ML20117M645
| ML20117M645 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/11/1996 |
| From: | Nunn D SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9609170589 | |
| Download: ML20117M645 (4) | |
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l Dwight E. Nunn Vice President An LDISOV INTERV4TIO%tL Company September 11, 1996 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington,.D.C. 20555 Gentlemen:
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Subject:
Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation No. 9608-01 San Onofre Nuclear Generating Station, Units 2 and 3
Reference:
Letter, Mr. James E.
Dyer (USNRC) to Mr. Harold Ray (Edison), dated August 12, 1996 The referenced letter provided'the results of NRC Inspection Report 50-361/96-08 and 50-362/96-08, conducted by Messrs.
Jim Sloan, John Russell, David Solorio, Brad Olson, and Ms. Denise Garcia on June 16 through July 27, 1996, at the San Onofre Nuclear Generating Station, Units 2 and 3.
The enclosure to the referenced letter transmitted a Notice of Violation for two instances of work performed on wrong components.
The enclosure to this letter provides Edison's reply to the Notice of Violation.
While the specific circumstances identified in this Notice of Violation involve the Maintenance organization, Edison has identified instances where other Edison divisions, who manipulate components, have recently been involved in similar wrong train / component activities.
Consequently, we have formed a special team composed of Nuclear Oversight, Operations, Maintenance, Chemistry, and Station Technical personnel, who are evaluating changes to improve overall personnel performance in the area of component manipulation.
Output from this team effort will be expanded to other divisions, as applicable, to help ensure compliance with our established "self-check" program, and to ensure work is performed on the correct component.
9609170589 960911 PDR ADOCK 05000361 G
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P. O. Nx Nx !28 San Clernente, CA 92674-0128 714 368-1480 Fax 714 368-1490
a DOCUMENT CONTROL DESK If you have any questions or require additional information, please call me.
Sincerely,
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s Enclosure cc:
L.
J. Callan, Regional Administrator, NRC Region IV J. E. Dyer, Director, Division of Reactor Projects, NRC Region IV K. E.
- Perkins, Jr.,
Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2& 3 M. B.
Fields, NRC Project Manager, San Onofre Units 2 & 3 l
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ENCLOSURE Reply to a Notice of Violation NRC Inspection Report 50-361/96-08 and 50-362/96-08 issued a Notice of Violation for two separate instances where technicians performed work on the wrong component after being briefly interrupted in their work.
In the first case, an I&C Technician returned to the wrong panel and manipulated the wrong knife switch.
In the second case, a Radiation Monitor Technician returned to the wrong radiation monitor and removed its fuse.
Reasons for the Violation Corrective action training, resulting from a similar non-cited violation (NCV) in NRC Inspection Report 50-361/96-05 and 50-361/96-05, had been provided to the I&C and Radiation Monitor Technicians involved in these two instances.
Edison had trained applicable personnel on procedures, had installed adequate labeling, and had emphasized the STOP program (Stop, Think, Observe, Perform).
Edison's STOP program is consistent with INPO recommendations on Self-Checking Programs.
Program enhancements, complete with j
leadership observations to verify compliance with expectations, were in place.
Also, regular compliance meetings were being l
conducted to ensure that I&C and Radiation Monitor Technicians understood the significance of self-checking or verifying the correct equipment or component.
As such, appropriate corrective actions resulting from the NCV were in place, and the individuals involved were aware of the requirements to self-check / verify the component / equipment for performing routine surveillances.
However, due to inattention-to-detail when resuming work after a brief interruption, the technicians involved in this current violation failed to STOP and confirm they were returnjng to work on the correct component.
Edison has therefore concluded the errors were caused by cognitive individual error.
Corrective Steos That Have Been Taken Immediately following the two events, Maintenance conducted a compliance meeting.
During this meeting, Maintenance management again stressed and demonstrated the proper use of the maintenance "self-check" program (SO123-I-1.43, " Maintenance Self-Checking l
Program").
In addition, Management also stressed the l
cross-checking technique (when more than one person is assigned l
to a job) and the "STOP" program.
Management emphasized the importance of using these (positive component verification) l
self-checking techniques either before initially starting work or before resuming work after an interruption.
Appropriate disciplinary action was taken for the two technicians involved with in~these two events.
' Corrective Steos That Will Be Taken To improve individual attention to detail and adherence to our established "self-check" program, Maintenance management will:
continue shop meetings between Maintenance Supervisors and Craftsmen, as needed, to develop additional methods for preventing recurrence; revise Maintenance ^ policy-to reflect these program enhancements; obtain and implement a self-check simulator for training purposes; and incorporate self-checking into maintenance training programs.
Date When Full Comoliance Was Achieved Full compliance was achieved shortly after the events occurred on i
July 2, 1996, when the mispositioned components were restored to their correct positions.
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