ML20213A052

Responds to SALP Rept 50-312/86-29 for June 1985 - 1986. Clarification of Weakness Identified in Rept Discussed, Including Operations Functional Area & Mgt

ML20213A052
Person / Time
Site:	Rancho Seco
Issue date:	12/19/1986
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
JEW-86-988, NUDOCS 8702030075
Download: ML20213A052 (32)

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$SMUDSACRAMENTO MUNICIPAL UTILITY DISTRICT O P. o. Box 15830, Sacrament 852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVIN EART OF CALIFORNIA OYf .13 JEW 86-988 ON December 19, 1986 J. B. Martin Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane Suite 210 Walnut Creek, CA 94596 Docket 50-312 Rancho Seco Nuclear Generating Station Unit #1 RESPONSE TO SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE FOR THE l PERIOD JUNE 1,1985 THROUGH JUNE 30, 1986 (REPORT NO. 50-312/86-29)

Dear Mr. Martin:

The Sacramento Municipal Utility District has conducted a ,

thorough management review of the Systematic Assessment of Licensee Performance (SALP) report, dated November 14, 1986, which provides the Nuclear Regulatory Commission's periodic performance evaluation of the Rancho Seco Nuclear Generating Station for the period June 1, 1985 through June 30, 1986. The District has reviewed the evaluated functional areas and identified performance weaknesses to ensure that sufficient management attention and adequate resources are allocated to achieve a higher level of performance.

The District considers that the SALP report generally provides an accurate and technically correct assessment of performance issues which occurred during the SALP period. The District's response to and clarification of certain weaknesses identified in the SALP i report is enclosed for your review and consideration.

With regard to the Operations functional area, the District considers that the statement on page 11 of the SALP report,

...the absence of all the instruments and parameters to control the plant in a transient from inside the control room...", is technically incorrect. The control room is designed in accordance to and in compliance with regulatory requirements and commitments concerning indication, annunciation and remote operation of pumps, valves, breakers, and other equipment necessary to mitigate the effects of plant transients. The District has also installed additional computer and annunciator points in response to past transients. These improvements can assist transient recovery, but are not necessary to control the plant during transient conditions. An auxiliary shutdown panel is also available to provide remote shutdown capability in the event of a control room evacuation.

8702030075 DR B61219 l ADOCK 05000 2 / 7 4,, )

RANCilO SECO NUCLEAR GENERATING STATION 14440 Twin Cities Road. Herald, CA 95638-9799;(209) 333-2935

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t t J. B. Martin 2 December 19, 1986 On page 12 of the SALP report, it states, "...The event involved failure to construct an operational Post Accident Sampling System...". The District considers this statement to be misleading in that it does not fully describe the circumstances surrounding the Post Accident Sampling System issue. Although startup testing of the system did not test all functions and equipment failures did lead to repeated operational delays, a Post Accident Sampling System was constructed. Post-construction problems were primarily equipment oriented and significant resources and management effort have been, and continue to be, directed to their resolution. At present, essentially al.

modifications of the PASS have been completed with the ex;eption of the in-line ion chromatograph. Efforts are underway to complete this item prior to restart.

The District also considers the statement on page 32 of the SALP report, " ...when it became necessary to reduce the accumulated liquid radwaste inventory, the licensee manipulated sampling techniques to release the liquid radwaste to the environment....the liquid effluent limits were exceeded...", to be misleading and it appears to imply that procedures were intentionally disregarded.

The water of interest was effluent from the Regenerant Holdup Tanks (RHUT). The RHUTs contain water which may be radioactive and require release as such or the water may not be radioactive and can be released with no specific accounting or tracking. The status of this water is determined by sampling and analysis.

In order to implement the technical specifications pertaining to radioactive effluents, the District analyzed samples of the water to determine if the sample was in excess of the Technical Specification Lower Limit of Detection (LLD) values. If the analysis determined the water to be in excess of the Technical Specification LLD, the water would be tracked and accounted for as radioactive. A counting time of 1000 seconds or greater had previously been established to assure compliance to the Technical Specification LLD requirements.

Since sensitivity and counting time are related (e.g. a longer counting time results in a greater sensitivity), effluent samples which were analyzed using counting times greater than 1000 seconds (typically 3000 seconds) occasionally resulted in the detection of gamma peaks for radionuclide concentrations which were in actuality less than the Technical Specification LLD.

Recognizing that a shorter counting time of 1000 seconds would have been sufficient to meet the Technical Specification LLD, the District considered recounting samples with detectable gamma peaks, for 1000 seconds to have been acceptable.

• . n J. B. Martin 3 December 19, 1986 In retrospect, the District acknowledges that a technical specification footnote required that effluent with any detectable activity, regardless of counting time, be considered and accounted for as being radioactive. At no time did the District intentionally disregard procedures or regulatory requirements.

Although the Technical Specification LLDs were always met, the District did not meet the requirement to report and track all effluent with detectable gamma peaks. It should be noted that the liquid effluents released contained minute quantities of radioactivity which were within the limits of 10CFR20 and did not pose a threat to human health or property. Our procedures in this regard are now fully in compliance.

On July 3, 1986, the District sent you a copy of our Action Plan for Performance Improvement at Rancho Seco. This action plan outlines a comprehensive effort to improve performance in every category evaluated by the SALP report. This action plan covers a L long term, determined effort to make Rancho Seco a source of pride to the District and to the nuclear powe" industry.

Amendment 2 of this plan was sent to your office on December 15, 1986. We are working with your staf f on an almost daily basis so that you will be kept apprised of our program.

In conclusion, the District believes that the SALP report generally provides an accurate assessment of its performance during the period June 1, 1985 through December 31, 1985. The District has evaluated the management weaknesses identified in the SALP report and has ensured that management attention and resources have been allocated to effect improvement as part of our action plan. The District remains committed to achieving prompt and significant improvement in all aspects of the operation of the Rancho Seco Nuclear Generating Station.

If you have any questions concerning these matters, please contact Mr. Ray Ashley at the Rancho Seco Nuclear Generating Station.

Sincerely,

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, W4 f,-~~3 3 ; . W rd Deputy General Manager, Nuc ar Attachment cc: Region V (2)

INPO I&E Washington DC

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o a ENCLOSURE Management Evaluation of the Systematic Assessment of. Licensee Performance (SALP) for the Period June 1, 1985 through June 3 0, 19 8 6.

Overall Results of SALP Assessment Assessment of performance was complicated during this evaluation period because of the fact that Rancho Seco has been shut down since December 26, 1985. Based principally upon the activities which occurred prior.to December 26, 1985, the Board found that the licensee's overall performance has declined since the last SALP evaluation period except in the area of fire protection.

Individual areas which contributed to this overall decline were plant operations, maintenance, emergency preparedness, security and safeguards, quality program and administrative controls, outages and licensing activities. The licensee's performance in the areas of radiological control, surveillance, training and engineering and construction was found to be unchanged since the last SALP assessment.

. District Response The SALP report's conclusion that overall performance has exhibited a decline as compared to the previous SALP period is based primarily on activities which occurred in the beginning of the current SALP period between June 1, 1985 and December 26,

, 1985. Prior to this SALP period, the District identified an

! overall trend of degrading performance at Rancho Seco in 1984 and i initiated efforts to identify and improve performance weaknesses

in the areas of hardware, management and administrative systems, organizational structure and staffing, maintenance, training l personnel.and physical facilities. Before implementation of this

! improvement program could affect measurable performance

improvements, several undesirable operating events occurred in i 1985 culminating in the December 26, 1985 loss of power to the i Integrated Control System.

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. s The December 26, 1985 event provided a clear indication that this improvement program required an increased focus and new direction to address the severity of existing performance inadequacies. To this regard, the District initiated a comprehensive Action Plan For Performance Improvement and voluntarily extended the shutdown following the December 26, 1985 event to identify and correct the root causes of performance weaknesses evident at the beginning of the SALP period.

In developing the Action Plan For Performance Improvement, the District has consciously avoided a previous tendency to apply a narrow focus in response to operational problems. The comprehensive scope of the action plan represents a substantial financial commitment which requires a sufficient time for implementation and achievement of long term performance improvement. The action plan utilizes diverse inputs for the identification of issues, a disciplined process for the systematic evaluation and management of the disposition of issues, a special organization to implement action plan activities, and clearly identified responsibilities for assuring the effectiveness and completeness of closecut actions. It includes a prioritization process which identifies actions which will be completed prior to unit restart as well as those of a longer-termed nature. In formulating and implementing the action plan, the District has been advised by an independent review group whose members have significant experience in the management and oversight of nuclear power plant operations, design and regulation.

The action plan reflects the District's intent to provide the leadership and resources necessary to improve the operational performance of the Rancho Seco Nuclear Generating Station. The District's Board of Directors emphasized this intent in its Policy Statement on the Performance Improvement Program at Rancho Seco by stating that it " considers the Performance Improvement Program...to be the District's highest priority activity" and that "The District's Board of Directors is committed to achieving a prompt and significant improvement in performance... and to provide the support necessary to achieve standards of excellence in all aspects of nuclear activities".

Indeed, the majority of the performance weaknesses identified in the SALP report were addressed by the action plan. Improvement in performance was apparent in the latter half of the SALP period as reflected by the improving trends in several SALP functional areas. The District is committed to maintaining improvements in these areas while improving other functional areas as the implementation of the Action Plan For Performance Improvement proceeds.

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1. Plant Operations SALP Conclusion Performance Assessment - Category 3. This area is characterized by operator errors during several off-normal events, procedural violations, lack of procedures, and incomplete event follow-up. Since the plant has been shut down since December, 1985, it is difficult to tell whether-corrective actions taken this year have been effective.

Trend: Declining SALP Recommendations Emphasis must be placed on following written procedures, formality of operation, and independent verification of plant configurations. Event follow-up must be thorough enough to find and correct the cause of operational events.

Management must insist on well written and complete procedures and extensive training, and a materially sound plant which will aid the operators in dealing with off-normal events, should they occur. A permanent management team must be developed.

With all the emphasis on other plant issues involving physical condition, procedures, et cetera, SMUD should not let operator performance decline.

District Response The SALP report expresses concern for the level of performance in plant operations. The prime concern is associated with weaknesses in the areas of procedures and personnel attentiveness to detail. Additionally, the report recommended that improvements are necessary in management involvement in assuring quality, and thus a reduction in challenges to safety systems.

In response to these concerns, the District has made certain programmatic and organizational changes. Increased staffing at the superintendent level has been accomplished to improve management awareness and response to operational activities ,

during the restart program. The responsibilities of the operations Superintendent have been separated such that two new positions have been established. The new operations Procedures / Projects Superintendent is charged with the responsibility for providing well written and complete 3

procedures. He is currently managing an extensive rewrite program for the emergency and casualty procedures in an effort to provide clear and explicit guidance for the operator to eliminate errors during abnormal events. The second new position, Operations Unit Superintendent, is responsible for the day-to-day operation of the plant. He will be available to directly increase management involvement in matters pertaining to shift activities. The segregation of duties will provide more effective management control over the activities that previously burdened one superintendent. These positions are under evaluation as part of the overall organizational restructure following restart.

The District has emphasized to all personnel the use of, and adherence to written procedures and the elimination of pro-cedure violations. In an effort to strengthen the District'is commitment to this issue and to increase visibi-lity of management's involvement in assuring quality, a management involvement program is under development. This program provides guidance. to ensure effective management involvement in daily plant activities on a first-hand basis; thus ensuring that the standards governing the work are consistent, well known and followed throughout the organization.

Corrective actions for past NRC concerns regarding verifica-tion of plant configuration is near completion. A program was established and implemented with the objective to verify the as-built plant configuration with P& ids and to incorpo-rate identified non-conformances into the drawings.

To provide the Rancho Seco restart effort with the most experienced operators available, an operator retraining program has been established. In summary, this program will provide operators additional team training on the simulator, and experience during Startup Testing and system qualifica-tion. The simulator training will include normal operating ,

evolutions in addition to casualty and emergency operating training.

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To further assure the adequacy of the on-shift operations during the restart and power ascension program, the following actions have been initiated. Currently, senior operations Division personnel are being assigned to shift coverage during major plant evolutions as defined by the Plant Manager. A shift advisor program is being developed to provide additional and continuous advise to the operating crews during the startup and test program through the completion of power ascension testing.

The District believes that these actions will provide the level of expertise necessary to make the restart of Rancho Seco safe and successful.

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2. Radiological Controls SALP Conclusion Performance Assessment - Category 3. The licensee's performance associated with PASS, the December 26, 1985 event, and radioactive liquid releases overshadowed the improvements observed in the radiation protection program '

during the last four to five months of the assessment period.

Trend: No overall trend was observed.

SALP Recommendations The Board recommends the following:

a. Timely implementation of the reorganization of the Chemistry, Radiation Protection, and the Technical Support group. The vacated Chemistry Superintendent's position should be filled as quickly as possible.

b. The licensee improve their NRC commitment tracking system.

c. Revise the Technical Specifications to improve the Radioactive Environmental Monitoring Program and to assure compliance with 10 CFR Part 50, Appendix I.

d. Complete the installation and testing of the Post Accident Sampling System.

District Response The District has addressed staffing and organizational concerns in the radiological control area by increasing allocated resources, restructuring the organization to more effectively support plant operation, and by filling key personnel vacancies with qualified personnel.

The Health Physics Support and Environmental Programs (HPSEP) Group was established as part of the restart organi-zation in October, 1986. The organization's function includes health physics support, ALARA programs and environmental programs. The group is currently staffed principally with contracted personnel. The Chemistry Supe-rintendent vacancy has been filled; Chemistry Supervisor 6

. s vacancies have been posted and advertised in an industry journal; Chemistry Foreman positions are being evaluated to determine the most efficient way to organize the department.

The post restart organization structure is under evaluation and staffing with District personnel is expected to be completed after restart.

As part of the restart organization, the responsibility for managing the radiological environmental monitoring program (REMP) has been transferred from Radiation Protection Group to HPSEP. The REMP has been reviewed in depth by HPSEP. Two principal items have resulted. The first item is the iden-tification of near-term needs in the environmental sampling program as detailed below:

The concept of control samples and indicator samples has been formalized.

The existing TLD program was determined to be adequate '

for the direct radiation and plume exposure pathway.

In the gaseous pathway, three principal items were determined:

a. The existing milk sampling program is adequate.

b. Air sampling needs to be upgraded with several near-site locations.

c. Edge-of-site gardens will be planted to improve leafy vegetable monitoring.

Most attention was given to review and upgrades in the i liquid pathway. The following items are being addressed:

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a. Add sample points for well, surface, and run-off water.

b. Install a timed composite stream sampler at the protected area outfall.

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c. Add several sites for downstream sampling of fish, algae, and invertebrates.

d. Add human and animal vegetation foodstuff sampling

at downstream locations which are known to be contaminated.

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e. Establish a garden, near the protected area boundary, which will be irrigated by plant effluent.

f. Add soil samples in downstream areas known to be contaminated.

The second item identified is the need for establishing a detailed data base of land use and pathway parameters which are specific to Rancho Seco. To accomplish this task, a large scale land use and pathway survey is planned for completion in early 1987, however, circumstances beyond the District's control (the refusal of counsel for certain parties who have filed suit against the District to permit his clients to be interviewed) have made obtaining such information difficult and may impact its completion. This survey is structured to establish sound statistical bases for usage and transfer constants and coefficients. It is also expected to serve as the basis for revising the Updated Safety Analysis Report (USAR), the ODCM data base, the land use census procedure, and the REMP.

Preparation of the Semiannual Effluent Report, the Annual Radiological Environmental Report, and the two radiation protection operating reports has been assigned to HPSEP.

Standard methods for preparing these reports have been established to address report uniformity and timelines.

Improved methods between Radiation Protection, Chemistry, and HPSEP have been established to facilitate acquiring correct data.

The procedures for releasing liquid from the regenerant hold-up tanks (RHUT) have been extensively rewritten with specific improvements in the following areas A system is included to predict the ef fect of a planned release on offsite dose and to track the total annual dose to date with respect to Appendix I guidelines.

Management approvals are required at more steps and at higher levels.

Duplicate sampling is performed for all pending releases.

The option to release a RHUT directly offsite has been eliminated.

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An appropriate counting time has been established as a -

standard for gamma analysis.

Concentrations which are required to be detected in the RHUT's are established based on projected dose in the environment.

A study is in progress to evaluate the feasibility of using sample results from locations upstream from the RHUT's for effluent control and a data management system for the effluent control and environmental monitoring programs is in the user needs specification stage. In addition, HPSEP has prepared a draft ALARA manual which also provides the policy and basis for procedures and manuals which are required toa effectively perform the radioactive effluent control and environmental monitoring programs. The procedures for liquid effluent release emphasize dose tracking with appropriate minimum detectable concentrations specified to meet 10CFR50, Appendix I guidelines. A new error analysis was completed and included in the first semiannual effluent report for 1986.

, The ODCM is currently undergoing detailed technical review l

and revision by the HPSEP staff. HPSEP has established internal controls to assure that review and approval as specified in Technical Specification 6.16 are accomplished.

A comprehensive review and revision of the Technical Specifications is in progress to correct site specific deviations from the standard Technical Specifications. The fact that the intent of Technical Specification 4.21.1 is to provide surveillance to comply only with 10CFR20, and is insufficient to provide compliance with the guidelines of 10CFR50, Appendix I, has been stressed to personnel involved with liquid effluent releases. Technical Specification 4.21.2 is being revised to provido detailed requirements for tracking offsite dose associated with liquid effluents on a real-time basis.

A system engineer has boon assigned responsibility to make the Post Accident Sampling System (PASS) operable. He interfaces closely with Chomistry, Engineering, and the Startup Engineer for PASS to achieve operability. PASS has boon added to the agonda of regular scheduling mootings.

The PASS will bo included for testing as part of the selected systems in the systems review and test program (SRTP).

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The chemistry operating procedures are written and the majority of the gas calibration is complete. Rebuilding of the ion chromatograph is also in progress under the cognizance of a chemistry consultant whose primary responsibility is PASS operation.

The District considers that these improvements will correct significant programmatic deficiencies in the radiological controls functional area which negatively impacted the performance rating observed during the SALP period.

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3. Maintenance SALP Conclusion Performance Assessment - Category 3. An improving trend has been evidenced in programmatic changes during this period, although operational events continued to reveal indications of previous weaknesses.

Trends Improving trend observed near the end of this period.

SALP Recommendation In order to produce a demonstrated improvement, sustained management attention is required to overcome the legacy of historically minimal maintenance. A series of operational events during this SALP period indicated a previously minimal program designed chiefly to satisfy technical specification requirements, and relying excessively on previous successful operation of equipment as the* basis for confidence in continued operability.

District Response since the SALP period, the District has continued to expand its maintenance program. The SALP specifically pointed out that previously, maintenance was provided only to satisfy technical specification requirements and that the District relied upon previous successful operation of equipment as a basis for confidence and continued operability. The cornerstone to changing that approach to maintenance is our commitment to an expanded balance of plant maintenance program such that inspection and maintenance, whether it be corrective or preventive, depends upon equipment function

• not safety class. An example is the preventiva maintenance (PM) program for manually operated valves which includes valves that are important to plant operations as well as valves that are technical specification related or safety related. The criteria for inspection of equipment dependo upon its function within the overall plant systems. The same approach has boon taken with the motor oporated valvo inspection program.

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. t In the area of staffing, the Maintenance Department has almost achieved authorized staffing levels: the one significant exception is the vacancy of Preventive Maintenance Supervi-sor in the mechanical area. The District is actively attempting to fill this position while evaluating the post-restart organizational structure.

Implementation of the programmatic aspects of improving the level of detail within work instructions, as well as control of work scope for. work activities, is underway. This is being addressed by the planning organization, which currently reports directly to the Maintenance Manager.

Quality engineering activities which provide a front-end review of proposed work and a final review of the work package have been included in this process. This has provided an essential programmatic link between Maintenance and the Quality Organization.

The measurement & test equipment (M&TE) and calibrated tool programs have been revised and modeled after the INPO Guidelines. In addition, the M&TE program has been expanded to ensure that installed plant instrumentation not covered by technical specifications and used for surveillance testing, is periodically calibrated as part of a PM program.

A new maintenance information management Data Base System (NUCLEUS) has been selected for implementation. Once the NUCLEUS system is operational, copies of machinery history will become accessible for comprehensive equipment trending.

In addition, the District is committed to develop a trouble-shooting (diagnostic) procedure for maintenance equipment problems. This will be accomplished prior to Restart.

The District considers that these programmatic changes will continue the improving trend observed near the end of the SALP period.

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4. Surveillance SALP Conclusion Performance assessment - Category 2 which is the same as the previous SALP. The licensee appeared to have met the surveillance requirements during this SALP period. The licensee's efforts currently underway to improve the procedures would enhance the overall program effectiveness.

Trend: Improving at the end of this SALP period.

SALP Recommendation The licensee should consider expansion of the scope of the surveillance program to address instrumentation which is important to operation but not specifically required by Technical Specifications, completion of the surveillance i procedure rewriting effort, implementation of a formal surveillance training program, and automation of a computerized scheduling system for surveillance.

District Response The District has directed management attention to the

improvement of the surveillance program. A high priority has been placed on meeting technical specifications and regulatory commitments, particularly in the area of

surveillance testing. The calibration of instrumentation important to the safe operation of the plant will be improved by a programmatic upgrade of the preventive maintenance program. Surveillance procedures are being rewritten pursuant to a new writer's guide which provides standardized procedural requirements and format and improves the performance and review process. Documentation of instrumentation calibration data within the procedure will provide a check of the preventive maintenance program for

, those instruments important to verifying the operability of plant systems.

The District is improving the method by which components and instrumentation are scheduled for calibration and operabili-ty checks by implementing a computerized surveillance scheduling program. The initial development of this program has been completed and functional testing is underway.

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INPO Self* Evaluation Reports on training programs for personnel accomplishing surveillance activities have been submitted to INPO for review. Accreditation of these training programs will establish formal training for these personnel.

To assure compliance with Technical Specifications, the District has developed a cross reference of the Technical i

specifications to the surveillance procedures. A guideline has been established which will require a detailed review of each Technical Specification Amendment to ensure that the i cross-reference is maintained current. The importance of communication in updating the cross-reference has been emphasized.

1 The District considers that these improvements will enhance l the overall effectiveness of the surveillance program.

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5. Fire Protection SALP Conclusion Performance Assessment - Category 1 Trend: Same.

SALP Recommendations Continued management attention is warranted in this area to ensure procedural revisions are completed, to ensure that the plant staff hiring is completed, and to close out items listed in the fire barrier penetration Special Report.

District Response The District will ensure that management attention remains focused on the fire protection functional area. The District plans to increase staffing in this area by hiring permanent staff members to implement the fire protection program. A fire protection procedure development and improvement program is underway which includes surveillance procedure reformatting, annunciator procedure upgrades and restucturing of administrative procedures.

These improvements will include an update of the fire pre-plan and an integration of the pre-plans and annunciator procedures to improve operator contingency response.

In the area of fire protection training, the District will develop an improved training program for general employees, fire protection staff and fire brigade members.

The District will provide an improved fire protection computer program and data base to track system malfunctions and impairments, limiting conditions for operation, breached fire barriers, transient combustibles, fire watches, ignition source permits and procedure status. The detection and suppression systems will be modified to provide greater reliability and to correct identified deficiencies and improve response to fire threats.

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6. Emergency Preparedness SALP Conclusion Performance Assessment - Category 3. The performance assessment for the previous SALP period was a Category 2.

Trend: Declining.

SALP Recommendation Management should improve their support and oversight of the EP Program, particularly in the areas of training, dose assessment, maintenance of the emergency plan and related implementing procedures and records associated with the EP program.

Quality Engineering, or a like group, should become directly involved in assuring the timely resolution of identified inadequacies and weaknesses in the EP program.

District Response The District has responded to many recent violations and audit items with programmatic changes rather than specific actions. This is demonstrated by the very successful annual drill conducted in October. The District believes that the quality of this year's drill is evidence that the District has turned the corner with the primary goal of maintaining the momentum of improvement. The District has established priorities to improve emergency preparedness (EP) capabilities. All incoming mail containing potential EP commitments will be screened by a commitment tracking coordinator who will assign responsible parties within the EP Department and a due date. Existing historical commitments have been accounted for, filed, and entered into the EPIC system (EP computerized, commitment tracking program). Responsible parties are notified of their individual commitments weekly, and the EP Manager reviews program status at a weekly staff neeting. This tracking program will address concerns regarding liRC initiatives and repeat audit items.

Personnel turnover continues to be a problem and over three years of active recruitment has not solved the problem. A re-assessment of the EP organization, including salary levels, will be performed and aimed at avoiding the continual loss of qualified personnel to other, higher paying District positions or other employers.

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. t The Emergency Plan and Implementing Procedures are being upgraded prior to restart to include lessons learned from the December 26, 1985 event. Other procedures and associated plan sections will be upgraded by the end of 1987. The restart portion includes a complete revision of the dose assessment procedures and computer equivalents for the control room, TSC, and EOF to include multiple release points.

Offsite notification improvement will result from a rewrite of the notification procedure prior to Restart. The retraining of operators and communicators has occurred which emphasized the 15-minute constraint.

An EP training Group has been formed and training schedules scoped for 1987. District Emergency Response Organization (ERO) training records will be maintained by the Nuclear Training Department with data entry current by March 1, 1987. Appropriate plan and procedure upgrades will be made to reflect this program. Offsite agency training records

, are maintained at the EOF.

With the exception of four clerical persons, all ERO staff completed training in 1986. Update training is occurring as necessary to address procedure revisions. Offsite agency training for 1986 has been completed as scheduled in the areas of meteorology, training, maintenance of required records, maintenance of the Emergency Plan and Implementing i Procedures.

The Meteorological (MET) Working Group is being formalized by charter to ensure effective surveillance of the meteoro-logical program. The most recent NRC inspection of the MET program pointed out some program weaknesses, but no deficiencies or violations. In addition, a recent QA audit has been issued and responses developed. Implementation of corrective actions, including a schedule for acquisition, procedure development and training for a variable trajectory dose projection program, will be followed through EPIC under the cognizance of the meteorological coordinator.

The EP Department is establishing an independent filing system in conjunction with nuclear records management guidelines. This system will be defined and functional by restart.

The District believes that these improvements will reverse the declining trend observed in the Emergency Preparedness functional area.

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7. Security and Safeguards SALP Conclusion Performance assessment - Category 3. While significant problems were identified during the appraisal period, the licensee's actions to date and the preliminary results of the SPIP implementation indicate that improvement has been achieved during the latter part of the report period.

Trend: Improving.

SALP Recommendation Licensee management is encouraged to expand their support of the station security program and the QA overview of this program including but not limited to the following:

frequency and root cause analysis of security events security force training frequent compliance monitoring (quality control) implementing security program improvements in areas being identified by the NRC Regulatory Effectiveness Review teams and discussed with licensee management by NRC inspectors (e.g., protected and vital area access control; alarm station operation, and safety / security interface).

District Response Weaknesses identifjed in the SALP functional area of Security and Safeguards have been addressed in a Security Improvement Plan (SIP) submittal to the NRC March 10, 1986 and updated on November 17, 1986. The implementation of the SIP includes the following improvements which should enhance management performance in this area:

a. New, state of the art, x-ray package inspection system was installed.

b. The number of security training instructors was increased and they are currently rotated en an annual basis. Lesson plans were reviewed, updated, and expanded.

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c. All incident reports are now entered into an IBM PC computer for purposes of tracking and dissemination of trends to management personnel for their action.

d. A security compliance auditor has been added to the corporate security staff to perform independent audits of the nuclear program.

e. A redundant site perimeter fence is being installed.

f. Additional supervisory staff was added to security watches.

g. Many improvements have been made in procedures for access controls, alarm assessments, etc., as detailed in the SIP.

The District believes that these expanded support capabili-ties and the increased management review of security activities should improve performance in this functional area.

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8. Outages SALP Conclusion Performance Assessment - Category 2. Although the licensee has had several serious outages, they have demonstrated some ability to manage outages. It is also apparent that the licensee is capable of comprehensive reviews, but has shown some reluctance during this period to initiate the reviews.

Trend: Not apparent.

SALP Recommendations The licensee should emphasize effective corrective action of the weaknesses identified by their Action Plan for Performance Improvement and other programs.

District Response The District has established an Incident Analysis Group that is responsible for the investigation of incidents, the determination of root causes and the recommendation of corrective actions to resolve and prevent recurrence of problems. The root cause program is procedurally chartered to investigate, in detail, events to ensure that all valid programmatic issues are identified, addressed, and corrected. The techniques used by this group include MORT (Management Oversight and Risk Tree Analysis), Barrier Analysis, Events and Causal Factors Charting, and Events Analysis.

The District is also participating in the B&W Owners Group project to improve unit availability. A key factor in the project is that each participating utility develop a root cause group, largely patterned after the District's program, but with the expanded responsibility for the Transient Analysis Program. The District intends to expand the root cause program to include this analysis. Procedures are i presently under development to establish the District's Incident Analysis Group as the coordinating group for response to transients. This new program will have essentially the same elements that the District developed in its Troubleshooting Action Plan, with the Incident Analysis Group serving as the central focus for those activitios.

Technical analyses will continue to be performed by support groups (such as Nuclear Engineering Corp., Babcock & Wilcox and Technical Support), but all such analyses will be compiled 20

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and the final Transient Assessment Report will be produced by the Incident Analysis Group.

These actions will assure a depth of review that will result in improved reliability and performance of Rancho Seco.

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9. Quality Programs and Administrative Controls SALP Conclusion Performance Assessment - Category 3. This has declined from the previous SALP Assessment. The ineffective corrective actions and meeting minimum requirements approach resulted in significant events and extended shutdown. The more positive philosophy by the new management promised improvement.

Trend: Improving.

SALP Recommendations The licensee should ensure active involvement by the QA organization in the restart / recovery program, more promptly resolve issues identified by the NRC, and consider quality programs which extend beyond quality Class 1 and safety-related systems and activities.

District Response The District has implemented various improvements to Quality Programs and Administrative Controls. The Quality Assurance (QA) Department has assumed responsibility for the procedure which governs the implementation of the restart recovery action plan. QA reviews Systems Status Reports and System Investigation Reports (SSR/ SIR) and resolves differences with the System engineer, reviews important submittals to the NRC to assure that all issues are adequately addressed and verifies the closure of action items.

Plans are in place for providing quality control inspections for quality classes 1 and 2 ASME/ ANSI, and environmentally /

seismically qualified equipment. All completed " inspection" required work requests are reviewed by QA.

Additional improvements in this functional area include the followings

a. A procedure was issued which describes the action item closure verification process,

b. One quality engineer was assigned full-time to sid licensing in closing out NRC open items and to vurify closure, 22

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c. Contract personnel were added and the budget includes additional contract and permanent personnel for 1987,

d. The audit organization was reorganized in order to  !

report to the Site Quality Manager. The post restart i organization is under review.

! e. The audit group was moved to the plant site, and

f. Quality personnel were assigned full-time to I J restart / recovery program groups such as the Recommendation Review and Resolution Board (RRRB), and

,' Performance Analysis Group (PAG).

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! The District is confident that these improvements will renew the qualify of operational activities at Rancho Seco.

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10. Licensing Activities SALP Conclusions Based on our evaluation of licensing activities, a Category 3 rating is assessed for SMUD licensing performance for the period June 1,1985 to June 30, 1986.

i Trend: Not observed.

SALP Recommendations SMUD management should provide a high level' of involvement in licensing to assure improvement; and specifically in the oversight of Technical Specifications to improve the quality of amendment submittals.

District Response The District agrees that past performance in the area of licensing has shown the need for improvement. Recognizing this need, the District is reordering the management organization to centralize licensing / regulatory activities and has allocated appropriate staff resources that will accomplish the SALP Board recommendations. These steps will strengthen the District'is licensing activities.

In the past, licensing activities have been performed by diverse groups throughout the District's nuclear organization. To ensure that licensing activities receive appropriate management attention during the restart program, the District has consolidated the activities of Regulatory Compliance, Incident Analysis and Licensing under the Manager, Nuclear Licensing. The Manager, Nuclear Licensing has extensive licensing experience and is responsible for ensuring the quality of licensing activities. The post restart organization and staffing are under review.

The District has ensured that regulatory compliance issues receive the appropriate level of management attention.

Resources allocated to improve the District';s timeliness in reporting licensee events, verifying Technical Specification compliance, responding to enforcement issues, dispositioning occurrence description reports, and coordinating onsite NRC activities are being studied as part of the overall organization restructure following restart.

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• k i The District has instituted a formalized incident analysis

/ root cause program, which has been allocated extensive resources and provided with management support. The results of this groupOs activities are reviewed, and corrective actions approved by a management review team to ensure proper management attention.

The District has implemented a procedure for the generation of technical specification amendments. This procedure ensures that adequate attention is given to the quality of the submittal and that proper management review by the Plant Review Committee (PRC) and the Management Safety Review Committee (MSRC) is obtained. Additional guidance on the preparation of safety analyses and "No Significant Hazards Determinations" has been provided. The results of these efforts were apparent when favorable NRC comments were received with respect to recent diesel generator technical specification submittals.

The District has taken steps, and is continuing to do so, to further strengthen its licensing activities. Some of these steps include:

Revision of procedures and guidance for the determination and the preparation of safety analyses (10CFR50.59) to reflect INPO good practices and the Districths own lessons learned.

The consolidation of licensing-related activities under l the Manager, Nuclear Licensing.

Initiation of a program to improve commitment management.

Initiation of a program to improve dissemination of j licensing information to District nuclear managers.

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i The District is confident that it is taking the necessary steps to improve its licensing activities at Rancho Seco.

, The increased management attention and plans for further i strengthening of the program will ensure continued improvement in this area.

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11. Training and Qualification Effectiveness SALP Conclusion Performance Assessment - Category 2, compared to the rating of a marginal 2 for the previous SALP period. The licensee has appeared to have accomplished the required training program during this SALP period. However, the ability of the training program to go beyond minimum requirements and adequately prepare the personnel for off-normal events needs emphasis. Management's increased attention to training has been beneficial in this area and has been demonstrated by recent training reviews. It was also noted that the training program for security officers and emergency preparedness in the beginning of this SALP period was being neglected by management.

Trend: Same.

SALP Recommendation Implementation of a comprehensive and effective training program is important. The emphasis must be on-going beyond the effort required to just establish or maintain the program. Increased attention to training of the staff on combating off-normal events is appropriate. Emphasis on the security and emergency preparedness programs should continue, as well as the licensee's effort to obtain the INPO accreditation for the training programs.

l District Response The District has provided resources in the functional area of training which represent a threefold increase since the beginning of the previous SALP period. The restart Nuclear Training Department presently consists of thirty-eight permanent employees and approximately twenty training consultants. As stated within the SALP report, the Training organization is at the department level. The District has submitted all ten Training Program Self-Evaluation Reports to the Institute of Nuclear Power Operations (INPO) for review. Four programs were accredited in April of 1986, and

! the other six programs were submitted six months ahead of schedule and will be formally evaluated in April of 1987.

The 1986 NRC evaluation of the District's operator requalification program received satisfactory results. The requalification training program, however, has been revised 26

• ,s, and strengthened due to recent events. The District has increased the simulator training for operators to twice that taken in 1985. Rancho Seco senior management now attends and evaluates this training at Lynchburg, Virginia. The District is also increasing the level of Diagnostics and Team Training given to operations personnel.

Requalification training attendance is mandatory for all licensed operators and instructors, with all sessions missed requiring make-up.

The emergency plan training for Ranch Seco has been completed for 1986, and the emergency plan exercise was successful. The District has instituted a mini-drill program for our operations personnel. This is to keep them abreast of any changes in procedures and improve their incident response and event recognition.

Overall, the District has improved the effectiveness of the Training Department during the evaluation period and plans to continue to improve the quality of training and its responsiveness to plant needs.

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12. Engineering and Construction SALP Conclusion Performance Assessment - Category 2. This area was characterized by several indications of the licensee's commitment to perform well, with the exception of insufficient management involvement to assure quality work was accomplished in all engineering areas for plant modifications.

Trend: Same. The licensee's efforts have been centralized on efforts to correct past deficiencies that have surfaced throughout this SALP period.

SALP Recommendation The Licensee's efforts should continue to discover existing engineering errors and to ensure correct engineering work is done right the first time.

District Response The District plans to develop a new Nuclear Engineering Department organizational ctructure following restart to improve responses to operational concerns, to improve configuration control, to strengthen the depth of resolution, and to maximize performance commitment through attention to detail.

The District has provided several staffing and organizational changes to improve the Nuclear Engineering Department and its interfaces prior to restart. A permanent Manager of Nuclear Engineering has assumed control of the Nuclear Engineering Department. The importance of configuration control was emphasized by creating a Configuration Control Supervisor reporting directly to the Manager, Nuclear Engineering. The design / drafting function was re-organized, given new direction, and reports directly to the Manager, Nuclear Engineering. Initial accomplishments include a substantial reduction in drawing change notice (DCN) backlog and an upgrade of the master equipment list controls. Both programs are continuing to receive attention towards further improvement. .A System Design Engineers program has been. developed within Nuclear Engineering to support Nuclear Plant System Engineers during the restart effort. These organizational changes are under evaluation as part of the post restart organization.

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'The District has implemented several procedural and programmatic improvements. An action tracking system within Nuclear Engineering has been developed to ensure issues are addressed, to improve response time, and to verify that responses address issues thoroughly.

The District has implemented a design change program to ensure that design changes receive comprehensive reviews prior to commencement of physical work and to ensure that all resources required to execute the changes are identified and available. This program will be further developed in conjunction with the configuration control program to

improve the design change package program and procedures. A revised design change procedure to streamline paperwork, to introduce a field problem resolution process, and to reflect organization changes, has been implemented.

The first draft of the Nuclear Engineering Configuration Management Process (RSMP 301) which will enhance design control, document control and configuration control has been completed and an engineering action request (EAR) program to improve response to plant problems has been initiated. The District is continuing to upgrade design bases for nuclear steam supply (NSS) and major balance of plant (BOP) systems and plans to establish a fuel integrity program and a project team to ensure that the control room simulator f

project is executed thoroughly and expeditiously.

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