ML20024E239

Responds to NRC 830617 Ltr Re Violations Noted in IE Insp Repts 50-361/83-15 & 50-362/83-13.Corrective Actions: Typographical Error in Check List Corrected & Checkoff List Expanded to Indicate Switch Location & Function

ML20024E239
Person / Time
Site:	San Onofre
Issue date:	07/12/1983
From:	Mccarthy C SOUTHERN CALIFORNIA EDISON CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20024E237	List: ML20024E239
References
NUDOCS 8308100105
Download: ML20024E239 (13)

Text

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4 c- r-i Southern California Edison Company 5}-.f P O. BOX 800 2 244 W ALNUT GROVE AVENUE ROSEMEAD. C ALIFORNI A 91770 M July 12, 1983 hp c h ~

h 9 U.S. Nuclear Regulatory Comnission  !! 3 Office of Inspection and Enforcenent 9 -

Region V .-

1450 Maria Lane, Suite 210 0 Walnut Creek, California 94596-5368 -

Attention: Mr. J. B. Martin, Regional Administrator

Subject:

Docket Nos. 50-361 and 50-362 IE Inspection Reports 50-361/83-15 and 50-362/83-13 Response to Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3 Mr. T. W. Bishop's letter of June 17, 1983, issued IE Inspection Report 50-361/83-15 and 50-362/83-13 and forwarded a Notice of Violation resulting from the March 23 through April 29, May 17, and June 1 and 2, 1983, routine -

inspection' conducted by Messrs. A..E. G affee, J. P. Stewart, and D. F. Kirsch.

'Ihe enclosure to this letter provides our response to the Notice of Violation contained in Appendix A to Mr. Bishop's letter of June 17, 1983.

Mr. Bishop also requested we address any actions taken or planned to: (1) assure that the valve and system lineup procedures, filed in the Control Room, adequately reflect installed plant conditions, correct position requirements, and provide adequate definition of component location and labels; and (2) assure that operators properly implenent the requirements of valve and system lineup procedures and promptly effect corrective actions to resolve procedure discrepancies observed i during the conduct of valve and systen lineups. Our response to itens Al and A2, l respectively, have been expanded to address these concerns.

If you require additional information, please so advise.

Sincerely, N/q/

c

~ '

/

l

! Enclosure cc: A. E. Gaffee (USNRC Resident Inspector, Units 2 and 3)

J. P. Stewart (USNRC Resident Inspector, Units 2 and 3)

Garles B. McCarthy 8308100105 830805 Vice President, Advanced Engineering i

' PDR ADOCK 05000361 O PDR

4 ENCIDSURE Response to the Notice of Violation contained in Appendix A to Mr. T. W. Bishop's

-letter of June 17, 1983.

j ITEM Al Appendix A to Mr. Bishop's letter states:

I "10 CER 50, Appendix B, Criterion V, states that ' Activities affecting I

quality shall be prescribed by documented. Instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative acceptance criteria for determining that important activities have been satisfactorily accomplished.'

. " Chapter 5-A of Southern California Edison Topical Report, SCE-1-A, implementing the above requirenent, states, in paragraph 10.0, that 'Esch procedure shall be sufficiently detailed for a qualified individual to perform

, the required function without direct supervision, but need not provide a i complete description of the system or plant process. Procedures ,

shall include, as appropriate, the following elements: ...(9) Geckoff lists. Complex procedures shall have checkoff lists. These lists may be included as part of the procedure or may be appended to the procedure.'

" Technical Specification paragraph 6.8.1 states that ' Written procedures shall be established, implemented and maintained covering...

4

a. The applicable procedures reconnended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978, ...

f. Fire Protection Program Implementation.'

" Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, i paragraph 3, states, in part, that '... Instructions for energizing, filling,

! venting, draining, startup,' shutdown, and changing modes of operation should

be prepared, as appropriate, for the following systems

...e. Component Cooling Water System ...l. Auxiliary Feedwater Systen.'

"1. Contrary to the above requirements, the following procedures were inadequate in that insufficient details or incorrect information existed, such that a qualified individual would be unable to perform the required function without direct supervision.

"(a) Operating) Procedure Operation was S023-2-4, inadequate in thatRevision Checkoff6 List (Auxiliary 2, Feedwater System steps 2.1.20, 2.1.22, 2.1.23, 2.1.25, and 2.1.26, lacked specificity and/or provided incorrect information.

l l

i ITB4 Al (Continued) i

"(1) Steps 2.1.20 and 2.1.23 identically describe as line items ' Breaker / Switch Ntsnber CBl' and as 'DC Feeder. '

%ese descriptions are not sufficient to allow an .

operator to positively identify the specific

. breaker / switch to be operated, the breaker / switch location, or position to be verified in the performance of this procedure. On June 1, 1983, the switches were found to be located in electrical panels MS4705 and MS4706, respectively, however, the breakers did not have any identification label attached identifying the breaker i- as CBl.

"(2) Steps 2.1.22 and 2.1.25 are essentially identical, describing the Breaker / Switch ntsnber as 'CB3' for valve

'HV-4715. ' On June 1, 1983, the switches were found to

be located in electrical panels MS4705 and MS4706, respectively, however, the breakers in question were not labeled as CB3, as identified in the procedure, but sere L instead labeled as 'HV4715' and 'HV-4730' as contained in the procedure description. Operators performing the Unit 2 electrical lineup check indicated in the Coments section, on April 19, 1983, that they believed the Breaker / Switch that was intended to be identified in step 2.1.22 was the Breaker / Switch for Valve HV-4730 instead of HV-4715. De Breaker / Switch for Valve HV-4730 was not contained in G eckoff List 2 nor was a position required to be verified contained in the checkoff list for this Breaker / Switch.

t'

"(3) In step 2.1.26, the components to be verified are +

L descr a i as 'DC Disconnect Switches' with the i

' Breaker /% itch ntsnber listed as 'NA' (NUT APPLICABLE).

he ntsnber of DC disconnect switches and the location of the switches could not be determined from the procedure.

he operators performing the Unit 2 electrical lineup I check, on April 19, 1983, indicated in the Comnents l section that the 'Asstaned location of the DC Disconnect l Switches was cabinet 2MS4816.'

"(b) % e Unit 2 Operating License No. NPF-10, paragraph 2.C(14),

and the Unit 3 Operating License No. NPF-15, paragraph 2.C(12) require full implenentation of all provisions of the approved

Fire Hazard Analysis.

'*Ihe Fire Hazard Analysis requires, on page III-36 of 4 Table III-1, that, when electrical supervision of fire protection valves is not practicable, an adequate management supervision program should be provided to include locking valves open. He licensee's statenent of compliance, on the same page, indicates that Post Indicator Valves and header

! isolation valves for Seismic Category 1 standpipes are

.normally locked open.

ITEM A1 (Continued)

(b) (Continued)

"The Safety Evaluation Report attached to the Unit 3 Operating License No. NPF-15, page 9, accepts the Southern California Edison Company's position that header isolation valves for seismic standpipes and locked open manual isolation valves to deluge systems are not electrically supervised.

" Contrary to the above requirements, as of April 14, 1983, Operating Procedure S023-7-1, Revision 7 (Fire Suppression Water System Operation), including Temporary Gange Notice No. 1, was inadequate in that certain valves of G eckoff List 1, listed below, were merely required to be open and not locked open with the exception of SA2301MU209, which was required to be closed and capped.

" PROCEDURE VALVE STEP NIMBER DESCRIPTION 60 SA2301MUO41 Manual isolation valve inside Unit 2 Containment 82 SA2301MU202 Manual isolation valve in Penetration Building just outside Unit 2 Containment 106 SA2301MU209 Manual isolation valve in Control Building north header 115 SA2301MU211 Manual isolation valve in Control Building middle header 118 SA2301MU212 Manual isolation valve in Control Building south header 250 SA2301MU219 Manual isolation valve in Unit 3 Contafrunent supply header 275 SA2301MUO44 Manual isolation valve inside Containment in Unit 3 Containment supply header 321 SA2301MU217 Manual isolation valve in Radwaste Building north header 326 SA2301MU216 Manual isolation valve in Radwaste Building south header

r.

ITEM Al (Continued)

"Fbrthermo e, the Piping and Instrumentation Drawings failed to implement the locked open requirements for the following valves:

VALVE DRAWING NGiBER DRK41NG NLMBER REQUIRED FOSITION SA2301MUO41 40184 OPEN SA2301MU202 40184 OPEN SA2301MUO44 40189S03 & 40189 OPEN "This is a Severity Imvel IV Violation (Supplement 1) applicable to thits 2 and 3."

RESPONSE

With respect to Item A1.1.(a) above, Southern California Edison (SCE)

, believes that the procedures were adequate in that sufficient details

, existed such that a qualified individual.would be able to perform the required function without direct supervision. However, action to be taken with respect to these procedures will include additional details, as described below, and our ongoing procedure review and revision program will include additional details in other procedures, as deemed necessary. The bases for this conclusion are set forth as follows for procedure S023-2-4, Revision 6:

1. The procedure has been used successfully a number of times previously with only normal supervision. No switch misalignments have been identified and only normal inquiry by less experienced j personnel concerning component location has occurred.

2. The examples cited concerning Checkoff List 2 relate to items in the

Auxiliary Feedwater (AFW) Building. The check list is logically arranged to promote efficient use by listing items in the following order: (1) Control Building (9 foot elevation) - Items 1-3 of check list; (2) Control Building (50 foot elevation) - Items 4-19; and (3) AFW Building - Items 20-27. The items in the AFW Building were not specifically labeled and locations within the building were given for only three of the nine switches. However, a qualified operator with normal supervision has successfully completed the list on several occasions because the lineup is simple and straightforward. There are only six electrical distribution panels in the AEW Building - one 480VAC MCC, one lighting panel, three DC distribution panels and the turbine governor panel. All switches in the AFW Building portion of the check list are inside these latter

'four panels. ' These switches consititute all the switches within these four panels. The required position of all switches in the AFW Building with the exception of Item 27_ is "CIDSED." Item 27 is required _to be in " NORMAL." That switch and position were clearly ,

labeled. <

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ITEM A1 (Continued)

A qualified operator who was uncertain of the location of any of the itens in the AFW Building portion of the checkoff list could consult the Electrical Schedule for the elenentary diagram for the valve of

, interest and quickly determine the electrical panel in which it is

' contained. % is method of referencira is an expected level of knowledge for a qualified operator. Control Room personnel could also be requested to perform the effort and relay the information to the operator completing the check list. Again, this is a normal level of supervison and directioa of operators by Control Room personnel.

For Itens 20 and 23 of the check list, the "DC Feeder" breakers, the identity of these breakers was considered adequate. H e breakers i are located in MS4705 and MS4706. Bere are only three switches (CB1, CB2 and CB3) located in each of the panels and the arrangenent

. of one of the switches interposed between the DC power bus and the other two switches makes it clear which breaker feeds power to the other two and all three are required to be closed. his position is clearly engraved in the breaker casing. Similarly, the DC disconnect switches are both located in MS4716 and are the only switches in that panel. %ey are " knife" switches making differentiation between closed and disconnect position obvious. We ninth and final switch in the AFW Building portion of the check list is the A rbine Control Panel (L-298) test switch. It is.the only switch within that cabinet and was clearly labeled. %e check list did, however, contain a typographical error in that valve HV4715 was listed twice vice listing the HV4730 control switch in MS4705.

3. Finally, improper alignment of the "DC Feeder" breakers would result-

- in loss of all valve position indication lights on the main control board for the two valves involved in each panel (MS4705 or MS4706). '

Improper alignment of either valve's DC supply breaker in MS4705 or MS4706 would result in loss of valve position indication for the valve associated with that particular breaker (HV4705, HV4706, HV4715 or HV4730). Similarly, the incorrect positioning of the "DC Disconnect" switch to HV4716 would result in a loss of its position indication on the main control board. Misalignment of these switches would then be apparent in the Control Room, since control boards are monitored continously during the shift and are specifically " walked down" as a part of shift turnover.

l l- Corrective Steps Which Have Been Taken and the Results Achieved With respect to Iten A1.l(a), the typographical error in the check list (HV4715 twice vice listing HV4730) has been corrected and the checkoff list

! has been expanded to indicate the switch location and functions and to l couple the switch letter designations in MS4705 and MS4706 to the checkoff list CB1, CB2 and CB3 nomenclature. All switches in MS4705, MS4706 and i MS4716 have been identified with engraved valve designations and names. We I believe these changes improve the procedure. Hisactivitywascompleted/

on May 26, 1983.

-*e y*ey y -e >r~yw,+ .e.9 -

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-mq. g --e w *m ,e , y-,-p y---.w- -,p-+y., w,eq , p.--yg . pp = m w w - 4 p gmw.--ym ~-p--,y-.a,.e

ITEM Al (Continued)

With respect to Itan A1.l(b), Operating Instruction S023-7-1, Revision 7, was modified by Tenporary Gange Notice (TCN) 3 on April 18, 1983, to reflect the correct position of the nine valves identified. P&ID 40184S03 (Valves SA2301MJ041 and SA2301MU202) and P&ID's 40189S03 and 40189 (Valve SA2301MUO44), were revised on June 23, 1933, to reflect the locked open requirenent of the referenced valves. P&ID 40184 (Valves SA2301MUO41 and SA2301NU202), was revised on June 29, 1983, to reflect the locked open requirenent of the referenced valves.

Corrective Steps Which Will Be Taken To Avoid Further Items of Noncompliance To assure that the valve and system lineup procedures, filed in the Control Rom, adequately reflect installed plant conditions, correct position requirements, and provide adequate definition of cmponent location and labels, an engineering consultant is in the process of validating the adequacy of operating instruction check list empleteness and accuracy as measured against the P&ID. This task will be cmpleted by October 31, 1983.

Date When Full Compliance Will Be Achieved Full compliance was achieved on June 29, 1983, with revision of P&ID 40184 to reflect the locked open requirements of valves SA2301MUO41 and SA2301MU202.

ITEM A2 Appendix A to Mr Bishop's letter states:

"10 CFR 50, Appendix B, Criterion V, states that ' Activities affecting c uality shall be prescribed by doctanented instructions, procedures or c rawings of a type appropriate to the ciretanstances and shall be accmplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative acceptance criteria for determining that important activities if have been satisfactorily ac m plished.'

" Chapter 5-A of Southern California Edison Topical Report, SCE-1-A, implenenting the above requirenent, states, in paragraph 10.0, that 'Each procedure shall be sufficiently detailed for a qualified individual to perform the required function without direct supervision, but need not provide a complete description of the system or plant process. Procedures shall include, as appropriate, the following elements: . . . (9) Geckoff lists. Complex procedures shall have checkoff lists. These lists may be included as part of the procedure or may be appended to the procedure.'

" Technical Specification paragraph 6.8.1 states that ' Written procedures shall be established, implanented and maintained covering...

a. The applicable procedures recournended in Appendix 'A' of Regulatory Guide 1.33, Revision 2, February 1978, ...

.f. Fire Protection Program Implementation.'

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ITEM A2 (Continued)

" Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, paragraph 3, states, in part, that '... Instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems:

...e. Component Cooling Water System ...l. Auxiliary Feedwater System.'

"2. Contrary to the above requirements, it was identified that the licensee did not accmplish activities affecting quality, as described below, in accordance with procedure requirements.

"(a) Approximately twenty drain and vent caps were not installed on the Unit 2 Component Cooling Water System contrary to the requirements of Procedure S023-2-17, Revision 2, m eckoff List 1 (Component Cooling Water System Initial Valve Lineup) c mpleted on April 15, 1982. The two operators performing the valve lineup identified that several of the caps were not installed, however, neither the operators nor the Senior Reactor Operator, approving the c m pleted procedure on April 16, 1982, took any action to have the caps installed as required or to revise the procedure to correctly reflect the as-found condition.

"(b) Approximately thirty (30) procedural Unit 3 system lineup steps of Procedure 5023-2-17, Revision 3, m eckoff List 1, were checked (initialized) by only one operator instead of two operators and approximately thirty-five (35) other steps were not empleted by any operators on November 23 and 24, 1982. E is is contrary to the requirements of Procedure S023-2-17, Revision 3, m eckoff List 1. As of April 22, 1983, the cmpleted procedure had not l yet been reviewed by the Operations supervisor. The failure to properly execute dual verification requirements is an apparent

! repeat violation (see Notice of Violation dated March 24, 1983).

"This improperly executed Checkoff List 1 was used as the basis for Unit 3 entry into Operating Mode 4 on January 5, February 26, and i March 4,1983 pursuant to operating Instruction S023-5-1.3,

! Revision 6 (Plant Startup from Gold Shutdown to Hot Standby),

step 6.15.2 and Pre-Heatup Checkoff List, Section 1, step 2.2.6.

'%is is a Severity Level IV Violation (Supplement 1) applicable to l

Units 2 and 3."

ITEM A2 (Continued) ,

RESPONSE

Corrective Steps Which Have Been Taken And The Results Achieved Operators and operations supervisors have been given written directions via Special Orders 83-27,' issued April 27, 1983, and 83-30, issued May 23, 1983, as to the discharging of their responsibilities, with respect to the equal requirement for vent / drain caps or flanges to be installed as well as the valve itself being properly positioned when conducting valve lineups. S023-2-17 m eckoff List 1 has been validated and performed again. This action was completed on June 6, 1983, for Unit 2 and June 3, 1983, for Unit 3.

meckoff List 1 of S023-2-17 dated November 23, 1982, was an incmplete doceent which was inadvertently placed in the systen alignment file for Unit 3.

Component cooling water was aligned for acceptance testing using the P&ID's without use of Checkoff List 1 prior to establishing equipment control over the systen at system turnover. Equipment control was established on October 2, 1982, and the system remained in service through the mode changes occurring January 5, February 26 and March 4, 1983. meckoff List 1 is intended to be used to re-establish equipment control after major outage work. As equipment control had been established on component cooling water prior to system turnover and fuel load, and was maintained since that time, no official use of Checkoff List 1 had been completed on the system until June 3,1983. Operations supervisors erroneously referenced the incomplete document in S023-5-1.3 as it

, was the only version in the system alignment file. Special Order 83-030 provides specific direction to the operations supervisor with respect to incomplete checkoff lists.

Corrective Steps Which Will Be Taken To Avoid Further Items Of Noncompliance To assure that operators properly implement the requirements of valve and system lineup procedures and promptly effect corrective actions to resolve procedure discrepancies observed during the conduct of valve and system lineups, modifications to Procedure S023-0-15, " Administrative Control of Valve Operation," are being developed and Special Orders83-027 and 83-030 have been issued to provide' cmprehensive guidance for all acceptable methods of determining valve position, conducting second verifications of valve position, and condition and status of locking devices. Training for all operators will be conducted as part of the pre-shift briefing process as soon as the procedure modifications are complete. This will be completed by July 15, 1983.

Additionally, to assure that complete alignments are promptly and correctly confirmed for all systens required by Attachment 3, " Systems Alignment File" of Procedure S023-0-28, " Operating Records," the checkoff lists for all fifty-five listed operations instructions will be validated and corrected as necessary and then reperformed completely by a Special Operations Task Force under the direction of an experienced shift supervisor. Although only eleven of the

]

fifty-five instructions concern safety related systems, all cifty-five will be

l I

J 9-4 ITEM A2 (Continued)

' completed under the guidance of Special Orders 83-27 and 83-30. As of June 29,

'1983, all Unit 3 System Alignment File instructions have been c m pleted. All -

but five of the Unit 2 instructions have been cmpleted, the remaining five instructions will be completed prior to mde 2 entry.

Date When Full Compliance Will Be Achieved j

Full compliance will be achieved prior to Unit 2 entering Mode 2 with the completion of the five renaining Unit 2 instructions.

, ITEM B I

Appendix A to Mr. Bishop's letter states:

"Un it 2 Operating License No. NPF-10, paragraph 2.C(14) states, in part:

! "a. SCE shall maintain in effect and fully implement all provisions of the approved Fire Protection Plan as amended through Amendment 10 and the IRC staff's Fire Protection Review described in the SER and Supplements 4 and 5 to the SER.'

"The San Onofre Nuclear Generating Station Fire Hazard Analysis, which is i

the approved Fire Protection Plan, states, on page III-36 of Table III-1, (Comparison of San Onofre Units 2 and 3 with Requirements of Appendix A of the NRC Branch Technical Paper 9.5-1) that the licensee c m plies with the following:

'All valves in the fire water systems should be electrically l

supervised. The electrical supervision signal should indicate in the control rom and other appropriate comand locations in the plant.

When electrical supervision of fire protection valves is not practicable, an adequate management supervision program should be provided. Such a program should include locking valves open with strict key control; tamper proof seals; and periodic, visual check of all valves.'

( "The licensee provided the following comnitment of compliance with the above requirenent with the statement, on the same page, that 'All valves in the fire water system are electrically supervised with the exception of the hose valves which are normally closed and the post indicator valves (PIV) i and header isolation valves for Seismic Category I standpipes in the radwaste and control buildings that are normally locked open. The hose valves are not electrically supervised since their opening will result in the starting of the fire peps due to system pressure drop and will also provide an indication in the control room. The electrical supervision signal provides an indication in the control room and that s al is retransmitted to the computer room (digital events recorder) d r-e v y ye = m-- -e ,m,--- ,w e- e -~--ee--,c--, c- e- - ,- ---* ++,-.,-+--e - - - - , --+s- ----w --r+--, v-- +---+.--w eer-- u.e-r.,--= . - - . - . - w

m . _ _ _ . - _.

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ITEM B (Continued)

" Contrary to the above requirements, on April 14, 1983, while Unit 2 was in Mode 5, valves SA230lMUO41 (inside Unit 2 Containment), SA2301MU202, and

'SA2301MJ213 (both inside the Unit 2 Penetration Building) were found to be open, but not locked open, and did not have electrical supervision as

' stated above. D ese three valves are in series and the closure of any one of these valves would -isolate all fire protection water to the Unit 2 containment. Bis portion of the Fire Protection Water.Systen was required 4

to be operable during this period by Technical Specification 3.7.8.3.

! "his is a Severity Level IV Violation (Supplement 1) applicable to Unit 2.

RESPONSE

f Corrective Steps Which Have Been Taken And %e Results Achieved On April 15, 1983, valves SA230lMUO41, SA230lMU202 and SA2301MU213 on the Fire Suppression Water System on Unit 2 were locked open. Procedure S023-3-3.36, i

" Fire Suppression System Monthly Tests," was revised on April 15, 1983, to reflect the requirenent to verify on a monthly basis that these three valves are locked open. On April 18, 1983, the procedure was revised again to include '

i additional valves required to be locked open.

A physical walkdown was conducted to confirm proper installation of all Fire Suppression valves as shown on the P&ID's. %ere were no other discrepancies regarding valves required to be electrically supervised or locked open identified as a result of these walkdowns. %e discrepancies corrected by the Apcil 15 and 18, 1983, revisions have been reflected on the P&ID's.

L l Corrective Steps Which Will Be Taken To Avoid Further Items Of Noncampliance i

No other corrective action is required in this matter beyond that discussed under Items Al and B, above.

Date When M 1 Compliance Will Be Achieved

, Full compliance was achieved on April 15, 1983, when valves SA230lMUO41, SA230lNU202 and SA2301MU213 were locked open.

l ITEM C Appendix A to Mr. Bishop's letter states:

"10 CFR 50, Appendix B, Criterion 17 (Quality Assurance Records) states

that ' Sufficient records shall be maintained to furnish evidence of activities affecting quality. % e records shall include at least the following

Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses. %e

l ITEM C (Continued) records shall also include closely-related data such as qualifications of personnel, procedures, and equipment. Inspection _and test records shall, as a minimun, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in

connection with any deficiencies noted.. Records shall be identifiable and retrievable. Consistent with applicable regulatory requirements, the applicant shall establish requirements concernin duration, location,andassignedresponsibility.9recordretention,suchas

" Unit 2 Operating License No. NPF-10, paragraph 2C(19)e, states that:

' Procedures for Verifying Correct Performance of Operating Activities (I.C.6, SSERil)

' Prior to fuel loading, SCE shall implenent a system for verifying the correct performance of operating activities, and shall keep the system in effect thereafter.'

"The Safety Evaluation Report, Supplanent 1, (I.C.6), (SSER #1) states:

'For the return-to-service of equipment important to safety, a second.

qualified operator should verify proper systens alignment unless functional testing can be performed without compromising plant safety, and 'can prove that all equipment, valves, and switches involved in the

! activity are correctly aligned.'

" Procedure S023-0-17, Revision 8 (Iocking of Critical Valves and Breakers), states:

'6.2.1 Control of Locked valves and Breakers Following Maintenance Following major outages, major maintenance or major modification of components in safety-related systens; system valve and breaker alignments shall be completed to assure correct valve and breaker positions in the affected system. The procedure which aligns the valves and breakers to their correct position is referenced on Attachment 2 for valves and Attachment 4 for breakers.'

"The Fire Protection System Procedure, S023-0-17, Attachment 2, references Procedure S023-7-1. S023-7-1, Revision 7 (Fire Suppression Water System

Operation) states, in paragraph 6.1.5, that '01eckoff List 1 is used to align the service water makeup system to'the FWST and for initial system alignment.'

f

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F ,

ITEM C (Continued)

" Checkoff List 1 (Fire Water Systen Valve Position Verification),

step 106,-required the following:

STEP VALVE DESCRIFFION REQUIRED CHECKERS VERIFIED NO. NIMBER AND LDCATION STATUS INITIALS INITIALS 106 SA2301NU209 Iso. North CIDSED Header, North Stairs CAPPED I " Contrary to the above requirements, the record showed signatures indicating that an individual checked the position of valve SA2301MU209 on March 15, 1983, and found it to be closed and capped and that a second

individual also verified that the valve position was closed and capped.

On April 15, 1983, the licensee found that the position of the valve was

. locked open and that the valve, in fact, was required to be locked open.

Subsequently, the procedure was corrected and changed to provide that the

! valve shall be locked open. However, at that time, a record was not made to show that the valve was checked and verified to be locked open.

l '*Ihis is a Severity 14 vel V Violation (Supplement 1) applicable to e

Units 2 and 3."

RESPONSE

Corrective Steps Which Have Been Taken And 'Ihe Results Achieved Operating personnel involved in the improper and incomplete verification have received formal counseling. Verbatim procedural compliance has been emphasized durirg shift training sessions which included the Station Manager, Operations Manager, and Units 2 and 3 Operations Superintendent. A memorandun from the Station Manager to Station Management and Station Supervisors on the

( 'Neaning of Signatures / Initials on Station Procedures" dated May 28, 1983, was i ' issued to formalize what signatures and initials are specifically intended to i represent.

Procedure S023-7-1 was modified by TCN 3 on April 18, 1983, to reflect the

, locked open position of valve SA2301MU209.

l Corrective Steps Which Will Be Taken To Avoid Further Items Of Noncompliance

, To correct the deficiency involving the method by which improper or erroneous I l check list (s) are corrected, operations procedures will be modified by  !

August 30, 1983, to delineate the proper method to denote revisions to ,

procedures in progress or completed.

Date When Full Compliance Will Be Achieved I \

Full compliance will be achieved on August 30, 1983, with the issuance of the l modified operations procedures.

8655 1

1

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