ML19332D326
| ML19332D326 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/20/1989 |
| From: | Bay H SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8912010016 | |
| Download: ML19332D326 (6) | |
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Southem Cali.bmla Edison Company l
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$RVINc. CAWORNIA Gehb vitt PMs tiDa ht 7+e-esp edOO
' November 20, 1989 U.:S.' Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.-20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generatina Station, Units 2 and 3 In a letter to the undersigned dated October 27, 1989, the NRC forwarded Inspection Report Nos. 50-361/89-24 and 50-362/89-24 and an associated Notice of Violation.
In accordance with 10CFR2.201, the. enclosure to this letter provides the Southern California Edison (Edison) reply to Violation A in the Notice of Violation.
A reply to Violation B will be provided. separately.
The-NRCjforwarding letter included expressions of concern.
Edison has carefully considered these concerns and provides additional responses as. discussed below.
NRC ConcRID.
"Of particular concern is your staff's failure to fulfill-Technical Specification requirements on August-24, 1989 instead of relying on generic letter guidance, as discussed in paragraph 4.a of the enclosed inspection report.
This lapse in the understanding and fulfilling of regulatory
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requirements should be clearly addressed as part of your response to the enclosed Notice of Violation."
L Edison Resoonse Edison's reasons for failing to fulfill the Technical Specification (TS) requirements are described in Section 1 of the response to Violation A enclosed.
Edison should have promptly requested relief ~from the TS requirements instead of only informing the~ Office of the Resident Inspector of Edison's course of action and its basis.
Edison does agree with the conclusion in Generic Letter (GL) 87-09 that a plant shutdown as a result of a missed l-surveillance is undesirable because it increases the risk to the L
plant'and public safety.
For this reason, Edison believed that the guidance of the GL could be used under the circumstances 99 [
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-Nuclear Regulatory Commission
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November 20,-1989 f%:7 Although Edison is committed to conservatively implement the requirements.of-the.TS, as discussed in my letter to l
Mr..Zimmerman dated ~ November 16, 1989, we believe that commencement of a plant shutdown in accordance with TS 3.0.3 in response to a missed surveillance, and without consideration of GL 87-09 conclusions, would be contrary to the objective of that commitment, which is to ensure maximum safety and to minimize-risk.
Because of this, Edison has taken' action to modify the TS change which was submitted.in December 1987 in response to GL 87-09, to seek approval of the port.on thereof which is related to i
the action-to be taken in the face of any subsequent' discovery of a missed-surveillance.
Pending approval of the TS change, Edison i
will immediately discuss with both the Office of the Resident Inspector and the staff of-the Office of Nuclear Reactor
' Regulation the' action which it should take if a similar event should occur.
NRC Concern "We are also concerned with recent operational problems that have. occurred in the last few months at San Onofre... These problems are considered to be attributable to training and insufficient formality in the conduct of normal operations.
Your attention to this matter is necessary to minimize the potential for further problems with performance of normal operations."'
Edison Resoonse Edison agrees that the problems-identified in the NRC
' letter, and other operational problems which have occurred subsequently, result from insufficient training and discipline in the performance-of normal operations.
This is a matter of significant concern to us, and its resolution is the objective of planned corrective action which has been under development since the first of this year.
We will discuss the status of our development of a comprehensive program in this regard in a meeting with Region V management now scheduled for November 29, 1989.
L If you have any questions or comments, or if you would like L
' additional information, please let me know.
L i-Sincerely, p
Enclosure i
cc:
J.
B. Martin, Regional Administrator, NRC Region V C.
W.
Caldwell, NRC Senior Resident Inspector, San Onofre G. Knighton, Office of Nuclear Reactor Regulation, NRC r
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o ENCLOSURE REPLY TO A NOTICE OF VIOLATION VIOLATION A i
Appendix A to Mr. Chaffee's letter, dated October 27, 1989, states in part:
"A.
Section 6.8.1 of the Unit 2 Technical Specifications i
requires written procedures to be established and i
implemented for 'The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.'
Appendix.A of Regulatory Guide 1.33, Revision 2, includes in the listing of procedures which should be provided,
'1.
Administrative Procedures... b.
Authorities and Responsibilities for Safe Operation and shutdown.'
"Section 6.5.2 of Operating Division Procedure SO123-0-14, TCN 0-9,
' Technical Specification LCO Action Requirements (LCOAR) and Equipment Deficiency Mode Restraints (EDMR),' requires that upon discovery of inadvertent LCO 3.0.3 entry, immediate action to
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correct the problem shall be initiated.
In addition,
'If the condition is not corrected within 30 minutes of discovery or one hour after initiation time (whichever time is later), then initiate a plant shutdown.'
"Section 4.0.3 of the San Onofre Technical Specifications states, in part, that ' Failure to perform a surveillance Requirement.within the specified time interval shall constitute a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation.'
"Section 3.3.2 of the Technical Specifications requires loss of voltage. relays associated with the 4.16 vital buses to be operable in Mode 1.
Section 4.3.2.1 of the Technical Specifications specifies channel calibration requirements for these relays.
" Contrary to the above, at approximately 1:00 p.m. on August 24, 1989, with the unit operating in Mode 1, the licensee determined that the channel calibration for the loss of voltage relays associated with the
'A' Train 4.16 KV vital bus was required to have been performed on August 15, 1989.
Since this channel was
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required to be operable pursuant to the limiting condition for operation under Technical Specification 3.3.2, Technical Specification 3.0.3 was entered.
However, the required surveillance test was not completed until 12:02p.m. on August 25, 1989, and a Unit shutdown was not initiated as required.
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... "This is a Severity Level IV violation,(Supplement I),
applicable to Unit 2."
RESPONSE TO VIOLATION A i
1.
Reasons for the violation.
Edison did not consider that it had entered TS 3.0.3 in this instance'because it: misapplied the guidance provided in Generic Letter (GL) 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements."
The misapplication resulted from a misunderstanding to the effect that the GL provided a clarification of NRC intent, based on its conclusion that plant-shutdown pursuant to TS 3.0.3 under these circumstances would be undesirable since it increases risk.
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Relevant parts of this GL and its enclosures provide that:
"(The) problem involves unnecessary shutdowns caused by Specification 4.0.3 when surveillance intervals are inadvertently exceeded.
The solution is to clarify the applicability of the Action Requirements, to specify a specific acceptable time limit for completing a missed surveillance in certain circumstances, and to clarify when a. missed surveillance constitutes a violation of the Operability Requirements of an LCO.
It is overly conservative to assume that systems or components are
' inoperable when a surveillance has not been performed because the vast majority of surveillances do in fact demonstrate that systems or components are operable.
When a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of a Surveillance Requirement.
Because the allowable outage time limits of some Action Requirements do not provide an appropriate time for performing.a missed surveillance before Shutdown Requirements apply, the TS should include a time Jimit that allows a delay of required actions to permit the performance of the missed surveillance based on consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and, of course, the safety significance of the delay in completing the surveillance.
The staff has concluded that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is an acceptable time limit for completing a missed surveillance when the allowable outage times of the 3
Action Requirements are less than this limit, or when time is needed to obtain a temporary waiver of the Surveillance Requirement."
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and, further:
"If a plant shutdown is required before a missed surveillance is completed, it is likely that it would be conducted when the plant is being shut down because completion of a missed surveillance would terminate the-shutdown requirement.
This is undesirable for two reasons.
First, the plant would be in a transient state involving changing plant conditions that offer the potential for an upset that could lead to a demand for the system or component being tested.
This would occur t
when the system or. component is either out of service to allow performance of the surveillance test or there is a lower level of confidence in its operability because the normal surveillance interval.was exceeded.
If the surveillance did demonstrate that the system or component was inoperable, it usually would be preferable to restore it to operable status before making a major change in plant operating conditions.
Second, a shutdown would increase the pressure on the plant staff to expoditiously complete the required surveillance so that the plant could be returned to power operation.
This would further increase the potential for plant upset when both the shutdown and surveillance activities place a demand on the plant operators."
Based on this discussion in the GL, the fact that Edison had submitted a TS change to the NRC to incorporate the required clarification, and that identical clarification changes have been issued to other licensees, Edison believed that the NRC intended that it apply.
This was in error.
2.
. Corrective steps that have been taken and the results achieved.
As discussed in the NRC inspection report, when Edison was advised by Region V that an approved TS change was required in order to use the provisions of the GL, the requirements v
of TS 3.0.3 were promptly applied.
The surveillance test, which had by then been underway for some time, was completed prior to requiring a plant shutdown.
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Corrective steps that will be taken to avoid further violations.
Applicability of the existing TS requirements, notwithstanding the guidance in GLs or anticipated changes in requirements, has been reinforced with appropriate personnel.
However, Edison agrees with the bases stated in
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- ' ' GL 87-09 for changing the TS; namely, that. commencing a shutdown due to a missed surveillance increases the risk to the plant and public safety.
Accordingly, Edison has taken action to modify the change.to the TS which was proposed in response to the GL letter, j
This change-was submitted in December 1987, and we expect j
that~the modified change will be issued by the NRC shortly.
1 On August 24, 1989, when Edison failed to implement the requirements of TS 3.0.3 for the reasons discussed above, Edison discussed its interpretation and course of action with the office of the Resident Inspector.
This led to the response from Region V and the subsequent action to enter TS 3.0.3 upon being advised that the GL guidance did not apply.
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Edison now' understands that a formal request for relief should have been submitted immediately to the staff of the Office-of Nuclear Reactor Regulation-(NRR).
Pending issuance of the requested TS change in accordance with GL 87-09, Edison will discuss the situation with the Office of the Resident Inspector and immediately seek relief from NRR in the event a similar circumstance involving a missed surveillance nhould again occur.
4.
Date when ful opliance will be achieved.
Compliance was oved on August 25, 1989, when Edison-implemented thu pt. -isions of TS 3.0.3, following discussion of'GL applicability with Region V.
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