ML13330B401
| ML13330B401 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/03/1988 |
| From: | Baskin K Southern California Edison Co |
| To: | Martin J NRC/IE, NRC/RGN-V |
| References | |
| NUDOCS 8810120247 | |
| Download: ML13330B401 (8) | |
Text
RECEiVEDf REGION V Southern California Edison Company P.O. BOX 800 3 C4 AS : 52 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 KENNETH P. BASKIN TELEPHONE VICE PRESIDENT 818-302*1401 October 3, 1988 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Attention:
Mr. John B. Martin, Regional Administrator
Subject:
Docket Nos. 50-206, 50-361 and 50-362 Independent Assessment of Engineering and Technical Support San Onofre Nuclear Generating Station Units 1, 2 and 3 The purpose of this letter is to discuss the results of SCE's assessment of technical support for San Onofre Nuclear Generating Station and ongoing and planned future actions to restore confidence in SCE's control of technical work. Over the past year you have expressed increasing concern about the adequacy of SCE's control of technical work. This concern results from the identification of several examples of engineering related problems including lapses in the Unit 1 EQ program, incorrect diesel generator loading calculations, use of incorrect battery load profiles in surveillance tests, failure to adequately translate design requirements into operating procedures, and inadequate command of the CCW system design bases which was evident in the recent Units 2 and 3 SSFI. These problems are of serious concern to SCE in that they are indicative of a breakdown of SCE's control of engineering and technical work and do not reflect the high standard of engineering excellence which SCE must achieve and maintain to inspire continued confidence in the nuclear option. As was discussed in the June 10, 1988 SSFI exit meeting and in our responses to the Notices of Violation related to the SSFI and Unit 1 EQ, SCE committed to an exhaustive independent assessment of technical support for the operation of SONGS. This letter provides an overview of the findings of this assessment and the actions which will be taken to achieve a high standard of engineering excellence.
SCE established a Task Force to perform an Independent Assessment of Engineering and Technical Support for San Onofre Nuclear Generating Station.
The Task Force was chartered with determining the root causes of the apparent breakdown in SCE's control of technical work, and recommending specific corrective actions. The Task Force was composed of experienced personnel drawn from a number of different organizations. In excess of 10,000 man-hours 8810120247 881003 O)
PDR ADOCK 05000206 P
- 3.
October 3, 1988 were dedicated by Task Force personnel in the past three months to the assessment of engineering and technical support. A three volume, two thousand page report documents the Task Force activities including over one hundred specific recommendations. A summary of the Task Force assessment including the principal conclusions and recommendations is attached.
The Task Force concluded that the major contributors to the existing problems are the complexity of the current organization, heavy reliance on engineering contractors combined with inadequate allocation of SCE engineering resources, and the lack of readily accessible design basis documentation. As corrective actions to address these conclusions, the Task Force has recommended a reorganization with responsibility for design functions and the design basis focused in one department, the augmentation of in-house engineering resources and performance of all conceptual engineering in-house, and the establishment of a design basis documentation (DBD) program to recapture and maintain the design basis for all three units. SCE is committed to act on these recommendations to resolve the identified problems.
As an initial step in implementing the Task Force recommendations, SCE's nuclear related activities, formerly distributed among three separate departments (excluding procurement of nuclear fuel which is the responsibility of the Fuel and Material Management Department), have been reorganized, effective today, under two departments. Essentially, the reorganization transfers the design and engineering nuclear support functions provided by the Engineering and Construction (E&C) Department to the Nuclear Engineering, Safety and Licensing (NES&L) Department. The effect of this will be to focus the responsibility for all design-related engineering activities including the design basis into one organization. This reorganization will more efficiently utilize engineering resources and simplify the interface between the offsite nuclear support functions and the Nuclear Generation Site (NGS) Department.
In addition, NES&L will move from the Rosemead General Office to Irvine, significantly reducing -the distance to San Onofre. The close proximity to the site will result in improved inter-department communications and will facilitate increased cross training between NES&L and NGS personnel.
The reorganization of all design related engineering functions into a single department will result in more efficient utilization of existing resources, effectively increasing the resource devoted to engineering activities. In the new organization, SCE will increase the level of in-house technical expertise by: 1) adding staff in key technical skills areas, 2) providing personnel with enhanced technical training necessary to perform their functions,-and 3) by increasing the level of supervisory involvement in the design process. The increased level of in-house technical expertise resulting from these actions will permit SCE to reduce reliance on engineering contractors and increase the amount of conceptual engineering performed in-house, over a period of time as in-house expertise is developed. SCE intends, eventually, to perform all
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October 3, 1988 conceptual engineering and some detailed design in-house. Recognizing that, in the near term at least, some degree of conceptual engineering and the majority of detailed design will continue to be contracted, SCE will negotiate long term engineering contracts with a limited number of contractors under which SCE could effectively exercise control over lead contractor personnel to ensure continuity of expertise.
A significant feature of the new organization is the establishment of a Design Basis Documentation (DBD) Organization. The Design Basis Documentation Organization will be responsible for the overall development and maintenance of comprehensive design basis documentation. SCE will primarily utilize in-house resources for DBD development. This, in combination with extensive in-house inter-disciplinary review, will foster a high degree of familiarity with the design basis documentation by the conclusion of the DBD development effort.
The SSFI noted that the SONGS 2/3 FSAR contained numerous discrepancies. SCE will utilize the Design Basis Documentation development effort to identify existing discrepancies which will be corrected in annual FSAR updates. SCE will improve the FSAR change process to more effectively identify the need for changes to the FSAR and will reduce the scope of the FSAR by removing repetition and information which is no longer relevant.
As noted above, an extensive report documenting the details of the Task Force investigation, findings and recommendations is available. It is necessarily long and complex and this letter only provides an overview of the most significant conclusions and recommendations. SCE will be scheduling a meeting with you in the near future to discuss the detailed findings and specific recommendations, and to answer any questions you may have regarding the actions we are taking.
The reorganization and relocation represent a major change which will foster the development of a high degree of in-house technical expertise and design engineering capability. Because of the magnitude and significance of these changes, we anticipate that it will be some time before the new organization coalesces and develops its full potential. Now that the initial step has been taken with our new organization becoming effective today, our managers will now turn their attention toward implementing the specific corrective actions in their areas of responsibility. SCE will strive to implement the corrective actions and achieve our goals as soon as is practical. SCE will keep you informed of the status and schedule for implementation of corrective actions as they are developed. As a minimum, a schedule for the DBD development will be provided within three months.
J.
October 3, 1988 SCE is confident that the actions we are taking to implement the Task Force recommendations will be effective in alleviating NRC concerns regarding SCE's control of technical work.
If you have any questions regarding the actions we are taking, please call me.
Very truly yours, Enclosure cc: U. S. Nuclear Regulatory Commission, Document Control Desk F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3
ENCLOSURE INDEPENDENT ASSESSMENT OF ENGINEERING AND TECHNICAL SUPPORT FOR SAN ONOFRE NUCLEAR GENERATING STATION SCE established a Task Force to perform an Independent Assessment of Engineering and Technical Support for the San Onofre Nuclear Generating Station as a result of the increasing emphasis on engineering excellence within the nuclear industry, and in response to NRC Safety System Functional Inspection (SSFI) findings at San Onofre. The purpose of the Independent Assessment was to: i) identify programmatic deficiencies in engineering and technical support to San Onofre and determine the causes of those deficiencies, ii) assess SCE's position relative to the industry with respect to organizational structure and staffing levels, and 1ii) to compare the SSFI findings at San Onofre with the findings and subsequent commitments of other utilities, and recommend specific corrective actions based on those findings.
The analysis was divided into the following areas:
Root Cause Analysis o Documentation and Audits Review:
Review of pertinent documentation of plant problems to identify programmatic deficiencies and to identify necessary corrective actions.
o Root Cause Evaluation: Detailed evaluation of seven engineering related problems to determine root causes.
o Comparison of-Task Force Corrective Actions, SSFI findings, and corrective actions previously identified by SCE.
Resource and SSFI Commitment Analysis o Resource Analysis:
An analysis comparing SCE's organizational structure and the engineering and technical support staffing levels with those of the Region V and five other selected utilities.
o SSFI Commitments Analysis: A review of the SSFI findings and subsequent commitments of those selected utilities that have undergone an SSFI to assess similarities between their SSFI findings and those of SCE.
The results of the above tasks were then reviewed to identify the actions necessary to enhance the quality of engineering and technical support at San Onofre. The principal conclusions and recommendations resulting from the assessment can be summarized as they relate to Organization, Resources and Design Basis Documentation:
ORGANIZATION
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Conclusions:==
The organization of three nuclear-related departments and the current division of responsibilities can be improved. While the current situation was adequate for the time period immediately following commercial operation of Units 2 & 3, a consolidation of nuclear functions and focusing of design responsibilities is now appropriate. A contributing cause to several of the identified problems was the complexity of the current organization, the fragmented design engineering responsibility, and resulting interorganizational communication difficulties. As a result, no single organization was charged with the responsibility and accountability for maintaining both the design and the design basis.
Recommendations:
Reorganize Into Two Nuclear Departments The nuclear functions should be reorganized from three departments into two departments and the design functions and responsibilities should be focused in one department. This consolidation would improve interface between organizations. In addition, consolidating design engineering functions within one department (NES&L) will improve the prioritization and allocation of resources resulting in a more efficient utilization of engineering and technical personnel.
Other reasons supporting consolidation of nuclear functions include:
o The quality and efficiency of engineering activities can be increased by reducing duplication of effort and further clarifying accountability.
o Management attention will be dedicated to and focused on nuclear matters without distraction by non-nuclear activities.
o Further consolidating design engineering functions within the NES&L Department and systems cognizant engineering functions within the NGS Department will result in a separation of "design" and "systems" engineering functions as recommended by INPO.
o Virtually all the utilities surveyed have consolidated design engineering functions to improve communications and further clarify accountability.
RESOURCES
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Conclusions:==
Engineering contractors no longer maintain an adequate level of nuclear plant-specific expertise and knowledge. This is in part representative of the declining demand for engineering contractor services; accordingly, engineering contractors no longer have contractual incentives to maintain the staff and training programs necessary to ensure adequate technical resources for a specific nuclear plant. SCE also does not have adequate resources to properly support all required routine engineering activities and adequately supervise engineering contractors. This insufficient oversight of contractors by SCE has aggravated or caused difficulties in a number of the identified engineering deficiencies. Under the current conditions where contractor expertise has diminished, additional SCE overview and supervision is required.
Recommendations:
Devote More Resources to Design-Related Engineering SCE should increase the staff devoted to design-related engineering by:
i) transferring engineers that are performing design-related engineering in other departments to the one group that will be responsible for design, ii) adding staff in key technical skills areas, iii) providing personnel with the technical and procedural training necessary to adequately perform their functions and iv) by increasing the level of supervisory involvement in the design process.
Perform Conceptual Engineering In-House SCE should perform the majority of conceptual engineering in-house and evaluate performing additional final design activities in-house.
Performing conceptual engineering in-house facilitates a better in-house understanding of the plant design and is responsive to the NRC's position with respect to assuming more responsibility for design work.
This permits SCE to increase the level of engineering excellence and allows for in-house control of the key areas of design-related engineering that affect the design basis and design integrity of the plant. This will further develop and help maintain design and design basis expertise that cannot otherwise be achieved.
Negotiate Long-Term Engineering Service Contracts Long term engineering service contracts should be negotiated with a limited number of contractors. This allows the contractors to efficiently maintain technical competency and allows SCE to specify and obtain control of lead engineering contractor personnel to ensure a continuation of contractor expertise.
DESIGN BASIS DOCUMENTATION
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Conclusions:==
A recurring contributing cause of the problems related to engineering and technical support is that the design basis of San Onofre 1, 2 and 3 is documented in a variety of sources that were not known to or not readily identifiable and/or accessible to the personnel involved in the design process. No programmatic requirements exist requiring the update and compilation of the Unit 1 Design Criteria documents as criteria is modified or created for a particular design change except when these changes affect an ongoing retrofit project. Design criteria have not always accurately reflected operational and/or licensing requirements which has led to improper criteria and thus improper designs.
Therefore, it has been difficult for engineering personnel to consistently and accurately determine the design basis of a given system and convert this design basis into the implementation design criteria necessary to develop a design change.
Some design affecting documents (e.g. special studies) did not always receive a formal or completely documented interdisciplinary review. The scope of each reviewers responsibility is not clearly defined during interdisciplinary reviews. Further, it has been difficult to ensure that all of the design basis considerations are included in the development and maintenance of station operating procedures. A primary source for design basis information has been the Final Safety Analysis Report (FSAR), however, this document is now considered inappropriate for use as a design basis by the NRC and INPO.
Recommendations:
Initiate a Design Basis Documentation Program SCE should develop an integrated design basis documentation program for San Onofre Units 1, 2 & 3. This responds to NRC concerns germane to the ability of SCE engineering and technical personnel to control the design and demonstrate understanding of the plant's design basis. It will further improve the quality of design work through improved
accuracy, accessibility, definition and understanding of the design basis. It will further establish utility knowledge and control of the plant design basis. And, it will further improve consistency between the physical plant configuration and the plant design basis. It provides a tool for future design basis training for SCE engineering and technical staff, and will facilitate the response to questions regarding impact of new regulatory issues on the plant's design basis. The program should address the following:
o The documentation should provide access to the complete design basis by all personnel involved in the design process, and the documentation should include or reference all pertinent engineering and licensing documents.
o The documentation must be administratively controlled by procedures that ensure that all information that could effect the design basis (such as licensing, operations and design changes) is properly reviewed, that appropriate information is incorporated, and that the documentation is current.
The process of formulating design basis documentation will educate personnel on the design basis. Once assembled, the documentation then becomes an invaluable tool for training on plant design and design basis.
These conclusions and recommendations reflect the changing nature of SCE's responsibilities in operating the San Onofre Nuclear Generating Station.
San Onofre Units 2 and 3 began commercial operation in August 1983 and April 1984, respectively, ending a successful period of construction that lasted approximately ten years. Over the past four years, SCE has essentially completed the transition from a construction to an operating site. The operating environment has different challenges from those which existed during the construction of Units 2 and 3. For example, the role of engineering contractors has reduced significantly in recent years with a corresponding reduction in specific nuclear design-related expertise. As a result, SCE must take action to ensure that adequate design-related expertise is devoted to the design process. The recommended actions are intended to refocus and augment SCE's nuclear organization so that responsibilities are more centralized, interfaces simplified, and the level of design-related expertise is increased. This, along with programmatic changes such as initiating a Design Basis Documentation program and increasing the level of in-house design work, will enhance the quality of engineering and technical support at San Onofre.
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