was given 8 hours of familiarization training on Tech 3 Specs and attended a systems training course on Rancho Seco. Because of the group's work load, he was thrown into a " sink-or-swim" environment with the back log of Tech Spec work. Much to his own credit and hard work he is now an effective contributor to the group. With regard to the split 1.icensing organizational issue, there does exist a hig.h probability that important issues could slip through without receiving the appropriate review. A case in point, in Sep'tember, 1981 the District made a comitment to the NRC to isolate an auxiliary steam line that' penetrated the HPI "A" pump room. Apparently, operations personnel were never advised of this comitment and consequently did not revise their operating procedures accordingly.' This error was detected f and an LER was issued in February of 1983 and the corrective action b stated was to rely upon _a new computerized comitment tracking system to ensure proper followup of comitments. Apparently, there are still coordination problems in the licensing area despite the use of the CCL. While most interviewees agreed that the CCL was a needed document, it was described as cumbersome to use and had no built-in method to assure that all parties to a comitment, not just the assignee of primary responsibility, were identified and their con-tributions tracked. To further guard against coordination problems, two a new inter-departmental procedures have been drafted. IDP-002, " INCOMING REGULATORY CORRESPONDENCE", and IDP-003 " OUTGOING REGULATORY CORRESPON-DENCE". The stated purpose of the procedures is to increase the coord-ination between the NED licensing group and the NORC with all incoming regulatory correspondence passing through licensing for assignment. thereby assuring no regulatory requests " fall through the crack." s P

4.1 Recomendations L-1 SMUD should move aggressively to fill the vacancies in the licensing group with experienced licensing engineers with major emphasis on ~ talent that could inmediately support the engineering design / licensing effort. L-2 SMUD should consider' consolidating the licensing function under one manager (OM-2). 4 L-3 Whether licensing is conso.lidated or not, the NORC group, if it keeps its present work load, should be increased by at least one or two nuclear engineers with additional clerical help. j L-4 In line with L-3 above, the practice of having an associate nuclear engineer solely responsibl,e for the generation of the PRC minutes should be reviewed and the option of having dedicated clerical support, including upgraded word processing capability, should be considered. L-5 Increased management emphasis should be applied to commitment tracking and timely submittals to NRC. i O e 1 i b . l

5.0 OPERATIONS The primary function of an operating department is to cortduct plant operations in a safe, effective, efficient and economical manner, and in ~ In order for the depart-compliance with all regulatory requirements. ment to accomplish its functions, it must be adequately staffed with In addition, highly skilled, trained, dedicated and motivated personnel. these personnel must be effectively and efficiently managed. Since the nuclear industry still faces a shortage of such personnel and the high skill levels required are attained by extensive training and re-training, it is imperative that SMUD develop and maintain training programs at all levels to insure that Rancho Seco has sufficient trained personnel in all positions to accomplish the goals and carry out the responsibilities 'of the department. In addition to these personnel, the success of the operational organizatien is heavily dependent on good operating procedures, con-trolled drawings representative of the actual plant conditions in the control room, an effective and safe work order and clearance control system, a controlled.means of obtaining information required by the operators and a well organized, condensed, coordinated manner of obtain-i LRS outlines its operational concerns ing industry related infonnation. l l as follow: Individuals appear to get trained to pass and maintain NRC o licenses and little, if any, management or supervisory skills are taught to individuals who are promoted to supervisory positions in operations. I Rancho Seco in 1981 organized to the six shift concept. l o Following the next refueling outage the plant returned to four l shifts because of a heavy loss of licensed personnel from The plant has since returned to five shifts and Rancho Seco. j k h i - b l l I "t 'IP' ""-m--g-..,w

' plans to go to six shifts.as soon as an adequate number of ~ trained and licensed personnel are available. It is a'pparent that substantial overtime has been required by operations to ~ support the plant during this period. Care must be exercised to insure " burn out" of key personnel does not occur. LRS has reviewed in detail approximately 50 of the current o plant operating procedures. Since most of the procedures were written during plant startup ten years ago, they do not meet present day criteria. In addition, many new and/or supple-mental procedures need to be written. Currently, a limited . number of procedures such as the Clearance procedure and the Abnomal Tag procedure have undergone or are undergoing revision. The system for controlling drawings at Rancho Seco appears to o be adequate. However', the system is not being maintained. A detailed review of several of the control room drawing " sticks" showed that they contain many pink and yellow drawings. In some cases, the yellow drawings date back to 1978. A major effort is necessary to audit and redraft the drawings to insure that the controlled drawings are totally updated and l accurate. In addition, the use of' uncontrolled drawings on I the control room wall and in the water treatment " shack" must . be teminated innediately. These drawings are utilized by personnel to perform critical functions such as develop work orders, align systems, establish system clearances and train personnel. A review of the control room log books (shift supervisor, o control room, abnomal tag and temporary procedure) was com-pleted. Both the control room and shift supervisor logs appear precise, neat and professional. The abnomal tag log was complete; however, some abnormal tags since 1979 are still outstanding. The temporary procedure program is a sound program and is being effectively implemented. The control and maintenance of the control room procedures o is the responsibility of the operations department. There has only been one internal operations and no exterrial operations audits of the procedure manuals. There does not appear to be a managerial structure of ind-o ividual accountability for plant personnel, especially opera-tions personnel. 0ver the years of plant operations and more importantly during the past few months several operational errors, such as the damage to a circulating water pump in September and to the canal pumps in October, or urred without a f detailed independent plant management investigation and follow-up corrective action. The regulatory requirement for the establishment of a Shift o Technical Advisor (STA) has been satisfied. However, an integrated working relationship with the operators has not been developed. A new Abnonnal Tag procedure has been dev-eloped that clearly defines the criteria for the use of ab-normal tags. It also requires the. sign-off of a maintenance engineer prior'to tag implementation. The sign-off is not the STA and when questioned as to why not, no clear reasons could I be obtained. LRS believes the STA, not the maintenance engin-eer, is the most qualified and trained engineer to review the abnonnal tags. l The Maintenance Infcrmation Management System (MIMS) is a well p o h defined and implemented program for the coordination, review, tracking, monitoring and close out of work requests. However, there appears to be an excessive backlog in the close out of g work requests. k L The Outage Coordinator does the planning and scheduling of the work requests during outages but not during normal operations. f It appears that during normal operation the interdepartr. ental a planning and scheduling results in wasted time and resources. p l* 48-O _m,., m.-. ,,-,,,,-._._-_.,- -_-._,-~._,.,,-, _,.__m,,,.._,w,cm,.-w.,,. __-w

) a-i 3 o The experience level of the operating personnel was reviewed. a The experience level of the shift supervisors, senior control 3 room operators and the auxiliary operators was quite good. Some-of the control room operators and most of the equipment attendants have little nuclear or plant experience.. Several licensed control room operators have less than three years of nuclear experience. o A control room shift change was witnessed. The change appeared to be orderly, professional and in accordance with good practice. o Since the control room and adjoining shift supervisor's office are extremely cramped for space, the plans to utilize the larger room adjacent to the control room for additional opera-tional space will be a most welcome addition. 5.1 Recommendations OP-1 Develop and implement a mandatory management / supervisory training program for all personnel promoted or hired into operations super-visory positions. OP-2 Develop and implement an expedited program to return to six opera-tional shifts to control the use of overtime and to improve requalification training opportunities. I OP-3 Develop and implement an extensive and detailed procedure review program to determine what operations procedures require revisions and what new procedures are required. OP-4 Develop a list of critical drawings required for operation, expedite the revision of these drawings and eliminate the use of uncontrolled drawings when completing critical plant operations. ? ) h )..

e OP-5 Develop a methodology of conducting independent review of operational - errors and establish a management system that assures delegation, authority, responsibility and accountability at the individual level .~ in the plant. OP-6 Consider expanding the use of the STA function into more plant activities, including Abnormal Tag engineer sign-off. OP-7 Study the benefits of developing a totally integrated planning and scheduling organizational concept. OP-8 The program to utilize the large room adjacent to the control room for additional space needs to be expedited. OP-9 SMUD should induce the NRC licensed personnel that have left Rancho Seco and are currently in.other positions within 5ff00 to return to operations or training at Rancho Seco. O e k L l l S b k-F - -

6.0 MAINTENANCE The efficient.and safe operation of a nuclear power plant is depen-dent on the support of a highly skilled and trained, well managed, motivated and organized maintenance organization. Anin-depi.happraisal of the Rancho Seco maintenance organization was conducted and the results of the two groups (Mechanical and Electrical-I&C) are highlighted as follows: Mechanical ~ o Management of mechanical maintenance is perceived as being co'nducted in a technically adequate fashion but utilizing a style which is both autocratic and intimidating. No opportunity exists in this organization to provide feedback from personnel performing specific tasks. Al'so, it appears that a climate of lack of respect for subordinates may exist. This is particularly true of the attitude toward the building maintenance mechanics. o During non-outage conditions, mechanical maintenance planning and inter-departmental scheduling are poor. This results in many wasted hours waiting for tags, clearances, and other department support. o The present mechanical maintenance training program is in- [ adequate. An apprenticeship training program does not exist. A program is under development, but was not available for review. o At department and safety meetings, individuals are instructed that it is mandatory to follow plant procedures; however, in at least one case, an individual was given a verbal order to f violate procedure. The individual refused and requested the order in writing. The order was then given in writing and the indivi, dual, completed the request. 1 I J. n_, __.,,,,7 n ,,._,.__,,.,_.,_._,,.,,,,_n_..,-..,,--___

The present plant clearance (tagging) Fecedure has been o deemed as unacceptable and a task force has been established to develop a new procedure. The results of the task force are expected in early November 1984. The present practice by operations to sign the clearance, "The foreman is responsible to insure clearance boundaries prior to work", is not an acceptable practice and should be discontinued.. The operators, not the maintenance foreman, have received system and system inter-relationship training and are clearly the individuals I responsible for determining clearance boundaries and adequately 4 installing tags. However, it is prudent for foremen and/or craftsmen to review tags and boundaries to the best of their ability. The SMUD supporting departments in Sacramento such as Personnel, o are perceived by plant personnel as non-supportive to the plant and its needs. As an example, it was stated that in late 1983, the 1984 manpower budget was approved which included some welders for Rancho Seco. The first welder arrived in September 1984 An integrated Rancho Seco program for the maintenance and I o i control of vendor manuals and technical information does not appear to exist. In some cases, uncontrolled and perhaps out-f of-date information is being utilized to maintain and/or repair plant equipment. I l Electrical-I&C i A maintenance training program for I&C does not exist and time o in grade is the dominant factor in promoting individuals to l journeyman. The electrician training program appears to be l l good. A department apprenticeship program is under develop-l nient, but was not available for review. l I l. ,,c n- -a -,--e,---.--- .-- -, -,,-,e

1 ( The 'ead I&C Technician provides supervision and direction to L o the !&C Technician Supervisors. Since the position of Lead IAC Supervisor is vacant and the Electrical-!&C Sisperintendent is almost fully occupied with administrative and technical committee work, the technician groups receive little, if any, direction and supervision. o As is the case of mechanical maintenance, the non-outage coordination of work requests is done manually by the depart-ment. During outage conditions all work request planning and scheduling is done by the Outage Coordinator utilizing a computerized program. o The I&C technician groups appear to have an excellent working relationship with the operating department. i o The average plant-specific experience level of the I&C group is in the respectable 3 to 5 year range, but appears to be dropping. The negat;ve trend must be countered by developing-and implementing an effective I&C training program. Such a program was said to be under development. P o There is a problem with the implementation of preventive ? maintenance (PM) procedures; however, the delinquent backlog P is decreasing. There were 140 delinquent PMs going into the h last[cheduledoutageandthiswasreducedto40atthecom-L .pletion of the outage. l o-There appears to be an excessive backlog of Engineering Change f Notice (ECN) related work requests in the I&C area. P e t L,

_L 6.1 Recomendations MA-1 Steps should be taken to correct the management style currently utilized in mechanical maintenance. l l MA-2 Consider the development and implementation of a total work management program utilizing a centralized planning and scheduling department for all plant conditions. MA-3 Develop and implement as soon as possible a maintenance department personnel apprentice training program. MA-4 Insure that all plant procedures. are adhered to and, when excep-tions are required, insure that appropriate procedural steps are taken prior to implementation. MA-5 Expedite the preparation,' review and issuance of the new Clearance i Procedure. I MA-6 Establish a responsive working relationship between Rancho Seco and I the St1UD supporting departments. l MA-7 Expedite the development and implementation of an integrated Rancho l ' Seco program for the maintenance and control of vendor manuals and technical information. This program should be coordinated and I controlled by the site document control organization, not main-tenance. i \\ MA-8 Expedite the filling of the vacant Lead !&C Technician position. l MA-9 Develop a corrective action plan to eliminate the backlog in the preventive maintenance

• program.

1 P t L s L

7.0 QUALITY ASSURANCE An effective Quality Assurance program, which includes ap effective - Quality Assurance organization is not only a Federal requirement of 10CFR50 Appendix 8. it is also a structured management approach that can and should be very beneficial to any nuclear utility company. Currently, the SMUD QA program, as described'in the Rancho Seco Quality Assurance Program Manual and the implementing procedures such as the Quality control Instruction Manual, minimally addresses all of the eighteen Also, the QA Department and SMUD management are having difficulty criteria. in adjusting to the new role of the QA Department as a line organization, instead of the pure staff function it had performed until nine months There are several experienced and qualified personnel in the QA ago. organization around'which an excellent organization can be built. Some specific observations related to Quality Assurance which include the nor.confomance/ corrective action and codes and standards activities are: i In general, the QA organization is not structured as an o organization with supervisors and leads along functional l 7 l lines. It is more a collection of individuals, much like a I staff organization, The formal educational level within the QA Department is very o high. However, the actual comercial nuclear operatiens experience is low and in need of strengthening. The QA Department practice of being reasonable may be admir-l o able, but in some instances the rules should either be enforced or the rules changed. For example, it is QA Department practice j within the construction activities, if a nonconforming condition j is found, to allow three or four days to correct the problem. l If the condition is not corrected in that time period, then an f i > I l

l 1 ) NCR is written. Also, the Technical Specifications require an ) audit of all Technical Specifications annually

However,

~ every eighteen months is the actual schedule QA is' working to, ~ which is perceived by QA to be satisfactory. Follow-ups of QA Surveillance Report open items are not being o conducted in the time frame required. It does not appear that C. an adequate tracking system exists to assure these follow-ups are conducted in a timely manner. SMUD management, both,.in Sacramento and at Rancho Seco, uses o the QA Department as staff to perfom a variety of tasks. This may show management confidence in the QA people, but as a ( result, the department spends a significant amount of its time on functions other than quality assurance. This in turn contributes to the QA Manager routinely by-passing all super-vision in his department and giving individuals specific work assignments which tends to further undermine the structure of ~ the organization. The salary structure of the QA Department personnel is generally o one grade lower than comparable positions in the Engineering Department. This could cause turnover problems in the future l and does presently cause recruiting problems. The site QA group was directed by the QA Manager ~to stop doing l o audits and only do surveillances early..this year in order to respond to an NRC item that indicated that QA was not involved j enough with the actual work. The surveillances are not done in accordance with a pre-planned schedule and for the last eight months the total hours per day devoted to this activity I have averaged approximately three hours for the total group. b Surve111ances of operations activities (RO-SRO activities) are h not being perfomed by QA. I I i ; i J

o The QA Department is not routinely involved in Class 2 items or fire protection items, or in-service requests:which could be used to repair or service Class 1 items. o The District and Department goals and objectives are not known by the QA Department personnel at the site. o Table 7-1 indicates those areas of Appendix B that lack complete or partial policy and procedure coverage. The site QA group do'es not have a file of the codes, standards o and Regulatory Guides, etc. that apply to their routine duties. o A comprehensive program for trainir.g affected SHUD personnel in the QA Program Manual and the QCI Manual and subsequent revisions do not exist. Training in the QA Department consists primarilyofon-the-jobtraining. o Serialized work requests have not been reviewed by QA for four ~ i to six months and QA does not mutinely review other Class I work requests. o The QA program does not address packaging and shipping of low level radioactive wastes. o 3ackground checks are not being routinely performed by SMJD for their auditors and inspectors. o Operations QC is performing engineering surveillances in addition to their QC functions. This dilutes their primary l l inspection function. o NCRs are not being processed by site QA in a timely manner. , l

The QA Department does not reference one-third of their QA 3 o procedures in their audit schedule and they only reference approximately fifteen of the Station's administrative pro-cedures. Items such as Mod Test Program, Work Requests, Procedures, Records Management. Turnover and Release of ECN Packages, Radwaste Control. Fire Protection Program, etc. are not referenced. All of the Construction QC inspectors are contractor personnel. o The QCI's are generally out of date (some instructions by o severalyears). A comittee was formed about two years ago to rectify this, but it does not meet very often and has not been very effective. QCI #7 requires a Corrective Action Coordinator within QA. o This has never been a functioning position and audits of this area have not addressed this fact. QA Department audits are primarily audits of paper and there o does not appear to be a close relationship between the surveillance i program and the audit program, which is primarily due to the functions being performed by two different groups. L 7.1 Recomendations l l~ QA-1 Revise the QA organizational structure along more traditional lines and identify supervisory and lead positions (refer to Recomendation ~- OM-2). OA-2 Revise the written QA Program Manual along more traditional lines, s such as eighteen sections in order to more closely track and 1 L. identify with the NRC requirements. g l . e-8. . = _ - - _ _ -

=__ i QA-3 Update and supplement the Qua'lity Control Instruction Manual to adequately and accurately provide implementing procedures for the i QA Program. Consideration might be given to changing the name to Quality Procedure Manual and include the four or five QAIPs that exist. Consideration should also be given to removing the NDE and welding procedures and putting them under a separate special l processes procedure manual. 0A-4 Revise the QA prograrito assure QA and QC department involvement in all QA Class 1. comercial grade to be used on Class 1 systems and l selected Class 2 activities. This would include, as a minimum, QA Department review and approval / concurrence of the Class 1 (and comercial grade) purchase requisitions and work requests and changes to both prior to their release. CA-5 Establish a comprehensive QA training program for all nuclear personnel who have responsibilities in the QA program. CA-6 Provide for QA and QC involvement in packaging and shipping of radioactive materials (low and high level). 0A-7 Establish a program of verifying education and experience records of all audit and inspection personnel (both SMUD and contractors) prior to their use on safety-related activities. 0A-8 Re-evaluate the audit and surveillance program to assure it covers all of the important safety-related procedures and work activities. Ok-9 Establish a system to assure timely follow-up of open QA Surveillance Report items. (

,A MATRIX Q Appendix B Criteria, QA Program Section QCI Section 1 I Organization ( II QA Program III Design Control 2, 3 and 7 5 and 11 IV Procurement Document Control 4 4 and 10 Instructions Pr.ocedures. 7, 20, 24 and 25 V and Drawings VI. Document, Control 18 (partially) 9 (partially) VII Control of Purchased 5, 10 and 11 6 Material, Equipment and Services VIII Identification and Control 8 of Materials, Parts and Components IX Control of Special Processes ~ 9 101, 102, 104, 105, 106, 109, 110, 111, 112, 113 and 114. X Inspection 6, 12, 13, 16, 107 and 108 21 and 29 ( XI Test Control 26 XII Control of measuring 14 (partially) f and Test Equipment XIII Handling, Storage and 15 Shipping XIV Inspection Test and 16 (partially) , Operating Status g XV Nonconforming Materials, 17 1 and.3 Parts and Components l XVI Corrective Action 27 7 and 13 XVII QA Records 18 (partially) 9 (partially) XVIII Audits 19 2 and 8 e Table 7-1 P 6 ?

8.0 TRAINING A well developed and effectively managed training organization is

instrumental in the support of an efficient, safe, reliable nuclear power plant. An in-depth appraisal of the Rancho Seco Training Department shows that the training has primarily focused on the licensed operator training and the requalification training. The success of this program has been reasonably good; especially the June 1984 NRC license examina-tion which was 100% successful.

However, the success of this program has been in part the result of a large dependency on contractors. Fourteen of the sixteen contractors in this program at Rancho Seco have been on site for extended periods, some for as long as 5 years. These contractors have become extremely knowledgeable about Rancho Seco and its systems. In this program only the group supervisor is a SMUD* employee. This dependency is extremely expensive. Although continuity of instructors, which is vital to a good ~ training program, has been good. SMUD employees would add strength to the training organization. To establish SMUD trainers, it is h important to remember that trainers have to be certified to serve as licensed operator instructors, which req'uires being qualified on the ( l Rancho Seco plant. This qualification would require approximately one full year of work. g i L The requalification program required by regulatory requirements also appears to be well done, but it too is being implemented by contractors. Since the plant is operating on a five shift basis, the time allowed for the operators to spend in requalification training is limited due both to shift ' rotation and overtime requirements. g L Additional observations are as follows: P I The supervision of the training organization has a great deal o P of operating plant experience. This has been valuable from a I license point of view but the co plexities of managing a .. _, _.,,., ~ -,,ww n,,,,,,,,,w,,,a-.-a,,, ,,,,n,-

complete training facility, as is required at a nuclear plant, requires leadership with broader training program ~ views. The program for review of SOER, industry information, etc. was o reviewed as part of the licensed operator requalification program. The program appeared satisfactory, but the limited time for training has impaired the program. The Nuclear Training Superintendent has tried unsuccessfully o to hire permanent SMUD trainers. Not only are qualified personnel hard to find, the SMUD hiring practices have not i been supportive. It is important to understand that the ( reliance on contractors will continue until the recruiting and hiring roadblocks can be removed. ~ o The Training Department is not involved with Quality Assurance. Fire Protection and Emergency Plan training except for personne,1 C and facility scheduling. o All of the training records are maintained on a manual system. The current security /ALARA computer system which was originally p scheduled for early 1981 has just recently been put into oper-9 This system was to include maintenance of training ation. b records; however, during the demonstration test it was deter-mined the training functions of the system cannot be utilized. .o The non-license training program is supervised by a contractor ~ and the program is under development. o The maintenance training section is staffed with SMUD personnel and is currently developing an apprenticeship program with the l_ l I affected departments. \\ h. 5 .u = =. - - -. - - -. -. -.

1 i i i o SMUD has connitted to INP0 accreditation of its training activities and has concentrated on licensed, requalification and non-licensed operator training. A second pre-accreditation INPO visit this fall appeared to indicate that INP_D accreditation in these three areas may be achieved in mid-1985. Such accreditation would appear to be dependent on retaining the present complement i of contractor trainers' for the three areas since there would be no way to qualify SMUD trainers within 8 months. Accreditation in the other seven areas is scheduled by the end of 1986. Given the present status of this training, it seems unlikely that this g5a1 can be met for all seven areas. Reliance i .on contractors for this accreditation will be both very expen-sive and time-consuming. In addition, it fails to develop SMUD competence in the vital training area. Experience with other utilities shows that these accreditation tasks can be accomplished without such excessive reliance on contractors. ~. o In the electrical-I&C area there are four training areas -- electricians. electrical technicians. ISC and computer special-i i ists. Instructors have been assigned for the first two groups l and one instructor has been designated for the I&C group. i Program plans for electricians and electrical technicians have been prepared by the Training Superintendent and concurred in I by the Electrical-ISC Supervisor. l o In the electrical maintenance area. a good deal of training has taken place. Of the 30 courses planned for 1984. some 14 were given. 6 cancelled. 6 rescheduled and 4 set for October / l November. Courses,such'as prints and references, valve actuator maintenance. AK-25 breaker maintenance and DeLaval diesel I&C systems have been well rectived although workshop facilities are lacking to make the training fully effective. l l. 1.--

L o Two instructors in the chemistry-radiation area are developing-lesson plans. One has a master's degree in comunications and has good plant experience. Both state that training is well f received by chemistry-radiation technicians. Their assignment, especially scheduling, will be simp 1tfied by splitting the chemistry and radiation protection organization into two entities so that a technician does not require training in both disciplines. These instructors face a challenge, comrron to other instructors, of developing new courses while devoting timet to implementing the on-going courses. Some 10 to 20 man-hours of development may be required for a one hour course. 8.1 Recomendations TR-1 A program for the replacement of training contractors must be developed and implemented a' soon as possible. s TR-2 As additional licensed operating personnel become available. licensed SMUD operators should be.made available as trainers. TR-3 The current training facilities are inadequate. A separate training f building capable of housing all of the training department's needs and the simulator should be designed and built expeditiously. TR-4 The procurement of the simulator currently under study should be expedited. TR-5 Replace the lead position in the INPO accreditation program with a .

• SMUD employee.

In addition, key personnel should visit other B&W facilities to gain experience on the job and task analysis. TR-6 Conduct a management review of the INPO training program accredit-ation plans and processes to assure that the technician resources f available for training are consistent with the comitrents. l k l l

1 I \\ l o TR-7 Assign a SMUD employee to lead the contractor effort of developing a lesson plans and system manuals. a 3 TR-8 The delivery of a computerized system for the training ~ department records should be expedited. C D C 9 O W D C C O h L l - o ?

l PLANNING. SCHEDULING AND OUTAGE MANAGEMENT 9.0 The planning and scheduling is accomplished at Rancho Seco in the Outage Supervisor's group that reports to the Nuclear Operations Departm The group is headed by an Out' age Supervisor, who at the present Manager. time is a B&W contract engineer but had previously served with SMUD as the STA supervisor; an Outage Coordinator, who is an ex-shift supervisor-SRO licensed and extremely knowledgeable about the plant, its systems and their operations; two maintenance planners that are both contmetor Plans are to fill all these positions with employees and three. clerks. SMUD employees in 1985. During outages, the group is supplemented by the addition of shift managers, drawn from the operations department, who report to the Outage Supervisor. The shift managers provide outage management coverage for all shifts. i t Outage planning is accomplished using the computerized Project /2 In addition to the normal refueling outage planning, the group system. has devel'oped " cook book" Project /2 schedules for mini-outages caused by C plant problems such as steam generator tube leaks, control rod drive stator failure and high pressure and low pressure turbine failures. C During outages the Outage Coordinator is in tactical control of the ( This key individual holds a daily morning meeting at the start plant. of the day shift with maintenance, operations, construction and E8QC person The meeting is to update the work that was accomplished on the back ~ All work in the Rancho Seco shift and to plan the work for the day. J plant is handled by a formal work request (WR) and WRs that are critical D the outage schedule are prioritized daily, employing computer printout i is sheets. iT The Outage Coordinator also holds a similar scheduling meeting at y the end of "the day shift and start of the second shift to update the i work completed and plan for the second shift. . <o s.

Following the Outage Coordinator's meeting at 0730, the Outage -Supervisor holds a meeting at 0815 with plant management and engineering l personnel. The Outage coordinator updates the group on plant status and the meeting concerns itself mat'ly with problem resolution and work-n around programs. This'1atter meeting is the primary interface meeting 'between operations and engineering on outage matters. The organizational concept of shifting plant management from the Plant Superintendent to the Outage Supervisor during all plant outages is quite comon in the industry.. What apparently makes it work. so well at Rancho Seco is that during normal operation the Outage Coordinator plays an important role in the daily planning of key maintenance activities. i After coordinating with the operations department during the morning shift turnover, where critical work requests are prioritized, the Outage Coordinator conducts a morning planning meeting with maintenance personnel to assign prioritized work requests. The Outage Coordinator's close involvement.on a daily basis during normal operations keeps the outage group infonned on plant conditions and allows for a smooth transition i l with no time lost getting up to speed when an outage occurs. During an outage the actual plant modification work is accomplished l by either the NED construction group or the operations department main-I tenance personnel. The split is generally made along the lines of size and nature of the job. The larger construction type activities that have few interfaces with existing plant systems would be accomplished by the construction group. The more complex and plant-system interrelated ECN's would be the responsibility of the maintenance group whose system i was being modified. Th: NED construction group is composed of 8 engineers, including the Resident Engineer, and one approved vacancy. There are also 7 i clerical and drafting support personnel. l = -

i To accomplish the ECN installation work, the group relies on craft The NPS j support from the craft site support contractor, presently NPS. \\ contract is administered by the Manager Nuclear Operations and both ~ maintenance and construction call upon that contractor for craft support. l During refueling outages craft support is approximately 200 personnel. For nonnal operations the steady state craft support level is approximately 100-120 with roughly an 80/20 split between construction and operations. respectively. When a system has been modified, either by construction or maintenance. there is a formal turnover and acceptarice procedure prior to that system being placed in operation. The interface group that accomplishes this is the Startup Group. The group is organizational 1y located in the i electrical-IAC maintenance group. This formal turnover is governed by Administrative Procedure AP 44. i l The process embraces the typicaT: joint walkdown of the system, a turnover l punchlist, a formal method for controlling testing or tie-in to an existing plant system and a formal method by which operations accepts i the modified system. AP 44 has just been completely rewritten to more l clearly define ttie interfaces and responsibilities of the various groups f and, if followed, should assure that the important elements of systems completion, turnover, acceptance testing and acceptance for operation are covered. f During the interviews there was some concern expressed about the I construction group being organizational 1y separated from the plant l operating organization. Supposedly the concern grew from the fact that l the bulk of the construction work had potential for interacting with plant operations. In the Organization and Management section of this report, an' organizational change of relocating the construction activities [ from engineering to planning, scheduling and outage management has t ? ) P l( -.

l ) I been recomended. Since the majcr irteraction of construction is with operations, involves operating systems and obtains the required con-struction crafts from the maintenance contractor controlled by main-tenance, the organizational inter-relationships will be strengthened with this move. On the negative side of outage activities, a number of persons interviewed indicated that the whole organization seemed to lack the necessary esprit de corps and drive to jump on critical path items and work them around the clock to get the plant back on-line as soon as possible. This coment came mo,re frequently from those who had previous nuclear utility experience. ~ , Some typical coments were. "an apparent lack of accountability in individuals who were poor performers," " poor cooperation between the various maintenance groups." "the absence of top-to-bottom management emphasis on improving plant performance" and that "SMU,D is reimbursed by PG&E whether the plant runs or.not." 9.1 Recomendations PS&OM-1 Consistent with the recomendation in the Organization and Management section of this report, the Goals and Objectives adopted by the Board and as translated into management ob-jectives by SMUD management have to be made clear and concise and passed down through all levels of the organization. This is especially true with regard to cost / benefit considerations of keeping the Rancho Seco plant up and operating and the actions necessary to return the plant to. operation after a ~ ( shutdown. ( e P l

\\ ~ PS&OM-2 Consistent with recomendation OM-2, relocate the construction functions into the Planning Scheduling and Outage Management organization. PS&OM-3 The Outage Coordinator's total control of all work requests during outage activities has proven to be most beneficial. Movement to a centralized total planning and scheduling organization for all work activities during all plant con-ditions should be considered. M e e D 9 8 C C C l c 70-i .-..._,-.3.3,-_3--.. ,--.--m__..,_---

4 t ca 10.0 CHEMISTRY AND RADIATION PROTECTION The.present organization has a single superintendent in charge of ' both chemistry and radiation protection and the supporting technical staff, with the exception of a staff health physicist and chemist, works on rotation to perform both chemical analyses and radiation protection activities. During outages, the most critical period for radiation protection, there is great reliance on contractors, both as superviso.rs and as technicians. a j Given the increasing demands and more rigid technical requirements, industry practice is to split chemical and health physics operations l into separate functions. This permits specialization and a higher degree of expertise to be developed. Extensive interviews with the C&RP staff and technicians led to the conclusions that: i .The current technician training program is inadequate. In l j o addition, the skill levels of the technicians do not satisfy I the criteria esteclished for the position. i. The organizational structure is too heavily dependent on con-o l tractors to perform normal operational duties. i S The Rancho Seco chemistry and radiation protection organization o is typical of industry organizations ten years ago. The tech-j l nical skill required of these positions today his increased l substantially and no longer lands itself to a combined group. i 15.1 Collective Radiation Exposure The collective exposure of the Rancho Seco work force is measured in person-rem i.e., the number of persons multiplied' by their average radiation exposure. Fig. 10-1 illustrates how the Rancho

T Seco collective exposure has varied from 1975 through 1984. The dotted line in the illustration represents the average exposure per PWR unit. It will be seen that on average Rancho Seco has been operated at a level of exposure well below the average for PWR units. This is illustrated in Fig. 10-2 where the average annual person-rem for all PWR units, reckoned from the date of comercial operation through Jan. 1, 1984, has been plotted. Rancho Seco's average of 343 person-rem compares favorably with 493 person-rem for all PWRs. Among the B&W units. Rancho Seco ranks second. This represents comendable control of worker exposure. The upward trend of collective exposure starting in 1979 reflects outage requirements. some of which involve NRC required backfits and plant modifications steming from TMI. The peak value of 689 person-rem in 1983 reflects steam generator repairs where radiation levels of 20 rem per hour are encountered. 10.2 Individual Worker Exposure, SMUD e ployees and contractors who enter radiation controlled areas (RCA's) are ordinarily limited to 0.3 rem per week and no more than 5 rem per year. Throughout its comercial operation no worker at Rancho Seco has received more than 5 rem in any year. In 1983, of 1.558 workers who were monitored for radiation exposure. 655 received less than 0.1 rem. This is about the amount of exposure received by a person living in the Saramento area as a result of esposure to cosmic rays and to the earth's natural radioactivity. An additional 612 workers received from 0.1 rem to 1.0 rem in 1983. Exposures above 1 rem annually were: No. of Persons DeseRange(Rem) 232' I to 2 46 2 to 3 6 3 to 4 0 Above 4,

f l l Workers having measurable exposure to plant radiation averaged 0.51 l , rem in 1983. Overall, this represents good control of radiation exposure. To put this average exposure in perspective'. it is noted t that in 1983 more than 4 million Americans received about-0.5 rem 1 each as a result of a single medical diagnostic x-ray examination, the sacro / lumbar diagnosis. l l Analysis of worker radiation records for the 1975 to 1984 period j shows that only approximately a dozen SMUD employees received more than 10 ran in their career. Only 3 workers accumulated from 15 to j l '18 rem as a result of occupational exposure at Rancho Seco. l 10.3 Control of Contamination f i i The radiation exposure detailed above relates to dose received as a l result of radiation external to the body. Workers may also be exposed to airborne particulates which represent p' tential for internal o 1 1 contamination. Air sampling identifies such contaminated areas [ 1 within the plant and, as required, protective clothing and respira-l 1 tors are worn. Contract workers arriving at the site and on tem-l inating are given a whole body count to identify the presence of an'y i j internally deposited radioactivity. SMUD employees also receive i periodic whole body counts. Records of these measure.ents are retained as documentary evidence in the worker's file. Examination of whole body count data for the 1984 steam generator work was studied and no cases of significant uptake of plant-produced radio-l activity were identified. I l l Plant areas requiring respiratory protection are posted and entry [ into such areas requires an appropriate radiation work pemit. l. Workers issued respiratory protection are required to pass medical f l tests and are face-fitted with a respirator. 1 4 t l ! _.._____n.._,u.._, c..

4 10.4 Radiological Events While the above radiation controls serve as an indicator of good health physics practice, one must also consider the frequency and severity of significant radiological events. An event of signifi-cance occurred during the July,1984 outage that involved steam generator work. A piece of metal later identified as part of a thermal sleeve for a steam generator tube, was picked up from the ] upper channel head of the '8" steam generator and tossed out of the i steam generator hatch by a SMUD worker. A contractor radiation protection technician noted that his radiation meter went offscale and covered the thermal sleeve with a lead bisnket. The area was j l not posted and no one was notified. Four days later the thermal i sleeve was found during a survey. It was lead-blanketed, posted and supervisors were infonned. Subsequently, the metal sleeve wa's found to measure 120 rem / hour contact. Thus, it posed a potential for worker overexposure. An NRC Region V report, dated September 21, 1984, described the l event sequence in detail and identified violations of procedures iri i I radiation protection. These were discussed with SMUD officials at an enforcement conference held on September 28th, at which time SMUD presented a detailed chronology of the event and estimation of worker doses. A consultant was subsequently retained to evaluate i potential worker extremity doses. At the present time it appears that no worker received an extremity dose in excess of allowable

limits, s

While the event is disturbing, because of the significant deviations from good health physics practice, it is noteworthy that Rancho Seco radiation protection technicians responded well to the event following the survey discovery and prepared an investigative report which critiqued deficiencies and made 12 specific recomendations j l for corrective action. Unfortunately, this report was not made 1 available to the NRC or to the public on a timely basis.. ,w, y, =-.-.. ..y.w.-_.. .. ~.. _

p /* .sf

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[ll 4 i, i ? t Overall, the 1975 to 1984 re:ord of ractation protection at Far,:no Se:o has been gooc and significantly better than :ne P'4R ir.destry average performance. Nonetheless, an effective radiation program must be constantly implemented by in-field supervision, preferably by SMUD workers as ooposed to contractors, and by continuing train-ing and retraining of workers in !!F fundamen als and in confom.ance to written procedures. 10.5 Chemistry Chemistry at Rancho Seco has an unusual problem compared to most other nuclear plants in that power level changes are made at pre-planned intervals over the year as base load reouirements and dispatch economics change. This imposes transient condition's on the reactor. coolant and feedwater systems more often than is the case for a fully base-loaded plant. The staff chemist is a com-petent individual who pays attention to careful trending-of the primary and secondary, water parameters. Chemistry laboratory facilities are cramped and should be upgraded. Comunications between Chemistry and Operations could stand improvement. 10.6 Recorrend.itions CRF-1 The present combined chemistry / radiation protection organ-ization should be split into separate units to allow for upgrading the perfort.ance of each activity. s CRD-2 Supervisors need to spend more tirre in the plant. In part-i icular 51100 supervisors should not delegate their respons-ibility to contractor supervisors.

CRP-3 SMUD should attempt to eliminate all contractors except during outages when more HP t'echs are necessary. Contract. workers should be carefully screened with written examinations and their training in Rancho Seco procedures should be d'ocumented. CRP-4 Supervisors should make sure that technicians are aware of significant radiciogical/ chemical events that occur at other nuclear sites. CRP-5 Documentation of personnel contamination should be executed carefully, including trending of significant contamination. ) CRP-6 Rigoroas' scheduling of all technicians should be done for training in chemistry and health physics. CRP-7 Supervisors should participate in lesson plan development and approve all such plans submitted by the Training Department. CRP-8 Radiation levels for specific plant locations should be tracked on a systematic basis and the data acquired should be trended CRP-9 Coneunications with Operations should be improved so that both chemistry and radiation protection supervisors are aware of i changed conditions in the plant. CRP-10 Workers should be given additional information on the health effects of ionizing radiation so that they are more aware of current knowledge in this field. CRP-11 Unusual radiological or chemical occurrences should be thor-oughly investigated and, where advisable, sumary reports L should be issued on a timely basis. l f P 1 ~

L 3 CRP-12 All workers exposed to radiation should be given written notification of their annual and cumulative plant. exposure. o CRP-13 Splitting of the CARP organization into two units 1111 prob-ably require adding to the technical staff. Such additional 0 personnel should be recruited on a timely basis and every effort should be made to obtain highly qualified individuals. o CRP-14 Chemistry laboratory facilities should be upgraded. CRP-15 Dosimetry should be organized as an entity headed up by a qualified health physicist. O CRP-16 Replacement of photographic film badges with TLD's should be c considered. CRP-17 Radiation records should be reviewed to make certain that the data are adequate and easily retrievable. CRP-18 SMUD audits should be made prior to INPO audits to make certain that previous recommendations have been carried out and that new adverse findings are minimal. CRP-19 ALARA should report to the plant Health Physicist. CRP-20 Health physicists in SMUD should be encouraged to achieve ~ certification by the American Board of Health Physics. CRP-21 The plant HP should prepare a quarterly tabulation of sig-nificant radiological events taking place at other sites and circulate this to training and to the RP staff. 0 7/-

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1 2 3 11.0 ALARA The present ALARA unit operates under the Nuclear Fuels Management / Health Physics organization in nuclear engineering. While this arrange-ment does allow for ALARA review of plant modifications, this constitutes only a small part of an effective ALARA program. A functional ALARA unit would best be located at the plant under the direction of the plant Health Physicist. The essence of good ALARA is careful review of g potentially high exposure work activities and well coordinated pre-planning of jobs, followed by close ALARA coverage of and monitoring of the actual work. A. free-reving ALARA coordinator provides insurance that worker. dose is being kept to a minimum. ? The effectiveness of the group would increase if exposure data for activities at other sites was incorporated into Rancho Seco planning and a tracking system was developed to monitor dose reductions on repetitive ~ ~ outage tasks. 11.1 Recorrendations l AL-1 ALARA should report as a separate function to the plant Hea th I Physicist. AL-2 Insure that the ALARA function is staffed by SM1)D, not a f* contractor. AL-3 Develop a detailed ALARA training program. L-4 Provide the support required to insure that ALARA has high plant visibility and the management backing to terminate activities that could result in unnecessary exposure to personnel. b e me l" 80-6

Al-5 Maintain. detailed'dosedats"onoutageworktopermitthorough ~ post-60tage ' ALARA analysis ' of high; exposure activities. i i b. . AL-6 Prepare an annual ALARA report summarizing outage and annual exposure data with'recomm' ndations for achieving future ALARA, e goals. t 9 l 9 J 9f e r-e t E o 4 1 g ? b I D ? .d ) 's s l e f ? l ' F / 1 'O c., .---.----w-.- ,,-_.-,s ..., -. _ _. -. - - - -,.. ~.... - -.. - -. - - -. _ - - -,. - - -,

12.0 EMERGENCY PLANNING ' _. _3 k .4 3{g> .g t 4 The location of Rancho Seco in'a'n isolated area with low near-plant ~ population density is favorable to the development of a good Emergency Radiological assessment. coordination appears,to be. satisfactory. . Plan. The' Emergency' Operations Facility, although more distant from the. nuclear site than is' comon, is wel1 designed and is adequately equipped.

t Emergency Planning appears to be functioning quite well with personne1'who appear to be both knowledgeable and dedicated to their

>w work. 12.1 Recomendations EP-1 A qualificatior. card system should be developed for the purpose of checking off the training requirements for persons engagedinemergency[,planningdrillsandexercises. o ks i o b a n \\ l 1 t l P .s2 l l.--,--_.-

13.0 ENVIRONMENTAL Steam g'enerator tube leaks in May 1981. November 1982 and September 1983 resulted in the release of small amounts of radioactivity to, waste s Results of enhanced environmental monitoring were reparted in a water. , public document, the 1983 annual SMUD report on Effluent and Waste Disposal. These included analyses of fish, algae, aquatic plants. In water, mud, silt. fresh milk, wildlife and edible vegetation. addition, there was constant recording of off-site radiation at 29 close-in off-site stations as well as at 15 stations out to a distance of 24 miles from the site. p Examination of the data indicate that off-site exposure of the general populat' ion has been minimal and less than the nonnal variations ^ that occur in the natural background due to extraterrestrial radiation We believe that the public health and and terrestrial radioactivity.' Furthermore, there has been full dis-safety has been well protected. closure of environmental monitoring data. However, Rancho Seco represents a dry land site, unlike reactors located on or near lakes or rivers. i which serve as a dilutant for disposal of liquid radioactive wastes. hRC regulations specify the computation of dose to a " member of the 1 public" thiough analysis of the critical pathway, in this cane, the l liquid pathway. to the individual. It is a very conservative calcula-tion that leads to an over-estimate of dose. The 1983 Effluent and l Waste Disposal report estimated a 0.1 rem whole body dose for radio-l cesium uptake through the fish-to-man pathway. Regulatory Guide (NRC) A more l 1.109 specified an annual fish intake of 46 pounds of fish. l realistic estimate of actual dose is obtained by making a whole body count and here a measurement of the most probable dose to the individual l showed no significant retention of cesium-134 or 137. By way of per-l spective a person who caught fish in a downstream pond demonstrated an L insignificant body burden of radiocesium. This was less,than that connon for most Americans following global fallout of radi6 activity from at.ospheric testing. T l 1 l L ~ 1

SMUD has undertaken extended surveys of downstream radioactivity uptakein.the'floraInd' fauna ~o'utsibethe'plantpYotectedareh. '~ The' release oN r2d'i$a$tivity to ths water' pathway has'been mon'itored and &b from 1980 through the first q'uarter 'of 1984-the total quantity of cesium-137 released amounted to 0.335 curies. Uptake of this radioactivity by 4.fish'(bluegills and large mouth bass) has been measured in numerous fish s i samples and has a mean value of 4.3 picocuries (0.0000043 mil 11 curies) 'per gram'of wet ' flesh. An ingestion of 46 pounds of such fish each year would imply a body dose of.'012 red per year. This would be about half the annual' dose delivered by the ' naturally occurring radioactive pot-assium (K-40) in one's body. Addidonalperspectiveonradiationdoset6humansissuppliedfrom the annual dose data collected at the '44 stations located outside the Rancho Seco protected area. A station located at the Jackson Civic ~ Center,10 miles east of the site, registered 0.091 rem per year in 1983. This radiation dose, due to natural radiation, was 20% higher ~ than the comparable annual dose measured at seven on-site stations. f These measurements are supplemented by independent observations taken at NRC and State stations, which validate the SMUD findings. )- ( Scientists from the Lawrence Livermore National Laboatory (LLNL) f have been retained to provide an independent assessment of the plant-p dispersed radiocesium. 13.1 Recommendations I EV-1 SMUD should consider reorganizing its environmental section, e which now reports to the manager of Nuclear Engineering, f so that there is better evaluation of the NRC RETS program. k This could be done by assigning responsibility for environ-h mental programs to the Plant Health Physicist. 1 F 'O., 'i

h EV-2 The LLNL report on radiocesium releases should be released to the public as soon as feasible along with a cover statement sumarizing the results in a manner that will be ~ easily under-stood. EV-3 SMUD should make available to the media and to the public an annual summary of its environmental findings, expressed in a form that permits easy public comprehension. 9 e = l e e G e d et se a9 1 ,e d o e e G m 9 d i L.

14.0 PROCUREMENT AND STORES Therecentre-organizationthatplacedallofthewarehodsingunder However,-the concept control of a single organization was a proper move. of mixing safety and non-safety related items together is a questionable I practice. Some specific observations related to Procurement and Stores activities are as follows: Conmercial grade items. are generally treated as Class I by o stte QA; however, the written rules regarding commercial grade are less stringent than those for safety-related Class I. In the warehouses on site, Class I, II, commercial grade and o non-class items cannot be visually identified as different from each other, either by their location in the warehouses or by identification on the item. Some items on hold in the warehouses are co-mingled with o acceptable items. Some warehouse personnel have not received adequate training o in the QA requirements for storage and identification of safety related items. The system relies on the Stores Department stock records cards o for proper classification of items, i.e Class I, II or commercial l However, not all stock records cards have been reviewed ( grade. [ for classification. The practice has been to' review the classif,1 cation when it is necessary to re-order the item. I b ~ Audits by QA of the warehousing (storage) practices have not o detected any problems. ~ l e, e

o SMUD'S envolvement with PIM (Pooled Inventory Management) is an excellent move. The availability of critica1 ' spares is greatly enchanced by SMUD's envolvement in this program. o Access into and out of the warehouses is loosely controlled. l 14.1 Recommendations PS-1 Re-evaluate the system for procurement of comercial grade items that are to be used in Class I systems to assure that these items have received adequate Engineering, QA and QC attention from the initiation of the purchase requisition through item storage and installation at the site. PS-2 Consider a separate nuclear purchasing group within the General Office Purchasing organization whose sole duties are to perform nuclear grade purchasing activities. These people should have had prior experience in nuclear purchasing and be properly trained and. indoctrinated in the QA program and procedures. PS-3 Revise the present practice of co-mingling Class I, II, and commercial ( grade items with non-class items in storage. Also institute a system for positive visual identification of safety-related items. Attendant with this recomendation is training the aporopriate personnel in the new system. PS-4 Establish a more positive system of control for entrance to and egress from the safety-related storage facilities. [ , PS-5 Expedite the placement of item classifications on the stock records cards. I l. -

15.0 RECORDS MANAGEMENT AND DOCUMENT CONTROL The Station ha's established a small, but solid, core of? knowledge-able records management personnel. The scope of their activ+fies is - still somewhat limited from an overall nuclear program aspect and staffing -has come along slowly, but steadily. The organization has good facilities and equipment and is well organized and managed. Document control in areas other than that controlled by the Records Management section is somewhat dis. jointed and lacks an overall plan. Some specific observations related to records management and document control are as follow: o There is no station administrative procedure or quality l control instruction on document control. 1 The Technical Manual [ library was transferred from control of o Records Management to Maintenance. o There is no requirement for the sections within the different nuclear departments to purge their active files on a routine basis in order to get their records to Records Management for I microfilming on a timely basis. o The only records storage facility at the site that meets all of the regulatory requirements is under control of site QA. o Site QA stores their QA records in their vault in file cabinets and boxes. Entry into the vault is not well controlled and the records staff is minimal and not trained in records management. The QA Program Manual states that the records ~ will be stored in accordance with the 1583 edition of ANSI /ASME standard NQA-1 supplement 175-1. This is not being implemented. i,

k ~ o A principal delay in the microfilming of the work requests is j y in Maintenance while the Maintenance History infortnation is being entered in the computer for MIMS. y P There is no limit to the number of yellow sheets that can be o f outstanding against a drawing. This means that the Operator f may have to look through many yellow sheets before he can determine the current status of his plant. Also, if the drawing he is looking at has a pink sheet against it that has been completely pre-operationally tested but a yellow sheet has not been issued yet, then that information will not be f available to the operator on a yellow drawing for 24 to 48 hours. o All 25.000 original drawings for Rancho Seco are stored in the trailers in " design city." A fire in these trailers would be of serious consequence, even though most of the drawings are stored in 4 hour fire-rated files and microfilm copies are stored elsewhere. j 'I o There does not appear to be an overall system for forms con ' trol.-e.g. when a form is changed the procedure with the form j in it does not necessarily get changed and the old copies of [ the forms are not purged from the system in a timely manner. l o Procedure control ist the station, except for Special Test Procedures, is controlled by the Administration group of the Nuclear Administration section. The present staff assigned to this activity is minimcl. P o All of the station procedures have been. microfilmed. 0 l,

o Control of QA documents within the site QA organization is not in accordance with a formal system.that assures they do not get lost and that they are processed expeditiously.i 15.1 Recommendations s Q RMDC-1 Establish a single Records Management / Management Information system for Rancho Seco using the site records management organization and system as a basis. RMDC-2 Assign control of the records vault to Records Management, provide funding for high density records storage equipment for the vault and provide qualified staff to operate the facility. RMDC-3

• Provide additional qualified personnel to the maintenance organization to accelerate their handling of work request infonnation into MIMS..

RMDC-4 Perform a study and action plan to determine the impact of a major fire in " design city" and the precautions to be taken to prevent same. Consideration should be given to providing permanent facilities. RMDC-5 The Technical Manual library should be returned to the control of Records Management (see Recommendation MA-7). + I l . -.}}