ML20246B570

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Forwards Enforcement Conference Repts 50-361/89-19 & 50-362/89-19 on 890602 & Notice of Violation.Importance of Prompt Corrective Actions for Identified Engineering Program Deficiencies Addressed During Conference
ML20246B570
Person / Time
Site: San Onofre  
Issue date: 06/22/1989
From: Faulkenberry B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Papay L
SOUTHERN CALIFORNIA EDISON CO.
Shared Package
ML20246B574 List:
References
NUDOCS 8907100012
Download: ML20246B570 (3)


See also: IR 05000361/1989019

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Docket Nos. 50-361 and 50-362

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Southern California Edison Company

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. P.- 0. Box 800

2244 Walnut Grove Avenue

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Rosemead, California 92770

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' Attention:- Dr. L. T. Papay,

LSenior Vice President

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'Gentiemen:-

This refers to the enforcement conference held with Mr. K. P. Baskin,

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Mr. C. B. McCarthy Jr., and other members of the SCE staff. at the Region V.

office on June 2,1989. 'The subjects discussed' are summarized in the:

enclosed report.A copy of the conference agenda is also' enclosed.

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- The. purpose of the' enforcement conference was to' discuss the circumstances.

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2 associated with SCE's failure to take appropriate actions after the discovery

of low: Freon levels for the San.0nofre Units 2 and 3 emergency chillers, and

- the consequent inoperability of the chillers. . Also discussed was your

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. staff'.s. failure to incorporate appropriate design characteristics for the

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chillers'into applicable station procedures.

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- During,the conference, we noted that the emergency. chiller issue. is an addi-

tional. example of the need for improved engineering work which prompted SCE

in'1988 to reassess and. reorganize its ' engineering division.

It.was also

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' acknowledged that ycur evaluation.of engineering program deficiencies,and the

associated corrective actions being implemented have.been extensively dis-

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cussed in' previous correspondence and.during. previous'NRC management meetings,

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Thejmportance of prompt corrective actions for identified ' engineering pro-

p m deficiencies was addressed during the conference, the discussion also

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focused on two associated issues which have not previously been.specifically-

addressed. ~As discussed further in the enclosed report, we emphasized the

following principal areas of NRC concern:

1.

Missed Opportunities to Correct the Emergency Chiller Problems

The primary symptoms of the emergency chiller problem were indications

of low Freon level in the chiller units and instances of failure of the

units to properly operate., The inspectors determined that there were

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. numerous opportunities over 'a number of years for licensee management

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and quality oversight activities to have identified and corrected the

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problems.

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During the conference, the NRC emphasized that the indicators of a sig-

nificant problem were not particularly subtle c,r difficult to recognize.

For example, there were repeated instances during which zero Freon level

in the chiller units were observed and documented by plant operators.

8907100012 890622

PDR

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SCE's failure to properly respond to this problem indicated a need for

additional operator attention to equipment conditions, and for addi-

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tional involvement by licensee organizations responsible for overview of

plant operations. This problem also appears to highlight the need for

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continued, if not additional, emphasis on more effective interface

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between plant operating and engineering / technical support organizations.

2.

Lack of Proactive Actions to Identify and Correct Potential Similar

Problems with Other Plant Safety Equipment

As addressed in licensee event reports (LERs), SCE has implemented

numerous actions to correct problems associated with the emergency

chiller system. However, the LERs did not adequately address' generic

concerns with other safety system parameters which may not have been

properly defined and incorporated into operating and maintenance

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procedures.

It was noted during the conference that SCE appeared to be

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placing considerable reliance on long term corrective actions (e.g. the

design basis document improvement program) to address generic aspects of

the emergency chiller issue. As emphasized during the conference, how-

ever, we consider additional shorter term actions to also be warranted.

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Mr. McCarthy and Mr. Baskin acknowledged the NRC's comments, including those

summarized above, and stated that they would be prepared to address the NRC

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concerns at greater length at the June 27 management meeting.

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Based on the results of the NRC inspection, as documented in NRC Inspection

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Report Nos. 50-361/88-35 and 50-362/88-37, dated May 5, 1989, it appears that

certain of your activities were not conducted in full compliance with NRC

requirements, as set forth in the Notice of Violation, enclosed herewith as

Appendix A.

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Your response to this Notice is to be submitted in accordance with the

provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violation.

In accordance with 10 CFR 2.790(a), a copy of this letter, the enclosure, and

your response will be placed in the NRC Public Document Room.

The response directed by this letter and the accompanying Notice are not

subje:t to the clearance procedures of the Office of Management and Budget as

required by the Paperwork Reduction Act of 1980, PL 96-511.

Should you have any questions concerning this inspection, we will be pleased

to discuss them with you.

Sincerely,

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B. H. N.ulkenberry

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Deputy Regional Administrator

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Enclosures:

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Appendix A - Notice of Violation

2.

Meeting Report Nos. 50-361/89-19 and 50-362/89-19

3.

Meeting Agenda

cc w/ Enclosures:

K. P. Baskin, Vice President (Rosemead)

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C. B. McCarthy, Vice President (San Clemente)

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H. E. Morgan, Station Manager (San Clemente)

State of California

bcc w/ copy of onclosures:

Docket File

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Project Inspector

Resident Inspector

G. Cook

B. Faulkenberry

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J. Martin

A. Johnson

R. Nease, NRR

J. Lieberman, OE

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