ML20149D746

Forwards Rept of Status & Progress Towards Resolution of Issues Identified During Operational Readiness Review Insp, Per Crutchfield 880107 Correspondence Re Restart Insp Findings

ML20149D746
Person / Time
Site:	Rancho Seco
Issue date:	01/28/1988
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Miraglia F Office of Nuclear Reactor Regulation
References
GCA-88-047, GCA-88-47, NUDOCS 8802090620
Download: ML20149D746 (8)

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$SMUDSACRAMENTO MUNICIPAL UTILITY DISTRICT O 62o1 S Street, P.O. Box 1583o. Sacramanto CA 958521830,(916) 452 3211 l

AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA j JAN 2 8 Iggg GCA 88-047 U. S. Nuclear Regulatory Commission Attn: Frank J. Miraglia, Jr.

Associate Director for Projects Phillips Building 7920 Norfolk Avenue Bethesda, MD 20014 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 OPERATIONAL READINESS

Reference:

Correspondence, Crutchfield to Andognini, January 7,1988, Restart Inspection Findings.

Dear Mr. Miraglia:

To assist in the NRC's preparation for completion of the Operational Readiness Review Inspection (ORRI), the attachment to this letter provides the current District status and progress toward resolution of those issues identified during the interim exit of the ORRI as documented in reference.

The Rancho Seco Hanagement Team has sought to see beyond the specific issues identified in order to assure itself that the people, programs, and plant are ready for resumption of power operations. As an example, the recently developed Rancho Seco Management Action Plan establishes short and long term activities to address both Rancho Seco Management and NRC concerns relating to operational readiness. This plan is available for your review and many of its results will be evident during the return ORRI.

Please contact me if you have any questions. Members of your staff with questions requiring additional information or clarification may contact Mr. David Compton at (209) 333-2935, extension 4915.

Sincerely, hgYhdyNmo G. Carl And6gnini Chief Executive Officer, Nuclear [,f 8802090620 880128 I l

PDR ADOCK 05000312 G PDR RANCHO SECO NUCLEAR GENERATING STATION D 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935

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GCA 88-047 Frank J. Miraglia - MN28 mg-Attachment cc: G. Kalman, NRC, Bethesda A. D'Angelo, NRC, Rancho Seco J. B. Martin, NRC,: Walnut Creek J. Dyer, NRR, Bethesda i

ATTACHMENT OPEN ITEM STATUS

1. ASRTP (Inspections 86-41 and 87-29) ITEMS NRC ITEM la.

"Conduct testing and modify operating procedures to resolve turbine-driven auxiliary feedwater ( AFW) pump (P-318) overspeed concerns (86-41-01)."

DISTRICT STATUS:

The AFW P-318 turbine trip setpoint was determined to be acceptable by Special Test Procedure STP.1025, "Turbine Test with Auxiliary Steam System", in July 1987. STP.1070, "AFW Hot Functional Test", is scheduled to be performed at 5-10%FP with normal system configuration including main steam supplying the P-318 turbine. STP.1070 evaluates the full response spectrum to a P-318 turbine trip. The minimum required shutdown time before restarting the turbine after a trip will be evaluated with the turbine, motor, and pump coupled. Test results will be evaluated to determine whether operating procedure revisions are necessary to caution against restarting the turbine prior to the tested minimum shutdown time.

NRC ITEM lb.

"Resolve main feedwater (MFW) system status report problem 31: Main feed pump control from Lovejoy to Bailey Hand / Auto Station is not performing as designed (86-41-07)."

DISTRICT STATUS:

Evaluation of this item with the vendor determined that the MFWP control transfer from Lovejoy to Bailey Hand / Auto Station is performing as designed. Operating Procedure A.50, "MFW System", was revised to reflect the correct operation of the control transfer. The control transfer was tested during performance of STP.1020, "MFWP Protection Test".

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+ Page 2 of 6 hhb NRC ITEM 1c.

"Develop maintenance procedure for safety-related, air-operated valves (86-41-36)."

DISTRICT STATUS:

Of the eleven new maintenance procedures identified for safety-related, air-operated valves, seven are complete and approved. The other four are in various stages of review, draft, and information gathering from the vendor. All are anticipated to be ready prior to plant heatup.

NRC ITEM 1d.

"Implement an effective QA Surveillance Program (86-41-39)."

DISTRICT STATUS:

-The quantity and quality of QA Surveillances have increased markedly since November 1987. Over 50 surveillances per month were performed by Quality in December and January. Surveillances are directed more toward field observation than toward documentation review. The QA inspectors have been trained on "Inspecting for Performance", a QA training course for NRC Inspectors (SAIC-87/3046). INPO good practices and guidelines are used in developing checklists. Responses to recent QA Surveillance Findings are proving both timely and effective.

NRC ITEM le.

"Resolve the concern that a nonsafety-related level instrument on the nuclear service water (NSW) surge tank could defeat the safety feature actuation system (SFAS) signal to the NSW pumps."

DISTRICT STATUS:

The level switches are being disconnected to preclude potential SFAS signal defeat. Train B modification has been performed. Train A modification is scheduled to be completed prior to plant heatup.

Annunciator Procedures for CR panels H2SFA and H2SFB have been revised to provide operator guidance for response to the level instrument alarm.

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Page 3 of 6 2 OPERATIONAL READINESS REVIEW (INSPECTION 87-40) ITEMS NRC ITEM 2a.

"Deficiencies identified with surveillance procedures, test performance, data review and problem resolution indicated that your surveillance program may not be ready to support plant mode change decisions."

DISTRICT STrJUS:

A Surveillance Program Action Plan was approved on December 23, 1987. The plan provides numerous actions which address the need to ensure adequate administrative controls, training, and program implementation. A Surveillance Procedure Master Matrix is nearing completion, with the objective to assure that all Surveillance Procedures required for plant mode change (s) have been successfully performed prior to mode change (s). ,

Surveillance Procedures in the Operations and Maintenance Departments have been reviewed to identify problems relating to return to service, dual l verification, equipment installation and removal, and performability.

l Corrective actions to these procedures are proceeding. Surveillance l performers and reviewers have received instruction on expectations l regarding test perfomance and documentation, data review, and proper corrective actions if problems are identified.

NRC ITEM 2b.

"The inspection team observed significant deficiencies with the maintenance activities associated with the replacement of a mechanical seal of high pressure injection pump "B." These deficiencies were in the areas of procedural adequacy, job planning and supervision, radiological control practices and quality control."

DISTRICT STATUS:

l l A formalized plant observation program has been implemented for the l Nuclear Directors, Panagers, Superintendents, and Supervisors to assess

! the performance of their working group. The Maintenance Department has i established the practice of monthly root cause evaluations of the Maintenance field observation program findings. The ALARA training program and radiological protection work monitoring practices have been evaluated for effectiveness to determine areas for further emphasis. The l Quality Department has established a field inspection program to improve l work performance standards on a continuing basis.

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Page 4 of 6 NRC ITEM 2c.

I "On-shift, control room operators did not appear to be adequately cognizant of the testing activities being conducted outside of the control l room."

DISTRICT STATUS:

As a result of certain testing incidents, the Quality Department issued a Stop Work Order (SWO) in mid Decemoer. The review and corrective action response performed to address this SWO are documented in the System Review and Test Group (SRTG) Action Plan. As part of this response, a Test Communications Policy has been implemented to assure that the CR operators are cognizant of testing activities. Procedure revisions have been made to clarify that Operations is responsible for plant equipment and control during testing. Pre-test briefings have been strengthened to assure mutual understanding between the Operations and Testing personnel.

NRC ITEM 2d.

"The inspection team was concerned that the proposed testing for the remote shutdown system will only demonstrate that recent modifications will perfonn adequately and that an integrated test of all remote shutdown system features has apparently never been accomplished."

DISTRICT STATUS:

Letter GCA 88-029, Andognini to Miraglia (January 25, 1988), provides the District's actions to assure the adequacy of Rancho Seco's remote shutdown capahili+v. These pre-restart actions include: 1) integrated testiiig to demonstrate primary system inventory control and secondary heat transfer control from the remote shutdown panel, and 2) in-plant walkdowns of OP-C.13a, "Plant Shutdown from outside the Control Room" with all operating crews. Present understanding is that the review and resolution of this item is being coordinated by the NRR project manager for Rancho Seco, f

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NRC ITEM 2e.

P "The second verification of motor operated valve (MOY) position during valve lineups did not always appear to be conducted in accordance with your station procedures and.could cause MOVs' to fail to automatically operate. This problem was caused by the lack of. local valve position indication. "

DISTRICT STATUS: -

Prior to restart, the Maintenance Department is identifying deficient local valve position indicators, and either repairing deficient indicators or coordinating justification of post restart repair. Procedural guidance for independent verification of valve lineups is being incorporated to assure valve operability is maintained. Necessary procedure revisions are scheduled for completion prior to restart. .

NRC ITEM 2f.

"The corrective action programs in place do not appear to be effectively implemented to identify and correct problems with station hardware or software. The Quality Assurance surveillance program was not actively searching for potential problems that could occur as the station prepared for mode change."

- DISTRICT STATUS: I The Managersnt Systems Department has reviewed and evaluated the ,

corrective, action process. It has been concluded that difficulties in  :

implemer'cing the existing progr.am result primarily from overlap of the '

multip'.e correction action mechanisms, and a related lack of clear -

understanding as to which mechanism to use. Prior to restart, the plant

is fr-plementing a revised program which incorporates a single primary mechanism for identification, reporting, and resolution of regulatory non-

onformance. Training of affected personnel is scheduled to be acconplished prior to restart. Following restart, the program is planned to be expanded to provide a sitewide integrated tracking system for  !

corrective actions. l

The QA surveillance program is addressed in status for NRC Item 1d.

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NRC ITEM 2g.

"The load test performed on your station batteries appeared to be conducted based on a load profile which did not accurately reflect new loads recently added to the batteries. As a result these previous tests did not appear to demonstrate that the batteries will support their design loads."

DISTRICT STATUS:

Letter AGM/NPP 87-487, Firlit to Miraglia (January 13,1988), provides the District's position that preoperational testing of the Nuclear Services Batteries demonstrates their operability. The service testing performed verified that the batteries were capable of supplying the expected load profile and demonstrated that the calculated battery response was more conservative than the actual response. Present understanding is that the review and resolution of this item is being coordinated by the NRR Project Manager for Rancho Seco.

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