ML20235Z463
| ML20235Z463 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/19/1987 |
| From: | Baskin K SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8710210158 | |
| Download: ML20235Z463 (4) | |
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Southem Califomla Edison Compan.y P, O. B(> 8 0 0
. 2244 WALNUT OROVE AVENUE j
ROSEM EAD, CALWORNIA 91770 MENNETH P. SASKIN
- TELEPMONE
. October 19, 1987
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'U. S. Nuclear Regulatory Commission g
-Attention:
Document Control Desk Hashington, D.C.
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Gentlemen:
Subject:
. Docket Nos. 50-362
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M Reply to Notice of Violation g
. San 0nofre Nuclear Generating Station Unit 3-O
Reference:
Letter, Mr. R. P. Zimmerman (NRC) to Mr. Kenneth P. Baskin'(SCE),
dated Septemoer 22, 1987 The'above referenced letter forwarded NRC Inspection Report No. 50-206/87-21, 50-361,87-19,= 50-362/87-21 and a Notice. of Violation resulting from a routine inspection conducted by.Hessrs. Pa Qualls and J. O'Brien from August 10 through September: 4, 1987.- In accordance with 10 CFR 2.201, the enclosure to L
this letter provides the Southern California Edison (SCE) reply to the subject E-Notice of Violation.
If you have any questions or require any additional information, please do not hesitate to call me.
Sincerely, l.
Enclos're u
L cc:
Mr. J. B. Hartin (USNRC Regional Administrator, Region V)
Mr. F. R. Huey (USNRC Senior Resident Inspector)
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'871021015e 871019 PDR ADOCK 05000262.
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l ENCLOSURE NOTICE OF VIOLATION Appendix A to Mr. R. P. Zimmerman's letter states in part:
During an NRC inspection conducted on August 10 through September 4,1987, a violation of HRC requirements was identified.
In accordance with the " General Statemer.t of. Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed below:
10 CFR 50 Appendix B, Section V, states in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures..."
Licensee Procedure S0123-I-1.7, Paragraph 6.12.21, states in part:
"6.12.21 The Maintenance General Foreman or Responsible Supervisor is responsible for the following actions:
"1 Review the Hork Package Documentation (FHP) for accuracy and completeness; "2
When satisfied that the work activities and documentation are complete, the General Foreman or Responsible Supervisor shall sign and date
.the hardcopy H.O. in the ' Supervisor Approval' block..."
Contrary to the above, on September 28, 1986, Maintenance Order No.
86071243001 was signed as i>eing complete by the responsible supervisor with the QC witness space for Step 12 unsigned and with the Measuring and Test Equipment (M&TE) identification and calibration data for the equipment used not recorded.
This is a Severity Level V Violation (Sepplement I).
' REASON FOR VIOLATION The investigation into the reason for this violation included a review of pertinent documentation and personnel interviews.
SCE has determined that L
inattention to detail.is the root cause of this violation.
Both the maintenance worker and the supervisor who reviewed and approved the work done in the Maintenance Order (MO) understand the requirements of the maintenance program.
SCE has determined that the maintenance workers' failure to record the Measuring and Test Equipment (M&TE) and the failure to have the restoration step witnessed by QC, did not impact the operability of the affected equipment
- (charging. pump).
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED The individuals involved with this particular maintenance activity have been counselled.
The Quality Control (QC) Inspector had recorded the M&TE identification number s in the MO under a section entitled "QC Notes".
SCE was therefore able to locate and verify that all the M&TE utilized was in calibration.
The maintenance worker did perform all required post maintenance steps, although they were not properly witnessed by QC.
The pump was then run for 24-hours, during which time QC checks were made regarding other maintenance activities associated with the pump.
SCE Maintenance Management continues to implement a policy of critical self-assessment to improve personnel performance.
Included in this program are " professionalism audits" which check, in addition to other attributes, the preciseness with which maintenance workers record their activities.
The I
" attention-to-detail" philosophy has been implemented by training, required i
reading assignments, and continued emphasis by management.
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l CORRECTIVE STEPS.THAT WILL BE TAKEN 'R) AVOID FURTHER VIOLATIONS
. A required reading assignment, outlining the findings in the NOV and Emphasizing the importance of completed documentation, has been compiled.
ThisLtraining will be provided to maintenance craft personnel, foremen, planners and supervisors and is~ scheduled for completion by November 1,1987.
The Site Quality Assurance Organization.has scheduled a special M0 sampling 1 surveillance ~to determine to what extent and frequency errars such as the one
' described in.this.NOV occur.- Following the results of-this sneveillance, it will. be determined if additional training.is warranted.
This'QA review will be completed.by December 31, 1987.
'DATE'HHEN' FULL COMPLIANCE HAS ACHIEVED
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Full compliance was achieved on' September 29, 1986 as the M&TE utilized in this maintenance activity was in calibration, and a 24-hour run demonstrated j
operability of the charging. pump.
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