ML13323B268
| ML13323B268 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/17/1987 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323B267 | List: |
| References | |
| 50-206-87-05, 50-206-87-5, NUDOCS 8707310130 | |
| Download: ML13323B268 (4) | |
Text
APPENDIX A NOTICE OF VIOLATION Southern California Edison Company San Onofre Unit 1 P. 0. Box 800 Docket No. 50-206 Rosemead, California License No. OPR-13 As a result of the inspection conducted during the period of June 1 to June 12, 1987, and in accordance with the NRC Enforcement Policy 10 CFR Part 2, Appendix C, the following violations were identified:
A.
Section 4.4.D2.d of the Station Technical Specifications denotes the requirement to demonstrate each 125 volt battery.bank operable as follows:
"at least once per 18 months, during shutdown, by verifying that the battery capacity is adequate to supply and maintain in operable status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test."
Contrary to the above, 125 volt battery number one was not demonstrated operable during the service tests conducted on May 7, 1986 and May 22, 1987, since the battery was discharged at a load profile below the design duty cycle, as specified in the revisions to design calculation DC-1604.
This is a severity Level IV Violation (Supplement I).
B.
Technical Specifications, Section 6.11, "Radiation Protection Program,"
reads:
Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Health Physics Procedure S0123-VII-7.4, paragraph 6.1.2.6, "Radioactive Materials Container", requires that:
Each container-having radioactive material in excess of the amounts specified in Appendix C of 10 CFR 20 shall bear a durable, clearly visible label bearing the radiation caution symbol and the words:
"CAUTION, RADIOACTIVE MATERIAL" OR "DANGER, RADIOACTIVE MATERIAL" It shall also provide sufficient information to permit individuals handling or using the containers or working in the vicinity thereof to take precautions to avoid or minimize exposures.
Contrary to the above, on June 3, 1987, eight 3'x3'x5" boxes which bore only the radiation symbol and the words, "Caution, Radioactive Material,"
were found in the housekeeping area outside door R3-60. No other PD)R A 1 O601 Q
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0 50 00 6
information was provided on the boxes. The monitored radiation dose rate was 48 mrem per hour at the surface with the dose rates being between 5-10 mrem in the general area.
This is.a severity Level V Violation (Supplement IV).
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 Resident Inspector, 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 action as may be proper should not be taken.
Consideration may be given to extending your response time for good cause shown.
ITHE UCLEAR REGULATORY COMMISSION Dated t Creek, California on 7__11 J. B. Martin Regional Administrator
APPENDIX B Areas Inspected and Results Procurement An assessment was made of the program and its implementation for the procurement, control and dedication of comercial grade parts and components for use in safety-related systems. While it appears that parts and components were being properly controlled, in that no specific deficiencies were identified, it was not apparent that the evaluation used to justify equivalency of parts for use in safety related applications was being adequately documented.
Station Batteries Various aspects of surveillance testing of the station Class 1E batteries were reviewed. Numerous deficiencies were identified in this area, one of which is a violation of the Technical Specifications (failure to demonstrate the operability of battery no. 1 -
two examples).
This appeared to result from a weakness in the performance of technical work. Design calculation data was not properly incorporated into implementing procedures onsite. While all of the examples of this problem involved the station.batteries, it could be manifested in other safety-related systems and components.
IST Program Although the implemention of your IST program was generally found to be in compliance with your commitments to the NRC, two areas of weakness were identified.
One area dealt with your method of taking vibration measurements on pumps.
The only way of assuring that pump vibration data were taken at the same location was to have the same cognizant engineer obtain the data each time. It is our understanding that you will revise pertinent IST test procedures, for all 19 pumps in the IST program, to clearly define points where IST vibration data are to be taken.
The second area involved the measurement of valve stroke times. The test procedures used do not specify the method for consistently obtaining valve stroke times. We understand that you will add a valve stroke time technique to the appropriate procedures to ensure valve stroke timing consistency and correctness.
Operations The team determined that the operations staff in Unit 1 is competent, knowledgeable, and generally aware of work that is in progress and how that work might affect plant conditions. Procedures exist for the performance of various activities and appear to be adhered to.
-2 Maintenance The team's impression of maintenance work performed during the outage was generally favorable. Work was performed in a deliberate,.,controlled manner according to written procedures. The procedures were reviewed and approved by various organizations.
However, the team considers that more detail is needed in post maintenance test procedures. Less reliance should be placed on the operations staff to ensure modifications are properly tested and more detailed procedures should be prepared by the responsible engineering organization. These enhanced test procedures should be properly reviewed and approved.
Surveillance The team noted that these activities were governed by approved procedures.
Generally, the procedures were found to have been properly implemented, with the exception of surveillance tests of station batteries.
Quality Assurance Quality Assurance involvement in activities undertaken during the current outage was evaluated. Also, specific audits pertaining to areas that the team was assessing were reviewed. The team determined that QA involvement was adequate. The team also determined that the audits they reviewed were in-depth and comprehensive, especially in the areas of IST and procurement.
However, some issues that were raised by QA appear to have been overlooked or disregarded until pointed out by the team. One example was the location of pump vibration measurement test points for IST purposes.
Radiological Controls The areas inspected included:
audits, changes in organization and programs, training and qualification of personnel, external and internal exposure, maintaining occupational exposures ALARA, and control of radioactive material.
This included reviews of licensee records and reports, discussions with licensee and contract personnel, and several tours of the licensee's facility.
One violation in the area of radioactive material control was identified.
Design Changes The Design Change program was reviewed and implementation of specific design changes was examined. In general, these activities were determined to be in compliance with procedural and regulatory requirements.
However, weaknesses were observed with regard to implementation of the design change for the addition of inverter 4A.