ML20023C543
| ML20023C543 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/14/1983 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20023C541 | List: |
| References | |
| 50-361-83-13, NUDOCS 8305170420 | |
| Download: ML20023C543 (3) | |
Text
APPENDIX A NOTICE OF VIOLATION Southern California Edison Company Docket No. 50-361 San Onofre Nuclear Generating Station Unit 2 License No. NPF-10 As a result of a special inspection conducted during the period of March 12-25, 1983 and in accordance with NRC Enforcement Policy, 10 CFR Part 2, Appendix C, the following violations were identified:
A.
Technical Specification 6.9.1.11 states, in part, that "The REPORTABLE OCCURRENCES of Specifications 6.9.1.12 and 6.9.1.13 below, including corrective actions and measures to prevent recurrence, shall be reported to the NRC..."
]
Technical Specification 6.9.1.12 lists the types of events which shall be reported by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Director of the Regional 4
Office, on his designate, and confirmed by telegram, mailgram or facsimile no later than the first working day following the event, with a written followup report within 14 days.
Technical Specification 6.9.1.12.i describes a type of event which shall be reported pursuant to Technical Specification 6.9.1.12 and states as follows:
" Performance of structures, systems, or components that requires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analyses in the safety analysis report or Technical Specifications bases; or discovery during unit life I
of conditions not specifically considered in the safety analysis report or Technical Specifications that require remedial action or corrective measures to prevent the existence or development of an unsafe condition."
On March 25, 1982, surveillance testing of the reactor trip breakers identified that trip circuit breakers (TCB) Nos. 4, 6 and 7 would not t
trip immediately when the undervoltage trip device was deenergized. On i
July 12, 1982, surveillance testing of the reactor trip breakers identified that TCB Nos. 4 and 7 would not trip when the undervoltage trip device was deenergized.
Contrary to the above requirements, as of March 15, 1983, neither of l
these failures had been reported to the NRC.
4 This is a Severity Level IV violation (Supplement I).
B.
10 CFR 50.34, " Contents of application; technical information," requires that each licensee submit information which describes the managerial and l.
administrative controls to be used to assure safe operation.
SCE-1-A, " Quality Assurance Program," is the licensee's topical report which describes these controls. Chapter 5-C, " Maintenance Program",
paragraph 3.0, states, in part.
8305170420 830414 PDR ADOCK 05000361 G
r "A preventative maintenance program shall be established and maintained which describes the frequency and type of maintenance to be performed.
It shall include the considerations described in paragraph 2.0 above..."
Among the considerations listed in paragraph 2.0 are:
"h.
The equipment supplier's suggested maintenance schedules and requirements i.
The maintenance history of the equipment" Station Order S0123-M-5, Revision 2, " General Maintenance Order," states, in paragraph 6.3.2, that:
"The scheduled preventive maintenance program shall consist of routine maintenance recommended by equipment vendors and experience with comparable equipment. The program should reflect service conditions of the particular components, should be revised and updated as experience is gained with the equipment, and shall prescribe the frequency and type of maintenance to be performed."
Station Order S0123-M-4, Revision 0, " Preventive Maintenance Program,"
paragraph 6.2.3, states tbst:
"The program (s) shall be updated to conform to current industry standards, i.e., Bulletins, vendor technical information, IEEE Stds., ANSI Stds., or other reference documents relative to the subject."
Contrary to these requirements, on March 15, 1983, the licensee's preventive maintenance program did not fully implement General Electric Service Alert Letter No. 175 (CPPD)9.3 in that the program only provided for inspection of the breakers each refueling. The General Electric Service Alert Letter requires that the frequency of inspection should be increased until it can be verified that the revitalization of lubrication is effective for the normal maintenance interval.
Furthermore, Station Maintenance Procedure MPES-008, " Maintenance Procedure for Undervoltage Tripping Device of the Reactor Trip Switchgear," did not check for excessive clearance between the undervoltage trip device armature and rivet as required by Paragraph 1 of the letter. This General Electric Service Alert Letter was provided by IE Bulletin 79-09.
This is a Severity Level IV violation (Supplement I).
+P 4
Pursuant to the provisions of 10 CFR 2.201, Southern California Ed4 son Company is hereby required to submit to this office within 30 days s2 the date of this Notice, a written statement or explanation in reply, including (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
The response directed by this Notice is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
APR 2.4 E03
._s Date D. F. Kirsch, Chief Reactor Projects Section No. 3
_. ___