ML20059J500
| ML20059J500 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/13/1994 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9402010044 | |
| Download: ML20059J500 (6) | |
Text
V
_ r"OV Southem Califomia Edison Company 23 PARME R STREET tRvlNE, CALIFORNIA 92718 RICHARD M. ROSE NBLUM vsLErwows
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January 13, 1994 U.
S.
Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Docket Nos. 50-361, and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2, and 3
Reference:
Letter from Mr. K.
E. Perkins, Jr. (USNRC) to Mr. Harold B. Ray (SCE), dated November 24, 1993 The referenced letter forwarded a Notice of Violation resulting from the NRC inspection conducted from September 20 through October 22, 1993, at the San Onofre Nuclear Generating Station, Units 2, and 3.
This inspection was documented in NRC Inspection Report Nos. 50-361 and 50-362/93-27, dated November 24, 1993.
In accordance with 10 CFR 2.201, the enclosure to this letter provides the Southern California Edison reply to the Notice of Violation.
As discussed with Mr. Narbut, USNRC Region V, on December 10, 1993, the due date for the response was extended until January 14, 1994.
The referenced letter also expressed concern about a perceived decline in the Edison commitment to procedural compliance by workers and first line supervisors.
We take your perception very seriously.
We have therefore carefully reviewed your report and concur that several of the noted procedural violations were the result of a failure by the individuals involved to adhere to procedures as written.
As noted in the enclosure, we are taking corrective actions on an individual and collective basis to improve overall compliance with procedures.
Edison maintains a strong commitment to verbatim compliance with procedures.
In order to monitor proce' dural compliance, Edison's i
Nuclear Oversight Division (NOD) has an ongoing program which tracks and evaluates procedural compliance trends.
Prior to the NRC inspection, these performance factors had indicated a sustained decreasing trend of procedural non-coupliance issues.
Although we have confidence that the NOD process is valid, your 9402010044 940113
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PDR ADOCK 05000361 0
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report has caused us to further review the issue.
As a result, we have concluded that although an improving. trend is clearly taking place, the level of procedural compliance has not improved sufficiently to meet our expectations, and additional action is required.
SCE is planing a broad, independent NOD review of procedural compliance issues at SONGS.
NOD will use techniques similar to those employed by the NRC when performing a diagnostic inspection to investigate such issues.
We anticipate that the plan for this f
effort will be completed and approved by the end of February 1994.
i The evaluation effort will be performed during the first and second quarters of 1994.
We will keep you advised of the j
progress, conclusions and corrective actions resulting from this i
effort.
If you have any questions regarding SCE's response to the Notice of Violation or require additional information, please call me.
Sincer ly,
)
i Pt g
)
1 Enclosure f
cc:
Mr. K.
E.
Perkins, Jr., Acting Regional Administrator, NRC
{
Region V J.
Sloan, Senior Resident Inspector, San Onofre Units 1, 2&3 M.
B.
Fields, NRC Project Manager, San Onofre Units 2&3 i
i
REPLY TO A NOTICE OF VIOLATION The enclosure to Mr. Perkin's letter dated November 24, 1993, listed six violations labelled "A" through "F" which are summarized as follows: (Item "F" did not require a response).
Item "A"
involved two examples of personnel signing for work they l
did not personally perform.
Item "B" involved five examples of failure to follow procedures as written.
Item "C" involved two examples of inappropriate acceptance criteria in procedures.
l Item "D"
involved a procedure that was not appropriate to the circumstances.
Item "E" involves the failure to perform a 10 CFR 50.59 safety evaluation on an operating change using the CCW heat i
exchanger vent valve.
REPLY TO THE VIOLATIONS 1.
REASON FOR THE VIOLATIONS The reason for item "A" was a personnel error in correctly documenting work performed.
The reasons for item "B" were: personnel error (Item B-1) in failing to follow the procedure as written; individual misjudgment and inadequate personal performance (Item B-2 &
B-5); miscommunication when M&TE accuracy information was verbally obtained which resulted in the incorrect identification of M&TE accuracy (Item B-3); and, a failure to effectively incorporate a sampling point change into appropriate procedures as a result of a change made to a Repetitive Maintenance Order (Item B-4).
The reasons for item "C" were: personnel error in incorporating vendor manual information into the procedure change (Item C-1); and the failure to incorporate, in a timely manner, a new reference in the IST procedure (Item C-2).
The reason for item "D" was a poor initial test methodology used in procedure SO23-V-3.5.4 and SO23-3-3.31.1, which has been in use since 1982.
Due to the lapse of time since the procedure was developed in 1982, Edison cannot determine the basis for initially selecting the test methodology.
The reason for item "E" was an inadequate 10 CFR 50.59 2
screening criteria at the time of the violation.
j
- i
j 2.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED For item "A",
the individuals involved were~ counselled.on j
the need to adhere to documentation requirements..Further, i
Edison has reviewed procedural documentation requirements 7
and concluded they are unnecessarily cumbersome and promote confusion.
Edison will review other procedures to evaluate the administrative guidance controlling sign-off steps.
l Appropriate changes to maintenance procedures will be made
.i to improve consistency between maintenance and site 4 l
4 procedures.
Edison believes this item is an administrative documentation failure only and has no safety significance..
Accordingly, this item should have been classified as a' l
Severity Level V violation in accordance with 10CFR2, i
Appendix C.
For item "B",
the following actions were taken:
Due to the seriousness of item B-1 and considering the.
individual involved was a supervisor, stern disciplinary action was taken.
In addition, the individual was counselled on the requirement to follow procedural and equipment clearance verification requirements.
The individuals associated with the inappropriate packing-leak-off, item B-2, have been counselled.
' Additionally, the acceptance criteria.has been improved and relocated to a more appropriate procedure, SO23-I-5.23, Diesel Fuel i
Oil Transfer Pump (s) Maintenance.
The individuals associated with the miscommunication on.
which M&TE to use, item B-3, have been counselled on the need to verify M&TE accuracy in accordance with procedure SO123-II-1, Calibration and Control of Measure and Test Equipment, for clear and complete communication.
- Also, i
the need to properly verify M&TE accuracy has'been discussed with Nuclear Construction Engineers and technicians.
(Note: The results of the periodic calibration, completed after performance of the test, indicated the actual (vs. rated) accuracy of the instrument was adequate to ensure the desired margin
)
recommended by NUREG 0800 (10 degrees less than the lowest expected temperature) was maintained).
The supervisor involved with the missing signatures for procedure SO23-V-3.25, item B-5, has been counselled on i
the need to formally complete all' procedure requirements.
w For item "C",
procedure SO23-I-5.4 has been modified to reflect the correct rotation direction, and procedures SO23-V-3.4 and SO23-V-3.42 have been modified to provide the current acceptance criteria reference.
For item "D",
a new CCW IST test methodology has been developed.
[ Note: the closure of the check valves has been confirmed by a review of tests showing the existence of adequate system flow).
For item "E, the inadequate 10 CFR 50.59 screening criteria was identified and corrected by Edison prior to;the NRC inspection.
Specifically, the 50.59 screening process was i
improved with the issuance of TCN 0-17 to procedure SO123-0-23.
[ Note: the auto vent valve deficiency was corrected and the 0-23 closed out on November 1, 1993.]
3.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER l
VIOLATIONS i
For item "A",
appropriate Maintenance personnel will be cautioned in proper documentation and annotation requirements.
For item B-1 and B-2, this NOV response will be reviewed with appropriate Maintenance supervision during future periodic supervisory meetings.
For item B-4, procedure SO123-III-6.5 will be modified by February 18, 1994, to identify the correct oil sampling frequency and_ sampling locations.
Associated Routine Maintenance Orders (RMOs) will be changed to reflect the appropriate oil sampling i
frequency and sampling locations.
Also, for item B-5, appropriate Station Technical engineers will be given i
training on the importance of verbatim procedure compliance as part of the continual training program.
For item "D",
IST procedures will be reviewed by March 1, 1994 for similar inappropriate test methodology.
4.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance with item "A", was achieved January 10, 1994, when the individuals involved were counselled.
Full compliance with the item B-1 was achieved on October 14,1993, when the SWC pump motor testing and inspection was completed in accordance with SONGS procedures.
Full compliance with Item B-2 was achieved on December 21, 1993, when procedure SO23-I-5.23 was revised to reflect a new acceptance criteria.
Full compliance with item B-3 was achieved on November 18, 1993 when Nuclear '
Construction Engineers and technicians received focussed training on the Calibration and Control of Measure and Test-Equipment procedure. Item B-4 will be corrected by February 18, 1994, when procedure SO123-III-6.5 will'be modified to identify the correct oil sampling frequency and sampling locations.
Full compliance with item B-5 was achieved by December _21, 1993.
Full compliance with item C-1, was achieved on October 7, j
1993 when TCN 4-4 was issued to. procedure SO23-I-5.4.
l Compliance with Item C-2 was achieved on October 25, 1993 when TCN No 5-4 was issued to procedure SO23-V-3.4. and TCN 7-10 to procedure SO23-V-3.4.2.
Full compliance with item "D",
was achieved on December 21, 1993, when the new IST CCW pump check valves test methodology was incorporated into a procedure.
i Full compliance with the inadequate 10 CFR 50.59 screening criteria (item "E"), was achieved on June 4,- 1993 when TCN 0-17 to procedure SO123-0-23 was issued.
l I.
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