ML20052B489
| ML20052B489 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/26/1982 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| NUDOCS 8204300488 | |
| Download: ML20052B489 (73) | |
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April 26,1982 Docket Nos. 50-206
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2 *%gS /Sgg j0 Southern California Edison Company 4% ar P. O. Box 800 2244 Walnut Grove Avenue E
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Rosemead, California 91770 E
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Attention: Dr. L. T. Papay, Vice President
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Advanced Engineering 1
Gentlemen:
Subject:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
Transmitted herewith in Enclosures 1 and 2 are copies of our reports " Regional Perfomance Evaluation Report - San Onofre Unit I and Southern California Edison Company" and " Regional Performance Evaluation Report - San Onofre Units 2 and 3."
These evaluations cover the period from May 16, 1980, to June 30,1961, for San Onofre Unit 1 and from June 1, 1980, to June 30, 1981, for San Onofre Units 2 and 3.
The findings cf these reports were discussed with the management of the Southern California Edison Company at the corporate offices on September 1,1981.
Our assessment of your performance in each functional area, and overall, is categorized in accordance with the criteria given in Enclosure 3.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2 Title 10. Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC's Public Document Room.
i Sincerely, N
R. H. Engelken Regional Administrator
Enclosures:
1.
Regional Performance Evaluation bec w/ enclosure:
Report - San Onofre Unit 1 and DMB/ Document Control Desk (RIDS)
Southern California Edison Company State of CA (Johnson)
(NRC Inspection Report No. 50-206/82-12)
L. Miller 2.
Regional Performance Evaluation Report -
A. Chaffee San Onofre Units 2 and 3 (NRC Inspection D. Kirsch Report Nos. 50-361/82-16 and 50-362/82-07)
J. Hornor 3.
Criteria for Rating of Licensee Performance G. Zwetzig D. Sternberg 32043064%
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NRC Inspection Report No. 50-206/82-13 DESIGNATD ORIGINAL Certified By ENCLOSURE 1 REGI0tlAL PERFORMANCE EVALUATION REPORT SAN Ofl0FRE UNIT 1 AND s
SOUTHERN CALIFORNIA EDISON COMPANY 1-1
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REGIONAL PERFORMANCE EVALUATION REPORT I.
UTILITY PERFORMANCE EVALUATION
. REGION V Utili ty:
Southern California Edison Facili ties:
San Onofre Nuclear Generating Station Unit 1 (0perating)
Unit 2/3 (Construction)
Appraisal Period: See Section II, Licensee Performance Evaluation Review Board Members:
See Section II, Licensee Performance Evaluation Areas of Good Performance The utility is generally responsive to NRC regulations and findings.
The utility has the capability to organize and maintain a sustained effort to solve difficult and complex technical problems.
The quality assurance organization has the respect of the other line staff organizations within the utility and appears to be doing a good job.
Large resources have been allocated to training; a comprehensive training program has been developed and mostly implemented.
This type of training program could prove to be a model for the industry.
Areas Where Improved Performance is Warranted Communication problems have existed during this period between the licensing group in the corporate office and the Unit 1 staff in the -
area of licensing commitments.
The licensee has reportedly taken some corrective action in this area.
Health Physics at Unit 1 is an area of significant weakness.
The extent of the problem has been defined but much work is still required to strengthen the existing fragile program.
The area of security at Unit 1 needs additional attention to prevent the frequent lapses which'have been cited.
Preparations for large maintenance and design change work needs to be more complete prior to commencing the work.
Personnel staffing needs. to be improved, particularly plant operators, in order to support training and to minimize the use of overtime to support a good mental attitude of licensee employee's.
1-2
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Comparison Between Reactor Sites Unit 1 is an operational plant.
Performance in this area has been less than the performance on ~ Units 2 and 3 which are in constructional and preparational phases.
Overall Evaluation It appears that the utility has shifted much of its talent to Units 2 and 3 which has reduced performance at Unit 1.
However, overall the utility has done a. satisfactory job.
The most notable weak area is health physics and the most significant strengths are Quality Assurance and training. Other problem areas are staffing and control of major jobs (e.g., repeated boron dilutions, Steam Generator sleeving problems, and overexposures). Also, i
some internal communication problems exist.
Overall, however, we rate the utility as Category 2.
Approved:
R. H. Engelken Regional Administrator l
t r
l-3
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE II.
LICENSEE PERFORMANCE EVALUATION Facility:
San Onofre Nuclear Generating Station Licensee:
Southern California Edison Unit Identification:
SONGS-1 Docket No.
License No./Date of Issuance Unit No.
50-206 CPR-13/ March 27, 1967 1
Reactor Information:
Unit 1 Unit 2 Unit 3 Unit 4 NSSS Westinghouse MWt 1347 Appraisal Period:
May 16, 1980 - June 30, 1981 Appraisal Completion Date:
Review Board Members:
A. E. Chaffee, L. F. Miller, S. J. Nowicki, D. W. Schaefer, W. J. Wagner, G. P. Yuhas, and T. Young.
Overall Licensee Management Evaluation The licensee's performance in this period was marked by areas of considerable strength and weakness.
The areas of health physics and safeguards were notably below average resulting in the majority of the enforcement citations and a large civil penalty.
The areas of " maintenance" and " design changes and modifications" were also, to a lesser extent, below average. All four of these weak areas can be traced to weakness in management controls.
In each area, the management controls in effect did not prevent the problems i
encountered, and NRC action was required to identify and initiate proper controls.
The licensee did, however, readily recognize the shortcomings addressed by the NRC and took prompt action to initiate better programs in the identified areas.
In fact, the licensee's most notable strength is his responsiveness to NRC concerns.
Two other significant strengths are the Quality Assurance Program and the Training Program; both are well above average.
Both these areas reflected significant management commitment.
Only staffing in the training program appears to be a potential problem.
Two other functional areas, " Refueling Operations" and " Surveillance and Inservice Testing," were also above average.
Overall, the licensee's performance is rated as just less than Category 2.
j 1-4
I i
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE III. PERFORMANCE ANALYSIS A.
Plant Ooerations 1.
Analysis The Resident Inspector conducted daily inspections during the evaluation period.
Three items of noncompliance were identified:
(a) Failure to observe a procedural limit on reactor coolant system chloride concentration.
(b) Failure to properly secure spent resin transfer valve lineup following spent resin transfer.
(c) Failure to have a procedure implementing the approved startup secondary chemistry program.
In addition to these difficulties, the facility has had to require extensive overtime by all operators.
This has resulted in very long working hours for the operators, and gradual attrition.
During June 1981, secondary chemistry was not tightly controlled due to the deficiencies in the secondary chemistry program.
Strong points in this area include a thorough revision of all operating and emergency procedures to reflect actual practice and ANSI N 18.7 requirements.
Shift supervisors are exceptionally cognizant of their safety responsibilities.
The training program has steadily improved to an above average level..
Supervisory and management response to revised regulatory requirements has been positive.
l 2.
Conclusion Performance is rated as Category 2.
l 3.
Board Comments The board recommends no change in inspection effort.
l l
l 1-5
SYSTEf4ATIC ASSESSf4Ef1T OF LICEftSEE PERFORf4AflCE B. Refueling Operations 1.
Analysis The Resident Inspector conducted several inspections of refueling and operations.
flo items of noncompliance were observed in this area.
The licensee staff and the contractor personnel (Westinghouse) appeared well qualified, knowledgeable, and careful during the refueling.
2.
Conclusion Performance was rated Category 1.
3.
Board Comments The board recommends no change in inspection effort.
C. f4aintenance 1.
Analysis During this period, three regional-based operations' inspections, two regional based construction inspections, and several resident inspections per month were performed in this area.
Three items of noncompliance were identified:
(a)
Failure to follow a maintenance procedure.
(b) Failure to obtain proper clearance prior to performing work on safety-related equipment.
(c)
Failure to follow the procedure for post maintenance leak test.
In addition to these items, several instances of corrective maintenance occurred which had to be repeated.
These i::cluded the containment personnel air lock failure, the south charging pump seal water line repair, the removal of desiccant from the instrument air system, and weld repair of the water box of the component cooling water heat exchanger E-208.
In addition, the repair of the steam generator tubes by sleeving was a large and complex maintenance project.
The significant problems which occurred during this repair included:
repeated 1-6
SYSTEMATIC ASSESSMENT OF LICEllSEE pERFORMAllCE uncontrolled boron dilution of the reactor coolant system; temporary loss of foreign material control in the reactor coolant system piping; radiation protection program shortcomings (noted elsewhere in this report).
These problems have been resolved.
However, they point to a more general problem of some lack of preparation before undertaking large jobs.
Other areas of lesser maintenance concern are snubber failure, component cooling water heat exchanger fouling due to marine growth, and exceeding the qualified life of nonmetallic components of the recirculation control valves.
Also during this period, the licensee has been devcloping a comprehensive maintenance program which is to be completed in August 1981.
This has necessitated the writing of more than 150 additional specific maintenance procedures.
In addition, the administrative controls for this maintenance program are being further developed.
This comprehensive maintenance program includes preventive, corrective, surveillance, and general maintenance.
The development of these procedures has been contracted to Nuclear Utility Services.
The maintenance department has been reorganized during this period.
This has markedly improved the ability of the main-tenance department to systematically identify and perform required maintenance in a controlled, safe manner.
The performance in.this area is improving, but the maintenance organization suffers from a history of maintenance which was primarily corrective rather then preventive, and informal rather than systematic.
Examples of this range from the large number of chronically leaking valves in control systems to the desiccant contamination of the instrument air system to the degradation of steam generator tubes.
Two construction inspections reviewed the circumferential weld repair to the main steam piping.
The inspection revealed above average performance in this area.
2.
Conclusion Overall performance is rated as Category 3.
3.
Board Comments The board recommends no change in inspection effort if the new maintenance program appears adequate.
1-7
~ SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE D. Surveillance and Inservice Testing 1.
Analysis (a) Four regional-based operations' inspections were conducted in this area.
No items of noncompliance or deviations were noted.
Inspection 80-18 reviewed surveillance of pipe supports and restraint systems.
It was noted that documentation of corrective actions taken and inoperability criteria were not clearly addressed.
The licensee agreed to clarify his procedures.
Inspection 80-20 reviewed periodic testing of the diesel generators.
No items of concern were detected.
Inspection 80-30 reviewed calibration of components and equipment associated with safety-related systems.
The inspector noted that the licensee is revising his procedures to allow for better analysis of "AS FOUND" conditions on plant operation.
Inspection 81-14 reviewed local leak rate testing prior to an integrated leak rate test.
No items of concern were detected.
Also during this period, a comparison of the Standard Technical Specifications (NUREG-0452, Rev. 3) and San Onofre Unit 1 Technical Specification (Amendment 56) was conducted and documented. This was initiated due to concerns over lack of proper maintenance and surveillance in the Salt Water Cooling System, which contributed to a
" loss of salt water cooling" event.
This event was discussed during the last SALP review.
The comparison was initiated to help evaluate the potential extent of l
this type of problem.
The comparison showed some 101 surveillance items that are not covered by SONGS Unit 1 i
Technical Specifications.
It appears that all of these surveillance items are potentially applicable to this unit.
This comparison has been forwarded to IE Head-quarters for review and action.
Also, a copy of this comparison has been given to the licensee for his It is expected that many of these surveillance I
use.
items are done by the licensee even though not included in Unit 1 Technical Specifications.
1-8
2 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (b) The Resident. Inspector conducted weekly inspections of routine surveillances which were performed, and reviewed licensee event reports of inservice testing exceptions.
No items of noncompliance were observed._ Several licensee event reports concerning weld defects, defective or missing pipe supports, and inoperable hydraulic shock suppressors were received.
The licensee discovered most o'f these flaws as part of '
the inspection required by IE Bulletins 79-13, 79-02, and 79-14.
Surveillance testing procedures were ccmprehensively updated to the requirements of ANSI N 18.7-1976 during this period.
2.
Conclusion l
Performance is rated as being Category 1 in this area.
I 3.
Board Comments The board recommends no change in inspection effort.
E. Personnel, Training, and Plant Procedures 1.
Analysis Three regional-based operations' inspections were conducted in j
this area.
No items of noncompliance were identified.
i During this cycle, the licensee has made extensive changes to -
his training program. A new training organization headed by an offsite manager at the same level as the plant manager has been completed.
This new training organization has defined an i
extensive training program which includes'the construction of a separate training facility adjacent to the site.
This facility will include a simulator for Units 2 and 3, classrooms, and equipment mockups. for surveillance and maintenance training.
The major problem encountered in this area has been the staffing -
j of this organization.
The licensee has great difficulty maintaining the manpower to provide the training.
In addition, due to the shortage of operators, a lot of training is done on overtime which tends to reduce its effectiveness.
In the area l
of procedures, the regional inspections identified no items of concern.
In the area of personnel, the licensee has had great i
difficulty in maintaining proper onsite staffing.
4 1-9
. ~... -..
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 2.
Conclusion Overall performance is rated as being Category 2.
The subarea
" training" is notably above Category 1.
3.
Board Comments The board recommends no change in inspection effort.
F. Fire Protection and Housekeeping 1.
Analysis Four regional-based inspections and daily resident inspections were conducted in this area.
One deviation was identified (Inadequate Housekeeping).
The four regional inspections focused on the completion of the fire protection modifications required by Amendment 44 to the Unit's license.
These inspections revealed no modifications that were unsatisfactorily completed.
The daily resident inspection identified re-occuring inadequate housekeeping in areas where modifications were being performed.
The resulting deviation resulted in improved licensee performance in this area.
2.
Conclusion Performance is rated as being Category 2.
3.
Board Comments The board recommends no change in inspection effort.
G. Design Changes and Modifications 1.
Analysis (a) Five inspections by regional-based operations inspectors were performed in this area.
No items of noncompliance were identified.
During this period, the licensee has revised several procedures in this area to provide more detailed control.
The level of activity has been very high, in part due to a large number of Three Mile Island requirements.
One inspection revealed approximately 81 outstanding safety-related design changes.
The licensee is aware of this large backlog and is attempting to complete these expeditiously.
Another major modification area is fire protection.
Many modifications in this area have been completed during this review period.
1-10
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (b) The Resident Inspector and regional construction inspectors conducted frequent inspections of the principal modifications in this period:
steam generator sleeving project, automation of auxiliary feedwater system, containment isolation system modification, vital bus addition, boric acid heat tracing system overhaul, fire protection system additions, and post accident shielding construction.
Several items of noncompliance or deviations were identified:
(1) Failure to properly review and approve a required procedure for sleeving project.
(2) Failure to obtain proper clearance prior to performing work on safety-related equipment.
(3) Failure to provide adequate cable separation for new auxiliary feedwater instrumentation panels.
(4) Failure to properly radiograph mechanical penetration added for sampling.
(5)
Improperly installed anchors on auxiliary feedwater instrumentation panels.
(6)
Inadequate review of test procedure (deviation).
By way of mitigation of this performance, it is noted that the mistakes observed occurred during a period of intense construction activity.
It was evident that the full resources of the utility were spent on this effort, as well as those of a host of contractors.
Only one of the items noted (1, above) concerned the work of the sleeving project.
The remainder was work associated with TMI modification, performed by the Engineering and Construction project management department of the licensee.
2.
Conclusion The performance is rated as being Category 3 due to the frequency with which items occurred.
3.
Board Comments The board recommends no change in inspec' tion effort at this time.
~
1-11
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMAi4CE H. Radiation Protection 1.
Analysis In early April 1980, the licensee was in the process of planning for a routine refueling and minor maintenance outage which they expected to involve about 200 contractors, when a rapid increase in steam generator tube leakage forced premature shutdown.
The radiation protection program was overwhelmed.
Two reactive inspections were performed in April to review personnel contamination incidents and allegations of poor radiation safety practices.
The first inspection of this SALP review period was the Health Physics Appraisal.
The Health Physics /
misal inspection conducted May 19-30, 1980, identified several s. iificant weaknesses in the licensee's radiation protection p.ogram including:
insufficient health physics personnel at the plant and corporate level, inadequate radiation protection training and retraining program, shortages of portable survey instruments, ineffective management of solid radioactive wastes, failure to implement a formal ALARA program, and deficiencies in health physics related facilities and equipment.
This inspection, although not focusing on compliance, identified an instance of failure to properly label a container of licensed material.
These findings were presented orally to high level licensee representatives at the conclusion of the inspection and transmitted formally on August 15, 1980.
In the interim, continual deterioration in the radiation protection program occurred as a function of the increasing unplanned workload.
In mid-June 1980, the Resident Inspector advised Region V of an apparent whole-body exposure in excess of regulatory limits.
A special inspection resulted in identification of three items of noncompliance:
(1) exposure of an individual in excess of three rem per calendar quarter; (2) failure to make an adequate evaluation of an individual's exposure; and (3) failure to adhere to a radiation protection procedure.
During July 1980, the Resident Inspector observed three instances of failure to adhere to radiation protection procedures which were cited as one infraction and two additional instances which were cited as a deficiency.
In August 1980, it became apparent that a major steam generator repair effort was about to be initiated by the licensee.
Region V conducted a special inspection to review the licensee's capability to provide adequate radiation safety for such a repair effort.
This inspection found that the licensee's planning did not appear adequate to accomplish the work, as scheduled, in a manner consistent with ALARA criteria, and in compliance with regulatory requirements.
A Management Meeting was scheduled 1-12
SYSTEMATIC ASSESSMEflT OF LICEflSEE PERFORMAf1CE for September 5, 1980.
While senior representatives of the licensee were attending the Management Meeting, activities at the site were not being adequately controlled with regard to handling a highly contaminated spent fuel shipping cask. As a result of the Management Meeting, an Immediate Action Letter (IAL) was issued on September 5,1980, detailing those actions f1RC considered necessary to provide adequatt radiation safety for workers involved in the steam generator repair effort.
In addition, the IAL required the licensee to resolve dosirnetry questions brought to their attention during the August inspection.
Region V Radiation Specialists conducted another special inspection later in September to verify conditions of the IAL and review circumstances surrounding handling of the spent fuel shipping cask.
This visit resulted in issuance of the October 2,1980 IAL confirming four specific actions to be taken by the licensee.
In mid-October another special inspection was performed to confirm that the licensee's actions had been effective in providing adequate radiological safety for initiation of the steam generator repair project.
This inspection found significant improvements had been made such that flRC was reasonably assured that the task could begin.
The inspection also documented those items of noncompliance resulting from inadequate evaluation of the steam generator radiation fields which lead to inappropriate personnel dosimetry resulting in 66 individuals exceeding the three rem per quarter limit between April and August 1980.
The inspection also found that failure to implement appropriate controls when handling the spent fuel shipping cask resulted in several items of noncompliance.
In addition, other items of noncompliance relative to the steam generator repair project were identified.
The findings of this inspection were transmitted to the Director, Office of Inspection and Enforcement, for action.
While the escalated enforcement package was being processed, another special inspection was conducted in mid-December to followup on the IALs and previous inspection findings.
l10 items of noncompliance were identified; however, several observed weaknesses were brought to the licensee's attention.
A routine radiation protection inspection was conducted in mid-January 1980 to followup on routine matters and previously identified problen areas.
flo items of noncompliance were identified. The inspector informed licensee management of apparent deterioration in the relationship between licensee and contractor radiation protection organizations.
On January 23, 1981, the Director, Office of Inspection and Enforcement, issued a civil penalty in the amount of $150,000 as a result of the personnel exposures of steam generator 1-13
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE entrants and the manner in which the licensee handled the spent fuel shipping cask.
In the licensee's February 17, 1981 response to the Imposition of Civil Penalties, they admitted each item of noncompliance, described their immediate and long term corrective action, and protested the imposition of civil penalty based on extenuating circumstances and their timely and effective corrective action to improve the radiation protection program.
On April 15, 1981, after careful consideration by NRC staff, an Order Imposing Civil Monetary Penalties was issued for $150,000.
The licensee subsequently paid the civil penal ty.
Routine inspection of transportation activities performed in early April 1981, noted significant improvement in the management of solid radioactive waste.
Weaknesses in control of radioactive materials inadvertently released from the restricted area were discussed.
In late April 1981, another special inspection was necessary to review allegations of unauthorized removal of contaminated tools and equipment from the restricted area.
The allegation was not substantiated; however, weaknesses in the control of materials leaving the restricted area were again brought to the licensee's attention.
In mid-May 1981, the licensee advised NRC that they had discovered low-level contamination of beach sand adjacent to the seawall.
A special inspection was conducted in early June 1981 to review the licensee's actions.
Insufficient information was available to determine compliance with respect to the cause of the contamination; however, the licensee's followup actions were considered consistent with ALARA criteria and regulatory requirements.
Nine inspections have been performed during the evaluation period:
Health Physics Appraisal (350 hours0.00405 days <br />0.0972 hours <br />5.787037e-4 weeks <br />1.33175e-4 months <br /> onsite); six special radiation protection inspections (339 hours0.00392 days <br />0.0942 hours <br />5.605159e-4 weeks <br />1.289895e-4 months <br /> onsite);
and three routine module inspections (116 hours0.00134 days <br />0.0322 hours <br />1.917989e-4 weeks <br />4.4138e-5 months <br /> onsite).
Fifteen items of noncompliance have been identified, a Management Meeting held, two IALs issued, and a substantial Civil Penalty imposed during this review period.
In the same period, the licensee conducted a major steam generator repair effort involving about 1,500 temporary maintenance personnel and 900 project support individuals at an exposure cost of 3,496 person-rem.
In response to identified weaknesses in the radiation protection program, the licensee has made numerous substantial commitments.
Several, such as increased health physics staff, improved radiation protection training, additional portable survey instruments, and improved solid radioactive waste management, have been accomplished.
1-14
a SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Throughout this arduous period, the licensee has relied heavily on contractor-supplied radiation protection support.
. ith the return.to. power, most of the contractor-supplied W
health physics expertise has left the site.
Chemistry and Health Physics have been separated, and a new site-wide Health Physics organization is being developed by a new Health Physics Manager. 'The corporate health physics position has not yet been filled by a licensee employee.
2.
Conclusion Performance is rated as being Category 3 during the evaluation period.
Significant improvements are being made.
However, NRC figion V remains concerned with the fragile nature of this situation.
3.
Board Comments The board recommends increased inspection effort in-this area to confirm the effectiveness of corrective actions taken and planned.
I. Environmental Protection 1.
Analysis 1
During the evaluation period, there has been no direct inspection i
of this area.
The licensee submitted three LERs associated with loss of ocean thermal data, and one involving loss of benthic sample ~ data.
License Amendment 53, issued March 26, 1981, deleted the "Nonradiological Surveillance" requirements noted above. One instance of failure to collect and analyze a local crop sample during 1980 was also reported.
2.
Conclusion Due to the lack of inspection activity in this area, no conclusions j
are drawn.
3.
Board Comments The board recommends implementation of the routine inspection program in thiS area.
i J. Emergency Preparedness 1.
Analysis During the evaluation period, the Health Physics Appraisal found the licensee's capability to respond to an emergency f
1-15
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE limited by the size of the radiation protection staff, their training, and the equipment available for use.
Observation of 9
-the licensee's May 13, 1981 exercise by NRC found several weak a reas.
However, none of the items identified were considered significant since they would not prevent appropriate protective measures from being implemented.
2.
Conclusion The licensee's' emergency preparedness needs some improvement, therefore this area is rated Category 2.
3.
Board Comments i
The board recommends implementation of TI 2515/55, " Emergency Preparedness Appraisal," as scheduled.
K. Security and Safeguards 1.
Analysis a.
General From May 16, 1980 to June 30, 1981, Region V conducted four Safeguards' inspections at SONGS-1 which identified a total of six items of noncompliance.
The resident inspector also identified three additional items of
" Physical Security" noncompliance.
Of the nine identified items of noncompliance, three were classified as severity level IV, five were severity level V, and the remaining item was classified as a "defi ciency. "
The nine identified items of noncompliance are distri-buted into the following four security areas.
(1)
Integrity of Security Barriers 4
(a) Two items of noncompliance identified four l
separate vital areas in which the potential existed for unauthorized passage of personnel from the protected areas to the individual vital areas.
l 1-16
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (b) Two additional items of noncompliance related to security requirements of the protected area barrier.
(c) A further item of noncompliance identified the licensee's failure to properly compensate for one of the above items related to the protected area barrier.
(2) Site Support to Security Alarm Systems Two items of noncompliance, of which one item is a repeat item, identified two functional areas in which the site Instrumentation and Control (I&C)
Section failed to provide proper and/or timely support to the site Security Section.
(3) Screening for Unescorted Access One item of noncompliance identified the licensee's failure to insure the conduct of complete screening prior to allowing unauthorized access to the site.
(4) Protected Area Escort One item of noncompliance identified a failure of an employee to continually escort six uncleared personnel within the protected area.
b.
Summary of Major Problems During the period of this SALp review, and as a result of the nine items of noncompliance, there existed two major areas of Safeguards' concern.
(1) Security Barriers There existed areas throughout the site which offered the potential for unauthorized personnel passage from the protected area to individual vital areas.
Most of these " passage situations" were directly caused by the extensive construction work being performed throughout the site.
(2) Site Support to Security Section For the past 16 months, the Security alarm system has not received sufficient and timely support from 1-17
)
i I
SYSTEf4ATIC ASSESSf4EflT OF LICE!!SEE PERFORf1AflCE j
the site I&C Section.
During the period of this I
SALP review, there were two items of noncompliance j
that were directly related to maintenance support of I
security alarm-related equipment.
One item was a-repeat item of noncompliance.
It appeared that the maintenance support available to 50flGS-1 security section decreased.
{
c.
Significant Strength of Licensee During the period of this SAL review, there were two
^
security related areas in which the licensee performed i
better than other Region V operating reactors.
(1) fianagement Attitude Licensee management continues to have a positive attitude towards security and the licensee is normally 4
attentive toward prompt corrective actions.
(2) Quality Assurance (QA) Section The site QA Section actively supports the operation of the Security Section through an ongoing review of l
all security procedures.
This QA review has been extemely effective towards improving the overall j
operation of the Security Section and preventing j
further repeat items of noncompliance.
l 2.
Conclusion Considering the nine items of noncompliance, of which four were identified within the last 60 days of the evaluation 4
period, and the individual severity levels of each item, the performance of the S0flGS-1 Security Organization during the period of this SALP review is rated as being Category 3.
i 3.
Board Comments The frequency and level of noncompliance for 50flGS-1 warrants l
an increase in the inspection frequency.
The increased inspection frequency takes into consideration the licensee's significant strength (QA Section and f4anagement Attitude).
1 L. Audits, Reviews, and Committee Activities 4
1.
Analysis One regional-based operations' inspection was performed in this area.
fio items of noncompliance were identified.
i 1-18
SYSTEMATIC ASSESSMENT OF LICEllSEE PERFORMANCE Inspection 81-09 evaluated the activities of the Onsite Review Committee and identified no items of concern.
The activities of the offsite committee were not scheduled for review during this period.
2.
Conclusion performance is rated as being Category 2.
3.
Board Comnents' The board recommends no change in inspection effort.
M. Administration, QA, Records, and Procurement 1.
Analysis Three regional-based operations' inspections were performed in this area. flo items of noncompliance were identified.
During this period, the licensee has changed his organization as indicated in Amendement 54 to the Unit's Technical' Specification.
Inspections 80-30 and 81-12 reviewed the licensee's quality assurance program and identified no items of concern.
This second inspection revealed a QA organization which is strongly supported by management, adequately staffed, and well managed.
The records retained by the licensee are adequate, but are not always easily retrievable by the licensee.
2.
Conclusion Performance is rated as being Category 1.
3.
Board Comments l
The board recommends no change in inspection effort.
fl. Corrective Actions and Reporting 1.
Analysis j
a.
Licensee Events The licensee identified 32 events in this period.
Some of the more significant events included:
(1) Loss of AC power to all station auxiliaries (personnel i
i error).
l 1-19
~
)
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (2) Multiple instances of boron dilution of the reactor q
coolantsystem(threeinstances).
(3) Repeated. sequence design errors (two instances).
(4) Repeated personnel air lock failures.
The licensee's reporting was timely, and on a case-by-ca.te basis, the corrective actions proposed were appropriate.
There were instances where the initial corrective action i
was inadequate to prevent recurrence, but in each case, the licensee's explanation for this repetition was adegaate.
l b.
IE Bulletin:
During this period, ten bulletins were issued which were applicable to this Unit.
The licensee provided complete and timely response to six of theses.
The responses to the other four were late.
The licensee provided, in each case, a timely letter informing the Regional Office of the delay and explaining the reason.
Some final responses have been as much as ten months late.
However, when the final response had been submitted, they were typically complete and properly addressed the issue.
2.
Conclusion Performance is rated as Category 2.
3.
Board Comments The board recommends no change in inspection effort.
IV.
SUPPORTING DATA AND SUMMARIES A. Noncompliance Data See Attachment 1.
B. Reports Data 1.
LER Nos. Reviewed: 80-18 through 81-10.
l 2.
LER
Conclusions:
See Attachment 2.
C. Licensee Activities 4
See Attachment 3.
I 1-20
t SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMAflCE i
i D. Inspection Activities See Attachment 4.
~
E. Investigations and Allegations Review i
i See Attachment 5.
F. Escalated Enforcement Actions j
See Attachment 6.
G. Management Conferences Held During Appraisal Period _
i See Attachment 7.
o h
I k
l l
i i
t
)
i l
1 I
l l
1-21
i i
SYSTEMATIC ASSESSMEflT OF LICEtiSEE PERFORMAflCE 1
l
)
ATTACHMEllT 1 fluMBER AtlD flATURE OF fl0flCOMPLIAtlCE ITEMS - OPERATIrlG REACTORS Facility flame San Onofre Unit 1
Inspection floncompliances Functional Area Manhours Severity Level Cl_assi fica tion _*
I II III IV V
VI Vio.
Inf.
Def.
Devl 33 19, A.
Plant operations 209 38 B.
Refueling operations 17 1,
31 26, C.
Maintenance 427 32, D.
Surveillance &
a inservice testing 227 E.
Personnel, training
& plant procedures 51 F.
Fire protection
& houskeeping 37 2,
3A2 4 37 i
G.
Design changes &
35 j
modifications 173 36 10, 11, H.
Radiation protec-12, tion, radioactive 13, waste management, 14, 5,7, 3,4,
& transportation 780 15, 16, 17 18 8,9, 20, I.
Environmental protec-14 tion J.
Emergency Preparedness 144 23, 21 6,
28, 22,
K.
Security & safeguards 344 29, g 30 L.
Audits, reviews, &
committee activities 15 1-22
. =-
SYSTEMATIC ASSESSMENT OF LICEtlSEE PERFORMATICE
! (cont. )
l Inspection Noncompliances.
]
Functional Area Manhours Severity Level Classification
- i, M.
Administration, QA, records, procurement 7
4 31 Corrective actions &
j reporting 133 i
1HIS CYCLE Totals 2568 0
0 6
4 13 3
0 4
6 2
0 13 3
LAST CYCLE l
i
" Complete this column for noncompliances issued under the old categorization.
NOTE:
Numbers refer to attached sheets for each item of noncompliance.
8 i
I l
1 l
l i
1-23
SYSTEMATIC ASSESSMENT OF LICEilSEE PERFORMANCE ITEMS OF NONCOMPLIANCE (cont.)
Report #
1.
80-16 Deficiency Failure to follow procedure in calculating shutdown margin 2.
80-16 Deviation Inadequate housekeeping 3.
80-17 Deficiency Inadequate labeling of radioactive material 4.
80-21 Deficiency Failure to wear protective gloves as required by Radiation Exposure Permit 5.
80-21 Infraction Inadequate radiological protective measures used by three personnel in an exclusion area 6.
80-21 Deficiency Security and Safeguards 7.
80-22 Infraction Overexposure of 3.5 rem in one quarter 8.
80-22 Infraction Failure to provide survey to prevent 3.5 rem / quarter over exposure to one individual 9.
80-22 Infraction Failure to follow procedure in that dosimeters were not read by Exclusion Area Monitors 10.
80-26 3
24 individuals greater than 3 rems per quarter ($75,000)
- 11. 80-26 3
Failure to provide adequate surveys of steam generator head to prevent exceeding 3 rem per quarter ($25,000)
- 12. 80-26 3
Failure to provide adequate survey of spent fuel' cask
~
to prevent over exposure
]
($18,750)
I
- 13. 80-26 3
Inadequate measurement of I
airborne contamination
($18,750) 1-24
SYSTEMATIC ASSESSMEllT OF LICEilSEE PERFORMAf1CE ITEMS OF fl0flCOMPLIAf1CE (cont.)
- 14. 80-26 3
Radiation Protection Technician who provided radiological control of spent fuel cask did not meet minimum qualification requirements
($6,250)
- 15. 80-26 3
Failure to follow procedure while working with highly radioactive material ($6,250).
16.
80-26 4
Failure to use respirator protective equipment in accordance with applicable requirements 17.
80-26 5
Improperly labeled radioactive material 18.
80-26 6
Feilure to follow procedure for controlling radiological stay times in steam generators 19.
80-28 Deficiency Primary coolant chloride concentration in excess of procedure limit 20.
80-28 Deficiency In line radiation monitor from holdup tank discharging to circulating water system incorrectly set 21.
80-29 5
Security and Safeguards 22.
80-29 5
Security and Safeguards l
l 23.
80-32 4
Vital area access portal l
was open and unattended 24.
80-34 5
Failure to properly review and approve a required procedure 25.
80-34 4
Failure to escort individuals l
I 26.
81-05 6
Failure to follow procedure l
in maintenance area 27, 81-13 5
Security and Safeguards l
l 1-25 m
,,y_-,_.v
_..y
a SYSTEMATIC ASSESSMErlT OF LICEfiSEE PERFORMAflCE ITEMS OF fl0flCOMPLIAflCE (cont.)
28.
81-13 4
Security and Safeguards 29.
81-13 4
Security and Safeguards 30.
81-13 5
Security and Safeguards 31.
81-15 5
Failure to obtain proper clearance prior to performing work on safety-related equipment 32.
81-15 6
Failure to follow procedure for leak test 33.
81-15 5
Failure to follow procedure during spent resin transfer resulted in overflow 34.
81-22 5
Failure to properly radiograph mechanical penetration added for sampling 35.
81-22 5
Failure to provide adequate cable separation for new auxiliary-feedwater instrumentation panels 36.
81-22 5
Improperly installed anchors on auxiliary feedwater instrumen-tation panel 37.
81-24 Deviation Inadequate review of test procedure l
38.
5 Inadequate chemistry control i
procedures I
t
{
1-26
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE i
LER ANALYSIS DATA SHEET From 4/15/80 to 6/30/81 Facility Name San Onofre Uni t 1
Causally Management Personnel Functional Area Linked Events Error
- Error
- 80-29 80-38 80-34 1.
Plant operations 80-36 2.
Refueling LER 80-18 operations LER 80-20, 81-04 LER 80-23 3.
Maintenance LER 81-03, 81-09 4.
Surveillance &
79-15 LER 80-20 i
inservice testing 81-10 5.
Personnel, training, LER 80-18
& plant procedures 6.
Fire protection
& houskeeping 7.
Design changes &
LER 80-19 LER 80-31 modifications 80-35 8.
Radiation protec-tion, radioactive waste managemerit,
& transportation l
9.
Environmentel protec-80-30 tion 80-37 81-05 4
- 11. Security & safeguards 1-27
SYSTEMATIC ASSESSMEllT OF LICEllSEE PERFORMAflCE (cont.)
LER AtlALYSIS DATA SHEET (cont.)
Causally Management Personnel Functional Area Linked Events Error
- Error *
- 12. Audits, reviews, &
committee activities
- 13. Administration, QA records, procurement
- 14. Corrective actions &
80-03 reporting 80-32 TOTALS 10 8
4
- (Excluding Linked)
Lic Acceptable Maximum TNE
.42 l
.7 LilE 2
1 4
ATBE 5.4 l min (1.9)
I 1-28
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORftANCE (cont.)
LER Evaluation The guidance provided by Teknekron Research: Inc., dated November 26, 1980, was used for this evaluation.
The following results were obtained:
a.
See Attachment 2 Data Sheet and LER Listing.
b.
The data sheet shows four causally linked event series.
The largest series consists of three events.
Numerical analysis of these events gives the following:
i 1.
Average Total Number of Events per Month (TNE)
This unit had.42 events per month which is well below the recommended maximum of.7.
11.
Largest Number of Linked Events in a Chain (LNE)_
LNE for SONGS is two which is much smaller than the recommended maximum of four.
iii.
Average Time Between Events (ATBE)
The ATBE for SONGS is 5.4 months which is much larger than the recommended minimum of 1.9 months.
c.
The causally linked event series #1 was a series of three uncontrolled boron dilutions which occurred during steam generator tube repair work.
d.
The causally linked event series #2 consists of three breaches of containment due to personnel access hatch failure.
e.
The causally linked event series #3 consisted of a series of lapses in the collection of environmental monitoring data.
f.
The causally linked event series #4 consisted of repeated failure of CV-537, service water to containment, due to various causes.
s 1-29
SYSTEMATIC ASSESSMErlT OF LICEflSEE PERFORMAf1CE (cont.)
LICEllSEE EVErlT REPORTS (LERs)
Listing LER #
Cause Description 80-18 Management (inadequate control)
Damage to an in-core instrument thimble during refueling operations 80-19 Personnel error Missing U-bolt support on the.
Residual Heat Removal Pump shaft seal cooling water return line (IEB 79-14) 80-20 Management (inadequate Failed hydraulic snubber due to maintenance) low hydraulic fluid level Personnel error Mechanical snubber failure due to overstressing during functional test 80-21 Component failure Failure of three feedwater system supports inside containment (IEB 79-13) 80-22 Manufactured flaw 1/8-inch deep pin hole in base metal of seal injection piping to reactor coolant pump B 80-23 Personnel error Flaw in previous weld repair in the wall of the water box of component cooling water heat exchanger E-20B 80-24 Original plant construction Six welds in Main Steam Lines flaws were found to have flaws in excess of ASME code 80-25 Service induced Linear indications found on the surface of the bore in Reactor Coolant Pump A and B flywheels 80-26 Original Plant Preliminary reanalysis of Main design Deficiency Steam Line Break Accident warrants:
control logic system design changes, inservice inspections, containment integrity evaluation, and main steamline pipe evaluations 1-30
. ~
SYSTEMATIC ASSESSMEllT OF LICEflSEE PERFORMANCE (cont.)
LICEilSEE EVEllT REPORTS (LERs)
Listing (cont.)
L_ER#
Cause Description 80-27 Original construction Unacceptable defects in seven welds defects of feedwater system inside containment (IEB 79-13) 80-28 Personnel error Inadequate and damaged pipe guides in the Safety Injection System 80-29 Hanagement (Inadequate Uncontrolled boron dilution Control) during steam generator decontamination 80-30 Component failure /
Failure to collect continuous Management (Inadequate Environmental water temperature control) due to sensor failure 80-31 Personnel error Failure of South Salt Water Cooling Pump discharge valve (POV-6) -
Wrong size spring 80-32 Management error Failure of containment isolation valve CV-537, service water to containment due to desiccant and inadequate pressure regulator 80-33 Design deficiency Inadequate design of Sequencer System:
will not auto sequence loads for certain scenarios 80-34 Management (Inadequate Uncontrolled boron dilution when control) removing steam generator tube for analysis 80-35 Inadequate Design Inadequate pushbutton switches in newly installed Containment Isolation Panels 13A and 138 r
80-36 Personnel error Uncontrolled boron dilution during decontamination of steam generator heads 80-37 Management (Inadequate Failure to collect continuous control) environmental water temperatures 1-31
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (cont.)
LICENSEE EVENT REPORTS (LERs)
Listin (cont.
LER#
Cause Description 80-38 Personnel error Loss of AC power to all station auxiliaries 80-39 Design deficiency Diesel Generator Tubocharger thrust bearing failure due to inadequate lubrication 81-01 Design deficiency Safeguard Load Sequencing System resequencing design inadequate 81-02 Personnel error in Missing bolts from anchor supports on construction feedwater line inside containment (IEB79-14) 81-03 Personnel (installation)
Failure of two mechanical snubbers Management (maintenance (IEB 81-01) prog.)
81-04 Management (Inadequate Components of recirculation flow maintenance) control valves beyond qualified life 81-05 Management (oversight)
Failure to collect semi-annual crop samples 81-06 Inadequate design Terminal block integrity could not be established in post-accident environment 81-07 Design deficiency RHR pump coupling not qualified for accident conditions 81-08 Component failure Defects in thermal sleeve l
and feedwater assembly in the "B" Steam Generator l
l 81-09 Component failure I.D. ' reduction of saltwater discharge pipe from component cooling water Hx due to marine growth i
l 1-32
SYSTE!4ATIC ASSESSf4ErlT OF LICErlSEE PERFORf4AllCE (cont.)
LICEflSEE EVEllT REPORTS (LERs)
Listing (cont.)
LER#
Cause Description 81-10 lianagement (inadequate Uncontrolled breaches of maintenance / surveillance) containment integrity due to failure to personnel access hatch 1-33
Licensee Activities The Unit has been in an extended shutdown for Steam Generator repair from the beginning and throughout n.ost of the evaluation period.
The unit returned to operation on June 15, 1981.
During this extended shutdown, the following work was completed:
a.
Steam Generator tube repair consisting of:
B C
percent of tubes for each S/G Tubes plugged prior to this outage
- 2. 5
- 1. 3
' 3. 2 Tubes plugged during this outage
- 6. 5
- 6. 5 5.1 Equivalent plugging due to sleeves 4.6 4.4
- 4. 4 Total plugging level at startup 13.6 12.2 12.7 i
i This repair required 3,496 person rem to complete.
b.
Three Mile Island (TMI) Modifications The following major items were completed:
1.
Installation of subcooling meter II.F.2 ii.
Auto initiation of auxiliary feedwater system II.E.1.2 111.
Zeroing the derivative input to the p.i.d.
controller to the Power Operated Relief -
Valves
- II.K.3.9 (Note:
Category "A" items were completed during the previous review cycle except item ii,above.)
c.
Other Modifications i.
Fire protection modifications ii.
Service water totalizer iii.
Boric acid system iv.
Hydrogen recombiners installation v.
Steam pipe weld repair
- Because of developments occurring subsequent to the evaluation period, this item has been reopened.
1-34
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE l
j Inspection Activities No. of Inspections Manhours Inspection Activities a.
Regional Inspection (Operations) 1.
Routine inspection 11 380 ii.
0 b.
Resident Inspection (mostly operations) 13 834 c.
Health Physics i.
Routine 3-116 11.
Reactive 6
339 iii.
Health Physics Appraisal 1
350 ll d.
Environmental 1.
Routine 0
0 11.
LER followup (N. A. )
14 e.
Security and Safeguards (routine) 4 334 f.
144 TOTAL 2511 f
f
't l
1-35
SYSTEMATIC ASSESSMEllT OF LICEilSEE pERFORMAflCE Investigations and Allegations Review One formal investigation was conducted during this period consisting of 144 manhours onsite. This investigation dealt with the alleged theft of potentially radioactively contaminated tools from San Onofre Unit 1.
Information developed during this investigation did not substantiate that contaminated tools had been stolen from San Onofre Unit 1.
i 1
4
'l 6
1-36
SYSTEMATIC ASSESSMEtlT OF LICEllSEE PERFORf4ATICE A_ttachment 6 Escalated Enforcement Actions a.
Civil Penalties A civil penalty for the amount of $150,000 was issued on.
January 23, 1981, by the Director, Office of Inspection and Enforcement.
This civil penalty was issued as a result of the personnel exposures of steam generator entrants and the manner in which the licensee handled the spent fuel shipping cask, b.
Orders On April 15, 1981, an Order Imposing Civil Monetary Penalties for the above civil penalty was issued for $150,000.
The licensee subsequently paid the civil penalty.
c.
Confirmation of Action Letters Four Confirmation of Action letters were issued during this period.
i.
Immediate Action Letter (IAL), dated September 5,1980.
This IAL was issued, based on a management meeting held on September 5, 1980, to discuss radiological control problems at San Onofre.
This IAL detailed those actions the flRC considered necessary to provide adequate radiation i
safety for workers involved in the steam generator repair effort.
ii.
IAL, dated October 2,1980.
This IAL confirmed four specific actions to be taken by the licensee concerning a highly contaminated spent fuel shipping cask.
iii.
IAL, dated October 15, 1980.
This IAL confirmed four specific actions to be taken by the licensee to control foreign material in the reactor l
coolant piping during steam generator repair.
iv.
IAL, dated flovember 19, 1980, This IAL confirmed the licensee's commitment to not commence production sleeving without prior f1RR review and approval.
1-37
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Management Conferences Held During Appraisal Period Two Management meetings were held during this period.
i.
Management Meeting, September 5,1980.
This meeting was held to discuss radiological controls for the steam generator tube repair project. As a result of this meeting, an IAL was issued.
ii.
Management Meeting, May 28, 1981.
This meeting covered an overview of licensee problems and corrective actions in the areas of health physics maintenance and security.
During this meeting, the Chairman of the Board, Mr. William Gould, expressed a strong commitment to further strengthening of all aspects of the management and operation of their nuclear facilities.
i 4
4 i
1-38 r.
GRR PERFORMANCE EVALUATION Facility:
San Onofre Unit 1 Project Manager:
S. J. Nowicki Appraisal Period: ' July 1, 1980 - June 30, 1981 1.
Performance Elements a.
Quality of responses and submittals Southern California Edison Company (SCE) provides licensing submittals which are technically correct but too brief to support the requested action. Their response to technical questions and staff requests for additional information have usually been delayed during this review period.
b.
Efferts required to obtain an acceptable response or submittal including:
(1) Timeliness - SCE has put most of their effort into steam generator repair during the period reviewed. Most of the other licensing actions were delayed.
SCE usually notified the staff when the action would be delayed and requested permission to delay their responses.
(2) Effort - The staff has had to request additional information on most requests because of the brief nature of the supporting documentation.
(3) Responsiveness to staff requests - SCE lic'ensing personnel are well qualified engineers.
SCE is very responsive to many informal requests common to a Systematic Evaluation Program plant.
(4) Anticipates or reacts to NRC needs - SCE does not attempt to anticipate HRC requirements.
SCE does respond to the NRC's requests.
i i
l-39
c.
Working knowledge of regulations, guides, standards and generic issues -
t Because of their background and experience in dealing with the.NRC, SCE l
has developed a licensing staff which has a good working knowledge of HRC regulations, guides, standards and generic issues.
4 d.
Technical competence - The SCE technical and licensing staff exhibits adequate technical competence.
Expertise is supplemented by use of consultants.
j e.
Conduct of meetings with NRR - SCE's conduct of meetings with NRR appears to be one of their strongest areas.
They are usually well prepared and willing to make commitments during meetings.
At meetings, SCE tends to l
alleviate the problems instigated by their brief written submittals.
i f.
Long-standing open items - SCE has deferred some long-standing open items to address the steam generator repairs in order to restart the plant and the seismic upgrading of the plant to keep it operating.
However, the deferred action by SCE does not prevent SCE for asking for prompt action from the NRC when part of the deferred action is needed for continued operation.
This mode detracts from the NRR effort and would be avoided if the licensee would complete his open commitments.
i g.
Organization and management capabilities - The organization has undergone I
a significant recent change to incorporate requirements for a 3-unit i
site and concerns of the NRC staff.
The effects of this change are not yet apparent.
However, one noted deficiency is that too many licensee I
I l-40
3-1 personnel are involved in interaction with the NRC resulting in conflicting l
requests and responses._ Also, there appears to be conflict or poor communication between the plant operating staff and the licensing and technical support staff.
Management attention should resolve these conflicts.
Results of operating licensing examinations conducted during the h.
appraisal period.- There were no examinations administered during this period.
- i. Performance on specific issues (as selected by +he Project Manager) -
Steam Generator-Repair - The major effort performed by SCE during this period was the repair of the steam generators. SCe made several j
mistakes during the period resulting in fines for health physics violations and additional effort due to poor worker and material control.
SCE made a commendable effort to keep the NRR staff informed I
and satisfied at each phase of the repair. As the repair neared completion, SCE required NRC urging to convert commitments to
~
enforceable licensing action requests. The outcome was an effort acceptable to the staff.
Seismic Reevaluation Procram - Another major program conducted by the i
licensee is the seismic reevaluation of the plant. The licensee is reluctant to provide the staff with all of the requested commitments.
SCE requires urging by the staff to expand its program and provide firm schedules.
SCe's efforts and costs for this program have been considerable since 1972.
I i
l-41
-=
i Systematic Evaluation Procram - The performance of SCE with regard to SEP is cluaracterized as average to slightly below average.
SCE has been slow in prmviding the topics they committed to review; the quality of the re-views are characterized about average. SCE has been slow in providing respomses to support the electrical reviews.
Observed trends in performance - The plant has been shutdown for this i
entire period except for a brief time starting June 15, 1981.
Once the effor to repair the steam generators and restart the plant was completed, the other daily operational concerns were being addressed more thoroughly.
It is too early to observe a trend in normal operation.
j n.
Notable Strengths and Weaknesses Strengths - The technical and regulatory awareness and competence are a.
SCE's rotable strength.
b.
Weaknesses - The apparent miscommunications between the plant operating staff and the licensing staff and the sparse supporting information provided with licensing requests are the notable weaknesses. Some lack of preparation before tackling a large job.was another noted i
l weakness.
4.
Overall Summary The SCE corporate headquarters staff have generally performed in an.
I average manner in conducting their business with NRR.
The plant operating staff appears to !!RR to have had problems during this period that puts their performance just below average.
l l-42
NRC Inspection Report Nos. 50-361/82-16 and 50-362/82-07 ENCLOSURE 2 REGIONAL PERF0PJ1ANCE EVALUATION REPORT SAN ON0FRE UNITS 2 & 3 2-1 l
(San Onofre Units 2/3)
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REGIONAL PERFORMANCE EVALUATION REPORT I.
UTILITY PERFORMANCE EVALUATION REGION V Utili ty:
Southern California Edison Company Facili ties:
San Onofre Nuclear Generatina Station Unit 1 (Operating)
~
Units 2/3 (Construction)
NOTE:
For utility evaluation, please see Regional Performance Evaluation Report for San Onofre Unit 1.
2-2
SYSTEMATIC ASSESSMENT OF LICENSEE PERF0PfiAEICE II. LICENSEE PERFORMANCE EVALUATION Facility: San Onofre Nuclear Generating Station Units 2/3 (Construction)
Licensee: Southern California Edison (SCE)
Uniti Identification:
SONGS-2/3 Docket No.
License No./Date of~Issuanc_e_-
Unit No.
50-361 CPPR-97/10-18-73 2 362 CPPR-98/10-18-78 3
Reactor Information:
Unit 2 Unit 3 MWt 3390 3390 Appraisal Period: June 1, 1980 thru June 30, 1981 Appraisal Completion Date: July 29, 1981 Plant Status:
Presently, construction for Units 2 and 3 is approximately 99 and 78 per cent complete, respectively; the licensee's schedule for loading fuel in Unit 2 is October 1981.
Review Board Members:
A. D. Johnson, R. F. Fish, H. Rood, L. Miller, T. Young Jr., and J. H. Eckhardt Overall Licensee Evaluation The NRC inspections of construction have resulted in a very small number of. items of noncompliance indicating adherence to construction
~
specifications, codes, and regulatory requirements. The Quality Assurance Program appears to be strong, has a postive image on -
site, and is supported by upper management.
SCE has generally been very responsive to NRC requirements and concerns.
Requests for information have usually been prompt and provided with a high degree of quality.
Personnel appear to be well qualified and technically competent.
Preoperational testing has' been performed in accordance with the requirements of the approved test program.
The tests have been comprehensive in collection of data and~the results have been subjected to detail review by several independent reviewers before acceptance.
The operating staff appears to be well qualified and motivated; however, additions to the operating staff need to-be made for more l
depth.
The training program now appears to have reached a high-level of perfort:ance.
Based on the licensee's perfonnance during the appraisal period, i
the overall rating of Units 2 and 3 is considered Category 1.
2-3
{
i SYSTEMATIC ASSESSMENT OF LICENSEE PERF0PJ1AtlCE III. Performance Analysis 1.
Quality Assurance (OA) a.
Analysis Ninety inspection-hours were used in examining audits and surveillances, 50.55(e) items, licensee's response to NRC concerns, and the general image of the QA organization.
No items of noncompliance or deviations were identified.
b.
Conclusion Performance is rated as Category 1.
c.
Board Comments The board recommends no changes in inspection effort.
2.
Substructure and Foundation, Concrete and Liner This functional area was not inspected during the appraisal period.
3.
Safety-related Structures This functional area was not inspected during the appraisal period.
4.
Piping and Hangers (includino welding) a.
Analysis-Seventy-six inspection-hours were used in examining this i
area.
One item of noncompliance (level IV) was identified concerning inadequate inspection of piping prior to insulating i
(Unit 2).
b.
Conclusion Performance is rated Category 2.
c.
Board Comments The board recommends no change in the inspection effort.
t 5.
Safety-related Components i
a.
Analysis Thirty-nine inspection-hours were used in examining this area.
No items of noncompliance or deviations were identified.
I 2-4
i b.
Conclusion Performance is rated Category 2.
c.
Board Comments-The board recommends no change in the inspection program.
6.
Electrical Equipment; Tray, and Wire a.
Analysis Fifty-eight inspection-hours were used in examining this area.
One item of noncompliance (level V) was identified concerning ).
electrical cable separation within cabinets (both Unit 2 and 3 l
i.
b.
Conclusion Performance is rated Category 2.
c.
Board Comments The board recommends no change in the inspection program.
7.
Instrumentation a.
Analysis Twenty-six inspection-hours were used in examining this area.
fio items of noncompliance or deviations were identified.
b.
Conclusion Performance is rated Category 1.
c.
Board Comments The board recommends no change in the inspection program.
8.
Fire Protection This functional area was not inspected during the appraisal period.
9.
Preservice Inspection a.
Analysis l
Four inspection-hours were used in examining this area.
fio
~
items of noncompliance or deviations were identified.
l 2-5
,e-n
--,,-,e
,,-,~-,--m e,v r,v,.
r.
ve-n:
-we,o e-,-,--
r--
e e
s,
b.
Conclusion Performance is rated Category 2.
c.
Board Comments Increased inspection effort will take pla e in Unit 3 due to the limited inspection during. this appraisal period.
- 10. Corrective Actions and Reporting a.
Analysis A total of 124 inspection-hours were used in examining this area.
The licensee's response and corrective actions to IE Bulletins and Circulars, items of noncompliance,-and other f1RC concerns has been timely and comprehensive.
The licensee has submitted twenty-two 50.55(e) reports during the appraisal-period in a timely manner..
b.
Conclusion Performance is rated Category 1.
c.
Board Comments The board recommends no change in inspection effort.
11.
Procurement a.
Analysis Ten inspection-hours were used in examining this area.
flo items of noncompliance or deviations were identified.
b.
Conclusion Performance is rated Category 2.
c.
Board Comments The board recommends no change in inspection effort.
12.
Design Changes a.
Analysis Ten inspection-hours were used in examining this area. flo items of noncompliance or deviati:ns were identified.
b.
Conclusion Performance is rated Category 2.
c.
Board Comments The board recommends no change in inspection effort.
13.
Training.
a.
Analysis flo direct inspection time was spent looking at training but training was examined as it is connected with other functional areas, e.g., qualifications of maintenance and health physics personnel. A very comprehensive training program for all operating staff personnel has been developed and implemented.
This program should prove itself to be a model for the industry to follow.
c.
Conclusion Performance is rated Category 1 in this area.
d.
Board Comments The board recommends no change in inspection effort.
14 Plant Operations a.
Analysis A total of 147 inspection-hours were used by the resident and regional based inspectors in reviewing procedures, witnessing tests and reviewing test results.
flo items of noncompliance or deviations were identified.
During hot functional testing, approved operating procedures were used and, subsequently, some have been revised.
Plant operators are in training and will be tested later this year before licensing.
b.
Conclusion Perfbymance is rated Category 1.
c.
Board Comments The board recommends no change in inspection effort at this time.
15.
Fuel Loading Preparation a.
Analysis Six inspector-hours have been used in reviewing the fuel receipt procedure and touring the fuel storage facility.
The plant is essentially ready to receive fuel. -Fuel is scheduled to be received onsite for Unit 2 between August 17 and October 15, 1981.
b.
Conclusion Performance is rated Category 2.
2-7
i c.
Board Comments The board recommends' no change in inspection effort at this time.
- 16. Maintenance a.
Analysis i
.The resident and regional-based inspectors used 74 inspector-hours i
in examining the maintenance activities associated with preoperational testing.
One item of noncompliance was identified:
Improper maintenance of stored electrical cables.
i b.
Conclusion Performance is rated Category 2 in this area.
c.
Board Comments The board recommends no change 'in inspection effort at this time.
- 17. Security and Safeguards This functional area was not inspected during the appraisal period.
- 18. Surveillance and Preocerational Testing a.
Analysis A' total of 831 inspector-hours were used by the-resident and regional-based inspectors in examining preoperational and surveillance testing. Three items of noncompliance and one deviation were identified:
(1) inadequate review of test procedures; (2) improper valve lineup during a preoperational test; (3) lack of QA signature on a startup package; and (4) inadquate housekeeping during one inspection.
f b.
Conclusion Performance is rated Category 2 in this area.
c.
Board Comments The board recommends no change in the inspection effert at this-time.
- 19. Emergency Planning This functional area was not inspected during the appraisal period.
2-8
- 20. Audits, Reviews and Committee Activities a.
Analysis The inspectors used 27 inspector-hours reviewing audits and committee activities.
No items of noncompliance were identified.
At this time, most of the committee activities consist of procedure review and approval, b.
Conclusion Performance is rated Category 1 in this area.
c.
Board Comments The board recommends no change in the inspection effort at this time.
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2-9 t
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE IV.
SUPPORTING DATA AND SUMMARIES A.
Noncompliance Data See Attachment.l.
B.
Reports Data See Attachment 2.
C.
Licensee Activities See Attachment 2.
D.
Inspection Activities See Attachment 4.
E.
Investigations and Allegations Review See Attachment 5.
F.
Escalated Enforcement Actions See Attachment 6.
~
G.
Management Conferences Held During Appraisal Period See Attachment 7.
2-10
ATTACHMENT 1 Noncompliance Data 2
Seven items of noncompliance and one deviation were identified during the appraisal period and are as follows:
Unit 2 - Deficiency, Criterion V; Lack of QA signature on startup package.
Unit 2 - Severity Level IV, Criterion V; Condition and inspection of piping prior to insulating.
Unit 2 - Severity Level V, Criterion V; Inadequate review of test procedures.
i
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Units 2 and 3 - Severity Level V, Criterion V; Inadequate cable separation within cabinets.
Unit 2 - Severity Level IV; Improper maintenance of stored electrical cables.
Unit 2 - Deviation; Inadequate housekeeping.
Unit 2 - Severity Level V, Criterion V; Improper valve lineup during preoperational test.
Unit 2 - Severity Level V, Criterion V; Inadequate electrical raceway separation.
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The following tabulations give the items of noncompliance ario inspection manhours in each functional area.
NUMBER AND NATURE OF N0?lCOMPLIANCE ITEMS - CONSTRUCTION REACTORS (Unit ~2)
Inspection Noncompliances Functional Area Manheurs Severity Level Classification Construction I
II III IV V
VI Vio.
Inf.
Def Dev.
1.
Quality assurance 67 2.
Substructure &
foundations, con-crete & liner (containment & others) 0 3.
Safety-related structures (incl. welding) 0 4.
Piping & hangers--
others--(incl. welding) 27 l-5.
Safety-related com-ponents (vessel, internals, & HVAC 10 6.
Electrical equipment, tray & wire 25 7.
Instrumentation 10 8.
Fire protection 0
9.
Preservice inspection 4
- 10. Corrective actions &
reporting 65
- 11. Procurement 10
- 12. Design changes 10
- 13. Training 0
14.
Plant operations 147
- 15. Fuel loading preparation 6
- 16. Maintenance 74 1
17.
Security & safeguards 0
- 18. Surveillance & pre-operational testing 831 2
1 1
19.
Emergency planning
- 20. Audits, reviews, &
committee activities 27 2-12
flUMBER AND flAIJRE OF fl0f! COMPLIANCE ITBis - C0flSTRUCTION REACTORS (Unit 3)
Inspection t!oncompliances Functional Area Manhours Severi ty ' Level Classification I
II III IV V VI Vio.
Inf. Def. Dev.
1.
Quality assurance 23 2.
Substructure &
foundations, con-crete & liner (containment &
o thers) 0 3.
Safety-related structures (incl.
welding) 0 4.
Piping & hangers--
o thers--(i ncl.
welding) 49 5.
Safety-related com-ponents (vessel, internals, & HVAC) 29 6.
Electrical equipment, tray & wire 33 1
7.
Ins trumenta tion 16 8.
Fire prote ion 0
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9.
Prescrvice inspection 0
i
- 10. Corrective actions &
reporting 59 11.
Procurement 0
12.
Design changes 0
13.
Training f
J 2-13
ATTACHMENT 2 Reports Data - Construction Deficiency Reoorts During the reporting period (June 1,1980 through June 30,1981),
the licensee reported 22 construction deficiencies or potential) deficiencies to Region V per the requirements of 10 CFR 50.55(e).
All written reports were submitted within the 30-day reporting period.
The following is a list of the 50.55(e) reports.
Verbal liri tten Notification Report Report Da te Descriotion Date Type 6/18/80 Lack of NDE of area prepared for repair 7/15/80 Final for certain piping weld repairs as 10/16/80 Clarifications required by the ASME code.
7/25/80 Deficiency in design of mounting bases 8/ 21/80 Final for CCll system pumps allowed excessive movement between pump and driver motor.
8/27/80 Excess bypass or recirc flow for the 9/25/80 Final HPSI pumps which reduces the net discharge flow of the pumps below specified requirements.
8/8/80 Lubrication on rubber bumpers in some 9/3/80 Final NEMA size 3 starters and Contactors manufactured by Square D Company becomes tacky causing the armature bumpers to stick 'and the starter or contactor not to close when required.
10/22/80 Failure of valve stem and valve seat 11/18/80 Final cracking in Target Rock 8" globe valve used in LPSI system.
10/8/80 Undersized ASME Code welding dimensions 11/7/80 Interim for certain socket weld connections.
12/16/80 Final 11/25/80 Westinghouse 3 inch motor operated gate 12/23/80 Interim valve used for containment isolation 1/28/81 Final did not close completely when tested under conditions of hi-flow and pressure i
differences.
11/25/80 HFA relays manufactured by GE and 12/23/80 Final supplied by ITE have cracked coil 2/5/81 Amended spool insulators which might result in failure of relay to operate properly.
12/8/80 Potential of premature time-out 1/5/81 Final condition exhibited by certain Agastat Model 700 Series pneumatic by Amerace Corp.
2-14
Verbal Written Notification Report' Report Date Descriotion Date Type 12/19/80 Potential for gearing of charging 1/12/81 Final spring motor to wear away wiring insulation causing a grounded condition in ITE 480 V loadcenter switchgear.
12/26/80 Inadequate consideration of pressure 1/16/81 Final
' thrust conditions of fuel transfer tube shell at the canal wall interface.
12/29/80 Deficiency in verifying chemical 1/28/81 Interim composition of certain bolt materials 3/13/81 Interim per ASME,Section III, NCA-3867, 4e.
5/18/81 Final 1/7/81 Potential that failure of one MCE 2/3/81 Final following recirc activation signal would result in incorrect valve alignment of ECCS system and contaiminated water from containment sump directed to refueling water storage tank.
3/27/81 Four valves in CCW system have design 4/22/81 Final i
pressure rating less than the design pressure rating of the system.
4/6/81 Collection of condensate in piping 5/1/81 Final from Unit 2 pressurizer to pressurizer relief valves due to pitch angle configuration in the piping lines.
4/29/81 Use of Y-pattern indirectional valves 5/28/81 Final in N2 pressurizer lines to SI tanks.
Loss of seismic Cl. II line upstream of the valve could result in simultaneous depressurization of i
the four SI tanks.
5/22/81 Separation of a blade from a CEDM 6/16/81 Determined cooling fan due to fa.igue crack Not Reportable.
in area of casting flow at the stressed surface of the Mode.
5/22/81 Soldering of terminal lugs for 6/19/81 Final Thermon Heat Tracing System RTD installations by unqualified personnel without soldering procedure.
2-15
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~
.. =.
Verbal Written Notification Report Report Date Description Date Type 6/1/81 Use of non-hardened washers on certain 6/29/81 Final ITT-Grinnel snubbers in lieu of.
hardened steel washers as required by ASME,Section II, Subsection NF, Paragraph NF-4724.
l 6/15/81 Use of incorrect material in keys between 7/13/81 Final motor drive shaft and pinion gear on l
Model SMB-4 Limitorque valve operators.
Reference IE Information Notice 81-08.
6/22/81 Use of non-self locking gear sets in 7/20/81 Final i
valve operators manufactured by Limitorque Corp. which results -in hammering action on seating the valve.
6/22/81 Loss of DG set output due to unit 7/20/81 Interim tripping on high crankcase pressure 8/20/81' Interim.
signal during preop. testing.
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2-16
1 ATTACHMENT 3 Licensee Activities 0
The following major activities were. performed during the appraisal period:
Unit 2 Primary cold hydrostatic test Secondary cold hydrostatic test CILRT and structural integrity test Hot functional test Initial turbine roll i
Unit 3 Continuing pipe installation i
Continuing electrical raceway and cable installation Installed diesel generators in diesel generator building Commenced preoperational testing f
r I
2-17 l
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ATTACHilENT 4 Inspection Activities During the appraisal period, a total of 24 inspections were performed on Unit 2 (construction and preoperations) and eight inspections were performed on Unit 3 (construction). Six construction inspectors and eight operations inspectors have participated in these inspections.
The type and hours of inspection are summarized below:
No. of Inspections Type Performed Inspection Hour 3 Unit 2 construction 8
228 Unit 2 preoperational testing 16 1085 Unit 3 construction 8
209 2-18
ATTACHMENT 5 Investiaation and Alleaations Review Two allegations were received during the appraisal period: one involved code plate welding and is documented in Report No. 50-361/80-10, and the other involved concrete anchor bolt installation and is documented in inspection Report Nos. 50-361/80-15 and 80-18.
Neither of these allegations were substantiated.
i 2-19
ATTACHMEtlT 6 Escalation Enforcement Actions flone.
Y
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t F
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ATTACHMENT 7 Manacement Conferences The only management conference held during the appraisal period was the meeting on July 15, 1980, to discuss results of the licensee's performance evaluation by Region V for the period June 1979 through June 1980.
The details of this meeting are documented in Report tio. 50-361/80-13.
2-21
NRR PERFORMANCE EVALUATION Facili ty: San Onofre 2 and 3 Project Manager:
H. Rood Appraisal Period: July 1, 1980 - June 30, 1981 1.
Performance Elements Quality of responses and submittals (such as SAR amendements, a.
technical specification cht iges, generic letter response, and responses to requests for additional information):
The quality of responses and submittals such as FSAR amendments and responses to requests for additional information has generally been acceptable.
SCE performance has been excellent when responding to specific NRR audits such as the Human Factors Branch control room review, the System Interaction Program audit, and the Enviornmental Qualification audit.
SCE performance was also above average in responding to staff concerns in geology-seismology areas.
b.
Efforts required to obtain an acceptable response or submittal including timeliness, effort, responsiveness to staff requests, and anticipation or reaction to NRC needs:
SCE timeliness, effort, and responsiveness has in general been good.
It has been above average for critical path items, such as reducing the number of open items to allow i
the SER to be issued on schedule. When the applicant focuses on a specific problem and marshalls.
When the applicant focuses on a specific problem and marshalls it's resources, it does a good job.
However, a few lower-priority items have been delayed to the goint that they could potentially impact the schedule if not resolved in the near future.
Such items include testing the CPC, and providing the financial information necessary to perform the staff's financial analysis.
Efforts on those areas appear to be below average. Also, development of operating procedures appears to be proceeding slowly.
c.
Working knowledge of regulations, guides, standards, and generic issues:
SCE knowlege 'of regulations, guides, etc., is above average, resulting from their early and continuous involvement with nuclear power.
d.
Technical competence:
SCE technical competence is above average.
e.
Conduct of meetings with,NRR:
Conduct of meetings is generally above average.
SCE has been well prepared, and has conducted the meetings in a i
compentent and professional manner.
2-22
f.
Long-standing open items:
There are several open items that could be considered-long-standing.
Two of these are discussed in item b, above, and another, emergency planning, is a major issue at the hearing. Although the emergency planning issue is now the pacing item in the licensing of Unit 2, it is a difficult issue to resolve, with changing staff criteria, FEMA '.eview participation, and a number of State, local, and Federal agencies involved in the issue.
SCE performance in this area is average.
g.
Organization and management capabilities:
SCE organization and management capabilities' were reviewed in some detail in resolving NUREG-0737 items, and were found to be acceptable.
h.
Results of operator licensing examinations conducted during the appraisal period:
No operator licensing examinations were conducted during the appraisal period.
i.
Performance on specific issues (as selected by the Project Manager):
Specific examples to illustrate applicant performance are given in items a, b, and f, above.
2.
Observed Trends in Performance Perfonnance during the appraisal period is improved over previous periods.
SCE has perfonned very well in the areas mentioned in 1.a and 1.b, above.
The AE, Bechtel, has done an excellent job in preparing for various NRR audits, and in responding to staff requests.
3.
Notable Strengths and Weaknesses a.
Strengths:
(1) Applicant has the capability to organize and maintain a sustained effort to solve difficult and complex technical problems.
(2) Applicant is capable of providing rapid response to staff requests when geared up for the effort.
(3) Applicant's licensing staff is cooperative and responsive to staff needs.
2-23
b.
Weaknesses:
The principal applicant deficiency noted during the appraisal period was below average performance in resolving certain issues, typically second priority items.
This appears to be due to being overloaded with work as the fuel load date approaches.
4.
0verall Summary Based on my observation of other utilities over the past eight years, I. rate SCE's performance above average, both in responsiveness and in quality of product.
O I
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4 1.
2-24 i
r-n---
,(ps accuy[g UNITED STATES y
g NUCLEAR REGULATORY COMMISSION
- C WASHINGTO N, D. C. 20555
'+,
p July 27, 1981 MEMORANDUM FOR: Darrell G. Eisenhut, Director Division of Licensing THRU:
Gus C. Lainas, Assistant Director for Safety Assessment Division of Licensing Dennis M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing I
FROM:
S. J. Nowicki, Project Manager Operating Reactors Branch No. 5 Division of Licensing
SUBJECT:
NRR SALP CYCLE 2 INPUT, SAN ONOFRE UNIT 1 Enclosed is the NRR SALP input for San Onofre Unit 1.
The enclosure follows the format provided by your guidance memorandum dated June 4,1981.
f/
"}b 3
e A
Stanley J. Nowicki, Project Manager Operating Reactors Branch No. 5 Division of Licensing
Enclosure:
As stated 2-25
NRR PERFORMANCE EVALUAT10N Facility:
San Onofre Unit 1 Project Manager:
S. J. Nowicki Appraisal Period:
July 1, 1980 - June 30, 1981 1.
Performance Elements a.
Quality of responses and submittals Southern California Edison Company (SCE) provides licensing submittals which are technically correct but too brief to support the requested action. Their response to technical questions and staff requests for additional information have usually been delayed during this review
- period, b.
Efforts required to obtain an acceptable response or submittal including:
(1) Timeliness - SCE has put most of their effort into steam generator repair during the period reviewed. Most of the other licensing actions were delayed.~ SCE usually notified the staff when the action would be delayed and requested permission to delay their responses.
(2) Effort - The staff has had to request additional information on most requests because of the brief nature of the supporting documentation.
(3) Responsiveness to staff requests - SCE lic'ensing personnel are well qualified engineers. SCE is very responsive to many informal requests common to a Systematic Evaluation Program plant.
1 (4) Anticipates or reacts to NRC needs - SCE does not attempt to anticipate f
NRC requirements.
SCE does respond to the NRC's requests.
2-26 c.
Working knowledge of regulations, guides, standards and generic issues -
Because of their background and experience in dealing with the NRC, SCE '
has developed a licensing staff which has a good working knowledge of MRC regulations, guides, standards and generic issues, d.
Technical competence - The SCE technical and licensing staff _ exhibits adequate technical competence.
Expertise is supplemented by use of consultants.
e.
Conduct of meetings with NRR - SCE's conduct of meetings with NRR appears to be one of their strongest areas. They are usually well prepared and willing to make commitments during meetings. At meetings, SCE tends to alleviate the problems instigated by their brief written submittals, f.
Long-standing open items - SCE has deferred some long-standing open i
items to address the steam generator repairs in order to restart the plant and the seismic upgrading of the plant to keep it operating.
However, the deferred action by SCE does not prevent SCE for asking-j j
for prompt action from the NRC when part of the deferred action is needed for continued operation. This mode detracts from the NRR effort and would be avoided if the licensee would complete his open commitments.
2 Organization and management capabilities - The organization has un'dergone g.
a significant recent change to incorporate requirements for a 3-unit site and concerns of the NRC staff. The effects of this change are not yet apparent.
However, one noted deficiency is that too many licensee 2-27
3-personnel are involved in interaction with the NRC resulting in conflicting requests and responses. Also, there appears to be conflict or poor
~
communication between the plant operating staff and the licensing and technical support staff. Management attention should resolve these conflicts.
h.
Results of operating licensing examinations conducted during the appraisal period.- There were no examinations administered during this period.
i
- i. Performance on specific issues (as selected by the Project Manager) -
Steam Generator Repair - The major effort performed by SCE during this peri;d was the repair of the steam generators. SCe made several mistakes during the period resulting in fines for health physics violations and additional effort due to poor worker and material control.
SCE made a commendable effort to keep the NRR staff informed and satisfied at each phase of the repair. As the repair neared completion, SCE required NRC urging to convert commitments to enforceable licensing action requests. The outcome was an effort acceptable to the staff.
Seismic Reevaluation Proaram - Another major program conducted by the licensee is the seismic reevaluation of the plant. The licensee is reluctant to provide the staff with all of the requested commitments.
SCE requires urging by the staff to expand its program and provide 3
firm schedules.
SCe's efforts and costs for this program have been considerable since 1972.
2-28
Systematic Evaluation Program - The performance of SCE with regard to SEP 4
is characterized as average to slightly below average. SCE has been slow in providing the topics they committed to review; the quality of the re-views are characterized about average.. SCE has been slow in providing responses to support the electrical reviews.
2.
Observed trends in performance - The plant has been shutdown for this entire period except for a brief time starting June 15, 1981.
Once the effort to repair the steam generators and restart the plant was completed, j
the other daily operational concerns were being addressed more thoroughly.
It is too early to observe a trend in normal operation.
3.
Notable Strengths and Weaknesses Strengths - The technical and regulatory awareness and competence are a.
SCE's notable strength.
b.
Weaknesses - The apparent miscommunications between the plant operating staff and the licensing staff and the sparse supporting information provided with licensing requests are the notable weaknesses. Some lack of preparation before tackling a large job.was another noted weakness.
4.
Overall Summary The SCE corporate headquarters staff have generally performed in an average manner in conducting their business with NRR. The plant operating staff appears to NRR to have had problems during this period that puts their performance just below average.
2-29
f-l ENCLOSURE 3 1
CRITERIA FOR RATING 0F LICENSEE PERFORMANCE The various functional areas and overall performance were assigned a Category 1, 2, or 3 rating based upon the following evaluation criteria:
Category 1.
Reduced NRC attention may be appropriate.
Licensee.
management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety is being achieved.
1 Category 2.
NRC attention should be maintained at normal levels.
1 Licensee management attention and involvement are evident and are concerned with~ nuclear safety; licensee resources are adequate and are reasonably effective such.that satisfactory performance with respect to operational safety is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee 4'
resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety is being achieved.
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