ML20052B396
| ML20052B396 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/13/1982 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20052B387 | List: |
| References | |
| NUDOCS 8204300371 | |
| Download: ML20052B396 (3) | |
Text
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ITD h5 Southern Cailfornia Edison Company
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,,g April 13, 1982 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Attention:
Mr.
R. !!. Engelken Regional Administrator DOCKET No. 50-206 SAN ONOFRE UNIT 1
Dear Mr. Engelken:
Your letter of March 19, 1982 forwarded IE Inspection Report No. 50-206/
82-05 and a Notice of Violation resulting from the February 22-26, 1982 routine operations inspection by J. W. !!ornor.
Enclosure (I) of this letter provides our response to the Notice of Violation contained in Appendix A of the subject report.
I trust the enclosure responds adequately to all aspects of the Violation.
If you have any questions or if we can provide additional information, please let me know.
,/
1982.
Subscribed on this
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WM. R. HORSLEY By
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T. Papay'
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hsINNLYsNurNy Vice Presiden Southern California Edison Company My commiwon boires Dec. 16.1983
__ge Subscribed and sworn to before me this /
day of br[/
, 1982.
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820430 037/
Notary Public in andAAr the County of Los Angeles, Statv of California Enclosure I cc:
L.F. Miller (NRC Site Inspector - San Onofre Unit 1)
e ENCLOSURE I RESPONSE TO ITEM A (continued)
Additional maintenance personnel were assigned to the Planning Pepartment in November,1981 as an interim measure to better ensure the proper completion of maintenance orders until per-manent maintenance planners can be procured. This has resulted in a threefold increase in the number of personnel in the planning section directly involved with the review and preparation of maintenance orders.
Maintenance Order Number S05248 was not subsequently rewritten since the associated work had already been finished and the completed work package filed in the Corporate Documentation Management repository.
2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMPLIANCE Unit 1 procedure S01-I-1.4, " Maintenance Order Preparation, Use, and Scheduling", is being prepared and will be issued by July 1, 1982. This procedure incorporates a Maintenance Order Tracking Log which will require Quality Assurance, Engineering, and Supervisor of Plant Maintenance review of each maintenance order before it is assigned to a Maintenance Foreman. The guidance contained in S01-I-1.4 will be sufficient to preclude the issuance of an incomplete maintenance order.
The Maintenance Section will continue to interview for permanent maintenance planners until all required positions have been occupied.
3.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on February 27, 1982 when all San Onofre Nuclear Generating Station Unit 1 Maintenance Planners were instructed on the proper use and interpretation of Station Order S-M-103, " Maintenance Order".
.~
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ENCLOSURE I Response to the Item of Non-Compliance identified in Appendix A to IE Inspection Report 50-206/82-05.
ITEM A "The Code of Federal Regulations, Title 10 (Energy), Part 50 Appendix B, Criterion II requires holders of operating licenses to have a Quality Assurance Program; and Criterion V requires that 'Activi-ties affecting quality shall be prescribed by documented... procedures...
and shall be accomplished in accordance with these... procedures....'
The licensee's procedure, S-M-103, ' Maintenance Order', Revision 4, describes the administrative controls applied to both safety and non-safety related maintenance.
Section 6.3.2 of Procedure S-M-103 specifies the information that must be entered on the Maintenance Order Form PSSO 430. This information includes the type of approval needed to initiate the work (' clearance' or other), the need for retesting, testing of the redundant train, an Open Flame Permit, a Radiation Exposure Permit, QA/ QC and engineering evaluation.
Contrary to the above, Maintenance Order Number S05248, dated September 25, 1981, utilized for safety-related maintenance, did not include any of the above information. A similar violation occurred during the previous inspection of the licensee's maintenance program in February 1981 (Inspection Report 50-206/81-05)."
RESPONSE
1.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED On February 26, 1982 the Acting Station Supervising Planner issued, by memorandum, specific instructions to all San Onofre Nuclear Generating Station Unit 1 Maintenance Planners concern-ing the preparation of maintenance orders. These instructions emphasized the thorough completion of the Requirements and Preparations sections of the maintenance order form by the planners prior to the maintenance order's issuance.
The Acting Station Supervising Planner conducted a period of instruction for all Unit 1 Maintenance Planners on February 27, 1982 on the use and interpretation of Station Order S-M-103, " Maintenance Order", which is the source document for the preparation and use of maintenance orders.