ML13323A927
| ML13323A927 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/13/1980 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML13323A928 | List: |
| References | |
| NUDOCS 8103240101 | |
| Download: ML13323A927 (3) | |
Text
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Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE L.T. PAPAY ROSEMEAD, CALIFORNIA91770 ELEPHONE VICE PRESIDENT 213-572-1474 November 13, 1980 R. H. Engelken, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Region V 1990 North California Boulevard Suite 202, Walnut Creek Plaza Walnut Creek, California 94596 Docket No. 50-206 San Onofre Unit 1
Dear Mr. Engelken:
By letter dated October 24, 1980, NRC Inspection Report No. 50-206/80-28 was transmitted, documenting the results of the NRC resident inspection for the month of September, 1980. Your letter included as Appendix A a Notice of Violation. The enclosure to this letter provides our response to Appendix A.
I trust the enclosure responds adequately to all aspects of the Notice of Violation. If you have any questions, or if we can provide additional information, please let me know.
Sincerely, Enclosure cc: L. F. Miller U. S. NRC Site Inspector San Onofre -
Unit 1
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ENCLOSURE RESPONSE TO NOTICE OF VIOLATION DATED OCTOBER 24, 1980 SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1 NOTICE OF VIOLATION
- a. Technical Specification 6.8.1 requires that written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Appendix "A" of USNRC Regulatory Guide 1.33, Revision 1. Paragraph 10 of this Appendix states that procedures should be written to prescribe the instructions for maintaining water quality within prescribed limits, and the limits on concentrations of agents that may cause corrosive attack or fouling of heat transfer surfaces.
Station Order S-E-2, "Operation, Maintenance and Chemical Control of Heat Exchange Equipment,"
provides that "corrosion of the primary system components will be controlled by maintaining the chloride levels within the defined limits."
Paragraph B.l.b of this Station Order defines the chloride limits as "less than.15 ppm."
Contrary to the above, on each daily sample recorded from September 2 to September 13,
- 1980, the chloride concentration was in excess of the specified limit by an amount which varied from 0.03 to 0.35 ppm, or 20-233% in excess of the limit. This is a deficiency.
RESPONSE
Corrective steps which have been taken and results achieved The document referred to in the above item describes limits to be adhered to during periods of plant operation.
These limits are not intended for periods when the system is shut down and open for maintenance.
For example, the oxygen concentration cannot be maintained below 100 ppb during these periods when the system is open to the atmosphere.
Similarly, chloride concentration is not as restrictive when the system is cooled down since temperature is a necessary ingredient to cause stress corrosion cracking of austenitic stainless steel..
In order to clarify chemical requirements during refueling, the results of a Westinghouse test described in WCAP-7628, "Stress Corrosion Testing" were reviewed.
This test indicates that an exposure period of nine months is required for stress corrosion cracking to occur in austenitic stainless steel exposed to a chloride concentration of 0.4 ppm under conditions similar to refueling. During periods of time when the reactor system is depressurized and open to the atmosphere, the operating chloride limit of 0.15 ppm can normally be maintained.
However, during infrequent periods of demineralizer equipment malfunctions, chloride levels may increase to 0.35 ppm for a period of a few days. Therefore, Station Procedure S01-III-1.14 will be revised to allow a chloride limit of 0.35 ppm during periods of shutdown when the reactor system must be opened for refueling or maintenance outages.
-2 Corrective steps which will be taken to avoid further violations Station Procedure SO1-III-1.14 will be adhered to during future plant shutdowns.
The date when full compliance will be achieved Station Procedure SO1-III-1.14 will be revised and full compliance will be achieved by December 1, 1980.
- b.
Technical Specification 6.8.1 requires that written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Appendix "A" of USNRC Regulatory Guide 1.33, Revision 1.
Paragraph 7a(3),
"Liquid Radioactive Waste System; Discharging the Effluents," is a recommended procedure of this Appendix.
The licensee's Operating Instruction S-3-2.26, "Receiving, Storage, Processing, and Discharge of Liquid Waste," implements the Appendix A recommendation.
Precaution III A. of this instruction states that "during holdup tank releases, the set point for ORMS 1218 shall be set at a maximum of 20,000 cpm above background."
Contrary to this procedure, on September 24, 1980, while the west holdup tank was being discharged to the circulating water system, the inspector observed that the set point for ORMS (Operational Radiation Monitoring System) 1218 was set at 110,000 counts per minute (cpm), 95,000 cpm above the background count rate of approximately 15,000 cpm.
This is a deficiency.
RESPONSE
Corrective steps which have been taken and results achieved The alarm had mistakenly been set at 20,000 cpm above the normal reading during the discharge instead of 20,000 cpm above the background reading prior to the discharge.
The operating personnel were counseled concerning the interpretation of "background" and the alarm point setting of ORMS Channel 1218.
-Operating Instruction S-3-2.26 has been revised to clarify this item.
These actions have resulted in prevention of further items of this nature.
Corrective steps which will be taken to avoid further violations All operating personnel will be instructed in the proper procedure for setting the alarm point on ORMS Channel 1218.
This instruction accompanied with the revised operating instruction should prevent any further violations of this nature.
The date when full compliance will be achieved Full compliance has been achieved as of November 1, 1980.