ML13329A246
| ML13329A246 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/19/1993 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML13329A247 | List: |
| References | |
| NUDOCS 9304050044 | |
| Download: ML13329A246 (7) | |
See also: IR 05000206/1992028
Text
psft REGCl <UNITED
STATES
NUCLEAR REGULATORY COMMISSION
REGION V
1450 MARIA LANE
WALNUT CREEK, CALIFORNIA 94596-5368
MAR 19 1993
Docket Nos. 50-206, 50-361, 50-362
Southern California Edison Company
Irvine Operations Center
23 Parker Street
Irvine, California 92718
Attention: Mr. Harold B. Ray
Senior Vice President, Nuclear
SUBJECT:
FINAL SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT
FOR SAN ONOFRE UNITS 1, 2 AND 3 (AUGUST 1, 1991 THROUGH NOVEMBER
30, 1992)
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP)
Board Report Number 50-206/361/362/92-28, dated December 24, 1992, for your
San Onofre Nuclear Generating Station and to the written comments provided in
.
your February 16, 1993 letter (Enclosure 4) in response to the SALP Board's
Report. The results of this assessment were discussed with you during a
management meeting on January 14,
1993, as documented in Meeting Report Number
50-206/361/362/93-04, transmitted to you by our letter dated February 12,
1993
(Enclosure 3).
We have reviewed your comments made in the February 16, 1993 letter. The
letter contained three comments regarding the SALP Board's Report in the areas
of Maintenance/Surveillance, Engineering/Technical Support, and Safety
Assessment/Quality Verification (SA/QV).
We have considered these comments,
as summarized below and further discussed in Enclosure 2.
Your February 16,
1993 letter provided new information to the SALP Board in
stating that risk analysis information had in fact been considered by SCE
management when developing the maintenance strategy to repair the High
Pressure Safety Injection pump. The comments made in the Initial SALP Report
were based on documented inspection report findings, discussions with SCE
management,
and Exit Meeting discussions which indicated that senior plant
management did not consider this risk analysis information to be significant
when planning the work. After consideration of this new information, the
Board concluded that the associated SALP Report paragraph should be deleted
(Enclosure 2, page 11).
This change did not affect the SALP Board's
conclusions regarding the Maintenance/Surveillance area.
The Initial SALP
Report, revised to reflect this change, is provided as Enclosure 2 to this
letter as the Final SALP Report for San Onofre.
The NRC recognizes the progress reported by you in the commercial grade
procurement area and discussed in the January 14,
1993 management meeting.
However, our Initial SALP Report, which cited weaknesses in your program at
that time, was based on the information available to the NRC staff in this
area, as of the end of the SALP period. Based on this, the SALP Board has
9304050044 930319
PDR ADOCK 05000206
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2
determined not to revise the SALP Report and its conclusion in the area of
Engineering remains unchanged.
Your February 16, 1993 letter commented that management aspects of events were
evaluated in both the Engineering/Technical Support and Safety
Assessment/Quality Verification (SA/QV)
areas, rather than in just the
Engineering/Technical Support area. This resulted in a less positive
evaluation in the SA/QV area. We would agree with your comment if Engineering
management had been ineffective, but upper management had interceded to
effectively deal with the issues discussed. That was not the case in the
issues discussed in the SA/QV area. Upper management did not intercede
effectively in these cases.
Therefore, the SALP Board concluded that changes
to the SA/QV section of the SALP Report were not considered to be warranted.
Overall NRC conclusions are presented in Enclosure 1 to this letter.
As
discussed in our January 14, 1993 management meeting, the challenge for
Southern California Edison Company (SCE)
is to effectively use the existing
management,
programs and personnel to consistently achieve good performance.
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 the enclosures, we
will be pleased to discuss them with you.
Sincerely,
Regional Adminis~ta tor
Enclosures:
1. NRC Conclusions
2. Final SALP Report
3. SALP Meeting Report No. 50-206, 361, 362/93-04
4. Licensee Response to Initial SALP Report dated
February 16, 1993
cc w/enclosures:
H. E. Morgan, Vice President and Site Manager (San Clemente)
R. W. Krieger, Station Manager (San Clemente)
State of California
3
bcc w/enclosures:
Chairman Selin
B. Faulkenberry
Commissioner Rogers
G. Cook
Commissioner Curtiss
C. Holden, NRR
Commissioner Remick
P. Ray, NRR
Commissioner de Planque
SALP Board Members
J. Taylor, EDO
SALP File
J. Sniezek, DEDO
Docket File
M. Lesser, OEDO
T. Murley, NRR
F. Miraglia, NRR
J. Lieberman, OE
LPDR
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M. Smith
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bcc w/enclosures:
Chairman Selin
B. Faulkenberry
Commissioner Rogers
G. Cook
Commissioner Curtiss
C. Holden, NRR
Commissioner Remick
P. Ray, NRR
Commissioner de Planque
SALP Board Members
J. Taylor, EDO
SALP File
J. Sniezek, DEDO
Docket File
M. Lesser, OEDO
T. Murley, NRR
F. Miraglia, NRR
J. Lieberman, OE
LPDR
bcc w/o enclosure:
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M. Smith
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0
NRC CONCLUSIONS
A.
Comments Received From The Licensee
Southern California Edison Company's (SCE) February 16, 1993 response to
the San Onofre SALP Report presented no significant objections to the
content of the report. The SCE response identified three corrections
and clarifications to the report. One of these three comments has been
incorporated into the final report and does not affect the conclusions
or rating for the associated functional area.
B.
NRC Conclusions Regarding Acceptability of the Licensee's Planned
Corrective Actions
We concluded that the licensee's proposed actions to address areas
needing improvement were responsive. We will review SCE's progress as
part of our future inspection program, as appropriate.
C.
Regional Administrator's Conclusions Based on Consideration of the
Licensee's Response
I have concluded that the overall ratings in the affected areas have not
changed.
Enclosure 1
SALP BOARD REPORT REVISION SHEET
PAGE LINES
18
22-31
NOW READS: An NRC inspection of the licensee's program for the procurement
and dedication of commercial grade items used in safety-related applications
at SONGS identified some weaknesses. These weaknesses included incomplete
identification of appropriate safety functions, and incomplete specification
and verification of specific safety function performance characteristics.
To
the licensee's credit, many of the dedication program weaknesses had been
self-identified before the NRC's inspection, and the licensee has committed to
fully upgrade their procurement program to staff guidelines by January 1993.
SHOULD READ:
[This section of the report has not been changed.]
Basis: The SALP discussion of the licensee's programs for the procurement and
dedication of commercial grade items used in safety-related applications at
SONGS did include the information provided to the staff during the June 2,
1992 meeting. The inspection report issued by the staff on March 24, 1992,
categorized the findings as deficiencies and stated that there was an apparent
2 year delay in upgrading the SCE program to be in accordance with NUMARC's
first initiative on the dedication of commercial grade items.
The inspection
report further stated that the findings would be referred to Region V for any
potential enforcement actions. Based on the information provided in the June
2, 1992 meeting, and on a generic re-evaluation of the staff's position in
this area, we concluded that the findings should be considered weaknesses, not
deficiencies, and that it would not be appropriate to cite the licensee in
regard to any possible delay in implementing the NUMARC program.
The second point discussed by the licensee was in reference to a meeting held
on January 13, 1993 and reported on in a memorandum dated February 2, 1993.
There are two reasons for not including the results of this meeting in the
SALP period under discussion here. First, the meeting occurred well after the
SALP period had ended, and after the SALP report had been issued. Second,
while the staff was pleased with the progress made by the licensee in
upgrading their commercial grade program, this meeting was not an inspection
and it would not be prudent to significantly alter the staff's previous
inspection findings based on a brief discussion of issues that are better
resolved by the normal inspection process. The progress of the licensee in
the area of commercial grade programs will be the subject of future NRC
inspections. Based on these two reasons, it is the staff's opinion that the
progress noted to date in 1993, and any future information obtained by the
staff in this area, is an appropriate subject for the next SALP report.
PAGE LINES
11
21-29
NOW READS:
One instance regarding the negative impact of scheduled
maintenance on safety was observed. It involved a Unit 3 high pressure safety
injection (HPSI) pump which was out of service for troubleshooting and repair
Enclosure 2
for more than six weeks. Although licensee management considered that the
spare pump was installed for operational flexibility, a probabilistic risk
assessment performed for work on a Unit 2 HPSI pump of a similar duration
determined that this resulted in an approximate 10% increase in core damage
probability.
SHOULD READ:
[This paragraph has been deleted.]
Basis: While discussions with SCE management during the inspection period
indicated that having the HPSI pump out of service for this length of time was
not safety significant, the written response from SCE states that the PRA was
considered when developing the HPSI maintenance strategy.
PAGE LINES
19
32-35
NOW READS:
...
but recent observations indicated continued weaknesses in:
management assessment of emerging issues, including effective communication
with the NRC on these issues; corrective action followup; and accuracy of
submittals to the NRC.
SHOULD READ:
[This section of the report, and a subsequent paragraph that
describes these weaknesses, have not been changed.]
Basis:
As identified in the SCE comment, the NRC does evaluate licensee
management effectiveness in each of the individual SALP functional areas.
.When
an issue with elevated safety significance requires interaction of senior
licensee management, this issue is also evaluated under Safety Assessment
Quality Verification.
Enclosure 2