ML20010J344
| ML20010J344 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/31/1981 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20010J337 | List: |
| References | |
| NUDOCS 8109300344 | |
| Download: ML20010J344 (7) | |
Text
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Q_... e Southem Califomia Edison Company h5 RO. BOX 800 1244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 vect entsecasov 283 572-1474 August 31, 1981 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1990 North California Boulevard Suite 202, Walnut Creek Plaza Walnut Creek, California 94596 Attention: Mr. R. H. Engelken, Director DOCKET NO. 50-206 SAN ON0FRE - UNIT 1
Dear Sir:
Your letter of July 31, 1981, forwarded a Notice of Violation and a Notice of Deviation with NRC Inspection Report No. 50-206/81-24. This inspection report was the result of the NRC resident inspection for the month of June, 1981.
Enclosure I to this letter provides our response to the Notice of Violation contained in Appendix A of the report.
Enclosure II to this letter contains our response to the Notice of Deviation contained in Appendix B of Inspection Report No. 50-206/81-24.
I trust the enclosures respond adequately to all aspects of your concerns.
If you have any questions or if we can provide additior.al information, please contact us.
Very truly yours,
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L.F. Miller (NRCSiteInspector-SanOnofreUnli!1)j',i cc:
Ti1093OO344 810924E PDR ADDCK 05000206:
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ENCLOSURE I Response to Item of Non-Compliance identified in Appendix A to NRC Inspection Report No. 50-206/81-24.
ITEM Technical Specifl cation 6.8.1 requires that written procedures 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, " Administrative Controls for Nuclear Power Plants."
Paragraph 5.3.8 of ANSI N18.7-1976, " Chemical Radio / Chemical Control Procedures" requires in part, that procedures shall be provided for chemical control activities. They should include limitations on concentrations of agents that could cause corrosive attr.ck (on reactor coolar.t system piping, in this case).
Station Order S01-A0109 [S01-A-109], " Station Documents - Preparation, Revision and Review, " defines the responsibilities for preparation, review, approval and revision of San Onofre Unit 1 documents.
Paragraph 6.4.8 of that order, " Procedures Prepared by Outside Contractors" requires that contractor procedures be assigned a special procedure number, and that they be reviewed by the OSRC and approved by the Plant Manager.
Contrary to these requirements, the licensee attempted to control chemical conditions during startup in accordance with Revision III to the Westinghouse " Steam Generator Soak / Flush Procedure". This procedure required significant changes in the limits of chemical parameters to be maintained from the recommended Station Order for chemical control, S-E-2, Revisions 12, " Operation, Maintenance and Chemical Control of Heat Exchange Equipment." No approved station procedure implemented the chemical control procedures and limits which were usad by station personnel during the heatup and power escalation portions of the Units' return to power. This is a Severity Level 5 Violation. (sic)
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S, ENCLOSURE I PAGE 2
RESPONSE
1.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED It is acknowledged that non-routine activities and programs involving Steam Generator chemistry control during heat up and power escalation testing at San Onofre Unit I require specific direction by written, approved procedures. The chemistry procedures utilized by Station personnel during the heat up and power escalation portion of the June, 1981 startup were developed by Westinghouse and contained in Appendix B to a report entitled " Steam Generator Repair Program Return to Power Report, San Onofre Nuclear Generating Station, Unit 1, April,1981".
The On-Site Review Committee reviewed the Steam Generator Repair Program Report and discussed the attached Westinghouse chemistry procedures prior to the onset of operations. The discussion, however, focused on the technical content and adequacy of the startup chemistry program and did not constitute specific approval of procedures. During the time of the initial discussion of the deficiency with the NRC (prior to July 1,1981), Chemistry Supervisors were advised of the necessity to evaluate the need for special procedures approved by the appropriate authority whenever an additioncl chemistry program is undertaken.
No further instances of this type of problem are anticipated.
The startup chemistry program, however, did have technical and programmatic controls. The Westinghouse program had been thoroughly reviewed by Station Chemistry personnel and the procedures judged to be adequate. Constant chemical surveillance increased the ability to minimize Steam Generator chemistry problems.
The steam generator procedures develcped by Westinghouse were intended to be a guide for optimizing the steam generator clean up.
Tney were written on anticipated chemical responses based on samples taken during the shutdown.
In order to respond to the actual start up conditions, a team of Westinghouse Chemistry personnel (one Senior Engineer in Chemistry Field Applications and four Chemistry Technicians) were present on site during the hot flush and startup procedures. Their primary function was to gather and review chemistry data and recommend changes to the program to most effectively optimize the system clean up.
The program, therefore, involved an on going evaluation of chemistry conditions during plant startup operations. All responsible station groups were given a copy of the Westinghouse Special Chemistry program.
6 ENCLOSURE I PAGE 3 2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMPLIANCE.
As a reinforcement of the previous actions, a written nanagement directive will be prepared by September 10, 1981 outlining the need for the OSRC to review and specifically approve chemistry programs and procedures in order to determine if any additional special procedures are required for anticipated non-routine activities. The memorandum will be reviewed with all technicians in the Nuclear Chemistry Department.
3.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED.
Full compliance was achieved on July 1,1981, when all SONGS Unit 1 Chemistry Supervisors were made aware of the necessity to evaluate the 1
need for special procedures during non-routine planned plant chemistry activities.
Additional reinforcement will be provided by the written memorandum described above which will be written and reviewed by all personnel by September 10, 1981.
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7..i-ENCLOSURE II Response to Notice of Deviation identified in Appendix 8 to IE Inspection Report No. 50-206/81-24 ITEM Based on the results of an NRC inspection conducted during the period June 1 to Ju'y 1,1981, it appears that one of your activities was not conducted in conformance with generally accepted industry standards as indicated below.
ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," Paragraph 5.2.2, " Procedure Adherence," recommends that rules shall be established which provide methods by which temporary changes to approved procedures can be made, including the designation of a person or persons authorized to approve such changes. Tempora ry changes which clearly do not change the intent of the apprond procedure, shall as a minimum be approved by two members of tre plant staff knowledgeable in the areas affet.ted by the procedures. At least one of these individuals shall be the supervisor in charge of the shift.
Contrary to this recommendation, the licensees' project organization procedure TI-01 " Test Procedure Preparation, Review Approval and Evaluation," allowed test engineers to deviate from an approved test procedure provided only that they documented the deviation for post-test review and approval. This is a deviation.
(0 pen Item 50-206/ 81-24-01) (sic)
RESP 0Li 1.
CAUSE OF DEVIATION SCE's Engineering and Construction Project (ECP) provides the engineering, construction, and testing for major plant backfit modi fi cations. The testing of these modifications is controlled by the SONGS 1 ECP Test Manual, which contains Test Instruction No. 1, (TI-01) " Test Procedure Preparation, Review Approval, and Evaluation".
The Test Manual was initially approved in June,1976.'"
The Test Manual establishes the Test Working Group (TWG) as the principal approval authority for preoperational test procedures. The TWG consists of the Project Lead Startup Test Engineer, Plant Supervision, and the Project Engineer. The Quality Assurance Organization reviews and approves these test procedures and results.
In addition, Station procedures require review and approval of ECP preoperational test procedures by toe On Site Review Committee (0SRC).
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ENCLOSURE II PAGE 2 CAUSE OF DEVIATION (cont'd):
During a preoperational test, system test operations are directed by a Test Engineer, using an approved preoperational test procedure, through the Watch Engineer. All system operations are performed by Station Operations personnel, including system valve lineup and electrical apparatus operations. Prerequisite test procedures, such as instrumentation calibration and electrical control component tests, are performed by a Test Technician assigned to the ECP test group after first obtaining the concurrence of the Watch Engineer or Control Room Operator.
The ECP Test Manual currently describes two types of changes for preoperational test procedures:
1)
A change to the scope or intent of these preoperational test procedures requires a Test Change Notice (TCN) and approval by TWG. Simultaneously, as required by the Station procedures, a Procedure Change Notice (PCN) is processed through the OSRC. Both activities occur prior to implementation of the change.
2)
A nonscope or intent change is called an " exception".
These changes are documented in the test procedure. They include a description of the change, justification for the change (in sufficient detail to assure it does not involve the scope or intent or invalidate the test results) and the Test Engineer's signature.
The post test evaluation of the results (and any exceptions) is performed by TWG and requires their signoff to indicate acceptance of the test results and approval of the exceptions (ensuring that they did not invalidate the test results).
SCE personnel who originally developed the Test Manual did not consider paragraph 5.2.2 applicable to test procedures.
It was considered as being directed to plant operating procedures as it refers to temporary changes and changes that will be incorporated during the next revision.
This indicates the procedure is one that will be used repeatedly.
It is noted that all examples and references in this section are to operating procedures.
The Test Manual was developed assuming that test procedures are temporary in nature as outlined in ANSI-N 18.7 - 1976, Section 5.2.5.
Subsequently, the authority to make nonscope or intent changes (exceptions) to the test procedure was delegated to the Test Engineer.
Such changes are those discovered during the conduct of the test, and are made in order to keep th' test progressing smoothly and safely.
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ENCLOSURE II PAGE 3 CAUSE OF DEVIATION (cont'd):
The Notice of Deviation states that 'The Licensee's Project Orgar,12ation Procedure TI-01 Test Procedure Preparation, Review, Apreoval and Evaluation' allowed Test Engineers to deviate from an approved test procedure provided only that they documented the deviation for post-test review and approval."
Contrary to this, a test change involving the scope or intent is required to have a TCN and a PCN processed prior to performing the acti vi ty.
Nonscope or intent change (exceptions) must be described, justified and signed by the Test Engineer in the test procedure.
Subsequently, TWG reviews and approves all exceptions.
2.
CORRECTIVE ACTION The review of the ECP Test Program indicates that it is organized in a manner consistent with regulatory requirements. In order to strengthen the control over test procedure review and approval, the following approval method will be utilized:
a)
Prerequisite and Preoperational test procedure changes involving the scope or intent of the procedure shall continue to be made by Test Change Notices, and approval by TWG obtained prior to implementation, in accordance with current procedure.
Preoperational test procedures and subsequent changes involving intent and/or nuclear safet?
will continue to require review and approval by OSRC prire to implementation.
b)
Preoperational test procedure nonscope, nonintent changes (exceptions) will be approved by the Test Engineer and additionally by the Watch Engineer or a licensed designee as appropriate. These exceptions will continue to be evaluated by the approval organization (TWG) to ensure they do not invalidate the test results. Test Instruction TI-01 will be changed to include the Watch Engineer approval of exceptions as appropriate.
l c)
Prequisite test procedures (instrumentation calibration procedures and electrical component test procedures) exceptions shall continue to be approved by the Test Technician with subsequent approval by the original approving authority, in accordance with current procedures.
3.
IMPLEMENTATION DATE The above action will be completed prior to December 15, 1981.
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