ML20133H335

Forwards Special Team Insp Repts 50-361/85-22 & 50-362/85-21 on 850812-23.No Noncompliance Noted.Control Over Preparation for Mod Work & Use of Work Instructions W/O Approved Maint Procedures Marginally Acceptable

ML20133H335
Person / Time
Site:	San Onofre
Issue date:	09/25/1985
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
Shared Package
ML20133H338	List: IR 05000361/1985022 ML20133H335
References
NUDOCS 8510170053
Download: ML20133H335 (4)

See also: IR 05000361/1985022

Text

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SEP 251985

Docket Nos. 50-361 and 50-362

Southern California Edison Company ,

2244 Walnut Grove Avenue

Rosemead, California 91770

Attention: Mr. Kenneth P. Baskin, Vice President

Nuclear Engineering, Safety and Licensing Department

Gentlemen:

1

Subject: NRC Inspection of San Onofre Units 2 and 3

This refers to the special team inspection conducted by Mr. W. Albert and

other members of our staff on August 12-23, 1985 of activities authorized by

NRC License Nos. NPF-10 and NPF-15, and to the discussion of our findings held

by Messrs. A. Chaffee and W. Albert and other members of our staf f with Mr. H.

B. Ray and other members of your.staf f at the conclusion of the ins.pection.

Areas examined during this inspection are described in the enclosed inspection

report. Within these areas, the inspection consisted of selective

examinations of procedures and representative records, interviews with

personnel, and observations by the inspector.

This inspection focused 60 percent of its effort upon your administrative

controls associated with the AWS, the emergency DGs, the HPSI and 125 VDC

systems and the implementation and adherence.of those controls in the

following areas: Calibration Program; Maintena'nce Program; Surveillance

Program; Vendor Field Change Notices; and Design Changes and Modifications.*

The other 40 percent of the team's effort was focused on administrative

controls in the following areas: Onsite/Offsite Committee Activities; Quality

Assurance Audits (onsite and offsite); Licensed /Non-Licensed Operator Training

and Plant Operations.

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Overall Conclusions

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l The strengths and weaknesses found in the areas examined are discussed in the

attached inspection report and also in the paragraphs summarizing the

inspection results (below). In general the team found your organization to be

competently staffed with adequate management systems as evidenced by our

review of your organization and your procedure systems. With the exception of

your control over preparations for modification work and your use of work

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instructions or drawings when approved maintenance procedures do not exist, we

l found no significant problems with the procedures or the implementation of the

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procedures. Recent events at your Unit 1 regarding the auxiliary feed water

pumps, subsequent to this inspection, indicate that your use of work

instructions or drawings may not be adequate. Management involvement was

l evident in the reporting systems provided.

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! Areas Inspected and Results

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A. Maintenance

Our inspection of maintenance activities included review of the

procedures controlling maintenance, review of selected records of

completed maintenance, verification of Quality Control Inspector

certification and evaluation of the timeliness of maintenance completion.

A concern was identified relating to the potential for violation of

Technical Specification requirements when approved maintenance procedures

were not available. Although some marginal instances were noted, no

clear-cut violations were identified in this area. In the other areas of

the inspection of maintenance activities, no items of noncompliance or

deviations were identified.

B. QA Audit Program

The quality assurance audit program as it relates to the operational and

support activities at the San Onofre facilities was found to be well

staffed, viable, and effective. The program appears to enjoy strong

support of the senior management of the Southern California Edison

Company.

C. Non-Licensed Staff Training

The inspectors reviewed the site non-licensed staff training program for

conformance with applicable regulatory requirements, licensee comitments

and industry standards. Training program implementation was also

reviewed for compliance with training program descriptions. The

inspectors concluded the non-licensed staff training program and its

implementation met evaluation criteria, with the exception of training

recordkeeping. During a record review of training received by selected

individuals, the licensee was unable to directly relate documented

training to training program requirements. However, at the NRC exit

meeting, the licensee indicated a mechanism, not previously identified,

was available to directly relate training records to program

requirements. Accordingly, this item will be evaluated in a subsequent

NRC inspection.

D. Procedures

The system for review, approval, and administrative control of procedures

was examined to ascertain whether procedures were maintained in

accordance with regulatory requirements. The technical content of

selected procedures was compared to various documents describing the

design operation of plant equipment. The inspectors concluded that

strong administrative control of procedures existed and that the

technical content of the procedures reviewed was consistent with the

Final Safety Analysis Report, the Technical: Specifications, and the

Vendor Manuals. One observation was made regarding temporary change

notices (TCN) to procedures. TCNs'are allowed to. remain effective

indefinitely. The inspectors felt that timely incorporation of TCNs into

procedures would be prudent for ease of -usage and administrative control.

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E. M: suring and Test Equipment

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The Measuring and Test Equipment (M&TE) program was inspected to

determine whether procedures were established and implemented for the

calibration and control of M&TE used to test, calibrate and repair

safety-related components and systems. The inspectors concluded that an

adequate program existed and was being implemented to ensure the proper

calibration and control of M&TE.

F. Technical Specification Surveillance

The licensee's surveillance programs for the auxiliary feedwater system,

diesel generator system, 125 volt D.C. power system, and HPSI system were

examined. The surveillances for these systems / equipment were verified by

comparing them with those surveillances required by the Plant Technical

Specifications. The program was sampled to determine the frequency and

thoroughness of the surveillances being performed. It is concluded that

the surveillance programs appear to be adequate and to function as

designed.

G. Committee Activities

The intent of this inspection was to verify that the Nuclear Safety Group

(NSG), the Onsite Review Committee (OSRC) and the Independent Safety

Engineering Group (ISEG) were functioning in conformance with Technical

Specification Requirements. The inspectors concluded that the groups

were meeting their requirements. Strengths noted during the inspection

were that, (1) QA audits were performed on all three groups within the

past year to assure that they were meeting their requirements and (2) the

OSRC chairman (Station Manager) had a major role in the discussions and

decisions made by the OSRC in the meetings that the inspectors attended.

H. Plant Modifications

During the inspection a construction activity was observed which involved

the erection of scaffolding above and on safety related electrical l

equipment. The inspectors questioned the conformance of this activity to i

applicable requirements. The NRC wished to examined other aspects of the

situation. This area will be followed up by the resident inspection

staff and reported on during a future inspection.

I. Vendor Field and Technical Manual Change Notices

.The inspectors reviewed the administrative controls and plant records to

assess the licensee's program to effectively identify, control,

distribute, schedule and implement vendor technical manual changes for

modifications and to ascertain that technical manuals are controlled and

maintained current according to a document' control program.

Several organizations are responsible for vendor mioual change control

depending on the type of change notices. Bechtel t. Siso receiving some

of the vendor's notices during this; transition,perloo. Overall, the

licensee's program and implementation.seemed adequate in this area.

Deficiency identified by previous NUS-audit appeared to be corrected.

No items of noncompliance with NRC requirements were identified within the

scope of this inspection. -

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In accordance with 10 CFRI2.790(a), a copy-of this letter and the enclosure

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will be'placed,in:the NRC'Public Document Room.

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Should you have any questions.concerning this inspection, we will be glad to

discuss them with you'. '

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l

Sincerely,

Crialnal stoned s'y

D.F.'kiks*c$,ActingDirector

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Division of Reactor Safety and Projects

Enclosures:

Inspection Report Nos. 50-361/85-22 and 50-362/85-21

cc w/ enclosure:

D. J. Fogarty, SCE

H. B. Ray, SCE, San Clemente

H. E. Morgan, SCE, San Clemente

State of CA

bec w/ enclosure:

RSB/ Document Control Desk (RIDS)

Mr. Martin

Mr. Faulkenberry

Resident Inspector

Greg Cook

bec w/o enclosure:

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