ML20247H555
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| ML20247H555 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/21/1989 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| References | |
| NUDOCS 8907310063 | |
| Download: ML20247H555 (3) | |
See also: IR 05000312/1988039
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JUL 211989
Docket No. 50-312
Rancho Seco Nuclear Generatir.g Station
Sacramento Municipal Utility District
14440 Twin Cities Road
. Herald, California 95630-9799
Attention: Mr. D. R. Keuter i
Assistant General Manager
Nuclear Plant Manager
Gent'.emen:
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP)
Board Report dated March 28, 1989 for your Rancho Seco Nuclear Generating
. Station and to the written comments provided in your May 11, 1989 letter in
response to the SALP Board's report.
We have reviewed your May 11, 1989 response and have concluded that your
response was appropriate. Based on discussions held between our respective
staffs, and in the absence of verbal identification of discrepancies within
the report or written comments from you which require resolution, we have
concluded that no changes to.the March 28, 1989 SALP Board Report are deemed ,
necessary. Related NRC conclusions are presented in Appendix I to this l
letter.
1
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures
will be placed in the NRC Public Document Room.
Should you have any questions concerning this letter or Appendix I hereto, or
the SALP Board's report, we will be pleased to discuss them with you.
Since ely,
& hfM
J. 3. Martin j
Regienal Administrator j
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Enclosures- l
1. Appendix I, NRC Conclusions l
2. SALP Meeting Report No. 50-312/88-39 1
3. Licensee response to SALP Report, dated May 11, 1989 j
!
CC. 1
Steve L. Crunk, Manager, Nuclear Licensing
State of Californic
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APPENDIX I
NRC CONCLUSIONS
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A. Conments Received From Licensee
Sacramento Municipal Utility District's (SMUD) May 11, 1989 response to
the Rancho Seco SALP Report presented no objections to the specific
content of the report. Because there were no objections, no changes .
were made to the SALP Report. l
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.
SMUD did provide c.larifying comments regarding situations described in
, the SALP Report. These clarifications were noted, and will be
considered in future inspections. !
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.B; NRC Conclusions Regarding Acceptability of Licensee's Planned
,
Corrective Actions q
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' We concluded that your proposed actions to address areas needing ,l
, improvement were responsive. We will review your progress..asc.part.of -{
our future inspection program, as appropriate. 1
C. : Regional Administrator's Conclusions Based on Consideration of
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Licensee's Response
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I have concluded that the overall ratings in the affected areas have not.
. changed.
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e ' UNITED STATES
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.,[ g. NUCLEAR REGULATORY COMMISSION
*
~L : j- REGION V
% g 1450 MARIA LANE, SulTE 210
% WALNUT CREEK, CALIFORMA 94596
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MAR 2 81989
' Docket No. 50-312
Rancho Seco Nuclear Generating Station -
Sacramento Municipal Utility District
'14440 Twin Cities Road
Herald, California 95638-9799
Attention: Mr. Joseph F. Firlit --
Chief Executive Officer, Nuclear
Gentlemen:
SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
The NRC Systematic Assessment of Licensee Performance (SALP) Board has
completed its periodic evaluation of the perfomance of Rancho Seco Nuclear
Generating Station _during the period July 1, 1986 through December 31, 1988.
The perfomance of Rancho Seco was evaluated in the functional areas of. plant
operations, radiological controls, maintenance / surveillance, emergency-
preparedness,. security, engineering / technical support, anc safety
assessment / quality verification. In addition, the performance of Rancho Seco
was also evaluated in a special functional area, startup testing. The
extensive startup testing performed necessitated evaluation of this additional
functional area. The crite.rfa used in conducting this assessment and the SALP
Board's evaluation of your performance in these functional areas are contained
in the enclosed SALP report. ,
Arrangements for a meeting to discuss the results of the SALP Board's
assessment will be made with your staff in the near future. i
As I discussed with you during our meeting at Rancho Seco on March 2, 1989,
SMUD's performance, on balance, since restart in March 1988 has been good and !
somewhat better than the average of other plants in the Region. The events of ;
- December 12, 1988 and January 31, 1989 have been recent exceptions to an
otherwise strong record of careful operation and testing since restart.
Your response to both of those events, however, indicates that SMUD has
improved substantially over the last four years.
Overall, the SALP Board found your performance to be acceptable and directed
toward
of strength. safe facility operation. Your startup testing was perceived as an area
In addition, improved performance was noted in all areas.
Specific strengths were noted in the generally professional and knowledgeable l
conduct of operations by control room operators, the engineering support for
the accomplishment of complex plant modifications, and the improved
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involvement of the quality department in plant activities.
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However, several concerns were identified by the NRC during this assessment
period which warrant your attention. Concerns comon to several functional
areas were the need for management to encourage greater use of your
nonconforming condition reporting system for identifying and correcting
discrepancies, and the need for management attention in assuring timely
completion of identified corrective actions including commitments to the NRC. .
A specific weakness in the area of plant operat, ions was the need for improved ;
communication and decision making among mid and upper level plant management.
In the area of radiological controls, continued improvement is needed with
respect to liquid effluent management.
A management sumary of this assessment is provided in Section II of the
enclosed report. Perceived strengths and weaknesses and Board recommendations
are discussed in Section IV, Performance Analysis.
You are requested to provide to this office, within 30 days after our
management meeting, a written response to this report. This response should
describe actions which you have taken or plan to take to provide improved
performance. Actions described in previous correspondence may be included by
reference if appropriate. Your response may also include comments on, or
amplification of, the SALP report as appropriate.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter, the ene.losed
SALP report, and your response will be placed in the NRC's Public Document
Room.
The NRC's Office for Analysis and Evaluation of Opertional Data performed an
assessment of licensee event reports submitted for Rancho Seco. This
assessment was provided as an input to the SALP process; a copy is therefore
provided as Attachment I to the enclosed report.
The response requested by this letter is not subject to the clearance
procedures of the Office of Management and Budget as required by the Paperwork
Reduction Act of 1980, PL 96-511.
Should you have any questions concerning the SALP report, we will be pleased
tc discuss them with you.
[ Si erely, ,,
1
Regional Administrator
Enclosure:
SALP Report No. 50-312/88-39
Attachment 1 Enclosed in SALP Report
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SALP BOARD REPORT
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-312/88-39
:
SACRAMENTO MUNICIPAL UTILITIES DISTRICT
RANCHO SECO NUCLEAR GENERATING STATION
JULY 1, 1986 THROUGH DECEMBER 31, 1988
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TABLE OF CONTEN1'S
P,ajte
1. Introduction 1
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A. Licensee Activities 1
l B.. Direct Inspection and Review Activities 2 L [' II. Summary of Results 2 l
A. Effectiveness of Licensee Manag*? cat 2
- B. Results of Board Assessment 3
C. Changes in SALP Ratings 4
III. Criteria 4
IV. Performance Analysis 5
A. - Plant Operations 5
B. Radiological Controls 9
C. Maintenance / Surveillance 13
D. Emergency Preparedness 15
E. Security 16
F.- Engineering / Technical Support 19
G. Safety Assessment / Quality Verification 21
H. 'Startup Testing 24
V. Supporting Data and Summaries 25
A. Enforcement Activity 25
B. Confirmation of Action Letters 26
C. .AEOD Events Analysis 26
D. Detailed Description of Licensee Activities 26
TABLES
Table 1 - Inspection Activities and Enforcement Summary 29
Table 2 - Enforcement Items 30
Table 3 - Synopsis of Licensee Event Reports 34
Attachment 1 - AEOD Review of Licensee Event Reports 35
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1. INTRODUCTION,
The Systematic Assessment of Licensee Performar.ce (SALP) is an NRC staff
integrated effort to collect.available observations and data on a
periodic basis and evaluate licensee's performance based on this
information. The program is supplemental to normal regulatory processes
used to ensure compliance with NRC rules and regulations. It is intended
to be sufficiently diagnostic to provide a rational basis for allocating
NRC resources and to provide meaningful feedback to the licensee's
management regarding the NRC's assessment of their facility's performance
in each functional area.
An NRC SALP Board, composed of the members listed below, met in the
Region V office on February 2, 1989, to review observations and data on >
the licensee's performance in accordance with NRC Manual Chapter 0516,
" Systematic Assessment of Licensee Performance," dated June 6, 1988. The
Board's findings and recommendations were forwarded to the NRC Regional
Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance j
at Rancho Seco for the period July 1, 1986 through December 31, 1988. l
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The SALP Board for Rancho Seco was composed of: I
**A. E. Chaffee, Acting Director, Division of Reactor Safety and Projects,
Region ~V (Board Chairman)
**G. W. Knighton, Director,' Project Directorate V, NRR
**G. P. Yuhas, Chief, Emergency Preparedness and Radiological Protection j
Branch
*H. S. North, Acting Chief Facilities Radiological Protection Section
*M. D. Schuster, Chief, Safeguards Section
*R. Fish, Chief Emergency Preparedness Section
**L. F. Miller Jr., Chief, Reactor Projects Section II
**R. P. Zimmerman, Reactor Projects Branch
**G. Kalman, NRR Project Manager
**T. D'Angelo, Senior Resident Inspector
**W. P. Ang, Proj ect Inspector
*K. Pendergast Emergency Preparedness Analyst
*D. Schaefer, Safeguards Inspector
*R. Pate, Chief, Nuclear Materials Safety and Safeguards Branch
*6 Denotes voting member in all functional creas.
A. Licensee Activities
Rancho Seco was in an extended shutdown outage from the start of the
evaluation period until March 30, 1988. After being. granted
Commission approval, a gradual approach to full power commenced with
plant startup on March 30, 1988 until the end of the evaluation
period. The gradual approach to full power included a rigorous
power acension test program. In general, Rancho Seco operated
satisfactorily from March 30, 1988 through December 31, 1988. A
detailed discussion of the significant occurrences during the period
is provided in Section V.D of this report.
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B. Direct Inspection and Review Activities
Approximately 15,427 on-site inspection hours were spent in
performing a total of 100 inspections by resident, region-based,
headquarters, and contract personnel. Inspection activity in each
functional area is summarized in Table 1.
The unusually large number of inspection hours was a result of the
extended SALP interval and a large inspection program prior to
restart on March 30, 1988.
II. SUMMARY OF RESULTS
A. Effectiveness of Licensee Management
The licensee's management organization stabilized somewhat in mid-
1987 with the appointment of a Chief Executive Officer (CEO),
Nuclear on May 4,1987, and the formation of a new organizational
structure. Subsequent to restart, on June 16, 1988, a new CEO,
Nuclear was appointed, and the organization's subordinate managers
have changed assignments, in some cases, as well.
During this SALP period SMUD senior management initiated several
major programs for improvement of Rancho Seco performance. These
included:
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An Action Plan for Performance Improvement
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A Systems Review and Test Program
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An Engineering Action Plan
*
A Procurement Action Plan
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Installation and Testing of a Safety Grade Emergency Feedwater
Initiation and '?nntrol System
*
Installation end Testing of Two Additional Emergency Diesel
Generators
The improvements undertaken by management are reflected in the
improved SALP ratings. However, numerous tasks remain to be
completed by the current management to improve plant reliability.
Included in these are commitments to the NRC such as the
establishment of design basis documents, and an effective
engineering oversight. The need for i>acreased involvement by the
current senior plant management in important plant evolutions was
evidenced by the December 12, 1988 feedwater transient. This senior
management involvement should be in sufficient detail to assure
greater caution and a more thorough understanding of plant
activities. Management attention needs to be focused on assuring
plant standards for performance established by the startup and test
program for testing are not relaxed as was evident by the auxiliary
feedwater overpressure event which occurred after the SALP period.
B. Results of Board Assessment
The SALP period was unusually long (July 1986 to December 1988) and
covered a period of plant operations that was characterized by
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several changes in plant management end organization and by diverse
plant evolutions associated with SMUD attempts to upgrade Rancho
Seco following an NRC imposed plant shutdown on December 26, 1985.
The plant restarted in March 1988 and commenced a power ascension
program which was completed in December 1988. This SALP focused on
post-restart operations and on the current management and staff.
Discussions of pre-restart evolutions and performances are included
when these events appeared relevent to the evaluation of currently
existing plant conditions and personnel.
Overall, the SALP Board found the performance of NRC licensed
activities by the licensee to be acceptable and directed toward safe
operation of Rancho Seco. The SALP Board has made specific
recommendations in most functional areas for licensee management
consideration. The results of the Board's assessment of the
licensce's performance in each functional area, including the
previous assessments, are as follows:
Rating Rating
Last This
Functional Area * Perioi Period Trend **
A. Plant Operations 3 2
B. Radiological Controls 3 2
C. Maintenance / Surveillance 3/2 2
D. Emergency Preparedness 3 2 Improving
E. Security 3 2
F. Engineering / Technical Support 2 2
G. Safety Assessment / Quality 3 2
H. Startup Testing Not Rated 1
* Maintenance and Surveillance were separate functional areas
during the last SALP period. Safety Assessment / Quality
Verification is a new functional area this period. It is
similar to, but more comprehensive than, the Quality Programs
and Adminiscretive Controls Affecting Safety functional area
which it replaced. Other functional areas rated separately
during the last SALP period, such as Fire Protection and ;
Training, were evaluated as appropriate within the scope of the
functional areas listed above.
** The trend indicates the SALP Board's appraisal of the
licensee's direction of performance in a functional area near
the close of the assessment period such that continuation of
this trend may result in a change in performance level.
Determination of the performance trend is made selectively and
is reserved for those instances when it is necessary to focus
NRC and licensee attention on an area with a declining
performance trend, or to acknowledge an improving trend in
licensee performance. It is not necessarily a comparison of
performance during the current period with that in the previous
period.
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C. Changes in SALP Ratings
Performance during this SALP period has inproved from that of the
previous SALP period. These improvements occurred because major
changes were made to equipment, personnel, and programs during-the
extended shutdown. Satisfactory accomplishment of these changes was
indicated by the Nuclear Regulatory Commission's approval of plant ,
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restart on March 22, 1988. The Plant Operations, Radiological
l Controls, Maintenance, Emergency Preparedness, Security, and Safety
Assessment and Quality Verification areas improved from Category 3
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to Category 2 ratings.
III. CRITERIA
Licensee performance is assessed in selected functional areas, depending
on whether:the facility is in a construction or operational phase. l
Functional areas normally represent areas significant to nuclear safety
and.the environment. In this evaluation, a special area of Startup
Testing was added due to the large amount of testing which was conducted
by the licensee prior.to restart in March, 1988.
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The following evaluation criteria were used, as applicable, to assess
each functional area:
1. Assurance of quality, including management involvement and control.
2. Approach to resolution of technical issues from a safety standpoint.
3. Responsiveness to NRC initiatives.
4. Enforcement history.
5. Operational events (including response to, analysis of, reporting
of, and corrective actions for events).
6. Staffing (including management).
7. Effectiveness of tha training and qualification program.
However, the NRC is not limited to these criteria and others may have
been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated was
rated according to three performance categories. The definitions of
thece performance categories are as follows:
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Category 1: Licensee management attention and involvement are readily
evident and place emphasis on superior performance of nuclear safety or
safeguards activities, with the resulting performance substantially
exceeding regulatory requirements. Licensee resources are ample and
effectively used so that a high level of plant and personnel performance
is being achieved. Reduced NRC attention may be appropriate.
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Category 2: Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are good. The
licensee has attained a level of performance above that needed to meet
regulatory requirements. Licensee resources are adequate and reasonably
allocated so that good plant and personnel performance is being achieved.
NRC attention may;be maintained at normal levels.
' Category 3: Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are not
sufficient. The licensee's performance does not significantly exceed
that needed to meet minimal regulatory requirements. Licensee resources
appear to be strained or not effectively used. NRC attention should be
increased above normal levels.
IV. PERFORMANCE ANALYSIS
The following is the Board's assessment of the licensee's performance in j
each of the functional areas, plus the Board's conclusions for each area
and its recommendations with respect to licensee actions and management
emphasis.
A. Plant Operations
1. Analysis
During the SALP period, approximately 4029 hours of direct
inspection effort were applied in the Plant Operations area.
Plant Operations has improved significantly during this SALP
period. The mo2t important accomplishments were th improved
professionalism of operators, and the reduction or operator
errors during intricate plant manipulations. Other strengths
were observed such as improved equipment control procedures and
significant upgrading of procedures. However, improved
communication among managers at different levels in the
organization appeared warranted. '
Prior to plant restart in early 1988, the licensee began a
performance improvement program designed to enhance the quality '
of future plant operations. The program included:
(a) Plant Emergency Operating Procedures were completely
rewritten in accordance with the latest Babcock and Wilcox
and NRC guidance.
(b) The Safety Parameter Display System (SPDS) was added to j
enable plant operators to quickly assess critical plant j
parameters. The system provided Rancho Seco operators !
with a useful, user friendly display and helped them to I
respond correctly to transients. l
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(c) The Technical Specifications (TS) were upgraded in format, I
Limiting Conditions for Operation (LCO) were added, and
previously included LCO's were modified to clarify the
Rancho Seco TS.
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(d) The licensee requested that Rancho Seco be a lead plant in
adopting the " Improved B&W TS" which are currently being
finalized by Babcock and Wilcox and the NRC.
The resident inspectors observed licensee operation daily,
including random backshift observations. Operations staffing
was observed to be correct, and operations personnel were
consistently observed to be knowledgeable and attentive to
plant conditionc. Control room demeanor was always observed to
be professional.
One negative observation was that during the event on December
12, 1988, decision making on the appropriate actions to be
taken was made by operations management without the involvement
of senior plant management for review. Senior plant management
subsequently recognized this weakness in communications and
decision making and established an action plan to improve in
this area.
Management presence within the plant has steadily increased
following the implementation of the licensee's management
monitoring program. Frequent tours of the power block by all
levels of plant management were observed by the resident
inspectors.
A weakness existed in the oversight role which plant management
performed in its control of the specific plant departments. An
example was identified which concerned the progress on near
term commitments made to the NRC prior to plant restart in
early 1988. The commitments which were made involved
improvements to the plant which had been identified by the
licensee's programs established as a result of the December 26,
1985 event. The inspectors noted that plant management was not
knowledgeable of the status of some of the significant
commitments which had been made to improve engineering and
procurement, in particular. The licensee responded to the
issue in a timely fashion with goals established for the
facility to complete previously identified items.
l l The licensee's approach to the resolution of operational safety l
issues was generally sound. Conservatism was routinely
exhibited by the control room staff when the potential for
I safety significant failures existed. During the startup l
program, detailed tests such as the Loss of Offsite Power Test,
l Emergency Feedwater Initiation and Control System Test and the
Steam Generator Secondary Pressure Test were properly conducted
and performed. These tests reed significantly abnormal valve
lineups of both the electrical and mechanical plant systems.
The December 12, 1988 reactor trip was an exception to this
overall trend. In that event, the licensee kept the reactor
operating despite a double failure in the controls for the
steam supply to the main feedwater pump. Also, the AFW
overpressure event demonstrated weakness in the conduct of post
maintenance testing.
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t Throughout this extended SALP period, the licensee's
responsiveness to NRC initiatives has been rapid and thorough,
particularly prior to the March 30, 1988 restart of Rancho
Seco. This was evidenced by the implementation of several
major programs resulting from NRC observations or inquiries.
These included:
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An Action Plan for Performance Improvement
*
A Systems Review and Test Program
*
An Engineering Action Plan
*
A Procurement Action Plan
*
Installation and Testing of a Safety Grade Emergency H
Feedwater Initiation and Control System
*
Insta11acion and Testing of Two Additional Emergency
f Diesel Generators (EDG)
Three Severity Level IV violations were issued during the
assessment period involving the failure to provide reports
required by 10 CFR 50.73. Licensee management satisfactorily
resolved the deficiencies through clarification of their
procedure for controlling notifications to the NRC.
A total of 36 LER's were submitted in this functional area.
Most of the LER's were attributable to personnel error. Nine
of these dealt with fire protection discrepancies that
predominately involved missed fire watches. During these
periods extensive modifications and testing were in process
with the plant in off normal configurations. The remaining
LER's appear to be attributable to weah procedures and isolated
events. Those LERs received additional management attention to
ensure improved performance and procedures. The licensee
developed an Operations Department Action Plan in December 1987
which resulted in improved performance and few LERs since have
related to personnel error or procedural deficiencies.
In the early phases of the test program, a number of
operational errors were committed during testing which
ultimately lead to suspension of testing during the Loss of
Offsite Power tests. In response to the difficulties
. experienced at the time, the Operations Department Action Plan
mentioned above was developed. Operator performance since that
time improved considerably with no significant operator errors
being detected.
The licensee conducted an extended power ascension program
which included significant Integrated Control System (ICS)
tuning and two preplanned reactor trips. During this phase,
the control room operators were also challenged by two
unplanned reactor trips, one which led to the reactor coolant
system being on natural circulation. During these events,
performance by the control room personnel was sound and timely
in response to the unexpected plant transients which had
occurred. In addition, the ICS and main feedwater system
caused several plant transients which were correctly addressed
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by the plant operators who prevented a reactor trip by quickly
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identifying the condition and correcting the cause for the
abnormal condition.
The licensed operator training program was effective during the
SALP period. This was evidenced by a high pass rate of 90
percent (9 passes of 10 candidates) on annual requalification
examinations and a 100 percent pass rate (17 out of 17) on the
1987 and the 1988 replacement examinations. The licensee has
started construction of an Engineering and Training a11 ding
'during this SALP period with completion (ready for training)
scheduled for the Summer 1990. Arrival and startup of the site
specific simulator is scheduled for mid-1990. The licensee's
operations staff has remained stable throughout this SALP
period. All licensed operator positions are filled and only
one vacancy occurred in the last year.
During this SALP period, the licensee's overall fire protection
program improved. Some deficiencies in fire barriers, fire
alarm systems, fire suppression systems, fire brigade training
and the performance of fire pumps continued; however, both a
plan and resources for correction of these deficiencies were
established by the liccuaee. Routine and corrective
maintenance activities appeared to be responsive to the need
for safe and reliable performance of fire protection systems.
Conclusion
Performance Assessment - Category 2
Board Recommendations
The Board recommends that the licensee continue to emphasize
improving communication and decisionmaking among mid and upper
level plant managers. Action should also be taken to enhance
specific plant knowledge among the plant management staff to
improve assessment and recognition of unusual or abnormal plant
conditions.
B. Radiological Controls
1. Analysis
A total of thirteen routine and four special inspections were
conducted by the regional staff during this assessment period
in the areas of organization and management, occupational
radiation safety, radiological effluent control _and monitoring,
radioactive vaste management, transportation of radioactive
materials, training and qualifications, and confirmatory
measurements. In addition, the resident inspectors provided
continuing observations in this area. i
For the last assessment period, the licensee was assigned a !
Category 3 rating. The board had recommended that the licensee f
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implement the reorganization of the Chemistry, Radiation
Protection and the Technical Support group in a timely fashion,
and fill the vacant Chemistry Superintendent's position as
quickly as possible; improve.the NRC commitment tracking
system; amend the Technical Specifications to improve the
Radioactive Environmental Monitoring Program to assure
compliance with 10 CFR Part 50, Appendix I; complete the
installation and testing of the Post Accident Sampling System
(PASS).
There has been significant improvement in management support in
the. radiological controls area. During the beginning of this
assessment period, management was slow in providing the needed
support. However, changes in upper management during the last
two years have resulted in increased support and improved
performance. Specific examples include: implementation of an
effective NRC commitment tracking system; demonstration of an
operable PASS prior to reactor restart (March 1988); revision
of the Technical Specifications and Off-Site Dose Calculations
Manual to improve the Radiological Effluent and Environmental
Monitoring programs, and assure compliance with 10 CFR 50,
Appendix I. The QA organization has been effective in
providing independent critical review, particularly, in the
area of the radioactive effluent control and monitoring
program. Surveillance conducced by the Corporate Health
Physics and Chemistry Services group have been effective in
identifying deficiencies _in the radiation protection and
effluents pro. grams. A monthly management observation program
was instituted which resulted in increased involvement of site
management in plant activities. Weekly supervisory plant
walkdowns have been effective in identifying and correcting
deficiencies and improvement in housekeeping practices.
A continuing concern involved the frequent changes in
management personnel, organization, and assignment of
responsibility for implementation of the radioactive effluent
programs. During the latter part of 1987, the responsibility -!
for offsite dose calculations was transferred from the
Radiation Protection Depertment to the Environmental Monitoring l
6 Emergency Preparedness (EM&EP) Department, with liqufd and
gaseous effluent sampling being performed by Radiation
Protection, and sample counting by Chemistry. On July 15, i
'
1988, responsibility for implementing the effluents program was
transferred to Chemistry. By February 1, 1989, Chemistry will
have responsibility for effluent sampling. The instability i
resulting from continuing changes in responsibility for
management of the effluent programs has inhibited the
establishment of a program with well-developed procedures and i
experienced personnel. Due to these changes, the licensee has
not always been timely in responding to and taking corrective
action for deficiencies identified through internal
assessments. During the last month of this essessment period,
the Chemistry group appeared to be aggressively working to
develop an effective program.
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On February 4,1988, the licensee experienced an event that
resulted in a worker receiving a calculated dose to a small
area of skin of whole body in excess of the quarterly limit
from a " Hot Particle." Review of this event indicated a lack
of management oversight with respect to communications,
training and implementation of the procedures to control hot
particles. Shortly after the incident, management recognized
the seriousness of the problem and took prompt and extensive
corrective actions to prevent recurrence. The licensee
accelerated implementation of their hot particle program and
completed training of all onsite workers on the hazards and
controls related to hot particles by April, 1988.
The licensee resolved most technical issues with appropriate
conservatism, technical competence, and supporting
documentation. This was notably demonstrated in the licensee's
response and corrective actions to the February 4, 1988 hot
particle incident. With respect to the effluents program, in
implementing their new Radiological Effluent Technical
Specifications (RETS), the licensee identified counting times
required to meet new lower limit of detection (LLD)
requirements for radioactive liquid pre-batch releases and l
composite samples that were unattainable for certain gamma
emitting isotopes. The long counting times (about 8 hours)
resulted in difficulties in making releases in a timely
fashion. It appeared that the licensee had failed to properly
evaluate their capabilities for meeting the LLD values prior to
submission of the request for license amendment. After a more
thorough review of this matter, the licensee submitted a
prcposed license amendment changing the LLD for specific
radionuclides, without affecting the bases of the LLD values,
thereby reducing the counting times.
The licensee's responsiveness towards resolving the operational
aspects of the liquid effluent issue has not been fully
satisfactory. While many plans have been presented, NRC
inspection findings, licensee audits and operational events
continue to reveal the need for additional management
attention. Changes which would allow operation within the
envelope of expected events without exceeding 10 CFR 50
Appendix I values should be completed.
During this assessment period, the licensee has been generally
responsive to NRC initiatives and concerns. This included
implementation of the SALp Board's recommendations from the
previous assessment, management's continued support of the
radiation protection program and improvements in facilities and
management of the dry radioactive waste program. Housekeeping
has been effective in minimizing contaminated areas. A number
of long outstanding items have been addressed.
One Severity Level III, nine Severity Level IV, and six
Severity Level V violations were issued during this assessment
period. The Severity Level III violation involved (1) an
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occupational dose to a small area of the skin of the whole body
[ of a worker that exceeded the regulatory limit, . (2) the failure
to notify an in.fividual in writing of his exposure, (3)la
'
failure to properly instruct workers in precautions and
procedures for minimizing exposures when working in a " Hot
Particle Zone", and (4) the failure of certain individuals to
adhere to procedures for control of personnel exposure. An
enforcement conference was held to discuss the apparent
violations and the licensee's corrective actions to prevent
recurrence. . Based on the licensee's prompt and extensive
corrective actions to prevent recurrence, a Notice Of Violation
was issued without a civil penalty. The other violations
identified during this long assessment period as indicated in
Table 2, appeared to be isolated occurrences that did not
indicate a programmatic breakdown in the management of the
radiological controls program. In addition, prompt and I
effective corrective actions were taken to prevent recurrence.
!
A total of 22 LERs were submitted in this functional area.
Most of the LERs were attributable to personnel error. One of 1
!
the LERs was related to the Severity Level III violation and
the others appeared to be isolated events. It appears that
additional management attention is needed to reduce the number ;
'
of personnel errors.
During the early part of this assessment period, several~
weaknesses were identified in the ALARA program. The ,
weaknesses were attributable to a lack of QA involvement, j
training for engineers and foremen, and poor planning.
Management's support for the ALARA program, resulted in the
implementation of an effective training program for
supervisors, engineering, and the design review staffs. The
work planning procedures were revised to include ALARA planning
in the initial phases of processing work requests. A new ALARA
Policy was issued and ALARA procedures were revised to
strengthen the program. For 1986, the licensee expended about
505 person-rem with a goal of 165 person-rem. In 1987, the '
goal vac set at 350 person-rem with 299 person-rem expended.
For 1988, the licensee's initial goal of 250 person-rem was
adjusted to 95 person-rem with about 79 person-rem expended as
of November 30, 1988. The long shutdown time and consequent
lower source term was a major contributor to the exposure ;
'
reduction.
There has been significant instability in organization and :
staffing during this assessment period. During most of the t
assessment period, the Radiation Protection Manager's (RPM)
position was filled on a temporary basis by several 1
individuals. The Chemistry Superintendent's position was ;
staffed with contract employees and experienced a high rate of i
turnover. The EM&EP group also experienced several management
and organizational changes. The changes in responsibility for
management of the effluent programs has been a major
contributor to these changes. During the last six months, the
I
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Radiation Protection group appears to have stabilized with key
!
positions staffed with permanent employees that included
. additions to the technical staff. In July, 1988, the RPM's
position was filled with a permanent employee, and as of
October 1988, the EM&EP Manager's position was staffed on a
permanent basis. - The Chemistry group continues to be staffed
by contract employees in key supervisory and technical
positions. The EM&EP Department also has a high number of
contract employees filling positions.
The licensee has made significant improvements in the training
program. During the last year, the licensee has received full
accreditation of their training programs from the Institute of
Nuclear Power Operations. A new upgraded General Employee
Training Program will be initiated in January, 1989. The
licensee's training and qualification program also included
contract employees. During this assessment period, there were
several events where deficiencies in training were identified
as causitive factors. The licensee took prompt action to
correct the deficiencies to prevent recurrence.
The licensee has established a satisfactory program for
performing radiochemical measurements. Laboratory quality
control and quality assurance activities were substantially
improved during this period due to improvements in procedures.
Inter-laboratory comparisons of radiochemical measurements were
also improved, as the licensee began participating in a new
contract laboratory intercomparison program. Onsite
intercomparisons with NRC measurements were successful.
2. Conclusion
Performance Assessment - Category 2
3. Board Recommendations .
l
i
The licensee needs to continue their efforts in the staffing of
Chemistry and EM&EP with permanent employees, in the
identification and correction of deficiencies in the
radioactive effluent programs, and in the control of liquid
waste.
C. Maintenance / Surveillance l
1. Analysis
During the SALP period, approximately 2096 hours.of direct
inspection effort were applied in the area of Plant Maintenance
and Surveillance. Strengths were observed in the work request
system with the installation of an automated computer based
generation, tracking and retrieval system for work request
documents. Preventive maintenance procedures were completely
revised during this SALP period and included monitoring and ]
trending of machine vibration, thermography, oil analyses and
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mean failure times. A continuing weakness during the SALP
period involved the failure to idetaify and document material
deficiencies when discovered during' repair or rework of plant -
equipment. For example, repeated trips of the feedwater heater
drain pump were not aggressively investigated.
The licensee programs to ensure follow-up and trending of
failed surveillance, clearance of equipment, performance of
required maintenance and curveillances.'and quality control of
safety related materials were found to be adequate in this
., period. A strength was noted in the generation and revision of I maintenance procedures for specific plant equipment. Such
procedures had included extensive use of graphics with enlarged
views of equipment showing internals. Some weakness was
demonstrated in the control of post maintenance testing during
the overpressurization of the AFW system after the SALP period
ended. Staffing of maintenance and surveillance organizations
was considered adequete.
The licensee had some difficulty in maintaining secoadary
diusolved oxygen levels within procedural requirements late in
this asseesment period. On one occasion, feedwater oxygen
concentration limits were exceeded with the consent of
management. However, the need to exceed the procedural
requirement was not recognized as a deficiency to be evaluated
L by the licensee's deficiency reporting system.
Licensee manaFement was actively involved in the scheduling and j
coordination c; :aintenance and surveillance activities. The
licensee was considered to be responsive in addressing NRC
concerns. Maintaining and utilizing current day industry
standards for preventive and predictive maintenance activities
appeared to be a goal of the Maintenance Department management.
Action was also taken to reduce work request backlogs, to i
control and reduce valve packing leaks, and to successfully !
conduct a secondary side hydrostatic test of the Main Steam
system following the large number of significant modification
made to that system.
The principal maintenance weaknees observed during this SALP
period was insufficient identification and focumentatiou of
deficiencies observed during the conduct of planned work
activitios or plant evolutions. For example, as discussed
above, difficulty in maintaining secondary side chemistry was
not documented as required. Another example was the licensee's
failure to recognize that improperly sized packing had been
used for the repacking of the auxiliary feedwater pumo during a
repair effort. Subsequent failure of the pump seal was
encountered during a start of the pump due to this error. As
noted above, after the SALP period, the overpressurization of
AFW indicated post maintenance testing as another area of !
significant concern.
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An industry accredited training program for maintenance and
surveillance personnel was developed and initiated. However,
s , the training of these personnel was deficient on at least one
occasion late in the period in that maintenance personnel and
supervisors did not reject kinked hydraulic hoses that they
were aware of on a feedwater valve controller.
;
Ten Severity Lev 21 IV and two Severity Level V violations, and
one deviation wsre issued during the SALP period. The majority
of the enforcement action was related to a failure to follow
procedures or to have an adequate procedure for the work
activity in process. While neue of the violations was
individually indicative of a programmatic breakdown, taken
collectively it appears that additional management attention is
needed.to reduce the number of maintenance personnel errors.
During the SALP period, 20 LER's were issued.in the area of
maintenance and surveillance. Of these 20 LER's, six involved
personnel error, 4 involved installation error, nine involved
defective procedures and one involved a component failure. The
LER's adequately described the major aspects of the events and
the corrective actions taken or planned to prevent recurrence.
Extensive maintenance program development (which included
procedure revisions) appeared to have resolved the conditions
which were reported.
Conclusion
PerformanceIAssessa--? - Category 2
Board Recommendations
Plant management should focus special attention on
identification and documentation of discrepant material
conditions and improvement in post maintenance testing.
Licensee management should continue to emphasize the
development of work procedures for specific plant equipment,
and to improve personnel performance and procedure adherence.
including the chemistry area.
D. Emergency Preparedness
1. Analysis
The area of emergency preparedness (EP) was the subject of 12
inspections, including the observation of three (3) exercises,
during this SALP period. These inspections represented
approximately 590 hours of direct inspection effort. The
resident inspectors assisted the regional inspectors in
accomplishing the inspections. The previous SALP assessment
concluded that the performance in the area of EP was a Category
3. Recommendations to improve management support and oversite
in numerous areas of the EP program uere made to Flant
Management by the previous SALP report.
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There has been a significant improvement in the management
support of the emergency preparedness program during the SALP
period. At the beginning of the period management support was
poor, reflective of the SALP 3 rating. The changes in upper
management during the last two years have brought increased
support for emergency preparedness to the extent that presently
it is considered a strength, particularly with respect to
devoting resources necessary to insure an adequate capability
is maintained. Considerab]c contractor support was obtained to l
provide adequate support for the changes needed to be made in
emergency preparedness. The required changes included a major
rewrite of the Emergency Plan and implementing procedures and
significant improvements in the records system and emergency
preparedness training program.
l
Technical issues associated with dose nssessment and
meteorology have been addressed during this SALP period.
Needed improvements in the area of meteorology were identifded
and are being implem nted. In the interim, the licensee has
made adjustments to the dose assessment program to better
address the uncertainties in the meteorological drta.
The licensee has displayed an increasing responsiveness to NRC
initiatives. The changes to the Emergency Plan and
implementing procedures that were made support this finding.
In addition, the responses to the violations identified during i
the SALP period have been more complete during the latter part j
of the period.
Three minor violations of NRC requirements were identified
during the course of the assessment period. Two of the
violations appeared to result from a failure by middle
management (EP management at the time) to asstre identified ]
deficiencies were corrected in a timely and thorough manner.
There was considerable variation in the licensee's emergency
preparedness staffing during the SALP period. At the beginning
of the period the supervision and staffin5 was weak. Shortly
thereafter, supervision was strengthened in an effort to
correct the many problems that existed. In addition, a uumber
of contractor personnel were hired to provide adequate staffing
to accomplish the numerous tasks to be performed. During the
last half of the SALP period anoervision of emergency
preparedness was in a state of fjux due to several persons
filling the supervisor'c position. At the present time the
staffing appears to have stabilized with the hiring of a new
employee to the position of Manager, Environmental Monitoring
and Emergency Preparedness. Also, permanent emergency
preparedness positions have been established to elirinate most
of the need for contractor support.
!
At the beginning of the SALP period the emergency preparedness j
training program was considered to be a significant weakness. I
During the last two years the licensee has expended
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considerable effort to improve this training program. The
program is now well defined and lesson plans have been
prepared. The exercise results have demonstrated the
licensee's ability "s respond to emergencies and identified
areas for improvements.
2. Performance Rating
Category 2, improving trend.
3. Board Recommendations
Continued management oversite to incure emergency preparedness
continues to improve and that identified problems are corrected
in a thorough and timely manner.
E. Security
1. Analysis
During this SALP assessment period, Region V couducted seven
physical security inspections at Rancho Seco. Approximately
460 hours of direct inspection effort were expended by regional
inspectors. In addition, the resident inspectors provided
continuing observations in this trea. There were no material
control and accounting inspections conducted during this j-
assessment period. I
~
Thz previous SALP report recommended that licensee management
expand their support to the overall security program. Since
the initial operation of Rancho Seco, the Security Department ,
reported directly to Corporate Security, loccted approximately )
35 miles from the site. In January 1988, the site Security l
Department severed their direct tie with Ca porate Security,
and commenced reporting directly to plant management. Thls
change, together with a major reorganization of the security
organization has improved the efficiency of the Security
Department by realigning key security positions and
responsibilities. The reorganization of the Security
Department has also improved the licensee's ability to
implement remedial measures to correct deficiencies identitied
in the course of both internal and NRC security inspections.
On March 7, 1986, approximately four months prior to this SALP
period, the licensee published a Security Performance
Improvement Plan (SPIP) for security operations at Rancho Seco.
This SPIP identified 79 separate actions the licensee intended
to complete in order to upgrade their security program to
resolve earlier NRC concerns. Additionally, in response to the
'eptet'ser 1987 NRC Regulatory Effectiveness Review (RER)
report, the licensea identified 19 additional actions. The
majority of these actions have been completed, and have
provided the licensee with an increased capability to defend
against the design basis threat.
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The previous SALP report also identified problems with security
force training. During this assessment period, as a result of
the Security Departments' reorganization, the Training Section
assigned a permanent supervisor, increased their training
staff, and acquired larger training support facilities.
Increased management emphasis resulted in development of a
Special Weapons and Tactics (SWAT) security response force, and
upgraded annual refresher training.
The previous SALP report also encouraged licensee management to
increase the frequency of compliance monitoring of the security ,
program. As a result of their SPIp, and the reorganization of
their Security Department, the full-time security auditor
(assigned to Corporate Security) coordinates his compliance
review with the licensee's Quality Assurance Department.
Security management has continued to demonstrate a coordinated
effort with oth6r plant staff in prevenving safety / security
problems at Rancho Seco. Currently, a new site radio
communication system is being installed which will increase the
overall communication ability of the Operations and Security
Departments. The licensee anticipates initial operation of
this new radio system by January, 1969.
During the assessment period, thirteen information notices
related to security were issued. The licensee's actions, as
reviewed to date, were found to be appropriate.
The enforcement history for the period of Ju..y 1, 1986 through
'
December 31, 1988 includes five Severity Level IV violations
for the licensee's failure to: provide adequate illumination
of an area inside the protected area; provide two physical
barriers for the protection of vital equipment; provide proper
storage protection for safeguards information; deny site access
to unauthorized personnel; and, test access alarms for certain
vital area portals. Additionally, the enforcement history
included one deviation for the licensee's failure to adequately
revalidate security badges every 31 days.
During this SALP period, Rancho Seco reported 51 safeguards
events. Three of these events occurred after the October 1987
change in the reporting requirements of 10 CFR 73.71(c), and
thus were reported in the Licensee Event Report (LER) format.
These events related to: repositioning plant toggle switches
(21); unauthorized (mistaken) entry into plant vital areas
(14); loss of security computers (4); bomb threats and
threatening telephone calls (4); unlocked vital ~ area portals
! (2); inadequate compensatory measures (1); degraded vital a rea j barrier (1); drugs found inside protected area (1); cutting of J equipment wires (1); unescorted visitor inside protected area
(1); and security-related document found on site (1). The
majority (94%) of these events occurred during the first half
of the SALP assessment period.
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In response to the August 1986, NRC policy statement on Fitness
for Duty of nuclear power plant personnel, licensee management
continues to support their established Fitness for Duty
Program. This program, applicable to all licensee and contract
personnel, consists primarily of: Pre-Employment Drug
Screening; Medical Clarification Examinations; Routine Testing
After Employment; For-Cause Drug Testing; and an Employee
Assistant Program. The medical clarification examination is
administered on a random basis, and consists of a short
physical examination designed to determine the presence'of
drugs and alcohol in the employee's system, plus a medical /
psychological evaluation. Licensee employees who work on or
operate vital equipment, and contract employees granted access
to site vital areas, qualify for this examination. If, in the
judgement of the examining practitioner, the employee is
considered to have indications of drug or alcohol use, the
employee is required to submit to a drug and alcohol urine
scieen. The routine testing after employment, is required when
a physical examination is mandated by a regulatory agency.
.
Additionally, the licensee's Program includes the random
unannounced use of drug detection dogs inside the' protected
area.
2.- Conclusion
Performance Assessment - Category 2.
3. Board Recommendation
Licensee management is encouraged to continue their support to
the overall security program, and to finalize ongoing
improvements identified in the Security Performance Improvement
Plan, and the responses to the RER report.
F. Engineering / Technical Support
I- Analysis
puring the SALP period, approximately 1902 hours of direct
ins 9cetion effort were applied to the Engineering / Technical
Support area. In addition to continuing coverage by the
resident inspectors, a NRC Augmented System Review and Test
Program (ASRTP) team inspection was performed along with
enhanced observation by senior regional staff. The major
weakness in this area involved the discovery of significant
inadequacies in the control of design and engineering work,
largely resulting from a poorly defined plant design basis and
insufficient attention to plant design details. In contrast, a l
strength observed during the latter part of the SALP period
involved the self-critical attitude demonstrated by senior SMUD
management in acknowledging the need for imprev,'d performance
in this area, including engineering reorganization.
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The initial findings of the NRC ASTRP inspection identified
several weaknesses in engineering involvement in the resolution
of problems identified by the licensee's systems review and
test program. The team also identified several deficiencies
with some engineering analyses for ongoing system
modifications. SMUD management subsequently developed and
implemented an innovative Engineering Action Plan (EAP) to
restore confidence in the Rancho Seco engineering design and
design process. The EAP included organizational,
administrative, and cultural changes to provide a better
definition of responsibility and authority for engineering
activities. SMUD also contracted with an independent group of
technical consultants to perform an expanded ASTRP (EASTRP)
inspection similar.to the NRC inspection on the remainder of
the systems not previously inspected by the NRC.
A revision to the EAP provided further technical aspects of the
plan. This included:
*
Upgrading the engineering design change process to improve
the control and quality of future work.
*
Review of calculations for technical accuracy and
completeness.
*
Review of technical work performed during the outage to
assure design adequacy.
*
Reestablishment of the plant system design bases.
The EASTRP was performed and the EAP initiated prior to
restart. An evaluation of EASTRP by the NRC ASTRP inspection
team concluded that the EASTRP inspection process provided
adequate confidence that any significant problems with the
design of Rancho Seco were being identified before restart.
The NRC ASTRP team also assessed the EAP and concluded that the
EAP appeared to improve the quality of calculations and analyses
performed. to support system design. Although many aspects of
the EAP were cotpleted prior to plant restart, many other
portions of the EAP remain to be completed. The second
revision of the EAP, dated September 16, 1988, was issued to
identify items completed and the long range items still to be
finished. One of the more significant aspects of the EAP that
remains to be corrpleted is the establishrnent of system design
basis documents. The licensee has a;ireed to complete the
initial portion (14 systems) of this very extensive program by~
the end of the next refueling outage.
Plant restart was contingent on several major system additions
and modifications. Engineering performance to support these
projects was excellent. Operational scfety was enhanced
significantly by the addition of the Emergency Feedwater
Initiation and Control (EFIC) system and the Safety Parameter
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Display System (SPDS). Hardware reliability and hu. nan !
engineering features associated with these, relatively complex, j
systems are indicative of SMUD's capacity for engineering 1
excellence. J
The addition of two diesel generators and modifications to the )
emergency electrical distribution system are additional j
examples of excellent engineering capability and performance.
Diesel angine vibrations and cable routing discrepancies,
tasked the engineering organizations ability to respond to
unexpected problems. In both instances, these complex issues
were resolved in a thorough and professional manner.
Three enforcement items were identified in this functional
area. Specifically, one Severity Level IV violation was
identified for failure to establish written procedures for
radiographic inspections of decay heat removal pump drain
lines; one Severity Level V violation was identified for an
inadequate drawing - four different welds had two redundant
weld number identifiers; and a deviation was identified for the
use of silicone sealants in the essential HVAC system.
During this SALP period 11 LERS were attributed to this
functional area. All of the LERs resulted from technical
discrepancies such as the lack of channel isolation devices for
two channels of the Reactor Protection System power summing
amplifier.
The extendad' outage during this SALP period required increased
technical manpower to support the varied codifications that
were initiated and completed. Licensee technical staff was
heavily supplemented by contract personnel to support the
workload. The supplemental contractor work force was reduced
following completion of the modifications and upon plant
restart. Despite the heavy workload, no significant
discrepancies were attributed to the adequacy of technical
staffing. Similarly, effectiveness of training and
,
qualifications of the technical staff appeared to be sufficient
I for the technical tasks that were being performed. l The licensee has been very responsive to NRC initiatives and
has taken extensive corrective action to improve the quality of
engineering's activities. For example a new design control
process utilizing a design change package (DCP) approach was i
j established. Although the licensee's corrective actions
appeared to be extensive and complete, no new engineering
products were available for audit to determine the
effectiveness of the licensee's revised design control process.
A number of significant weaknesses were identified by both the
NRC and licensee in past procurement practices utilized by the
licensee in the purchase of safety-related parts. Of specific
concern to the NRC was the practices used to upgrade commerical
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grade parts for use in safety-related systems. The practices
utilized in procurement before July, 1987 were not adequate.
The licensee revised their procurement program to incorporate
improved practices to prevent use of substandard parts in
safety related systems.
After the SALP period, the ovarpressurization of the AFW system
event revealed two weaknesses in this area as related to this
event: weak engineering oversight of maintenance activities
and continued weakness in procurement.
Conclusion
Performance assessment - Category 2
Board Recommendation
Management attention is needed to maintain a permanent, stable
site engineering staff. Engineering efforts to complete the
design basis records project should continue, and a review of
the effectiveness of the current design change process should
be conducted once a representative sample is c7ailable.
Management attention is needed to enhance engineering oversight
of maintenance activities in light of the AFW overpressure
event.
G. Safety Assessment / Quality Verification
1. Analysis
During the SALP period, approximately 5739 hours of direct
inspection effort were applied in the area of safety
assessment / quality verification. Significant strengths noted
during the SALP period included the implementation of a root
cause analysis process and an aggressive approach by management
to involve outside organizations, mainly INPO, in reviewing
problem areas and providing recommended corrective action.
However, several significant weaknesses were also noted in this
functional area. These included the need for more aggressive
use of the licensee's nonconforming condition reports (termed
potential deviations from quality (FDQs) by SMUD), and a lack
of progress in the completion of several post-restart
commitments such as the creation of design bases.
Over the lengthy evaluation period, many technical submittals
were reviewed by the staff. These included technical
specification change requests, NUREG-0737 itemst exemption and
relief requests, responses to generic letters, licensee
activities related to resolution of safety issues, and
responses to other regulatory initiatives. The plant was shut
down for a significant portion of the evaluation period because
of major problems at the plant that required full technical
resolution prior to restart. Several of these issues involved
a substantial interface with the NRC technical staff. Issues
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_ _ - _ - - _ _ _ -
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L? . 22
-
included addition of two emergency diesel generators,
envf.ronmental qualification, fire protection, upgrades to
emergency feedwater and instrument air systems, addition of
hydrogen recombiners, establishment of a minimum meteorological
monitoring program, system review and test program, reactor
trip system reliability modification, and others.
Licensee submittals were generally found to be adequate and
responsive to the subject matter. Contractor assistance and
licensee management oversight of the. contractors appeared to be
edequate as reflected by the submittals.
A conservative approach to fire protection issues has been
evident. However, two supplemental changes were submitted up
to a year after the original amendment submittal. This was
indicative of a lack of attention to detail. Specifically, all
_ parts of the technical specifications that needed to be changed
were not considered. These changes resulted from oversights
that failed to incorporate original plant areas in tables and j
charts. This oversight appeared to be inconsistent with other
submittals and was ccasidered to be an isolated case.
Inspection activities during the SALP period resulted in the
identification of twelve enforcement items. Specific
enforcement topics included two Severity Level IV violations
for inadequate closure of nonconforming condition reports;
three Severity Level IV violations for inadequate control of
safety related material in the warehouse; one Severity Level IV
violation for not performing a 10 CFR'50.59 evaluation for
gagging two decay heat removal (DHR) system relief valves; one
Severity Level.IV violation for failure to perform cable
routing inspections; one Severity Level IV violation for
performance of liquid penetrant inspections of the spent fuel
pool liner plate without appropriate acceptance criteria; one
Severity Level IV violation for numerous housekeeping
violations; and one Severity Level V violation for failing to
retain radiographic records of degraded DER lines.
The two violations identified for failing to write
nonconforming condition reports were indicative of a persistant
hesitancy on the part of licensee personnel to report
nonconformances properly. A preference to use work requests
for identifying and correcting nonconforming conditions was
noted on several occasions. This demonstrated the need for
greater management emphasis to ensure nonconformances are
properly identified.
_
No LERs were specifically attributed to this area. However,
weaknesses in the licensee's safety assessment and quality
verification performance contributed to numerous LERs such as
the cable routing problems, the AFW pump packing material
discrepancy, and non-inclusion of containment isolation valves
in the local leak rate test program.
J
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On several occasions during this SALP period, the licensee
demonstrated a v1111ngness to review its own programs to
identify weaknesses. These reviews included EASTRP, INPO
readiness for operation evaluation, Babcock and Wilcox
transient assessment team evaluation, and independent
assessments of the QA program. These reviews demonstrated
increased willingness by the licensee to be self-critical and
to learn from the expertise of outside organizations.
The licensee's quality verification program has shown
improvement in various areas such as increased on-the-job QC
inspection of maintenance and modifications, performance of QA
surveillance and the implementation of a new nonconforming
condition reporting program.
In March, aaae and August of 1988, an enhanced operational NRC
inspection taam evaluated performance of operating crews and
supporting otAanizations during the plant's power ascension
from the extended shutdown period. The team observed that the
Plant Review Committee (PRC) did not include department level
managers. This weakness has since been corrected by inclusion
of several department managers on the PRC. During an extendea
inspection of the Augmented System Review and Test Program
(ASRTP) between December 1986 and February 1987, it appeared
that QA and the Management Safety Review Committee (MSRC) did
not actively review closeout of audit findings. Additionally
QA audit and surveillance programs were not providing plant
management with adequate feedback of safety activities.
Subsequent inspections by the inspection team confirmed that
these problems had been corrected.
Staffing, training, and qualifications of the licensee's
Nuclear Quality Department and Licensing Department appeared to
be adequate during the SALP period.
Toward the end of the SALP period, Region V inspections
observed that the licensee was not completing post-restart
commitments as scheduled. Management meetings between the
licensee and NRC Region V, on November 14, 1988, and December
12, 1988, were held to review SKUD's commitments for work to be
accomplished post restart, including the various aspects of the
EAP that remain to be completed. During the meetings, the
licensee agreed that numerous near and long term items still
remained to be completed, but reaffirmed its original
commitment to promptly resolve the near term items.
2. Conclusion
~
Performance Assessment - Category 2
3. Board Recommendations
The licensee should ensure the full use of the established
system to identify and resolve nonconformances. The licensee
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, 24 I
, _ ,
is encouraged to complete action on the near term commitments
as previously agreed upon.
I
H. Startup Testing l
Analysis
l
During the SALP period, significant inspection of startup testing ]
was performed. Strengths were observed in the integrated system '
functional testing approach and in the development of a system
status report which documented known past problems with specific 1
plant systems. A significant strength observed was an initiative by )
the licensee to develop and implement an inspection technique which
was patterned after the NRC's Augmented System Review and Test j
Program (ASRTP) inspections that identified plant system performance )
or documentation problems. A weakness identified during the early )
portion of the SALP period r,'ss the initial planning and completeness l
of the test program.
The hTC inspected licensee startup testing activities during hot
functional testing and power ascension, with particular attention to
the adequacy of special test procedures and clearance boundaries,
where used. Evaluations were made of the adequacy and depth of the
testing to determine whether the specific system under test was
performing according to the design bases of that system. A specific
strength was noted in the licensee's responsiveness to NRC
identified problems in the Auxiliary Feedwater system and the onsite
electrical distribution system during the ASRTP inspection.
Lfcensee management actively participated in the generation of the
test program purpose and scope. An extensive program was undertaken
to identify and document known past problems with the thirty-three
selected systems which were determined by the licensee to be
important to safety. This high integrity system was used as an
input source to the test program development.
Specific system functions and test requirements were soundly and
thoroughly documented within a system status report (SSR) document.
Technical and management reviews were conducted by the Plant Review
Committee and were effective in identifying potentini underlying
test problems. 10 CFR 50.59 reviews were conducted prior to the
conduct of each test with edequate documentation of the test's
technical rationale. The program was .onducted slowly,
methodically, with high mansgement attention to ensuring preparation
for each testing evolution.
A weakness was observed in the identification and documentation of
conditione which were potentially detrimental to quality.
Spet.f fically, during a portion of the loss ot offsite power testing,
I
a deficiency was identified with an emergency diesel generator. The
deficiency was not reported on the licensee's nonconformance
reporting system. Significant management attention was subsequently
devoted to the identified problem with both the specific hardware
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i
deficiency being resolved and the programmatic problem being
resolved.
No enforcement action was issued during the SALP period in this
functional area. Two LER's were submitted documenting e start of
the emergency diesel generator (emergency safety features -
equipment start) and a reactor trip following a preplanned turbine
generator trip. The licensee's corrective action for these LERs was
appropriate. j
During the period of significant testing, staffing was adequate and
commensurate with testing in process. Expertise ef the testing
staff was adequate for both the management of the program and
conduct of testing.
Conclusion
Performance Assessment - Category 1
Board Recommendations
The licensee's effort in this functional c.taa has been completed
except for some minor testing at the 100% power plateau. Lessons
learned from this program should be evaluated for application to
routine post maintenance testing in light of the auxiliary feedwater
overpressurization event.
V. SUPPORTING DATA AND SUMMARIES
A. Enforcement Activity
Three resident inspectors were assigned to Rancho Seco during the
SALP assessment period. 100 inspections were conducted during this
lengthy SALP period that encompassed the extended shutdown of Rancho
Seco. Significant team inspections included:
*
Two NRC headquarters Augmented Systems Review and Test Program
Inspection Teams during 1986 and 1987
*
NRC headquarters Operational Readiness Inspection Team in 1988
*
NRC headquarters Procurement Inspection Team in 1988
*
Regional Enhanced Operational Inspection Team in 1988
A total of 15,427 hours of direct inspection were performed during
this SALP period. A summary of inspection activities- is provided
in Table 1 along with a summary of enforcement items from these
inspections. A description of the enforcement items is provided in
Table 2.
B. Confirmatory Action Letters
;
_ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
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. . 26
One Confirmatory Action Letter (CAL) was issued during this
assessment period. The letter confirmed licensee corrective action
activities for the December 12, 1988 main feedwater pump trip event.
Shortly after the appraisal period ended, a CAL was also issued
concerning the licensee's planned actions following the
January 31, 1989 auxiliary feedwater system overpressurization
event.
C. AE00 Events Analysis
The Office for Analysis and Evaluation of Operational Data (AE0D)
reviewed the licensee's events at Rancho Seco and prepared a report
which is included as Attachment 1. AEOD reviewed the LERs and
significant operating events for quality of reporting and
effectiveness of identified corrective actions.
D. Detailed Description of Licensee Activities
*
Before the December 26, 1985 transient, a number of criteria
(performance level monitoring, plant performance statistics,
and systematic assessments of licensee performance had
indicated that Rancho Seco was below the industry norm for
similar plants. This, plus a 1984 evaluation by a consultant,
moved the licensee's Board of Directors to take action to
improve the performance level at Rancho Seco. Before these
actions were implemented, a number of undesirable operating
experiences, culminating in the event of December 26th, further
demonstrated the need for performance improvement. On the
basis of the review of the December 26th event by the NRC and
the utility, the licensee developed the " Rancho Seco Action
Plan for Performance Improvement."
The initial portions of that plan were implemented as the Plant
Performance and Management Improvement Program (PPMIP). The
PPMIP was designed to systematically evaluate the plant, its
systems and their operation, and the management programs and
organization necessary to support the safe and reliable
operation of Rancho Seco. The specific goals of the PP&MIP
were to: (1) reduce the number of reactor trips, (2) reduce
challenges to safety systems, (3) ensure that the plant remains
within allowed ranges of reactor coolant system pressures and
temperatures immediately following a reactor trip, (4) ensure
compliance with license requirements, (5) minimize the need for
operator actions outside the control room, and (6) improve the
reliability and availability of the plant. On the basis of
anticipated benefits from the PP&MIP, the licensee established
near-term performance goals for returning Rancho Seco to power
operations. Those goals included plant availability exceeding
60%, a forced outage rate of less than 10%, and fewer than
three reactor trips per year. l
l
During the extended shutdown period, the licensee developed a j
system review and test program (SRTP) the objective of which -
was to demonstrate, before plant restart, that systems
!
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9. ,
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27 4
. .
important to safety were capable of performing their required
function. The SRTP was performed by the licensee to provide a
comprehensive review and functional demonstration of 33
selected systems thac were important to safe plant operation..
The licensee's SRTP identified the functional decription for
the 33 systems, design changes or modifications required for
the systems, testing necessary to demonstrate functions
important to safe plant operations, and final acceptance of the
systems.
*
On November 21, 1986, while attempting to fill, vent and
pressurize the primary system, approximately 11 of 35
pressurizer heater bundles were damaged when the heaters were
energized without sufficient water covering them. Operators
disregarded correct pressurizer level indications due to
incorrect status information for properly functioning level
channels. The operators relied on the remaining level channel,
which had a drained reference leg caused by loosely controlled
troubleshooting of the level channels (operators being unaware
of that condition).
*
On March 15', 1988 and on March 21, 1988, while the plant was in
hot standby, letdown system relief valves PSV-22031 (March 15,
1988) and PSV-22024 (March 22, 1988) lifted and resulted in a
discharge of water from the letdown system to the Reactor
Building sump. The cause of both events was a steam / water
transient involving isolation of letdown system piping and heat
exchangers, flashing of water to steam in the low pressure
area, and rapid expansion of the steam.
*
On August 6, 1988, as part of a planned Emergency Feedwater
Initiation and Control System (EFIC) test, the reactor was
manually tripped from 80 percent power and EFIC was manually
initiated. Both auxiliary feedwater (AW) pumps started as
designed. Approximately one hour siter both A W pumps started,
smoke was observed in the vicinity of the outboard packing !
gland of AW pump P318. P318 was immediately secured and the
EFIC test was completed using the other AW pump, P319.
Subsequent licensee investigation determined that an identical
AW pump packing overheating event had previously occurred on
July 7, 1988. The event was attributed to the installation of
incorrectly sized vendor supplied packing.
*
On December 12, 1988, while conducting a plant startup, with
the reactor at 12 percent power, and one of two Main Feedwater
( W) pumps inoperable, feedwater flow to the Once Theough Steam
l_
Generators (OTSG) was reduced significantly by fluctuations of
the steam pressure to the operating W pump n.rbine. The
reduced W flow resulted in low OTSG 1evels reaching the EFIC
system actuation setpoint and initiation of EFIC. Proper OTSG
1evels were reestablished by EFIC. The operators subsequently
manually tripped the reactor with the belief that main
feedwater was no longer available. The initial response of the
plant to the reactor trip was normal. However, the licensee
- _ _ _ _ _ - _ - _ _ - _
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soon became concerned that the reactor coolant system was j
cooling down more than expected, due to continued steaming from
the."B" OTSG, and, by procedure isolated AFW flow to the "B"
OTSG. This resulted in emptying the 'B' OTSG for'approximately
.
15 minutes. The licensee located an unexpected' steam demand-
from the-auxiliary steam supply to the fourth point FW heater,
isolated the auxiliary steam to the fourth point FW heater, and
refilled the "B" OTSG. Subsequent licensee analysis attributed-
the initiation of the event to operator actions while manually
controlling two different. auxiliary steam pressure reducing
stations for the steam. supply to the low pressure FW pump
turbines.
*
On January 31, 1989, after the SALP period..while testing a
newly installed governor for the. dual-driven auxiliary ,
feedwater pump, the steam turbine for the pump oversped. The i
auxiliary feedwater system pressure was estimated to have
. reached approximately 3800 psig for about three minutes. The
system design pressure is 1325 psig. The NRC and licensee
investigation of this event revealed weaknesses in post
maintenance testing, communications, maintenance program, use
of generic information, and procurement.
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TABLE 1
INSPECTION ACTIVITIES AND ENFORCEMENT SUMMARY (07/01/86 - 11/30/88)
RANCHO SECO
Inspections Conducted Enforcement Items
Functional Inspection * Percent Severity Level **
Area *** Hours of Effort I II III IV V D
A. Plant Operations 4029 26.1 - - -
3 - -
B. Radiological 664 4.3 - -
1 9 6 -
Controls
C. Maintenance / 2096 13.6 - - -
10 2 1
Surveillance
D. Emergency Prep. 590 3.8 - - -
3 - -
E. Security 407 2.7 - - -
5 -
1
F. Engineering / 1902 12.3 - - -
1 1 1
Technical Support
G. Safety Assessment / 5739 37.2 - - -
12 2 -
Quality Verif.
_ _ _ _ _ _
Totals 15427 100.0 1 43 11 3
* Allocations of inspection hours to each functional area are
approximations based upon NRC form 766 data.
** Severity levels are in accordance with NRC Enforcement Policy (10 CFR
Part 2, Appendix C).
*** Inspections hours for the special functional area of startup testing were
not distinguished in the NRC Form 766 data. Those hours were included in
the other functional areas and predominantly were included in the hours
for plant operations.
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Table 2
Rancho Seco
Enforcement Items
Report Severity Functional
Number Subject Level Area
86.27 FAILURE TO REPORT TS TABLE 3.16-1 4 B
RADIOACTIVE GASEOUS EFFLUENT VIOLATION.
86.27 FAILURE TO POST AND CONTROL HI RAD AREA - B 4 B
OTSG IDWER CHANNEL HEAD.
86.30 FAILURE TO ESTABLISH WRITTEN PROCEDURES FOR 4 F
RADIOGRAPHIC INSPECTIONS. !
86.30 FAILURE TO RETAIN RADIOGRAPHIC RECORDS OF 5 G :
DEGRADED DHR DRAIN LINES. i
86.35 INADEQUATE ILLUMINATION INSIDE PROTECTED 4 E
AREA.
86.37 PROCEDURES NOT PROVIDED FOR TESTING AND 4 B
CALIBRATING RAD MONITORS R15701 AND 15702.
86.37 CLEARLY VISIBLE LABELS FOR LICENSED 5 B
MATERIAL NOT PROVIDED IAW
10CFR2 0. 2 03 (F) (2 ) '.'
86.38 PROCEDURE FOR FUNCTIONAL TESTING OF 4 C
SNUBBERS DID NOT PROVIDE APPROPRIATE ,
ACCEPTANCE CRITERIA FOR LOCH-UP VELOCITY - ;
VELOCITY NOT CORRECTED FOR TEMPERATURE AS
RECOIDIENDED BY THE VENDOR.
87.01 FAILURE TO SPECIFY CONTENT OF EMERGENCY 4 D
PROCEDURES.
!
87.01 NO PROCEDURE FOR CRIMPING TOOL CALIBRATION 4 C l
AND CONTROL.
87.01 CR/TSC HVAC HI AIR FLOW RA'E T DURING 4 C
12-26-85 EVENT.
87.02 UNUSUAL EVENT NOT DECLARED FOR SECURITY 4 D
ALER1' AND ESCALATED SECURITY MEASURES.
87.03 INADEQUATE DRAWING - REDUNDANT WELD 5 F
IDENTIFICATION NUMBERS ON SAME DRAWING FOR I
DIFFERENT WELDS.
- _ _ _ _ _ _ _ _ __ _ _ _ _
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; 87.05 FAILURE TO PERFORM TS REQUIRED SR-89 AND 90 4 B
ANALYSIS.
87.05 INADEQUATE YELLOW SHIPPING LABELS FOR 4 B
RADIOACTIVE MATERIAL SHIPMENT.
87.06 STORAGE OF EXPIRED' SHELF LIFE ITEMS NOT 4 G
CONTROLLED.
87.06 FAILURE TO NOTIFY NRC OF ACTUATION OF 4 A
EMERGENCY DIESEL GENERATOR (EDG).-FAILURE
TO REPORT CR/TSC HVAC MALFUNCTION.
'
87.06"NO PROCEDURE FOR GREEN TAGGING PARTS IN 4 G
WAREHOUSE.
87.06 ABNORMAL TAG NOT WRITTEN FOR TEMPORARY 4 C
MODIFICATION ON "A" TRAIN NUCLEAR SERVICE
RAW WATER SYSTEM.
87.06 VOIDING OF NCR WITHOUT DETERMINING CAUSE OF 4 G
EMERGENCY DIESEL GENERATOR NONCONFORMING
CONDITION.
87.06 NCR NOT WRITTEN FOR NON-ISOIABLE PIPE 4 G
LEAKAGE.
87.06 FAILURE TO PROVIDE 10 CFR 50.73 REPORT FOR 4 A
MISCELLANEOUS CONDITIONS.
87.07 FAILURE TO PROVIDE TWO PHYSICAL BARRIERS 4 E
FOR PROTECTION OF VITAL EQUIPMENT. '
87.07 FAILURE TO PROVIDE PROPER STORAGE 4 E
PROTECTION FOR SAFEGUARDS INFORMATION.
' 87.11 SURVEILLANCE PROCEDURES NOT REVISED TO D C
REQUIRE DOCUMENTATION OF CALIBRATION DATA
IAW COMMITMENT ON PREVIOUS VIOLATION
RESPONSE.
87.13 CLEANLINESS PROCEDURE NOT FOLLOWED FOR A 5 C
CIASS 1 WORK REQUEST.
87.13 LIQUID PENETRANT INSPECTION OF SPENT FUEL 4 G
POOL LINER NOT CONTROLLED BY PROCEDURE WITH
APPROPRIATE ACCEPTANCE CRITERIA,
87.13 REPLACEMENT FILTER FOR CBAST ISSUED AND 5 C
'- INSTALLED WITHOUT SMUD ACCEPT TAG. ..
87.14 FAILURE TO WRITE NCR FOR BROKEN REACTOR 5 G
COOIANT PUMP CAPSCREW. l
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, 87.14 FAILURE TO COMPLY WITH COMMITTED CODES AND D F
STANDARDS, USE OF SILICONE SEALANTS IN
ESSENTIAL HVAC.
87.16 STROKE TIME NOT MEASURED FOR TESTING OF 4 C
TV-1,2,3,4. SIM-19,20,21,22 NOT FULL STROKE
TESTED EVERY COLD SHUTDOWN.
87.19 LICENSEE FAILED TO CORRECT DEFICIENCIES 4 D
IDENTIFIED DURING 1986 HEALTH
PHYSICS / MEDICAL DRILL.
87.20 HEAT TREATING OF VALVE YOKE WITHOUT 4 C
PROCEDURE.
87.20 FAILURE TO PROVIDE REQUIRED CABLE BEND 4 C
RADIUS AND CABLE TRAY EDGE BUMPERS.
87.21 FAILURE TO PERFORM CABLE ROUTING 4 G
INSPECTIONS DURING 1983-1985 TIME FRAME.
87.22 MISCELLANEOUS VIOLATIONS OF AIARA PROGRAM. 5 B
87.26 RADIOACTIVE MATERIAL INSIDE RV HEAD STAND 4 B
NOT SURVEYED.
87.26 DAILY SOURCE CHECKS NOT PERFORMED WHEN 4 B
R15020 WAS OPERABLE, RHUT CONTAINED KNOWN
ACTIVITY AND RELEASES MADE VIA THIS
PATHWAY,
87.26 RADIOACTIVE MATERIAL INSIDE RV HEAD STAND 4 B
NOT POSTED AS HIGH RAD AREA.
87.37 FAILURE TO FOLLOW MAINTENANCE WORK REQUEST 4 C
INSTRUCTIONS.
87.37 FAILURE TO WRITE AN NCR FOR CR/TSC 4 G
REFRIGERATION UNIT NONCONFORMING CONDITION
OF AS BUILT WIRING.
87.44 NCR CLOSURE BY QE PRIOR TO COMPLETION OF 4 G
l WORK. CORRECTIVE ACTION INCORPORATED INTO I
ECN WITHOUT PRIOR CLOSURE OF ECN.
88.04 FAILURE TO REVALIDATE SECURITY BADGES EVERY D E
31 DAYS.
88.04 FAILURE TO DENY SITE ACCESS TO UNAUTHORIZED 4 E
SITE PERSONNEL. -
88.06 EXPIRED SHELF LIFE ITEMS IN STOCK. REPEAT 4 G
VIOLATION.
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88.12 CR/TSC HVAC ACTUATION NOT REPORTED WITHIN 4 A
i FOUR HRS.
88.13 LICENSEE DID NOT MAINTAIN ON FILE RECORDS 5 B
l
FOR RADIOACTIVE MATERIAL SHIPMENT.
1
88.13 LICENSEE DID NOT OBTAIN WRITTEN 5 B
CERTIFICATION FOR EMERGENCY SHIPMENT OF
i RADIOACTIVE MATERIAL.
88.17 FAILURE TO SUBMIT REQUIRED ANNUAL EXPOSURE 5 B
REPORT.
88.20 FAILURE TO POST, MONITOR, CONTROL HOT 3 B
PARTICLE ZONE.
88.23 TEMPORARY MODIFICATION FOR AFW PUMP P318 4 C
OUTBOARD SEAL WAS NOT CONTROLLED AND !
DOCUMENTED IAW PROCEDURE.
88.24 INDIVIDUAL DID NOT WEAR TLD IAW RWP. 4 B
88.25 TWO PORTABLE DOSE RATE METERS EXCEEDED 5 B
CALIBRATION FREQUENCY.
80.29 ALARMS FOR CERTAIN VITAL AREA DOORS NOT 4 E
TES':lED.
88.31 Calibration interval for EFIC pressure 4 C
transmitters changed without proper
approvals required by procedure.
88.32 DHR RELIEF VALVES GAGGED WITHOUT ADEQUATE 4 G
10 CFR 50.59 REVIEW.
88.33 NUMEROUS HOUSEKEEPING VIOLATIONS - 4 G
UNSECURED LEAD SHIELDING, UNSECURED ROLLER
CARTS, LADDER TIED TO SAFETY RELATED
CONDUIT.
88.33 PDQ FOR FEEDWATER OXYGEN CONCENTRATION NOT 4 G
DELIVERED TO OPERATIONS TECHNICAL ADVISOR
WITHIN 4 HOURS AS REQUIRED BY PROCEDURE.
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TABLE 3
S F PSIS OF RANCHO SECO LICENSEE EVENT REPORTS (LERs)
SALY Cause Code *
Functional
Area A B C D E X Totals
A. Plant Operations 11 8 3 3 10 1 36
B. Radiological 11 4 - 4 1 2 22
Controis
C. Maintenance / 6 4 -
9 1 - 20
Surveillance
D. Emergency Prep. - - - - - - -
E. Security 2 -
1 - - -
3
F. Engineering /
Technical Support 5 4 -
2 - -
11
G. Safety Assessment /
-
Quality Verification - - - - - -
l
Totals 35 20 4 18 12 3 92
The above data are based upon LERs 86-11 through 88-19.
* Cause Code
A - Personnel Error
B - Design, Manufacturing or Installation Error
C - External Cause
D - Defective Procedures
E - Component Failure
X - Other
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Attachment 1
AEOD Input to SAlp Review for Rancho Seco
LER Review
During the assessment period, 84 Licensee Event Reports (LERs) were submitted
to the NRC. These reports, reviewed by AEOD, consisted of LERs 86-14 through
88-16.
Significant Events
Utilizing AEOD's screening process, the following 18 LERs were categorized as
safety significant: i
86-14 Decay heat removal (DUR) system train B rendered inoperable due to a
leaking weld on the pump casing drain line, while the train A
emergency diesel generator was out-of-service.
86-16 Loss of DHR capability for a period of 13 minutes during cold
shutdown as result of inadvertent closure of the DHR system suction
drop 11ne isolation valve. Electrical arcing from I6C technician
troubleshooting activities caused the valve closure.
86-25 Spent fuel pool liner leakage while containing 316 spent fuel
assemblies. Contaminated water seeped through the concrete walls of
the fuel storage building to an uncontrolled storm drain. About 275
gallons were released offsite, creating an estimated whole body
dose of 0.14 mrem.
87-02 Fire protec'cion deficiency involving potential loss of alternate
shutdown capability. A control room fire could cause an electrical
short in the protective circuitry of a diesel generator's output
breaker, causing the breaker to trip. A loss of offsite power is
assumed to occur at the same f.ime as the control room fire.
87-06 Problems with safety related motor-operated valves identifed in
response to IE Bulletin No. 85-03, problems included over thrust
conditions, incorrect brate voltage ratings, undersized power
cables, lack of stem nut staking, valve internals damage,
unqualified operator grease, and incorrect pickup / dropout voltages.
87-08 Inadequate automatic sequencing of the high pressure injection pumps
onto the emergency diesel generator bus, due to the pump lube oil l
pressure bypass circuits defeating a three second time delay.
87-10 Fire protection inadequacy whereby the reactor coola t system high
point vent valves were susceptible to opening from electrical
shorts.
87-11 Safety related snubbers failed functional testing after temperature
considerations were factored into lock-up velocity and bleed rated
acceptance criteria,
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87-15 Fire protection carbon dioxide deluge system left deactivated
without appropriate compensatory measures.
87-23 Inadequate electrical isolation on the reactor protection system
total nuclear power channels. Channel isolation devices required by
IEEE-279 and General Design Criterion 20 were not provided.
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87-29 Inadequate surveillance testing of unsupervised control room fire
alarm annunication circuits. Required monthly testing was not
performed since 1976.
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87-34 High pressure injection (HP1) pump mini-flow recirculation lines !
vere not seismically supported since original plant construction due
to improper classification. Failure of the lines coincident with a
LOCA would render HPI capability indeterminate.
87-36 Blockage of bearing cooling water system piping to both reactor ,
building spray pumps due to fouling. )
874-41 Non-seismic level switches installed on nuclear service water pumps,
which could prevent the pumps from starting on a safety features
actuation signal (SFAS).
87-42 Failure of electrical connectors due to residual coating from
cleaning solutions. Systems affected included the reactor
protection system, integrated control system, SEAS, and non-nuclear
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instrumentation.
87-44 Loss of nuclear services electric building essential heating.
ventilation and air conditioning system, due to inadequately
designed isolation dampers between Seismic I and Seismic II ducts.
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88-02 10 CFR 21 report regarding a manufacturing defect in undervoltage
devices, causing improper operation of the control rod drive trip
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88-11 Auxiliary feedwater pump inoperability due to incorrectly sized d
vendor supplied packing in packing gland.
Other Events )
AEOD's review also identified the following events, while not necessarily
being individually categorized as safety significant, collectively represent
adverse trends in plant performance worthy of additional plant management
attention.
Inadequate fire protection compensatory measures: -- l
LER 86-18 Disabled smoke detectors in the reactor building with-
out compensatory measures (fire watch) due to licensed
operator error.
LER 86+31 Hourly instead of continuous fire watch in 480 volt
switchgear room due to licensed operator error.
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LER 86-32 Missed fire watch in the east nuclear services battery
room due to nonlicensed personnel error. Additionally,
LER 86-18 regarding missed compensatory measures, was not
referenced in this LER.
LER 87-01 Hourly rather than continuous fire watches on 1/17
and 1/27/87, due to licensed operator error. No reference
to LER 86-18 included.
LER 87-03 Continuous fire watches not posted on 12/27/86,
12/29/86, 12/30/86, 1/2/87, 1/3/87, 1/5/87, and 1/20/87.
LER 87-04 Abandoned continuous fire watch post in nuclear
services electrical building (NSEB) due to nonlicensed
personnel error. No reference to the above 1987 similar
LERs was provided.
LER 87-15 Carbon dioxide fire protection systems were
deactivated without establishing fire watches on 17
occasions in 1/87 and 2/87 due to nonlicensed personnel
error.
LER 87-19 Continuous fire watch posting not performed in the
NS'EB due to licensed operator error.
LER 87-33 11 missed hourly fire watches in 77 inspection zones
due to administrative problems. Previous LERs on this
subject.not referen:cd except for 87-04.
LER 87-35 Continuous fire watch ar fire alarm panel abandoned
due to nonlicensed operator error.
LER 88-09 Missed hourly fire watches on NSEB fire barrier
penetrations on 7/21/87 and 7/25/87 due to licensed
operator error.
LER 88-10 Missed fire watches on 7/14, 7/19, 7/25, 7/27, 7/28,
and 8/10/88 due to nonlicensed personnel error.
Effluent monitoring deficiencies:
LER 86-19 Missed auxiliary building noble gas grab sample due
to nonlicensed personnel error.
LER 86-22 Missed continuous sampling of the auxiliary building
gas due to procedural inadequacies.
LER 86~27 Lost data from reactor building duct particulate air
sample filter due to nonlicensed personnel error.
LER 86-29 Sample valves open on auxiliary building stack
exhaust sample line, rendering previous samples
inaccurate.
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LER 86-33 Failure of a continuous noble gas monitor on the
reactor building exhaust duct on two occasions, due to
loss of electrical Tower when non-safety related loads
were applied to a safety related power supply.
LER 87-40 Required surveillance (daily source check) not
performed from 8/84 to 8/87 on regenerant hold-up tank
discharge monitor during periods of known tank activity
due to procedural error..
LER 87-43 Unmonitored releases from the auxiliary building
during effluent monitor and ventilation system testing due
to nonlicensed personnel error.
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LER 87-47 Missed continuous sampling of reactor butiding purge
effluent on two occasions due to licensed operator error.
LER 88-01 Reactor building effluent particulate filter lest j
prior to gross alpha activity analysis due to unknown 3
Causes.
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Causes
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Root causes associated with the 84 LERs, categorized on a yearly basis, were:
1986 1987 1988 TOTAL
Licensed operator errors 3 7 3 13 ,
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Other personnel errors 5 10 3 18
Maintenance errors 0 4 0 4 i
Design / installation / fabrication 6 13 2 21
Administrative control problems 5 12 2 19
Random equipment failures 1 1 2 4
Licensee Unidentified 0 1 4 5
Of the 19 administrative control problems identified, 14 were associated with
inadequate procedures, and 3 were related to programmatic deficiencies.
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The licensee did not identify root causeo on five LERs. Additionally, the
l supplemental report specified in LER 88-06 (event date 4/14/88) has not yet
been received.
LER Quality
LER quality has improved since the end of 1986, when the ctility adopted a new
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LER format. LERs submitted adequately described the major aspects of each
event, including identifying component or system failures that-contributed to
the event. The reports were well written, easy to understand, and typically
complete except for those with unidentified root causes. Corrective actions
f taken or planned to prevent recurrence were generally specified. However, in
writing the LER text, the use of the word " operator" should be clarified to
indicate nonlicensed or Ideensed operator, as requird by 10 CFR
50.73(b)(2)(ii) (J)(2)(iv).
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Preliminary Notifications
AEOD's review of preliminary notifications issued by Region V concluded that
no additional LERs were required of the licensee.
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SACRAMENTO * ilNICIPAL UTILITY DISTRICT D 6201 S Street, P.o Box 15830, Sacramento CA 958524830.(916)452 3211
AN ELECTRIC SYSTEM SERVING THE h(EART,OF CAllFORNIA
CEO 89-236
NAY 11 1989
U. S. Nuclear Regulatory Commission
Attn: -J. B. Martin, Regional Administrator
Region V
.1450 Maria Lane, Suite 210
Halnut Creek, CA 94S96
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Docket No. 50-312
Rancho Seco Nuclear Generating Station
License No. DPR-54
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT RESPONSE
Dear Mr. Martin:
The District has thoroughly reviewed the Commission's SALP Report evaluating
Rancho Seco's performance during the period July 1, 1986 through December 31, 1
1988. Overall, the District considers the SALP Board's assessment to be fair,
accurate, and technically correct. He appreciate the SALP B3ard's insight in
identifying areas for further improvement and recommending appropriate
actions. The attached response provides the actions taken or planned to
continue improved performance.
The District is committed to continuing the established safety culture at
Rancho Seco. The success of this effort by the Rancho Seco team is evidenced
. by the performance improvement trend recognized by the SALP Board. Our goal
is to reach the upper performance quartile for U.S. nuclear plants by 1993.
Continued constructive interaction with the Commission will assist us in
meeting this goal.
Members of your staff with questions requiring additional information or
: clarification may contact Mr. Steve Crunk at (209) 333-2935, extension 4913.
Sincerely,
seph F. Firlit
Chief Executive Officer
Nuclear ,, f geg_j
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Attachment O.[F
cc w/atch: A. D'Angelo. NRC, Rancho Seco
Document Control Desk, Washington DC .m
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RANCHO SECO RESPONSE TO 1989 SALP REPORT
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A. Plant Operations
SALPBbardRecommendations
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The Board recommends that the licensee continue to emphasize improving
communication and decisionmaking among mid and upper level plant managers.
Action should also be taken to enhance specific plant knowledge among the
plant management staff'to improve assessment and recognition of unusual or
abnormal plant conditions. j
Assessment
The District concurs with the analysis and recommendations. Significant
improvement in plant operations was noted in the areas of communication / j
decisionmaking and plant-specific knowledge among plant management staff.
The District will continue its actions to assure improvement, emphasizing
communication and decisionmaking (as highlighted by our response to the i
December 12 event), commitment tracking, and plant-specific knowledge level of
plant management staff.
Accomolishmenti
Following the December 12, 1988 event, a Management Systems Action Plan was
developed to improve leadership, decisionmaking and communications, with
emphasis on middle and upper management.
The plan was developed based on several independent reviews of the area of
concern. Significant accomplishments include:
* A formal, senior management monthly review is conducted cr. key
performance indicators. Degrading trends are identified and
corrective actions are established.
* Assistant positions have been established and filled for the CEO,
Nuclear, AGM, Nuclear Plant Manager, and AGM, Nuclear Technical
Services. This allows senior management more time for communicating
with staff and being involved in plant operational decisionmaking.
* The CEO, Nuclear has met with shift operating crews.
* Management involvement has been increased in the review / approval
process for significant evolutions by changing the focus of the Daily
Plant Status Meeting attended by senior and middle management.
Additionally, the AGM, Nuclear Plant Manager has reviewed the Lessons
Learned regarding communication and decisionmaking with Operations
management. Operations has lowered the threshold for informing
senior management of off-normal conditions.
* A training program for decisionmaking has been developed and training
classes are beiag scheduled.
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A. Plant Operations '(Continued)
Accomplishments (Continued).
To enhance the plant-specific knowledge of plant management' staff, the
District implemented an SRO-level training program for managers and staff in
July 1988. The first class' completed the six month long, full-time, classroom
phase in February 1989; the simulator phase is scheduled for August 1989.
Participants included the Assistant Plant Manager, the Plant Per
Manager,theMeterialsManager,andtheSupervisorofQualityEng$rmance ineering.
Commitment tracking improvements are continuing. An integrated tracking list
is produced weekly and a weekly status is provided to senior management. The
CEO, Nuclear has issued a directive holding management accountable for meeting-
commitments. As a result, the number of overdue commitments has been reduced
significantly.
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A Plant Status Control Action Plan and schedule is being implemented,
integrating Limiting Conditions for Operation tracking, turnover logs, routine
logs, and panel walkdowns. The plan also includes features to minimize errors
in status tracking.
Plans for Further_ Improvement
Plant operations will continue to improve as the Management Systems Action
Plan, Plant Status Control Action Plan, Post-Maintenance Testing Action Plan,
and management SRO-level training programs are continued. Additiona?ly, the
new assistant positions discussed previously are providing senior management
opportunity to become more involved in operational decisionmaking and assuring
proper communication between middle and upper management.
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B. Radiological Controls
SALP_EQArd Recommendations
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The licensee needs to continue their efforts in the staffing of Chemistry and
l EM&EP with permanent employees, in the identification and correction of i
deficiencies in the radioactive effluent programs, and in the control of
I liquid waste.
Assessment -
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The District concurs with the performance assessment on radiological
controls. Significant improvement continues in correcting organizational
weaknesses and the radioactive effluent program.
The District's continued actions are highlighted by the recent hiring of a
Chemistry Department Manager and filling three Superintendent positions, '
previously staffed with contractors, with qualified permanent SMUD personnel.
In addition, numerous effluent modifications were completed that will mitigate
the consequences of an uncontrolled spill, decrease the volume of wastewater,
and reduce the amount of radioactivity released.
Accomplishments
Chemistry has developed procedures, instituted programs and hired capable
personnel to manage and implement the radioactive effluent program. In
addition, a Radiological Effluent Information Management System (REIMS) is
being implemented which automatically composes results and discharge permits,
generates Semiannual Reports / Effluent Reports, and stores source term and dose
information.
Some of the majc,r restart enhancements were:
e construction of a new makeup demineralized sump,
e construction of the C Regenerant Hold-Up Tank (PHUT) for segregation
of non-radioactive wastewater;
e addition of a demineralized skid to provide effluent processing at
the RHUTs, and
* installation of an effluent strainer.
The Projects Department is coordinating tasks which:
* lessen the risk of unplanned offsite releases.
* reduce both the volume of wastewater and the activity in wastewater,
and
* provide wastewater management under Steam Generator Tube Rupture
(SGTR) conditions.
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To lessen the risk of unplanned site releases, a splash guard was built around
the RHUT demineralized. Additionally, the Retention Basins now have a berm
surrounding them to reduce the migration of dirt. The moisture separator
reheater and turbine deck drains can be rerouted to a controlled sump. Some
of the near term tasks include installing an RHUT liner telltale drain and a
radwaste solidification structure.
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B. ' Radiological Controls (Continued)
Accomplishments (Continued)
'To reduce the volume of wastewater, many sample flows, discharges and seal- .
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leakoffs are being routed to the condenser. To reduce the activity of
wastewater, filters and a demineralized have been added to the polisher sluice
water discharge. Near term tasks include rerouting the auxiliary feedwater
(AFH) mini-flow and test lines.to the condensate storage tank.
To provide wastewater management under SGTR conditions, a "MO-FLOH"
demineralized is on site. This demineralized can process 600 gpm whereas the
current demineralized'can process 100 gpm. A Hastewater Treatment Facility
will be a long term solution for water management under SGTR conditions.
Plans for Further Improvement
Technical Specification Amendments and procedure changes needed to resolve
longstanding problems regarding analysis sensitivity will soon be in place
(LLD values).
During the next several months, many of the tasks in progress should be
complete. The two long term tasks, the Tank Farm uporade and the Hastewater
Treatment Facility, are projected for completion by 1991.
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C. Maintenance / Surveillance
SALP Board Recommendations
Plant management should focus special attention on identification and
documentation of discrepant material conditions and improvement in post
maintenar.ce testing. Licensee management should continue to emphasize the
development of work procedures for specific plant equipment, and to improve
personnel performance and proctJure adherence, including the che stry area.
Assessment
A review of the analysis and recommendations reveals strengths in the
Preventive Maintenance Program enhancements, Maintenance Procedures for
specific plant equipment, quality control of safety related materials,
responsiveness to NRC concerns, and actions to reduce Work Request backlogs.
Specific weaknesses include the failure to identify and document material
deficiencies, failure to appropriately control Post-Maintenance Testing, one
instance of inadequate training of personnel to industry standards, and
failure to follow procedures or to have an adequate procedure for the work
activity in process.
Maintenance Management acknowledges these as valid observations and will
continue the Maintenance Improvement Program with special emphasis on the
areas identified.
Accomolishmenti
The District addressed the NRC's concerns about documentation of discrepant
material conditions and personnel performance by implementing meetings with
all levels of plant personnel. These " Cascade Meetings" are part of the
mana;ement communications program designed to reinforce management's policies
of quality performance, pride of workmanship, verbatum procedure compliance,
and root cause evaluation of failures. Meetings have been conducted at all
levels of the organization including follow-up meetings to assure the flow of
information has permeated each level of plant personnel.
Maintenance Verification Testing requirements are specified on Hork Requests
and guidance for those requirements are delineated in the Maintenance
Administrative Manual.
A Hanagement Event Review Board has been convened including the AGMs,
Nanagers, and the CEO, as appropriate, to investigate instances of
noncompliance to plant standards of professionalism and assure root causes are
thoroughly identified and addressed.
Responsibility for preparation and upgrades of Maintenance Procedures has been
transferred to the Maintenance Engineering organization to ensure technical
adequacy of those procedures issued for use.
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C. Maintenance / Surveillance (Continued)
Accomplishments (Continued)
The District improved post-maintenance testing by revising Maintenance
Administrative Procedure MAP-0006, "Hork Request Planning." The procedure now
requires all Work Requests to address Maintenance Verification Testing
requirements and provides guidance for establishing those requirements.
System Engineers are required to review post-maintenance testing rior to
release _of the work package.
Plans for Further Improvement
The Maintenance Engineering organization is being re-structured to provide a
staff of qualified Maintenance Engineers with plant-specific experience at
Rancho Seco. The District is emphasizing the development of work procedures
by transferring the responsibility for maintenance procedure preparation to
the Maintenance organization. A program is in place to write new procedures
and upgrade existing procedures prior to field use. This will help assure the
technical adequacy of the procedures issued to the field.
The Maintenance Improvement Program provides for up to one week of training of
all maintenance' craftsmen each five to six week period. !
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'The management involvement meetings will continue to be conducted on a routine
basis to reiterate management's policies of profe.<!!cnalism and excellence.
The Preventative Maintenance (PM) Group has been chartered to reduce the PM
Hork Request backlog and has been provided with Planning personnel dedicated
to that purpose. Outage support staffing will be provided to assure readiness
of the PM Progrtm to support Cycle 8 refueling outage.
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D. Emergency Preparedness
SALP Board Recommendations
Contitried management oversite to insure emergency preparedness continues to
improve and-that identified problems are corrected in a thorough and timely
manner.
Accomplishments
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During the past six months, the District has filled the open Emergency
Preparedness-(EP) positions to approved levels. Dependency on contractor
support has been substantially reduced. The increased stability of the EP
staff has resulted in improved relations and cooperation with the Rancho Seco
Planning Team, including state and county agencies.
Since 1986, the EP Section has completely reevaluated and rewritten the
Emergency Plan and Implementing Procedures.
The Emergency Response Facilities have been upgraded in response to audits and
drill comments over the past three years. In recent drills, the number of
facilities-related comments has decreased and most of the ccmments concern
minor, easily repaired problems. The inventory of emergency equipment has
been incorporated into procedures and the frequency of inspections has been
increased.
The EP Section has completed three successful Annual Exercises since the
initiation of the restart effort. The last two exercises were completed
without any significant findings. Each year the Section has increased the
amount of realism in the scenarios to enhance the drills. EP has implemented
a multi-discipline Scenario Review Group that is responsible for approval of
all major drills and also assists in the development of technical data.
The EP Section now maintains a full-time Emergency Preparedness Planner
working in public education in addition to assistance provided by the
District's Public Affairs Department.- The addition of this position has
enabled the District to expand its public education efforts beyond the 10-mile
Emergency Planning Zone.
Plans for Further Improvement
During 1989, the Department will begin developing an Emergency Preparedness
Program Maintenance Manual. This document will provide a guideline for j
performing all routine tasks in Emergency Procedures.
The Drills and Exercises Coordinator is directing the development of standards
for scenario development, which includes specific software applications for
data preparation hnd style sheets for date presentation. Also, the Drills and
Exercise Group is developing a scenario library to reduce time and cost for
scenario development.
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D. Emergency Preparedness (Continued) ;
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Plans for Further Improvement (Continued)
Emergency Preparedness is evaluating methods to expedite emergency callouts.
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The District is investigating an emergency callout system that utilizes both !
an autodialer and pagers. {
The District will begin revising, as necessary, Emergency Preparaginess
training modules in 1989 to include better graphics and student Mndouts.
The District is evaluating Emergency Response Facilities for possible
modifications. A list of proposed modifications has been prepared and is
being evaluated and ranked by priority.
The Emergency Response Organization is being reviewed for consolidation of
functions and reassignment of personnel to more appropriate posittbns.
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E. Security
SALP Board Recommendations
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Licensee management is encouraged. to continue their support to the overall
security- program, and to finalize ongoing improvements identified in the
Security Performance Improvement Plan, and the responses to the RER report.
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Assessment
Management support for the program is present, as evidenced in the
' Accomplishments' section. Nevertheless, there are security projects, notably
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modifications, which require continuing management support.
Accomplishments
The District has completed 75 of 79 NRC-recommended improvements. Of the 19
Regulatory Effectiveness Review (RER) commitments, only 4 remain.
The District completed Armed Response Force selection and training and
improved the weapons mix. i
The District installed a Badge Detector. (The badge removal problem has been
reduced by 75%.)
Improved microwave detection along the entire perimeter was installed. Vital
area barriers.throughout the plant have been strengthened.
-The District installed a new radio system which is presently operational.
Workplace Improvement Network committees have been established and are working
well.
The District established a compliance auditing program and initiated a QA
interface under the auspices of the AGM, Nuclear Quality & Industrial Safety. '
The District selected a new Nuclear Security contractor. Significant
improvements in contractor' performance are expected.
The Security Training Department and its training programs were upgraded. The
upgrades include supervisory training, lesson plans, and trainer certification.
Plans for Further Improvement
The District has planned and budgeted for site lighting upgrades in 1989 and
1990. An evaluation of vital area penetrations is being conducted and repairs
effected. The Tank Farm fence and alarm system upgrade are to be completed by
the end of 1989.
An evaluation of systems and equipment essential to safe plant shutdown is j
currently being performed to determine the adequacy of physical security
protection. The District continues to improve its security officer training.
A new Security System Upgrade Plan has been prepared by Projects Management, ,
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incorporating the remaining items from RER and NRC and any new items requiring
management attention.
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F. Engineering / Technical Support
SALP BoardJecommendations l
Management attention.is needed to maintain a permanent, stable site
engineering staff. Engineering efforts to complete the design basis records
project'should continue, and a review of the effectiveness of the current
design change process should be conducted once a representative sample is
available. Management attention is needed to enhance engineeringsoversight of ,
maintenance activities in light of the Auxiliary Feedwater (AFH) overpressure j
event.
Assessment
The District concurs with the NRC's recommendations.
eccomolishmenti
A permanent, SMUD Nuclear Engineering Manager was appointed in January. ,
Additionally,' each discipline engineering Manager and Supervisor is now a l
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permanent District employee. Goals for both the retention and hiring of
permanent District employees have been established as have goals for the j
systematic reduction of contractor dependence.
The District's commitment to the timely and satisfactory resolution of
Configuration Management / Control issues remains unchanged as defined in the l
Engineering Action Plan. Design bases reconstitution and completion of the j
System Design Basis documents (SDBDs) remain on schedule. Fourteen SDBDs will -
be issued on or before the end of Cycle 8 refueling outage. {
Revision 3 to Rancho Seco Administrative Procedure RSAP-0303, ?lant
Modifications," was issued as a result of a comprehensive review of the
effectiveness of the design change process. The most significant changes in
Revision 3 involve the general streamlining of the process and the inclusion
of " parts equivalency evaluations" within the scope of the RSAP. These
changes were precipitated by lessons learned from the AFH overpressurization
event.
Similarly, as a result of lessons learned from the AFH event, Plant '
Performance engineers are now required to participate in post-maintenance
testing activities.
Plans for Further Improvement
Aggressive hiring policies will :.ontinue to oe implemented and turnover rates
trended. The overall employment picture should imptove in June.
The District will continue to adhere to the scope and schedules f(r
configuration items defined in the Engineering Action Plan. Additionally, i
close monitoring of the design change process will continue with emphasis
placed on the trending of related Field Problem Rept,rts (FPRs) and Potential
Deviations from Quality (PDQs).
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Plans for further Improvement (Continued)
Further improvement and strengthening of the Engineering / Maintenance interface
is expected by the recent establishment of the on-shift support office and i
participation.in turreover meetings. Both Keciear Engineerir.g and Plant !
. Performance personnel tre represented at and participate in these activities,
providing input and feedback relative to design, operation, and
Maintenance provides a " Maintenance Shift Supervisor" forshift thesupport
onjpst issues.
office.
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G. Safety Assessment / Quality Verification
SALP Board Recommendations
The licensee should ensure the full use of the established system to identify
and resolve nonconformances. The licensee is encouraged to complete action on
the near term commitments as previously agreed upon.
Assessment 4
.e
Rancho Seco management is keenly aware of the issue of ensuring nonconforming
conditions are promptly and accurately reported via the PDQ program. The
intent is for all nonconforming conditions to Le reported to plant management
for prompt resolution. The fundamental problem is differentiating between a
nonconforming condition and a condition which may be corrected by a Work
RequGst.
The District agrees with the SALP finding of a persistent hesitancy to report
nonconforming conditions properly. However, the PDQ pror.ess is designed to
allow an individual to initiate one document to identify any problem, hardware
or nonhardware. The condition noted in the SALP finding is believed to have
improved during the latter part of the reporting period after the March 1988
implementation of the PDQ program.
In the past six months significant improvements have been made in tracking and
resolution of commitments. An attempt is being made to consolidate the
existing tracking systems. An integrated commitment tracking list has been
provided daily to all managers. Each week a status report on commitments has
been provided to senior management. The CEO, Nuclear has issued a directive
stating that commitments are to be completed by the due dates and holding
ma.N ement accountable to see that commitments are met. Meetings have been
held to implement the commitment closure philosophy. As a result of these
actions the number of overdue commitments has been reduced significantly and
an overall improving trend can be raported.
Accomplishments
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The implementation of the PDQ program was for the purpose of encouraging the
identification of nonconforming conditions. This was accomplished by allowing
personnel to initiate just one document whether the problem was hardware or
nonhardware. The District later modified the PDQ process to allow personnel
to initiate a PDQ on a problem regardless of QA classification.
i This information was given in formal training to site supervisory and
management personnel during October and November 1988. In particular,
specific PDQ training has been provided to Maintenance personnel to ensure
they understand the importance of properly identifying nonconforming
i conditions. During the period of September - December 1988, ?44 site
personnel received PDQ-specific training. The importance of and the proper
process for documenting deficiencies is also being emphasized in General
Employee Training sessions. Additionally, Hork Requests are being reviewed to
see if PDQs should be initiated.
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' G. Safety Assessment / Quality Verification (Continued)
Accomplishments' (Continued)
To further encourage the use of PDQs to report nonconforming conditions, the
. PDQ procedure was split.into two procedures, one covering only.the initiation
phase of PD0s. This allows personnel to review the procedure and become
familiar with PDQ initiation separate from the PDQ processing details. The
AGM, Nuclear Quality and Industrial Safety reinforced the importa,1ce of
documenting nonconforming conditions in discussions with plant milagement.
P1ans'for Further Improvement
Rancho Seco will continue PDQ-specific training for non-supervisory
personnel. Plant Management will continue to emphasize to plant personnel the.
importance of properly identifying nonconforming conditions. Quality
Assuranc6 will continuously monitor the program and refine the process as
necessary.
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H. Startup Testing
SAi.P Board Recommendations
The licensee's effort in this functional area has been completed except for
some minor testing at the 100% power plateau. Lessons learned from this
program should be evaluated for application to routine post maintenance
testing in light of the auxiliary feedwater overpressurization event.
Accomolishmenti J '
The group responsible for the System Review and Test Program (SRTP) which did
the startup testing at Rancho Seco transitioned into the Plant Performance
Department in late spring of 1988. The personnel core of the SRTP group
became the new System Engineers (SEs) of the Department, in order to maintain
continuity of the experience gained during the Restart program. Likewise, the
success of the testing program which included the ccmponent, functional, and
integrated testing of all modified equipment continues by the
proceduralization of the entire Special Test Procedure (STP) process. Current
procedures control test director qualifications, the procedure format, the
review cycles, and the emphasis of Operations personnel involvement.
The minor testing that is continuing after the plant reached the maximum power
level is receiving a similar amount of review as those tests during the
Restart effort. The minor testing includes ICS data gathering for tuning and .
high power performance confirmation. !
The District rcvised procedure MAP-0006, "Hork Recuest Planning" to
incorporate many of the Lessons Learned from the System Review and Test l
Program. To ensure that the Lessons Learned are not limited to o' iy STPs, the
SEs have been included in the development of Post-Maintenance Testing (PMT)
and Post-Maintenance Verification (PMV). Thus, any maintenance and post-
m;intenance testing, including that work considered routine, is reviewed by
the SE and may not proceed throagh work planning without his authorization.
Additionally, SEs have the responsibility of Dedicated Outage Coordinators
(DOCS) who control the scope of system work during the Quarterly System
Scheduled outages (OSSs). The return to service of the system and each of the
components is also under the guidance of the SE.
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