ML13316B976

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Notice of Violation from Insp on 880925-1117.Violations noted:safety-related Electrical Conduit for Safety Injection Valve Found Improperly Repaired W/O Required Engineering Evaluation,Noncomformance Rept or Repair Disposition
ML13316B976
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 12/16/1988
From: Zimmerman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML13316B975 List:
References
50-206-88-24, 50-361-88-25, 50-362-88-27, NUDOCS 8901090415
Download: ML13316B976 (2)


Text

APPENDIX A NOTICE OF VIOLATION Southern California Edison Company Docket No.

50-206 50-361 50-362 San Onofre Units 1, 2 and 3 License No. DPR-13 NPF-10 NPF-15 During an NRC inspection conducted on September 25 through November 17, 1988, violations of NRC requirements were identified. In accordance with 10 CFR Part 2, Appendix C, "General Statement of Policy and Procedure for NRC Enforcement Actions," 53 Fed. Reg. 40019 (October 13, 1988), the violations are listed below:

A.

10 CFR Part 50, Appendix B, Criterion XVI requires that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

Southern California Edison Topical Quality Assurance Manual, Chapter 1-F requires that systems be established, implemented and controlled by written procedures to assure that conditions adverse to quality are identified, documented, evaluated, and corrected and that action is taken to prevent recurrence of the condition.

Station Procedure S0123-XV-5.0, Revision 2 paragraph 6.2.1, which defines nonconforming material, requires that a Nonconformance Report (NCR) be generated and properly evaluated by designated station technical personnel for deviations in the characteristic or material of safety related components. The procedure requires that this evaluation be performed prior to dispositioning repair of the component and requires that such repairs conform with component design requirements.

Contrary to the above, on October 16, 1988, a safety related electrical conduit for safety injection valve HV8528 was found to have been improperly repaired without the required NCR, engineering evaluation or authorized repair disposition having been generated. In particular, at some time prior to October 16, a tear in the plastic cover of the conduit was improperly repaired with electrical tape, which did not conform with the environmental qualification design requirements for the conduit.

Furthermore, an NCR was not generated to document the conduit deficiency and an engineering evaluation of the nonconforming condition was not performed.

This is a Severity Level IV violation (Supplement I) applicable to Unit 1.

8901.090415 981216 PDR ADOCK 05000206 0

PNU

-2 B.

Technical Specification 6.8.1 requires that applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978 be established and implemented.

Section 8.a of Appendix A of Regulatory Guide 1.33, Revision 2, states that procedures should be provided to ensure that instruments and controls, including alarm devices, are properly controlled and calibrated at specified periods to maintain accuracy.

Contrary to the above requirement, as of November 1, 1988, procedures had not been established for the periodic calibration of time delay relays on 12 safety-related feeder breakers, as set forth in paragraph 6.b of NRC Inspection Report No. 50-361/88-25. These time delay devices had not been calibrated since initial plant startup in 1982 and 1983.

This is a Severity Level IV violation (Supplement I) applicable to Units 2 and 3.

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 each violation:

(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. If an adequate reply 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 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.. i!(rman, hief Reactor Projects Branch Dated at Walnut Creek, California this !leday of s

1988 nII