ML13316C024
| ML13316C024 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/16/1989 |
| From: | Kirsch D NRC/IE, NRC/RGN-V |
| To: | Baskin K Southern California Edison Co |
| References | |
| NUDOCS 8906270190 | |
| Download: ML13316C024 (9) | |
See also: IR 05000206/1989009
Text
Docket Nos. 50-206, 50-361, 50-362.
Southern California Edison Company
P. 0. Box 800
2244 Walnut Grove Avenue
Rosemead, California 91770
Attention:
Mr. Kenneth P. Baskin, Vice President
Nuclear Engineering, Safety, and Licensing Department
Gentlemen:
Thank you for your letter of June 5, 1989, in response to our Notice of
Violation and Inspection Report No. 50-206/89-09, 50-361/89-09 and
50-362/89-09, dated May 5, 1989, 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 inspection.
Your cooperation with us is appreciated.
Sincerely,
Dennis F. Kirsch, Chief
Reactor Safety Branch
bcc w/copy of 1tr. dated 6/5/89:
Docket File
Resident Inspector
Project Inspector
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B. Faulkenberry
J. Martin
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State of California
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REGION V
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Southern California Edison Company
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2244 WALNUT GROVE AVENUE
ROSEMEAD, CALIFORNIA 91770
KENNETH P. BASKIN
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VICE PRESIDET
June 5, 1989
U. S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, D.C. 20555
Gentlemen:
Subject:
Docket Nos. 50-206, 50-361 and 50-362
Reply to a Notice of Violation
San Onofre Nuclear Generating Station,
Units 1, 2 and 3
Reference:
Letter, Mr. Roy P. Zimmerman (NRC) to Mr. Kenneth P. Baskin (SCE),
dated May 5, 1989
The Reference forwarded NRC Inspection Report Nos. 50-206/89-09, 50-361/89-09
and 50-362/89-09 and a Notice of Violation resulting from the routine
unannounced inspection conducted by Messrs. J. F. Melfi and F. S. Gee during
the period of March 6 through March 10 and April 3 through April 7, 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 so advise.
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
ENCLOSURE
REPLY TO A NOTICE OF VIOLATION
Appendix A to Mr. R. P. Zimmerman's letter, dated May 5, 1989, states in part:
"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 (1)
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 ate (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 h
350 degrees F. These technical specifications were included into the
license with technical specification amendment 117, issued December
13, 1988.
"The NRR Safety Evaluation with Amendment 117 states that the range
of the intermediate range is 1 E-7% to 200% power. Neither the UFSAR
nor the Amendment describes any blocking function on the intermediate
range SUR trip below 10% power.
"fContrary to the above, in March, 1989, the intermediate range
reactor trip was changed so that the trip function is blocked below 1
E-4% power, and a technical specification change was not requested.
"This is a Severity Level IV violation (Applicable to Unit 1)."
RESPONSE TO ITEM A
1.
Reasons for the violation, if admitted.
SCE admits that in March 1989, the Intermediate Range reactor trip
was changed so that the trip function is blocked below1 E -4%
power,
and a technical specification change was not requested. Although no
-2
credit is taken in the accident analyses for the Intermediate Range
High Startup Rate (SUR) Trip, a change to the technical specification
was submitted to NRR, at the direction of Region V, on April 11, 1989
(Proposed Change Number [PCN]-208).
During the Cycle X refueling outage for Unit 1, a new nuclear
instrumentation system (NIS) was installed. This work was performed
under Design Change Package (DCP) No. 1-3003. In accordance with
procedure E&C 24-10-16, DCP No. 1-3003 was reviewed and appropriate
changes to the Technical Specifications were submitted (PCN-180).
During performance verification testing of the NIS, significant noise
interference was observed when certain pieces of equipment were
operating. Specifically, the NIS Intermediate Range High SUR Trip
spuriously actuated when certain electrical devices were operated.
In accordance with procedure S0123-XV-5.0, "Nonconforming Material,
Parts, or Components", .a
Nonconformance Report (NCR) No. S01-P-7112
was issued on March 10, 1989, to document the spurious actuations.
The evaluation of NCR S01-P-7112 concluded that the new NIS system's
Intermediate Range was so large (in
actuality it also encompasses the
full Startup and Power Ranges) it was susceptible to noise
interferences at the low end of its range. The NCR disposition to
fix the spurious actuations, was to modify the NIS system by.
installing.a trip-block to the High SUR Trip below 1 E-4% power.
This modification was effective in eliminating the spurious
actuations.
In accordance with procedure S0123-XV-5.0, a safety evaluation was
performed as part of the NCR. The safety evaluation review
established that no credit is taken for the NIS High SUR Trip in the
accident analyses. Therefore, the NCR concluded that there was: (a)
no increase in the probability of occurrence of an accident or
malfunction previously evaluated in the UFSAR; (b)
no increase in the
consequences of an accident or malfunction previously evaluated in
the UFSAR; (c)
no creation of a different type of accident or
malfunction than any previously evaluated in the UFSAR; and (d) no
reduction in the margin of safety as defined .in
the bases of the
Technical Specifications. Therefore, the NCR correctly concluded
that there was no impact on safety from installation of the trip
block.
To effect the physical modification to the Intermediate Range High
SUR Trip circuit, a Field Interim Design Change Notice (FIDCN) was
prepared in accordance with procedure-E&C 24-10-17. Procedure E&C
24-10-17,Section II, Step 2 states in part: "If field changes meet
the Exhibit I criteria, prepare an FIDCN... If field changes do not
meet this criteria, initiate a revision to the DCP..."
Exhibit I,
Step 2, states in part: "...
An FIDCN shall not be used for the
following changes. These changes must be issued using a DCP or DCP
-3
revision..."
Step 2.F. continues "... Changes to instrument
span/range, setpoints or computer software which are imposed by the
UFSAR or Technical Specifications."
During the preparation of the FIDCN, Exhibit I was reviewed and it
was concluded that the Intermediate Range span/range was not being
changed (the-High SUR Trip was being blocked while the Intermediate
Range channel was not changed). Had Exhibit I.2.F included the
instrument function, as described in the Technical Specifications, an
FIDCN would not have been prepared.
Therefore, SCE has concluded that the lack of clarity in procedure
E&C 24-10-17, misled reviewers in whether a DCP revision was
required. Had a revision to the DCP been prepared, wider
interdisciplinary review would have been provided and a formal
documented assessment made as to whether the modification
necessitated a change to the Technical Specifications.
Notwithstanding that an FIDCN was incorrectly issued in lieu of a DCP
revision, informal consideration was given by management personnel to
initiating a Technical Specification change. When reviewing
Technical Specification Table 3.5.1-1, it was concluded that since no
credit is taken for the trip feature for plant protection and because
the system would retain the capability to provide its function for
design basis events, a change to the Technical Specification would
not be considered necessary.
The final analysis regarding whether a Technical Specification change
was required concluded that if a Technical Specification change was
to be submitted, it would be administrative in nature. As such, it
was SCE's intention to resolve this item during a future submittal of
administrative Technical Specification corrections.
2.
Corrective steps that have been taken and the results achieved.
At the direction of Region V, an emergency Technical Specification
amendment request (PCN-208) was submitted to NRR on April 11, 1989,
which added a footnote to Table 3.5.1-1 in the Technical
Specifications to indicate the Intermediate Range High SUR Trip is
not available for all of Mode 2 but only above 1 E-4% power.
3.
Corrective steps that will be taken to avoid further violations.
By August 1, 1989, procedure E&C 24-10-17 will be revised to provide
enhanced guidance on FIDCN/DCP usage.
In addition, to ensure that management personnel understand the
importance of not only complying with the Technical Specifications
but also for the Technical Specifications to be an accurate
reflection of plant design, a letter will be written by the Manager
I0
-4
of Nuclear Licensing for all NGS and NES&L Engineering Supervision
personnel.
The letter will emphasize that if any changes to
equipment discussed in the Technical Specifications are made during
plant modifications, a Technical Specification change cannot be
discounted based on the fact that the change has no safety
significance.
4.
Date when full compliance will be achieved.
Full compliance was achieved on May 16, 1989, when Technical
Specification Amendment 126 was approved by NRR.
Appendix A to Mr. R. P. Zimmerman's letter, dated May 5, 1989, states in part:
"B.
10 CFR 50, Appendix B, Criterion V, states in part:
'Activities affecting quality shall be prescribed by documented
instruction, procedures, or drawings, of a type appropriate to the
circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings....
"I. 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:
0
-5
1.
Several tie wraps.
2.
Spray can cap.
3.
Painted metallic safety light cover with partiall
chipped bare metal surface exposed.
"The following materials were in the Unit 3 remote
shutdown panel:
1.
A half 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 50123-1
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:
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)".
RESPONSE TO ITEM B
1.
Reasons for the violation, if admitted.
SCE admits that the items listed above were found in the control room
and remote shutdown cabinets.
SCE admits that the pull rope listed above extended beyond the
conduit in the Unit 3 remote shutdown cabinet. However, there is no
safety significance associated with this condition.
-6
Cabinet Material-Condition Inspections
As a result of a previous Notice of Violation issued July 19,
1988, for failure to follow separation criteria specified in
SONGS Construction Specification, CS-E03, Revision 17, entitled
"Safety Related and Non-Safety Related Electrical Construction
Specification for Cable Splicing, Termination and Supports, SCE
committed to inspect the material conditions of electrical
cabinets in the letter from Mr. Kenneth P. Baskin (SCE) to NRC
Document Control Desk, dated August 28, 1989:
"... The remainder of the Unit 2 panels containing
redundant trains will be inspected for compliance with
CS-E03 during the next outage of sufficient duration
(when the risk of an inadvertent plant transient/trip
does not exist). This delay in completing the Unit 2
inspection is justified based on the absence of
safety-significant findings in the inspections performed
on Unit 2 to date and in the complete inspection of Unit
3."
Accordingly, SCE scheduled Unit 2 cabinet inspections for the
Cycle V Outage, which is anticipated to begin in the Fall 1989.
SCE reiterates the aforementioned commitment that during the
Cycle V outage the Unit 2 cabinets will be opened, examined for
cable separation, and appropriately groomed and cleaned.
As stated above, the Unit 3 cabinets were inspected during the
last outage and were groomed and cleaned to an acceptable
standard at that time. An investigation into the listed
conditions was unable to identify the specific individual(s)
responsible for leaving the debris found in the Unit 3
cabinets.
SCE has concluded the referenced minor amounts of debris in the
Unit 3 cabinets were apparently inadvertently overlooked during
the cleanup or occurred during subsequent activities.
Inspection of Pull Ropes
During the initial construction of Units 2 and 3, SCE followed
the established, industry practice of abandoning pull ropes
after installing conduit wiring.. Because the ropes are non
conducting, construction procedures did not require the removal
of pull rope ends and there may be other instances of abandoned
pull ropes with exposed ends.
In January 1988, SCE issued TCN 0-21, to procedure 50123-I
4.59, to include the referenced step 6.5.3. The purpose of
this procedure step was to establish a mechanism by which, over
1,
-7
time as routine maintenance activities were performed, the pull
ropes might be groomed. However, the procedure intentionally
used "should" to indicate that this is a suggested, and not
mandatory, practice.
Material Condition Goals
It is the goal of the referenced SCE procedures to keep
material conditions clean and neat. SCE procedures go beyond
both ANSI N45.2.3 and NRC Regulatory Guide 1.39 which only
specify that housekeeping conditions shall not deteriorate to
the point that housekeeping deficiencies have an impact on
safety related equipment.
Specifically, SCE has voluntarily elected to use "shall" in
procedures S0123-VI-23 and S0123-1-1.20, because it is
difficult to provide concise procedural guidance to workers on
when and how to use judgement as to when material conditions
deteriorate to the extent that safety-related equipment is
impacted. As previously stated, procedure S0123-1-4.59
intentionally used "should" to denote that the grooming of pull
rope ends is not mandatory.
2.
Corrective steps that have been taken and the results achieved.
The referenced debris found in the cabinets was removed by May 5,
1989.
SCE has initiated programmatic enhancements to require that as work
is performed in electrical cabinets, a "final check", which includes
a review for cleanliness, is performed by the supervisor responsible
for the work activity. SCE believes that as the electrical cabinets
are opened for work under the "final check" program, that material
conditions will improve.
3.
Corrective steps that wi.11 be taken to avoid further violations.
To enhance the aforementioned "final check" program, a review of
which cabinets are locked will be conducted. As appropriate,
additions to the number of locked cabinets may be made.
The referenced exposed pull rope end will be removed during the next
scheduled cabinet work.
4.
Date when full compliance will be achieved.
By May 5, 1989, the identified debris was removed.