ML13316C012

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Notice of Violation from Insp on 890306-10 & 0403-07. Violation noted:intermediate-range Reactor Trip Changed So That Trip Function Blocked Below Specified Power & Tech Spec Change Not Requested
ML13316C012
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 05/05/1989
From: Zimmerman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML13316C011 List:
References
50-206-89-09, 50-206-89-9, 50-361-89-09, 50-361-89-9, 50-362-89-09, 50-362-89-9, NUDOCS 8905230101
Download: ML13316C012 (3)


Text

APPENDIX A NOTICE OF VIOLATION Southern California Edison Company Docket Nos. 50-206, 50-361, 50-362 P. 0. Box 800 License Nos. DPR-13, NPF-10, NPF-15 2244 Walnut Grove Avenue Rosemead, California 91770 During an NRC inspection conducted during the periods of March 6-10 and April 3-7, 1989, 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 (1988), the violations are listed below:

A.

10 CFR 50.59 (a)(1) states in part that: "The holder of a license authorizing operation of a production or utilization facility may (i) make changes in the facility as described in the safety analysis report, without prior commission approval, unless the proposed change, test or experiment involves a change in the technical specifications incorporated in the license..."

The Updated Final Safety Analysis Report (UFSAR), section 7.2.1.2.2 states in part that the intermediate range high Startup Rate (SUR) "trip is active during reactor startup and blocked above 10% power."

Consistent with this statement, technical specification 3.5.1 of the license states that the intermediate range trip is to be operable in mode 1 (below 10% power) and in mode 2. Table 1.2 of the technical specifications states startup as mode 2, with a Reactivity Condition

> 0.99 K Thermal Power < 5%,

and an Average Coolant Temperature > 3500F.

These tec ical specifications were included into the license with technical specification amendment 117, issued December 13, 1988.

The NRR Safety Evaluation7with Amendment 117 states that the range of the intermediate.range is 10 % to 200% power. Neither the UFSAR.nor the Amendment describes any blocking function on.the intermediate range SUR trip below 10% power.

Contrary to the above, in March, 1989, the intermediate range ractor trip was changed so that the trip function is blocked below 10 % power, and a technical specification change was not requested.

This is a Severity Level IV violation (Applicable to Unit 1).

B.

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...."

8905230101 890505 PDR ADOCK 05000206 PDC

2

1. Administrative Procedure S0123-VI-23, "Implementation of Site Housekeeping and Cleanness Controls," sets forth the following requirements:

"6.4 Cleanliness and Protection of Facilities, Materials, and Equipment To ensure the cleanliness and protection of facilities, materials, and equipment, each individual shall cleanup after themselves in a timely manner such that quality is not affected and conditions do not degrade...."

"6.4.1.1.1 Large quantities of trash, debris, supplies, materials, and any unused equipment shall not be allowed to accumulate at any work site or create conditions that would adversely affect the quality of work...."

Maintenance Procedure S0123-I-1.20, "Seismic Controls During Maintenance, Testing, and Inspections," sets forth the following requirement:

"6.10.2 Leftover material shall be removed at the completion of the job."

Contrary to the above, on April 6, 1989:

The following materials were in three control room instrument panel cabinets, 3CR50/3CR51, 3CR52, and 3CR56:

1. Several tie wraps.
2. Spray can cap.
3. Painted metallic safety light cover with partially chipped bare metal surface exposed.

The following materials were in the Unit 3 remote shutdown panel:

1. A half of an inch thick 8.5" by 11" paper pad.
2. Spare resistor.
3. Non-metallic washers.
4. Chipped terminal block cover plate.

The following materials were in the Unit 2 remote shutdown panel:

1. Unmounted embossed labels.
2. Light bulbs.
3. A string of non-metallic washers.
2. Southern California Edison Maintenance Procedure S0123-I-4.59, "Wire and Cable Termination," sets forth the following requirement:

"6.5.3 An abandoned pull rope should be fully inserted into the conduit and the conduit ends capped or closed by suitable putty."

Contrary to the above:

3 On April 6, 1989, a pull rope was found extending beyond the end of the conduit at the top of and in the Unit 3 remote shutdown panel, wrapped around an unterminated coiled cable, and tied to the side of the panel.

The conduit end was neither capped nor closed by putty.

This is a Severity Level IV Violation (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 of 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 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 which have been taken, and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance wil1 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 actions 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. Zimmerman, Director Division of Reactor Safety and Projects Dated this £i day of (ly 1989 at Walnut Creek, California 0II