ML13316B889
| ML13316B889 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/15/1988 |
| From: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13316B888 | List: |
| References | |
| 50-206-88-03, 50-206-88-3, 50-361-88-03, 50-361-88-3, 50-362-88-03, 50-362-88-3, NUDOCS 8804290300 | |
| Download: ML13316B889 (3) | |
Text
APPENDIX A NOTICE OF VIOLATION Southern California Edison Company Docket Nos.
50-206 50-361 50-362 San Onofre Units 1, 2 & 3 License Nos. DPR-13 NPF-10 NPF-15 During an NRC inspection conducted during the period of January 17, 1988 through February 27, 1988, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violations are listed below:
A. Technical Specification 3.7.1 requires all main steam line code safety valves to be operable with lift settings as specified in Table 3.7-1 when the reactor is in Mode 1, 2 or 3. Table 3.7-1 specified setpoints for the nine safety valves on each steam line ranging from 1100 to 1155 psia.
Contrary to the above requirements, in 1986 and early 1987, Units 2 and 3 were operated in Mode 1 for more than 7 and 11 months, respectively, with two safety valves in each unit set 3 to 8 psi above the highest allowed setpoint, and an additional valve in each unit set 7 to 14 psi above a lower specified setpoint. The licensee's evaluation showed that these incorrect setpoints would have caused the reactor coolant system peak pressure during the most severe transient (loss of condenser vacuum) to increase by less than 1 psi.
This is a Severity Level IV violation, applicable to Units 2 and 3 (Supplement I).
B. Technical specification 6.8.1.c requires that written procedures be established, implemented and maintained covering surveillance and test activities of safety related equipment.
Station operating procedure S01-12.9-11, Temporary Change Notice (TCN) 4-17, specified surveillance testing requirements for the safety related backup nitrogen system for auxiliary feedwater system flow control valves FCV 2300, 2301, 3300 and 3301. In particular, step 6.5.12 of the procedure required that:
"If any cylinder falls below its minimum required pressure (2013 psig),
then initiate maintenance to ensure the cylinder is replaced within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />."
Contrary to the above, during the period between January 14 and February 1, 1988, one of the eight backup nitrogen system cylinders for the auxiliary feedwater system flow control valves was at a pressure less than the minimum required pressure, and proper maintenance was not initiated to correct a leaking cylinder regulator valve.
R,8042903'00 880415 PDR ADOCK 05000206 DCD
2 This is a Severity Level IV violation, applicable to Unit 1 (Supplement I).
C. 10 CFR 50, Appendix B, Criterion 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, or drawings."
Chapter 1F of the licensee's Topical Quality Assurance Manual states the following requirement:
"1.0 Systems shall be established, implemented and controlled by written procedures to assure that conditions adverse to quality are identified, documented,.evaluated and corrected in a timely manner and that action is taken to prevent recurrence of the condition...."
General Procedure 50123-XV-5.0, TCN 1-5, titled Nonconforming Material, Parts or Components, paragraph 6.2.1.5, required that items found not to be in accordance with drawings or other design disclosure documents that are in use in the plant are to be documented on a nonconformance report.
Contrary to the above, the following nonconforming conditions were not documented on a nonconformance report:
- 1. On February 1, 1988, during disassembly of HPSI valve MU-012 on Unit 3, a mechanic identified that the yoke bushing was not tack welded as required by the station valve drawing (3527-3, Revision 0).
- 2. On February 4, 1988, during replacement of solenoid coil 2HY8205AX for MSIV 2HV-8205, an electrician identified that the electrical circuit was not labelled in accordance with the electrical circuit diagram (30548, Revision 13).
This is a Severity Level IV violation, applicable to Units 2 and Unit 3 (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region V, and a copy to the NRC Senior Resident Inspector, San Onofre, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for violations B and C above:
(1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. In view of the actions taken by SCE and documented in licensee event report 50-361/85-61, a response to violation A is not required. If an adequate reply for violations B and C is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or.revoked or why such other
3 action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
FOR THE NUCLEAR REGULATORY COMMISSION R. P.'Zimme n, Chief Reactor Projects Branch Dated at Walnut Creek, California this IS -1 day of
, 1988