IR 05000206/1989011
| ML13316C031 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/10/1989 |
| From: | Mendonca M NRC/IE, NRC/RGN-V |
| To: | Baskin K Southern California Edison Co |
| References | |
| NUDOCS 8907140069 | |
| Download: ML13316C031 (14) | |
Text
JUL 1 0 1989 Docket Nos. 50-361, 50-362 Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, CA 91770 Attention:
Kenneth P. Baskin, Vice President Nuclear Engineering, Safety and Licensing Department Thank you for your letter of June 26, 1988, in response to our Notice of Violation and Inspection Report Nos. 50-206/89-11, 50-361/89-11 and 50-362/89-11, dated May 26, 1989, informing us of the steps you have taken to correct the items which we brought to your attention. Your corrective actions will be verified during a future inspectio Your cooperation with us is appreciate
Sincerely, M. M. Mendonca, Acting Chief Reactor Projects Branch bcc w/copy of letter dated 6/26/89:
docket file State of California A. Johnson G. Coo B. Faulkenberry J. Martin Resident Inspector Project Inspector J. Zollicoffer
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D12 023 DISPOSITION OF INCOMING MAIL sol COPY RETAINED FOR REGION V CENTRAL FILES COPY NOT RETAINED FOR REGION V CENTRAL FILES:
IF YO)ANT COPY OF DOCUMENT RETAINED IN REGION V CENTRAL FILES, PLEASE ASSURE THAT ORIGINAL OR COPY, AS APPROPRIATE, IS SENT TOTHEREGIONVFILEANDRECORDSCLERK ( )
RENCLOSURE NOT COPIED FOR REGION V CENTRAL FILES - TODVOLUMINOUS. RETURN ORIGINAL OR Attention:
COPY, AS APPROPRIATE, TO FILE AND RECORDS Washington CLER Gentlemen:
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REPLY REQUIRED:
AFFIX FORM NRC 3265, MAIL AND CONTROL FORM, AND FORWARD AS Subj ect:
rAPPROPRIAT C Submitted h REMARKS:
to the Topi Notice 28 r Change Noti Topical Rep submittal, NOTE: REGION V CENTRAL FILJ..ROOM IS NOT DC THIS DOCUMENT COMPLETED AND AFFIXED BY REGION V MAIL ROOM PERSONNE JKT:03028902 cc: R. Hi Units 1 0II
Southern California Edison Company P.O. BOX 800 2244 WALNUT GROVE AVENUIE ROSEMEAD. CALIFORNIA 91770 KENNETH P. BASKIN TELEPWONE VICE PRESIOENT aa8-302-1401 June 26, 1989 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3 Reference:
Letter, Mr. M. M. Mendonca (NRC) to Mr. Kenneth Baskin (SCE), dated May 26, 1989 The Reference forwarded NRC Inspection Report Nos. 50-206/89-11, 50-361/89-11, and 50-362/89-11 and a Notice of Violation resulting from the inspection conducted by Mr. C. W. Caldwell during the period March 13 -
17 and April 3 -
7, 198 The Notice of Violation is applicable only to San Onofre Units 2 and 3. In accordance with 10 CFR 2.201, the enclosure to this letter provides the Southern California Edison Company (SCE) reply to the Notice of Violatio If you require any additional information, please do not hesitate to call m Very truly yours, Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region V F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3
ENCLOSURE REPLY TO A NOTICE OF VIOLATION Appendix A to Mr. Mendonca's letter, dated May 26, 1989, states in part:
"10 CFR 50.49(f) requires that each item of electric equipment important to safety be environmentally qualifie "10 CFR 50.49(j) requires that a record of the qualification be maintained to permit verification that each item of electric equipment important to safety is qualified for its application and meets its specified performance requirements when it is subjected to the conditions predicted to be present when it must perform its safety functio "Contrary to the above, as of March 17, 1989, the licensee did not have a record of qualification for a predicted condition for electrical connectors on excore neutron monitors. The licensee was notified by the manufacturer of the monitors on May 10, 1988, that there was significant possibility of leaks in the connectors for the monitors which could cause degradation or failure of the neutron flux monitoring channel during a design basis acciden "This is a Severity Level IV violation (Supplement I)
applicable to Units 2 and 3."
NRC Inspection Report No. 50-206/89-11, dated May 26, 1989, states in part (page 8):
"Based on the information reviewed, as discussed above, the inspector considered that the licensee's NCR and 10 CFR 50.59 evaluation did not provide an adequate assessment or documentation in accordance with 10 CFR 50.49 requirements. In particular, the 10 CFR 50.59 evaluation credited alternate instrumentation for accomplishing the safety function despite the fact that none of the listed variables provides real time core reactivity information and no administrative controls were established (e.g.', control room operators were not notified of the potential for these monitors to fail during post accident conditions).
This is considered a violation of NRC requirements."
-2 RESPONSE Reasons for the vi6lation. if admitte SCE admits that the environmental qualification record for the Gamma Metric flux connectors was not maintained in accordance with 10 CFR 50.4 SCE admits that when notified by the vendor (via a 10 CFR 21 Report) that the environmental qualification for the connectors could not be assured, SCE did not adequately perform the requisite safety evaluation and justification for continued operation (JCO).
On May 12, 1988, SCE received a copy of a 10 CFR 21 Report from Gamma Metric concerning the solder connections on their cable assemblies. SCE uses the Nonconforming Report (NCR) process, with its safety evaluation and corrective actions, in conjunction with a written JCO to satisfy 10 CFR 50.49 environmental qualification requirements. On June 13, 1988, Nonconformance Report (NCR) G-0865 Rev. 0, was initiated to document the Gamma Metric 10 CFR Part 21 report concerns. The NCR was reviewed and approved on August 2, 198 The NCR received an initial assessment of "operable pending technical evaluation". As a result, the NCR was not resolved in an expeditious manner. Due to unrelated previous problems with resolving NCRs in a timely manner, the NCR procedure has been revised to restrict the use and duration of "operable pending technical evaluation" and to improve the timeliness of NCR issuanc SCE design engineering personnel were aware of the 10 CFR 21 report and that an NCR was in preparation. They
- promptly contacted the vendor to research industry reaction. A summary paper, prepared by the design engineering group, was provided to the NCR author. It was SCE's intent that the summary paper serve as the JC However, the summary paper was not in the appropriate format and did not contain the requisite information necessary for a formal JC The NCR author relied upon the summary paper when preparing the NCR's 10 CFR 50.59 safety evaluation and attached the summary paper to the NCR. Engineering supervision and Quality Assurance (QA) personnel reviewed and approved the NCR and safety evaluatio SCE admits the safety evaluation and summary paper improperly credited alternate instrumentation as being equivalent for accomplishing the safety function despite
- ,
- 3 the fact that none of the listed variables provides real time core reactivity information. Further, the corrective action section of NCR G-0865 Rev. 0 failed to establish administrative controls to provide operators with appropriate compensatory measures in the event the excore neutron monitors faile Neither the design engineering personnel nor the NCR author and reviewers (including QA) were adequately trained in preparing or reviewing either the 10 CFR 50.59 safety evaluation or the requisite JCO documentation. As a result of a previous item of noncompliance (reference letter Mr. Kenneth P. Baskin (SCE) to Mr. J. B. Martin (NRC), dated October 8, 1987), SCE developed a special training program, which commenced mid-year 1988, to improve the quality of engineering and technical work/review in NCRs, JCOs and safety evaluation On March 23, 1989, NCR G-0865 Rev. 1 was prepared as a result of the NRC's identification of the deficient NCR safety evaluation and JCO. NCR G-0865 Rev. 1 was issued to revise the safety evaluation and the corrective action A formal JCO was also prepared. However, since SCE relies upon the NCR process to identify and initiate corrective action, the JCO did not include a discussion of the NCR's corrective action During a further review by the NRC, the omission of the corrective action from the JCO Rev. 1 was identifie Coupled with several other enhancements, NCR G-0865 Rev. 2-and a revised JCO were issued and found to be acceptable by the NR.
Corrective steps that have been taken and the results achieve A Special Order was issued April 14, 1989, to alert operators to the potential for failure of the flux connectors in a post-accident environment.. A caution sticker was placed on the equipment in the control room which stated "May fail high during accident conditions" to alert the operators of the potential failure mode. The Units 2/3 Emergency Operating Instructions (EOIs) were revised to diract operators to commence emergency boration upon indications of unexpected increasing reactor power level or inadequate shut down margi *
- 4 As stated above, SCE had previously developed a training program to improve the quality of engineering and technical work/review in NCRs and 10 CFR 50.59 safety evaluations. As of February 28, 1989, the training program was considered fully implemente Engineering personnel who prepare and review JCOs have been instructed in the requirement to include all applicable corrective actions and administrative control The QA organization is conducting enhanced training of appropriate personnel performing NCR reviews. In addition, the NCR review process has been enhanced to direct NCRs to cognizant QA and Independent Safety Engineering Group (ISEG) engineer.
Corrective steps that will be taken to avoid further violation The excore neutron flux connectors will be inspected, tested and repaired or replaced as necessary prior to return to service from the next outage of sufficient duration. Completion of this activity will occur no later than the completion of the Cycle 5 refueling outag.
Date when full compliance will be achieve Full compliance was achieved on April 12, 1989, when NCR G-0865 Rev. 2 and the revised JCO were issued and accepted by the NR II
SOUTHERN CALIFORNIA EDISON COMPANY TOPICAL REPORT SCE-1-A CHANGE NOTICE Change Notice Number:
Affected Amendment:
Affected Pages:17.0-2, 17.0-3, 17.0-5, 17.2-34, 17.2-35, 17.2-36 Description of Change:
(1) Revise definitions for testing program to clarify different types of tests i Section 17. (2) Reorganize Section 7 2.11 to clarify the different types of testing programs, update organizational references and clarify test program requirement Reason for change (including basis for concluding that the change-satisfies the criteria of 10CFR50, Appendix B, and the quality assurance program commitments previously accepted by the NRC):
Changes made are to clarify the requirements applicable to the various phases of the test program. These changes continue to satisfy the requirements of 10CFR50 Appendix B Criterion X Change does X does not reduce commitments previously accepted by the NR Approvals:
a age of Qua ity A surance Vice President Date Submitted to NRC:
0576Q 0577Q 0II
17.0.1 DEFINITIONS Following are definitions of terms used in this repor Additional terms not defined by this subsection are defined in ANSI N45.2.10, as endorsed by Regulatory Guide 1.7 Architect-Engineer (A-E) -
An organization contracted to design, construct and perform backfit modifications to a 111CN28 nuclear generating statio Accept-As-Is -
A disposition to accept a nonconforming item without further work as the deviation is judged not to negatively affect the as-designed quality or function of the 11CN28 ite Administrative Authority -
The responsibility of an individual to direct the work (excluding technical direction)
of another individual or group including the responsibility for hiring, firing, salary review, and position assignment of an individual. See Technical Authorit Auditor -
An individual who performs any portion of an audit, including lead auditors, technical specialists and other such
as management representatives and persons in training to become Lead Auditor Construction Material Tests -
Physical and chemical testing of materials intended for construction use to verify conformance 11CN28 with material specifications Consultant - A person or organization retained under contract by SCE to provide expert advice, recommendations, or wor Coordinating Agency for Supplier Evaluation (CASE) Register -
A document published periodically as a service to the Aerospace and Nuclear industry containing quality assurance capability evaluation information on suppliers developed by member Aerospace and Nuclear companie Design Disclosure Documents -
Drawings, P&I diagrams, calculations, or specifications whichdefine items and which are needed to translate engineering concepts into structures, systems and component Engineering Construction Project (ECP) -
A major modification to an operating nuclear generating statio Corporate Documentation Management (CDM) Centers -
The
locations where project documents including quality assurance records, are maintained in accordance with established doc umentation retention and control requirement.0-2 Amendment 11 CN28
17.0.1 (continued)
Engineering Review Board (ERB) -
Those cognizant individuals responsible for providing approvals of Accept-As-Is or repair dispositions of nonconformance report Engineering Review Process -
The procedure used to determine dispositions of nonconforming item Initial Startup Tests -
Tests conducted after fuel loading and prior to commercial operation that confirm the design bases and demonstrate, where practical, that the plant is capable of withstanding the anticipated transients and postulated accident In-Service Inspection -
The planned and periodic nondestructive examinations performed on installed and/or operating structures, systems, and components, as required by Section XI of the ASME Boiler and Pressure Vessel Cod In-Service Tests -
Testing which is conducted to satisfy the requirements of Section XI of the ASME Boiler and Pressure 11CN28 Vessel code Modification Tests -
Those tests performed during or after completion of a modification to demonstrate that the affected structure, system or component can perform its design function 11CN28 and that it is compatible with existing plant system Includes tests similar to those performed during the initial
.
plant construction and startu Nuclear Fuel -
Fuel assemblies including 'but not limited to the following items:
fuel rods, poison rods (where applicable),
spacer grids, control element assembly guide tubes, and end fitting Nuclear Steam Supply System (NSSS) Supplier -
An organization contracted to design and manufacture a nuclear steam supply system for a nuclear generating statio Qualification -
Required acts to select a source for providing
items or service CN28 Preoperational Tests -
Tests conducted to demonstrate the capability of items to meet safety-related performance 11CN28 requirement Procurement Documents -
Contract documents including purchase orders, work assignments, memoranda of changes, and applicable design disclosure.0-3 Amendment 11CN28
17.0.1 (continued)
Station Orders -
Procedures and/or instructions prepared by the station staff and approved by the Station Manage Station Tests -
Tests to demonstrate that the work performed by the station staff or contractors is satisfactory and meets 11CN28 established requirements. Includes operability testing and In-service Testin Stop Work -
The authority to stop unsatisfactory work and control the further processing, delivery, or installation of nonconforming items. This does not include the authority to 11CN28 stop station power operation Technical Authority -
The authority to provide technical directio Technical Direction -
Instructions and directions defining technical requirements for an activit Technical Specification -
Appendix A (Safety) and Appendix B (Environmental) to the operating license of a station issued by the Nuclear Regulatory Commissio Unreviewed Safety Question -
A proposed change, test or experiment involves an Unreviewed Safety Question if:
(1) the probability of occurrence or the consequences of an accident or
malfunction of equipment important to safety previously evaluated in the Safety Analysis Report (SAR) may be increased; or (2) the possibility for an accident or malfunction of a different type than any previously evaluated in the SAR may be created; or (3) the margin of safety as defined in the basis for any Technical Specification is reduce.0-5 Amendment 11CN28
17.2.11 TEST CONTROL 17.2.11.1 Scope
.
This subsection describes the measures utilized by SCE to control testing activities in compliance with Regulatory Guides.30, 1.58, 1.94 and 1.116 (reference Table 17.2-1).
17.2.11.2 Test Control-General requirements All testing conducted in support of station operations or modification programs is documented, and accomplished in accordance with approved test program procedure Test program procedures and instructions described herein incorporate or reference:
o Applicable Regulatory Guides and SAR Commitment o Applicable codes and standards o
The requirements and acceptance limits contained in applicable design and Procurement Document o Existing station procedural requirements o
Instructions for performing the tes o Test prerequisites that may include, but are not limited to, the following provisions:
a)
Calibrated instrumentatio b)
Adequate and appropriate equipmen CN28 c)
Pretest walkdown and briefing d)
Completeness of item to be teste e)
Suitable and, if required, controlled environmental condition f)
Mandatory hold points established by designated organizations for inspection or witness activities g)
Acceptance and rejection criteria, either qualitative or quantitativ h)
Methods for documenting, recording, evaluating and approving the test data result Provisions for personnel training, data collection and storage are contained in other internal SCE documentatio.2-34 Amendment 11CN28'
17.2.11.2 (continued)
Tests are conducted in accordance with approved procedures and the results evaluated to determine compliance with established acceptance criteria. Records of tests performed at the station and supplier test records as required to be submitted by procurement documents are forwarded to the CDM Center and are available for audit by the Quality Assurance Organizatio The test program shall require that modifications, repairs and replacements of items be tested, using the same criteria as the original item If alternatives are required, they must be reviewed and approved by the same organization that established the original requirements or by alternate organizations which have been provided sufficient background informatio.2.11.3 Prototype, Shop and Construction Material Tests Procedures for Prototype and Shop tests are normally prepared by 11CN28 the organizations conducting the test; however, SCE, A-E's, or contractors may prepare these procedures where they have design or procurement responsibility. These procedures require appropriate preparing organization, quality assurance organization, and associated engineering organization review and approval prior to test implementation. Test results are docu mented, evaluated, and acceptance status verified by qualified individuals within the organization performing the test, and witnessed, as appropriate, by an inspector designated by the procuring organizatio Construction material test procedures are prepared by the SCE Quality Assurance Organization (QAO) or contractor based on established engineering criteria. Tests are performed and results documented in accordance with these procedures by SCE QAO or the Contractor. Deviations from engineering criteria are evaluated by the responsible engineering organizatio.2.11.4 Initial Plant Tests For initial plant startup, construction and component tests are conducted in compliance with test procedures normally prepared by A-E and the testing contractors performing the tests. The A-E is responsible for approval of the test procedures and for the review and evaluation of test results. The Nuclear Engineering, Safety and Licensing and Nuclear Generation Site Departments are responsible for management of the test progra Preoperational and Initial Startup Tests are also conducted in accordance with a Startup and Test Manual for the applicable station. This manual is the responsibility of the Nuclear Engineering, Safety and Licensing Department. It contains descriptions of organization's functions, authority, responsi bility, and the policies and procedures for the conduct of Preoperational and Initial -Startup Test programs. The technical portions of these programb, including quality assurance requirements, are contained in test procedures prepared by SCE, A-E's, NSSS Suppliers, and other major contractors. These procedures are approved by representatives from the responsible 17.2-35 Amendment 11CN2
17.2.11.5 (continued)
engineering, test and operating organizations. Evaluation and approval of test results is the responsibility of these organizations also..
The Nuclear Construction Group is responsible for implementation of the initial Startup Test program in accordance with SCE Quality Assurance Program requirements. Procedures required for implementation of this program are reviewed and approved by the Quality Assurance Organization as defined in Subsection 17..2.11.5 Station Tests Station Tests performed subsequent to operational status are accomplished by the Station Staff in accordance with approved written procedures prepared by or under the direction of the Nuclear Generation Site Department. As a minimum, test results are reviewed, evaluated, and approved by the Cognizant Supervisor prior to declaring the equipment/system operable. Where test results are not acceptable,the test organization is responsible for evaluation of the test and/or result In addition, out of tolerance as-found conditions in Technical Specification instrumentation, computers, radiation monitors and adjustable relays shall be reported to Site Support Services (formerly Operations and Maintenance Support OMS)) who will trend and evaluate this data in accordance with written criteria approved by Station Technical. Indications of too large and/or too
.
frequent deviations as defined by this written criteria shall be reported by OMS by use of a Nonconformance Report to Station-,
Technical for disposition. The Quality Assurance Organization performs periodic audits of these test result CN28 17.2.11.6 Modification Tests Modification Tests are the responsibility of the implementing organization Manager. The implementing organization is respon sible for development of required procedures with technical assistance provided by the responsible engineering organizatio Procedures developed for the final operational test phase are reviewed and approved by the Station Manager or designated representative. Test results are evaluated by the responsible test organization. Deviations of documented test results beyond specified acceptance limits shall be dispositioned by the responsible engineering organization prior to declaring the equipment/system operable. Quality Assurance Organization personnel are responsible for providing inspection surveillance throughout the testing progra.2-36 Amendment 11CN28