ML20096C741
| ML20096C741 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/11/1992 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9205140265 | |
| Download: ML20096C741 (4) | |
Text
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- I ~ C' Southem Califomia Edison Company 23 PARKER STREET tRvlNE. CALIFOR"'A 92718 HAROLD B RAY 7,ttawoht May 11, 1992 u....c.......,
7....oo U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Dccket No. 50-361 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Unit 2
Reference:
Letter Trom Mr. S. A. Richards (USNRC) to Harold B. - Ray (SCE), dated April 2, 1952 The referenced letter forwarded-a Notice of Violation resulting from the routine NRC inspection conducted from January 28, 1992 through March 10, 1992, at the San Onofre Nuclear Generating-Station, Units 1, 2,
and 3.
This inspection was documented in NRC Inspection Report Nos. 50-206/92-06, 50-361/92-06, and-50-362/92-06.
In accordance with 10 CFR 2.201, the enclosure to this letter provides the Southern California Edison (SCE) reply to the Notice of Violation.
If you have any questions regarding SCE's response to the Notice of Violation.or require' additional information, please call me.
Sincerely, b
Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region V k
C. W. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2,
and 3
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ENCLOSURE Reply to a Notice of Violation The-enclosure to Mr. Richards' letter dated April 10, 1992 states
-in.part:
1 "10 CFR 50.59 (b) (1) states, in part, that the licensee shall maintain ~ records carried out pursuant to making changes to the facility and that these records must include a written safety evaluation which provides the bases for the determination that N
the change does not involve an unreviewed safety question.
10 CFR 50.59 (a) (2) (ii) states that a change'is deemed to involve an.
unreviewed-safety question-if the possibility for a malfunction of a different type than any evaluated previously in the safety analysis report may.be created.
" Contrary to the.above, as of December 31, 1991, the licensee installed and operated temporary facility modification (TFM) 2-91-BHA-001, Revision 0, that introduced a credible chemical spray hazard to safety related components in the high pressure safety
- injection, containment spray, shutdown cooling, and low pressure
-safety' injection systems..- The-safety evaluation did not consider all potentially affected components nor did it document the bases for this~ modification's acceptability, given that the.
environmental qualifications _of safety related components could have been impacted.
"This 'is a Severity' Level-IV violation (Supplement I) "
REPLY TO NOTICE OF VIOLATION May 11, 1992
RESPONSE
1.
Reasons for the violatignu Trained and experienced SCE engineers are typically assigned the responsibility of preparing Temporary Facility Modifications (TEMs), including the associated safety evaluation (10 CFR 50.59).
In addition, a substantial technical and supervisory review of TFMs is conducted prior to their implementation.
TFM 2-91-BHA-001 was prepared under the direction and oversight of SCE supervision, by a contract engineer with no previous experience with respect to SCE temporary
- aodifications.
However, the review of the TFM, including the safety evaluation, performed by SCE supervision was inadequate, in that it did not effectively take into account the experience of the engineer.
As a consequence, even though the Environmental Qualification (EQ) issues associated with the modification were considered during the TFM preparation, the review was not sufficiently 1igorous to ensure that all the components potentially affected by the TFM, including EQ aspects, were formally addressed..
2.
Corrective steps that have been taken and the resulta achieved.
Revised TFM
.On April 4, 1992, Revision 1 of TFM 2-91-BRA-001 was issued.
The safety evaluation in Revision 1 included a documented assessment of the impact of the TFM on the EQ of installed components.
This evaluation concluded that the TFM would not affect the EQ of important-to-safety plant equipment and components.
Training The engineer was trained on the requirements of SCE management relating to the thoroughness of safety evaluations.
REPLY TO NOTICE OF VIOLATION May 11, 1992 3.
Corrective steps that will be taken to avoid __further violations.
Management Direction to Supervision SCE management will meet with Station Technical supervisors and emphasize the expectation that supervisors are to ensure that assignments to engineers are consistent with their technical capabilities.
In addition, supervisors will be reminded of their obligation to provide a level of oversight of technical work commensurate with the qualifications and experience of each of the contributors.
Revise Procedure Procedure SO123-V-5.10, " Temporary Facility l
Modification (TEM) ", will be revised by August 15, 1992, to include more specific controls that ensure safety evaluations include a complete and documented EQ evaluation when temporary modifications have the potential of impacting the environmental qualification of important-to-safety components.
In addition, the revised procedure and this NOV response will be incorporated into the lessons learned portion of the training program for TFMs and safety evaluations.
Review Safety Evaluations l
Although it is believed the problems associated with Revision 0 of this TFM represent an isolated case, SCE will review safety evaluations for TFMs currently installed in Units 1, 2,
and 3.
This review will ensure the environmental impact of those TFMs has been properly evaluated and documented.
4.
Date when full compliance will be achieved.
Full compliance was achieved on April 4, 1992, when Revision 1 of TFM 2-91-BHA-001 was issued.
The safety j
evaluation in Revision 1 documented the basis for concluding l-the TFM would not affect the EQ of important-to-safety plant equipment and components.
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