ML13309A334
| ML13309A334 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/15/1992 |
| From: | Hammond G SOUTHERN CALIFORNIA EDISON CO. |
| To: | Caldwell C NRC |
| References | |
| NUDOCS 9210210224 | |
| Download: ML13309A334 (3) | |
Text
Southern California Edison Company SAN ONOFRE NUCLEAR GENERATING STATION P.O. BOX 128 SAN CLEMENTE, CALIFORNIA 92672 October 15, 1992 Mr. Chris Caldwell Senior Resident NRC Inspector San Onofre Nuclear Generating Station
Dear Mr. Caldwell:
Subject:
Docket Nos. 50-206, 50-361, and 50-362 NRC Concerns Regarding SONGS Measuring and Test Equipment (M&TE)
Program San Onofre Nuclear Generating Station, Units 1, 2, & 3 This letter provides information on two items identified by the NRC during the routine NRC Resident Inspector debrief meeting conducted on Tuesday, October 6, 1992. The NRC identified that our M&TE program had potential deficiencies in the areas of tracking measuring and test equipment deficiencies and in evaluating those deficiencies. We agree that improvements to this program are warranted and have previously initiated actions which we believe will address your concerns.
SCE Formulation of a Quality Action Team Early in 1992, an internal audit of our M&TE program identified program deficiencies. As a result of this and other concerns with the M&TE program, an SCE Quality Action Team (QAT) was formed in June of this year to perform a broad and in-depth look at the M&TE program.
This QAT review is ongoing, but to date has identified problems similar to the ones the NRC identified. Specifically, they are evaluating improvements that can be made to the program in the areas of M&TE accuracy, the calibration failure process, the traveler system, and user awareness and understanding of program requirements. While the specific problems the NRC identified were not yet identified by the QAT, we expect that the QAT review would have identified and corrected the concerns identified by the NRC prior to the disbandment of the QAT.
Evaluation of Specific Concerns We have evaluated the specific concerns the NRC brought to our attention in the area of M&TE. A discussion of each follows.
9210210224 921015 PDR ADOCK 05000206 P
P-DR
MR. CHRIS CALDWELL OCTOBER 15, 1992 M&TE Tracking Discrepancies The NRC identified 24 instances where the use of M&TE was documented on Maintenance Orders in the San Onofre Maintenance Management (SOMM) System, but their use was either not documented on M&TE travelers or was recorded on the travelers incorrectly. Consequently, the use of this M&TE on plant equipment was not entered into the SONGS Measuring and Test Equipment (STEM) System; and therefore, STEMs did not accurately--identify all of the actual uses of the M&TE. The concern was raised that if a calibration failure notice was issued for any of these M&TE devices, we would not be able to readily trace the M&TE to the plant equipment on which it was used, and the plant systems upon which the equipment was used would not have been evaluated for the impact of the calibration failure.
We have reviewed the 24 deficiencies and have determined that they do not impact plant performance or safety. A root cause evaluation is also being performed to determine the reason for the discrepancies between the STEM and SOMM databases. The results of the root cause evaluation will be provided to our QAT for their use.
In the interim, in order to determine if this problem is wide spread, we have developed a computer program which examines both the SOMM and STEM databases to identify discrepancies in recorded use of M&TE. We are utilizing this program to complete a review of all M&TE used during the last 18 months. Any discrepancies which are identified will be evaluated by Octo*ber 30, 1992, for potential impact on plant systems due to any previous M&TE calibration failures. Corrective action will be taken.as appropriate. Thereafter, we will run this computer program on a monthly basis and correct any identified discrepancies until improvements to the M&TE process allow this overcheck to be discontinued.
In addition, we will conduct retraining for all M&TE users by November 25, 1992, on the importance of properly documenting the use of M&TE on the M&TE traveler and in the SOMM and STEM databases. Beginning November 26, 1992, personnel who have not received this training will not be issued M&TE.
Finally, the M&TE traveler will be revised to enhance-tracking capability of each M&TE application to ensure that adequate evaluations will be performed following M&TE calibration failures.
M&TE Calibration Failure Evaluations The-NRC M&TE program review also identified five M&TE calibration failure evaluations which did not adequately consider the effect of the calibration failures on plant equipment, and which were not performed in accordance with procedural requirements. The NRC also noted that in two of the five cases, the evaluations were not supported by sound justification.
MR.-CHRIS CALDWELL OCTOBER 15, 1992 We have reviewed the five calibration failure evaluations and agree that they should have been performed more rigorously. We have reevaluated these failures and determined that there were no safety related plant systems affected.
Nevertheless, as a result of this finding, we will conduct retraining for all evaluators of M&TE calibration failures by November 25, 1992. The training will cover the proper methods for performing calibration failure evaluations.
Beginning November 26, 1992, personnel who have not received this training will not be allowed to evaluate M&TE calibration failures.
Furthermore, the M&TE calibration failure evaluation process is being reviewed to determine whether the responsibility for performing calibration failure evaluations is assigned to the appropriate level within the maintenance organization and receives adequate reviews. As a result of this review, changes will be made, as appropriate, in the evaluation and review process.
Conclusion The corrective actions we have taken and plan to take will resolve the specific deficiencies identified. Interim measures will assure that the concerns the NRC identified will not be repeated and that the significance of previously unidentified problems will be properly evaluated. Long term improvements will be implemented as a result of the continuing QAT review.
If you have any questions, please feel free to contact me.
Sincerely, G. E. Hammond Supervisor, Onsite Nuclear Licensing MMFarr:D\\WP51\\M&TE cc:
Document Control Desk, Washington, D. C.
J. B. Martin, Regional Administrator, NRC Region V J. 0. Bradfute, NRC Project Manager, San Onofre Unit 1 M. B. Fields, NRC Project Manager, San Onofre Units 2 & 3