ML14114A615
| ML14114A615 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/26/1990 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 9007310016 | |
| Download: ML14114A615 (3) | |
Text
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Southern California Edison Company r
23 PARKER STREET
(
IRVINE, CALIFORNIA 92718 HAROLD B. RAY TELEP E
SENIOR VICE PRESIDENT July 26, 1990 7I4-458 oo Mr.
Roy Zimmerman, Director Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368
Dear Mr. Zimmerman:
Subject:
Docket Nos. 50-206, 50-361 and 50-362 Quality Assurance Program Description San Onofre Nuclear Generating Station, Units 1, 2 and 3 Your letter dated June 26, 1990 responded to the submittal by Southern California Edison Company (SCE) of Change Notice 37 to Topical Report SCE-1-A, "Quality Assurance Program",
Amendment 12.
This change proposes to delete the in-line QA review of drawings and specifications by the Nuclear Oversight Division (NOD).
Your letter included the following conclusion:
"Change Notice 37 does not provide assurance that in-line reviews by the Nuclear Oversight Division are unnecessary, or what corrective action would be taken if unacceptable quality levels are indicated. Therefore, as discussed in a telephone conversation between W. Wagner (NRC/RV) and B. Katz (SCE) on June 26, 1990, we are requesting additional justification or clarification addressing our comments.
Without these provisions, Change Notice 37 represents an unacceptable reduction in commitments as defined by 10 CFR 50.54(a)."
The purpose of this letter is to provide the additional justification or clarification requested.
Necessity For Continued In-Line Reviews By NOD The SCE Nuclear Engineering Design Organization (NEDO) has implemented a number of significant changes during the past two years that are directed at improving the quality of the drawings and specifications, including changes, which are issued in support of San Onofre. Significant changes have also been implemented by NOD, including the establishment of a Safety Engineering organization providing Quality Engineering and Nuclear Safety groups which are involved in oversight of engineering quality.
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Mr. Roy Zimmerman July 26, 1990 In the wake of these changes to improve engineering quality, and as suggested in your letter, SCE has performed evaluations which we conclude indicate that continued in-line reviews of drawings and specifications by NOD are not worthwhile. The results of these evaluations are summarized as follows:
Field Generated Drawings Of 2,800 documents reviewed by Quality Assurance, 3.9%
were returned for minor deficiency resolution. Examples include:
- Missing signatures.
- Wrong type of document used, i.e. DCN instead of FCN.
- Lack of identification of other design documents affected.
- Inconsistency in design information, e.g. Bill of Material, which governs purchasing of correct materials, called for a different material than the ISO drawing.
(Material control procedures would prevent the issuance of the wrong material for a specific job.)
These deficiencies represent minor administrative document processing errors that are not safety significant and would be detected during the normal course of events.
All document deficiencies were corrected and commitments to action to prevent recurrence was obtained from the organizations involved.
Engineering Generated Drawings and Specifications Analysis of drawing and specification reviews, which includes vendor and SCE Engineering generated documents, provides similar results as with Field Generated Drawings.
Discussions with the groups performing these reviews indicates a small percentage of documents reviewed had only minor technical and administrative errors.
These deficiencies did not impair the adequacy of the design, and the normal processes of final package reviews and submittals would have detected and corrected the errors.
The deficiencies were corrected and commitments to action to prevent recurrence was obtained from the responsible organizations.
Mr. Roy Zimmerman July 26, 1990 We believe our resources can be more effectively utilized, consistent with NRC guidance as referenced in your letter, by oversight techniques which are performance-based and which emphasize in-depth, vertical assessments of the entire engineering process and its results.
Corrective Action Which Would Be Taken If Unacceptable quality Levels Are Indicated SCE will incorporate into the annual update of Topical Report SCE-1-A a commitment to continued evaluation of the quality of drawings and specifications which are currently subjected to in-line review and to take appropriate corrective action, including to reinstitute in-line review if necessary.
This annual update will be submitted to the NRC shortly.
CONCLUSION Change Notice 37 is submitted in accordance with 10 CFR 50.54 (a)(3) on the basis that it provides for more effective use of SCE resources to provide high quality drawings and specifications in compliance with NRC guidance. We believe the results of our evaluation demonstrate that continued in-line reviews by NOD are unnecessary and that they should be replaced by in-depth vertical assessments, as proposed.
A commitment to reinstate in-line reviews, if necessary, will be included in SCE-1-A as discussed above. On this basis, approval of Change Notice 37 is hereby requested.
If you have any questions, or if you would like additional information, please let me know.
Sincerely, cc:
Mr. John B. Martin, Regional Administrator, Region V Mr. C. W. Caldwell, NRC Senior Resident Inspector, SONGS Mr. W. Wagner, NRC Region V