ML13330B431
| ML13330B431 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/20/1988 |
| From: | Mccarthy C Southern California Edison Co |
| To: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8811230311 | |
| Download: ML13330B431 (3) | |
Text
Southern California Edison Company P.O. BOX 28 SAN CLEMENTE, CALIFORNIA 97 cc CHARLES B. McCARTHY, JR.
June 20, 1988 VICE PRESIDENT AND SITE MANAGER TELEPHONE SAN ONOFRE 714-368-9470 Mr. Roy Zimmerman Reactor Protection Branch Chief U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek. CA 94596
Dear Roy:
Subject:
Accelerated Maintenance Process San Onofre Nuclear Generating Station, Units 1, 2 and 3 During your recent visit to San Onofre, we had an opportunity to discuss a number of important topics of current interest within the NRC. One of these topics related to the use of accelerated maintenance processes.
You-expressed general concern over the use of such processes, which can lead to deficiencies in the review, concurrence, and documentation of maintenance activities. Since we recently made changes to improve our accelerated maintenance process, called the Shift Superintendent's Accelerated Maintenance (SSAM) process, I thought it would be beneficial to identify these changes for your information.
As background information, I will describe the circumstances which led to our decision to change the SSAM process. As you may recall, the alloy steel packing gland follower studs for motor operated Shutdown Cooling System suction isolation valve 2HV-9378 failed during attempts to manually operate the valve on August 31, 1987.
At the time, San Onofre Unit 2 was in cold shutdown and on Shutdown Cooling; however, 2HV-9378 could not be opened remotely. The failure resulted in leakage estimated at 100 gpm from the reactor coolant system through the packing gland. Our evaluation of this failure is contained in Licensee Event Report No.87-014, Revision'l.
As part of our evaluation, we examined the SSAM process and noted several weaknesses.
Specifically, the work plan for the SSAM was overly vague and broad in scope. The Shift Superintendent did not formally review and approve the work scope or sign the SSAM. The SSAM in this particular situation was not warranted, although allowed since the plant was in a 7-day action statement under the Technical Specifications.
'8811230311 80620 PDR ADOCK 05000206 P
PNU
Mr. Roy Zimmerman June 20, 1988 The changes we have made to the SSAM process can be categorized into three general areas:
application, formality, and authority/control. Each of the areas is discussed below.
- 1.
APPLICATION The SSAM was previously applied when (1) plant safety was in a degraded mode, (2) a Technical Specification Action Statement was entered, (3) personnel safety was affected due to plant conditions, (4) the emergency plan was activated, (5) the ability to monitor or satisfy safety functions was impaired, and (6) the availability of the plant was impaired. Clearly, this was a very board application, and in order to place stricter controls on the use of the SSAM the application guidelines were changed to allow its use only when (1) a significant unplanned load reduction or trip is imminent, and (2) a Technical Specification shutdown is required within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
This is a narrower and more appropriate application of the SSAM process.
- 2.
FORMALITY Since the concept of the SSAM process is to obtain the same interdisciplinary review and concurrence by appropriate personnel as that required for the normal pre-planned maintenance activity, but to allow the documentation of the maintenance activity to take place in the field concurrent with the activity, formality is essential to the success of the SSAM process. As indicated by our experience with 2HV 9378, changes to the SSAM process were implemented to strengthen its formality by explicitly requiring that:
(1) the Shift Superintendent, Shift Technical Advisor or Cognizant Engineer, Maintenance Planner, Maintenance Foreman and any other personnel required to execute the work (i.e.,
maintenance personnel, operators, etc.) attend the tailboard to discuss the work plan, (2) the details of the work plan which are developed during the tailboard be entered onto the SSAM maintenance order which is signed, dated and timed by the Shift Superintendent, (3) the Maintenance Planner and Foreman who are at the field location to immediately initiate generation of a Priority 1 maintenance order to supersede the SSAM maintenance order, (4) any changes to the tailboard work plan be authorized in advance by the Operations Supervisor (a senior reactor operator), (5) a tailboard be conducted following completion of the work plan with involved personnel to ensure that all appropriate documentation is initiated for review by supervision, and (6) the SSAM be cancelled within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of initiation unless specifically authorized by the Shift Superintendent.
Mr. Roy Zimmerman June 20, 1988
- 3.
AUTHORITY/CONTROL I consider this the most significant change to the SSAM process. Previously, there wasn't an explicit assignment of authority/control over the process. This led to confusion and lack of formality. In order to establish the proper accountability for authority/control over the SSAM process, the Shift Superintendent has been assigned the responsibility for strictly dictating, understanding, and controlling the SSAM work plan. As such, he assures that the SSAM work plan is precise and very specific.
In summary, the changes discussed above have (1) defined limits on the use of and provided termination criteria for a SSAM, (2) placed emphasis on ensuring that the work plan of a SSAM receives sufficient, formal review, (3) provided an appropriate feedback mechanism to operations as the work progresses for ongoing evaluation, and (4) established the requisite accountability for the authority/control over the SSAM process As experienced this year, these changes should result in minimal use of the SSAM. In addition, if a SSAM is required, the changes should assure that the review, concurrence, and documentation of accelerated maintenance activities by appropriate personnel.
As a matter of interest, the monthly average number of SSAM's used at San Onofre Units 2 and 3 between January, 1987 and October, 1987, prior to.implementation of the changes in the application guidelines, was approximately 18 (e.g., 23 were used in June, 17 were used in July, 15 were used in August, 7 were used in September, 2 were used in October).
There have been no SSAM's used at San Onofre Units 2 and 3 since October, 1987. At San Onofre Unit 1, the monthly average number of SSAM's used was approximately 4 over the same time period (e.g., 5 were used in June, 7 were used in July, 5 were used in August, 5 were used in September, 2 were used in October).
There were no SSAM's used in November,. 1 used in December, and none have been used since December, 1987 I would be interested in discussing your views on the changes we have made to our SSAM process during your next visit to San Onofre.
.Sincerely, cc:
John B. Martin, Regional Administrator