ML20148A462
| ML20148A462 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/19/1988 |
| From: | Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-1275 AGM-NPP-88-037, AGM-NPP-88-37, NUDOCS 8801220540 | |
| Download: ML20148A462 (21) | |
Text
--
gSMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S Street. PO. Box 15830. Sacramento CA 95852 1830.(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CAllFORNIA AGM/NPP 88-037 Jan. 19, 1988 U. S. Nuclear Regulatory Commission Attn: Frank J. Miraglia, Jr.
Associate Director for Projects Phillips Building 7920 Norfolk Avenue Bethesda, MD 20014 l i
DOCKET NO. 50-312 RANCHO SECO NUCLEAR GENERATING STATION LICENSE N0. DPR-54 RANCHO SECO RESPONSE TO NUREG 1275 l
Dear Mr. Miraglia:
Enclosed for your information is the "Rancho Seco Nuclear Generating Station Response to NUREG 1275, Operating Experience Feedback Report - New Plants,"
dated January 1988.
NUREG 1275 recommendations have been reviewed for relevance to Rancho Seco i restart and post restart activities. For many of the items included in the l NUREG, current District practices (in place or to be implemented prior to restart) are considered to be in accordance with the NRC recommendations. 1 Please contact me if you have any questions. Members of your staff with questions requiring additional information or clarification may contact Mr. Bob Croley at (916) 452-3211, extension 4571.
Sincerely, Joseph F. Firlit Assistant General Manager, Nuclear Power Production Attachment cc: G. Kalman, NRC, Bethesda (w/atch) 0\
A. D'Angelo, NRC, Rancho Seco ( " ) E J.B. Hartin, NRC, Region V (
)
L
\\
8801220540 880119 PDR P
ADOCK 05000312 DCD RANCHO SECO NUCLEAR GENERATING STATloN D 1444o Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935
t
-g i
- 2. : ,-
1 i
f w i i
l l
l t
RANCHO SECO NUCLEAR GENERATING STATION i RESPONSE TO NUREG 1275 !
1 f
Operating Experience Feedback Report - New Plants P
. ?
e January 1988 i !
t I h P
f h
4 l i
t i 4
h I i f
v i
l h
i-
.a t
i 4 i i
I
. NUREG 1275, "Operating Experience Feedback Report - New Plants," documents a detailed review of the cause of unplanned events during the early months of licensed operation for plants licensed between March 1983 and April 1986. The major lessons and corrective actions that appear to have the greatest potential for improving the effectiveness of plant startups are provided for considera-tion through the operating experience feedback programs and activities of the industry and NRC staff.
NRR recommended that the District review this NUREG for relevance to Rancho Seco restart and post restart activities. This report documents the District review and response. The complete text of the "Improvement lessons for Consideration by Licensees" is provided for your information. Each item is then repeated and followed by the District response.
The District's review of NUREG 1275 identified the following two recommendations as requiring further action:
B.(2) Install test jacks and bypass switches (OR), and Personnel condu: ting surveillance will be instructed to be alert for and to make appropriate recommendations regarding enhancements such as the installation of bypass switches and test jacks that could reduce the possibility of transients and trips during the conduct of surveillances.
B.(7) Incorporate scram prevention measures such as:
- Develop a color coding scheme for single point scram components whose misoperation could cause a scram (for example, pressure sensing lines). (OR)
Further evaluation of this item will be conducted after restart.
l t
l l
l
e
. NUREG 1275 Imorovement lessont for Consideration by Licensees A. Management lessons (1) Establish an operating plant mentality well prior to initial criticality.
- Ensure that plant operations personnel have the responsibility for operating all equipment as early as possible in the construction completion process. Take early, complete control of the transition from construction to operation. (0L)
- Have personnel who will be responsible for maintenance and testing of plant systems after licensing begin these activities using post licensing procedures before fuel load. This lets procedures get debugged, and the plant staff gains experience in working under licensed conditions. (OL)
- Stress the importance of details, the need for discipline in following .
procedures, the need for awareness of plant conditions and the regulatory requirements associated with these conditions, tight coordination throughout the plant staff, and the need for expedited resolution of problems. (OR)
- Hinimize continued construction activities after fuel load that may have an adverse impact on plant operations. Reduce plant staff to operational size, remove construction equipment, and establish housecleaning programs. Bring A/E, NSSS vendor key personnel onsite so that problems can be resolved promptly when discovered. (OL)
(2) Conduct a deliberate, evenly paced, thorough and well-planned preoperational and startup test program.
- Conduct thorough reviews and dry runs for planned testing and allow time for additional testing during either the preoperational or startup testing program. Emphasize planning to reduce the frequency of unplanned scrams and unnecessary ESF actuations. A detailed review of operational experience of similar plants should be a principal guide to the areas needing additional attention. (OL) e Minimize the number of deficiencies and outstanding items carried forward. Establish a policy of complete resolution before proceeding. (OL)
(3) Use the finalized Technical Specifications (TSs) to generate and validate (e.g., against the as-built plant) surveillance testing procedures as early as possible. In this regard, great discipline should be exercised to restrict the number of last-minute changes in the proposed TSs. Once final draft TSs are issued, the licensee should begin to incorporate TS ,
requirements into plant procedures instead of waiting until the last few changes have been implemented. In conjunction with this activity, have plant staff (as cpposed to NSSS vendor or special startup group) perform all surveillances. It is recognized that development of finalized TSs
! involves joint licensee /NRC staff effort. Therefore, this measure relates i directly to item A(3) under Improvement Lessons for Consideration by the NRC Staff, which addresses the corresponding staff effort. (OL) l l l l
(4) Improve ad2inistrative control of surveillance. For exa:ple:
- Since problems have been experienced when work has been performed in the vicinity of instrument racks during plant operation, licensees should evaluate the location and nature of work activities during operation in terms of adverse effects on plant operation and take appropriate administrativo actions. (OR)
- Implement schemes to separate channel testing, such as a specific day of the wesk assigned to work on each channel, and to identify the channel in test, such as posting on control room panels. (OR)
- Flag, categorize, and schedule surveillance according to risk of scrams or other ESF actuations. (OR)
(5) Give high visibility to the sources (i.e., organizational element) of unplanned scrams (and other unplanned events) caused by human error and establish performance goals. (OR)
(6) Ensure that operating experience feedback programs: (a) combine internal events and relevant events from similar plants, (b) communicate them directly to the appropriate first level supervisors and working level staff at the plant on a periodic basis, including prior to startup, and (c) address preventive measures. For example, segregate the trip and ESF actuations data involving human errors from recent plant startups into the specific positions, organizational or functional element, working activity, systems and components, time of day, etc. Feed this information back at the lowest levels so that the experience of others, the complexity of what is being done, and the ramifications of errors can be seen and appreciated. (OR)
(7) A number of improvement lessons are directed at training as follows:
(a) Establish as a major goal an increased commitment to training in performing surveillance testing, calibration, and troubleshooting activities well prior to operations. I&C training initiatives, such as repeated practice for those surveillance testing activities that could cause a transient and which should be conducted on actual in-plant equipment on live systems prior to operations, should be emphasized. An additional action to improve surveillance testing suggested by licensee staffs was training for I&C personnel in valving instrumentation in and out of service. (OR)
(___.
. (b) Emphasize training for routine operations involving power level changes and the associated communications among shift personnel (i.e., feed flow and turbine evolutions) that have historically caused trips. Accelerated programs / efforts appear appropriate for newly licensed plants regarding steam generator level control.
Emphasize the need for site specific simulators to include, prior to startup, the best achievable fidelity of the simulator to the plant regarding feedwater effects (Rad / lag characteristics of level indication and control methods), and include provisions to continue to improve fidelity as the startup progresses. (OR)
(c) Establish extensive, detailed training for all segments of the onsite plant staff, including I&C technicians, maintenance mechanics, security staff, operations, and management. (OR)
- This training would emphasize: (a) the applicability of the various TSs to the changing plant modes of operation and associated schedules, (b) the relationship of the TSs to the plant procedures, (c) the NRC requirements for reportability of violations, and (d) the basis for the TSs and discussion of '_C0 requirements. (OR)
B. Equioment lessons (1) Focus on the 80P prior to operation and early in the life appears to provide a high return regarding the reduction of unplanned scrams and ESF actuations. Within this area, attention could be given to:
- Conducting additional reviews of feedwater and turbine control and bypass systems to identify sensitivities and plant-specific characteristics that could contribute to transients or the ability of the system to cope with expected transients. (OR)
- Conducting a systematic review of equipment-protective logics and l setpoints on components such as pumps (suction trip, time delay,
- vibration trip) or power supplies to identify areas where a time delay or additional channels for coincidence could reduce the potential for unnecessary transients or spurious actuations. Give special attention to first-of-a-kind features not incorporated in earlier designs. Additional examples obtained from the plants visited include the main steam reheater drain high level trip and other turbine protective trips. (OR)
(2) Install test jacks and bypass switches at appropriate points in actuation l circuitry. (OR)
(3) Implement on a priority basis vendor oi licensee trip reduction measures.
i Licensee trip reduction programs should focus on safety-related equipment i as well as on B0P equipment. (0L) l l
l l
(4) Pay attention to the design and installation of equipment located in the vicinity of radiation monitors and associated cabling to ensure that adequate grounding or equipment, cable shielding, etc., are provided to prevent the occurrence of EMI, which can trigger this extremely sensitive instrumentation. (OR)
(5) Thoroughly test new or unique plant features, such as new RPS systems, electrical systems, etc., prior to fuel load to reduce unanticipated failures or unexpected erratic behavior. Emphasize planning to reduce the frequency of unplanned scrams and unnecessary ESF actuations. (OL)
(6) For future designs or major plant modifications, preference for proven designs and standardization of design in plant feedwater and turbine systems appears justified. Conduct further analyses of any first of a kind, one of a kind, and state-of-the-art features, since they have generated a large number of problems during plant startups. (Examples of remedial actions are more extensive preoperational testing, reexamination of actuation logic to better achieve reliable indication and actuation; for example, reanalysis of actuation on a single input or loss of-a single input.) (OR)
(7) Incorporate scram prevention measures such as:
- Develop a color coding scheme for single point scram components whose misoperation could cause a scram (for example, pressure sensing lines). (OR) e Install cages or covers over switches or racks that could provide trip signals. (OR) l I
l l
l 1
1
^
- NUREG 1275 RESPONSE NUREG 1273 A. Management Lessons (1) Establish an operating plant mentality well prior to initial criticality.
- Ensure that plant operations personnel have the responsibility for operating all equipment as early as possible in the construction completion process. Take early, complete control of the transition from construction to operation. (OL)
Resoonse Equipment is being turned over from System Review and Test Program (SRTP) when testing is complete. Administrative Procedure AP.44, "Plant Hodification - ECN Implementation," is used for system turnover. This procedure establishes the requirements for site implementation of Engineering Change Notices (ECNs). Since Rancho Seco is not in a "construction" phase, systems have been under Operations control except for modifications and testing. All systems are under Operations control for testing and required systems will be operable for heatup.
Operations reviews plant modifications in detail prior to implementation.
The progress of modifications being implemented is reviewed in the daily management meeting.
- Have personnel who will be responsible for maintenance and testing of plant systems after licensing begin these activities using post l licensing procedures before fuel load. This lets procedures get debugged, and the plant staff gains experience in working under licensed conditions. (OL)
Resoonse This item is not directly applicable to Rancho Seco since the plant has been working under licensed cor.dition during the entire outage with fuel loaded in the reactor. Personnel responsible for maintenance and testing have been using the permanent procedures. Procedures are revised at l
changes to the plant are made and appropriate training is conducted.
l l Rancho Seco has embarked on a program to rewrite all of its surveillance I and maintenance procedures to bring them up to current standards and incorporate ECNs and Technical Specification changes. As rewrites are i completed they are incorporated into the schedule for performance and the "old" procedure voided or superseded. In this way, the majority of the
, procedures required to be conducted during the power run following l restart will have been used at least once before restart.
l l
l l
- Stress the importance of details, the need for discipline in following procedures, the need for awareness of plant conditions and the regulatory requirements associated with these conditions, tight coordination throughout the plant staff, and the need for expedited resolution of problems. (OR)
Resoonse Quality and attention to detail is a high priority of management. The importance of adherence to procedures and attention to detail has been stressed to plant personnel during staff meetings and in management memoranda to the staff.
Adherence to procedures and attention to detail is stressed in Administrative Procedure AP.23, "Conduct of the Operations Division," in the AP.4 series of clearance, test and caution authorization procedures, and in Special Order #87-37, "Surveillance Procedure Scheduling /
Performance".
Maintenance Administrative Procedure HAP-0002, "Control of Haintenance Activities," details how work is to be conducted at Rancho Seco. It requires that procedures be adhered to and any problems or deficiencies identified be documented and reported in the appropriate manner. The Maintenance Department program to rewrite all of the surveillance procedures and maintenance procedures to conform to current standards should reduce procedural errors that can be attributed to procedure inadequacies. ,
Plant personnel use the reporting chain, the wo*k request process, the Nonconformance Report (NCR) process, the Occurrence Description Report (0DR) process, and the Engineering Action Request (EAR) process to document and resolve problems.
- Hinimize continued construction activities after fuel load that may have an adverse impact on plant operations. Reduce plant staff to operational size, remove construction equipment, and establish housecleaning programs. Bring A/E, NSSS vendor key personnel onsite so that problems can be resolved promptly when discovered. (0L)
Resoonse The present schedule reflects reduction in construction activities as criticality approaches. The contract labor force has dropped from 1,662 at the end of 1986 to 1,314 on December 25, 1987. Each department has an approved destaffing plan. All restart commitment construction activities, except for those items needed to resolve System Review and Test Group (SRTG) problems, will be completed by criticality. A housecleaning program has been established. The policy for housekeeping activities is detailed in Administrative Procedure AP.18, "Plant Housekeeping and Inspection." Construction equipment is being removed. NSSS and other vendor personnel are being utilized during testing and will be available during the power ascension program.
. NUREG 1275 (2) Conduct a deliberate, evenly paced, thorough and well-planned preoperational and startup test program.
- Conduct thorough reviews and dry runs for planned testing and allow time for additional testing during either the preoperational or startup testing program. Emphasize planning to reduce the. frequency of unplanned scrams and unnecessary ESF actuations. A detailed review of operational experience of similar plants should be a principle guide to the areas needing additional attention. (OL)
Resoonse The power ascension program is a comprehensive program with planned reactor trips to ensure integrated equipment functioning and six power plateaus to permit thorough hands-on operator training for each shift.
This program includes one week testing at both the 0 and 25 percent power plateaus, eight weeks at the 40 percent power plateau, and five weeks each at the 65, 80 and 92 percent power plateaus. The Restart Personnel Qualification Guide has been developed to provide a program to verify personnel are ready to proceed to the next power level.
Plant Operating Procedure B.1A, "Control of Heatup and Operating Procedure for Power Escalation Testing," is in place to control the progression of startup and integrate the operating, special test, and surveillance procedures required for startup.
These measures have been established to allow sufficient time to ensure that the plant, procedures, and people are ready for each power increase.
- Hinimize the number of deficiencies and outstanding items carried forward. Establish a policy of complete resolution before proceeding. (OL)
Resoonse High priority is being given to resolving Occurrence Description Reports (00Rs) and Nonconformance Reports (NCRs). The number of open 00Rs has been reduced from a high of 661 on June 22, 1987 to 135 on December 29, 1987. Open NCRs have been reduced from 816 on March 3, 1987 to 473 on December 31, 1987.
Rancho Seco has just completed a second review of the open corrective maintenance work requests to verify those that are reauired to be worked before restart and those that may be postponed until after restart. Hork continues on reducing the total backlog of work requests to the minimum attainable by restart. The goal is to have no more than two month's backlog of non-restart required work requests still open at restart.
A Preventive Haintenance (PH) program has been established with a goal of ensuring that all of the PMs on Category 1 equipment are current at restart. Category 2 equipment PHs will be addressed after restart. The definitions of Category 1 and 2 equipment are given in HAP-0009, "Preventive Maintenance Program."
Maintenance Administrative Procedure MAP-0017 "Root Cause Determination,"
ensures that the root cause of equipment failure and maintenance concerns are identified, appropriate corrective actions are taken, and measures to prevent recurrence are established.
Procedure 8.1A, "Control of Plant Heatup and Operating Procedure for Power Escalation Testing," is the Operations procedure documenting that there are no outstanding restart related items to prevent a change in mode or escalation of power level.
This procedure requires management approval from Maintenance, Operations, Training, Testing, Scheduling, Quality, Licensing, both Assistant General Managers and the CEO Nuclear prior to each power level plateau change.
NUREG 1275 (3) Use the finalized Technical Specifications (TSs) to generate and validate (e.g., against the as-built plant) surveillance testing procedures as early as possible. In this regard, great discipline should be exercised to restrict the number of last-minute changes in the proposed TSs. Once final draft TSs are issued, the licensee should begin to incorporate TS requirements into plant procedures instead of waiting until the last few changes have been implemented. In conjunction with this activity, have
- plant staff (as opposed to NSSS vendor or special startup group) perform l all surveillances. It is recognized that development of finalized TSs involves joint licensee /NRC staff effort. Therefore, this measure relates directly to item A(3) under Improvement lessons for Consideration by the NRC Staff, which addresses the corresponding staff effort. (0L)
Resoonse l The Technical Support staff maintains the Surveillance Procedure Cross Index data base in accordance with Administrative Procedure AP. 303.05, "Technical Specifications to Surveillance Procedure Cross Reference Data Base Update Guidelines." Administrative Procedure AP.303.04, "Cross-Index of Technical Specifications and Surveillance Procedures," is the cross-indexing reference document.
The organizations responsible for procedures have been provided with all proposed Technical Specifications. All procedures are written to conform to the revised Technical Specifications. Procedures which do not comply with the present Technical Specifications are being issued and implemented based on proposed Technical Specification amendments. These procedures are re-reviewed for conformance upon issuance of the Technical Specification amendment. All surveillances are performed by plant staff.
l
_9_
NUREG 1275 (4) Improve administrative control of surveillance. For example:
- Since problems have been experienced when work has been performed in the vicinity of instrument racks during plant operation, licensees should evaluate the location and nature of work activities during operation in terms of adverse effects on plant operation and take appropriate administrative actions. (OR)
Resoonse Administrative Procedure AP.44, "Plant Modifications - ECN Implementation," describes the interface between various organizations on site who are impacted by a design change. It requires that all affected groups participate in a walkdown of the job before implementation. At this time, any interference with, or adverse impact on, other systems is identified.
Maintenance Administrative Procedure MAP-0006, "Hork Request Planning,"
requires that the discipline planner walkdown the work site during the planning of corrective maintenance work requests. This walkdown should identify any problems.
Rancho Seco Administrative Procedure RSAP-0803, "Hork Requests," requires that work on power block and safety-related systems be reviewed by the Shift Supervisor and approved prior to starting work. His operating experience and plant knowledge should be helpful in identifying problems of this type during his review.
- Implement schemes to separate channel testing, such as a specific day of the week assigned to work on each channel, and ;o identify the channel in test, such as posting on control room panels. (OR)
Resoonse i Separate Maintenance Department Surveillance Procedures are written for l indiviJual channels, which inherently provides the separation of channels desired. The Shift Supervisor ensures that no multi-channel or cross-channel testing is performed by controlling which surveillance procedure is authorized for performance and when.
The preventive maintenance tasks are also written against individual channels or instruments to help achieve the separation of channels as desired. The preventive maintenance work requests are also authorized for work by the Shift Supervisor, ensuring that he has control over which I channel is being tested.
It is envisioned that after restart the bulk of the surveillance testing and preventive maintenance work will be performed on the second and third
, shift when interference from other activities is minimized. Until restart l is accomplished, it is necessary to perform these tasks on all shifts to I
ensure that all surveillance tests and Category 1 equipment preventive maintenance tasks are current prior to restart.
l l 1 1
Resoonse The Maintenance Department has an I&C Engineering organization which provides valuable support to the technicians in resolving problems in the field.
Recent re-evaluation by the District has shown that consolidation of some of the engineering functions in the Nuclear departments will prevent overlap and duplication of effort. The Plant Performance Department will be the point of consolidation and will have a systems engineering group headed by a superintendent. This systems engineering group will include I&C engineers who will provide necessary support to the I&C maintenance groups.
- Flag, categorize, and schedule surveillance according to risk of scrams or other ESF actuations. (OR)
Resoonse Surveillance procedures involving channel / subsystem testing of the RPS, SFAS and EFIC that have the potential of causing a reactor trip have been identified. The identified procedures have been reviewed to ensure that statements are included in the Limits and Precautions or Preroquisites Sections to minimize the risk of a reactor trip. Procedures with l inadequate precautionary statements will be revised. (The procedure l
review was performed per SPIP Recommendation TR-111-RPS.)
Resoonse The I&C Shop has one crew of six men specifically assigned to conduct surveillance testing, corrective maintenance, and preventive maintenance on the following systems: Radiation Monitoring (RDM), Heteorological (SHE), and Security (PSS). This crew does not rotate on shift, thus allowing them the time they need to test and repair these very complicated systems. The remaining crews provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage for the shop.
Their experience and knowledge is not system specific and they are prepared to work on any system. Further evaluation of this arrangement will be made after significant experience has been obtained.
NUREG 1275 (5) Give high visibility to the sources (i.e., organizational element) of unplanned scrams (and other unplanned events) caused by human error and establish performance goals. (OR)
Resoonse Administrative Procedure AP.28, "Post Trip Transient Report," provides a systematic method for diagnosing the cause(s) of a reactor trip. The proper functioning of safety-related and other important equipment during the trip is ascertained. Detrimental effects on plant equipment caused by the trip are identified and the determination is made when the plant can be restarted safely.
10 CFR 50.73(a)(2)(iv) requires the initiation of a Licensee Event Report (LER) for any unplanned actuation of the Reactor Protection System.
Licensing Department Administrative Procedure LDAP-0004, "Incident Analysis," provides that the Independent Investigation / Reviews Group (IIRG) will review LERs for programmatic deficiencies and prepare investigations as required. The investigation and associated corrective actions are reviewed by the Management Review Team (HRT). After approval by the MRT, corrective actions are assigned to the cognizant departments for implementation. The IIRG also reviews NRC violations, inspection findings and other areas as requested by management for programmatic problems.
NUREG 1275 (6) Ensure that operating experience feedback programs: (a) combine internal events and relevant events from similar plants, (b) communicate them directly to the appropriate first level supervisors and working level staff at the plant on a periodic basis, including prior to startup, and (c) address preventive measures. For example, segregate the trip and ESF actuations data involving human errors from recent plant startups into the specific positions, organizational or functional element, working activity, systems and components, time of day, etc. Feed this information back at the lowest levels so that the experience of others, the complexity of what is being done, and the ramifications of errors can be seen and appreciated. (OR)
Resoonse i Administrative Procedure AP.50, "Operational Assessment (Operating l Experience) Program," provides for the evaluation of events classified by
, INP0 as "significant" and the determination of their applicability to l Rancho Seco. This procedure also addresses the development, distribution and tracking of the resulting proposed actions and for the dissemination to Nuclear Management as appropriate. The administration of the program t
addressed in AP.50 has recently been shifted from the Operations l Department to Licensing. Administrative Procedure AP.69, "Nuclear Network Usage at Rancho Seco," provides a minimum list of recipients of the Nuclear Network. This program is also the responsibility of Licensing.
l
The Training Department receives industry-related information from several sources. Training Department procedures (TDAP-5100, TDIP-5110, TDIP-5130, TDIP-8120) have been established to route industry-related items, such as INP0 SOERs, SERs, O&M Reminders, Network, NRC Inspection Reports, I&E Bulletins and Circulars, ANI Evaluation Reports, Plant Incident Critiques and Reports, and B&H Bulletins.
These items are reviewed and evaluated by Training Department supervisors and instructors to determine the value and training impact of each item.
Emphasis is placed on identifying root causes of problems and applying the lessons learned to our operating practices. When the item results in equipment or procedure changes, the training programs are revised to ensure the operators, technicians, and maintenance personnel understand the basis for the change and how it affects their speciality.
Training is provided to the qualified plant operators, technicians, maintenance personnel, and their supervisors during requalification/
continuing training sessions. The initial training and qualification programs are also revised to ensure important "lessons learned" from industry events are incorporated.
All Training Department work related to industry events is tracked on the Department Hork Track system. This ensures proper records and documentation are maintained to meet the current industry and regulatory requirements regarding this training.
NUREG 1275 (7) A number of improvement lessons are directed at training as follows:
(a) Establish as a major goal an increased commitment to training in performing surveillance testing, calibration, and troubleshooting activities well prior to operations. I&C training initiatives, such as repeated practice for those surveillance testing activities that could cause a transient and which should be conducted on actual in-plant equipment on live systems prior to operations, should be emphasized. An additional action to improve surveillance testing suggested by licensee staffs was training for I&C personnel in valving instrumentation in and out of service. (OR)
Resoonse During the current outage, the Training Department has provided training to the plant I&C technicians through the continuing training program.
Training has been conducted on several modified systems, such as EFIC, ICS, and Controlatron. Additional training is planned during restart and power ascension to cover the RPS, additional ICS modifications, and revised surveillance procedures.
In addition to this training, the Operations Training area uses shift briefings and required reading assignments to prepare the operating crews to perform significant tests and evolutions, such as Safety Features Actuation System (SFAS) and Loss of Offsite Power.
- Currently the Technical Training staff is developing new I&C training materials to meet INP0's accreditation objectives and criteria. This particular program requires hands-on training of the technician in such activities as taking transmitters in and out of service, calibrating various instrumentation, and use of various types of test equipment for calibrations and troubleshooting.
NUREG 1275 (b) Emphasize training for routine operations involving power level changes and the associated communications among shift personnel (i.e., feed flow and turbine evolutions) that have historically caused trips. Accelerated programs / efforts appear appropriate for newly licensed plants regarding steam generator level control.
Emphasize the need for site specific simulators to include, prior to startup, the best achievable fidelity of the simulator to the plant regarding feedwater effects (lead / lag characteristics of level indication and control methods), and include provisions to continue to improve fidelity as the startup progresses. (OR)
Resoonse The present operator training programs at Rancho Seco provide extensive training on watchstanding principles to non-Licensed Operators (NL0s),
Reactor Operators (R0s), Senior Reactor Operators (SR0s), Shift i Supervisors, and Shift Technical Advisors (STAS). This training is done initially in the classroom and is reinforced through on-the-job-training and simulator training. These programs deal extensively with AP.23, "Conduct of Operations Division," and cover crew communications, use of procedures, reporting responsibilities, and other watchstanding
! requirements. Licensed Operators (L0s) have also received additional simulator training on Teamwork and Diagnostic Skills as part of the initial and requalification training programs.
1 i The operations training programs (NLO, R0, SRO, and STA) were all l accredited by the National Nuclear Accrediting Board in April 1986. These programs have been evaluated by INP0 and the NRC and found to be acceptable.
i The Restart Personnel Qualification Guide provides for special training
! for problem areas and for activities that have not been performed since l the plant has been shutdown.
Long-range plans are in place to obtain a site-specific, plant-referenced simulator for Rancho Seco. This will allow us to provide additional i
training in a high fidelity environment. Delivery of the new simulator is j scheduled for mid-1989.
NUREG 1275 (c) Establish extensive, detailed training for all segments of the onsite plant staff, including I&C technicians, maintenance mechanics, security staff, operations, and management. (OR)
- This training would emphasize: (a) the applicability of the various TSs to the changing plant modes of operation and associated schedules, (b) the relationship of the TSs to the plant procedures, (c) the NRC requirements for reportability of violations, and (d) the basis for the TSs and discussion of LC0 requirements. (OR)
Resoonse Operators are trained on procedures, the Updated Safety Analysis Report (USAR), and Technical Specifications (including Limiting Conditions of Operation (LCO) and bases) during the systems phase of training. This is reinforced during simulator training and while on shift during the on-the-job-training phase. Operators are required to use plant procedures and interpret the Technical Specifications frequently during on-the-job-training and simulator scenarios. The training program requires the operators to operate the plant during all modes of operation and make all necessary reports during the simulated emergency scenarios. Technical Specification training continues to be reinforced during requalification training. Both classroom and simulator training sessions are used to cover the Technical Specifications, changes and amendments, and proper use and interpretation of the LCOs. All of the operator programs have been accredited by the National Nuclear Accrediting Board.
All of the Technical Training programs (I&C, electrical, mechanical, chemistry and radiation protection) include training on applicable Codes and Standards, USAR, Technical Specifications, and plant procedures as they apply to each specific job. These programs are being designed to meet current industry requirements for accreditation.
The Rancho Seco Technical Staff and Managers' program provides training on Codes and Standards, USAR, Technical Specifications, and procedures to all designated plant engineers and support personnel. This training specifically addresses the Technical Specifications and their relation to i
plant procedures and the facility license. These programs are being designed to meet current industry requirements for accreditation.
t All of these non-operations programs have continuing training programs to I ensure the Technical Specification changes or amendments are taught to the affected plant disciplines.
l l
1 l
NUREG 1275 B. Eautoment lessons (1) Focus on the 80P prior to operation and early in the life appears to provide a high return regarding the reduction of unplanned scrams and ESF actuations. Hithin this area, attention could be given to:
- Conducting additional reviews of feedwater and turbine control and bypass systems to identify sensitivities and plant-specific characteristics that could contribute to transients or the ability of the system to cope with expected transients. (OR)
- Conducting a systematic review of equipment-protective logics and setpoints on components such as pumps (suction trip, time delay, vibration trip) or power supplies to identify areas where a time delay or additional channels for coincidence could reduce the potential for unnecessary transients or spurious actuations. Give special attention to first-of-a-kind features not incorporated in earlier designs.
Additional examples obtained from the plants visited include the main steam reheater drain high level trip and other turbine protective trips. (OR)
Resoonse Balance of Plant training importance is emphasized during R0/SR0 training in Hitigating Core Damage (started due to THI Secondary System oscillation).
Training is provided at the simulator on the effects of and integrated response to feedwater and steam system transients on the RCS. Many scenarios are formulated around secondary plant operation.
The Main and Auxiliary Feedwater Systems and the Turbine Bypass Control System were the subject of a Babcock & Hilcox (B&H) Test Program review conducted in August / September 1987. The review yielded an extensive report on the design configuration and testing of these systems. Items of concern identified in the report were assigned restart and post-restart priorities.
l The Turbine Bypass Control System, including the pneumatic controls, has undergone several modifications to reduce or eliminate spurious trips and certain nuisance characteristics. The Main Feedwater Pump controls have also been modified to improve controlability and reliability.
Equipment protection logic components which have caused an unnecessarily high scram rate have been targeted for adjustment on a case-by-case basis.
The issues listed above are encompassed by the trip reduction recommendations developed by the B&H Owners Group Safety and Performance j Improvement Program (SPIP). These trip reduction recommendations address l
all aspects of plant operation including control system interaction, individual instrument setpoints, operating procedures, and maintenance procedures. The District evaluated each of these recommendations for applicability to Rancho Seco. These trip reduction recommendations have been prioritized and many of the key B&H recommendations are being l
implemented prior to plant restart.
l
O
. The following specific SPIP recommendations are being implemented prior to restart to address the areas discussed previously:
A. Feedwater, Turbine Control TR-003, Remove startup FH flow correction to MFH flow from the ICS TR-006, Delete FH temperature correction to FH demand from ICS TR-096, Evaluate design of turbine bypass and atmospheric dump systems
- 8. Equipment Protective Logics TR-012, Determine if operator has necessary information from procedures, indicators, etc. to detect loss of NNI power TR-013, Prevent loss of power to the ICS or NNI TR-01E. Determine if a low MFH pump suction pressure is needed NUREG 1275 (2) Install test jacks and bypass switches at appropriate points in actuation circuitry. (OR)
Resoonse Test jacks and bypass switches were included in the design of the Emergency Feedwater Initiation and Control System (EFIC) and have been installed.
Personnel conducting surveillances will be instructed to be alert for enhancements to the procedures and the methodology used to conduct surveillances and to make appropriate recommendations. This will include enhancements such as the installation of bypass switches and test jacks to reduce the possibility of transients and trips during the conduct of surveillances. Recommendations for equipment installation will be considered within the existing plant modification programs.
l (3) Implement on a priority basis vendor or licensee trip reduction measures.
Licensee trip reduction programs should focus on safety-related equipment as well as on B0P equipment. (0L)
Resoonse Rancho Seco has adopted the B&H0G Safety and Performance Improvement Program (SPIP). All 207 recommendations from SPIP have been evaluated and 57 have been determined to be not applicable. Fifty-eight will be fully operable at restart. The remaining recommendations are scheduled for implementation over the next two fuel cycles. A report indicating the status of each SPIP recommendation was submitted to the NRC on l
December 1, 1987 (GCA 87-796). Records on the status of each item are i available for review at Rancho Seco.
The SPIP implementation program was audited by the B&H0G December 8 through 10, 1987 with generally favorable results.
i
NUREG 1275 (4) Pay attention to the design and installation of equipment located in the vicinity of radiation monitors and associated cabling to ensure that adequate grounding or equipment, cable shielding, etc., are provided to prevent the occurrence of EMI, which can' trigger this extremely sensitive instrumentation. (OR)
Resoonse The following precautions have been taken to limit the effect of electromagnetic interface (EMI) cn radiation monitors:
- 1. The analog signal cables have been routed separately from AC power and control circuits.
- 2. The installations have been designed based upon design guide Nuclear Engineering Procedure NEP 5204.43, "Instrumentation Systems, Shielding and Grounding, and Surge Protection."
- 3. The manufacturer's recommendations for limiting the effect of EMI have been followed.
NUREG 1275 (5) Thoroughly test new or unique plant features, such as new RPS systems, electrical systems, etc., prior to fuel load to reduce unanticipated failures or unexpected erratic behavior. Emphasize planning to reduce the frequency of unplanned scrams and unnecessary ESF actuations. (OL)
Resoonse The EFIC and TDI Diesel Systems are new systems installed at Rancho Seco.
The EFIC System will be fully preoperationally tested. The Cabinet Functional Test (STP.665), the Cold Functional Test (STP.666), and the Cold Preoperational Test (STP.667) have been performed. A Hot Functional Test (STP.1113) and a Post Critical High Decay Heat Test (STP.668) will l be performed. EFIC will also be tested during the Loss-of-Instrument Air Test (STP.1056) and the Loss-of-Offsite-Power Test (STP.961). Operators have been trained on the simulator on the new EFIC panel.
The TDI Emergency Backup Diesel Generators were fully preoperationally tested in STP.1009A/8, preceded by 27 Special Test Procedures for individual component and sub-system functions. These diesels and associated equipment will undergo post modification and integrated system phase II retests (STP.1134A/B). They will also be tested during the Loss-of-Offsite Power Test (STP.961).
l l
l l
l m
c A
NUREG 1275 (6) For future designs or major plant modifications, preference for proven designs and standardization of design in plant feedwater and turbine systems appears justified. Conduct further analyses of any first of a kind, one of a kind, and state-of-the-art features, since they have generated a large number of problems during plant startups. (Examples of remedial actions are more extensive preoperational testing, reexamination of actuation logic to better achieve reliable indication and actuation; for example, reanalysis of actuation on a single input or loss of a single input.) (OR)
Resoonse Analyses of any first-of-a-kind, unique or state-of-the-art features are always conducted as a part of engineering evaluations in accordance with engineering and quality procedures. Preference is always given to proven designs. New designs are considered only when they offer an advantage in safety or reliability.
NUREG 1275 (7) Incorporate scram prevention measures such as:
- Develop a color coding scheme for single point scram components whose misoperation could cause a scram (for example, pressure sensing lines).
(OR)
Response
The Reactor Trip, Generator Trip and Turbine Trip Push Buttons located in the Control Room are all the same unique size, shape and color. Further use of color coding single point scram components will be evaluated after restart.
- Install cages or covers over switches or racks that could provide trip signals. (OR) l Resoonse Two hundred seven toggle switch guards were installed under Engineering l
Action Request (EAR) EH87-033 on Class 1 125V DC panels / switch gear.
l L