ML13323B308
| ML13323B308 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/08/1987 |
| From: | Baskin K Southern California Edison Co |
| To: | Martin J NRC/IE, NRC/RGN-V |
| References | |
| NUDOCS 8710150197 | |
| Download: ML13323B308 (5) | |
Text
RECEIVED NRC Southern California Edison Company REGI0H V P.O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 KENNETH P. BASKIN TELEPHONE VICE PRESIDENT 818-302-1401 October 8, 1987 Mr. John B. Martin Regional Administrator U. S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368
Dear Sir:
Subject:
Docket No. 50-206 San Onofre Nuclear Generating Station Unit 1 Your letter of July 17, 1987, forwarded the report of the NRC team inspection of San Onofre Unit 1 which was performed between June 1 and June 12, 1987.
Our response to the Notice of Violation included with your letter was provided by a letter to the NRC from Mr. Kenneth P. Baskin dated August 14, 1987.
The purpose of this letter is to respond to.concerns addressed by your letter.
Delay in our response, in order to complete our evaluation, was requested by SCE in a letter to the NRC from Mr. H. E. Morgan dated September 17, 1987.
As described by your letter in some detail, your concerns stem from inspection findings which pointed out apparent weaknesses in our conduct of technical and engineering work. In your letter, you urge that we thoroughly assess our technical and engineering performance and aggressively implement needed corrective action to restore full confidence in these important areas.
As you noted, the weaknesses identified exist in the performance of our technical work, both station-wide and at the corporate office. This work is performed by the Engineering and Construction (E&C), Nuclear Engineering, Safety and Licensing (NES&L), and Nuclear Generation Site (NGS) departments.
This letter forwards the results of the assessment performed in response to your letter. Vice Presidents Harold B. Ray and Robert Dietch and I have jointly participated in the assessment. As requested, we have addressed the broader aspects of the problems associated with our technical and engineering
.8710150197 871008 PDR ADOCK 05000206 PDR
Mr. 3.
October 8, 1987 work, considered if plant systems other than those identified in the inspection report may be affected, and identified necessary generic corrective action. Our assessment is provided as an enclosure hereto.
If you have any questions or comments concerning this matter, please let me know.
Very truly yours, Enclosure cc: F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2, and 3 USNRC Document Control Desk
Enclosure PURPOSE This assessment is provided in response to NRC concerns described in an NRC forwarding letter from Mr. 3. B. Martin to Mr. Kenneth P. Baskin (SCE), dated July 17, 1987.
Specific responses to some of the examples of weakness in performance of technical work identified in Mr. Martin's letter were provided in Mr. Baskin's letter dated August 14, 1987.
The following addresses only the broader aspects of the issues involved.
DESIGN CHANGE PROGRAM The E&C Department is responsible to maintain the current design of San Onofre Units 1, 2, and 3, in accordance with regulatory requirements. The E&C Department Nuclear Project Manager is responsible to direct the process established to control the development and implementation of changes in the design. The NES&L and NGS Departments provide support to, and participate in, this process.
The NES&L Department is responsible for the QA/QC function, as well as Licensing and Nuclear Engineering functions. The NGS Department is responsible to approve design changes, and to support their implementation with appropriate changes to procedures and training. The overall design change process has been modified a number of times over the past decade to reflect changing needs.
An overall review is being performed, under the direction of the Nuclear Project Manager, to identify any aspects of the design change process which require improvements regarding clarity of responsibilities, requirements for documentation, or adequacy of procedural support. This review will be completed by year-end 1987.
Additionally, the QA Organization is performing a special audit of the design change control process from design change inception to completion including all interacting activities. This audit will comprehensively analyze a sample of recently completed design changes to identify any other generic weaknesses which may exist. This audit will be completed in the first quarter 1988.
TRAINING OF TECHNICAL PERSONNEL Formal training programs are currently in place for E&C, NES&L, and NGS personnel performing technical and engineering work. The E&C and NES&L programs emphasize Quality Assurance aspects of work performance, including design process administrative controls, as well as supplemental training in technical areas, based on needs identified by supervision. A program to provide systematic training for technical personnel in the NGS Department has recently been developed and accredited as part of the National Nuclear Training Academy.
-2 We have reviewed these training programs and have identified an area for enhanced training pertinent to supervisory personnel who review technical and engineering work. This enhanced training for selected supervisory personnel will include a review of Technical Specification, Design Bases, Safety Analysis Report, General Design Criteria, 10 CFR 50.59 reviews, and responsibilities of technical reviewers. This program will also include training to foster a questioning attitude in the review of technical work to ensure that poor quality work is identified during the review process.
Development of this training program will require about six months; implementation will commence by mid-year 1988.
DISTRIBUTION OF ENGINEERING INFORMATION Under certain circumstances, engineering information (e.g., design calculations) may be revised without being identified as a "design change."
This might occur, for instance, as a result of testing that is performed, or as a result of revised information from a vendor of installed equipment.
We determined that, in the absence of an identified design change, revised engineering information has not consistently been distributed to affected organizations. As a result, required changes in procedures were not made in a few cases.
As corrective action, design process procedures for distribution of revised engineering information have been reviewed, and are being revised to ensure distribution to appropriate station personnel. A review has been conducted of station procedures that could be affected by this type of distribution problem. No omissions of pertinent information were found.
PREPLANNING OF FUNCTIONAL TESTING Our design change implementation program uses two methods to perform testing of design change modifications, as follows:
(1) The first method utilizes specific test procedures for preoperational testing of systems. Specific test procedures, which are typically used once, provide step-by-step detail to test the design modification. This type of procedure goes through a rigorous level of review and management approval before implementation.
(2) The second method utilizes generic test procedures for component testing. Examples of components tested by this method include circuit breakers, relays, etc. The Construction Work Order (CWO) implements and documents the performance of the test. The test procedure and CWO's receive supervisory review and approval.
We have concluded that testing CHO's have sometimes not included a sufficiently detailed work plan. Changes are being made to appropriate procedures to require that testing CWO's include functional test objectives, special test conditions and instructions, reference to appropriate procedures and test steps, and QC hold points and acceptance criteria. These procedure changes will be completed by end of the year.
-3 EVALUATION OF SPARE PARTS FOR EQUIVALENCY For a number of reasons, there is a rapidly increasing need to evaluate substitute spare parts for equivalency to original equipment which is no longer available. Procedures will be revised to improve the quality and completeness of the documentation of these evaluations, and the process used to perform the evaluations will be reviewed and revised as necessary. This will be completed by year-end 1987.
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