ML13316C001
| ML13316C001 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/16/1989 |
| From: | Baskin K Southern California Edison Co |
| To: | NRC/IRM |
| References | |
| NUDOCS 8903210081 | |
| Download: ML13316C001 (3) | |
Text
Southern California Edison Company P.O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 KENNETH P. BASKIN TELEPHONE VICE PRESIDENT 818-302-1401 March 16, 1989 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Docket No. 50-206 Reply to a Notice of Violation San Onofre Nuclear Generating Station
-Uni ti-1_
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Reference:
Letter, Mr.
R. P. Zimmerman (NRC) to Mr.
Kenneth P. Baskin (SCE),
dated February 16, 1989 The Reference forwarded NRC Inspection Report No. 50-206/88-28 and a Notice of Violation resulting from the routine inspection conducted by Messrs. F. R.
Huey, J. E. Tatum and A. L. Hon during the period of November 18, 1988 through January 7 and January 12, 1989. In accordance with 10 CFR 2.201, the enclosure to this letter provides the Southern California Edison (SCE) reply to the subject Notice of Violation.
If you require any additional information, please do not hesitate to call me.
Very truly yours, Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region V F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3
...III......
ENCLOSURE REPLY TO A NOTICE OF VIOLATION Appendix A to Mr. R. P. Zimmerman's letter, dated February 16, 1989, states in part:
"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 10 of Appendix A of Regulatory Guide 1.33, Revision 2, states that procedures should be provided for periodic chemistry sampling of plant systems.
"Station procedure S0123-III-1.6.1, Revision 3 (Normal Operation of the Reactor Sampling System), defines the requirements for periodic sampling of the reactor coolant system for proper concentrations of boron for core reactivity control.
Step 3.1 of this procedure requires that prior to use of the procedure_ the user must verify that the latest revision of the procedure is being used.
"Contrary to the above, between November 30 and December 24, 1988, a Unit 1 chemistry technician did not verify use of the latest procedure revision for performing reactor coolant chemistry sampling. In particular, the technician used a Revision 2 procedure which did not include the latest requirements for sampling a depressurized reactor coolant system.
"This is a Severity Level IV violation (Supplement I)."
RESPONSE
- 1. Reasons for the violation, if admitted.
SCE admits that during the period November 30 through December 24, 1988, the boron sampling of the Reactor Coolant System was performed using a superseded revision (Rev. 2) of the sampling procedure. SCE notes that there was no safety significance to this event because the samples were, in fact, taken in accordance with the provisions of the current vers.ion of the procedure (Rev. 3).
Revision 3 incorporated the existing practice of using the sample pump for obtaining the sample. Chemistry personnel had already been trained in the operation of the sample pump.
Boron samples are taken in the Primary Chemistry Laboratory (PCL) sample room. Because the room is susceptible to contamination during sampling activities, Chemistry personnel minimize the number of items brought into the PCL sample room. As such, a copy of the sampling procedure, S0123-III-1.6.1 (Rev. 2), was kept in the PCL sample room.
-2 Due to a lack of administrative controls on the use of such uncontrolled copies of procedures, when Revision 3 of S0123-III-1.6.1 was issued on September 27, 1988, the old version (Rev. 2) was not purged from the PCL. As a result, Chemistry personnel continued to use a superseded revision of the procedure.
- 2. Corrective steps that have been taken and the results achieved.
On December 27, 1988, the superseded S0123-III-1.6.1, Revision 2, was removed from the PCL sample room and replaced with Revision 3.
All Chemistry procedures, and the locations where uncontrolled copies of procedures are kept and/or utilized by Chemistry personnel, were reviewed. There were other instances identified where superseded procedures were available for use. The procedures at these locations have been updated. Chemistry supervision has been instructed to personally ensure that revisions and Temporary Change Notices (TCNs) are distributed to appropriate locations until administrative controls, discussed below, are fully implemented.
- 3. Corrective steps that will be taken to avoid further violations.
Administrative controls are being instituted on the Chemistry Department's use of uncontrolled copies of procedures. These controls will ensure that revisions and TCNs to procedures are identified and provided to Chemistry personnel.
These controls and appropriate Chemistry personnel training will be completed by May 1, 1989.
- 4. Date when full compliance will be achieved.
Full compliance was achieved on December 27, 1988, when S0123-III-1.6.1 (Rev. 3) was provided to appropriate Chemistry personnel.
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