ML20150B983

Forwards AEOD/S802, Trends & Patterns Program - Special Rept Operational Experience Feedback Evaluation,Rancho Seco Nuclear Generating Station,Restart, in Response to 880211 Memo.Lists Items That Should Be Addressed for Restart

ML20150B983
Person / Time
Site:	Rancho Seco
Issue date:	03/08/1988
From:	Novak T NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:	Holahan G Office of Nuclear Reactor Regulation
Shared Package
ML20150B986	List: ML20150B983 ML20150C007
References
AEOD-S802, NUDOCS 8803170235
Download: ML20150B983 (76)

Text

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1. UNITED STATES E" o,i NUCLEAR REGULATORY COMMISSION

i cE WASHINGTON, O. C. 20555

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MAR 08 888 MEMORANDUM T0: Gary Holahan, Assistant Director for Regions III, and V Division of Reactor Projects III. -

IV, Y and Special Projects FROM: Thomas M. Novak, Director Division of Safety Projects Office for Analysis and Evaluation of Operational Data

SUBJECT:

REVIEW 0F RANCHO SEC0 This memorandum responds to yours of February 11, 1988, regarding the readiness review of Rancho Seco.

Our benchmark for the evaluation of plant readiness was based on the LERs of B&W plants that restarted after long outages and the Lessons Learned contained in NUREG-1275 that applied to operating reactors. The information to be evaluated was obtained from the licensee's submittal dated January 19, 1988, and on-site meetings with the licensee on February 16 and 17,1988.

Our evaluation is enclosed along with the B&W plant LER evaluation. To summarize, we conclude that the licensee has made extensive use of their own operating experience and that of other B&W plants. Several examples are cited in the evaluation that range from exemplary formal operations reviews such as their Precursor Review (an element of the Plant Performance and Management Improvement Program) to their use of more recent Crystal River 3 experience to improve their 2FIC system. As the restart date approached, the focus on forthcoming operations produced their "0perations Department Management Action '

Plan". That SMUD initiative highlights several issues common to NUREG-1275 that merit attention. Based upon the enclosure we consider that the following items should be addressed for restart:

1. Methods and Procedure Modification for Post Event Analysis -

The current Rancho Seco procedure for post-trip review (AP.28) classifies events into one of two categories - Type I or II. It appears that Type II events receive an adequate level of multidisciplinary review and root cause analysis. However, Type I events are treated much more lightly.

This type of events involves scrams where no "important equipment behaved abnomally or failed". Our generic safety concern for new plants was driven, in large part, by th(ir very high frequency of Type I events.

During our review of that experience, we noted that the high frequency of events was due to recurring causes similar to those of comp;ex events. It was the inadequate resolution of the causes of these simple events that produced the safety concern. More thorough post-event review and senior management involvement in restart decisions was the means to resolution, 8803170235 880308 PDR ADOCK 05000312 P PDR 2

I We suggest that the licensee modify their procedure for post trip review and the review of all reportable events to more fully enre that the proper root cause corrective measures are fully defined prior to restart, implemented in a timely manner, and that the appropriate level of management is involved in the analysis and decision making.

2. The adequacy of surveillance procedures and personnel training on these procedures -

It is our understanding that the licensee has rewritten about 80% of their surveillance procedures. This initially raised a concern regarding the experience of the plant staff in the use of these new procedures. In addition, the plant staff appeared to raise some human factors (format and content of procedures) issues in their management action plan. However, subsequent discussions with the licensee have indicated that they have confidence that the trajority of the procedures will be debugged prior to restart. We are not certain that all aspects of the procedure readiness issue have been addressed by the licensee. Therefore, we would suggest the conduct of some inspection effort to ensure that each individual involved has been adequately trained on the new final procedures prior to use during operations.

The recent progress of the licensee toward readiness for restart has been excellent, as noted by the staff members involved in the restart review. It appears that the plant management team has the correct focus. They have recently identified operational improvements to ensure smoother operations, however, all of these improvements are not yet implemented. In addition, startup testing and low power operation should provide an environment that is more revealing regarding their staff's performance and the plant readirass (procedures and equipment). Therefore, it appears beneficial to consider a mid-power hold /lookback point, similar to that utilized for new plants, that would allow the licensee to perform, and submit to the staff, a formal review of operations. Particular attention would be given to events involving personnel or procedural deficiencies.

Please r,ote that our suggestions are for restart and the extent that they be addressed prior to restart is your decision. The concepts involved are clear and our intent was to provide this information to be responsive to your request.

Sincerely, Thomas M. Novak, Director Division of Safety Program Office for Analysis and Evaluation of Operational Data Enclosure As stated cc: R. Bevan Distribution:

G. Knithton TPAB RF/CF TNovak D. Crutchfield G.L. Plumlee Edordan F. Miraglia C.J. Heltemes TMurley G. Kalman V. Benaroya J. Axelrad RDennig D. Kirsh (RV) liWilliams R. Zimmerman (RV) oPublic Docuinent Room J. Crews (RV)prt

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We suggest that the licensee modify their procedure for post trip review and the review of all reportable events to more fully ensure that the proper root cause corrective measures are fully defined prior to restart, implemented in a timely manner, and that the appropriate level of managerrent is involved in the analysis and decision traking.

2. The adequacy of surveillance procedures and personnel training on these procedures -

It is our understanding ...at the licensee has rewritten about 80% of their surveillance procedures. This initially raised a concern regarding the experience of the plant staff in the use of the;e new procedures. In addition, the plant staff appeared to raise some human factors (format and content of procedures) issues in their management a tion plan. However, subsequent discussions with the licensee have indicated that they have confidence that the majority of the procedures will be debugged prior to restart. We are not certain that all aspects of the procedure readiness issue have been addressed by the licensee. Therefore, we would suggest the conduct of some inspection effort to Ersure that each individual involved has been adequately trained on the new final procedures prior to use during operations.

The recent progress of the licensee toward readiness for restart has been excellent, as noted by the staff members involved in the restart review. It appears that the plant management team has the correct focus. They have recently identified operational improvements to ensure smoother operations, however, all of these improvements are not yet implemented. In addition, startup testing and low power operation should provide an environment that is more revealing regarding their staff's performance and the plant readiness (procedures and equiptrent). Therefore, it appears beneficial to consider a mid-power hold /lookback point, similar to that utilized for new plants, that would allow the licensee to perform, and submit to the staff, a formal review of operations. Particular attention would be given to events involving personnel or procedural deficiencies.

Please note that our suggestions are for restart and the extent that they be addressed prior to restart is your decision. The concepts involved are clear and our intent was to provide this information to be responsive to your request.

Sincerely, W1 Thomas M. Novak, Director Division of Safety Program Office for Analysis and Evaluation of Operational Data Enclosure As stated cc: R. Bevan G. Knighton  ;

D. Crutchfield F. Miraglia G. Kalman J. Axelrad D. Kirsh (RV)  :

R. Zimmerman (RV)

J. Crews (RV)