IR 05000206/1981005
| ML20004D249 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/09/1981 |
| From: | Chaffee A, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20004D244 | List: |
| References | |
| 50-206-81-05, 50-206-81-5, NUDOCS 8106090069 | |
| Download: ML20004D249 (5) | |
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U. S. tiUCLEAR REcCIATORY C0!cilSSIO:t OFFICE OF I!:SPECTIO!! AliD ENFORCE.C.r.!T
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REGION V
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Report No.
50-206/81-05
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Dicket No.
50-206 License tio.
DPR-13 safeguards Group Licensee:
Southern California Edison Company
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P. O. Box 800 - 2244 Walnut Grove Avenue Rosemead. California 91770
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Fccility Name: San Onofre Unit 1
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Inspection at: San Onofre, California Inspection conducted-February 2-5, 1981 d
3 [cypf Inspectors:
l A. Chaffde, Reactor Inspectue cate ' Signed
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Date Signed
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Date Signed
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A proved By:
P G.%.'ZQtzig,UAchingChief Ddte Signed
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Reactor Projects Section #2 3_
Inspection on February 2-5. 1981 (Report No. 50-206/81-05)
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Areas Inspected: Routine, unannounced inspection of licensed operator training and requalification programs; maintenance; and IE Bulletin followup. This inspection involved 24 inspector-hours on site by one NRC inspector.
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Results: Of the three areas inspected, no items of noncompliance were identified in two areas; one item of apparent noncompliance (failure to follow maintenance
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procedures - Paragraph 3) was identified in one area.
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RV Form 219 (2)
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l DETAILS
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Persons Contacted j
- J. Haynes, Manager, Nuclear Operations j
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- J. Curran, Plant Manager
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- D. Hunn, Manager. QA
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- J. Buckles, QA Engineer
- G. Mcdonald, QA/QC Supervisor
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- J. Reeder, Supervisor of Plant Operations, Unit 1 l
- J. Reilly, Engineer f
- B. Katz, Supervising Engineer i
- M. Wharton, Supervising Engineer
- H. Morgan, Superintendent, Unit 2/3 i
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- S. McMahan, Supervisor Flant Maintenance
- J. Dunn, Project Quality Assurance Supervisor
- W. Frick, Compliance Engineer
- J. Willis, Manager Training
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- R. Santosuosso, Supervisor, Nuclear Plant Inst.
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- R. Brunet, Superintendent Unit 1 I
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B. Jones, Maintenance Planner
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S. Scholl, Engineer
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- Denotes those persons who attended the exit interview. Also present
at the exit interview were the NRC Senior Resident Inspector, R. Pate t
and the Resident Inspector, L. Miller.
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2.
Inspection of TMI Task Action Plan Requirement I.A.2.1 i
A.
Licensed Operator Initial Training l
Based on discussions with licensee personnel and review of a portion of the N.U.S. draft document, " Training Administration Procedure
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11.1" the inspector determined the following
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The licensee training organization was familiar with the requirements i
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of the March 28, 1980 letter from H. Denton to all power reactor
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applicants and licensees.
2)
The licensee was in the process of reviewing the draft " Training I
Administration Procedure 11.1" submitted by N.U.S.
The licensee i
stated that this review will insure that requirements A.2.a.
A.2.b. and A.2.c of the March 28, 1980 Denton letter are included l
in this procedure.
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I 3)
The licensee stated that instructor qualification requirements
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A.2.c, and A.2.d of the March 28, 1980, Denton letter, will
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be included in an instructor qualification document being l
developed.
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The licensee has reviewed the licensed operator training program
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against the Denton letter to ensure compliance during the l
interim period, prior to implementation of the final program.
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The licensee has implemented a training program in accordance
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with the comittments contained in a July 23, 1980 letter
to the NRC.
B.
Licensed Operator P.equalification Program
l Based on a review of the Operator Requalification Program, Revision 2 for Unit 1 and discussions with licensee personnel it appears that
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I requirements C.1, C.2 and C.3 of the March 28, 1980 Denton letter have been implemented in accordance with the comittments contained i
in the licensee's letter to the NRC, dated July 23, 1980.
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I No items of noncompliance or deviations were identified.
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3.
Maintenance The following documents were reviewed on a sampling basis as a part of this inspection-i S-0-111. Rev. 3, " Equipment Testing Before and After Maintenance" S-M-103, Rev. 4, " Maintenance Order" S01-I-1.14, Rev. 4, " General Maintenance Procedure"
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S0123-A-109, " Station Documents Preparation, Revision and Review" l
PSSO (1) 430-A, Rev.1, Maintenance Order Form, and
PSSO (1) 430. Rev. O. Request for Equipment Repair l
The inspector also reviewed the documentation related to several specific
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maintenance tasks.
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l Based on review of the above documents and discussions with licensee l
personnel, the inspector made the following observations:
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Since the last annual inspection in this area the licensee has revised
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the form used to request maintenance from the Request for Equipment
Repair Forn (PSSO (1) 430 Rev. 0) to the Maintenance Order Form (PSSO I
(1) 430A Rev. 1). This revised form provides means for documenting
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the proper performance of maintenance and for helping to ensure all i
requirements of a maintenance item are completed in the proper sequence.
Procedure S-M-103, Rev. 4, " Maintenance Order" prescribes in detail i
how the Maintenance Order Form is to be completed and used. This Maintenance
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Order. procedure (S-M-103 Rev. 4), however, contains _ prerequisite condition i
regarding " Active Initiation of the Generation Management System (GMS)".
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-3-r The inspector believes that this prerequisite only relates to activation t
of the computerized collection and processing of maintenance costs and schedules, and does not relate to control of the quality and safety of maintenance activities.
Because this computerized system has not been
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activated for SONGS 1 at this time however, there appears to be a question among licensee personnel as to the implementation status of procedure
S-M-103 Rev. 4.
In addition, based on review of several maintenance
orders, it is apparent that the forms are not being used as prescribed
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by procedure S-N-103 Rev. 4.
This may be because, as stated above,
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licensee personnel may not be certain of the applicability of procedure S-M-103 Rev. 4.
This condition has resulted in an item of apparent noncompliance.
I Specifically, facility Technical Specification 6.8.1 requires conformance
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with sections 5.1 and 5.3 of ANSI N18.7-1976. Section 5.3 of ANSI 18.7-t 1976, in turn, requires that activities affecting safety at nuclear power
plants be described by written procedures of a type appropriate i
to the circumstances, and Section 5.3.5.(1) requires that maintenance i
procedures reflect ec.uipment control considerations. The Maintenance
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Order Form PSS0 (1) 430A, Rev.1, reflects the following equipment control considerations which are addressed in procedure S-N-103, Rev. 4, " Maintenance l
Order:" pre-maintenance inspection or test of redundant component or
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system, post-maintenance testing, clearances, approvals, open flame l
permits, and radiation exposure permits.
Procedure S-M-103 Rev. 4 Maintenance l
Order requires that various qualified personnel initial either the "yes" i
or "no" block adjacent to each of the above listed requirements to indicate l
its applicability to the particular maintenance work to be performed.
Contrary to the above requirements, on Maintenance Order Fonn S00910 (Inspection of #1 diesel generator turbo charger thrust bearings) two of the above items, namely:
test or inspection of redundant unit, and
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retesting (post-maintenance testing) were not initialed.
Thus, the
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l applicability of these requirements to this maintenance work was not
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defined.
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This is an item of apparent noncompliance.
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In the area of preventive maintenance, the licensee has an extensive
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upgrading project undemay in response to the finding of an NRC Performance
Appraisal Branch inspection which was conducted in February 1979. This i
upgrading is scheduled for completion in August 1981.
l Based on the review of the preventive maintenance program conducted during this inspection, no items of noncompliance or deviations were identified.
4.
Followup on IE Bulletin 80-11 (closed)
Based on visual inspection of masonry block walls TB-2, TB-4 TB-6, TB-7, TB-9, and TB-11, discussions with licensee personnel and review l
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of licensee responses to this bulletin (dated July 17 and Nc, enter 10, 1980), the inspector determined that drawings SK-C-001, Rev, B through SK-C-023, Rev. B appear to accurately represent the mesenry block walls
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in question.
Further, in the responses noted above the licensee has provided a portion of the information requested by the Bulletin. The balance of the requested information relates to seismic re-evaluation of the above walls.
In his response of July 17, 1980, the licensee states that the results of this re-evaluation will be included in his report of the overall seismic re evaluation of balance of plant structures, as described in his letter of April 28, 1980.
Based on this commitment, the requested information should be provided about April 1981. This schedule has been discussed with IE Headquarters and is acceptable.
This item is closed.
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Exit Interview i
The inspector met with the licensee representatives denoted in paragraph 1 on February 5,1981. The results o' che inspection were discussed and the licensee made a committment to provide a Procedure Change Notice i
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which would clarify the implementation status of Procedure S-M-103 Rev. 4 Maintenance Order.
(Note: This Procedure Change Notice was issued by the licensee on February 12,1981.)
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UNITED STATES
NUCLEAR REGULATORY COMMISSION o
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REGION V
1990 N. CALIFORNIA BOULEVARD og g
SulTE 202. WALNUT CREEK PLAZA g4 e,, *,e WALNUT CREEK. CALIFORNIA 94596 JUtl 1 1981
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Docket No. 50-206 P
Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770
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Attention: Dr. L. T. Papay, Vice President Advanced Engineering Gentlemen:
Thank you for your letter dated March 30, 1981, informing us of the steps you have taken to correct items which we brought to your attention in our letter dated March 9, 1981. Your corrective actions will be verified during a future inspection.
Your cooperation with us is appreciated.
y, hY i
.. trews, Chief
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eactor Operations Project Branch
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Southern California Edison Company
<,7; 2 RO.DOx800 2244 WALNUT GROVE AVENUE ROSE 8 DEAD, CALirORNIA 94770 L. T. PA P AY ftterpowc voce p.gs.og.g
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March 30,1981 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1990 North California Boulevard Suite 202, Walnut Creek Plaza Walnut Creek, California 94596 Attention: Mr. R. H. Engelken, Director DOCKET No. 50-206 SAN ON0FRE - UNIT 1
Dear Sir:
Your letter of March 9,1981, forwarded a Notice of Violation resulting from IE Inepection Report 50-206/81-05 which took place February 2
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through February 5,.981.
The enclosure to this letter provides our response to your Notice of Violation.
I trust the enclosure responds adequately to all aspects of the Notice of Violation.
If you have any questions or if we can provide additional information, please let me know.
Subscribed on the Jo day of March,1981 by W ek i
i.. T. Papay
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Vice President Southern California Edison Company Subscribed and sw rn to before me this Je day of March,1981.
T#"'E;mr% AGNES CRABTREE
S Ofl NOTW 5900C CAUFOW4 D$N#-
$NitiTES"n N tary ublic in and for the County
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Mr comass.on bp Auc.27.19tr2 u ocenoaoornaoocr:.
p-bp Enclosure
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L. F. Miller (NRC Site Inspector - San Onofre Unit)
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ENCLOSURE 1
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RESPONSE TO NOTICE OF VIOLATION ITEM A-
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Technical Specification 6.8.1 states:
" written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1976".
Section 5.3.5(1) of ANSI N18.7-1976, Preparation for Maintenance, states:
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" Maintenance procedures shall reflect considerations listed under 5.2.6."
(Equipment Control).
l The licensee's Maintenance Procedure and Form PSSO (1) 430A, Rev. 1 require recording of whether or not test of redundant components, and testing after maintenance are required in connection with the work to be performed.
Contrary to the above, on December 10, 1980 Maintenance Order No. 500910
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authorized inspection of the thrust bearing on the No. I diesel generator turbo chargers. The section of the order prescribing the need for redundant unit testing, and for post-maintenance testing of the No. I diesel generator, was not completed.
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RESPONSE:
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Corrective Steps Which Have Been Taken And The Results Achieved.
Equipment control at San Onofre is accomplished in accordance with-several operating procedures.
Equipment cannot be released for maintenance or returnad to service following maintenance until all
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necessary requirements have been met.
The naintenance order form now in use, PSSO (1) 430A, Rev. 1, was developed to improve the productivity of the maintenance department by providing additional information useful for pre-planning of work activities.
Information on redundant equipment testing and post-maintenance re-testing is provided so that this can be taken into account when scheduling maintenance personnel to perform the work.
The information on this form was not intended to provide the actual control of equipment.
In the incident in question, all required testing of redundant equipment and post maintenance testing was accomplished.
The operations supervisor did not complete the portion of the maintenance order form related to equipment control because the necessary information had previously been transmitted orally to the maintenance planner.
On March 10, 1981, Procedure Change Notice No. 2 was issued against Procedure 501-M-103 to better define the use of the maintenance order form for equipment control.
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. Corrective Steps Which Will Be Taken to Avoid Further Items Of
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Noncompliance.
In regards to equipr.ient control, San Onofre Unit I has remained in compliance with applicable technical specifications and regulatory requirements. Those portions of 501-M-103 which require'd completing the redundant equipment control sections of PSS0(1)-430A were deleted by PCN 2.
However, as a result of this incident, a consulting firm has been retained to review the maintenance order form and the procedures governing equipment control in order to develop a simpler and more unified system.
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The Date When Full Complianct.-Will Be Achieved Insofar as equipment control is concerned, San Onofre. Unit I has remained
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in full compliance. Procedure Change Notice No. 2 was issued against procedure 501-M-103 on March 10, 1981 in order to clarify the use of the i
redundant sections of the maintenance order form.
The review of the
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maintenance order and simplication of the system will be complete by August 1, 1981.
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