ML20063G505
| ML20063G505 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/15/1982 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20063G500 | List: |
| References | |
| NUDOCS 8207290117 | |
| Download: ML20063G505 (5) | |
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L.T. PAPAY ggggpwogg wer passiness:
asa s72-8474 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368 Attention:
Mr. R. H. Engelken, Administrator
Dear Sir:
Subject:
Docket No. 50-361/50-362 NRC Inspection Report 50-361/82-20 and 50-362/82-10 San Onofre Nuclear Generating Station, Units 2 and 3 Mr. Sternberg's letter cf June 15, 1982, Issued Inspection Report 50-361/82-20, 50-362/82-10 and forwarded a Notice of Violation resulting from the April 10 to May 24,1982 inspection of SONGS Units 2 and 3 by Messrs A. E.
Chaffee, G. Fiorelli and G. Johnston of your office.
Enclosure (1) 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 of if we can provide additional information, please let me know.
Sincerely, Enclosure cc:
A. E. Chaffee (NRC Resident Inspector, San Onofre Unit 2) 8207290117 820726 PDR ADOCK 05000361 G
F ENCLOSURE 1 Response to the Items of Non Compliance identified in Appendix A to NRC Inspection Report 50-361/82-20, 50-362/82-10.
Item A.
The Appendix to Mr. Sternberg's letter of June 15, 1982 states:
" Technical Specification 6.9.1.10 states:
"' Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the safety valves, shall be submitted on a monthly basis to the Director, Of fice of Management and Program Analysis, U.
S. Nuclear Regulatory Commission, Washington, DC 20555, with a copy to the Regional Office of Inspection and Enforcement, no later than the 15th of each month following the calendar month covered by the report. '
" Contrary to the above, on April 19, 1982 the inspector was informed by the licensee that the required report for the month of March,1982 was not submitted by April 15, 1982 as required but would be submitted shortly. Because of previous difficulties experienced by the licensee in this regard, the need for timely submittal, or the option of making a timely request for an extension of the submittal date for good cause, was discussed with the licensee's representatives by the inspector.
Despite these earlier discussion, however, on this occasion no timely request for an extension of the submittal date was made.
"This is a Severity Level V violation (Supplement 1)."
Reponse 1.
Corrective Steps Which Have Been Taken and Results Achieved Administrative procedures are being revised to more specifically identify responsibilities for production and transmittal of these reports.
In addition, reports required by the Technical Specifications or NRC requirement are now being uniquely identified by cover sheets that identify the required submittal date so such submittals are not unduly delayed in review or approval cycles.
The Monthly Operating Report for the month of March,1982 was submitted 4 days late on April 19, 1982. April and May Monthly Operating Reports were provided no later than the 15th of each month following the calendar month covered by the report, and the June report will be issued on or before July 15, 1982.
e.
Page 2 of 4 2.
Corrective Steps Which Will Be Taken To Avoid Further Items of Non-Compliance Station Actions required on a prescribed schedule are being included in a management tracking system now under development, and identified as the Nuclear Engineering and Operations Commitment Register (NE0CR). The NEOCR will contain the due dates and names of responsible personnel for all periodic reports due to NRC, as well as reportable occurrence follow-up reports and special reports required by Technical Specifications. Thi s Register will provide management with the visibility of report due dates necessary to assure compliance with reporting requirements. NE0CR is currently being initiated and is scheduled for full implementation no later than September 1,1982.
3.
Date When Full Compliance Was Achieved Full compliance was achieved on April 19, 1982 with the submittal of the Monthly Operating Report for the month of March, 1982.
Item B.
The Appendix to Mr. Sternberg's letter of June 15, 1982 states:
" Technical Specification 3.0.2 states in part:
"'Non-compliance with a specification shall exist when the requirements of the Limiting Condition for Operation and/or associated ACTION requirements are not met within the speci fied time intervals....... '
" Technical Specification 3.8.3.1 states in part:
"'The following electrical buses shall be energized in the specified manner:
'c.
120 volt A.C. Vital Bus #2Y01 energized from its associated inverter connected to D.C. Bus #2D1.
'd.
120 volt A.C. Vital Bus #2Y02 energized from it associated inverter connected to D.C. Bus #2D2.
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120 volt A.C. Vital Bus #2Y03 energized from its associated inverter connected to D.C. Bus #2D3.
'f.
120 volt A.C. Vital Bus #2Y04 energized from its associated inverter connected to D.C. Bus #2D4.
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' APPLICABILITY : MODES 1, 2, 3, and 4.
'b.
With one A.C. Vital Bus either not energized from its associated inverter, or with the inverter not connected to its associated D.C. Bus:
(1)reenergize the A.C. Vital Bus within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) reenergize the A.C. Vital Bus from its associated inverter connected to its associated D.C. Bus within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within ths next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.'
" Contrary to the above, on May 16, 1982 at approximately 6:00 p.m., while in Mode 4, two Vital Buses (2Y03 and 2YO4) were not energized from their associated inverters for a period of approximately 15 minutes for test purposes (alternate power sources were utilized).
Such a configuration, however, is not permitted by the Technical Specifications.
"This is a Severity Level IV violation (Supplement 1)."
Response
1.
Corrective Steps Which Have Been Taken and Results Achieved The two A.C. Vital Buses were returned to their normal inverter power supplies on May 16, 1982 within approximately 10 minutes of their being energized from alternate power supplies. Operations personnel, including the Shift Technical Advisors have been reinstructed in the correct interpretation of Technical Specification 3.0.3, which had been misunderstood leading to this item of non-compliance.
In addition, written memoranda are being issued by the Station Technical and Operations managers to appropriate personnel within their organizations describing the occurrence and providing guidance with respect to errors committed in the course of activities leading to the identified non-compliance.
A review of the nature of this item of non-compliance by Station Management led to the conclusion that a thorough, independent evaluation and review was warranted.
The results of this independent evaluation have been reviewed and conclusions and associated corrective action have been identified as presented in Section 2 below.
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Page 4 of 4 2.
Corrective Steps Which Will Be Taken To Avoid Further Items of Non-Compliance Conclusions and associated corrective action from review of the independent evaluation and review of this item of non-compliance are as follows:
Technical Specification 3.0.3 was erroneously interpreted as an Action statement that could be voluntarily entered whenever Action statements associated with a particular Limiting Condition for Operation do not permit specific plant conditions desirable for the purpose of performing a test, for example.
This mininterpretation suggest inadequate training of personnel in the Technical Specifications. Consequently, formal training will be provided to STA's, Watch Engineers and Station Compliance Engineers to more thoroughly familiarize these individuals with the content and proper interpretation of the Technical Specifications.
On shift personnel responsible for operation of the unit may have been unduly influenced by personnel seeking expeditious approval to perform troubleshooting and/or reports of telephonic approval by representatives of Station Management. Consequently, Station Orders and procedures will be reviewed and revised as necessary and supplemental instruction will be provided to appropriate personnel, emphasizing the key role and responsibility of the Watch Engineer in determining what operations can and will be carried out within the plant, and the care which must be exercised in presenting information in seeking approvals of offsite individuals, and the care with which such approval should be provided and documented.
3.
Date When Full Compliance Was Achieved Full compliance with Technical Specifications was achieved on May 16,1982 when two A.C. Vital Buses were returned to their normal inverter power supplies. Completion of all reinstruction and training will be realized by September 1,1982.
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