ML20041E235
| ML20041E235 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/04/1982 |
| From: | Pappy L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20041E223 | List: |
| References | |
| NUDOCS 8203100269 | |
| Download: ML20041E235 (4) | |
Text
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Southem Califomia Edison Company g6 A O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 T ELE PHo N E vsca poetssosser 88 3
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U. S. Nuclear Regulatory Commission E:;
Office of Inspection and Enforcement
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Region V ER ES 1450 Maria Lane, Suite 210 5!
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Walnut Creek, California 94596-5368 E
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Attention:
Mr. R. H. Engelken, Director Docket No. 50-206 San Onofre - Unit 1
Dear Sir:
Your letter of December 31, 1981 forwarded IE Inspection Report No.
50-206/81-40 and a Notice of Violation resulting from the November 2-24, 1981 routine surveillances of the Resident NRC Inspector for San Onofre Unit 1.
Per telecon between P. A. Croy and D. M. Sternberg on January 25, 1982, the response due date was extended to February 5, 1982.
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 aspects of the Violation.
If you have any questions or if we can provide additional information, please let me know.
9
,9 Subscribed on this
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day of cz4m%s,
, 1982.
By L. T. Papay' g7 Vice President Southern California Edison Company Subscribed and sworn to before me this E
dayof,7 m,, 1982.
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- Z Z Z Z-Z-Z -z-z-g g g g-: - z-g jt AGNES CRABTREE W W 'A wormmeoc caurom
, Notary Public in and for the County l
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.of Los ' Angeles, State of California My commmn br Aug 2uW ;
FB:0150u/ryh 8203100269 820301 Enclosure I PDR ADOCK 05000206 G
PDR cc:
L. F. Miller (NRC Site Inspector - San Onofre Unit 1)
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f ENCLOSURE I-Response to the Item of Non-Compliance identified in Appendix A to IE Inspection Report No. 50-206/81-40.
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 N18.7-1976, " Administrative Controls for Nuclear Power Plants".
a.
ANSI N18.7-1976, Paragraph 5.3.7, " Calibration and Test Procedures," states that " Procedures shall be provided for periodic calibration and testing of safety related instrumentation and control systems...
The procedures shall provide for... assuring measurement accuracy adequate to keep 4
safety related parameters within operational and safety limits."
Contrary to this requirement, procedures were not provided for periodic calibration of the hydraulic accumulator and manifold pressure indicators for the safety injection system hydraulic valve actuators since their installation in 1977.
This is a Severity Level V violation.
b.
ANSI N18.7-1976, Paragraph 5.3.4.4, " Process Monitoring Procedures" states that " Procedures for monitoring performance of plant systems shall be required to assure that... engineered safety features and emergency equipment are in a state of i
readiness to maintain the plant in a safe condition if needed.
The limits (maximum and minimum) for significant process parameters shall be identified."
Contrary to this requirement, on November 18, 1981, while in Mode 1, no procedures identified nitrogen 'ottle pressure as a significant process parameter (as a backup power source) for the air-operated auxiliary feedwater system valves, pressurizer power operated relief valves and relief valve block valves.
- Further, no procedures identified measures to ensure that the nitrogen bottle pressure was in an appropriate state of readiness for operation in Made 1.
This is a Severity level V Violation."
i i
RESPONSE
t 1.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED Part a.
Our review of this matter has led to the conclusion that transducer calibration as well as calibration of the local digital readout indicators should be formalized by procedure. A transducer verification test procedure (S01-II-1.91) has been issued; the instrumentation loop calibrations were complete on November 6, 1981.
During this effort, the calibration of the
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indicators was checked and found to be satisfactory.
l Part b.
Revisions to plant operating procedures and instructions were completed by January 22, 1982 to identify back-up nitrogen bottle pressure for the valves listed in the citation as a significant process parameter.
The following procedures identify the minimum conditions to assure operability and the associated surveillance requirements:
Station Procedures S01-3-5, " Plant Shutdown From Hot Standby to Cold Shutdown", and S01-12.3-6, " Safety Related Valve Alignment", correctly specify proper valve lineup for the backup nitrogen systems.
A new procedure, S01-12.2-12, " Backup Nitrogen Supply Capacity Check", has been issued and Operating Instruction 501-8-4, " Nitrogen Storage System", has been revised to specify pressure and surveillance requirements for the backup nitrogen systems.
2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMPLIANCE Part a.
The digital readout indicator calibration will be formalized in a I
procedure prior to the next major outage expected to start February 26, 1982. The loop calibration check requires the plant to be shutdown. A calibration check of this instrumentation will be conducted during the outage.
4 The Station procedure changes identified herein will prevent recurrence of this failure to properly maintain the instrumentation in a calibrated status.
Part b.
After installation of the backup nitrogen system, it was placed in operation without identification of all required procedure changes to provide for its proper operation.
. Part b.
(Continued)
The corrective steps which will be taken to avoid recurrence of this type of problem will include requiring that significant -
process parameters be identified during the design / construction phase of plant modifications.
Engineering Procedure 50123-V-4.15, " Structure and Equipment System Turnover", will be revised to require the identification of significant process parameters, valve lineups and limiting conditions for operation for systems as part of the process of turnover from engineering to operations.
Incorporation of the above information into operating procedures will be required prior to utilization of new or modified systems and components. Maintenance and/or surveillance requirements will be incorporated into appropriate procedures prior to the necessity to perform these activities.
3.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Part a.
Full compliance with the requirements of ANSI N18.7-1976, Paragraph 5.3.7, will be achieved by February 26, 1982, when revisions to the digital readout indicator calibration procedure are issued.
Part b.
Full compliance with the requirements of ANSI N18.7-1976, Paragraph 5.3.4.4, will be achieved on March 1, 1982, when Engineering Procedure S0123-V-4.15 has been revised and reissued.
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