ML20058K701

Notice of Violation from Insp on 930920-1022.Violation Noted:Activities Were Not Accomplished in Accordance W/ Procedures in That on 930708,signature for Procedures Were Entered by Supervisor Who Did Not Conduct Rotation

ML20058K701
Person / Time
Site:	San Onofre
Issue date:	11/24/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20058K699	List: IR 05000361/1993027 ML20058K693 ML20058K701
References
50-361-93-27, 50-362-93-27, NUDOCS 9312160011
Download: ML20058K701 (6)

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-1 NOTICE OF VIOLATION .

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Docket Nos. 50-361, 362

- Southern California Edison Company License Nos. HPF-10, NPF-15.

San Onofre Units 2 and 3 __ _

22, 1993, During an NRC inspection conducted from September 20 through October six violations of HRC requirements were identified. In accordance with the -

" General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C, the violations are listed below:

1. Violations Reouirina a Response. _

A.

Criterion V of 10 CFR Part 50, Appendix B, " Instructions, Procedures,'and Drawings," states in part that: " Activities affecting quality shall be prescribed by documented ... procedures, ... and shall b~e accomplished in accordance with those ... procedures,...."

Administrative procedure 50123-VI-0.9, Rev. 3, " Author's Guide for the Preparation of Orders, Procedures and Instrtttions," -Attachment 7, requires that the signature of an individual who performs a -

verification A a step designated as " PERFORMED BY" be "The -

signature / initials of one who personally conducted an operation identified by the document."

Maintenance Procedure S023-I-5.4, TCN 4-3, " Pumps - Saltwater Cooling Pump Disassembly, Inspection and Assembly," Step _6.7.19 required a rotation check of the uncoupled motor for rotation " or in the-proper direction. A space was provided to check " SAT "UNSAT

" and a " PERFORMED BY" verification signature space was .

provided. -

Contrary to the above, activities were not accomplished in accordance with procedures in that on July 8,1993, for Saltwater Cooling Pump S21413MP112, the " PERFORMED BY" ~ signa.ture for procedu 5023-I-5.4, Step 6.7.19 was entered by a machinist supervisor who Likewise,.on July 10, did not personal.ly conduct the rotation.

1993, for Saltwater Cooling Pump S31413MP307, the " PERFORMED BY" signature was entered by a different machinist supervisor Both machinist who did supervisors not personally conduct the rotation.

stated that their signatures were based on verbal information from an electrical supervisor. In both cases, the motors did not rotate in the direction specified by the procedure.

This is a Severity Level IV violation. (Supplement I).

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' 9312160011 931124 PDR ADOCK 05000361 O PDR 1

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B. CriterionVof15CFRPart50,.AppendixB," Instructions, Procedures,and - - -

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Drawings," states in part that: Activities affecting qual.ity shall be  !

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prescribed by documented instructions, procedures, ... and shall be  !

accomplished in accordance with these instruction, procedures ... ."

1. Maintenance Procedure 5023-I-5.4, TCN 4-3, " Pumps - Saltwater.

Cooling Pump Disassembly, Inspection and Assembly," Step 6.7.18 l stated: " Verify coupling adjustment nut has satisfactor: clearance to motor coupling to allow rotation without contact." The step l required a verification signature and a data entry to indicate that the clearance was satisfactory. or unsatisfactory. l

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i Contrary to the above, activities were not accomplished in- -

accordance with procedures in that on October.4,1993, adequate clearance was not verified and a verific~ation signature was not .l made. Clearance was, in fact, not present. Consequently a rotation l of the. motor for Saltwater Cooling Pump S.21413MP113 resulted in ~

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significani loads being applied to.the pump and motor.

Maintenance Procedure 502'3-1-5.31, " Pumps - Centrifugal Pump Packing

2. '

Adjustment and Replacement," Section 6.0 required adjustment of the diesel fuel oil transfer pump packing leakage to an acceptable ,

leakoff rate'of "no less than 40 - 60 drops per minute."

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Contrary to the above, activities were not accomplished in .'

accordance with procedures in that on July 2,1993, the final packing leakoff rates 'for Diesel Fuel Oil Transfer Pumps S22421MP094 and S22421MP095, respectively, were recorded in the procedure as "less than 30 drops per minute" and "3 drops per minute." These leakoff' rates were less than the minimum leakoff rate of 40 drops _

per minute.

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3. Licensee Procedure 503-XXVI-9.6818.0.1, Revision 0,_" Emergency-Diesels Starting Air System Compressors Performance Test," Sectiori 6.0, Step 6.3, required that the dew point indicator used in Steps 8.2.15, 8.5.15, 8.8.15 and 8.11.15 have. an accuracy of~ plus or minus one degree Fahrenheit. Steps 8.2.~15, 8.5.15, 8.8.15 and 8.11.15 also required that the M&TE [ Measuring and Test Equipment] used be recorded in Section 6.0.

Contrary to the abpve, acti/ities were not accomplished in accordance with procedures in that, between November 1991 and February 1992, the dew point indicator recorded in Section 6.0 as having been used for Steps 8.2.15, 8.5.15, 8.8.15, and 8.11.15 had an accuracy of plus or minus four degrees Celsius versus one degree Fahrenheit.

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Procedure 50123-111-6,5, " Oil Sampling and Analysis Program,"

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Revision-0, Ma~y 29, 1992, Attachment. 3, required -that a sample be drawn and analyzed annually _ from the Unit 2 Turbine Driven Auxiliary - ,

Feedwater Pump turbine. outboard bearing housing. Step 6.9.1 of the

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procedure stated: " Chemistry Engineering shall obtain the-trending

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and analyses data, enter it into the database, and provide reports-for review by the Cognizant Engineer." Step 7.2 stated, " Chemistry Engineering shall maintain a file copy of all oil sample (s) test results for 10 years."

Contrary to the above, activities were not. accomplished in accordance with procedures in that on October 20, 1993, the licensee did not maintain a file copy of oil sample test results for the Unit - -

2 Turbine Driven Auxiliary Feedwater Pump turbine outboard bearing.

Licensee personnel stated that the bearing ~ oil apparently had never been sampled or. analyzed. -

- 5. Procedure 5023-V-3.25, Temporary Change Notice (TCN) 0-2, " Component

- Cooling Water Heat Exchanger Testing," requires verification signatures for the following steps: -

• Step 6.2.9 states (for heat exchanger E001A;: " Verify removai of temporary -instrumentation and reinstallation of permanent plant gauges." .

• Step 6.3.9 states (for heat exchanger E002B): " Verify removal of temporary instrumentation and reinstallation of previously removed plant ir.;trumentation."

• Step 6.6 states: " Provide the completed procedure and trends of -

data to the Supervising Engineer for review and approval."

4 Contrary to the above, activities were not accomplished in accordance with procedures in that on January 26, 1992, the Unit 3, cycle 6 heat exchanger performance tests were completed for CCW heat exchangers E001A and E002B, and verification signatures for step 6.2.9, step 6.3.9', and step 6.6 were not accomplished. The completed test procedur.es were sent for archiving on July 8,1992.

This is a Severity Lcvel IV violation. (Supplement I).

C. Criterion V of 10 CFR Part 50, Appendix B, " Instructions, Procedures and Drawings," states, in part, " Instructions, procedures , or drawings shall include appropriate . .. acceptance criteria. . . ."

1. The vendor manual for the saltwater cooling pumps, Byron Jackson Pump Division Instruction Manual No. S7210 IF-7735 (S023-405-3A 0), Section 1.9 identified the proper direction of motor rotation as: " Rotation, viewed from top, is counter-clockwise."

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Maintenance procedure 5023-I-5.4, TCN 4-3, " Pumps - Saltwater  !

Cooling Pump Disassembly, Inspection and Assembly," Step 6.7.19

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- required an electrically powered rotation of the uncoupled motor The and a verification of the proper direction of motor rotation. ,

procE are acceptance criteria identified the proper directior of '

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motor rotation as: " clockwise looking from the top down on the  ;

motor." i Contrary to the above, appropriate acceptance criteria were not included in procedure S023-I-5.4, in that an incorrect direction of l motor rotation was specified. _

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2. Procedure S023-V-3.4.2, Temporary Change Notice (TCN) 7-8, .

" Component Cooling Water Inservice Pump Test,"

Attachment:

1, Step  ;

6.14, Note 1, directed the procedure user to Attachments 2-and 6 of Engineering Pro.c edure 5023-V-3.4, TCN 5-3, " Inservice Testing of

-Pumps Program" for the pump test design basis acceptance criteria.

Contrary to the above, the procedure did not include appropriate acceptance criteria in that the acceptance criteria referenced were incorrect. The correct acceptance criterii, were contained in i

- drawing 41066, Sheets I throug'h 6; Rev 0, dated March 9,1993, i

" Component Cooling Water Pump Tag No. 2P024 (2P025, 2P026, 3P024, i 3P025, 3P026) IST Curvas," which was not referenced.  !

This is a Severity Level IV violation. (Supplement I).  !

D. Criterion V of 10 CFR Part 50, Appendix B, " Instructions, Procedures, and Drawings," st-ates in part that: Activities affecting quality shall be r

prescribed by documented ... procedures, ... appropriate to the _!

l circumstances ...." _

i Procedure, 5023-V-3.5.4, TCN 3-25,' " Inservice Testing of Check Valves," Attachment 1, " Component Cooling Water System Check Valves," and procedure, S023-3-3.31.2, TCH 0-14, " Inservice Testing of Check Valves (Cold Shutdown Frequency)," Attachment 10,

" Component Cooling Water Check Valves," each require the back flow

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prevention function of the component cooling water pump discharge check valves be verified by measuring the differential pressure across the respective idle pumps of less than 5 psig and 10 psig-respectively.

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Contrary to the above, procedures were not appropriate to the

' - - circumstances in that the back flow prevention function 6f the j component cooling water pump discharge check valves could not be t verified by verifying that differential pressures across the pumps were 5 psig or 10 psig. A calculation, performed by the inspector, showed that a back flow of 4,500 gpa would be required to produce a  !

- 2 psi differential pressure across the idle pump. Higher back flows  ;

would be required to produce 5 psi and 10 psi. -!

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j This is a Severity Level IV violation. (Supplement I). ,

.i E. 10 CFR 50.59 states, in part, that: "The holder of a license. . . may...

'make changes in the facility as described in the safety analysis report,  :

... unless the prop 6 sed change... involves... an unreviewed safety .

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l question....The licensee shall maintain records of changes in the facility... to the extent that these changes constitute. changes in the facility as described in the safety analysis report... These records must i include a written safety evaluation which provides the bases for the -

determination that the change... c'oes not involve an unreviewed safety ~

question."

The San Onofre Final S'afety Analysis Report -(FSAR), Revision 9,  :

Figure 9.2-1, "P&I Diagram Component Cooling Water System Heat Exchangers System 1203, Drawing 401270S03 Revision 14," shows valve  !

W544, an automatic vent valve, for the salt water cooling portion of i the Component Cooling Water (CCW) heat exchanger, E002.  !

j Procedure S0123-0-23, " Control of System Alignments," TCN 0-15,  !

Attachment 2, provides a method for management approval of abnormal i

valve alignments. Step 2 of the attachment requires an ~

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determination be made as ta whether an unreviewed safety question  !

was created.

l Contrary to the abaa. on February 1,1993,' changes were made in the l facility as described in the safety analysis report in that ti.e  ;

automatic vent valve W544 on tinit 3, CCW heat exchanger E002 was i isolated, by closing its iWtion valve, and was therefore

'fety function. Previously, on

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prevented from performi.t it: an had been made, in accordance wi'.h 1 January 28,1993, a deti 6%t the abnormal valve alit W procedure, that an unreviewed safety ,

question had not been c _ued. However, a written safety evaluation  ;

which provided the bases for the determination that the change did not involve an unreviewed safety question was not performed. The l

?- l abnormal valve lineup cxisted until October 14, 1993, when air was j found in a portion of the heat exchanger,  ;

This is a Severity Level IV violation. (Supplement I) l

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. Violations Not Recuirina a Response. - _ _

' -10. CFR'50, Criterion III states, in part, that:~ " Measures shall be

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design basis... are correctly translated into specifications, drawings, l procedures and instructions." and "These measures shall include

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provisions to assure that appropriate quality si andards are specified and ,

included in design documents and that deviatier..

r rom such standards are controlled."  !

i Design Change Partage (DCP) 6473.00BJ, Revision 0, Section 9 -;

requires thc t itrogen Charging System for the actuation of the main steam atraspheric relief valves be in conformance with design

- _ require:oents of piping code ASME B31.1 (1973). , l

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ASME B31.1 (1973),' section 122.6.2(D) states that: " Discharge linest .

j from pressure relieving safety devices within .the scope of this Code -

shall be designed to facilitate drainage." and section 122.6.2(F) states that: " Drainage shall be provided to emove water collected ,

above the safety valve seat." _  ;

- Contrary to the above, a deviation from the standards of ASME B31.1

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was not controlled in that the discharge'line for the Unit 2 i l

nitrogen charging system relief valve PSV-8450 was not. designed to '

facilitate drainage and drainage was not provided to remove water collected above the safety valve seat. l This is a Severity level IV violation (Supplement I). l Your corrective actions were reviewed by the inspector and found to be satisfactory. Therefore, no response is required for this violation.  ;

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Pursuant to ~the provisions of 10 CFR -2.201, South ~ern California Edison Company 1 is hereby req ~uired to submit a written statement or explanation to the U.S. '

tiuclear Regulatory Commission, ATTt4: Document Control Desk, Washington, D.C.

20555 with a copy to the Regional Administrator, Region V, and a copy to the .

liRC Resident Inspector, San Onofre flu'elear Generating Station, within 30 days j of the date of the letter transmitting this tiotice of Violation (flotice). i This reply should be clearly marked as a " Reply to a flotice of Violation" and j should include for each violation: (1) the reason for the violation,'or, if contested, the basis for disputing the violation, (2) the corrective steps  !

that have been taken and the results achieved, (3) the corrective steps that  !

will be taken to avoid further violations, and (4) the date.when full compliance will be achieved. If an adequate reply is not received within the i

time specified in this tiotice, the Commission may issue an order or a demand i

for information as to why the license should not be modified, suspended, or .

revoked, or why other action as may be proper should not- be taken. Where good ,

cause is shown, consideration will be given to extending the response time.  ;

i Dated at Walnut Creek, California thise2[ day of.. v.cro.M 1993 .

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