ML20214U940

Forwards Rev 0 to Engineering Action Plan. Plan Is Part of Continuing Efforts to Upgrade Performance of All Depts Supporting Facility Operation.Activities Currently in Progress or to Be Implemented Described

ML20214U940
Person / Time
Site:	Rancho Seco
Issue date:	06/04/1987
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Crutchfield D Office of Nuclear Reactor Regulation
Shared Package
ML20214U944	List: ML20214U940 ML20214V508 ML20214V525 ML20214V540
References
GDC-87-054, GDC-87-54, NUDOCS 8706110384
Download: ML20214U940 (1)

Text

esuu.SACRAMENTO MUNICIPAL UTILITY DISTRICT O P. O. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA GCA 87-054 JUN 0 41997 Division of Reactor Projects Dennis M. Crutchfield, Director U.S. Nuclear Regulatory Commission Philips Bldg.

7920 Norfolk Avenue Bethesda, MD 20014 DOCKET 50-312 RANCHO SECO NUCLEAR GENERATING STATION UNIT 1 LICENSEE NO. DPR-54 ENGINEERING ACTION PLAN, REPORT NO. D-0050, APRIL 17,1987

Dear Mr. Crutchfield:

Enclosed is a copy of Revision 0 of the Engineering Action Plan (EAP) .

discussed in the April 28th meeting held at the Region V office between l NRC and SMUD representatives. This plan is part of our continuing efforts to upgrade the performance of all departments supporting the '

Rancho Seco operation. It describes activities currently in progress or to be implemented in the near future to achieve desired goals in the engineering design process, design reviews and baseline documentation. 1 The Engineering Action Plan is a living document. A revision is planned to incorporate comments from the Region V meeting, and issues discussed in the NRC Augmented System Review and Inspection Report 50-312/87-14 dated April 15, 1987. He expect this revision will be complete by June 24, 1987.

Please contact Mr. Gregory Cranston, Manager, Nuclear Engineering on extension 3963 if you have any questions. ,

Sincerely, Y bahfwas

f. Carl/Andogn4f11 Chief Executive Officer, Nuclear Attachment cc w/atch: '0 1

G. Kalman, NRC, Bethesda (2)

A. D'Angelo, NRC, Rancho Seco Brian Grimes 8706110384 870604 PDR P

ADOCK 05000312 PDR RANCHO SECO NUCLEAR GENEHArtNG STATION C 1444o Twin Cities Road. Herald, CA 95638-9799;(209) 333-2935

ENGINEERING ACTION PLAN FOR RANCHO SEC0 NUCLEAR GENERATING STATION SACRAMENTO MUNICIPAL UTILITY DISTRICT Report No. 0-0050 REVISION 0 April 17,1987

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Manager, Nuclear Engineerir.g G. V. Cranston ,

5 7estart Implement 4t16n Manager W. Bibb i

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eneral Manager, Nuc r 4706MGM

Executive Summary This plan describes actions initiated or planned by SMUD t6 restore confidence in the engineering design and design process at Rancho Seco. It addresses improvements in:

• The design change process for future work

• The design reviews of work performed during the current outage

• The baseline Rancho Seco design (System Design Bases).

This first issue of the Engineering Plan places emphasis on current reviews and those process changes which are in progress. As elements of this program are implemented and schedules are finalized, this plan will be updated and incorporated into future amendments of the Rancho Seco Action Plan for Performance Improvement.

Because the District recognizes that the effectiveness of the Engineering Plan and the prevention of recurring design engineering problems are more likely to occur in concert with supporting organizational, administrative, and cultural changes, this plan summarizes the changes related to each of P these areas. ,

Based on our in-progress review of the NRC Augmented System Review and Test Program and on internal studies currently in progress, these changes are described below. (Future updates of this plan will provide further deta',1 concerning these changes.)

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Organizational Changes In contrast to an engineering department originally comprised of a core of SMUD personnel supported by contractors, all of whom worked in Sacramento, the engineering department now nas a permanent staf f of 85 working onsite. The group has been reorganized so that the overall organization reflects the appropriate delegation of authority, responsibility, and accountability. Heading the organizational structure is the Manager of Nuclear Engineering, supported by the Configuration Control Manager, Electrical Engineering Manager, Mechanical Engineering Manager, and Project Engineering Manager.

The Nuclear Engineering Department consists of:

• System Design Engineers who provide the necessary resource of system knowledge and coordinate resolution of design problems

• Design Assurance Engineers within the engineering disciplines who assist with resolution of programmatic and procedural issues e

• A Planning and Scheduling Group which provides improved

• control and coordination between all departments. This part

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of the group will ensure that engineering activities are more 4

s effectively planned both in terms of 1) time required to get the job done and 2) sequencing work to match plant priorities.

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Administrative Changes Tracking systems are in place and being implemented to control more effectively the administrative processes. These systems include computerized tracking of engineering action items through the Action Item Memo (AIM), tracking master equipment lists items to support design change package turnover, and establishing and tracking work plans with respect to unit rates, budget, and other managerial concerns.

Cultural Changes The key cultural change is directed towards a new definition of completed staff work. That definition is based on the understanding of all of the requirements for issuing not merely a technical answer, but a ,

technically-acceptable and functional Design Change Package.

Specifically, the responsible discipline must recognize that personnel involved in the design process:

• Should understand the problem before designing its resolution Must agree that completing the paperwork (e.g., calculations, l

• l master equipment lists, design basis updates, procedural changes, changes to technical specifications) is just as

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critical as the technical resolution .

• Must understand that the job is not finished until the last drawing change notice to reflect plant configuration is .

incorporated into as-built drawings.

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The next revision of this plan will:

i s Address the items identified in the Augmented Systems Review 3

and Test Program Inspection (50-312/86-41) and the results of the internal Design Calculations Review Program (as described in Appendix E)

• Include the specific actions for preventing recurrence of design engineering problems.

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TABLE CF CONTENTS Page Executive Summary. . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.0 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . I 2.0 Engineering Action Plan . . . . . . . . . . . . . . . . . . . . 3 2.1 Summary of the Engineering Action Plan . . . . . . . . . . 3 2.2 Elements of Engineering Action Plan. . . . . . . . . . . . 5 2.2.1 Engineering Process Changes (Summary) . . . . . . . 5 2.2.1.1 Configuration Baseline . . . . . . . . . . 7 2.2.1.2 Design Change Package Program. . . . . . . 9 2.2.1.3 Design Assurance Engineering . . . . . . . 11 2.2.1.4 ECN Closure. . . . . . . . . . . . . . . . 13 2.2.1.5 Calculations . . . . . . . . . . . . . . 15 2.2.1.6 Periodic Technical Reviews . . . . . . . . 17 2.2.2 Review of Outage Design Work (Summary). . . . . . . 19 2.2.2.1 Calculation Review and Correction. . . . . 21 2.2.2.2 System Status Report Items . . . . . . . . 24 2.2.2.3 Auxiliary Feedwater. . . . . . . . . . . . 25 Functiona'ity 2.2.3 Design Validation (Summary) . . . . . . . . . . . . 28 2.2.3.1 System Design Basis Reconstitution . . . . 30 2.2.3.2 System Functional Review . . . . . . . . . 33 2.2.4 Independent Reviews (Summary) . . . . . . . . . . . 35 2.2.4.1 Technical Oversight Committee. . . . . . . 36

, 2.2.4.2 SMUD Quality Audits. . . . . . . . . . . . 37 Y

l APPENDICES j Appendix A James G. Partlow (NRC) letter to John E. Ward (SMUD) A-1 l dated 3/11/87 .

l Appendix B RSMP 301, Rev. O, " Configuration Management Process" B-1 Appendix C G.V. Cranston Memorandum 87-188, dated Feb. 10, 1987 C-1 Appendix D Design Change Package Program Plan (draft) D-1  ;

Appendix E Design Calculation Review Program Plan E-1 l Appendix F Procedure QCI-12 (Systematic Assessment Process and F- 1 System Review and Test Program)

Appendix G NEP 4121 Rev. 2 " System Design Bases" G-1 Appendix H System Functional Review Procedure H-1 Appendix I Quality Assurance Audit Plan I-1 Appendix J Nuclear Engineering Department Organization J1 e

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1.0 Intrcducticn After the December 1985 overcooling event, the District began a ,

1 program of plant evaluations that have resulted in numerous design mcdifications scheduled to be implemented during the current outage. The review program is described in the Rancho Seco Action Plan for Performance Improvement. Nuclear Engineering particpates in the ongoing system review elements of this program and in preparation and support for implementation of design modification packages.

In the course of this effort, the District has recognized that a program of ongoing design reviews and further improvements in the modification design process are needed to strengthen Nuclear Engineering's ability to support plant operation. Areas of concern were identified by the District in such documents as the System Status Reports. Additionally, areas of strength and areas of concern were identified in recent independent reviews of engineering activities by the NRC in the Augmented System Review and Test Program Inspection and by INP0. The areas of concern noted by the NRC and INP0 have provided additional observations reinforcing the need for continuing improvement in engineering programs, as well as specific corrective action related to current outage work.

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4 The elements of Engineerir.g's action plan are described in the following sections. fluclear Engineering's objective with this program is to continue in the direction of developing a mature engineering department with solid baseline documentation and effective controls over the quality of work.

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2.0 Enaireering Acticn plan 2.1 Summary There are three primary objectives of the Engineering Action Plan. These are:

A. Upgrade the engineering design change process to improve the quality of work performed in the future.

B. Review elements of work performed during this outage to assure design adequacy.

C. Re-establish the plant System Design Bases including in-depth system functional reviews and reviews of past design work, which includes review of previous (to the Cycle 7 outage) design changes, calculations, design criteria, etc.

The primary elements, along with the implementing program, are shown in Figure 2.1.

In each area, specific tasks are underway or planned to accomplish these objectives. These are discussed in the following sections, with the formal department plan, procedure, or program provided in the referenced Appendix. ,

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ENGINEERING ACTION PLAN CONFIGURATION BASELINE ECN CLOSURE CALCUL ATION PROCEDURE U PERIODIC TECHNICAL l 8 PROGRAMMATIC REVIEWS CHECKLIST REVISION l PROCESS ( 2. 2.1.11 ( 2.2.i.4) ( 2. 2.1.5) lj ( 2. 2.1. 6 )

CHANGES l l l l l l _

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! DESIGN DCP TECHNICAL ASSURANCE ' '

PROGRAM COMMITTEE l

ENGINEERS

( 2. 2.1.3 ) ( 2 . 2 .1. 2) , ( 2. 2. 4.1) ll I

CALC ADDED SMUD ,

^LITY REVIEW SSR ITEMS UD 7 U T (2.2.2.1) (2.2.2.21 ( 2. 2.4. 2) i O

e WORK l l l POST RESTART SSR WORK' AFW l FurCTIOrr(ITY l

l (2.2.2.3 ) F SYSTEM 1 DESIGN BASES SYSTEM SYSTEM DESCRIPTION & hl 4m(5 SYSTE MS)+

FUNCTIOflAL REQUIRMENTS REVIEW DOCUME 14TS (5 SYS TE MS ) ll SYSTEM SMUD REV.I DESIGN (2.2.3 ) (2.2.3.1) (WORKING DRAFTS) ll DESIGil BASES SYSTEM ( 2. 2. 3.1)

, VALIDATION l l l l j (5 SYSTEMS) - FU i NAL =

SYSTEMATIC SYSTEM REV.O i ASSESSf ( ES gSgo pg pg TESTING _( 2.2. 3.1)

(2.2.3) ( 2. 2.3 ) I

• REVIEW Y l

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TEST I WORKING ( 2. 2. 3.1 ) ,

GROUP l (2.2. 3 )

FIGURE 2.1

2.2 Elements of Encineering Action Plan 2.2.1 Engineering Process Changes The District is proceeding with changes to the design change process that will provide increased assurance of the quality of modification packages released for installation and improved integraticn of closure activities before turnover of the completed modification to plant operations. These changes are motivated by experience with the present modification process during this outage, as well as observations from INP0 and the flRC.

Under the direction of a permanent Configuration Control Manager, a baseline configuration will be established that correlates the as-built plant configuration with baseline documentation. A Design Change Package program will be implemented to facilitate integrated reviews of modifications prior to release. These packages will contain design basis information, safety analyses, and design output documents. The analytical basis for design, i.e., calculations, will be strengthened by issuing a good practices supplement to the present NEP 4106,

" Design Calculations".

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Implementaticn of these changes will be facilitated by a function called Design Assurance Engineering, consisting of designated representatives from each engineering discipline. These engineers will do design engineering as well as being functionally matrixed to the Configuration Control Manager to provide a resource of people to identify and resolve programmatic and procedural concerns with the design process and institute corrective action to prevent recurrence. To provide added confidence that the proposed effort is achieving desired improvements, periodic technical and programmatic reviews by an offsite technical organization will be instituted.

The following sections discuss the specific elements of this program.

2.2.1.1 Config'uration Baseline 2.2.1.2 Design Change Package Program 2.2.1.3 Design Assurance Engineering 2.2.1.4 ECN Closure  !

2.2.1.5 Calculation Procedure Revision j 2.2.1.6 Periodic Technical Reviews O

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,2.2.1.1 Conficuration Baseline Issue .

Additional improvements to plant baseline documentation, such as design bases and streamlined procedures to maintain as-built documentation, will reduce the potential for design or operational errors traceable to inaccurate or incomplete design records.

Resolution The configuration of the Rancho Seco Station will be managed.to ensure the station is operated, modified and maintained in accordance with the Rancho Seco Quality Program. The nuclear engineering configuration management process will address the regulatory and District requirements affecting configuration management, . including design control, document control, material control, and records control.

Engineering Action plan (1) Approach The Configuration Control Management responsibilitie,s have been defined under RSMP-301 " Configuration Management Process" (Appendix B). The process is being implemented under a multidiscipline effort to accomplish the following:

A) Reconstitution of the system design basis for the five systems subject to the system functional review (Section 2.2.3.2), and ultimately all key plant systems.

B) Upgrade of the construction specifications to reflect current criteria.

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C) Valication of the design data elements of the cceponents in the Master Equipment List (MEL).

E) Establishment of a configuration status accounting process to ensure that changes to the configuration baseline are recorded and disseminated in a timely ranner.

(2) Design Output

' - System Design Basis Documents (See Section 2.2.3.1)

- Construction Specifications (Approximately 30) i' -

MEL design data validated ,

- Configuration status accounting system on-line 9

(3) Status as of 4/13/87

- Construction Specifications - 50% complete

- MEL Design Data validated - 15% Class 1 equipment data complete i

- Configuration status accounting system - ?0% complete l

- System Design Basis Documents (See Section 2.2.3.1)

(4) Closure schedule Prior to Restart

- Five System Description and Function Requirements documents l issued (See Section 2.2.3.1)

Post Restart

- Remaining items 4

2.2.1.2 Design Change Package Program Issue The current method of preparing modification packages is complex and fragmented with respect to interfaces among disciplines and departments in the preparation, review and closure cycle.

Resolution The District will implement a Cesign Change Package program under the auspices of the Configuration Management Process. The Design Control Program will define a method for reviewing and implementing proposed design changes and defining authorized changes in discrete manageable elements, such that design basis, functionality requirements, design criteria, interfacing group reviews, licensing commitments, and other

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appropriate criteria are incorporated.

Engineering Action Plan (1) Approach ,

i The elements of the design change package currently befrg developed, consist of the following:

A) A process for requesting, fully evaluating, prioritizing, and

- authorizing design changes. This includes establishing criteria for the acceptance of proposed design changes.

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O B) A process for ensuring that technical requirements defined for the design change are comprehensive.

C) A process for implementing the design change package into the plant configuration and associated design baseline documents, plant procedures and training plans, while maintaining compliance with the technical specifications and other and licensing comitments.

D) A process to ensure that the design change package is properly pre-reviewed, issue.1, and closed, with revisions to. I the package being carried through all appropriate interfacing groups. ,

The draft plan is provided in Appendix D.

(2) Design Output Design Change Package Procedures (Approximately 15)

(3) Status as of 4/13/87 Design Change Package Procedures (Approximately 20'. complete)

(4) Schedule Procedure modifications are being made now and will be periodically made to incorporate elements of the DCP plan as they are completed.

2.2.1.3 Desien Assurance Enqireering Issue Restart activities have demonstrated a need to continually upgrade engineering procedures as the practices of engineering or interfacing departments evolve or weaknesses are identified. An efficient and centralized mechanism is needed to identify and correct engineering procedural problems.

Resolution Implement a Design Assurance Engineering program with personnel (designatedbytheDisciplineSupervisor)whosefunctionsarematrixed to Configuration Centrol Management. The Design Assurance Engfreerfrg Program will detect, i' valuate and correct programatic weaknesses in engti sering procedures-Enaineerina Action Pla_n, (1) Approach Nuclear Engineering has initiated a program of Design Assurance Engineering. Specific engineers from each discipline have been assigned design assurance responsibilities. Areas of The programmatic weakness will be identified and reported.

Design Assurance Engineer may still be available for discipline engineering responsibilities.

Design Assurance Engineer responsibilities incitde:

A. Providing guidance to each discipline on procedure interpretation and discipline practice.

B. Identifying programmatic weaknesses and working with the Configuration Centrol core group to upgrade procedures and training to prevent recurrance.

C. Assuring that interfaces with other disciplines and the plant on procedural issues are adequate.

D. Monitoring discipline implementation of engineering procedures.

(2) Expected Output In the near term, closure of ECN's will be docueented by concurrence of the Design Assurance Engineers and discipline Supervisors on the ECN closure checklist (see section 2.2.1.4).

Long term, the Design Assurance Engineers will participate in the ongoing effort to upgrade Nuclear Engineering procedures.

(3) Status as of 4/13/87 This program has been started. Designations of engineers with design assurance responsibilities have been completed.

(4) Closure Schedule

.This program will be integrated with the engineering program on a permanent basis.

2.2.1.4 Engineering Change f:otice Cicsure issue Existing engineering practices related to completion of design activities when closing modification packages are not clearly documented.

Resolution The District will implement a documented closure review of all restart related ECNs, using a memorandum checklist (Appendix C). Procedure NEP 4109, " Rancho Seco Configuration Control Procedure," will be revised to incorporate this checklist This is recognized as an interim progran until the Cesign Change Package Program is fully and successfully implemented.

Engineerino Action Plan (1) Approach For each ECN, the Cognizant Engineer will be responsible for completing a closure checklist. The checklist includes detaffs on the as-built review of the ECN, and verification that documentation is complete, and the activities of the interfacing disciplines and departments activities are complete. The checklist will be jointly reviewed by the Cognizant Engineer and the Discipline Design Assurance Engineer, and approved by the Discipline Supervisor.

(2) Design Output

a. Engineering Change flotice and Checklist

b. Completed ECN checklists for ECris which are scheduled for restart.

c. Revision to NEP 4109, " Rancho Seco Configuration Control Procedure" (3) Status as of 4/13/87 Completion of ECN checklists is in progress and the revision to NEP 4109 is in preparation.

(4) Closure Schedule This effort will be complete by restart and integrated into NEP 4109 and the the appropriate DCP procedures for future work.

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2.2.1.5 Calculaticns l l

Issue Some calculations have been found to be difficult to follow, with assumptions and conservatisms not clearly stated and lacking complete references. Procedural requirements are not definitive with respect to acceptable levels of clarity.

Resolution The procedure which governs control of design calculations will be revised to include a " good practice" guideline which defines acceptable technical and quality requirements for Nuclear Engineering calculations. In addition, an immediate review is being conducted of recent design calculations to assure technical adequacy as discussed in section 2.2.2.1.

Engineering Action Plan (1) Approach The Design Assurance Engineering core group under the purview of configuration control management will revise NEP 4106, " Design Calculations" to include a good practice guideline. Formal training will be conducted on calculation technical and quality, standards. ,

(2) Expected Output (a) Revision to NEP 4106, " Design Calculations."

(3) Status as of 4/13/87 The revision to procedure NEP 4106, " Design Calculations" is in progress.

(4) Closure Schedule By Restart.

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u 2.2.1.6 Periedic Technical Reviews Issue The' quality of engineering output can be improved by strengthening the design verification and review process.

Resolution Nuclear Engineering will establish a program of pericdic technical reviews. The reviews will be performed by independent, senior level ,.

professionals, and will emphasize both technical and programmatic aspects of the department.

l Engineeffnq Action Plan (1) Approach An outside technical organization will be contracted to implement

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periodic reviews of engineering output at Rancho Seco. The team

! will be compri. sed of individuals with an appropriate cross section of backgrounds to evaluate the technical adequacy of design packages and calculations. The objective is to assure that an appropriate level of quality is maintained and that-i procedures and practices are appropriate.

(2) Design Output This review will be procedurally controlled and documented for

' -i corrective action and audit records.

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(3) Status as of 4/13/87 The Calculation Review Program current in progress in an example '

of this type of activity (Section 2.2.2.1)

, (4) Closure Schedule Post restart and ongoing.

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2.2.2 Review of Outage Design Work The District is engaged in continuing assessments of the ,

quality of work and the scheduling of resolution of known issues. The NRC's Augmented System Review and Test Program Inspection reinforced the need for this continuing self-assessment by identifying concerns related to some calculations and drawings prepared for work scheduled during the current outage. The audit team also recomended that several items not presently scheduled for completion during this outage be considered for completion prior to restart.

To address concerns with current modifications and calculations, a program of calculation reviews and modification reviews has been instituted. The calculation review will provide a comprehensive assessment of the technical adequacy of analysis performed for modifications being implemented presently. A sampling of modifications will also be reviewed to assure that the design objectives are met. (This will be integrated with the SMUD Quality Audits in Section 2.2.4.2.)

With regard to scheduling of priority 2 and 3 activities prior f

to restart, SMUD is proceeding with a review of items identified by the NRC inspection team. The District is proceeding with restart activities presented in the Rancho Seco l.

Action Plan, implemented under QCI-12.

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I The follcwing secticn discusses the specific elecents of this

- program.

2.2.2.1-. Calculation Review 2.2.2.2 System Status Report Items 2.2.2.3 . Auxiliary Feedwater Functionality Issues i

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2.2.2.1 Calculation Review and Correction Issue Nuclear engineering design calculations have some deficiencies such as improperly documented assumptions and problems with clarity. Examples have been identified where superseded calculations remain on file with current calculations.

Resolution A technical review of Nuclear Engineering Calculations will be performed. -

Engineering Action Plan (1) Approach The approach for conducting the calculation review has been divided into the following subtasks:

a. A review of recent engineering design calculations for technical adequacy will be performed. A calculation review team has been established from outside technical resources to independently review a broad selection of calculations associated with restart modifications. The focus will be on technical acceptability of the calculations. A cross-section of calculations in different discipline and technical areas will be reviewed, with an emphasis on unique or complex .

calculations for safety-related applications. The review i

procedure is provided in Appendix E. Deficiencies affecting i the design output of current work wil1 be corrected.

Based on their review, the team will make progrartmatic recommendations to correct deficiencies in the current review process.

b. Obsolete source documents:

A review of all system calculations for obsolete source documents will.be performed, and obsolete calculations will be deleted or revised to state they are obsolete.

Calculations will be revised as necessary to make-appropriate technical corrections, and the effect on plant systems of any calculation change will be evaluated. The first priority for '

this review will be all select systems,

c. Completion of calculations:

As part of the above effort, missing or preliminary calculat' ions will be identified. The reconstruction.or conversion of documents to fomal calculations will be performed,

d. Procedural controls on adequacy of documentation:

A " Good Practice Guideline" is b'eing added to Procedure NEP 4106, " Design Calculations." See Section 2.2.1.5

" Calculations."

(2) Design Output (prior to restart)

a. Design Calculation Review Program (see Appendix E)

b. Documented review of restart related ECN design packages for select systems (approximately 250 ECNs affecting all select systems)

c. Review of restart related calculations for select systems (approximately 100 calculations affecting all select systems)

d. Correction of calculaticns or procedures

e. Formal review observations and ShiUD responses to document all action taken as a result of the review These activities relate to subtask (1)a above. Other subtasks will be completed after restart.

(3) Status as of 4/13/87 Review of restart ECNs and associated calculations is underway with approximately 80% complete. Initial results indicate that the observations are generally similar to the NRC vertical audit findings. There are concerns that relate to completeness and attention to detail, but no findings to date that would affect the safe and proper operation of the plant.-

(4) Closure The initial review of recent design calculations is scheduled to be complete by restart. Unless significant problems are found, the schedule for resolution will be parallel with that of the reconstitution of the system design bases or occur when the system calculations are reviewed in conjuncticn with a future design modification. Where significant problems are found corrective action will be taken prior to restart. Reviews for obsolete calculations and calculation completeness will also be performed in conjunction with efforts to develop System Design Bases (see section 2.2.3.3).

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2.2.2.2 System Status Report Items Issue The District and NRC identified items in System Status Reports to be reconsidered for resolution prior to restart. Generally, these were-in the areas of operating procedure changes, as-built documentation problems, or resolution of design problems related to previous Rancho

'Seco transients.

Resolution The District is evaluating these items and will provide a response under separate cover.

2 Enaineering Action Plan (1) Approach These items will be reviewed by the District and resolutions provided under separate cover.

(2) Design Output Nuclear Engineering will prepare any necessary drawing changes or design modification packages.

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2.2.2.3 AFW System Functionality Issues Concerns have been raised regarding AFW system functionality under all potential reviews. The specific concerns relate to:

A. Confirmation of the AFW Pump minimum recirculaticn flow, B. Surveillance testing of the CST Vacuum Breakers and pressure Relief Valves, C. Capacities of the CST Vacuum Breakers and Relief Valves, D. Surveillance of CST level indication.

E. Structural integrity of CST for over pressure or under pressure conditions.

F. AFW Pump runout under certain circumstances, G. Seismic integrity of the CST, i H. AFW Pump flow indication I. Motor overspeed, on a turbine overspeed event for P318, J. Maximum flow of AFW.

Resolutien A specific evaluation of functionality issues is being added to the System Status Report for Auxiliary Feedwater. Proposed resolution is summarized below: ,

A. The actual value of the recirculation flow will be verified by testing, and the appropriate supporting calculation identified.

The orifice diameter will be inspected for both AFW pumps.

B. The appropriate Surveillance Procedures for the vacuum breakers and relief valves wt11 be performed.

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C. The capacity calculaticn for the relief valves and vacuum breakers will be reviewed against the design limits of the tank structure.

D. The surveillance procedure test results for the CST level indication will be reviewed and performed.

E. The structural integrity of the CST is being reviewed against maximum tank pressure based on the as-found relief valve setpoints, and minimum credible vacuum in the tank.

F. Potential pump degradation at pump runout will be investigated.

G. The seismic integrity of the CST and the standpipe is being reviewed.

H. Engineering will evalbate flow indicaticn and modify flow indication such that appropriate flow indication is ava11able.

I. Engineering is evaluating the motor overspeed condition, considering the alternatives of qualifying the motor or reducing the overspeed trip setpoint.

J. The AFW system will be modified to include a flow limiting device to preclude exceeding the max'imum acceptable flow rate to the steam generators.

Engineerina Action Plan (1) Approach The resolution of AFW pump and CST issues are being documented in 4 the Aux 111ary' Feedwater System Status Report.

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(2). Design Output Additional analysis and modification packages are required.

(3) Status as of 4/13/87 In progress.

(4) Closure Schedule The closure schedule for these issues is under review.

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2.2.3 Desicn Validaticn The purpose of this program is to provide confidence in the baseline Rancho Seco design and, in a effort continuing past restart, documentation of baseline design requirements in a more retrievable form than at present.

Significant elements of this effort are presently in place.

These include the completed Systematic Assessment Program as described in Section 4A of the Rancho Seco Action Plan and the System Review and Test Program as discussed in Section 1.4 of the Acticn Plan. A parallel effort has been undertaken to prepare System Design Basis documents. After restart, a SMUD System Functional Review of five systems as discussed in section 1.4.2 of the Rancho Seco Action Plan will validate the design basis effort and provide a reference point for modifying and expanding the design basis program to all key plant systems.

The fo,llowing sections discuss the specific elements of this program, which are not discussed in depth in the Rancho Seco Action Plan.

2.2.3.1 System Design Basis Reconstitution 2.2.3.2 SHUD System Functional Reviews

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i The integration of program is considered to provide a thorough, in depth review of system design. Key elements will be complete before restart, but substantive evaluations will continue after restart with development of the System Design Bases and the

! System Functional Reveiws.

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2.2.3.1 System Cesicn Basis Reconstitution 1

issue The plant configuration has undergone a significant number of modifications throughout the plant operating history. In addition, design or licensing evaluations of conditions not considered in the original design have been performed. Through thfs process, the system design bases have evolved and may be difficult to retrieve.

Development of System Design Basis documents will recapture key design criteria and, in the process, provide an in-depth review of system design.

Resolutten Prior to restart, SMUD will compile Revision A documents called System Description and Functional Requirements documents for the 5 systems f described in the action plan to be reviewed in the SMUD System l Functional Review (Section 2.2.3.2). The documents these will be I compiled to reflect the current plant configuration, licensing

' commitments, and system functions and operating modes. A hierarchy of

! design bases from the system level to specific components will be i developed.

This effort will be expanded to other systems after restart.

Development of these documents requires a careful review of the 2

current plant design, and provides a review of design adequacy w.ith a different perspective than that of the System Review and Test Program.

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! Enaireerina Acticn Plan j (1) Approach i The long-term objective for the content of the System Design .

l Basis documents is as stated in Nuclear Engineering Procedure NEP 4121 " System Design Bases" (See Appendix G). On an interim

. basis, documents reflecting preliminary infomation for select i systems are available to System Design Engineers and System f

Engineers. Prior to restart, five of these documents will be l

l developed as Revision A " System Descripticn and Functional Requirements Documents," after review by the System Design Engineers.

After restart, documents for the first five systems will be o upgraded to the objectives of the NEP. The quality of these documents will be validated in the SMUD System Functional Review (see section 2.2.3.2), after which the effort will be expandad to additional systems.

When Revision 0 documents are issued, a configuration control procedure will be implemented to assure that the baseline documents are maintained current as design or licensing basis l-changes occur.

(2) Design Output Ultimately, System Cesign Bases will be in place for all plant systems as input to future design modifications, with the thirty three select systems receiving priority (as defined in 001-12.

" Plant Perfomance and Management Improvement Program "

AppendixF).

(3) Status as of 4/13/87 Work proceeding on documents for the thirty three select systems with emphasis on five systems that are identified in the action plan.

(4) Closure Schedule Ongoing e

2.2.3.2 System Functicnal Peview Issue System function reviews are needed to reconstitute the System Design Bases.

Position Section 1.4.2 of the Rancho Seco Action Plan describes SVUD's commitment that " systems critical to secondary side heat removal will undergo a long-tenn and more extensive review" than those of the System Review and Test Program. The review, "which is modelled after the safety system functional inspections by the NRC, consists of: a)

Design Basis reconstitution, b) reliability assessment of the system; and c) evaluation that individual components support the system design basis." Initially five systems are to be reviewed: Main Feedwater, Auxiliary Feedwater, ICS/NNI, Pressure Control Functions of the Main Steam System, and Instrument Air. The Action Plan states that "This comprehensive review of these five selected systems will be initiated prior to restart and will be ccepleted prior to ccming out of the

' cycle 8 refueling outage",

t Enaineerina Action Plan (1) Approach The System Functional Review will be augmented by the System Review and Test Program, identifying some issues that are outside the scope of previous reviews. Issues identified will be subject to broad, horizontal evaluations to resolve programmatic issues.

1 A reliability assessment of the system performed fr, parallel will give a frame of reference for evaluating the significance of l

identified issues. This evaluation will serve to validate the An quality of design basis documents currently in preparation.

! outline of a planned approach is provided in Appendix H.

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(2) Design Output The output of this effort, in general terms, will be resolutien of identified technical and programmatic issues, as well as feedback concerning the quality of the System Design Basis l

' documents.

! '(3) Status as of 4/13/87 Preliminary scoping of the System Design Basis work is underway.

remainder of the effort has been completed.

(4) Closure Schedule a

The effort is scheduled to be complete by Cycle 9.

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2.2.4 Independent Feviews The action plan described in the preceding secticn will be Although administered by the Nuclear Engineering Department.

several elements, such as the reviews of calculations and modifications, are intended to have a high degree of impartiality, it is considered valuable to provide an oversight function independent of fluclear Engineering. SNUD intends to provide this independent confirmation of plan effectiveness through the offices of the Restart Implementation Manager and Quality Assurance. Specifically, a Technical Oversight Committee of experienced industry professionals reporting to the Restart Implementation Manager will audit the technical effectiveness of the Engineering Action Plan. Also, SMUD Quality Department is adopting a program of vertical audits assessing the technical and programmatic effectiveness of design package implementation.

These activities are discussed in detail in the following sections:

2.2.4.1 Technical Oversight Committee 2.2.4.2 SMUD Quality Department Audits

2.2.4.1 Technical Oversicht Ccomittee Issue It is desirable to provide independent assurance to management of the effectiveness of improvement actions taken by the fluclear Engineering Department to address issues discussed in this plan.

Resolution A Technical Oversight Committee will be instituted, reporting to the Restart Implementation Manager, to review the adequacy of the programs outlined in the Engineering Action Plan.

Engineering Action Plan (1) Approach The Technical Oversight Committee will review the progress and output of tasks identified in the preceeding sections of this report. The Committee will review program definition, procedure development, work progress and output quality.

(2) Output Documented results will be issued at the conclusion of each review, identifying conclusions and recommendations.

(3) Status as of 4/13/87 Forecast date for initiating these reviews is 6/1/87.

(4) Closure Schedule This effort is scheduled to be complete by Cycle 8.

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2.2.4.2 SMUD Quality Audits issue Quality Department audits of Nuclear Engineering activities.

Resolution The Quality Department is presently committed to adopt vertical audit techniques to evaluate the effectiveness of Nuclear Engineering programs.

Engineerina Action Plan (1) Approach SP,UD Quality' Department personnel en a periodic basis, will review engineering practices and interfacing activities in other departments. To obtain an in-depth evaluation of program effectiveness one approach will be to review plant modifications from the initial stage of problem definition through final plant implementation. The Audit Plan for the intitial vertical audit is provided in Appendix I.

(2) Output Each review will be documented in an audit report detailing conclusions and unresolved issues.

O (3) Status as of 4/13/87 An audit team has been formed and preparation started for the intitial vertical audit.

(4) Closure Schedule Orgoing.

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UNITED STATES g NUCLEAR REGULATORY COMMISSION

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Docket No. 50-312 March 11,1987 R,,E ,C Ec our, ,IV E D .

$R 17 N Mr. John E. Waro 6 Tl84 g gg g gi$g d i Deputy General Manager, Nuclear Sacramento Municipal Utility District &

Rancho Seco Nuclear Generating Station P. O. Box 15830. Mail Stop No. 291 Sacramento, California 95852-1830

Dear Mr. Ward:

A special announced team inspection of the restart activities at Rancho Seco Nuclear Generating Station was conducted by NRC headquarters staff during the period December 1,1986-February 12, 1987. The team discussed the inspection findings with you and members of your staff during the course of this inspectior.

and at the exit meeting on February 12, 1987. This letter provides a summary ofthesignificantfindingsinadvanceoftheinspectionreport(50-312/86-41) so that appropriate corrective actions may be factored intn your restart planning activities. The findings listed below are only the more significant concerns identified during the inspection and provide neither a complete list of inspection concerns nor any of the strengths identified by the inspection team. A complete discussion of all the inspection findings will be provided in Inspection Report 50-312/86-41. The more significant inspection findings are summarized below:

1. Functionality Concerns:

a. The auxiliary feedwater (AFW) system pumps may not be able to provide the flow required by Technical Specifications. This problem may have been concealed by inadequate testing procedures, inconsistent cali-bration of the condensate storage tank (CST) level instrument and inaccurate (low) estimates of the minimum recirculation flow that is diverted from the steam generators. ,

b. The structural reliability of the CST may be in question due to im-properly set pressure relief valves and vacuum breakers that appear to be incorrectly sized and did not receive required periodic in-service testing.

I c. The AFW system may be susceptible to pump runout situations despitt:

Emergency Feedwater Initiation and Control (EFIC) System installation.

Operator action is still required to prevent runout under some cir-

, cumstances and the alarm and flow indication in the control room could provide unreliable information. The comitment to install flow limiting devices in the AFW system may correct this concern. Additionally, the proposed action for correcting the potential pump damage from the runout condition experienced during the event on December 26, 1985, appeared inadequate.

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, ' d. Certain breakers on DC Buses SOA and 508 may be incorrectly sized for

• . Interrupting short circuit current after installation of the larger

.' BA and 88 batteries.

2=. . Progransnatic Concerns.

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a. Examples were found where improper impivmentatiop qf the dvsign t control program resulted in poor analyses, incorrect calculations, and inaccurate drawings being used for modification activitivs in l . the plant. ,

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'j b. The surveillance /in-service test program was found to have several

, deficiencivs including incorrect procedures, poor procedure imple- t mentation, and inadequate evaluation of test results. l 1

l . 1. c. Ovficiencies were identified with the implementation of administrative e procedures for the control of plant systems and equipment status .

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d. Heintenance procedures used for AFW air-operated flow control valves j appeared inadvquate, which raised questions about the material condi-tion of the valves. Additionally, equipment maintenance history programs were not fully impivmented.

v. The quality assurance (QA) audit and surveillance programs were '

l not providing station management with adequate feedback on safety activities. Management Safety Rvview Consnittee (MSRC) oversight ,

of the QA audit program did not appear to advquately review close-out of audit findings. l i

! f. The corrective action prugram did not appear to have a procedure J issued for identifying and currecting significant conditions adverse  ;

j tu quality.

3. SystemReviewandTestProgram(SRTP) Concerns ,

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e. Selected System Status Reports (SSRs) did not appvar to be properly i controlled considering their importance as a basis for the f1RC j development of the restart safety evaluation report (SER).

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bl The SRTP priurity system and restart plan did not sufficiently l

identify all system problem resolutions which would be accomplished i prior to restart. Some probivms, classified as a )riority 2 or 3.

which affect or demonstrate safe plant operation siould be completed 1

• privr to restart. The team acknowledged the comitment to correct .

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tha specific items identified during the inspection for the eight j

• systems reviewed; hcwever, a review for similar problems in the remaining selected systems should belperformed, i

c. The problems with the surveillance /in-service testing program and i j procedures reflect poorly on their use for SRTP testing. ,

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Mr. John E. Ward - 3-No respotise is required to this letter sinew Inspection Report 50-312/86-41 detailing the inspection findings end concerns will be issued in the near future.

Sincerely.

1 Jame s G. f 6rtlow. Director Division of Inspection Programs Office of Inspection and Enforcement cc: See next pagt 9

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o Mr. John E. Ward V}9 -

0 sc: Mr. Stuart Knight Mr. Joseph 0. Ward.. Chief Sacramento Municipal Utility District Radiological Health Branch Rancho Seco Nucidar Generating Station State Department of Health Services 1440 Twth Cities Road 714 P Street. Office Building #8 Herald, California 95738-9799 Sacramento, California 95814

. . . Mr. Gordon K. Van.Vieck . . . . Sacramento County . . . . .

Sverstery, Resources Agency Board of Supervisors 1416 9th Street, Room 1311 827 7th Street, Room 4I4 Sacramento, California 95814 Sacramento, California 95814 Mr. David S. Kaplan, Secretary Ms. Helen Hubbard and General Counsel P. O. Box 63 Sacramento Municipal Utility District Sunol, California 94566 6201 S Street P. O. Box 15830 Sacramento, California 95813 Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N Strevt, N.W.

Washington, D.C. 20037 Mr. Ron Columbo Sacramento Hunicipal Utility District Rancho Seco Nuclear Generating Station 4440 Twin Cities Road Herald, California 95638 9799 Mr. Robert 8. Borsum Babcock & Wilcox Nucivar Power Generation Olvision

. Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 20814 Rustdent inspector / Rancho Seco .

c/o U.S. NucIvar Regulatory Comission 14410 Twin Cities Road Herald, C41 t furnia 95630 Director .

Envrgy Facilities Siting Olvision Energy Resourcea Conservation and Ovvelopment Comission 1516 - 9th Strvvt '

Sacramento, California 95814

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