ML20062J371
| ML20062J371 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/28/1993 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9311040157 | |
| Download: ML20062J371 (4) | |
Text
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,]sur amu Southem Califamia Edison Company 23 PARKER STREET tRVINE, CAL IFORNIA 92718 I
RICHARD M. ROSENBLUM tgggreeoems
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October 28, 1993 U.
S.
Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Docket No. 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating St.ition, Unit 3
References:
(1)
Letter from Mr.
L. Mille;r (USNRC) to Mr. Harold B. Ray (SCE), dated September 23, 1993 (2)
Letter from Mr.
R. M. Rosenblum (SCE) to Mr.
K.
E.
Perkins (USNRC), dated September 17, 1993 Reference (1) forwarded a Notice of Violation resulting from the NRC inspection conducted from August 16 - 20, 1993, at the San Onofre Nuclear Generating Station, Units 2 and 3.
This inspection was documented in NRC Inspection Report No. 50-362/
93-17, dated September 23, 1993.
Reference (2) provided additional information relating to the San Onofre Motor Operated Valve (MOV) program.
Your letter (Reference 1) requested that SCE address the programmatic implications of maintenance deficiencies observed following the March 1993 test failure of 3HV4705.
As discussed in Reference (2), SCE believes that the failure of 3HV-4705 was an isolated occurrence and does not imply programmatic maintenance deficiencies.
In accordance with 10 CFR 2.201, the enclosure to this letter provides the Southern California Edison (SCE) reply to the Notice of Violation.
As discussed with Mr.
L.
Miller on-September 28, 1993, due to the delay in receipt of the referenced letter from the NRC, the due date was extended until October 28, 1993.
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Document Control Desk October 28, 1993 s
If you have any questions regarding SCE's response to the Notice of. Violation or require additional information, please call me.
Sincerely,
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Enclosure i
cc:
B. H. Faulkenberry, Regional Administrator, NRC Region V.
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Fields, NRC Project Manager, San Onofre Units 2 &3 NRC Resident Inspector Office, San Onofre Units 1, 2 & 3-b i
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ENCLOSURE REPLY TO A NOTICE OF VIOLATION 1
The Enclosure to Mr. L. Miller's letter dated September 23, 1993, states in part:
r "During an.NRC inspection conducted during the period of August 16-20, 1993, one violation of NRC requirements was identified.
In accordance with the ' General Statement of Policy and Procedures for NRC Enforcement Actions', 10 CFR Part 2, Appendix C (1992), the violation is listed below:
"A.
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states,
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall. assure that the cause of the condition is identified and corrective action taken to preclude repetition.
The identification of the significant condition adverse to quality, the l
cause of the condition and the corrective actions taken shall be documented and reported to appropriate levels of j
management.
" Contrary to the above, indications of improper MOV l
operation during a March 23, 1992 diagnostic test of auxiliary feedwater control valve 3HV4705 were not documented nor promptly corrected.
Indications of improper MOV operation in the March 1992 diagnostic test signature showing cyclic thrust loads were not documented and corrected until August 5, 1993.
"This is a Severity Level IV violation (Supplement I)"
REASON FOR THE VIOLATION
~
As discussed in Mr. R. M. Rosenblum's letter (Reference 2)
-dated September 17, 1993, during the March 23, 1992 diagnostic j
test of valve 3HV4705 the MOV trace exhibited a unique j
signature which was consistent with traces obtained for o
3HV4705 since-1986, but exhibited characteristics not normally i
seen in similar valves.
j This unique trace was judged to be acceptable at the time i
since; the trace had exhibited the unusual attributes essentially unchanged since 1986, the valve had performed well upon demand over that period, and had passed it's GL 89-10 U
design basis test (max operating condition) in March 1992.
l
REPLY.TO NOTICE OF VIOLATION October 28, 1993 The trace was consistent, notwithstanding maintenance and re-furbishment of the valve during the period 1986 through 1992.
It was therefore Edison's judgement that the valve was fully functional and capable of performing its intended safety function during this period.
This judgement was reinforced when the unique trace was again obtained in May 1993 after the valve was comprehensively inspected and fully refurbished following an unrelated valve failure.
Edison agrees that the engineering judgement used to accept the March 1992 trace was not documented.
At the time, based on the experience gained in the evolutionatry MOV testing program, it was the judgement of engineering personnal that the trace was not sufficiently unusual such that, by itself, it constituted a nonconforming condition nor warranted a documented analysis.
This violation was therefore caused by the failure of Edison personnal to recognize that the unusual j
aspect of the trace, by itself, was a significant condition requiring documented evaluation irrespective of the otherwise l
acceptable operation of the component.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED 1
As discussed in Reference (2), in August 1993 during preparation for a test, the anti-rotation collar for 3HV4705 was broken and replaced.
Subsequent to the repair of the anti-rotation collar the MOV trace no longer exhibited the unique trace.
Currently, the valve meets Edison's GL 89-10 acceptance criteria, has passed it's required surveillances, and thus requires no further action.
As discussed in Reference (2), prior to this response Edison had issued procedure SO23-V-3.50, to formalize the process for evaluation of MOV traces. This procedure requires a documented evaluation of unusual traces such as the one which is the subject of this citation.
CORRECTIVE STEPS THAT WILL BE TAKEN A copy of this Notice of Violation response will be provided to personnel who perform MOV trace reviews in order to provide them guidance on the level at which unique trace analyses should be documented.
This action will be completed by November 15, 1993.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved in August 1993 when a new 3HV4705 trace was obtained which did not have the unique signature previously present.