ML20032E013
| ML20032E013 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/26/1981 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20032E009 | List: |
| References | |
| NUDOCS 8111190505 | |
| Download: ML20032E013 (4) | |
Text
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c Southern California Edison Company 9
P O. BOX 800 3
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-P" U.S. Nuclear Regulatory Commission Office Of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Attention:
Mr. R.H. Engelken, Director L"CKET No. 50-206 SAN ON0FRE - UNIT 1
Dear Sir:
Your letter of October 2.,1981, forwarded IE Inspection Report No. 50 -
206/81-31 and a Notice of Violation resulting from the the NRC resident inspection for the month of August,1981.
Enclosure (I) of this letter provides our response to the Notice of Violation contained in Appendix A of the subject report.
I trust the enclosure responds adequately to all aspect.; of the Violation.
If you have any questions or if we can provide additional information, please let me kn ow.
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L.T. Pa' pay
//
7 Vice President Southern California Edison Company M
, 1981.
Subscribed and sworn to before me this g4 day of
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AGNES CRABTREE 0
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1s, tos meassoouwrr Notg Public in and for the County q _ _ _ _ _ _M M Em_AEPM, o f to s An gel e s, Stat e o f Ca l i fo rn i a 1
Enclosure I cc:
L.F. Miller (NRC Site Inspector - San Onofre Jnit 1) 8111190505 811113' PDR ADOCK 05000206 G
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.r-ENCLOSURE I Response to the Item of Non-Compliance ident1fied in Appendix A to IE Inspection Report No. 50-206/81-31.
ITEM
" Technical Specification 6.8.1 requires that written; procedures be established, implemented and maintained that meet or exceed the requirements and recommendations of Section 5.1 and 5.3 of ANSI N 18.7-1976,
" Administrative Controls, for Nuclear Power Plants."
ANSI N 18.7-1976, Paragraph 5.3.2(5), " Precautions," states that precautions should be established to alert the individual performing the task to those
.important measures which should be used to protect equipment and personnel, including the public, or to avoid an emergency situation.
Station Procedure, S01-5-I [S01-5-1], " Radioactive Waste Gas System," is the licensee's procedure for releasing waste gas decay tanks. Precaution 4.4 of this procedure states that, " explosive mixtures of hydrogen and air in the Radwaste Gas System must be avoided at all times. The oxygen concentration must be maintained below 5 percent by volume."
Contra ry to this requirement, on July 17,1981, at 2125, the licensee released the contents of the North Waste Gas Decay Tank while it contained a canbustible mixture. As a result the contents of the tank ignited, resulting in an uncontrolled release of radioactivity to the environment.
This is a Severity Level 4 Violation (Supplement 1)."
RESPONSE
1.
CORRICTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED A crosstie between the Station Instrument Air System and the a.
Nitrogen System was installed in 1980 in response to TMI requirements. Leakage of check valves separating the systems resulted in the air (oxygen) infiltration to the Radwaste System '
and ultimately to the ignition of the contents of the North Waste Gas Decay Tank. The Instrument Air and the Station Nitrogen Systems have been physically separated. The work was accomplished under Design Change 81-30 which was appropriately reviewed and approved by the Onsite Review Committee.
b.
North Waste Gas Decay Tank (C-6) and interfacing systems have been inspected, repaired, and tested as s.J.fied by Engineering r
Repair Specification ERS-81-01, Rev. 04. This specification was based upon the provisions of ASME Boiler and Pressure Vessel Cude,Section VIII 1980 Edition. The Cryogenic Waste Gas Treatment System repairs are ongoing; the oxygen analyzer incorporated in the system for component protection has been repaired.
ENCLOSURE PAGE 2 RESPONSE (Continued):
Operating Instruction S01-5-2 " Cryogenic Waste Treatment System",
c.
has been revised to ensure the proper operation of the system.
Oxygen analyzer and to provide direction for the action to be taken in the event that oxygen concentration is out of.
speci fi cation.-
d.
Review of the circumstances surrounding the event showed that the initial analysis indicating high oxygen concentration in the Station Nitrogen System could have potentially been utilized to prevent the ignition. The event has been discussed with all Unit 1 Nuclear Chemistry Technicians and specific direction has been provided to strengthen and formalize canmunications with Operations via the use of a formal Chemistry Information Report, which. requires signature by both Operations and Chemistry personnel to signify transmittal and understanding of the information. This report is now required for all nonroutine testing not reported on standard log sheets and the results of routine testing requirirg corrective action.
2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMP LI ANCE.
Review of all circumstances surrounding the event showed that a.
Operations personnel did not react to the first indication of an off-normal condition; that is, the initial analysis which indicated unprecedented high oxygen levels in the nitrogen system. The operator training and requalification program will include discussion of the personal responsibility of individuals to forcefully and formally report of f-normal conditions, to act to operate the plant conservatively on the basis of displays and measurements available to them, and to keep management informed of off-normal circumstances as they are known.
b.
Operating Procedure S01-5-1, "Radwaste Gas System", will be modified to require sampling for oxygen concentration prior to a waste gas release and to specify appropriate corrective action.
The existing precaution concerning the necessity of maintaining the oxygen concentration less than 5% will be maintained.
Operating Procedure S01-5-2, " Cryogenic Waste Gas Treatment c.
System" will be modified to prohibit operation of the system with an indicated oxygen concentration greater thaa 3%, and to require use of the system oxygen analyzer whenever that system is in operation.
d.
The formal use of the Chemi stry Information Report and the instruction of chemistry technicians discussed in ld. will be extended to Units 2 and 3.
l
.I*
ENCLOSURE PAGE 3-RESPONSE '(Continued) :
e.
The oxygen recombiner and system filters in the Cryogenic Waste Gas Treatment System will be replaced prior to future system operation. Although the system is designated as non-safety -
related, required preventive maintenance will be included in the Station PM Program.
3.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED a.
Full compliance for Item 2 a. will be achieved by December 1,1981.
b.
Full compliance for Items 2 b. and 2c. will be achieved prior to November 1,1981.
Full conpliance for Item 2 d. will be achieved by January 1,1982.
c.
d.
Preventive maintenance schedules for the Cryogenic Waste Gas Treatment System will be incorporated in the Station PM Program by February 1,1982.
FB:2548
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