ML20141C502
| ML20141C502 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/09/1997 |
| From: | Krieger R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20141C506 | List: |
| References | |
| 50-361-96-018, 50-361-96-18, 50-362-96-018, 50-362-96-18, NUDOCS 9705190077 | |
| Download: ML20141C502 (3) | |
Text
i
'4 SOllIHERN CAuf ORMA R. W. Krieger
%cc President (D -
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Nuclear Generation 8
An EUf5oN INTERNATIONAL Company c i
s May 9,1997 t
U. S. Nuclear Regu'atory Commission Document Control Desk Washington,D.C. 20555
Subject:
Licensee Event Report (LER) No. 2-97-001, Revision 3 Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station, Units 2 and 3
References:
(1)
Licensee Event Report No. 2 96-009, Revision I, Dockct No. 50-361, dated January 30, lo97 (2)
NRC Inspection Report 96-018, Docket Nos. 50 361 and 50-362, dated January 24, 1997 Reference 1 reported Edison identification of a problem with the implementation of the Technical
- Specification Improvement Project (TSIP). As corrective action, Edison committed to a comprehensive self assessment of every Technical Specification (TS) Surveillance Requirement (SR). To assure the bounds and generic implications of the TSIP implementation problems were understood and addressed, this review was not limited to SRs changed as a result of TSIP. Rather, it looked at every SR in detail to determine if existing procedures fully implemented the SR.
This review involved an Edison multi-disciplinary team composed of over 50 engineers, and lasted more than two months. The enclosed LER provides the results of our review,"Self Assessment Implementation of SONGS 2/3 Technical Specifications Surveillance Requirements, SEA 97-0')l."
Please note that for each discrepancy example identified by the SEA 97-001 revtiew, where the TS SR was not fully consistent with the surveillance procedures, there was no safety significance or safety consequence to the discrepancies. There were no cases where safety-related equipment was not properly msintained, nor were there any instances in which safety related equipment was not capable of performing its inter.ded safety function.
The SEA 97 001 review did identify three separate problem areas where TS SRs were not fully consistent with the associated surveillance procedures:
1.
Proiect Mattgement For the TSIP Effort [5 examples}. Edison's project management of the TSIP elTort (approx!imately 1375 pages in 4 Volumes for each Unit) did not ensure adequate technical i
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reviews of the TS SR and the implementing surveillance procedures. A contributing cause was the V
- failure of some reviewers to appreciate subtle TS SR wording changes. Two of these examples 9705190077 970509 I
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Document Control Desk May 9,1997 required Notices of Enforcement Discretion (NOEDs) authorizing delayed implementation of the Unit 3 TS SR until the Cycle 9 refueling outage.
Early Plant TS SR and Surveillance Procc3 ures (7 examples). During the period 1980-1985, Edison 1
2.
personnel did not properly translate TS SRs into surveillance procedures (cognitive personnel error).
Due to the passage of time, more detailed root cause infoimation could not be determined. One of these examples required a NOED authorizing delayed implementation of the Unit 3 TS SR until the Cycle 9 refueling outage.
3.
Contemporary TS SR and Surveillance Procedures [2 examples]. During the period 1985-1995, Edison personnel did net properly translate TS SRs into surveillance procedures (pre-TSIP)(cognitive personnel error). Neither of these examples required a NOED.
The following two examples illustrate these problems:
TS Requirstdhli Load Testina of the Diesel Generators. In this example, the new TSIP TS SR required a less rigorous test of diesel performance (lower kW loading) than the previous TS SR.
Thus, when TSIP became effective, the last surveillance performed did not satisfy the new requirement verbatim. This was the subject of one of the NOEDs discussed in item I above.
The NRC staff approval of the NOED stated that diesel functionality was never compromised.
IMson's review identified this as a discrepancy example even though the test of record for the previous TS SR was more rigorous.
Signage. for Certain Comnematorv Fire Hoset In this example, because signs had been attadtg31 19 the compensatory hoses rather than pmissi above the hoses as required by the pre-TSIP TS Action Statement, Edison was not in verbatim compliance. Edison's review considered this to be a discrepancy example even though the full time on-site fire department carries their own fire hoses, and would not have used the compensatory hoses.
Edison has discussed the results of our review with other Region IV licensees through the Region IV Utility Group (RUG IV), and with the CE Owners Group Licensing Subcommittee. Edison is separately providing copies of this LER and SEA 97 001 to these groups because our lessons learned may be of benefit to other licensees.
NRC Region IV staff have been closely following the progress of the SEA 97-001 review. Reference 2 discussed the issue, and opened NRC Unresolved Item No. 50-361(362)/96 18-02. Edison believes that the information contained in the enclosed LER 2-97-001 R3 should resolve all outstanding questions.
As discussed in the enclosed LER, Edison believes: (1) the examples were licensee identified and reported; (2) all examples have been or are being promptly corrected; (3) most examples were, in fact, identified as a result of the thoroughness of Edison's review; (4) none of the examples were safety significant or had safety consequence; (5) individually, each example constitutes a minor violation; (6) the three cases have significantly different underlying root cause(s) and/or are significantly separated in time, and therefore should be evaluated separately; (7) viewed separately, each of the three cases is indicative of poor individual personnel or management performance, rather than a programmatic breakdown; and (8) Edison
Document Control Desk May 9,1997 management has aggressively responded to the situation [special training, document revisions, changes to equipment, preparation of over 300 Action Requests]
Ifyou have any questions, please contact me.
Sincerely, f
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Enclosure:
LER No. 97-001-03 cc:
E. W. MerschofT, Regional Administrator, NRC Region IV T. P. Gwynn, 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, Units 2 and 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 Institute of Nuclear Power Operations (INPO)