ML20028C489
| ML20028C489 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/03/1982 |
| From: | Dietch R SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20027A871 | List: |
| References | |
| NUDOCS 8301100266 | |
| Download: ML20028C489 (15) | |
Text
- b ENCLOSURE 3
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Southem Califomia Edison Companyr e _3 5E e
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O. BOX 800 2244 WALNUT GROVE AVENUE
.b ROBERT DICTCH December 3, 1982
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213-572-4 44 U. S. Nuclear Regulatory Commiss ion Of fice o f Inspection and En forcement Region V 1450 Maria Lane, Suite 210 Walnu t Creek, California 94596-5368 At tention:
Mr. R. H. Engelken, Regional Adminis trator
Dear Sir:
Sub i ec t:
Do cke t No. 50-206 NLC Systematic As sessment of Licensee Performance (SALP)
Response to SALP Report Dated October 18, 1982 San Onofre Nuclear Generating Station, Unit 1 Mr.
D. M. Sternberg's letter o f October 18, 1982, issued the NRC draf t SALP Report for San Onofre Nuclear Generating Station, Un it 1, and requested our comments on the SALP Report and the actions we have taken or will take to improve performance in th e functional areas o f:
plan t operations; radiological controls; maintenance; security and safeguards; and design changes and modifications.
The enclosure to this letter provides our response to the referenced SALP Repor t.
We believe the SALP Report should be reconsidered in th e functional areas o f:
plant operations ; radiological controls; and design changes and modifications.
As we d iscus sed at our meeting on November 8,1982, and for reasons detailed in the enclosure, we believe the SALP board should consider reclasaif1. cation o f enes e functional areas to Category 2.
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G Ed Wl.
U.S. Nuclear Regulatory Comm. December 3,1982 We have concluded that the magnitude of our effort, discussed in the enclosure represents evidence o f our subs tantial commitmen t to safety.
We trus t that you will concur i
and that your characterization of our overall safety performance wil1 reflee t th is.
If you have any questions or if we can provide additional informatio n, pleas e contac t me.
Sincerely,
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Enclosure cc:
L. Miller (NRC Resident Inspector, San Onofre, Unit 1) f i
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s ENCLOSURE Southern California Edison Company Response to NRC SALP Report Dated October 18,198 2, on San Onofre Nuclear Generating Station, Unit 1 1.
SECTION IV. A - PERFORMANC E ANALYSIS - PLANT OPERATIONS SALP REPORT:
"The licensee's management appears to be involved and concerned with nuclear safety.
Howeve r,
during this period, licensee resources were not effective ly used.
Only minimally satisfactory performance with respect to operational safety was ach ieve d.
Th e maj o r fire in th e number 1 Diesel Generator (LER 81-17), the discovery of serious design flaws in the high pressure safety injection sys tem (LER 81-20), and numerous apparent s eismic design deficiencies were significant occurrences in this period.
In addition, several s ignificant operational errors were made which demonstrated an occasionally casual approach to procedural co mplianc e.
Specifically, the failure to recognize an explosive mixture accumulation in the was te gas sys tem (NRC Inspection Report No. 81-31), chronic operation o f the mixed b.ed demineralizers with evidence o f retention screen plugging (NRC Inspection Report No. 82-10), and the removal of two o f tnree required boration flowpaths contrary to the Technical Specifications (NRC Inspection Report No. 82-17) resulted from failure to observe procedural precautions.
Recently, licensee managemen t has vigorous ly emphasized procedural compliance by operating pers onne l. "
RESPONSE
The SALP report identifies three examples of "significan t occurrence s" as evidence o f una t is I
characterized as " minimally s atisfactory performance with respect to operational safety".
The firs t and second examples were the Diesel l
Generator fire reported in LER 81-17 and the inoperability of the Safety Injection System f
reported in LER 82-20.
Neidne r o f thes e are l
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causally linked to operator action or performance.
Moreover operator action in these two incidents was promp t and appropriate.
The third identified example is the characterization of " numerous apparent seismic design de fic ienc ie s".
This is a mischaracterization of modifications required as a result of new seismic criteria being imposed on the as-built condition of Unit 1 as no deficiencies in the NRC-approved and implemented original design basis of the plant have been es tablished.
T1e SALP report also characterizes "s eve ra l s ignificant operational errors" which demons trate "an occasionally casual approach to procedural c omp l iance. "
Although procedural errors have occurred, the Company's approach to procedural compliance has not been " casual".
Th is f ac t is recognized by the NRC in tneir observation tnat
" license management has vigorously emphasized procedural compliance".
Such vigorous emphasis has included numerous policy directives, training and disciplinary actions and has been accompanied by an unprecedented commitment of resources to improve procedure content and control.
The SALP report, as presented in the summary table on page 29, states 677 man 41ours were expended inspecting Operations.
Th is comprehensive examination disclosed only three violations:
two level IV violations (Report 82-17) and a level V violation (Report 82-15).
S ALP REPORT:
"The Board is concerned that the licensee's performance in tais area may have been adversely affected by the need for larger numbers of l
personnel to assis t in the s tartup program for l
Unit 2, which resulted in a less effective manning level for Unit 1 in both the engineering and nonlicensed s taff.
The effectiveness of management involvement will be closely monitored during the next SALP period."
RESPONSE
Ta e SALP Repor t characterizes s taf fing as "resulting in a less effective manning level for Uni t 1", and implie s dia t management has no t given l
Un it 1 adequate suoport resources.
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In 1979, top management recognized the need for increased management and personnel support.
T1e Nuclear.Engineeting and Operations Department was established and the Station organization was ex tens ive ly. revis e d subs equent ly.
Health Physics and Ch emis try were separated and given individual Management positions.
'In 1981, to increase management and supervision at th e s tation, tne Deputy Station Manager pos.ition was es tablished.
Assistant Manager positions were created in the Operations and Maintenance Eupar tments.
To summarize, s ince 1980 the number o f Station positions authorized has been increased from 359 i
to 1241.
In addition, 600 contract employees now support the Station s taf f in upgrading a number of programs directed toward enhanced compliance.
During th e SALP period alone, Station s taf f increased 76%.
T11s represents a subs tantial commitment o f manpower and resources to support all Station activities.
In our view, a substantial increase has been made in the effective manning in support of Unit 1.
Th e SALP repor t rates Plant Operations as Category 3.
Fo r th e reasons cited above, we believe the classification should be i
upgraded to Category 2.
i II.
SECTION IV. B. - PERFORMANCE ANALYSIS - RADIOLOGICAL C ONTROLS i
l SALP REPORT:
"Since Augus t 1980, frequent major changes in the i
radiation protection organization have been made.
Plis has resulted in some lack of continuity.
Many new technicians are being integrated into the plant s taff while the licensee continues to rely heavily on contractor supplied radiation pro tection technicians.
Several experienced foremen have recently been promoted thereby temporarily decreasing the effectiveness of first line supervision.
With the upcoming increase in retrofit activities and other major site l
evolutions, it is suggested the licensee direct attention to these conditions which could have a potentially negative impac t.".
3.
RESPONSE
We have reviewed the Health Physics s taffing.
h is tory and have concluded that the department achieved stability and continuity for mucn of the SALP evaluation period.
Organizational change in the Station Health Physics Department has occurred in the past as a result o f:
- 1) th e los s o f the Department Manager; and 2) the implementation of corrective action to improve th e effectiveness o f th e organization.
Organizational change has now been s tabilized with th e appointment o f the present Depar tmen t Manage r in early 1982.
To increase "the effectiveness of firs t line supervision" there are currently three qualified supervisors reporting to the Manager who head the four major areas of the department and there are sufficient back up personnel to assure continuity.
There are presently three SCE Health Physics Foremen assigned to Unit 1.
Bo th Technician and Foreman positions have been declared critical.
Tais prevents their loss by transfer to other parts of the company until there is sufficient organizational depth to ensure personnel replaceability.
To reduce SCE's " relying heavily on contractor-supplied radiation protection technicians", an extensive program of training for the approximate ly sixty SC E Assis tant Health Physics Technicians has been in progress for more than a year.
This program include s.:
(1) six months of classroom training; (2) use of a comprehensive qualification manual; and, (3) the requirement that, af ter gaining three years of experience, the assistants mus t attain a passing grade on die company's validated j ourneynan examination before promotion to Health Physics Technician.
Approximately twenty-five o f the As sis tant Health Ehysics Technicians are assigned to Unit I along with five SCE Health Physics Technicians.
Th ese are supplemented where necessary with contractor Health Physics Technicians.
All full Technicians-l have passed the journeyman examination.
SCE will continue to use contractor Technicians in varying numbers depending upon plant status until a sufficiently large number of assistants have been promoted to Technician. !
l SALP REPORT:
" Liquid and gaseous radioactive waste management and effluent monitoring responsibilities res t with the licensee's chemis try s ection.
An inspection of these activities revealed a significant lack of management attention in this area.
The following programmatic weaknesses were identified:
The assigned engineer was not fully aware of his responsibilities ; was unfamiliar with applicable license conditions and regulatory requirements; and was no t well versed in the effluen t monitoring ins trum entation.
Tae e ffluent monitoring ins trumentation was not being maintained.
Bor example:
tne liquid radwaste monitor had not operated properly for nearly a year; the stack gas monitor was not operating properly when the was te gas decay tank failed; effluent monitor flow meters had not been calibrated; and the operational radiation monitor multipoint recorder frequently malfunctioned.
Several radioactive releases were not properly evaluated and reported.
Bor example:
batch releases producing inconsistent effluent monitor responses were no t evaluated; the January through June 1981 Semiannual Ef fluent Release Report was no t submitted until requested by the NRC.
Procedures for liquid and gaseous radwaste management lacked specificity and appeared not to have been followed.
For example:
procedures did no t specify wnat item on the Gas Eklease Permit constitutes conditions which must be met for the release to take place; and although gas discharge flow rates were recorded as required, it appeared that the flow instrument nad been bypassed to decrease discharge times.
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As a result o f dais inspection effort, thre e Severity Level IV violations were cited (f ailure to:
monitor gaseous effluen t releases; perform surveys or evaluations; and develop and implement procedures) and l
one Severity Level V (failure to submit the semiannual l
e ffluent release reports).
An Enforcement Conference l
was held on November 25, 1981."
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RESPONSE
Tae SALP Report reflects an earlier weakness in the SCE waste management and effluent monitoring programs.
Noncompliances were limited to those inspections conducted prior to November 5, 1981.
Corrective action has been prompt and effective in that during the eight remaining months (November 1981 through June 1982) of the SALP period, no further noncompliance occurred in the effluent controls area.
Specifically, corrective action has included:
establishment of a qualified, full time effluent engineer position assigned the responsibility for all effluent monitoring; completion of a recalibration and evaluation of effluent monitoring equipment; issuance o f new procedures which have ensured proper calibration of all effluen t monitors (thereby correcting improper ins trument response) ; and revision of procedures to specify conditions and instrument readings which must be met prior to initiation of any e f fluen t releas e.
The NRC has recognized SCE's correction of earlier deficiencies and the SALP report reflects SCE's "p rograma tic imp rovement".
T1e SALP report rates this area as Category 3.
For the reasons cited above, we believe the classification should be upgraded to Category 2.
III. SECTION IV.C - PERFORMANCE ANALYSIS - MAINTENANCE SALP REPORT:
" Increased licensee management attention needs to be focused an maintenance documentation, procedure revisions, maintenance record retrieval, maintenance order approvals and close outs,
maintenance department communications with other departments and formal controls on all maintenance work.
Future NRC inspections of maintenance i
activities monitor the effectiveness of these j
measures in preventing further violations in this are a."
RESPONS E:
Increased management attention to the Maintenance Department nas been and will continue in order to improve the maintenance function.
The mos t significant measures to improve our performance in 8
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the maintenance area were implemented af ter the SALP period ended on June 30, 1982.-
Bl is included, among odaer things, reorganization of the Ma intenance Department.
Several Unit I maintenance managerial positions have been es tablished including:
the Unit 1 Supervisor of Plant Maintenance who is responsible for maintenance order planning and SCE craf ts and craf t supervision; Unit 1 Phintenance Contractor Manager who is responsible for management of contractors ; and the Maintenance Support Group who provides direct s taff support in training, outage planning, materials support, and commitment tracking.
A Maintenance Engineering Group has been es tablished to prepare procedures, process Nonconformance Reports, process ASME repair travelers and weld papers, and conduc t technical analysis o f maintenance problems.
In addition, comprehensive review and modification, where necessary, of the Maintenance Training Program is being conducted at this time.
The Training Program is being developed to address all functional areas o f th e Maintenance Depar tment
- i.e., craf ts foremen, general foremen, planners,
supervisors, engineers, and managers.
T1e maintenance planning function will be defined and formal training establisned to augment on-the-job training for key individuals.
On November 15, 1982, th e Maintenance Depar tmen t retained a Maintenance Consultant for a period of l
6-9 mon tns.
T1is individual has an extensive I
background in the development and implementation of nuclear maintenance programs.
Ta e purpos e o f this additional resource will be to nelp ensure that the Maintenance Depar tment management addresses and follows through in a timely manner on organizational, management, and developme.ntal issues.
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IV.
SECTION IV.G - PERFORMANC E ANALYSIS - SECURITY AND S AF EGUARDS SALP REPORT:
"The evaluation indicates that s tation middle management has no t effectively communicated with subordinates thus contributing s ignificantly to the observed program implementation deficiencies.
Although the licensee has been agreeable and cooperative in dealings with the regional NRC s taff, e ffective corrective action has not been consis tently acnieved.
Die licensee recently implemented a new management s tructure with new personnel at the station.
Recent improvements in the security program effectiveness have been observed by security inspectors..."
"... Maintain the increased level of inspection, determined necessary during the previous assessment period, to establish the effectiveness o f the new managemen t s tructure."
RESPONSE
As referenced in the SALP Report, the Security Department has been reorganized and a new management s tructure implemented.
Imp rovements have been made to clarify responsibility and chain o f command.
Also, the s taff has been expanded in some areas to provide ennanced administrative support and to increase line supervision.
The new organization also provides for a continuous audit program to identify and correct deficiencies.
Extensive corrective actions, as referenced in dae i
SALP Report, have provided s ignificant improvement in the Security program.
In addition to die reorganization and realignment of Security management and personnel, increased numbers of personnel have been assigned to the Central Alarm Station (CAS), Secondary Alarm Station (SAS), and to fixed posts dedicated to the rapid assessment l
o f alarms.
Training of Security personnel is l
being increased.
Security procedures are being substantially upgraded.
Th e Security Plan, I
itself, is being rewritten.
Physical and procedural improvements have been implemented which have resulted in a s ignificant reduction in nuisance and false alarms.
Communications between the CAS and SAS have been improve d.
New fixed and hand held search equipment is being acquired. !
.i Waile the number o f noncompliances has been s ignificantly reduced s ince the SALP Report, increased management attention in tne Security Department will continue.
As shown by the numerous changes implemented, management support and dedication to Security remains a nigh priority.
V.
SECTION IV.L - PERFORMANC E ANALYSIS - DESIGN CHANGES AND MODIFICATIONS SALP REPORT:
"The design change and modification program shows a lack of continuity (NRC Inspection Report Nos.
81-12 and 82-11) and an apparent failure to consistently document adequate completion of design change and/or modification packages.
Th e NRC identified problems in this area, including a large backlog of incomplete design change packages, a definite lack of communication between the s ite personnel and SCE projects personnel, a poor document control system (multiple files and identifiers for a single project), a lack of updated drawings, no individual responsible for tracking the packages (especially to close out),
and a poorly conducted review and approval system...
"...Ta e board again feels that the pressures of Units 2 and 3 have diverted middle-management attention and resources away from Unit 1.
Ta e implementation o f the revised design change and modification controls will be examined in detail."
RESPONSE
Tae SALP Report characterization of dais area is inconsistent with the referenced NRC inspection report (81 -12) wh ich s tate d, "... th e inspec tor concluded that, to the extent they had been completed, all the above design changes appeared i
to have been performed in accordance with Station l
Orde r... and Technical Specification I
requirements".
Tae SALP notes "a large backlog of incomple te des ign change package s".
It would no t be unexpected that, given the plant s tatus, a large backlog of design changes would exis t and therefore be in an open (incomplete) s tatus.
Most design changes document betterment of Unit 1 rather than correction of deficiencies.
Th ere for e, a large number of outstanding design l
changes is not necessarily indicative of a problem.
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- It should be noted that the second inspection (82-11) did no t include interviews of Unit 1 Project personnel who are responsible for performing the majority of the design changes.
The " poor document control system" nas been replaced by the Unit 1 Proj ec t computer based file s ys tem, which now cross-references required file identifiers electronically, thereby improving indexing and retrieval speed.
A similar type compute r system is being developed by the Station to electronically track PFC's and other data.
In evaluating "a definite lack of communication between the site personnel and SCE projects personnel", we believe this interaction has been s trengthened by the creation of the " Integrated Outage Management Team" in February 198 2.
Le Station has es tablished a Plant Be tterment/
Re tro fit Design Section in the Technical Department with the responsibility of interfacing with Projec t personnel and processing Proposed Facility Ch anges (PFCs).
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In addition, a position (Manage r, Proj ec t Suppor t) has been created, reporting directly to the Station Manage r, wnos e sole function is to provi~de
. coordination and management representation between th e Station and the Proj ec t.
To correct the " lack o f updated drawings", a conprehensive multimillion dollar drawing verification program is being conducted.
Th is program entails a physical walkdown of selected sys'.em (on a prioritized basis), comparing them to tha drawings.
Contrary to the SALP s tatement that "no individual (is) responsible for tracking the packages", each Project cons truction work package has an assigned engineer who is responsible for tracking and closeout.
Each PFC has an assigned Station Ehginee r. respons ible fo r tracking and closeout.
i What S ALP characterized as "a poorly condu'eted review and approval system" has been substantially improved by enhanced procedures and training in ta is are a.
Each change is reviewed by the On-Site I
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Review Committee (OSRC) prior to implementation.
A Construction Safety Evaluation is performed prior to making physical changes.
In reviewing the QA program and OSRC which comprise a major portion of the company's review and approval sys tem, the NRC spent 157 manhours and identified no items of noncompliance or deviations.
The classification of this area as a Category 3 appears unjustified in view of the above.
We recommend that t,his functional area be rated as a Category 2 based on the review of the information abov e c -
V1.
'SECTION Ih.J - PERFORMANCE ANALYSIS - QUALITY ASSURANCE 4
'SALP REPORT:
"The Board recommends tha t s ite managenent. develop -
a permanently workable solution for resolving internally identified corrective actions in a time ly manne r."
RESPONSE
A " permanently workable solution for resolving internally ide'ntified corrective actions in a timely manner" has been in place since March 1982 and is maturing rapidly.
Over the second part of
- the reportini period, there was a 67% increase in the number o f CARS received per month, and while the number awaiting responses doubled during this period, the percentage of CARS overdue was cut in half.
Th is improvement in our performance should be reflected in the NRC Assessment in this area.
4 Our commitment to improvement in the program to resolve internally ' identified corrective actions is demons trated by the creation, in November 1981~,
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of the Configuration Control Organization within the Station Staff.
The new organization is charge d, among o ther things, with die
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responsibility to provide for promp t, high quality j
response to CARS received by the Station.
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?'w NRC Evaluation of the-Lijenhe's Response c:
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n Draft NRC SALP. Regrt I.
Section IV.A - Performance Analysis -1bant Operations 1-The licensee's response to this functiona%b brea suggssts a s$aeSat narrower :
scope to the activities which constitute Plant Operations than d'oes the
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NRC. The wider-scope considered by'N'RC includes, in additioMtc<oyerator ?
,4 performance, the performance of plant systems and significant event's which impact the safety of operations. Th1s, NRC'.s SALP evaluation of' Plant Operations includesbothequipmentmalfunctionsl(e.g'.,SdfqthInjectionSyste'mInoperability' LER 82-20) and plant casualties- (e.g., Dies'el Gu.ner'atorL Fire-LER 81r17).
g The licensee has objected to the characterizationSf LERs 81'-F7 'ahf B2-20 l
as adverse to P1 ant Operations;' stating'thatyneither wac:causallf linked to operator action or performance, and that, operator"~actfun was scompt and '
appropriate'. The NRC appraisal of this functional' area *wmnot critical of the performance of ' licensed operators in either of the oc'currences cited.
TheNRCconcursthatthediscussionregardingdesign;inthePikntOperations area, should have more properlyLbeen included in the functionah area of Design Changes and Modifications.
In addition, the NRC agrees'that-the s
statement " numerous apparent seismic' design deficiencies" issirf error in that no specific deficiencies have been" identified regardihg c6mpliance with the NRC approved original design bashs'df the plant.
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n The NRC draf t SALP report did not imply that'the attDludes of f Ui ci ate T
and Site Management were " casual" with respedt' to procedure corpUance.~
The NRC draft SALP report provided three examples which rssulted t'roin the failue.e, by operations personnel, to observe procedural ' precautions.
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addition, the NRC draft SALP report, in Table 5 on page 33, identifies thirteen
. enforcement actions and two-LER's during,the appraisal period which'reculted>
from the failure of plant personnel to fdliow written procedures. Thes,
- the SALP board's finding was that personnhl,iwho are required to follow' procedures in the performance of licensed activities, demonstrate "an occasio,nally casual approach to procedural compliance."
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The NRC recognizes the considerable effort by the licensee'.to increase the size and improve the effectivenest of the management, administrative and technical support staff at the San Onofre site as well'as the corporate.
4 office. The effectiveness of such efforts by the lic'ensee will be fur 3he'r, evaluated during future SALP evaluations. We do not feel, howeW r, that
i the licensee's response in this functional area constitutes.a sufficient
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basis to change the NRC's performance classification to Category'2.,
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O II.Section IV.B - Performance Analysis - Radiological Controls The$RCacknowledgesthoseactionstakenbythelicenseetoimproveperformance in this area..However, the NRC considers that most of these actions were taken largely in response to NRC inspection findings, not as a direct result of licensee internal evaluation and audit initiatives. The effectiveness of the licensee's corrective actions will be examined during future inspections and reflected in future SALP evaluations. We do not concur with the licensee's recommendation that the performance classification for Radiological Controls be changed to Category 2.
III.Section IV.L - Performance Analysis - Design Changes and Modifications The NRC has reviewed the licensee's response to this functional area and again acknowledges that the licensee has taken several significant actions to improve performance.
The licensee's response indicates that each Project Construction Work Package has an assigned engineer who is responsible for tracking and closecut, and that each PFC has an assigned Station Engineer also responsible for tracking f A' and closeout.
Discussions between NRC inspectors and licensee personnel
> <at the San Onofre site during the SALP appraisal period led our inspectors to conclude that cognizant personnel did not appear to be aware that each work package or PFC did, indeed, have an assigned engineer responsible for 4
tracking and closecut. This was the basis for the SALP board's statement that "no individual (is) responsible for tracking the packages."
A recent inspection conducted at SONGS-1 indicated that similar problems still exist in the area of communications between. organizational entities responsible for the generation, installation and closecut of design change work packages and PFC's.
This recent finding is documented in NRC Inspection
'g Report No. 50-206/82-34 The NRC does not concur with the licensee's recommendation that the performance classification for Design. Changes'and Modifications be changed to Category 2.
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