ML13331A245
| ML13331A245 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/19/1988 |
| From: | Morgan H SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8802250439 | |
| Download: ML13331A245 (2) | |
Text
Southern California Edison Company SAN ONOFRE NUCLEAR GENERATING STATION P. O. BOX 128 SAN CLEMENTE, CALIFORNIA 92672 H.E.MORGAN TELEPHONE STATION MANAGER February 19, 1988 (714) 368-6241 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555
Subject:
Docket No. 50-206 Special Report San Onofre Nuclear Generating Station, Unit 1 Pursuant to Technical Specifications (TS) Limiting Conditions for Operation (LCO) 3.14.B.1.a of Provisional Operating License DPR-13 for San Onofre Unit 1, this letter provides the required Special Report for Fire Suppression System being out of service for greater than seven days.
This report is delinquent.
On May 16, 1987, Post Indicating Valve (PIV) "C" failed the 12-month valve cycle test required by TS 4.15.A(4).
PIV "C" is a manually operated isolation valve on the branch line from the main fire water supply loop to the 4 hose stations inside the Sphere Enclosure Building.
PIV "C" failed the test due to being stuck in its normally open position. The valve was subsequently repaired and was tested satisfactorily on January 11, 1988.
LCO 3.14.B.1.a requires that if the valve is inoperable for greater than 7 days a Special Report be submitted within the next 30 days. On January 20, 1988, a Quality Assurance review of Fire Suppression System TS surveillances identified that the required report had not been submitted.
The failure to submit a Special Report was a result of two separate errors in implementing the administrative controls for tracking of inoperable fire protection equipment. Contrary to administrative procedures, 1) an operator failed to initiate a Limiting Conditions for Operation Action Requirements (LCOAR) and, 2) fire protection personnel failed to identify the valve as being inoperable on the Fire Impairment Program (FIP).
The FIP and the LCOAR are relied upon for tracking inoperable fire suppression equipment and identifying TS required Special Reports.
802250439 880219 PDR ADOCK 0 5O00206 S
-1
Document Control Desk
-2 The lack of LCOAR and FIP tracking of the TS Action Requirements for PIV "C" was a result of a misunderstanding of TS requirements. The operability review by both Operations and fire protection personnel were focused primarily on the effect of the failed valve on its associated fire suppression flow path and the isolation function of the valve was not considered. With the valve failing in the normally required open safety position, it was erroneously concluded no fire suppression equipment was rendered inoperable. Consequently, the applicable TS Action Statement was not tracked and the need to submit a Special Report was not identified.
As corrective action, all Unit 1 operators and FIP reviewers will receive additional instructions on administrative procedures associated with the tracking of inoperable fire protection equipment. Additionally, an enhanced computerized Fire Protection Impairment System (FPIS), which automatically matches inoperable fire protection equipment or systems to the associated TS Action Statements, is scheduled to be implemented by the end of April 1988.
If you require additional information, please so advise.
Sincerely, cc: J. B. Martin (Regional Administrator, USNRC Region V)
F. R. Huey (USNRC Senior Resident Inspector, Units 1, 2 and 3)
Institute of Nuclear Power Operations (INPO)