ML20010A352

Responds to NRC 810616 Ltr Re Violations Noted in IE Insp Rept 50-361/81-09.Corrective Actions:Low Pressure Safety Injection Pump Given Special Retest & Determination Made That No Damage Occurred

ML20010A352
Person / Time
Site:	San Onofre
Issue date:	07/14/1981
From:	Papay L SOUTHERN CALIFORNIA EDISON CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20010A346	List: ML20010A352
References
NUDOCS 8108110344
Download: ML20010A352 (4)

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f. t no o J

Southern Californi Edison Comoany RO. BOX 800

[E 2244 WALNUT GROVE AVENUE ROSEMEAD, CALWORNIA 9I770 vect Pattactiet 213 + S 72 8474 July 14, 1981 Mr. R. H. Engelken, Director hptpDC 'v.*^

Office of Inspection and Enforcement F U. S. Nuclear Regulatory Comnission #

f3 Region V t{ 4[y$gg x

[f jQ Suite 202, Walnut Creek Plaza Ds gg f/

1990 North California Boulevard A\l/

Walnut Creek, California 94506 rg, Ibar Mr. Engelken:

Subject:

Docket No. 50-361 San Onofre Nuclear Generating Station, Unit 2 In a letter frm your office dated June 16, 1981, we were requested to respond to a Notice of Violation resulting frm inspections of San Onofre Unit 2 construction activities which tock place during the period March 13 to April 14, 1981. 'Ihe condition described by the Notice of Violation involved operation of Im Pressure Safety Injection Punp, P016, for San Onofre Unit 2 with valves closed so as to prevent a supply of water to the punp suction.

'Ihe actions taken or to be taken to correct and to prevent re-currence of this condition are described in Attachment 1. I trust the attach-ment 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.

Subscribed on this /VM day of , /9// by Am L. T. P5 pay Vice President ff g-l Southern California Edison Company Subscribed and sworn to before me this /v#day of ,/p//

4 omau sut AGNES CRABTREE Gra:s >

NotapfPublicinandforthe

@_ _ _ _ _Mrof California l " "S*fM,7'^

tosmotus muNn 0mmenn Em Au County of Los Angeles, State

_ _ _ _ . _ - - - - - - - _ _ - :_- = _

Enclosure cc: R. J. Pate (NRC-San Onofre Units 2&3) 8108110344 810806 T PDR ADOCK 05000361 a eDn VI,ll4

Attachnent 1 RESPONSE 'IO NRC NEIG OF VIOLATION IWIED JURE 16, 1981 SAN ONDFRE NUCEAR &NERATING STATION, UNIT 2 Response to the Notice of Violation which was identified in Appendix A to IE Inspection Report No. 50-361/81-09, is provided below. A statement of the condition as described by the Notice is given for reference.

NEIG OF VIDIATION Southern California Edison Conpany Docket No. 50-361 As a result of an NRC inspection on March 13 to April 14, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1950),

the following violation was identified:

Appendix B of 10 CFR 50, Criterion V, states, in part, that, " Activities affect-ing quality shall be prescribed by doctrnented instructions, procedes, or drawings,...and shall be accouplished in accordance with these instructions, procedures, or drawings."

SG Operating Procedure S023-3-2.6, " Shutdown Cooling," requires in part that valves HV-9339, HV-9337, IN-9377, and IN-9378 be opened to initiate shutdown cooling.

Contrary to the above, the inspector detennined that on March 21, 1981 shut-down cooling had been initiated without opening valves IN-9377 or IN-9378.

As a result of the above failure to follow an applicable procedure, the Iow Pressure Safety Injection Pmp, P-016, was operated for at least several minutes with a conbination of valves closed, such as to prevent a supply of water to the ptmp suction.

'Ihis is a Severity Imvel V violation (Supplement II).

RESPONSE

Corrective Steps Taken and Results Achieved Iow Pressure Safety Injection Pmp P-016 was given a special retest in accordance with Startup Work Permit 15970 subsequent to the event described above and a determination was made that no damage had been incurred.

During the investigation of the adninistrative aspects it was noted that Station-specific tagging p"rocedures had not been issued at the time of the incident. S023-0-19, Use of Caution and Magnetic Tags." has since been issued. In accordance with that procedure, use of a Caution Tag Iog has been inplemented to strengthen Control over the proper placement of caution tags.

Procedural conpliance, already addressed in a February 24, 1981 menorandum to Station enployees from the Plant Manager, was formalized by the issuance of Adninistrative Procedure S023-0-4, " Station Operations". Station policy makes willful failure to observe procedures a disciplinary problem with severe conse-quences.

Response to NRC Notice of Violation Dated June 16, 1981 San Onofre Nuclear Generating Station, Unit 2 Page 2 As a result of the incident with the IPSI Pmp, the SCE Quality Assurance Organization issued a Corrective Action Request and an NRC Action Item Report. The corrective actions of CAR-S023-P-22 were reviewed by Quality Assurance and considered cmplete as of June 10, 1981. Ihe evaluation required by NRCAIR-F-NRC-265 has been empletedand the resulting preventive measures are currently in progress.

On-shift training related to this incident has been conducted with Unit 2 operating personnel. Discussions included a review of the cause of the event, the Station Incident Report and the related procedures and administrative policies. %e reviews with operations personnel have been docunented. The individuals involved directly with the occurrence have been verbally counseled. Although failure to follow procedures is attributed to be the primary cause, there is no indication.that deliberate carelessness was a factor in the loss of suction to the IPSI pmp.

Supervision is aware of the seriousness of the matter and the poteatial consequences of poor equipment status centrol. This subject was the topic of a Units 2 and 3 Operating Supervisor's meeting on April 4,1981.

There have been no further instances of failure to follow procedures by Unit 2 operating personnel since this incident.

Corrective Steps Which will be Taken to Avoid Further Items of Non-con 1pliance Procedures currently in effect concerning the control and status of safety-related equipment will be adhered to without exception.

Continual reinforcement and enphasis on the necessity for procedural cocpliance will be directed to all personr.el involved by the respansibic supervisors.

Menbers of the Unit 2 operating staff who bcve not already received the on-shift training and review of the LPSI loss-of-suction incident will be given such instruction by August 1,1981. The reviews will be docmented and available for future NRC inspection.

The existing procedure for operation of the Shutdown Cooling System, S023-3-2.6, will be revised by August 1,1981 to include a caution statement on the inportance of opening both parallel suction paths.

A procedure covering initial aligment of the Safety Injection System, S023-3-2.7, will be issued by August 1,1981. The associated electrical alignment check off list will contain a requirenent to ensure that the maintained contact key switches are properly positioned prior to closing the power supply. This will assist in avoiding the undesired valve movement that resulted in the loss of suction to pmp P-016 on March 24, 1981.

Response to NRC Notice of Violation Dated June 16, 1981 San Onofre Nuclear Gcnerating Station, Unit 2 Page 3 Additionally, Operating Procedure S023-3-1.4, " Fill and Vent", will be reviewed in parallel with the procedures described above to determine whether any revision is necessary.

Date When Full Canpliance will be Achieved Full empliance will be achieved by August 1,1981, when trainits for Unit 2 operations personnel and revisions to the referenced procedures hme been ca.pleted.

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