IR 05000361/1993013

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-361/93-13 & 50-362/93-13 on 930903

ML20058H246
Person / Time
Site:	San Onofre
Issue date:	11/10/1993
From:	Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Ray H SOUTHERN CALIFORNIA EDISON CO.
References
NUDOCS 9312130030
Download: ML20058H246 (3)

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'e* g()y 1 0 $ 23 Docket Nos. 50-361 50-362 Southern California Edison Company 23 Parker Street Irvine, California 92718 Attention: Mr. Harold B. Ray Senior Vice President, Power Systems Thank you for your letter of October 12, 1993, in response to our Notice of Violation and Inspection Report No. 50-361/93-13, 50-362/93-13, dated September 3, 1993, informing us of the steps you have taken to correct the items which we brought to your attention. Your corrective actions will be verified during a future inspectio ~

Your cooperation with us is appreciate

Sincerely, L. F. Miller, Jr., Chief Reactor Safety Branch cc:

Mr. Edwin A. Guiles, Vice President Engineering & Operations, San Diego Gas and Electric C T. E. Dubre, Esq., Southern California Edison Company Chairman, Board of Supervisors, County of San Diego Mr. Sherwin Harris, Resource Project Manager, Public Utilities Department Mr. Charles B. Brinkman, Manager, ABB Combustion Engineering Nuclear Power Mr. R. W. Krieger, Vice President, Nuclear Generation, Southern California Edison Company Mr. Don J. Womeldorf, Chief, Environmental Management Branch, California Department of Health Services Mr. Thomas E. Bostrom, Project Manager, Bechtel Power Corporation Mr. Robert G. Lacy, Manager Nuclear Department, San Diego Gas & Electric Company Mr. Steve Hsu, Radiologic Health Branch, State Department of Health Services Mayor, City of San Clemente bec w/ copy of letter dated September 3,1993:

Docket File Resident Inspector Project inspector G. Cook R. Huey 100033 B. Faulkenberry D. Clevenger bcc w/o copy of letter dated September 3, 1993:

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Docket Nos. 50-361 50-362 Southern California Edison Company 23 Parker Street  ;

Irvine, California 92718  ;

Attention: Mr. Harold B. Ray Senior Vice President, Power Systems Thank you for your letter of October 12, 1993, in response to our Notice of Violation and Inspection Report No. 50-361/93-13, 50-362/93-13, dated September 3, 1993, informing us of the steps you have taken to correct the ;

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items which we brought to your attention. Your corrective actions will be verified during a future inspectio Your cooperation with us is appreciate .

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Sinc rely,

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. F. Miller, J ief Reactor Safety Branch cc:

Mr. Edwin A. Guiles, Vice President Engineering & Operations, San Diego Gas and Electric C i T. E. Oubre, Esq., Southern California Edison Company Chairman, Board of Supervisors, County of San Diego Mr. Sherwin Harris, Resource Project Manager, Public Utilities Department Mr. Charles B. Brinkman, Manager, ABB Combustion Engineering Nuclear Power Mr. R. W. Krieger, Vice President, Nuclear Generation, Southern California Edison Company '

Mr. Don J. Womeldorf, Chief, Environmental Management Branch, California Department of Health Service '

Mr. Thoinas E. Bostrom, Project Manager, Bechtel Power Corporation Mr. Rcbert C. Eacy, !!anager Nuclear Department, San Diego Gas & Electric

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Company Mr. Steve Hsu, Radiologic Health Branch, State Department of Health Services !

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Mayor, City of San Clemente

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October 12, 1993 U. S. Nuclear Regulatory Commission Attention: Document Control Desk washington, D.C. 20555 Gentlemen:

Subject: Docket Nos. 50-361, and 50-362

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Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2, &3 Reference: Letter from Mr. L. F. Miller (USNRC) to M Harold B. Ray (SCE), dated September 3, 199 The referented letter forwarded a Notice of Violation resulting from the NRC inspection conducted July 19 through July 23, 1993, at the San Onofre Nuclear Generating Station, Units 1, 2, and 3. This inspection was documented in NRC Inspection Report Nos. 50-206, 361, 362/93-13, dated September 3, 199 In accordance with 10 CFR 2.201, the enclosure to this letter provides the Southern California Edison (SCE) reply to the Notice of Violation. As discussed with Mr. Miller on September 10, 1993, due to the delay in receipt of the referenced letter from the NRC, the due date for the response was extended until October 12, 199 If you have any questions regarding SCE's response to the Notice of Violation or require additional information, please call m +

sincerely, ,

A Pt / /

Enclosure ccr H, Faulkenberry, Regional Administrator, NRC Region V M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 NRC Resident Inspector Office, San Onofre Units 1, 2, &3 f:

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ENCLOSURE i

REPLY TO A NOTICE OF VIOLATION I

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The Enclosure to Mr. Miller's letter dated September 3, 1993 states in part: [

"During an NRC inspection conducted from July 19, through August 6, 1993, six {

examples of a violation of NRC requirements were identified. In accordance~ j with the ' General Statement of Policy and Procedure for NRC Enforcement j Actions,' 10 CFR Patt 2, Appendix C, the violation is identified below " Technical Specification 6.8.1 states in part that written procedures f shall be established, implemented and maintained covering the applicable l procedures recommended in Appendix A of Regulatory Guide 1.33, Revision _l 2, February 1978, including those for surveillance and test activities of !

safety related equipmen .

" Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, l recommends written procedures for procedure adherence and for J!

surveillance test .

"(1) Engineering procedure SO23-V-3.5.4, Rev. 3, Temporary Change .i Notices (TCN) 3-15, " Inservice Testing of Check valves (Quarterly j Frequency), Attachment 8, Section 6.0, Note 4, required that an-NCR be initiated and an engineering operability evaluation be performed for test results outside the specified acceptance range when this range baa exceeded. The acceptance range for the flow ;

rate for the seal water flow for Salt Water Cooling System (SWCS) .

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Pump P110, as measured by Flow Indicator 2FISL6385, was required #

by Section 6.2.1 of SO23-V-3.5.4, Attachment 8, to be 2 to 7 GP for the testing of associated check valve j l

"(2) Engineering Procedure SO23-V-3.5.4, Rev. 3, TCN 3-16 and 23, l Attachment 8, Sections 6.2.8, 6.3.8, and 6.4.8 provided i instructions for the testing of Service Water System Check Valves l S21413MUO48, S21413MUO49, and S21413MUO50. Sections 6.2.8, 6. .

and 6.4.8 required that seal water flow to SWCS Pumps P133, P307, ';

and P114, respectively, be verified to be a minimum of 2 GPM to

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verify that the check valves being tested were not leaking excessively, and that the verification be performed by circling j one of the words ' Satisfactory' or 'Unsati factory.' t i

" Contrary to the above,  ;

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"(1) During testing of associated check valves, a flow rate of 11 GPM, ,

in excess of the limits specified,-was recorded for Flow Indicator ;

2FISL6385 nn November 23, 1992. but nn Ncn wan initiated and no ;

engineering operability evaluation was performed for the noted conditio l

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ENCLOSURE I

"(2) Records for surveillance testing performed on.the dates listed .

below, of saltwater Cooling System check valves listed below, did not indicate verification by circling *Satisf actory* or

" Unsatisfactory *;

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S21413MUO49, December 10, 1992 S21413MUO50, December 15, 1992 S21413MUO49, December 16, 1992 i S21413MUO48, May 12, 1993 .

S21413MUO49, May 26, 1993 ,

"These examples are considered a Severity Level V violation l (Supplement I)."

REPLY TO THE VIOLATION REASON FOR THE VIOLATION The reason for the violation was personnel error. The engineers performing the testing failed to implement the procedural requirements of

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the Inservice Testing (IST) procedure with a strict attention to detai ' CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED

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I The personnel involved have been counselled, reinforcing management's expectations with regard to attention to detail and [

compliance with procedure i

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Procedure SO23-V-3.5.4 was revised on December 7, 1992, to delete the acceptance range of 2 to 7 GPM from step 6.2.1 and replace it with instructions to only record the flow rate observe ,

SCE performed a review of 100 valve IST surveillances and 65 pum IST surveillances performed over the last two years l

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a) The review identified two additional occurrences where test data exceeded specified acceptance limits and an NCR was not initiate Both tests involved conditions similar to the example identified by the NRC, where a flow entry was outside the ;

indicated range. SCE determined that the acceptance criteria l was too restrictive and the procedure was revised in October 1992 to include appropriate acceptance criteria, prior to the August 1903 NRC Inspectica; and t

b) The review revealed 10 occurrences where the words I

" Satisfactory" or " Unsatisfactory" were not circled as required. All were associated with the SWCS attachment to <

SO23-V-3. l f

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ENCLOSURE j i These incomplete valve IST surveillance records were ;

corrected on October 7, 1993, and resupmitted to CDM for .j i

record keepin . CORRECTIVE STEPS THAT WILL BE TAKEN t

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i SO23-V-3.5.4 will be reviewed to determine if additional changes ;

are needed to clarify the intent of the procedure and revised as :

appropriate. This review and revision will be completed by December 4, l 199 This NOV and response will be distributed to all Station Technical ;

engineers and Supervisors as required reading. This will be completed by ;

November 4, 199 .

l DATE WHEN FULL COMPLIANCE WILL DE ACHIEVED Full compliance was achieved on October 7, 1993, when the IST test records were correcte .

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