ML20004C831

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Forwards Response to NRC Re Violations Noted in IE Insp Rept 50-206/81-05 on 810202-05.Corrective Action: Procedure Change Notice Issued 810310 to Define Use of Maint Order Form for Equipment Control
ML20004C831
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 03/30/1981
From: Papay L
SOUTHERN CALIFORNIA EDISON CO.
To: Engelken R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20004C830 List:
References
NUDOCS 8106050455
Download: ML20004C831 (3)


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O Southern Califomia Edison Company yC R O. BOX 800 2244 WALNUT GROVE AVENUE

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ROS EMEAD, CAUFORNIA 94770 f

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vce..e, ment March 30,1981 g

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-1 Office of Inspection and Enforcement

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V 1990 North California Boulevard

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Suite 202, Walnut Creek Plaza

%' M\\d Walnut Creek, California 94596 Attention: Mr. R. H. Engelken, Director DOCKET No. 50-206 SAN ON0FRE - UNIT 1

Dear Sir:

Your letter of March 9,1981, forwarded a Notice of Violation resulting from IE Inspection Report 50-206/81-05 which took place February 2 through February 5,1981.

The enclosure to this letter provides our response to your Notice of Violation.

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I trust the enclosure responds adequately to all aspects of the Notice of Violation. If you have any questions cr if we can provide additional information, please let me know.

Subscribed on the Ja day of March, 1981 by L. T. Papay

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Vice President Southern California Edison Company Subscribed and sworn to before me this Je day of March,1981 go

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soTARY Pfrde. CAUFORNIA Q g

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..s ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION ITEM A Technical Specification 6.8.1 states:

" written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1976".

Section 5.3.5(1) of ANSI N18.7-1976, Preparation for Maintenance, states:

" Maintenance procedures shall reflect considerations listed under 5.2.6."

(Equipment Control).

The lic.nsee's Maintenance Procedure and Form PSS0 (1) 430A, Rev. I require recording of whether or not test of redundant components, and testing after maintenance are required in connection with the work to be performed.

Contrary to the above, on December 10, 1980 Maintenance Order No. 500910 authorized inspection of the thrust bearing on the No. I diesel generator

. turbo chargers. The sectioa of the order prescribing the need for redundant unit testing, and for post-maintenance testing of the No. I diesel generator, was not completed.

RESPONSE

1.

Corrective Steps Which Have Been Taken And The Results Achieved.

Equipment control at San Onofre is accomplished in accordance with severei operat ng procedures. Equipment cannot be released for maintenance or returned to service following maintenance until all necesscry requirements have been met.

The maintenance order form now in use, PSS0 (1) 430A, Rev. 1, was developeu to improve the productivity of the maintenance department by providing additional information useful for pre-planning of work l

activities.

Information on redundant equipment testing and post-maintenance re-testing is provided so that this can be taken into account i

when scheduling maintenance personnel to perform the work. The information on this form was not intended to provide the actual control j

of equipment.

l In the incident in question, all required testing of redundant equipment and post maintenance testing was accomplished. The operations supervisor did not complete the portion of the maintenance order form related to equipment control because the necessary information had previously been j

transmitted orally to the maintenance planner.

l On March 10, 1981, Procedure Change Notice No. 2 was issued against Procedure S01-M-103 to better define the use of the maintenance order form for equipment contral.

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Corrective Steps Which Will Be Taken to Avoid Further Items Of Noncompliance.

In regards to equipment control, San Onof re Unit I has remained in compliance with applicable technical specifications and regulatory requi rements. Those portions of S01-M-103 which reqttired completing the redundant equipment control sections of PSS0(1)-430A were deleted by-PCN 2.

However, as a result of this incident, a consulting firm has been retained to review the maintenance order form and the procedures governing equipment control' in order to develop a simpler and more unified system.

3.

The Date When Full Compliance Will Be Achieved Insofar as equipment control is concerned, San Onofre Unit I has remained in full compliance. Procedure Change Notice No. 2 was issued against procedure S01-M-103 on March 10, 1981 in order to clarify the use of the redundant sections of the maintenance oroer form. The review of the maintenance order and simplication of the system will be complete by August 1, 1981.

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