ML20148E033

Forwards Operational Readiness Review Committee Restart Readiness Assessment Indicating Plant Ready for Restart,For Info.Rept Discusses Methods Used,Areas Reviewed,Background of Each Contributor & Recommendations

ML20148E033
Person / Time
Site:	Rancho Seco
Issue date:	03/16/1988
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Murley T Office of Nuclear Reactor Regulation
References
GCA-88-183, NUDOCS 8803240433
Download: ML20148E033 (35)

Text

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Osuun SACRAMI.NTO MUNICIPAL UTIUTY DISTRICT O P. O. Box 16830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECThiC SYSTEM SERVING THE HEART OF CALIFORNIA GCA 88-183 MAR 161988 U. S. Nuclear Regulatory Commission Attn: Dr. Thomas E. Murley Director, Office of Nuclear Reactor Regulation 115:i5 Rockvillt. Pike Rockville, MD 20852 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 OPERATIONAL READINESS REVIEW C0tHITTEE RESTART READINF.SS ASSESSMENT

Dear Dr. Murley:

Rancho Seco has received numerous reviews from outside agencies (e.g., NRC, INPO, ANI) in addition to the District's self-imposed testing and review in preparation for plant restart. In October 1987, I appointed an independent group to assist and provide input in evaluating our restart readiness. The individuals were assembled from the industry to provide an objective third party review of the plant condition and readiness for resumption of power operation. The attached report contains a discussion of the methods used, areas reviewed, background of each contributor, and their recommerdations.

This final report, indicating the plant is ready for restart, is provided for your use and information.

Please contact me if you have any questions. Members of your staff with questions requiring additional information or clarification may contact Mr. Bob Croley at (209) 333-2935, extension 4571.

Sincerely, G. Carl Andogg ni 9k Chief Executive Officer, D

Nuclear Attachment cc: F. Miraglia, NRR, Rockville D. Crutchfield, NRR, Rockville

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G. Holahan, NRR, Walnut Creek k g\g l

G. Knighton, NRR, Rockville \

l G. Kalman, NRR, Rockville 8803240433 880316 TION O 1444o Twin Cities Road, Herald, CA 95638-9799;(209) 333-2935 l PDR ADOCK 05000312 P DCD ,

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nco mn r.u MAR 151988 March 11, 1988 CE0 fli c D R G. Carl Andognini Chief Executive Officer, Nuclear Rancho Seco Neclear Generating Station Sacramento Municipal Utility District 14440 Twin Cities Road Herald, CA 95638

Dear Carl:

In early October, you appointed an Operational Readiness Review Com-mittee (0RRC) to carry out an independent assessment of the Rancho Seco plant readiness to restart and to assist you and your staff in the iden-tification of necessary actions which must be completed prior to restart. The members of ORRC, along with a short resume of their pro-fessional experience, are given in Attachment A. The ORRC members were to examine the readiness of plant systems and equipment, personnel qualifications and training, procedures and practices, and support func-tions and material. The objective of the ORRC evaluation was to ensure plant safety during and following restart and that the applicable requirements and commitments have been met.

This letter provides the conclusions of ORRC about Ranchu Seco readiness to restart. It describes the mode of operation employed by the Commit-tee, its principal findings, its summary review of ten specific program areas critical to plant operability, and several Committee suggestions that might deserve your consideration or special attention beyond restart.

Committee Mode of Operation The Committee mode of operation consisted of:

l o Getting presentations on November 10 and 11,1987, from the Rancho Seco responsible Directors / Managers of their readiness l

program and their status for restart.

l o Assigning specific areas for review to Committee members. The i

areas examined by each Committee member are listed in Attach-ment B. The Committee members made their own arrangements to ,

interview responsible personnel, to examine relevant practices  ;

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, and procedures, and to observe appropriate work being carried out. A compilation of SMUD personnel interviewed and of key work observed by the Committee is given in Attachment C.

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l G.. Carl'Andognini March 11, 1988 Page.2 o Providing you and Joe Firlit with a preliminary set of our findings and suggestions on December 4,1987.

o Completing by December 17, 1987, the evaluation of ten program areas critical to plant operabilty. The Comittee preliminary review of these ten programs was issued on J;nuary ~ 5,1988, and is reproduced in Attachment D.

o Continuing the review of personnel, procedures, and plant ,

progress through heatup isntil the issuance of this letter.

I Principal Findings

1. The plant systems and equipment are ready for restart. This conclusion relies upon the extensive System Review and Test Program (SRTP) implemented at Rancho Seco and its review by Bat'. Completion of SRTP and its acceptance by plant operations assure that systems important to Rancho Seco safe plant operation are ready to perform tneir required functi on . The Expanded Augmented System Review and Test Prcgram (EASRTP) completed for 33 critical systems further confirmed the overall functional readiness of Rancho Seco.

2. The Operations Department is adequately staffed to support the restart effort. There is extensive Rancho Seco operating experience in the staff positions; however, members of the snift crews have limited experience in their present positions. The shift operating crews could benefit from the staff's experience in operating Rancho Seco and it is recommended that every effort be made to utilize on-shift the staff people or personnel with equivalent B&W experience, during startup and continuing through full power operation. Based on ORRC interviews and observations, the assistant shift supervisors should participate in the training and provide guidance to the plant equipment operators during startup and power ascension since many of the equipment operators have had small exposure to Rancho Seco generating power '

3. Personnel qualification and training are adequate for restart.

We have reviewed the contract personnel situation with you and you assured us that you have a plan to continue to replace contract person-nel with SMUD employees in key positions and we urge your pursuit of that objective. Also, we have discussed with you the fact that Rancho Seco has been shut down for over two years and that plant operations and l

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G. Carl Andognini March 11, 1988 Page 3 maintenance personnel have not had recent hands-on experience in an operating plant. We were pleased to see that SMUD management had recognized that situation and is implementing an Operations Department Self-Evaluation Program during which specific performance requirements and criteria would have to be met by operations personnel being eval-uated by management. You informed us of your intention to provide extensive on-shift training of plant personnel and evaluation by manage-ment at different plateaus during the power ascension schedule. The ORRC believes that effective implementation of such a program wi".1 enhance the performance level of plant operating personnel. We urge SMUD management to emphasize the importance of continued supervisor evaluations of their personnel as a means of identifying weaknesses and correcting them.

4. Procedures are ready for restart. Our conclusion is based upon the fact that over 1300 procedures which were identified for plans There are changeto prior to restart have been upgraded satisfactorily.

We have mentioned to you that upgrade other procedures as required.

many of the newly generated procedures may have had a limited "use" fac-tor and we urged that as many as practical of these procedures be util-ized and carefully tested prior to restart and during the proposed Operations Department Self-Evaluation Program. We recognize that there may be minor inconsister.cies among the multitude of documents generated for restart, but we believe the Rancho Seco process did not allow incon-sistencies with safety impact to get through. You indicated that you plan to audit a sample of such documents for degree and type of incon-sistencies after restart and to develop a program to correct them if needed.

5. Our review of supporting functions and materials shows that they are ready for restart.

During ou- last visit to Rancho Seco on March 10 and 11,1988, we empha-sized the importance of resolving as soon as possible the existing uncertain. I about the future operation of Rancho Seco. It will be difficult to maintain an appropriate positive attitude with the future of Pancho Seco being debated and reevaluated every few months. Sech uncertainties cannot help but have an adverse impact upon the morale of your present personnel and your capability to fill your openand A stable or contract positive positions with permanent experienced employees.

overall climate is necessary not only to retain the key persons who are in charge of the startup and power ascension programs, but also to pro-vide the continued leadership required in implementing the many iden-tified post-startup improvement programs.

G. Carl Andognini March 11, 1988 Page 4 REVIEW OF RANCHO SECO PROGRAMS The ORRC has reviewed the following ten programs implemented at Rancho Secc:

1. System Review and Test Program (SRTP) Status Reports

2. B&W SRTP Review

3. Response to NRC Augmented System Review and lest Program

( ASRTP) Findirigs

4. Expanded Augmented System Review and Test Program (EASRTP)

5. Quality Vertical Audit

6. Engineering Actim Plan

7. Technical Specification Compliance / Verification Program

8. Surveillance Procedures Technical Review

9. Preventive Maintenance Program Verification

10. Operator Readiness Program i

These programs wer6 chosen because they deal with areas critical to plant operability and berause they can provide another way of assessing plant readiness to restart. Our review, It completed before January 5, shows that all program actions 1988, is summarized in A tachment D.

to be completed before restart have been reviewed and approved by SMUD I line management or by the Performance Analysis Group (PAG), made up of Rancho Seco nuclear senior managers. In All such commitments have been its evaluation of January 5, scheduled for closure before restart.

1988, the ORRC had found that all the SMUD personnel and management were dedicated to meet their obligations and to complete the necessary l

corrective actions identified under these ten programs before restart.

During its visit of March 10 and 11,1988, the ORRC:

o reviewed the Self-Evaluation Program and concluded that the Operations Department to-date has met the intent of each performance requirement;

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March 11, 1988 Page 5 o found surveillance procedure's'have been prepared and the sur-veillance tests are being scheduled and conducted as required by the Technical Specifications; ;

o noted that non-category I preventive maintenance items have been reviewed and selected items identified for performance prior to restart. t Based upon these observations , the ORRC firris the ten programs it reviewed to be ready for restart, ,

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COMMITTEE SUGGESTIONS FOR BEYOND RESTART.,

In the course of carrying out its revkew,'the ORRC identified several areas which may deserve your consideratiA1 or increased attention beyond restart. Most of our suggestions are aimed at accelerating Rancho Seco reaching the status of an effective operating plant. The suggestions include:

o the development of a transition plan to a full operational mode in which many of the r comittees making decisions for l restart would be replaced by clearly defined responsibilities and decision making by line management; also, it is important to start looking beyond restart and to giving attention to the review, prioritization, and implementation of the multitude of items identified in the Long Range Scope List (LRSL);

o review, integration, and simplification of the various pro-generati ng plant documents or' plant status. For cesses example, the programs to ensure plant status control involve the Work and Test Authorizations (WATA), equipment clearances, Work Requests, System LPeup Alterations and Logs. It is suggested that such processes be reviewed and consolidated to reduce the administrative burden of the shift personnel; f

o increased emphasis of the QA program to support plant opera-tions and upon the netd for each organization to be respon-sible for the quality of its own work; the use of Quality Assurance as a management tool should be increased to evaluate programs, identify deficiencies and verify the adequacy of corrective actions.

These and other suggestions are detailed in Attachment E.

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.a G. Carl Andognini March 11, 1988 Page 6 s

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' During the course of conducting this Operational Review, Weonewishmember to of our Committee, John F. Pearson, unexpectedly passed away.

itake this opportunity to recognize the dedication, interest, and pro- h

,_ I, fessionalism he exhibited during the Review.

In summary, the ORRC concludes that Rancho Seco is ready for restart.

The Committee considers its task accomplished and awaits your further instructions.

Sincerely yours,

& M$1 U Aaurlg,u hbb .Y D.R. Bradshaw, H. . Green.

. . Hughps, S. Le# , . Parris J.F. Pearson I

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,s fa o ATTACHMEN1 A G/

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BIOGRAPHIES OF EMPVRS OF ORRC

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00N R . AD 3 W, ,

Don 3radshb is (pd has been employ'ed by Duke Power Company since 1964.

/ He paesently ds . Generatiori Management Coredinator for the McGuire u Nuclev Station. ' AM' Generation Management Coordinator, he is respon-n l

sible for providi i i and technical expertise to the station

! iand department 4eng erg neer ngrsonnel on all matters ,thaVingact the station's abi i i rom 1964 to 1968, he was in the i

' syty to maximize plictrical generat on, operations In 1968, hedeprtmant transferred to at a fossil stati the s0:onee' Nuclear' Station where by served as Shif t Supe viser for the starty 9 Oconee Units 1 and y, and 'the pre-operational desting' of Ocon/p Un:t 3. In 1974, he transferTe1 to the McGuire Nuclear Station where he,rervd as McGuire Unit 1 Stgtup Coordinator. Mter s'tartup, he was'Anit .1 Operating Engineer until transferring to his current '

General Office position in 1985. ,

He is a member of the local Amerfcan Nuclear Society and is currently a wo-king group member of, the American Society of Mechanical Engineers developing standcrds for nuclear power plant outage management and refuelings. He receiveo' the Westinghouse Quality Achievement ~ Award in 1985 for his participati ?n in the eliminati on of the Resistance Temperature Detector Manifo)% S;ystem on Westinghouse nuclear units. He has held NRC Senior Reactor; Operator Licenses on Oconee Units 1, 2 and 3, and McGuire Units ', and ' ,

sl 422 South Church RJet /'

Charlotte, NC 28242, ' i

(704) 373-7018 /l l l' H. JIM GREEN ,

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H. J. Green has over twenty-five years > irxperience in Nuclear Plant operation and utility management. Fu/ the past f_ive. years he has been in priva:e practice serving as consultan,t and advisor to tht upper man-agement of a number of Nuclear Utilities. He also works with several utility Safety Review Organizations.

From 1961 through 1983, he was employed by' the Tennessee Valley Authority in various managerial positions. The last position held with that agency was as Director of Nuclear Power where he Wat, responsible for administ* ring til activities necessary to ensure the safe, efficient and environMMally sound operation and maintenance of the TVA nuclear generating platt j and appurtenant facilities. Previous positions successively held were, Assistant Power Plant Seperintendent of a four-

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H. JIM GREEN (Continued) 945-megawatt coal-fired generating plant. As Power Plant Super-unit, intendent, he was responsible for staffing, training, plant startup, and the operation and maintenance of the Browns Ferry Nuclear Plant (a th ree-uni t , 3,294 megawatt generating plant equipped with General Electric boiling water reactors and turbogenerators). He also held the position of Assistant Manager, Power Operations. In this capacity he was in-line Assistant to the Manager of Power Operations, whose respon-sibility included coordinating the operation and maintenance of a 31,000 MW electric generation and distribution system.

He attended the U.S. Naval Advanced Nuclear Power School He is a graduate of theand served U.S. Navalin the Navy Nuclear Submarine Program.

Academy and nolds a Bachelor's Degree in Engineering.

5607 Cold Springs Road Hixson, TN 37343 (615) 870-9031 EDWARD M. HUGHES E. M. Hughes is the Engineering Manager for Bechtel Power Corporation's project of fice in Ann Arbor, Michigan. He is responsible for the per-formance of that office's engineering department in support of several operating nuclear and fossil power plants. He has been employed by Bechtel since 1969 in various engineering and managerial positions in Bechtel's offices in Madrid, Spain; San Francisco, California; and Ann Arbor. Michigan. His position titles have included Chief Mechanical Engineer, Chief Nuclear Engineer, Project Engineer, Project Manager, Manager of Engineering, and the current Engineering Manager.

He has been the Project Manager for Bechtel's Independent Design Review of the Byron Station (Commonwealth Edison Company), the Deputy Project Manager for Bechtel's Independent Oe:ign Review of the Clinton Station (Illinois Power Company), and the Bechtel member of the Independent Process Review Commi ttee for the Davis-Besse Nuclear Plant (Toledo E di son Company) .

He is a registered professional engineer in Michigan and California.

777 East Eisenhower Parkway P.O. Box 1000 Ann Arbor, MI 48106-1000 (313) 994-7292 A-2

SALOMON LEYY Dr. S. Levy is and has been the President of S. Levy Incorporated, a consulting firm to the power industry since 1977. He presently consults for many electric utilities and several power equipment manuf acturers, the Electric Power Research Institute, two National Laboratories, and Nuclear Regulatory Commission. From the Research Division of the U.S.

1953 to 1977, he was employed by the General Electric Company in various technical and managerial positions. He was successively Manager - Heat T ransf er and Fluid Flow Development, Manager - Systems Engineering, Manager - Design Engineering, General Manager - Nuclear Feel Department, General Manager - Boiling Water Reactor Systems Department. In April 1975, he became General Manager - Boiling Water Reactor Operations where he was responsible for all the engineering and manufacturing of General Electric nuclear power business. Dr. Levy is a member of the National Academy of Engineering and a fellow of the American Society of Mechanical Engineers from which in 1966 he received the ASME Heat Transfer Memorial Award.

He is a member of the American Nuclear Society from which, in 1987, he received the Thermal Hydraulics Division Technical Achievement Award.

He is a Director of IE Industries and Iowa Electric, a member of the Oversight Committees for four nuclear power plants, an advisor to the Directors of Philadelphia Electric, and a member of the Nuclear He has Regulatory Commission Nuclear Safety Research Review Committee.

authored more than 50 published technical papers.

3425 S. Bascom Avenue Campbell, CA 95008 (408) 377-4870 HUGd PARRIS Hugh Parris is Vice-President-Production for the Nebraska Public Power District. In this position ne is responsible for the District's fossil and nuclear programs. The District owns and operates an 800 MW BWR at the Cooper Nuclear Station. He was employed by the< Tennessee Valley Authority (TVA) f rom 1958 to 1986. While employed by TVA, he held various technical and management posi ti ons including (successively)

Chief of the Power Supply Planning Branch, Director of the Pcwer Resource Planning Division, Manager of Power Planning, Manager cf Power, Manager cf Power and Engineering, and Senior Advisor to TVA's General Manager. While Manager of Power and Engineering for TVA, he was respon-sible for all aspects of TVA's power program and for the agency's Engineering and Construction program. During 1986 and 1987, he was a consultant to the President of the Nebraska Puolic Power District pro-viding consul tati on and advice to the President relative to the District's Nuclear Program.

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HUGH PARRIS (Continued)

Mr. Parris was a member of the founding Board of Directors of the Institute of Nuclear Power Operations. He served on the INPO Board of Directors from 1979 until 1986. He served on the Executive Comittee of the Board from 1983 until 1986. He served as Chairman of the South-eastern Electric Reliability Council (SERC) from 1984 to 1986. He was a 1986. He also member of the SERC Board of Trustees from 1979 until served on the Board of Trustees of North America Electric Reliability Council from 1979 until 1986.

Mr. Parris received a B .S . in Electrical Engineering from Clemson Universi ty in 1958 and an M.S. in Electrical Engineering from the University of Tennessee in 1966.

1414 15th Street Columbus, NE 68601 (402) 563-5518 JOHN F. PEARSON, JR.

John F. Pearson, Jr., was Senior Technical Consultant for Babcock &

Wilcox's Nuclear Power Division (NPO) at the time of his death in January 1968.

Mr. Pearson joined B&W in 1981 as a technical consultant. Since that time, he served in a number of managerial positions including Program Manager of the Three Mile Island Unit 1 steam generator recovery program; Manager of NPO's steam generator services; Manager of the Nuclear Construction Department at the Zimer Nuclear Power Station in Moscow, Ohio; Manager of Bellefonte Nuclear Plant Operations Services; B&W Resident Manager at Toledo Edison Company's Davis-Besse nuclear plant near Clinton, Ohio; and Manager of Nuclear Plant Services at NPD.

Prior to joining B&W, Mr. Pearson was Assistant Manager, 06k Ridge Operations, for the U.S Department of Energy from 1978 to 1981; Project Engineering Manager, Clinch River Breeder Reactor, as well as Resident Manager, Clinch River Breeder Reactor Project office in Oak Ridge,

Tennessee, for Burns and Roe, Inc. from 1975 to 1978; Assistant Director

! for Engineering and Operations, Division of Reactor Safety Research for the Atomic Energy Commission / Nuclear Regulatory Commission from 1972 to 1975; and from 1959 to 1972, held various engineering and staff assign-l ments with the Atomic Energy Commission.

Mr. Pearson served in the U.S. Navy for 25 years, retiring in 1970 with the rank of comander. He received : B.S. degree from the U.S. Naval Academy and M.S. and Engineer's degrees f rom the Massachusetts Institute i of Technology,

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ATTACHMENT B

, SPECIFIC AREAS ASSIGNED TO ORRC MEMBERS Technical and Administration Services Material Control Department H. J. Green Document Control E. M. Hughes Director, Nuclear Technical Services Nuclear Engineering S. Levy Nuclear Licensing E. M. Hughes Environmental Protection J. F. Pearson Nuclear Management Systems H. Parris Nuclear Power Production Director, Nuclear Operations and Maintenance Operations D. R. Bradshaw Maintenance H. J. Green Modifications J. F. Pearson Director, Nuclear Plant Support Radiation Protection J. F. Pearson Chemistry S. Levy /G. Walke E. M. Hughes Plant Performance Training H. J. Green Director, Nuclear System Review and Test Prograr.

Post Modification Test Program J. F. Pearson Plant Startup Program O. R. Bradshaw Schedule and Outage Management D. R. Bradshaw S ecuri ty H. Parris Quality Assurance H. Parris/G. Walke B-1

SPECIFIC AREAS ASSIGNED TO ORRC MEMBERS (Continued)

SPECI AL AREAS ASSIGNMENTS Readiness of Unmodified Plant Systems E. M. Hughes and Equipment Saf ety Review Groups S. Levy Outstanding Work Requests for Safety Impact H. J. Green Operating Experience Review Program D. R. Bradshaw Environmental Qualification (EQ) H. J. Green Cable Sep& ration S. Levy E. M. Hughes Fire Protection Saf ety and Performance Improvement Program J. F. Pearson SPECIFIC PROGRAM ASSIGNMENTS E. M. Hugnes Expanded ASRTP Program SRTP System Status Reports J. F. Pearson J. F. Pearson B&W SRTP Review S. Levy Engineering Action Plan H. J. Green Surveillance Procedure Tech. Review Preventive Maintenance Program Verification H. J. Green D. R. Bradshaw l Operator Readiness Program Technical Specification Compliance /

Verification Program D. R. Bradshaw S. Levy Quality Vertical Audit E. M. Hughes Response to NRC ASRTP Findings i

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ATTACHMENT C PERSONS INTERVIEWED AND ACTIVITIES OBSERVED BY ORRC EMERS A large number of SMUD personnel were interviewed by ORRC members. The following is not a couplete list of all persons with whom discussions were held, but is a list of most of the persons at Rancho Seco from whom information was obtained to support the operational Readiness Review:

Aley, B., Principal Engineer, NEO Andognini, Carl, CEO Nuclear Astronomo, Joe, Equipment Operator Aycock, C., Restart Engineering Manager Baker, R. J., B&W Engineer

• Barrerd, Art, Operational Planner Barrot, Bill, Test Engineer Baxter Fred, Equipment Operator Bender, Paul, Manager, Modifications Department Bosakowksik, Paul, Licensing Department Supervisor Brock, Dave, Manager, Maintenance Department Carlton, Red, B&W Engineer Carmichael, Steven, Maintenance and I&C Engineer Carnes (Giangi) Earl Caspersen, Gary, Licensed Operator Requalification Coordinator Chapin, Bill, Lead Mechanical Plcnner Cherba, Robert, Staff Assistant, Nuclear Quality Childress, Tom, Assistant Director, Supaort Clif ton, G., SRTP Special Projects Cole, John, Preventative Maintenance Supervisor Coleman, Quennon, Supervisor, Quality Engineering Compton, D. , Licensing Engineer Conklin, Linda, Manager, Management Systems Cooper, Mike, Shif t Supervisor Cork, John, Assistant Shif t Supervisor Coward, George, AGM Technical and Administration Services Cranston, Greg, Manager, Nuclear Engineering Department Croley, Bob, Director, Nuclear Technical Services Dans, Thomas P., QA Engineer Dobson, Ron, t.ead 1&C Maintenance Engineer Downs, Mike, Assistant Director, Electrical Testing Elliot, Don, Lead, Audit Fanning, Dwight, Mechanical Maintenance Supervisor Firlit, Joe, AGM Nuclear Power Production Flynn, Joe, Manager, Plant Performance Department Fossum, Lee, Manager, Scheduling and Outage Management Fraser, Allan, Shif t Supervisor Friedrich, Bill, Quality Engineer C-1

4 PERSONS INTERVIEWED AND ACTIVITIES OBSERVED (Continued)

Gibson, Bob, Scheduling Superintendent Gilles, J., Manager, Information Management Services Giroux, Norm, Operations Planner Grimes, John, Mechanical Maintenance Superintendent Harlow, Richard, Supervisor, Configuration Management Heckert, Herb, Surveillance Program Supervisor Hieronimus, Mike, Staff Shift Supervisor Huebner, Roger, Manager, Cost Control & Office Services Department Humenansky, D. , EASRTP Program Manager Hutchinson, Richard, Operations Scheduler Hyffman, Jim, Preventative Maintenance Supervisor Hyzer, Pete, Scheduling Janis, Joel, B&W Resident Engineer Jones, Jeff, Assistant Director, Electrical Testing Kawamoto, Tom, QA Auditor Kearns, J., Document Control Supervisor Kellie, Fred, Manager, Radiation Protection Kelly, J., Engineering Response Team Supervisor Kemper, Bill, Nuclear Operation Manager Kesinger, C., Licensing Engineer Keuter, Dan, Director, Nuclear Operations and Maintenance Khan, T., Mechanical Engineering Supervisor, NED Kline, Dick, Scheduling Knight, Edwin, Reactor Operator Knoblauch, Ed, Training Instructor Krunk, S., Region V and Inspection Coordination Kymir, Baron, Principal Electrical Engineer Lewis, Barry, Licensing Department Linkhart, Charlie, I&C Maintenance Superintendent Manofsky, Steve, Superintendent, Chemistry Martin, Dan, Manager, Environmental Protection Department McColligan, John, Director Nuclear Plant Support Meyer, Jan, Superviscr, Audit & Surveillance Meyer, K., Manager, Nuclear Licensing Technical Support Mock, Jim, Senior Startup Engineer Fast Acting Response Team l

Moran, Dwane, Maintenance Planning Superintendent Murdock, Richard, Superintendent, Chemistry Neal, Joe, Shift Advisor Paredez, Robert, QA Auditor Parenteau, Mike, Lead, Surveillance Patel, P., Engineering Response Team Supervisor Pospisil, Chip, Scheduling Support Superintendent Powers, Roger, Supervisor, Nuclear Fuel Price, David, Shift Advisor I Prince, K., EASRTP Team Leader C-2

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PERSONS INTERVIEWED AND ACTIVITIES OBSERVED (Continued)

Rackley, Jay, Assistant Director, Mechanical Testing Rausch, Bruce, Senior Reactor Operator Redeker, Steve, Assistant to Operati0ns Itanager Redican, Tom, Manager, Material Control Department Robertson, J., Licensing Engineer-CCTS Rosebaum, Doug, Control Operator Ross, D., Nuclear Security Satpathy, D., Supervising Engineer, NEO Scala, Tony, I&C Technician Sefick, John, Manager of Nuclear Security Shanbagg, Snan, QA Auditor Shanker, Gary, Deputy Manager, Scheduling & Outage Shetler, J., Director, Systems Review and Test Program Shewski, Tom, QA Auditor Simons, Grant, Shif t Technical Advisor Smickley, Kirsten, QA Computer Specialist -

Sperling, Al, Planning Support Supervisor Stahl, B.

Strange, John, Director, Management Systems Tellf ord, T., Engineering Response Team Manager Tindle, C., Engineer, NEO Tipton, Dennis, Procedure Development Superintendent Tucker, Tom, Operating Engineer Turner, Paul, Manager, Training Department Vinquis+. John, Director, Nuclear Quality Wadman, Will!am, Supervisor. Environmental Programs Williams, Rick, Mechanical Planner Wilson, William, Superintendent, Chemistry Wood, S., Supervisor Nuclear Documents Yelliott, Grant, Project Manager Procedure Development Yochneira, Eric, Manager, Nuclear Chemistry Yount, Dan, Electrical Maintenance Superintendent Zimmerman, K., Fire Protection Engineer Zott, J., Engineer, NED l

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4 PERSONS INTERVIEWED AND ACTIVITIES OBSERVED (Continued)

The following activities were observed by ORRC members:

Calibration of Feedwater Pump Electronic Speed Control using Procedure I-312 Control Room Operations, i.e., log keeping, use of procedures, alarm response, comunications, etc.

Control Room Operator Watch Turnover Daily Outage Schedule Mecting Equipment Clearances, both paperwork process and actual tagout Operations Start-of-Shift Crew Briefing Operator Requalification Training Classroom-December 2,1987 Plant Heatup Program Review Meeting Plant Rounds by Equipment Operators Shift Supervisor and Control Room SR0 routines Shif t Supervisor's Start-of-Shif t Crew Briefing Shif t Supervisor Watch Turnover l Test Engineer's Crew Briefing in preparation for conducting Start-up Test Procedure.

l Test Engineer's pre-requisite procedure sign-offs in preparation for Start-up Test Procedure.

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ATTACHMENT 0 REVIEW OF RANCHO SECO PROGRAMS COMPLETED BY OPERATIONAL READINESS REVIEW COMMITTEE (ORRC) ON JANUARY 5,1988 Subsequent to the December 26, 1985 overcooling incident at Rancho Seco, numerous programs were initiated to define potential problem areas and to develop corrective actions. Among the multitude of programs imple-mented, 'a specific set has been identified as being capable of giving an assessment of plant readiness for restart because they provide indepen-dent and redunciant reviews of the areas critical to plant operability.

The programs included in that selective set are:

1. System Review and Test Program (SRTP) Status Reports

2. B&W SRTP Review

3. Response to NRC Augmented System Review aad Test Program

( ASRTP) Findings Augmented System Review and Test Program 4 Expanded (E ASRTP)

5. Quality Vertical Audit

6. Engineering Action Plan

7. Technical Specification Compliance / Verification Program

8. Surveillance Procedures Technical Review

9. Preventive Maintenance Program Verification

10. Operator Readiness Program A member of the ORRC was asked to review each of the above ten programs.

The overall progress to-date and 75e completion of committed actions prior to restart were evaluated and the ORRC findings are summarized in this Attachment.

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1. System Review and Test Program (SRTP) Status Reports Selected System Status Reports (SSRs) have been prepared by SMUD for each system or area which needs to be modified, revised, o. repaired before restart of Rancho Seco. Each report contains the appropriate problem descriptions, the proposed resolutions, and the closure require-ments. All recomendations contained in the SSRs are reviewed and dispositioned by the Performance Analysis Group (PAG), made up of the Rancho Seco Nuclear senior managers.

Review of sample Rev.1 SSRs by one ORRC member and by B&W indicates that the technical work done by SMUD and their contractors identifies problems and testing important to safe operation of Rancho Seco. These items have been incorporated in work requests, ECNs, test procedures and other documents, which in turn have been prioritized, planned and sched-uled. It was found that SMUD's approach to system review corresponds to Davis-Besse's, and in several areas is more conservative. For example, the approach to power and prerequisite testing is more extensive than Davis-Besse's; the decision-making on priorities of all work items is more completely documented. In fact, the level of detail addressed by PAG is greatly in excess of that dealt with by a corresponding group at D avi s-B es se .

The SRTP management has recently undergone a complete change. The new management has shown flexibility in dealing with the urgency of work and

! addressing organizational needs with contractor personnel. SMUD has committed to the completion of Rev. 2 SSRs prior to restart and is working to this end.

The ORRC understands that with the completion of Rev. 2 SSRs, SMUD is considering closing the SSR as a program document. This entails the assurance that all action items are accounted for in the test program and the Restart Scope List (RSL) and the Long Range Scope List (LRSL).

I The ORRC sees no problems and several advantages to this action.

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Subject to the completion of Rev. 2 SSRs and the satisfactory completion of the pre-start test program, and subject to completion of the restart list of commitment, ORRC concludes SSRs should present no obstacle to restart.

2. B&W SRTP Review In October,1987, B&W reported the completion of a review of thirteen systems which had been the subject of System Status ReNrts produced by the SRTP. The review was done by a team of experienced 88W engineers.

The purpose of the B&W review was to determine that; o System functions defined in SSRs are consistent with

• design basis documents; and o Test program as planned is adequate to confirm the abil-ity of each system to perform the defined functions.

The Executive Summary of the B&W review states that B&W sees nothing to prevent support of the earliest possible restart of the unit, assuming resolution of the significant concerns identified in the report. The concerns identified included suggestions and recommendations. The Executive Summary provides a compilation of all recommendations by the review team. The recommendations have been evaluated by SMUD senior management and they have been prioritized with a method prescribed by SMUD. The recomendations have been segregated into those which must be c ompleted before restart and those to be implemented af ter restart. The recommendations are tabulated by SMUD in the "Babcock and Wilcox SRTP Review Report Master," which includes identification of responsible organi zation , Restart Scope List /Long Range Scope List (RSL/LRSL) number, and assigned priority.

A sample review of treatment of these recomendations has been carried out and it shows appropriate treatment. Further, sampling of items known to be troublesome shows assignment of correct R1 or R2 priority to 0-3

D those items. Therefore, it appears that the B&W review has been pro-perly addressed in that recomendations have been prioritized and placed in the restart scope list or long range scope list. It was noted that in one of the items reviewed SMUD expanded a specific repair recomen-dation into a generic issue, calling for fixing the root cause of failure.

It is concluded by the ORRC that, subject to completion of RSL items and c omi tment to support LRSL i tems , the B &W review is adequately addressed. It is suggested that after assuring that all items in the B &W SRTP Review Report Master are included in the RSL and LRSL, the Report Master be discontinued, in order to minimize the number of active tracking systems.

3. NRC ASRTP Findings An Augmented Systems Review and Test Program ( ASRTP) inspection was per-formed by an NRC team over the period December 1,1986 to February 12, 1987. It consisted of a detailed review of two critical systems and six supporting systems included in the SRTP and an in-depth review of the Rancho Seco engineering and modification, maintenance, operations, sur-veillance and in-service testing, and quality programs. Responses and comitments to ASRTP deficiencies were made by SMUD to NRC in May 1987, and a status progress report was provided in September 1987, prior to a follow-up NRC inspection. Ninety-seven open items were identified in the original inspection report and the district comitted to resolve a l

significant majority of the deficiencies prior to restart.

1 One member of ORRC has reviewed the status of responses to NRC ASRTP.

He examined the ASRTP Inspection Report 50-312/86-41; G. Carl Andognini letter to James Partlow, Director of Reactor Inspection and Safeguards of May 15,1987 -

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Augmented Systems Review and Test Program (ASRTP) Inspection; G. Carl Andognini letter to James Partlow of September 16, 1987 -

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Program (ASRTP) Inspection Response; applicable CCTS entries as of December 15, 1987; and Licensing Department's ORR ASRTP Status (from C. Kesinger) as of December 11, 1987. It was found that commitment sta-tus is tracked presently by the Licensing Department on the CCTS. Items were closely tracked and the closecut rate appears suitable for plant restart. The process includes specific responses to NRC for review prior to final closure. At the time of the recent NRC operational review in early December, only three items remained to be closed by Rancho Seco, pending NRC acceptance of the closure bases.

In the opinion of ORRC, when commitments are completed, i .e. all com-mitted restart ASRTP items closed to the satisfaction of NRC, the Rancho f

Seco plant should be considered operationally ready for restart with respect to ASRTP findings.

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4. Expanded Augmented System Review and Test Program (EASRTP)

Under the program title Expanded Augmented System Review and Test l

Program (EASRTP), 33 selected systems were reviewed for functionality.

The inherent design capability to meet the system design bases was con-sidered, as well as the adequacy of testing, maintenance, selected training, and human factors considerations. The system reviews covered a 4-1/2 month period and were completed in November 1987. Individual reports on each selected system have been issued, identifying potential and valid concerns. A tott.1 of 249 corrective action items were i

generated. The deficiencies have been evaluated and decisions have been made as to actions required prior to restart and for justification of

' items as post-restart activities. This has been done in accordance with the procedures involving PAG review. Tracking is accomplished with the RSL/LRSL in addition to other tools. Approximately half of the correc-tive action items were determined to need some corrective action prior to restart. A final report for the EASRTP effort is planned to be issued shortly; it is not yet available in final form.

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He examined One member of the ORRC has reviewed the EASRTP status.

selected EASRTP reports including Reactor Sample system, Nuclear Service Cooling Water, Nuclear Service Raw Water, Fire Protection Systems; RSAP-0218, Rev. 0; As-Built Discrepancy Resolution Plan for EASRTP MEL Walkdown Data (unsigned); Engineering Response Team EASRTP RI status tracking listing; Nuclear Engineering package documenting closure of EASRTP potential concerns for NCW/NRW systems heat exchanger capacity / heat removal capability; and initial drafts of proposed EASRTP Final Report.

It was found that:

o Functionalit, concerns regarding the reactor sample system remain to be resolved prior to restart, o Apparent repetitive EASRTP conce.rns regarding potential effects on systems' functionality f rom past deficiencies in preventive main-tenance and spare parts control need to be resolved in a manner satisf actory to NRC.

In the opinion of ORRC when present EASRTP related commitments (as resolved with NRC) that are required for restart are completed, Rancho Seco can be considered operationally ready for restart with respect to E ASRTP . ORRC has suggested that an independent review be carried out of a few critical closures under EASRTP, This will assure completeness of the resolutions developed by the affected departments. Such an indepen-dent review need not be completed before restart. It is our under-standing that a QA audit of the EASRTP paperwork is planned after restart, which should satisfy ORRC suggestions.

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5. Quality vertical Audf t It On April 20, 1987, a Quality Vertical Audit was initiated by SMUD.

covered the modifications made to the Emergency Feedwater Initiation and Control (EFIC) System, the Electrical Tie-in of the TDI Emergency Diesel Generators, the Auxiliary Turbine System and the Hot Leg level Measuring / Steam Generator Level Measuring System of the Rancho Seco plant. The results of this investigation were issued on August 14, 1987 in Rancho Seco Audit Report No.87-020. Twenty-six audit findings resulted from this audit. Open Items (01s) were issued to the respon-sible departments for each audit finding and they have been tracked by QA for status and closure.

One member of ORRC has examined the following documents:

Rancho Seco Audit Report No.87-020 Nuclear Engineering Response to QA Audit 87-020, dated 9/14/87 QA Department review of Nuclear Engineering Responses, SQA 87-154 Nuclear Engineering Revised Response to QA Audit 87-020, dated 11/12/87 Status of QA Audit No.87-020 of 11/13/87, SQA 87-182 Nuclear Engineering Restart Task List, dated 12/2/87 The validity of the status given in SQA 87-182 was confirmed for the corrective actions completed or committed to be completed prior to l

restart. It was found that one finding (87-020-16) had not yet been l

! responded to by early December. The material furnished ORRC (SRT 87-805, SQA 87-167, NOM-87-287) would tend to support that this finding i

does not need to be closed prior to restart.

l Based upon the above review, the ORRC concludes that there is no restriction to restart with respect to the Quality Vertical Audit sub-I I

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ject to the completion of open items now scheduled to be completed before restart, and subject to having QA verify that the one finding with no response to-date does not need to be completed by restart.

6. Engineerir.g Action Plan On April 17,1987, SMUD issued an Engineering Action Plan for Rancho Seco. The plan described actions initiated or planned to restore con-fidence in the engineering design and design process at Rancho Seco.

Specifically, it dealt with improvements in the design change process, the design work performed during the current outage, and the system design bases for Rancho Seco.

This plan has been subjected to the review of a Technical Oversight Comittee (TOC) which judged the plan to be satisfactory for restart af ter holding four review meetings with Nuclear Engineering and its principal interfaces. Two of the members of the TOC are members of the ORRC. One of these members has rechecked that the Engineering Action Plan commitments for restart have been met. It was found that o A documented closure review of all restart related ECNs has been l implemented by using a memorandum checklist. Procedure NEP 4109 l "Rancho Seco Configuration Control Procedure" has been revised to incorporate this checklist.

l o The procedure which governs control of design calculations has been revised to include "good practice" guidelines which define accep-l table and quality requirements for Nuclear Engineering calcula-l tions.

t o Good progress is being made towards issuing a new Design Change j

P ack age . Seventy-five percent of the work has been completed and l

final issuance is scheduled for early 1988.

o Thirteen Revision A documents called "System Oescription and Functional Requirements" documents have been issued. This exceeds D-8

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the comitment of the Engineering Action Plan for five such docu-ments to be issued.

The ORRC has had the opportunity to review a preliminary version of Revision 2 of the Engineering Action Plan. It was noted that the new plan includes new programs for training engineering personnel, a Vendor Technical Information program and an effort to increase QA surveillance of engineering.

Based upon this review, the ORRC concludes that the Engineering Action Plan commitments prior to restart are being satisfied and that the Plan presents no obstacle to restart.

7. Technical Specification Compliance / Verification Program A Rancho Seco Technical Specification Verification Program was initiated in response to Notice of Violation and Proposed Imposition of Civil Penalty (NRC Inspection Report Nos. 50-312/86-06 and 50-312/86-07). The verification project committed that "a comprehensive itemization of the detailed technical specification requirements with the procedures which implement them, will be developed prior to restart."

This program has been reviewed by one ORRC member and he found that a l i ne-by-l ine item review of the Technical Specifications (with the exception of Sectior,1, Definitions) was conducted. Each Technical Specification line item is correlated with an implementing procedure, t

This inf ormation is compiled in a data base and is controlled by f Licensing to ensure Technical Specification verification. Compliance with Technical Specifications is accomplished by weekly schedules issued I from the Plant Performance Group to all station groups indicating the surveillance procedures to be completed. Satisf actory review of completed surveillance procedures is performed.

The Rancho Seco Technical Specification Compliance / Verification Program has been reviewed by ORRC and it is considered ready to support plant startup.

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8. Surveillance Procedure Technical Review In response to a violation finding contained in NRC Inspection Report 85-23 dated September 3,1985, SMUD committed to revise all Surveillance Procedures to require the documentation of calibration data for all instrumentation other than control room instrumentation. The task was to be completed and full compliance achieved prior to January 1,1987.

By letter dated April 20, 1987, SMUD received a Notice of Us vi? tion because the above comitment had not been met. At that timet some 67 procedures had been revised. SMUD subsequently revised their comitment to read ". .

. surveillance procedures required to support restart will be reviewed and revised to assure technical adequacy prior to restart.

The remaining procedures will continue to be revised to assure tachnical adequacy as the procedures are required to be performed. The procedures will be revised to reflect the format requirements of the Writers Guide no later than the first biannual review of the procedure following restart."

As an additional measure to preclude adverse impact on the schedule for heatup and restart, SMUD developed an action plan to assure that all requisite Surveillance Procedures are revised as necessary and imple-mented to support plant restart. This plan was reviewed by one ORRC member and he found that the following specific actions are in progress or have been accomplished under this plan.

o Technical Specification / Surveillance Procedure cross-references were developed independently by the Surveillance group and by the Licensing Department and compared as discussed under item (7) above. This line-by-line review and independent verification was to assure an implementing procedure is developed for each Technical Specification requirement.

o A comparison of old and new Surveillance procedures was made to identify previous procedures deleted or incorporated into other D-10

I procedures. Some thirty old surveillance procedures were iden-tified as not required by Technical Specifications. It is intended that these will eventually be included in more appropriate programs (such as PM). Until that occurs, these old procedures are being scheduled for performance.

o A determination has been made as to which Surveillance Procedures are required to be performed prior to plant heatup and prior to each mode change, o Because of time and manpower limitations, a number of Surveillance Procedures will not be rewritten in the new format. These old pro-cedures are receiving an Engineering Review for Technical Adequacy and will be used during the upcoming restart and power ascension i effort.

o Prior to initial usage, the operational surveillance procedures are l

walked through. This same degree of walk-down is not practical with the more technical procedures such as those used by I &C .

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These procedures must be corrected or verified through actual usage.

o Following performance, surveillance results are reviewed first by the Performing organization and then by the Plant Performance Section. Surveillance results review is scheduled on the P-2 schedule as is rework and reperformance in cases of failed test results.

The ORRC concludes that the SMUD Rancho Seco Surveillance Procedure Technical Review is in the final stages of development and should be ready to support reactor restart. However, to-date, the ORRC has not had the opportunity to adequately determine the implementation and effectivenes of this program. The ORRC plans to carry out such obser-vations in the next four weeks and will report its final opinion on the surveillance program shortly af ter plant heatup.

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9. Preventive Maintenance Program Verification In August 1987, Maintenance Administrative Procedure MAP 0009 was issued to establish the philosophy, policies and details of a new Preventive Maintenance Program for the Rancho Seco plant. This release met the SMUD commitment to implement a comprehensive and proceduralized preven-tive maintenance program with all Category I PMs performed prior to restart or omission justified prior to plant startup.

Following this issuance, and using the Master Equipment List as the equipment basis, the Preventive Maintenance Group researched applicable vendor information and experience reports to compile a list of "tasks" to be performed and their periodicity. When vendor recomendations were The not followed, the departure and justifications were documented.

tasks subsequently were sent to planning, much the same as any work reques t, and a work package prepared. Preventive Maintenance items appear on the P-2 schedule in the same manner as corrective maintenance items.

The Preventive Maintenance Program has been reviewed by one ORRC member, particularly as it relates to Category I PMs. It was found that the Maintenance Department has an action plan the purpose of which in part l

l is to assure that all requisite PM work requests are completed in a timely manner to support plant restart. All Category I PM tasks have been identified and all Category I work requests have been issued and are being worked. All modifications, NCRs, and work requests have been reviewed to ensure the required work has been identified and the items scheduled. All work requests not scheduled to be performed prior to l

l restart have been evaluated by Operations. All Category I .PM tasks have been developed, issued, and will be scheduled for implementation prior to reactor startup.

The ORRC concludes that the basis for a good Preventive Maintenance Program is being established and that all Category I PMs will be per-D-12

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formed or omission-justifed prior to plant startup. Programs and proce-dures are in place to provide new policy and direction for the Maintenance organization. However, the ORRC notes that procedures quality and verbatim procedure adherence are areas for continuing improvement at Rancho Seco.

10. Operator Readiness Program The ORRC has looked at the Operator Training Program as well as the Operator Readiness Program as described in' the Operations Department Restart Action Plan. The training program identifies the material to be covered prior to plant rest.1rt while the Operations Department Restart Action Plan defines the actions 6. 4 schedule to be completed by Operations to ensure that restart issues are conpleted to support plant restart. In addition to the action plans for paperwork closecut such as ODRs, WCRs, Procedure Revisions, etc., the main Operations Department Action Plan to ensure operator readiness is the Department Readiness Self-Evaluation Program. The Self-Evaluation Program provides for the detailed review of the following six Operations Department Performance Requirements.

o Operations Organization and Administration o Conduct of Operations o Plant Status Control o Operator Knowledge and Performance o Operations Procedures and Documentation o Operations Facilities and Equipment The above six Performance Requirements are broken down into a total of sixty-six criteria. The basis and actions for how each criterion is or will be met has been developed. Assembly of documentation is currently in progress to define how the Operations Departnent will meet the intent of each Performance Requirement. The AGM, Nuclear Power Production and CEO, Nuclear, will review and approve each of the six requirements to ensure the intent has been met before criticality.

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One ORRC member has reviewed the Operator Training while another member has examined the Operations Department Action Plan and in particular the Operations Department Self-Evaluation Program.

Based upon this review the ORRC concludes that training will have covered all required material prior to plant restart and plans to pro-vide on-shif t instructors for additional' training during startup. With the successful completion of all remaining action items, and in par-ticular the Stlf-Evaluation Program, the Operator Readiness program should be ready to support plant restart. The ORRC still plans to observe the Readiness Self-Evaluation Program during plant heatup. The ORRC will provide any additional comments it might have in its final letter.

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"J ATT ACHENT E ORRC SUGGESTIONS FOR BEYOND RESTART The ORRC The ORRC has identified several areas needing improvement.

wants to make it clear that none of the following suggestions are required for restart; however, they deserve to be given increased atten-tio by Rancho Seco management.

Transition Plan: SMUD needs to develop a detailed transition plan from restart to beyond reaching full power operation. For over two years, Rancho Seco has been involved in a systematic assessment and restart project during which significant equipment and documentation upgrades were undertaken. During this period of time, comittees, boards, and o+.her groups were created to carry out the multitude of restart programs. Also, special organizations such as the System Review and Test Program were formed. The decisions previously made by committees, boards, groups, or special organizations need to be assumed by if ne management. The entire organization has to go into a mode where the emphasis is placed upon operating the plant safely and providing it with the necessary support to run efficiently and reliably. It is recognized

that a Management Systems Control Program has been initiated to meet that objective. However, because of the time required to complete the Management Systems Control Program, the ORRC suggests that an interim transition plan be fonnulated. The transition plan could, for example, define responsibilities among organizations with strong interfaces (e.g., plant performance and systems engineers and nuclear engineering)

Also, it is time in enough detail to avoid overlap or lack of coverage.

to start looking at the long range schedule and for line management to review and prioritize the items in the Long Range Scope List and to l

assure that resources are available and being applied to meet the Rancho Seco needs.

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Integrated Schedule: Great strides have been made by SMUD management to During its develop an integrated schedule for the Rancho Seco site.

review, ORRC still noted that there are duplicate tracking systems in which the same item appears several times. ORRC encourages SM)D manage-ment to continue to strive for a single fully integrated scheduling and tracking system. This will achieve increased cohesiveness among the various departments.

Following Procedures: During its visits to the site, the ORRC observed that procedure step sign-off provisions were not incorporated in all procedures; procedure steps were not performed in sequence; and root causes were not always identified when procedures were not followed.

The ORRC believes management needs to put continued and renewed emphasis on following procedures.

Simplification of Processes: The review revealed several opportunities to simplify processes. There is a large number of different documents identifying deficiencies across the various organizations and a more centralized system would be desirable. Similarly, programs to ensure plant status control are numerous and involve the Work and Test Authorization (WATA), equipment clearances, Work Requests, System Lineup Alterations and Logs. Consolidation of these processes is suggested to reduce the administrative burden of the shift personnel. Or again, the

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engineering change process is very tedious and the past difficulties in f developing and maintaining up-to-date control room drawings are well known to SMUD management.

It is recognized that steps are being taken to simplify the engineering process by planning to introduce the Design l

Change Package, but there are many more opportunities for simplifica-ti on . Rancho Seco personnel should be encouraged to identify, promote, and implement such simplifications.

Nuclear Chemistry: In its July,1987 assessment, INPO pointed out that Following that the Rancho Seco Chemistry Program needed improvement.

While review, a Nuclear Chemistry Action Plan was developed and issued.

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progress against the Plan was noted, the Nuclear Chemistry management appears to be over-optimistic about its' capaM?!ty to meet the Plan objectives in a reasonable period of time. Additional commitment of resources (in particular, a B&W e,.perienced backup to the Manager) and increased attention may be advisable to ensure that INPO identified defici6ncies are corrected in a timely manner. In particular:

o The chemistry limits now are specified in at least three different This may be an manuals and some of the limits are inconsistent.

impediment to obtaining management support, operations adherence and technical compliance with chemistry limits. Efforts should be accelerated to have a single, comprehensive, integrated document that specifies unequivocally tne chemistry control (a draft control document is being readied for issuarge). Also, Operations should be sensitized to the need to involve Nuclear Chemistry per-sonnel when chemical upsets begin to develop, o it is suggesteti that every effort be maoe to upgrade the amount, accuracy, precision and reliatility of chemistry on-line instru-mentati on so that it can be used for quantitative assessments against acceptance criteria. Consideration should be 9'ven to l

applying dedicated I&C Technicians to speed up such equipment installation and operability. 1 I

l In some cases, the QA program has been heavily Quality Assurance:

l I involved in day-to-day activities; in other cases, activities were being carried out or new processes implemented with very limited QA involve-ment. It is suggested that each organization be made more responsible for the quality of its own work and that QA emphasis should be on plant operations: Technical Specifications compliance, in-process monitoring l and verification of critical plant activities and the periodic (i.e.,

audi ts) and continuing (i .e., surveillances) assessment of the effec-tiveness of the management administrative, and technical contrul systems that assure reliable plant operation. Management should make increased 1

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use of QA to evaluate programs, identify deficiencies, and verify the adequacy of corrective actions.

0A Auditors and Surveillance staff do not have available to them a use-ful base of deficiency report data to utilize in preparing and focusing their audits. A data base is currently being developed but it does not appear that it will include the many types of available deficiency reports. It is suggested that the Management Systems and QA Depart:nents be comissioned to reduce the number and type of deficiency reports and to consolidate their contents.

Securi ty: An Action Plan for improvement to the Security System is being formulated. Until it is implemented, increased emphasis by JAn-agement is necessary to reduce the compensatory measures being taken to address several identified security deficiencies. Also, improvement in equipment is advisable in those cases where frequent repair and mid-tenance have heen required.

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