ML20023B925
| ML20023B925 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/02/1983 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8305090278 | |
| Download: ML20023B925 (3) | |
Text
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,s Southem Califomia Edison Company g6 R O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 al3 572-s474 vics passiosat U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Washington, D.C. 20555 Attention:
Mr. R.C. DeYoung, Director
Dear Sir:
Subject:
Docket No. 50-361 IE Inspection Reports 50-361/83-06 and 50-361/83-08 Response to Notice of Violation San Onofre Nuclear Generating Station, Unit 2
Reference:
Letter, R.H. Engelken (NRC) to Dr. L.T.Papay (SCE), Dated March 24, 1983 The referenced letter forwarded Notice of Violation and Proposed Imposition of Civil Penalties based on the inspection conducted by Messrs. A.E. Chaffee and L.F. Miller during the period January 3 through February 12, 1983, and by Messrs. G.P. Yuhas and C.I. Sherman on February 7 through 11, 1983.
Pursuant to 10CFR 2.201, the enclosure " Response to Notice of Violation (10 CFR 'J 2.201)," to this letter provides the Southern California Edison Company (SCE) response to the Notice of Violation contained in the referenced letter.
In addition to l
the five specific factors the Notice of Violation requests be addressed, we have set forth a separate section (identified as Section 2) that identifies the facts and circumstances surrounding the event.
Also enclosed is a check in the amount of $120,000 payable to l
the Treasurer of the United States, as called for by the Notice of Violation.
i l
l t
8305090278 830502 gonanocxo5ooojpg ff j l
I
1 Mr. R.C. DeYoung I trust the enclosed " Response to Notice of Violation (10 CFR 9 2.201)" responds adequately to all aspects of the violations.
If you have any questions or if we can provide additional information, please let me know.
Subscribed on the [ day of 1983 by 4
L. T. P'apay Vice Presiden Advanced Engineering Southern California Edison Company Subscribed and sworn to before me this gd[ day of h.
1983 9
...m..-
OFFICIAL SEAL AGNES CRABTREE l
1 SOTARY PW8 LAC - CALWM p
P5UNCIPAL OFFICE IN LOS ANGELES COUNTY 2; _ NNrD I $~.
Enclosure cc:
J.B. Martin (USNRC, Regional Administrator, Region V)
A.E. Chaffee (USNRC Resident Inspector, Units 2 and 3)
L.F. Miller (USNRC Resident Inspector, Unit 1)
G.P. Yuhas (USNRC Radiation Specialist, Region V)
C.I. Sherman (USNRC Radiation Specialist, Region V) 4
~~
~'
^
^
I ENCLOSURE RESPONSE TO NOTICE OF VIOLATION (10CFR S 2.201) i In accordance with 10 CFR S 2.201, this enclosure provides the Southern California Edison Company's ("SCE") response to Notice of Violation contained in the enclosure to Mr. R. H. Engelken's letter of March 24, 1983.
The enclosure to the March 24, 1983 letter states:
"A.
Technical Specification 3.6.2.3 provides the following:
"Two independent groups of containment coolin'g fans shall be OPERABLE with two fan systems to each group.
" APPLICABILITY:
MODES 1, 2, 3, and 4.
" ACTION:
"a.
With one group of the above required containment cooling fans inoperable and both containment spray systems OPERABLE, restore the inoperable group of cooling fans to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hcurs and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
"b.
With two groups of the above required containment cooling fans inoperable, and both containment spray systems OPERABLE, restore at least one group of cooling fans to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the i
i following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Restore both above required groups of cooling fans to OPERABLE status within 7 days of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
"c.
With one group of the above required containment cooling fans inoperable and one containment spray system inoperable, restore the inoperable spray system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 i
hours.
Restore the inoperable group of j
containment cooling fans to OPERABLE status l
~ _ _. _,-,
Enclosure RDeponse to Notice of Violation Page 2 within 7 days of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
" Technical Specification 3.0.3 provides, in part:
"When a limiting condition for operation is not met, except as provided in the associated ACTION requirements, within one hour, action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in:
1.
At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 2.
At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and 3.
At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
" Contrary to the above requirements, on January 16, 1983, while t'he reactor was operating in Mode 1 at about 50% of rated power level, both groups of independent containment cooling fans and one train of the containment spray system were inoperable during the period of time between 10:50 a.m. and 12:45 p.m..
The licensed operator knew or should have known shortly after 10:50 a.m. that the stated conditions existed and appropriate action should have been initiated.
"This is a Severity Level III violation (Supplement I)
(Civil Penalty $40,000)"
1.
ADMISSION OR DENIAL OF ALLEGED VIOLATION:
SCE admits that on January 16, 1983, both groups of independent containment cooling fans and one train of the containrent spray system were inoperable during the period of time between 10:50 a.m. and 12:45 p.m. and that the licensed operator should have initiated action pursuant to LCO 3.0.3 prior to 11:50, 2.
STATEMENT OF FACTS AND CIRCUMSTANCES:
a Review of this matter with Operations personnel involved and review of records produced reveals the following:
a.
At 0945 on January 16, 1983, Containment i
Cooling System (CCS) Train A Fan'2ME-401 was removed from service for repairs including i
the removal and replacement of breakers.
This was done with the permission of the Control Room SRO, and, based on the routine nature of the repair, the Shift Supervisor l
was not advised, l
Enclosure Rroponse to Notice of Violation Page 3 b.
At 1050, Saltwater Cooling System Train B valve 2HV6495, which had been undergoing test, could not be reopened from the Control Room or locally and was declared inoperable.
Inoperability of this valve was recognized by the Shift Supervisor as I
rendering Component Cooling Water (CCW)
System Train B inoperable, and Train B of all systems served by CCW inoperable.
The Shift Supervisor directed the Control Room SRO to initiate a Limiting Condition for Operation Action Request (LCOAR) form.
The Control Room SRO did not recognize that inoperability of 2HV6495 rendered CCS Train B inoperable based on the belief that CCS was served by the Emergency Chilled Water System which was, at that time, operable by virtue of Component Cooling Water from San Onofre Unit 3.
This was, of course, an erroneous belief in that the CCS is serviced by CCW not Emergency Chilled Water.
The Control Room SRO completed the LCOAR for inoperability of 2HV6495 indicating that its inoperability resulted in entering an Action Statement requiring restoration of the inoperable Saltwater Cooling System Train B within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (LCO 3.7.4 Action Statement).
c.
At the time 2HV6495 was declared inoperable, the Control Room SRO had sufficient information to recognize that the provisions of LCO 3.0.3 applied, however he failed to recognize that LCO 3.0.3 had been entered based on the belief that CCS Train B was served by Emergency Chilled Water and remained operable.
At the same time, the Shift Supervisor, who correctly understood that CCS Train B was inoperable by virtue of the inoperability of 2HV6495, was not aware that CCS Train A was inoperable as a result of Pan 2ME-401 in CCS Train A having been removed from service at 0945 that morning.
d.
At approximately 1200, the Shift Supervisor, on routine review of Control Room panels, observed the clearance tag on CCS Train A Fan 2ME-401, recognized that both trains of CCS were inoperable and discussed with the Control Room SRO why the inoperability of 2HV6495 at 1050 was not recognized as requiring entry into LCO 3.0.3. 'This discussion further evidenced the Control Room SRO's erroneous belief that CCS was served by Emergency Chilled Water.
The Shift Technical Advisor also (independently) l concluded that inoperability of 2HV6495 I
required entry into LCO 3.0.3.
I
Enclosure Rseponse to Notice of Violation Page 4 e.
The Shift Supervisor was aware, at the time, of having authorized emergency repair of 2HV6495 at 1056 and believed, based on valve position indication lights in the Control Room, and based on prompt repair of the valve following a failure several weeks before, that emergency maintenance had progressed to the point that the valve could soon be returned to operable status.
The Shift Supervisor was also aware that, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> earlier, preparations for variable T average testing had begun with the establishment of steady-state operation to permit xenon stabilization; this testing would commence shortly after 1200 provided plant conditions were not changed.
f.
The Shift Supervisor contacted the Assistant Superintendent to discuss the discovery that LCO 3.0.3 had been entered.
The Assistant Superintendent advised the Shift Supervisor that if one or more of the inoperable CCS trains could not be restored to operable conditions within an hour (i.e., by 1300),
shutdown was required.
The fact that entry into LCO 3.0.3 had actually occurred at 1050, rather than at 1200, was not discussed.
g.
At 1245, 2HV6495 was declared operable and Fan 2ME-401 was returned to service.
With those actions, both CCS trains were restored to operable condition and LCO 3.0.3 and the LCO 3.7.4 Action Statement were no longer in effect.
h.
These activities of January 16, 1983 include personnel error in that the Control Room SRO failed to recognize that the inoperability of 2HV6495 represented inoperability of CCS Train B and, therefore, failed to recognize conditions warranting entry into LCO 3.0.3 at 1050.
These activities do not, however, suggest any reluctance on the part of Control Room personnel to take prompt action as required by the Technical Specifications.
The decision to not commence plant shutdown at 1200 was based on the expectation that plant conditions could be rectified within the one hour provided by LCO 3.0.3.
Enclosure Response to Notice of Violation Page 5 i.
Although inoperability of 2HV6495 was correctly recognized by the Shift Supervisor as rendering CCW Train B inoperable, inoperability of the valve would not have precluded use of CCW Train B under accident l
conditions.
Valve 2HV6495 is the outlet valve for the heat exchanger in CCW Train B; system design provides for a bypass of 2RV6495, which permits saltwater discharged from the CCW heat exchanger to be diverted to the seawall.
Diversion of this saltwater to the seawall permits CCW Train B to perform its intended safety function; namely, removal of heat from plant systems--including the CCS.
Consequently, plant conditions as they existed during the time when 2HV6495 was inoperable did not preclude operation of CCW Train B nor, therefore, CCS Train B if required in an emergency.
3.
REASONS FOR THE VIOLATION:
This violation was caused by a combination of:
(a) personnel error in that the Control Room SRO did not recognize that CCS Train B was rendered inoperable by virtue of the failure of 2HV6495, and, (b) the fact that existing procedures did not adequately delineate the dependence of systems such as CCS on support systems such as CCW.
In addition, the period of non-compliance was extended by the absence of clear guidance to the licensed operators of when the one-hour period to commence reactor shutdown, required by LCO 3.0.3, begins: at the time of discovery of conditions requiring shutdown or at the inception of the conditions.
It should be noted that no criteria have been promulgated by the NRC concerning when the one-hour period to commence reactor shutdown, required by LCO 3.0.3, begins: at the time of discovery of conditions requiring shutdown or at the inception of the conditions.
In the absence L
of NRC-promulgated criteria, SCE had not, prior to February 23, 1983, established clear and unambiguous policy on this matter.
Although clear and unambiguous policy on this matter is warranted, in this case, the absence of that policy resulted in action to correct the condition being initiated only 10 min'utes beyond the time period provided by LCO 3.0.3.
This action was effective in removing applicability of LCO 3.0.3 within the following one hour.
Enclosure Response to Notice of Violation Page 6 4.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The circumstances which were eventually identified as a violation were identified by SCE and promptly reported to the NRC.
Failure of valve 2HV6495 at 1050 on January 16, 1983, invocation of LCO 3.0.3 and the satisfaction of LCO 3.0.3 at 1250 were reported to the NRC by Licensee Event Report (LER)83-004 in Docket 50-361.
That LER and its associated 14-day Follow-up Report were supplemented by numerous discussions with the NRC Resident Inspectors.
This incident and its significance were discussed in a Special Order reviewed by on-shift control Room personnel and STAS beginning February 23, 1983.
It will also be included in the operator retraining program.
A Special Order was issued by Station Management establishing the policy with respect to when the one-hour period to commence shutdown, provided by LCO 3.0.3, begins; namely, at the inception of the conditions and not at their discovery.
This Special Order will remain in effect until clarification can be obtained from the NRC.
5.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
A generic procedure describing actions to initiate a LCOAR currently exists.
This procedure will be modified to detail key plant systems whose operability may be affected by specified support system failures.
Use of such information, in lieu of the generic procedure, in this case would have precluded the personnel error which occurred.
These procedures are expected to be completed by April 30, 1983.
6.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance with the Technical Specifications was achieved at 12:45 on January 16, 1983 when both CCS trains were restored to operable status and LCO 3.0.3 and the LCO 3.7.4 Action Statement were no longer in effect.
Full implementation of all corrective actions will be achieved by April 30, 1983.
Enclosuro R9eponse to Notice of Violation Page 7 The enclosure to the March 24 letter states:
"B.
License Condition 2.C.(19)i states:
'By January 1, 1983, the post-accident sampling system shall be operable and the post-accident sampling program shall be fully implemented.'
" Technical Specification 6.8.4 states in part that:
'The following programs shall be established, implemented, and maintained:
'd.
Post-Accident Sampling
'A program
- which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions.
The program
- shall include the training of personnel, the procedures for sampling and analysis and the provisions for maintenance of sampling and analysis equipment....
'*Not required to be implemented until January 1, 1983.
" Contrary to the above requirements, on February 10, 1983, (1) the post-accident sampling system was inoperable.
During operation of the system, the hydrogen and oxygen analyses of the primary coolant were invalid due to apparent air in-leakage; and (2) the post-accident sampling program was not fully implemented in that:
(a) During operation of the system, cognizant engineers using approved Station procedures were unable to obtain and analyze a reactor coolant sample within the allowed time period; (b) The individuals normally expected to operate the post-accident sampling system (chemical technicians) had not completed the licensee's prescribed training program; (c) Provision for maintenance of the system ir.cluding periodic use to verify operability had not been established; (d) Procedures to analyze highly radioactive samples onsite of radioactive iodines and particulates in plant gaseous effluents under accident conditions had not been developed.
"This is a Severity Level III violation (Supplement 1)
(Civil Penalty - $40,000)"
y
-~_
Enclosure Response to Notice of Violation Page 8 1.
ADMISSION OR DENIAL OF ALLEGED VIOLATION:
Based on the presently accepted requirements for demonstration of " operability" of the PASS, SCE admits that the system was not operable on February 10, 1983.
2.
STATEMENT OF FACTS AND CIRCUMSTANCES:
a.
The PASS system is a prototypical system specifically designed, engineered, and installed for use at San Onofre.
Based on discussions with USNRC:NRR, SCE believes there are no PASS systems or PASS programs in the Nuclear Industry further developed than at San Onofre.
SCE has spent over
$8,000,000 on developing the PASS system.
The prototypical nature of the PASS system is such that it would reasonably lead to the expectation that component failures would be encountered during the early stages of operation.
b.
Prior to December 1982, each PASS component had been individually tested; but the entire unit had not been integrally tested.
c.
On December 21, 1982, the following PASS status was reported to the NRC in a letter from K.P. Baskin (SCE) to G.W. Knighton (NRC) on December 21, 1982:
... Improvements and modifications as discussed in Reference
'C' (letters from K.P. Baskin (SCE) to F.A. Miraglia (NRC),
dated September 11, 14, and 15, 1982) and in a meeting with NRC staff on September 13, 1982, have been completed.
Testing of each item has also been completed.
On the day that the PASS Demonstration Test was to be performed, SONGS 2 tripped while operating at the fifty percent power level.
The plant remains in a shutdown condition to replace reactor coolant pump seals.
With the plant shutdown, it is not possible to complete the PASS Demonstration Test or to implement the enhanced operator training on the system after the demonstration test.
" SONGS 2 is expected to return t'o power by early January 1983 at which time the PASS Demonstration Test will be completed and operator training will be conducted.
In the meantime, SCE considers the PASS to be operable and License Condition 2.C.(19)i to be satisfied."
Enclosure Rasponso to Notice of Violation Page 9 c.
Prior to submitting the December 21, 1982, letter to the NRC, SCE personnel called NRC Region V and reviewed the content of the draft letter.
d.
On or before January 1, 1983, twenty-two Station procedures covering PASS operation and calibration had been approved, issued, and were available for use:
(i)
S0123-III-8.2.23 Startup and Fill of PASS (ii)
S0123-III-8.3.23 Sampling Procedures and In-Line Analysis for PASS (iii)
S0123-III-8.4.23 Purging and Refilling of the PASS (iv)
Sol 23-III-8,5.23 Chemistry Calibration Procedure for PASS (v)
S0123-III-8.6.23 Access to the PASS During Accident Conditions (vi)
S0123-III-8.7 Operation and Calibrtion of PASS Spectrometer (vii)
SO23-II-4.45 PASS Area Radiation Monitor Channel Calibration (viii)
S023-II-8.10 Loop Verification (ix)
SO23-II-9.361 Containment High Range Area Radiation Monitor Calibration (x)
SO23-II-9.362 Area Radiation Monitor Readout Calibration (xi)
SO23-II-9.363 Area Radiation Monitoring System Calibration (xii)
SO23-II-9.191 Sigma Indicator Model 9263 Calibration
Enclocure Recponse to Notice of Violation Page 10 (xiii)
SO23-II-9.384 Sigma Boron Meter Converter Calibration (xiv)
SO23-II-9.382 PASS Liquid and Gaseous Flowmeter Calibration (xv)
SO23-II-9.10 Rosemount Differential Pressure Transmitter Calibration (xvi)
SO23-II-9.37 Pneumatic Valve Calibration (xvii)
SO23-II-9.351 Fischer Port Manual Station Calibration (xviii) SO23-II.9.383 Beckman pH Analyzer Calibration (xix)
SO23-II-9.381 Delhi Thermal Conductivity Analyzer Calibration (xx)
SO23-II-9.82 Pressure Switch Calibration (xxi)
SO23-II-9.380 Depha Paramagnetic Oxygen Analyzer Calibration (xxii)
SO23-II-9.183 Thermon Temperature Indicating Controller Calibration These procedures were issued notwithstanding the continued PASS system debugging, maintenance, and modifications to improve reliability or overcome technical difficulties.
It was recognized that installation of these modifications would result in procedural revisions.
e.
On January 17 - 21, 1983, during a routine inspection, SCE personnel discussed with the NRC inspector, ongoing PASS problems and system status.
f.
The IIRC inspector verified on February 8, 1983, that classroon training had been comp'leted.
Limited training of SCE personnel in PASS operation did not preclude use of the PASS, as PASS design and installation experts (Combustion Eningeering) were available to augment or advise SCE staff personnel.
Enclocurc R2sponse to Notico of Violation Page 11 9
On February 9, the DRC, in a letter from K.P.
Baskin (SCE) to G.W. Knighton (NRC), was provided an updated statje as follows:
"Upon re-escablishing proper test conditions following the p?. ant outage identified in the referenced letter, repairs to eliminate minor leakage of the fittings and valves, and modifications to enhance reliability were shown to be necessary.
These modifications delayed completion of the Demonstration Test until January 22, 1983.
Operating Instructions have continued to be refined during preparation for and conduct of the Demonstration Test.
During this time, personnel qualified to operate the system have been available.
" Station operating procedures have not been finalized pending verification during the enhanced operator training, identified in the referenced letter, which amounts to
' hands-on' training (classroom training has been completed).
This training is necessarily conducted during plant operation when hot and pressuriced Reactor Coolant Samples can be obtained.
Station operating procedures and ' hands-on' training will be completed by March 1, 1983, provided continued operation of Unit 2."
h.
On February 10, 1983, in the presence of NRC inspectors, the PASS system was operated and the observations quoted from the Notice of Violation, Section B above, were made:
(i)
" Hydrogen and oxygen analysis of the primary coolant were invalid by apparent air in-leakage."
A hydrogen and oxygen sample had been successfully obtained during an earlier test on January 22, 1983, although air inleakage occurred on February 10, 1983.
It should be noted that the oxygen analysis is not required by the NRC.
(ii)
"During operation of the system (on February 10, 1983), cognizant engineers using approved Station procedures were unable to obtain and analyze a reactor coolant sample within the allowed time period."
Enclosure Rasponse to Notice of Violation Page 12 Cognizant engineers were unable to obtain and analyze a reactor coolant sample within the three-hour time period required by NUREG 0737 on February 10, 1983.
This inability was the result of a typographical error in the procedure which resulted in the need to issue and approve a temporary change to the procedure before proceeding.
Such a sample was obtained and analyzed within the three-hour time period on January 22, 1983, with the exception of gaseous and liquid radionuclide analysis.
Gaseous and liquid radionuclide analysis were successfully performed within the three-hour time period on December 22, 1982.
(iii)
"The individuals normally expected to operate the post-accident sampling system (chemical technicians) had not completed the licensee's prescribed training program."
This information is consistent with that reported to the NRC on December 21, 1982, and February 9, 1983.
(iv)
" Provision for maintenance of the system including periodic use to verify operability had not been established."
As of January 1, 1983, eighteen calibration procedures applicable to PASS were in place.
Additional procedures prescribing maintenance and calibration of the PASS were not finalized pending accumulation of PASS operating experience, which was considered necessary in order to identify the appropriate frequency and nature of such maintenance and calibration.
Provisions were available, under Operating Instructions and the Combustion Engineering PASS Technical Manual, which established operating limits.
Exceeding these operating limits results in the issua'nce, under an existing maintenance program, of a work order to correct the deficiency.
i
Enclosure Response to Notice of Violation Page 13 (V)
" Procedures to analyze highly radioactive samples onsite of radioactive iodines and particulates in plant gaseous effluents under accident conditions had not been developed."
3 Existing procedures on January 1, 1983,-
stated that highly radioactive iodine and particulate samples would be analyzed offsite.
Negotiations were underway with General Atomics laboratory to expand the existing contract for PASS liquid analysis to include iodine and particulate filters.
General Atomics laboratory had verbally informed SCE that it would accept other samples but needed to assess handling and processing to establish procedures and contract billing rates.
Station procedures were not developed for transport and shielding these samples.
However, if the samples were less than 2mR/hr on contact, the existing Station procedures covered their analysis.
Therefore, existing procedures permitted analyses of samples obtained following most accidents defined in the Final Safety Analysis Report, i.
During the period from December 21, 1982, until February 25, 1983, SCE considered the license condition and technical specification program requirement for the PASS to be satisfied based on the completed installation and limited testing, procedural development and training.
NRC has not promulgated criteria to be utilized in assessing PASS operability, similar to criteria utilized in assessing the operability of other technical specification required systems.
In the absence of such criteria, and based on the prototypical nature of the PASS, SCE believed the system to be operable notwithstanding continued PASS system debugging, maintenance, modifications, procedural development, and training.
Based on the prototypical nature of the PASS, and the absence of operating experience with the system within the industry and limited testing of the installed system, complete procedural development was not viewed as precluding satisfaction of the license condition and technical specification program requirement.
Completion of the technician training had previously been discussed with the NRC.
Enclosure R@Cponce to Notice of Violation Page 14 9
SCE considered the system to be operable notwithstanding system debugging, maintenance, and modifications to improve reliability or overcome technical difficulties.
j.
On February 24, 1983, SCE submitted to USNRC:NRR the license amendment request to NPF-10 and NPF-15, respectively, reguesting an extension of the licensee condition due date to September 1, 1983.
NRR issued this license amendment on April 28, 1983, as License Amendment No.17 to NPF-10.
3.
REASONS FOR THE VIOLATION:
This violation was caused by lack of a sufficiently definitive standard by which operability of the PASS could be determined.
In the absence of the standard, SCE believed that operability could be established on a component by component basis based on the prototypical nature of the system.
4.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
To correct PASS program deficiencies, a PASS Task Force was established with a broad spectrum of SCE representatives.
A program for equipment modification, procedural development and training has been established under the auspices of this PASS Task Force.
The status of activities in these areas is as follows:
(a)
Equipment (i)
No additional design changes are required to perform the required analysis.
(ii)
Shielding containers are being evaluated for the iodine and particulate samples to be sent offsite, and the capability to analyze iodine and particulate effluent samples onsite is being evaluated.
Completion of this task is scheduled for September 1, 1983.
(iii)
Modifications may be necessary, if unforseen problems develop in future tests of the system.
.g.
Enclosure Response to Notice of Violation Page 15 (b)
Training One group of two SCE training instructors and two chemical technicians have nearly completed their 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> " hands-on" training.
A second group of four chemical technicians will now be trained.
Completion of the training is scheduled for June 31, 1983.
Eventually SCE intends to train j
essentially all of its chemical technicians in operation of the PASS.
(c)
Procedures The original list of twenty-two procedures has been expanded to include forty procedures and other documents.
These additional eighteen procedures are as follows:
(i)
SO123-III-8.10.23 Radioactive Iodine and Particulate Sampling Under Accident Conditions (target date 6/1/83)
(ii)
SO123-G-19 PASS Program (assigns administrative responsibilities)
(target date 6/1/83)
(iii)
(No i Yet) l Maintenance of PASS Heat Tracing (target date 8/1/83)
(iv)
(No f Yet)
Handling and Shipping of Offsite Chloride Sample (target date 6/1/83)
(V)
(No i Yet)
Onsite Handling, Transfer and Storage of PASS Samples (target date 6/1/83)
(vi)
(No i Yet)
Handling and Shipping of WRGM Filters Offsite (target date 6/1/83) a,- - - -
7 em..-
-..,,.e m-n
..v,.nr-,
.,,, - - - - -.. -. _ _,. _ -, -,.. = -
, -,. - - -, =
w.,
.~~ ~---
Enclocuro Risponto to Notice of Violation Page 16 (vii)
(No i Yet)
Core Damage Assessment (target date interim 5/30/83 - final 2/15/84)
(viii)
(Contractor Program)
Offsite Chloride Sample Analysis (General Atomic - estimate 7/1/83)
(ix)
(Contractor Program)
Offsite Analysis of WRGM Filter (General Atomic - not yet scheduled may not be required)
(x)
SO123-III-8.9 Operation and Calibration of the ND-SIX (xi)
SO123-III-8.1 PASS Routine Surveillances (xii)
SO123-III-8.8 Alternate Methods of Post-Accident Sampling (xiii)
SO23-I-8.30 PASS Semi-Annual Preventative Maintenance
( x.'. v )
SO23-I-8.131 PASS 18-Month Preventative Maintenance (xv)
SO23-I-8.132 Refueling Interval PASS Air Cleanup System Absorber Testing (xvi)
SO23-I-8.133 Refueling Interval PASS Air Cleanup System HEPA Filter System (xvii)
SO23-II-8.772 PASS Instrumentation Loops Calibration (xviii) SO23-II-12.446 PASS Instrumentation Calibration
-~
l Enclosure Response to Notice of Violation Page 17 1
It should be noted that the procedure SO123-III-8.8, " Alternate Methods of Post-Accident Parameter Sampling,"
describing in detail the alternate methods of post-accident parameter sampling, is F
available for use in the event of a PASS component failure.
5.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
To avoid future violations concerning compliance with license conditions, special review meetings have been, and will continue to be, convened to review license conditions, regulatory requirements, commitments related to them and the 3
details of conformance with the requirements.
These meetings include SCE senior management as well as managers and technicians responsible for the activities associated with the license conditions.
6.
DATE WHEN PULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved by September 1, 1983, the date identified in Amendment No. 17 to Operating License NPF-10 for Unit 2, when license conditions and Technical Specification program requirements related to the PASS will be satisfied.
Enclosure Response to Notice of Violation Page 18 The enclosure to the March 24 letter states:
"C.
License Condition 2.G. states:
'SCE shall report any violations of the requirements contained in Section 2, Items C(l), C(3) through C(22), E, and F of this license within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirmed by telegram, mailgram, or facsimile transmission to the NRC Regional Administrator, Region V, or his designee, no later than the first working day following the violation, with a written followup report within fourteen (14) days.'
' Contrary to the above requirements, although the licensee's Corrective Action Request (CAR SO23 P-325),
dated January 31, 1983, stated 'the post-accident sampling program has not been fully implemented,' as required, 'in that adequate system operating procedures have not been approved or issued for use and operator training on the system has not yet been conducted,' this licensee-identified violation of license condition 2.C.(19)i was not reported to the NRC until March 4, 1983 by letter dated February 25, 1983.
"This is a Severity Level III violation (Supplement I)
(Civil Penalty - $40,000)"
1.
ADMISSION OR DENIAL OF ALLEGED VIOLATION:
SCE admits that the licensee's Corrective Action Request (CAR S023 P-325), dated January 31, 1983, stated "the post-accident sampling program has
(
not been fully implemented," as required, "in that adequate system operating procedures have not been approved or issued for use and operator training on the system has not yet been conducted" and that a failure to meet License Condition 2.C.(19)i was not reported until done so by letter dated February 25, 1983.
2.
STATEMENT OF FACTS AND CIRCUMSTANCES:
I a.
As described in Section B.2 above, on December 21, 1982, SCE advised the NRC by l
telephone and in writing, that operator training could not be completed until the plant returned to power.
l
[
i l
-s Enclosure Response to Notice of Violation Page 19 b.
As described in Section B.2 above, as of January 1, 1983, twenty-two operation and calibration procedures had been approved and issued.
3.
REASONS FOR THE VIOLATIONS:
As described in Section B.2.i above, limited procedure development and training were not viewed as precluding satisfaction of the license conditions and Technical Specification program requirements related to the PASS.
Based on the prior reporting to the NRC of the status of operator training and based on the existence of approved and issued Station procedures delineating PASS operation and calibration, the conditions identified in CAR SO23 P-325 were not viewed as r eportable to the NRC.
4.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Based on recognition that a different standard was to be utilized in assessing PASS operability and program implementations, SCE made the report required by License Condition 2.G on February 25, 1983.
5.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
As described in Section B.5 above, special review meetings are being held to evaluate compliance with license conditions, regulatory requirements, t
l commitments related to them and the details of conformance with the requirements.
Reportable i
conditions identified by these reviews, and by other processes such as QA surveillances and audits, will be promptly reported to the NRC.
I 6.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved when this matter was reported to the NRC by letter dated l
February 25, 1983.
1 l
t t
Enclosure Racponse to Notice of Violation Page 20 The enclosure to the March 24 letter states:
10CFR 50.59 ' Changes, tests and experiments,'
"D.
provides, in part, that '(a)(1) The holder of a license authorizing operation of a production or utilization facility may (i) make changes in the facility as described in the safety analysis conduct tests or experiments not report'...'and (iii) described in the safety analysis report, without prior j
Commission approval, unless the proposed change, test or experiment involves a change in the technical specifications incorporated in the license or an unreviewed safety question.
"The licensee is also required to maintain records of changes, tests and experiments carried out pursuant to I
of this section.
The records are paragraph (a) required to include a written safety evaluation which provides the bases for the determination that the change, test or experiment does not involve an unreviewed safety question.
" Contrary to the above, when a test loop containing a flow rate meter was installed in the suction piping of high pressure safety injection (HPSI) pump 2P017, on January 16-17, 1983 and HPSI 2P019, on January 19-23, 1983 to test the flow characteristics of each pump, the records of these changes and tests did not include a written safety evaluation.
'This is a Severity Level IV violation (Supplement I)"
1.
ADMISSION OR DENIAL OF ALLEGED VIOLATION:
SCE admits that the records of tests conducted from January 16 - 23, 1983, did not include a written safety evaluation although such an evaluation was made for the temporary i
installation of the required flow measuring i
l device.
l 4
i
Enclosure Response to Notice of Violation Page 21 2.
STATEMENT OF FACTS AND CIRCUMSTANCES; a.
In November 1982, the Station identified the need for use of a temporarily-installed, calibrated flowmeter to be used for HPSI pump ISI testing and to calibrate the flowmeter normally used for this testing.
This rasulted in an assignment to the Project to develop a design for temporary installation of such a device.
The design was documented in Design Change Package (DCP) 858 N.
This DCP was subjected to a written safety analysis based on the criteria of 10 CPR 50.59, and that analysis resulted in conclusions that neither the probability nor consequences of accidents analyzed in the FSAR were increased and the possibility of an unanalyzed accident was not created (these conclusions were documented on pages 6 and 7 of DCP 858N).
The basis for these conclusions was that the flowmeter would be only temporarily installed for testing of a pump which would not then be in operation, and it would be removed before the associated HPSI train was placed in operation.
b.
Inasmuch as the HPSI train undet test was to have been considered inoperable during that time when the flow-measuring device was installed and would not again be declared operable until the device was removed, the train returned to its pre-test configuration and its components subjected to operability checks, no 10 CPR 50.59 review of the performance of the test was considered to be necessary.
c.
Although the HPSI train to be tested was to have been declared inoperable with the flow-measuring device installed, Operations believed that installation of the flow-measuring device only affected the operability of the HPSI pump being tested.
For example, for the testing of HPSI pump 2P-017, Operations aligned HPSI pump 2P-018 with Train A in parallel with 2P-017 and believed that installation of the flow-measuring device only affected the operability of 2P-017, not the e'ntire Train A.
Enclosure Response to Notice of Violation Page 22 d.
Recognition of inoperability of HPSI Train A would have caused Operations to prepare a LCOAR which would have identified the fact that Train A would become inoperable during the period of pump-flow testing, when 2P-017 isolation valves would be opened and Action Statement "a" associated with LCO 3.5.2 would apply, requiring restoration of the ECCS subsystem within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The need for this LCOAR was not recognized by Operations or communicated to Operations by Station Engineering.
3.
REASONS FOR THE VIOLATION:
The violation was caused by failure to declare the HPSI train inoperable during that time when the flow-measuring device was installed.
Inoperability of the HPSI train with the flow-measuring device installed was the basis for concluding that a 10 CFR 50.59 evaluation for the performance of the test was not required (a 10 CFR 50.59 evaluation was required, and was performed, for installation of the flow-measuring device).
This failure to declare the HPSI train inoperable was, in turn, caused by the fact that the organization responsible for the test was not required to identify the effect of the test on component and system operability.
4.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
In most cases, the Station organization requesting work initiates required paperwork, such as Work Authorization forms, Equipment Control forms, and associated LCOARs.
An exception to this has been the Inservice Inspection (ISI) testing program by Station Engineering, in which case Operations has initiated the required paperwork.
This led to the error in this case, wherein Station Engineering believed HPSI Train A to be inoperable, and Operations believed that only 2P-017 was inoperable,but did not recognize the effect of the unqualified flowmeter on 2P-018 when 2P-017 was in the test configuration.
Procedures were revised to eliminate such exceptions by February 25, 1983.
Enclosure Response to Notice of Violation Page 23 5.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Although a 10 CFR 50.59 review was conducted for installation of the flow-measuring device and a 10 CFR 50.59 review was not required for the performance of the test had it been conducted, as planned, with the HPSI train declared inoperable during the time the flow-measuring device was installed, the importance of conducting such reviews whenever an unreviewed safety question may be created will be emphasized in writing to all cognizant personnel.
Procedures will also be reviewed, and revised as necessary, to emphasize the importance of conducting 10 CFR 50.59 reviews where required.
These actions will be completed by May 30, 1983.
In this case, most valve manipulations were controlled by the Equipment Control forms or reference to the engineering test procedure and no special procedure was developed.
Valve manipulations required to control pump and line venting were based on operator experience with operating procedures.
Accordingly, corrective action will also include:
(1) revision of Engineering ISI and Operating Procedures, as necessary, to ensure all ISI procedural steps are included in these procedures, and (2) renewed emphasis on exactly following approved procedures, or other documents such as work authorizations, and on not proceeding with operations where they do not exist in approved documentation or cannot be followed, except when necessary to protect personnel or equipment.
6.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved with implementation as above-identified corrective action which will be completed by July 31, 1983.
_,_v
~
Enclosure Responce to Notica of Viointion Page 24 The enclosure to the March 24 letter states:
"E.
Technical Specification paragraph 6.8.1.a prescribes that " written procedures shall be established, implemented and maintained covering...the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978."
1.
Station Operating Instruction SO23-0-16,
" Temporary Modification Control," states, in paragraph 1.1 that:
'1.1 Temporary Modifications to plant design are controlled by one of three methods as follows:
'l.1.1 Temporary Modifications specifically called for by a station procedure which contain steps to install and remove the Temporary Modification shall be documented and controlled by the station procedure.
Use of the temporary Modification Control Form SO(123)106 is not required.
'l.1.2 Temporary Modifications installed and removed during the course of repair (before the work authorization is released) shall be documented and controlled by the Work Authorization Control Form SO(123)l15.
Therefore, use of the Temporary Modification l
Control Form SO(123)106 is not required, l
l
'1.1.3 Temporary Modification not specifically called for in a procedure and to remain installed following the release of the work authorization shall be documented and controlled by the use of the Temporary Modification Control Form SO(123)106.'
l I
l
~~
1 Enclosure R3sponse to Notice of Violation Page 25
" Contrary to the above requirement; temporary
)
modifications to the suction piping of HPSI pumps 1
Nos. 2P017 and 2P019 were made and not controlled by one of the above methods.
Specifically, a flow test loop consisting of approximately twenty feet of piping and a turbine flow rate meter was installed and used in the suction line for pump 2P017, on January 16-17, 1983, and for pump 2P019, on January 19-23, 1983 to measure flow rates of the respective pumps.
The installed test loop was not described specifically in a station procedure, nor was this temporary modification installed and removed in the course of repair, nor was it documented and controlled by the use of the Temporary Modification Control
^
Form SO(123)106.
"This is a Severity Level IV violation (Supplement I)"
1.
ADMISSION OR DENIAL OF ALLEGED VIOLATION:
SCE admits that the installed test loop was not described specifically in a Station procedure, nor was this temporary modification installed and removed in the course of repair, nor was it documented and controlled by the use of the Temporary Modification Control Form SO(123)106.
However, it should be noted that although it was not installed and removed during the course of
" repair", a Work Authorization did authorize the installation and removal of the flow-measuring device and the Work Authorization Record Sheet was not closed until the flow-measuring device was removed.
2.
STATEMENT OF FACTS AND CIRCUMSTANCES:
Review of this testing with the personnel involved reveals the following:
a.
As was identified in Section D above, design and installation of the flow-measuring device was documented in Design Change Package (DCP) 858N.
j i
b.
Station Operating Procedure SO23-0-16,
" Temporary Modification Control," currently identifies three methods to control modifications to plant design wh'ich, like that described in DCP 858 N, are considered temporary.
They are:
Enclo2uro Racponco to Notice of Violation Page 26 (i)
Control by Station procedure calling for installation and removal; (ii) Control by a Work Authorization form when the modification is to be installed and removed prior to release of the Work Authorization; and, r
(iii) Control by a Temporary Modifications Control form when the modification is not specifically called-for in Station procedure and when modification is to remain in place following the release of the work Authorization.
c.
Representatives of Station Engineering and the Project met to discuss the DCP and concluded that the installation and test did not require processing as a Temporary Modification since the HPSI train would be inoperable during that time when the flow-measuring device was installed.
They believed that the HPSI train would not again be declared operable until the flow measuring device was removed, the train returned to its pre-test configuration, and its components subjected to operability checks.
Under these circumstances, installation, use and removal of the flow-measuring device was to be controlled by a Work Authorization (method 11, above),
d.
Operations prepared Work Authorization 2-4096 for the installation, and removal of the flow-measuring device.
e.
The Work Authorization Record Sheet reflects two Clearances: one Clearance to permit installation of the flow-measuring device; the other, to permit removal of the device.
The initial clearance authorized the installation of the flow-measuring device and was released to permit pump testing.
The second clearance authorized the removal of the flow-measuring device and when it was released, the Work Authorization Record Sheet was closed out.
3.
REASONS FOR THE VIOLATION:
The reason for this violation was the' belief that adequate control of plant configuration was maintained by the Work Authorization, since the HPSI train was to have been declared inoperable j
during the time the flow-measuring device was installed.
j
Enclosuro RagponCo to Notice of Violation Page 27 4.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The circumstances surrounding this incident were reviewed with all Operations and Station Engineering personnel.
This was completed on March 30, 1983.
5.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTEER VIOLATIONS:
A Station Order will be developed and issued, which will document policy with respect to control of plant status which is now described in several Station procedures dealing with Equipment Control, Temporary Modifications, etc.
This Station Order will be issued by May 31, 1983.
The Temporary Modification Control procedure will be revised to clearly indicate that the procedure is only intended to control modifications to the plant which are outside the other administrative controls used to control changes in plant configuration as depicted in design documents.
These other administrative controls are procedures and work authorizations.
Configuration changes which are made by a procedure are controlled by the procedure.
Work performed under a work authorization is returned to its original configuration prior to release of the work authorization.
If in the performance of work under that work authorization a change in plant configuration will remain, then either a Temporary Modification would be initiated, or a Proposed Facility Change would be initiated.
These clarifications will be incorporated in the procedure.
This change will be incorporated by May 15, 1983.
6.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Corrective actions to clarify the control of temporary modifications which have been shown by this matter to be necessary will be completed by May 15, 1983.
Enclosure R2 ponse to Notice of Violation Page 28 The enclosure to the March 24, 1983 letter states:
- 2.
Station Operating Instruction SO23-0-13, " Work Authorizations," prescribes that for systems or components important to safety, an independent verification of the alignment of equipment returned to service shall be performed and documented.
' Contrary to the above requirement, on January 16, 1983 HPSI pump No. 2P-017 was returned to service for testing (releasing Work Authorization 2-4096) without proper independent verification of the positions of the manual suction, discharge, and miniflow valves for the pump.
A purported independent verification was substituted for the required verification by the control operator who signed the valve line-up sheet as the independent verifier by relying on the oral assurance of the operator who changed the position of the valves that the valves had been restored to the desired positions.
"This is a Severity Level IV violation (Supplement I)"
1.
ADMISSION OR DENIAL OF ALLEDGED VIOLATION:
SCE admits that on January 16, 1983 HPSI pump No.
2P017 was returned to service for testing without proper independent verification of the positions of the manual suction, discharge and miniflow valves for the pump.
2.
STATEMENT OF FACTS AND CIRCUMSTANCES:
Review of this matter with Operations personnel involved and review of records produced reveals the following:
a.
Valve lineup to be established following the inservice testing of HPSI pump 2P-017 on January 16, 1983 was documented on the Work Autnorization Record Sheet for the installation and subsequent removal of the flow measuring device (Work Authorization 2-4096).
Enclo2ure R0sponG@ to Notics of Violction Page 29 b.
Valve positioning, as required by the Work Authorization Record Sheet, was accomplished by a qualified Nuclear Plant Equipment Operator, and was documented on the Work Authorization Record Sheet.
c.
The required second verification was identified as being completed by the initials of the Reactor Operator in the appropriate locations on the Work Authorization Record Sheet.
d.
The Reactor Operator initialed the Work Authorization Record Sheet signifying completion of a second verification of valve lineup based on the belief that the Inservice Inspection Engineer, responsible for performance of the inservice testing of the HPSI pump, had verified proper valve lineup following the test as part of his procedure for the performance of the test.
The Inservice Inspection Engineer was neither directed by the Reactor Operator to verify valve lineup nor contacted by the Reactor Operator to confirm that a valve lineup check had been performed.
3.
REASONS FOR THE VIOLATION:
This violation was caused by personnel error on the part of the Reactor Operator.
4.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
This valve line-up was verified to be correct on January 19, 1983, using Station Engineering Procedure SO23-V-3.4.4.
The operator indicating that a second verification had been made has been counseled concerning his error.
Additional instruction and guidance was provided on February 1983 in writing, to Operations personnel clarifying the requirements for second verification and acceptable means of performing and documenting initial and second verifications.
This will be included in the operator retrail.ing program.
- ~.
Enclosure R3sponse to Notice of Violation Page 30 5.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Station-wide clarification on what signatures and initials represent, relative to procedural requirements for same, will be issued by May 30, 1983.
i 6.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on January 19, 1983, when the valve line-up was verified to be correct.
l
Enclosure Response to Notice of Violation Page 31 The enclosure to the March 24, letter states:
"3.
Station order SO23-Q-16, " corrective Action" requires that conditions adverse to quality at San Onofre Nuclear Generating Station Units 2, - and 3, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, be promptly identified and corrected as soon as practicable.
" Contrary to the above requirements, action had not been taken at the time of the inspection to correct the malfunction of the Kirk Key interlock on the Train
'A' breaker of HPSI pump 2P018, which the licensee identified on September 6, 1982.
This malfunction permitted the starting of two HPSI pumps on the same ESF bus at the same time, a condition which had not been previously analyzed in the FSAR.
"This is a Severity Level IV violation (Supplement I)"
1.
ADMISSION OR DENIAL OF ALLEDGED VIOLATION:
SCE admits that following action taken intended to correct the malfunction of the Kirk Key interlock on the Train A breaker of HPSI pump 2P018, an inadequate retest was specified to verify that it had been effective in correcting the cause of the malfunction.
2.
STATEMENT OF FACTS AND CIRCUMSTANCES:
SCE notes that action was taken promptly in response to the observed malfunction involving starting of two HPSI pumps on the same ESF bus at the same time.
On September 6, 1982, during the performance of a.
ESFAS Auxiliary Relay testing, the Unit 2 HPSI pumps, 2P-017 and 2P-018 were observed to start simultaneously when provided with what represented a Safety Injection Actuation Signal (SIAS).
This should not have occurred, as the simultaneous starting of these two pumps is not consistent with the intent of the system design.
The test being performed, however, did not include an acceptance criteria that two pumps not start as one normally has its breaker racked out.
Therefore, the starting of two pumps was not a test failure and the test was not rerun following investigation and repair of the problem.
A Station Incident Report (SIR 82-201) was initiated and a Work Order (WO 13416) was created to provide for investigation and repair.
Enclonuro Response to Notice of Violation Page 32 b.
Investigation identified, as the cause, a sticking kirk key.
This key is provided in the design to select among pumps to be started automatically and prevent simultaneous starting of more than one pump on a. single diesel generator.
Based on prior problems with kirk keys, and based on the recognized significance of the malfunction on September 6, 1982, Station Engineering initiated a generic review and evaluation of the kirk key problems.
Corrective actions were implemented to ensure proper operation of all kirk keys and this particular case was reported as having been corrected and checked.
c.
The actual problem leading to simultaneous starting of 2P-017 and 2P-018 was discovered, after January 16, 1983, to be a factory-installed jumper in the associated switchgear which has now been removed.
d.
In this case, corrective actions were deliberate and well thought-out.
They received review by higher levels of management and were considered to be adequate and appropriate (Station Incident Reports and associated corrective actions are reviewed and approved by the Station Manager and the Manager of Nuclear Operations).
In this case, however, corrective action, being influenced by past problems with kirk keys, was misdirected.
Subsequent analysis by SCE Engineering and e.
confirmed by the Architect-Engineer indicated that the Diesel Generator and the emergency electrical distribution system are capable of accepting and operating with the j
increased load of both HPSI pumps starting l
simultaneously on the same train.
3.
REASONS FOR THE VIOLATION:
The reason for the violation was an error in identification of the cause of the malfunction leading to insufficient corrective action, inadequate retest and the failure to remove the factory installed jumper.
This error resulted from the fact that surveillance testi'ng does not normally seek to find and correct errors in construction which existed in this case.
Enclosure Response to Notice of Violation Page 33 4.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RENULTb ACHIEVED:
The factory-installed jumper has been removed and a review of other switchgear has indicated no similar construction errors exist.
Procedures specifying the testing-of the HPSI pumps have been modified to include verification that SIAS initiated start of a HPSI pump does not result in simultaneous starting of more than one HPSI pump on a single diesel generator train.
This requires racking in a breaker of the second pump which is normally racked out.
5.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
This matter and the importance it attaches to thorough, creative evaluation of problems and the corrective actions they warrant, will be included in the retraining of Operations personnel and will be the subject of an instructive memorandum to engineering personnel.
A written Station policy will be developed that prescribes the scope of retest requirements and, in particular, triggers the expansion of such retest requirements where necessary to verify the adeq'uacy of repair or maintenance.
This will be completed by May 31, 1983.
l 6.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
t Full compliance was achieved on February 12, 1983,
~
l when the factory-instal 2ed jumper was removed and the system restored to its design basis I
l configuration.
Corrective actions shown to be j
necessary by review of this matter will be completed by May 31, 1983.
j t
I 6
w
Enclosure R0nponse to Notice of Violation Page 34 The enclosure to the March 24 letter states:
"F.
Technical Specification 6.8.3.c requires that temporary changes to procedures of Technical Specification 6.8.1 may be made provided:
the change is documented, reviewed and approved by the station manager; or by his designated manager within 14 days of implementation.
" Temporary change number (TCN) 3 Procedure S023-V-3.4.4, "High Pressure Safety Injection Pump Test" was approved on October 23, 1982 by two members of the plant management staff.
Contrary to the above requirement, TCN3 was neither documented, revised, nor approved, as of January 23, 1983, by the station manager or his designee.
"This is a Severity Level V violation (Supplement I)"
1.
ADMISSION OR DENIAL OF ALLEGED VIOLATION:
SCE admits that Temporary Change Notice (TCN)
No. 3 to procedure SO23-V-3.4.4 was not approved by the required date of November 6, 1982 by the Station Manager or his designee.
2.
STATEMENT OF FACTS AND CIRCUMSTANCES:
a.
TCN Number 3 to Engineering Procedure S023-V-3.4.4, "High Pressure Safety Injection Pump Test" was issued on October 23, 1982 requiring Station Manager (or designee) approval within the following fourteen days.
The TCN was misfiled in processing and not retrieved until January 1983.
b.
Issuance of this TCN preceded corrective actions taken by Station, on a generic basis, to ensure that TCN's are approved within fourteen days of issuance.
These corrective actions were implemented on November 5, 1982, in response to a Corrective Action Request issued by SCE Quality Assurance.
The corrective actions included:
i (i)
Responsibility to obtain approval of TCN's within fourteen days of issuance was assigned to a specific Station organization (the Station Procedures Group).
(ii) Computerized tracking of issued TCN's wts implemented.
This tracking provides a 10-day " reminder" after TCN issuance.
)
Enclocure Responce to Notico of Violation Page
'S (iii)
Corporate Documentation Management personnel, who are responsible for filing approved TCN's, were instructed in the requirement that TCN's which have not been approved following issuance are not to be filed as completed.
These corrective actions were implemented November 5, 1982, after the problem with the subject TCN occurred.
Corrective actions taken November 5, 1982, did not include a review of prior records for completeness.
3.
REASONS FOR THE VIOLATION:
This violation was caused by personnel error in misfiling the TCN prior to approval.
4.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
SCE had identified and implemented corrective action to prevent recurrence of this problem prior to its identification by the NRC.
Records of TCNs processed prior to November 5, 1982 have been reviewed.
This was completed March 11, 1983.
All TCNs issued before November 5, 1982 have been verified to have received proper approval.
5.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
The ongoing program identified in Section 2 above will preclude recurrence of this oversight.
6.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on March 11, 1983.
00397u:jll l
m
be s Scock Form i114 October 1967 Title ?, GAO Manual BILL FOR COLLECTION ito-w6 Bill No.
U. S. Regululatory Commissidn Date Mat h 19C3 (Department or Estabbshment and Bureau nr OtTice)
Washinotnn DC 20 }35 (Address)
PA YER:
Southern California Edison
'O' OOE O 2244 Walnut Grove Avenue This bill should be rrturned by the p y,,,,,4 a f,,,,,n,,,,,,,,
Rosemead, California 91*i70 SEE INSTRilCTIONS BELO W.
"I' Date DESCRIPTION Quantity Amount Cost Per 5/6/C3 Full payment for CP EA G3-13, dated 3/24/03, Docket No. 50-351.
5120,000.00 l
A.\\l0U.YT DUE THis BILL, S1a.u, 0 u. m,,JJ 3
0 This is not a receipt INSTRUCTIONS Trneler of p.n ment of the above hill may be made in cash. Unient States postal money order, express money order, bank draft. or check, to the othre imin ated.
Such temler, w hen in any other form than cash, shouhl be elraw n to the order of the Department or Establishment and Burrau or ()tlu r nuiu aird abus e.
Rei ripts will be murel in all cases w here "< ash" is ret en ed. aimi only ulum r equest w hen remittance is in any other form. If tender of pas ment ut ihn hdl is olhrr than a ash or linitrti States postal mones.nrder, t he ret ript shall not bei ome an acquittance until such temirr has brrn irarnt amt the amount reirised bs the 1)cpartment or F.stabbshment and flus rau or Olli< c indicated abus e.
Fadure to in ene a in apt inr a i ash pas ment shoubt be promptis reported hv the pascr to the c hief administratne officer of the burrau or aerm s mennunrd alwn c.
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5ANK of AMERICA N.T. & S.A.
,'ina t : e f. Cmce Rosemeal c3tr 16 f 5>'222 10825 00001 MAY -
1983 Southern California Edison Company a,
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PLEASE CASH
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CMECE NO.
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