ML20064B953

Forwards Comments Re Draft SALP Rept,Per NRC . Specific Plan & Schedule Developed for Full Implementation of Power Plant Mgt Info Sys

ML20064B953
Person / Time
Site:	San Onofre
Issue date:	12/03/1982
From:	Dietch R SOUTHERN CALIFORNIA EDISON CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20064B919	List: ML20064B953
References
3445H, NUDOCS 8301040254
Download: ML20064B953 (4)

Text

.

. -l . l '-

C b EcavED t=

Southern California Edison Company m***?

• • DEC -8 R1 1: E0 h

RO. BOX 800 2244 WALNUT GROVE AVENUE ROBERT DIETCH

, O j(*.,.."'

"~

..c........, December 3,1982 ,"[,," "*

Enclosure 3 U. S . Nuclear Regulatory Commission Of fice of Inspection and Enforcement Pegion V 1450 Maria Lane, Suite 210 Walnu t Creek , California 94596-5368 At ten tion: Mr . R . H . En gelk en , Regional Administrator

Dear Sir:

Sub j ect: Do cke t No s . 50-361 and 50-362 NRC Sys tematic Asses smen t of License Performance (SALP)

Response to SALP Report dated October 18, 1982 San Onofre Nuclear Generating Station, Units 2 and 3 Mr. D. M. Sternberg's letter of October 15, 1982, issued the NRC draf t SALP Report for the San Onofre Nuclear Generating Station, Units 2 and 3, and requested our comments on the SALP Feport and any actions we are initiating to improve management attention in the areas of surveillance and safeguards and security.

'Ihe enclosure o f this le tter provides our reply to the referenced SALP Report. -

If you have any ques tions or if'we ~ can provide additional informatio n, pleas e contac t me.

I Sincerely, i

i i

Fnclosure cc: A . E. Ch af fee (NRC Re s ident Insoector, San Ono fr e , Uni ts 2 and 3) 8301040254 821230

' 2 . / /'j/

PDR ADOCK 05000361 .

\

o _ _

PDR_ _ , .

()

ENCLOSURE h

Southern California Edison Company i Response to NRC SALP Report Dated October 18,198 2, on San Onofre Nuclear Generating Station, Units 2 and 3

1. SECTION V.4 - Performance Analys is o f Functional Areas -

Operations - Surveillance SALP REPORT: "Several event reports have resulted from the failure to comply with Technical Specification Limiting Conditions for Operation and surveillance requirements (82-004,82-010, 82-011,82-017, 82-020). These indicate the need for increased management attention to assure that surveillances are appropriately scheduled and performed as required by Tecnnical Specifications ."

RESPONSE: Since the issuance of the last referenced Licensee Even t Repo r t (82-020) on June 10, 198 2, additional Station Orders and procedures have been prepared wnich implemen t th e surveillance program. To assure the adequacy of procedures , all surveillance procedures for Unit 2 (and for Unit 3 as it proceeds through mode changes) are reviewed by thre e organizations , (the Corporate Nuclear Engineering Staff, Quality As surance and an independen t consultan t) , independent of die review by the cognizant Station organization.

f Additionally , a specific plan and schedule has been developed for the full implementation of the "Powe r Plan t Management Information Sys tem" (P PMIS) a t Un i t 2. PPMIS will bring together the plant data base, surveillance plan, preventive maintenance planning, and the execution of surveillance activities into a single coherent computer based s ys tem.

l II. ITEM V.7 - Performance Analys is o f Functional Areas -

+

6perations - Sa feguards and Security SALP REPORT: "The board recommends that licensee management take precautions to ensure tha t mobility o f emergency response personnel will not be inh ib ite d . "

i

. . - . , _.s. m_ .- ,_- , . _ . _ - . - . _ _ .

. h - {.),

RESPONSE: As noted in the discussion of Safeguards and Security , a number o f corrective actions were implemented following the NRC Region V Safety / Security Interface Task Force review in order to ensure the mobility of emergency response personnel will no t be inhibited. A subsequen t review by the NRC was undertaken in November 1982 by the Committee to Review Safeguards Requiremen ts at Power Reactors chaired by Mr. Ronald C . Haynes.

_ SC E recognizes dia t this committee _ has da e ability, if not the mandate, to revise NRC safeguards rules to ensure that implementation of security does not unacceptacly encumber plant acces s during emergency conditions. Inasmuch as SCE had initiated action leading to the eventual replacemen t o f equipment ins talled and utilized at San Onofre to control access , and the results o f th e committee's work will like ly change requirements placed on such equipment, SCE's plans for security system replacement by 1984 are being delayed. Tais is being done in order that any re gulato ry change s s temming from th e committe e's activities may be properly incorporated in any comprehens ive sys tem replacemen t. A revised schedule for sys tem replacement will be provided to the NRC in 1983 following the completion of the committee's review.

III. ATTACHMENT I - Functional Area Evaluation - Licens ing Ac tivi tes SALP REPORT: " Management involvement. . .was below average in the area o f Technical Specifications. Tais below average rating is based on the relatively frequent eques ts fo r emergency Technical Specification changes that have occurred s ince the Unit 2 Operating Licens e was issued."

RESPONSE: We have reviewed the nine Engineering Technical Specification change reques ts made for Unit 2 since issuance of the Operating License, and have concluded the frequency of these enanges is justified and appropriate and should not result in a "below average" rating as s tated in the Draf t SALP repor t.

t

h h San Onofre Dait 2 is the firs t 3400 megawatt class CE plant. It is also the firs t CE plant to be licensed since ANO-2 wnich was licensed July 18, 1978. Several reques ts resulted from a tartup problems on equipment which is eidler oifferent from or not included in the design of ANO-2 (i.e. ,

Regulatory Guide 4.15, Revision 2, radiation monitoring sys tem and the pos t-accident s ampling sys tem) . It is no t unexpected tha t s tartup of a plant which is four years removed from its nearest counterpart would entail unanticipated equipment proble ms .

In addition to changes related to equipment problems , a few of the changes have resulted from inaccuracies in the Technical Specifications th ems elve s . There were two revisions to the CE Standard Technical Specifications between ANO-2 and San Onofre Unit 2. As with ut e des ign itself ,

the Unit 2 Technical Specifications include completely new sections no t covered by the ANO"2 Technical Specifications .

3445h 0219U

_- . .- . _ - _ . - _ _ _ . _ _ _