ML20033E296
| ML20033E296 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/20/1990 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| IEIN-88-043, IEIN-88-43, NUDOCS 9003120204 | |
| Download: ML20033E296 (5) | |
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Southem Calitbmla Edison Company 1
23 PARKER STRECT IRVINE, CALWORNIA 92788 HAROLD S, RAY TE L E SHONC
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' February 20, 1990 s
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I Mr'. Roy Zimmerman,= Director Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission 1450 Maria' Lane, Suite 210 l-
. Walnut Creek, California 94596-5368 J
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Dear Mr. Zimmerman:
Subject:
EDocket Nos.-50-206, 50-361 and 50-362
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Corrective Action Program 30 San Onofre Nuclear Generatina Station L
1989 forwarded NRC Mr. Faulkenberry's letter of December.26,
-Inspection Report:No.~50-206/89-31:and an associated Notice of L,
Violation'- (NOV)..- Southern California Edison (SCE) responded to the NOV in my letter dated January 25,'1990.
I indicated in the L
E Eletterithat'SCE would respond separately to comments in the-L
.. inspection report concerning our. program for handling corrective.
actions.
We<have: reviewed the NRC comments carefully, and.this b
letter' addresses their. generic implications and the actions we.
l haveltaken.,
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_ LThe NRC report summarized' conclusions from.the inspection <as
'follows.
(Item numbers have.been added for clarity of. response.)
g L"A's'a result of this inspection, the_ inspector concluded-
/that there:were;significant deficiencies in the licensee's
= program for handling corrective' actions.
In particular,
. problems _werefidentified involving (1)-inadequate
' dissemination of.information about. component problems to the ac organizations. responsible-for evaluations, (2) resolution of I
-root ~cause determinations and (3) submission of supplemental.
1, licensee event reports'(LERs), (4) review of component
' failures-for. potential 10 CFR 21' applicability,1(5) follow-1through on: commitments made in LERs, (6)~ oversight of
~ outstanding items, and ' (7) review of component failures for
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generic implicat: o l' gg g We have addressed many of these items in separate correspondence, however this' letter'provides an integrated response?and: discussion!ofithe actions we have taken.
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W, Mr. Roy Zimmerman
_/2ber*W February _20, 1990 1
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'(1):
Inadesunto dissemination of information about~connonent nroblems to the oraanisations resnonsible'for evaluations =
This problem was described in the inspection report as follows:
"The-COPE procedure had a requirement for personnel to-l provide ~ pertinent information concerning equipment failures to the COPE list. However, there was no specific requirement for interfacing programs such as the NCR or LER programs to make input to the-COPE program, and it was not apparent that j
L all personnel knew to provide information to the COPE
- program, i
The experience review program did not get the word disseminated ~to appropriate personnel regarding Information
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Notice 88-43.-
This was apparently due to the fact that ASCO E
solenoids.were of a different'model than those discussed in L
the Notico, even though both models involved the use of lubricant on normally energized solenoids.
p The EQ program did'not~have anything in the file on ASCO solenoids.
This was apparently due to the fact that NCRs-l-
L for valve' failures were not supplied to the EQ program in the 1987-88 time" frame.
(The inspector considered ~that it might be worth reviewing old NCRs to see if other potential
- input to the EQ program might exist.
This.was discussed l
with the licensee.)"
COPE Process As discussed in our January 25, 1990 response to the NOV, in establishingLthe Control Of Problem Equipment (COPE) program, we L
had-judged that theLneed to include equipment on the COPE List
.would be recognized, and action taken, without the need for
-specific requirements in the procedures'for other-programs.
Such requirements are being added to procedures for the NCR' program.
Similar requirements are also being included in procedures which are under development for the Root'Cause program.
This program is being revised in accordance with my letter to Mr. Jess Crews dated October 27, 1989.
Based on these additions h
to the NCR and Root Cause programs, we conclude that similar-requirements should not also be added to LER program procedures.
1 ISEG Reviews O
R As indicated in the inspection report, the Independent Safety. Engineering Group (ISEG) recognized that the specific
,h models of solenoid valves addressed by IN 88-43 were not in use L
at San Onofre.
In addition, ISEG.was aware of-the ongoing root L
cause evaluation for the ASCO solenoid failures which had been Lv experienced at San Onofre..This evaluation included discussions
.with the manufacturer in which he did not agree with the cause of the failures postulated by SCE.
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Mr. Roy Zimmerman
,ySII February 20, 1990 It should be noted that SCE had taken effective corrective action to resolve what it believed to be the cause of the failures, including those addressed by IN 88-43, (i.e., removal of the offending lubricant), except for the one valve which had been added to the plant as part of a modification and which subsequently failed.
Based on the action already taken, ISEG did l
not consider that additional dissemination of information from IN 88-43 was;necessary.
Dissemination of information from industry experience reviews must.be managed in order to.be useful.. The enornous volume of-such information cannot simply be forwarded to all potential users, and the action taken by ISEG in this instance.
.was appropriate.. However, we have initiated a program to provide information to all interested personnel on IE Notices, on INPO i
SERs and SOERs and on other industry experience feedback using a
.j widely available, on-line database.
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This program allows key word searches and provides a means l
for.those dispositioning NCRs and performing root cause l
assessments to rapidly access this information.
This capability i
is nearly complete for recent. items (1987-1990).
By J
October 1990, information on all presently available industry l
reviews will be input into the system and available for use.
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.Upon full availability of this information program, the NCR and Root Cause programs will be amended to include guidance for its j
utilization.
EO Proaram
' The' procedures for the NCR-program will be. revised.to
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require that, if the NCR involves EQ program equipment, then the
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NCR'will be so identified and information provided.to personnel responsible for the EQ program.
In order to ensure that previous
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NCRs are also reviewed in this respect,.an ongoing program to review and validate EQ packages for.all three-SONGS units-will=be revised to include a review of NCRs from the inception of the EQ-y programLto the present.
The ongoing EQ review program is l
L scheduled to be completed in.the first quarter of 1991.
(2). Resolution of root cause determinations l
The problem was described in the inspection report as j
L-follows:
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"An NSG review (on August 5, 1988) of procedure SO1-I-8.171 j
L' identified the need to revise the procedure, and requested a response within 30 days.
However, the procedure was not revised to reflect the NSG's comments until September 7, 1989.
This was more than a year later.
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Mr. Roy Zimmerman
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February 20, 1990 The NCR procedure did not have any specific provisions to ensure timely resolution of root cause determinations."
Delinquent responses to comments and recommendations originated by groups within the Oversight Division has been recognized, as discussed ir my letter to Mr. Scarano dated December 20, 1989 concerning a self assessment of our respiratory protection program.
Consistent with the corrective action discussed in that letter, NSG action requests are now formalized w
in corrective action documents and tracked to resolution on a more timely basis.
The NCR procedure will be revised to establish a required root cause resolution date at 3 months following the NCR validation date.
Also, as discusbad in my letter to Mr. Crews referred to above, revisions to our Root Cause program include the establishment of a dedicated program oversight group to ensure appropriate and timely determinations.
(3)
Submission of gucclemental Licensee Event ReDorts (LERs)
The inspection report identified the fact that a number of supplemental LERs were delinquent with respect to their initially forecasted submittal dates.
The procedure governing the process for LER submittals will be revised by March 15, 1990 to include z
the requirement to identify who is responsible for timely development of each supplemental LER and the action to be taken in the event that required information is not available when initially forecast.
As discussed in my letter to Mr. Dennis Kirsch dated November 21, 1989, additional management attention han been devoted to providing visibility and timely response to NRC-related commitments, including supplemental LERs.
(4)
Review of component failures for Dotential 10 CFR 21 applicability With respect to the ASCO solenoids, as discussed in my January 25, 1990 response to the NOV associated with failure of CV-304, SCE became engaged in a protracted period of attempting to obtain concurrence from the vendor as to the cause of the failures previously experienced.
In submitting a report in accordance with 10 CFR 21, a licensee must make reasonably certain that failures are actually due to a component deficiency and not due to circumstances related to incorrect installation, maintenance or use.
When, as in this case, a vendor denies the existence of a component deficiency, then the burden to establish that one does exist is increased.
SCE regularly considers the need for reporting deficiencies in accordance with 10 CFR 21.
However, in order to emphasize
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'Mr.nRoy_Zimmerman M
February 20, 1990' thisirequirement, explicit provisions will be included in the 1
LER,-NCR:and Root Cause program procedures.
(5)- follow-throuah on commitments made in LERs L
P Action being taken to ensure follow-through on commitments
-made in LERs is described in my letter to Mr. Kirsch referenced above.-
(6)
Oversicht of outstandina items
-The SCE audit program is being' revised to provide for-
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periodic; audits of outstanding items in categories such as NCRs, LE's, Corrective Action Recuests, Maintenance Orders, Site R
Problem Reports, Significant Operating Experience Reports and Problem Review Reports.
Management attention.will thereby be
-directed regularly to the status of these items.
(7)
Review of component failures for Generic implications i
My letterfto Mr. Crews referenced above describes revisions being madeito our Root Cause program.
These revisions will include review of component failures (including those reported-as industry experience) for generic implications, under the cognizance of the Manager of Safety Engineering.
CONCLUSION 1
The foregoing is provided to summarize SCE's evaluntion of the results summarized in Inspection Report 89-31.
If you have any questions.or comments, or if you would like additional information, please let me know.
Sincerely, 3
o cc:
JohnLB. Martin, Regional Administrator, Region V C..W.
Caldwell, NRC Senior Resident Inspector, San Onofre I