ML20059K914
| ML20059K914 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/17/1994 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9402020352 | |
| Download: ML20059K914 (7) | |
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za PARxER s,REcr IRVINE. CALIFORNIA 927tO RICHARD M. ROSENBLUM T E LE PMONE
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January 17, 1994 i
U.
S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.
C.
20555
Subject:
Reply to a Notice of Violation
References:
A.
- Letter, C. A. VanDenburgh (NRC) to Mr. Harold B. Ray (SCE), dated December 17, 1993 B.
Letter, R. M. Rosenblum (SCE) to NRC, dated January 13, 1994 Reference A provided the results of the routine inspection conducted by Messrs. J. J. Russell et al, at San Onofre Nuclear t
Generating Station, Units 2 and 3, from October 7, 1993 through November 17, 1993.
The enclosure to the referenced letter also transmitted a Notice of Violation.
The purpose of this letter is to provide the Southern California Edison reply to the Notice of Violation.
Edison's review has concluded that the Commission did not obtain a full understanding of the facts and circumstances surrounding some of the examples cited in the Notice of Violation.
Due to the press of time, Edison was unable to provide fully those f acts and circumstances prior to the issuance of the citation. Edison's evaluation found that there is only_one example, rather than four examples, of a failure to follow procedures.
Edison has presented this additional information in our. response to the Notice of Violation.
We request that the NRC re-evaluate the citation and the severity level of the citation in light of this' additional information.
Although in this case there are mitigating facts and circumstances which materially affect the enforcement considerations, we wish to reemphasize Edison's commitment to'a high standard'of procedural compliance.
In Reference B, Edison acknowledged that although an improving trend in procedural compliance has been demonstrated over the past year, additional N.RR109 g
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monitoring and increased emphasis is warranted to meet our expectations. Edison is committed to taking prompt and effe'ctive corrective action to improve in this area..
If you have any questions, please call me.
Sincerely,
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Mr. K. E. Perkins, Jr., Acting Regional Administrator, NRC Region V J. Sloan, Senior Resident Inspector, San Onofre Units 1, 2 & 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 & 3 l
E ENCLOSURE 4
EEELY TO A NOTICE OF VIOLATION The Enclosure to Mr.
C. A. VanDenburgh's letter, dated December 17, 1994,' states in part:
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"During an NRC inspection conducted from October 7 through November 17, 1993, one violation of NRC requirement was identified.
In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR 2, Appendix C,.the violation is listed below:
" Criterion V of 10 CFR Part 50, Appendix B,
" Instructions, Procedures, and Drawings," states, in part, that; " Activities i
affecting quality shall be prescribed by documented instructions, i
i procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, j
procedures...
"1.
Procedure 50123-0-13, TCN 0-24, " Technical Specification Limiting Condition for Operability Action Requirement and i
Equipment Deficiency Mode Restraints {LCOAR/EDMRs},"
Step stated that, Tags are placed to identify the affected system or component...LCOAR/EDMR tags should be used for this purpose.
" Contrary to the above, activities were not accomplished in accordance with procedures when on November 16, 1993, an i
EDMR/LCOAR tag was found posted in the Unit 3 Control Room for Nuclear Indication Startup Channel "A"
indicating that' Startup Channel "A" was out-of-service, when,the Startup channel was in-service, and not affected.
"2.
Procedure SO123-I-1.7, TCN 4-12, " Maintenance Order Preparation, Use, and Performance," Step 6.15.1.2 states that, " Work packages, including maintenance orders and procedures, must be followed in procedural compliance The procedure allows steps to be performed out-of-sequence
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under certain conditions.
" Contrary to the above, as of November 16, 1993, Maintenance l
Order 93100709000, "High Pressure Safety Injection Flow i
Indication Indicates Flow With Shutdown Cooling In Service,"
was not followed when a step to remove a deficiency tag for Unit 3 HPSI Flow Indicator 3FIO3112 was performed out-of-sequence.
The maintenance order did not provide exceptions for performing the steps out-of-sequence, nor were the conditions met for performing the steps l
out-of-sequence.
"3.
Procedure SO23-I-3.1, TCN 1-23, " Minor Refueling Procedures," step 6.1.1.4.3, states that, " Lanyards need not i
be attached to wiping materials taken into the area as long as... the wipes are held or otherwise controlled.
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84 ENCLOSURE
" Contrary to the above, activities were not accomplished.in accordance with procedure SO23-I-3.1, TCN 6-23, as of October 20, 1993, when a material wipe was not held or i
otherwise controlled and fell into the Unit 3 refueling cavity.
"4.
Procedure SO123-I-1.8, TCN 2-12, " Foreign Material Control during Maintenance, Testing and Inspection," Attachment 2, i
step 2.2, states that, 'All loose objects-such as badges and dosimeters shall be securely fastened to the clothing.
" Contrary to the above, on November 5, 1993, a security L
badge and dosimeter was not securely fastened to an l
individual's clothing and was lost in the secondary side of Unit 3 steam generator E089.
"This is a Severity Level IV violation."
l Facts and Circumstances Item 1 On November 13, 1993, Edison was preparing for Mode 6 entry in accordance with Operations procedure SO23-5-1.8.
One of the requirements of SO23-5-1.8 is to review the LCOARs/EDMRs,.and ensure they are closed / converted as necessary.
On November 14, 1993 the Control Room Coordinator (CRC) was continuing this effort, and identified the S/U Channel 1 as an open'line item on EDMR 3-93-038.
On November 15, 1993, the CRC determined that the temporary power installation had been completed on November 10, 1993, and closed the EDMR line item, but did not remove the sticker from the indicator.
The failure to remove the sticker was an error of omission on the part of the CRC.
On November 16, 1993, the same CRC who closed the EDMR on the Start-up channel was questioned by the NRC as to why the EDMR sticker was still on the indicator.
After discussing the situation with the NRC, including the fact that the S/U channel was Operable and being supplied by temporary power, the CRC
-j removed the EDMR sticker.
l The CRC's performance did not fully meet Edison's expectations in this instance.
His error was in the conservative direction, as the EDMR/LCOAR logs and the system alignment records correctly reflected the status of the S/U channel.
The monitor was, in fact, fully operable; therefore, the safety significance of he l
omission was low.
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l ENCLOSURE Item 2 On November 16, 1993, it was_ observed that an equipment deficiency tag had been improperly removed from a component.
The commission apparently believed that the missing deficiency tag had been deliberately removed prior to completion of the work, contrary to station procedure SO123-I-1.7 " Maintenance Order l
Preparation, Use, and Performance," which-states that MO steps must be followed in sequence unless specific conditions were met.
b The craftsman who performed the work did, in fact, follow the procedure in that he followed the steps in the MO properly and in the proper sequence.
At the step to remove the. deficiency tag, he found no tag.
In accordance with the procedure, he documented in the MO, " deficiency tag not found."
Edison has not been able.
j to determine how or when the tag was lost or removed.
I Nevertheless, the craftsman followed his procedure and MO, in sequence, when he documented his actions.
In addition, the purpose of the deficiency tag is administrative in nature.
Specifically, these tags provide visual indication that a deficiency has been identified and is being tracked by the work process solely to minimize the initiation of additional MOs
.for the same deficiency.
It is Edison's position that the absence of his deficiency tag does not constitute a procedural violation in and of itself and has no safety significance.
Item 3 The note to procedure SO23-I-3.1, TCN 6-23, Step 6.1.1.4.4," Minor Refueling Procedures", states (in full):
" Lanyards need not be attached to wiping materials taken into the area as long as: (1) retrieval eauioment is i
'immediatelv' available should a wine fall in the nool, and (2) the wipes are held or otherwise controlled, i.e. bagged j
or lanyarded while in the area." (emphasis added).
I The note clarifies the intent of the procedure, which is that l
wiping material should be' held or otherwise controlled; but the-note also recognizes the possibility of dropping a wipe, which is why the retrieval equipment was made available.
This procedure is consistent with Industry practice.
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Retrieval equipment was immediately available in the area f
and when the wiping material was inadvertently dropped.
The retrieval equipment was used to divert the wipe from the Upper Guide Structure (UGS), which was still in the reactor vessel, to 4
the pool seal ring.
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I ENCLOSURE Use of the retrieval equipment prevented the wiping; material from falling into the reactor vessel.
With the wiping material diverted to an area where it was not'likely to move or fall into i
the reactor vessel, the decision was made by'the Refueling Supervisor to leave the material for later retrieval.
This is allowed-by the notes preceding step 6.1.3.2'of SO23-I-3.~1, " Minor Refueling Procedures".
Therefore, Edison believes there was no j
violation of the procedure.
The wiping material was permanently removed using the retrieval equipment at a later date.
It is not the purpose of the procedure to require that wipes be so rigorously controlled that the mere dropping of a wipe is a violation of regulatory requirements.
Rather, the purpose of the procedure is to provide a reasonable balance between the practical need to have and use wipes as contamination control media, and to reasonably avoid introduction of foreign material into the reactor vessel.
In summary, the activities on October 20, 1993, were conducted in-i full compliance with procedure SO23-I-3.1 as intended.
Item 4 On November 5, 1993, prior to entering the Steam Generator, an J
individual securely taped his dosimetry and site badge to his i
upper thigh in accordance with the applicable radiation exposure permit and SO123-I-1.18.
The individual checked that'the items were securely fastened.
j While the individual was maneuvering around inside the steam generator (a' limited space area), the dosimeter and site badge were jostled, became detached, and fell from his person.
In 1
accordance with the FME program, this was promptly identified by the HP engineer upon exiting the steam generator, and the item j
was identified and tracked until its removal.on November 19, 1993.
Edison believes that it is not credible to expect that items y
securely fastened to personnel (dosimetry, etc.) must be so rigorously controlled that merely having the item torn away or knocked from the body constitutes a violation of-regulatory requirements.
In summary, the items were securely fastened-to the HP engineer in full compliance with procedure SO123-I-1.18.
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1 ENCLOSURE
RESPONSE
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REASONS FOR THE' VIOLATION
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The' reason the EDMR/LCOAR tag (Item 1) was not removed from 4
the control board was an individual error.of ommision by the Control Room Coordinator who completed the paperwork but l
forgot to' remove the sticker.
As noted above, there is
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minimal safety significance to this. omission.
As discussed above, Edison believes Items 2, 3 and 4 were in accordance with procedures as written.
2.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS
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ACHIEVED For item 1, the EDMR tag was removed upon discovery and the importance of attention to detail was discussed with the
.l individual involved.
No corrective actions have been taken for items 2 through 4.
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CORRECTIVE STEPS THAT WILL BE TAKEN No additional corrective actions are planned.
4.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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Full compliance with procedure SO123-O-13 was achieved on November 16, 1993 when the EDMR tag was removed.
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