ML20004E336

Responds to NRC 810410 Ltr Re Violations Noted in IE Insp Rept 50-361/81-03.Corrective Actions:Test Procedure 2HH-102-01 Reviewed Against Latest Effective Design Documents & Test Change Notices Issued

ML20004E336
Person / Time
Site:	San Onofre
Issue date:	05/04/1981
From:	Papay L SOUTHERN CALIFORNIA EDISON CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20004E334	List: ML20004E336
References
NUDOCS 8106110567
Download: ML20004E336 (4)

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Southem Califomia Edison Company P O. Box 8 00 3C5 2244 WALNUT GROVE AVENUE OSWAD, CAWONA WO L. T. PAPAy vettanoNE vict per seesser II3 572 s474 May 4, 1981 Mr. R. H. Engelken, Director

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Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Region V h

'4 WM 7 gcy d

Suite 202, Walnut Creek P~aza j' '#

1990 North California Doulevard b,# 8 Walnut Creek, California 94506 kgi

Subject:

Docket No. 50-361 San Onofre Nuclear Generating Station, Unit 2 In a letter from your office dated April 10, 1981 we were requested to respond to a Notic.e of Violation resulting from inspections of San Onofre Unit 2 construction activities which took place during the period January 16 to February 13, 1981. The condition described by the Notice of Violation in-volved failure to perform an adequate review and updating of a Startup Test Procedure prior to performing the test.

I trust the attachment responds adequately to all aspects of the Notice of Violation. If you have any questions, or if we can provide additional information, please let me know.

Subscribed on this //M day of May, 1981 by:

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L. T. 'Papay, ygce/ President Southern California Edison Company Subscribed and sworn to before me this / day of May, 1981.

N"' E AGNES CRABTREE I f MTAeVFt. Talc CA1FORNIA

=: FWINCDML OF81CE W tos v.catts couwiv Notary /'Public in and for the p ./# Mr Commism bp. Aow.1982 County of Los Angeles,

"" State of California

, Enclosure cc: R. J. Pate (NRC-San Onofre Units 2&3)

TI'71 8106110 % 7

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• • ** ATTACHMENT 1 Page 1 RESPONSE TO NRC NOTICE OF VIOLATION DATED APRIL 10, 1981 San Onofre Nuclear Generating Station, Unit 2 Response to the Notice of Violation is provided below. A statement of  !

the condition as described by the notice is given for reference. {

l NOTICE OF VIOLATION l i

Docket No. 50-361 As a result of an NRC inspection on January 16 to February 13, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,  !

1980), the following violation was identified:  ;

1 Appendix B of 10CFR50, Criterion V, states, in part, that, "A c tivities l mffecting quality shall be prescribed by documented instructions, procedures, ;

or drawings, . . . and shall be accomplished in accordance with these in- i structions, procedures, or drawings."

l Startup Test Instruction TI-2, Paragraph 5.2.2, states, in part, " Approx-imately 90 days prior to the scheduled test date ... the writing organiza-tion will withdraw the test procedure from their files for update. This update includes the following: (b) Revising / rewriting the procedure to incorporate any known design changes."

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Paragraph 5.2.3 of TI-2 states, in part, Prior to performance of the test, a final review and update of the procedure is performed by the cognizant Startup Engineer as follows: (a) Check the procedure against the latest design documents listed in the reference section."

Contrary to the above, the inspector determined on February 4, 1981, that Test Procedure 2 HA-102-01, Thermal Expansion, had not been updated to incorporate the latest design changes prior to the scheduled test date, nor had the cognizant Startup Engineer checked the procedur- against the latest design documents. As a result of the licensee's failue to perform l the required procedure reviews, approximately 30 thermal expansion measure- '

ments were not taken at the ambient temperature plateau and major revisions l were required to the data sheets in test Appendices AA,10 K,10 M,10 0, 10 Q, 10 U, and 10 W. The 260 F plateau measurements were not complete end had to be repeated. l This is a Severity Level V violation (Supplement 1). l l

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/. R'ESPONSE TO NRC NOTICE OF VIOLATION ATTACHMENT 1 Page 2 DATED April 10, 1981 o San Onofre, Unit 2

RESPONSE

1. Corrective Steps Which Have Been Taken and Results Achieved

. The condition stated in the Notice of Violation was identified in Corrective Action Request SE-F-0147, dated February 7, 1981.

The failure to perform an adequate review and update of the test procedure prior to performance of testing has been addressed by the following actions.

a. A hold was placed on Hot Functional Testing at 2600F, pending further evaluation of data. During the 4 day hold

period a review of problems related to administration of the Thermal Expansion Test was conducted. These problems, which included the noncompliance described in the Notice of Violation, were identified in a series of Corrective Action Requests. It was determined that the discrepancies noted in the CAR's did not result from a lack of controls in the Startup program but rather from a failure to adequately implement the existing controls.

b. Test Proce' dure 2HA-102-01 was reviewed again against latest effective design documents and appropriate Test Change Notices were issued.

c. A stress engineer from the design g aup was added to each team taking thermal expansion data. Ti.is engineer was made responsible for providing technical advice and consultation on data acquisition and reporting methods. Points were established in the procedure which direct the Test Engineer to obtain a review by the stress engineer.

d. All measurements at the 260 F plateau which were added by the updating of the procedure were taken.

e. Thirty (30) measurements which were added by the procedure l revision and which had not been taken during the original ambient

temperature condition were taken in accordance with the revised procedure when the system returned to ambient temperature. Cer-tain measurements which had been taken at original ambient by the use of lanyards were not repeated on return to ambient because lanyards had been removed inadvertently. A test Exception Report was initiated to disposition this omission.

'c RESFGeh -f0 NRC NOTICE OF VIOLATION DATED ATTACHMENT 1 Page 3

2. Corrective Steps Which Will Be Taken The steps listed above have been taken and documented. These steps address remedial action such as updating of the procedure and repeating affected test steps. Corrective action to prevent recurrence has included replacement of involved personnel and training sessions for Startup Engineers. The effectiveness of these remedial and corrective actions will be monitored by Quality Assurance Organization. No further corrective steps are to be taken.

3. Date When Full Compliance Will Be Achieved Full compliance was achieved on March 28, 1981 when all measure-ments required by the updated procedure had been taken and train-ing sessions had been completed for Startup Engineers.

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