ML20057G107
| ML20057G107 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/12/1993 |
| From: | Roseblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9310200181 | |
| Download: ML20057G107 (4) | |
Text
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October 12, 1993
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Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555 i
Gentlemen:
Subject:
Docket Nos. 50-361, and 50-362
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Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2, &3
Reference:
Letter from Mr. L. F. Miller (USNRC) to Mr.
f Harold B.
Ray (SCE), dated September 3,
- 1993, i
The referenced letter forwarded a Notice of Violation resulting from the NRC l
inspection conducted July 19 through July 23, 1993, at the San Onofre Nuclear l
Generating Station, Units 1, 2,
and 3.
This inspection was documented in NRC f
Inspection Report Nos. 50-206, 361, 362/93-13, dated September 3, 1993.
j In accordance with 10 CFR 2.201, the enclosure to this letter provides the j
Southern California Edison (SCE) reply to the Notice of Violation.
As discussed with Mr. Miller on September 10, 1993, duo to the delay in receipt of the referenced letter from the NRC, the due date for the response was extended t
until October 12, 1993.
If you have any questions regarding SCE's response to the Notice of Violation i
or require additional information, please call me.
Sincerely, J
J b /M /5-zz, A
r i
i Enclosure cc:
B.
H.
Faulkenberry, Regional Administrator, NRC Region V M.
B.
Fields, NRC Project Manager, San Onofre Units 2 and 3 NRC Resident Inspector Office, San Onofre Units 1, 2,
& 3 9310200181 931012 i
PDR ADOCK 05000361 y
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I ENCLOSURE MEPLY TO A NOTICE OF VIOLM. ION a
The Enclosure to Mr. Miller's letter dated September 3, 1993 states in part:
"During an NRC inspection conducted from July 19, through August 6, 1993, six examples of a violation of NRC requirements were identified.
In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' 10 CFR Part 2, Appendix C, the violation is identified below:
"A.
Technical Specification 6.8.1 states in part 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, including those for surveillance and test activities of safety related equipment.
" Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, recommends written procedures for procedure adherence and for surveillance tests.
"(1)
Engineering procedure SO23-V-3.5.4, Rev.
3, Temporary Change Notices (TCN) 3-15, " Inservice Testing Of Check Valves (Quarterly Froquency), Attachment 8, Section 6.0, Note 4, required that an NCR be initiated and an engineering operability evaluation be performed for test results outside the specified acceptance range when this range has exceeded. The acceptance range for the flow rate for the seal water flow for Salt Water Cooling System (SWCS) 4 Pump P110, as measured by Flow Indicator 2FISL6385, was required by Section 6.2.1 of SO23-V-3.5.4, Attachment 8, to be 2 to 7 GPM for the testing of associated check valves.
"(2)
Engineering Procedure SO23-V-3.5.4, Rev. 3, TCN 3-16 and 23, Attacheent 8, Sections 6.2.8, 6.3.8, and 6.4.8 provided instructions for the testing of Service Water System Check Valves S21413MUO48, S21413MUO49, and S21413MUO50.
Sections 6.2.8, 6.3.8 and 6.4.8 required that seal water flow to SWCS Pumps P113, P307, and P114, respectively, be verified to be a minimum of 2 GPM to verify that the check valves being tested were not leaking excessively, and that the verification be performed by circling one of the words ' Satisfactory' or ' Unsatisfactory.'
" Contrary to the above,
"(1)
During testing of associated check valves, a flow rate of 11 GPM, in excess of the limits specified, was recorded for Flow Indicator 2FISL6385 on November 23, 1992, but no NCR was initiated and no engineering operability evaluation was performed for the noted condition.
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1 ENCLOSURE
"(2)
Records for surveillance testing performed on the dates listed below, of saltwater Cooling System check valves listed below, did not indicate verification by circling ' Satisfactory' or
' Unsatisfactory',
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S21413MUO49, December 10, 1992 e
S21413MUO50, December 15, 1992 S21413MUO49, December 16, 1992 I
S21413MUO48, May 12, 1993 S21413MUO49, May 26, 1993 "These examples are considered a severity Level V violation (supplement I)."
REPLY TO THE VIOLATION i
5 1.
REASON FOR THE VIOLATION j
The reason for the violation was personnel error.
The engineers performing the testing failed to implement the procedural requirements of the Inservice Testing (IST) procedure with a strict attention to detail.
2.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED The personnel involved have been counselled, reinforcing l
management's expectations with regard to attention to detail and i
compliance with procedures.
Procedure SO23-V-3.5.4 was revised on December 7, 1992, to delete the acceptance range of 2 to 7 GPM from step 6.2.1 and replace it with instructions to only record the flow rate observed.
l SCE performed a review of 100 valve IST surveillances and 65 pump IST surveillances performed over the last two years:
a)
The review identified two additional occurrences where test data exceeded specified acceptance limits and an NCR was not initiated.
l Both tests involved conditions similar to the example identified by the NRC, where a flow entry was outside the indicated range.
SCE determined that the acceptance criteria was too restrictive and the procedure was revised in October 1992 to include appropriate acceptance criteria, prior to the August 1993 NRC Inspection; and i
b)
The review revealed 10 occurrences where the words
" Satisfactory" or " Unsatisfactory" were not circled as required. 'All were associated with the SWCS attachment to SO23-V-3.5.4.
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4 ENCLOSURE i
I These incomplete valve IST surveillance records were corrected on october 7, 1993, and resubmitted to CDM for record keeping.
3.
CORRECTIVE STEPS THAT WILL BE TAKEN SO23-V-3.5.4 will be reviewed to determine if additional changes are needed to clarify the intent of the procedure and revised as appropriate.
This review and revision will be completed by December 4, 1993.
This NOV and response will be distributed to all Station Technical engineers and Supervisors as required reading. This will be completed by November 4, 1993.
4.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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Full compliance was achieved on October 7, 1993, when the IST test i
records were corrected.
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