ML20070U777
| ML20070U777 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/02/1991 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9104090311 | |
| Download: ML20070U777 (6) | |
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- h AROLD 6 RAY T$bEPHONE April 2, 1991 Director, Office of Enforcement U. S.-Nuclear Regulatory Commission-
-Attention:
Dccument Control Desk Washington, D.
C.
20555 1-
- Gentlemen:
Subject:
D o c k e t' N c ;.. 50-361 keply to a Notice of Violation R
San onofre Nuclear Generating Station, Unit 2 4
Reference:
Letter from Mr. S. A.-Richards (USNRC) to-Harold B.
Ray (SCE), dated March 4, 1991 The referenced letter forwarded a Notice of Violation resulting from the routine NRC inspection conducted from December 23, 1990.
through January. 30, 1991, at the San Onofre Nuclear Generating Station,: Units 1, 2,_and 3.
This inspection addressed a failure toLfollow-.a' surveillance procedure-when-Instrument and Control
- technicians did not reset one trip channel prior to testing a second_ trip channel.
Thi's resulted in the-inadvertent actuation of;the "ontainment Spray System, Safety ~ Injection System, and the Econtunment' Cooling System.
This inspection was documented in NRCEInspection Report Nos._ 50-206/90-43, 50-361/90-43 and 50-1-362/90-43.
In-accordance with 10 CFR 2.201, the enclosure:to this letter provides the Southern California Edison (SCE) reply-to the Notice ofLViolation.
If-you havenany questions regarding'SCE's response to the Notice
- of Violation or_ require additional information, please call me.
Sincerely, f VU J
Enclosure cc:
'J. B.' Martin, Itegional Administrator, HRC Region V C. W.
Caldwell, WRC Senior Resident Inspector, San Onofre Units 1, 2 and 3 l
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ENCLOSURE Reply to a Notice of Violation The enclosure to Mr. Richards' letter dated March 4, 1991, states in part:
"Section 6.8.1.c of the San Onofre Unit 2 Technical Specifications requires the licensee to inplement written procedures for the accomplishment of surveillance and test activities for safety related equipnent.
" Procedure SO23-II-1.1.5, Revision 1,
' S u r'.?ailla nce Requirement, Reactor Plird Protection Systee. Logic Matrix Functional Test (31 Day iterval),' Section 6.4.9, specified the following steps to icset trir path 1 of the Containment Spray Actuation System (LiAS):
8.5 Depress the Reset pushbutton for CSAS on the Actuation Reset Panel Bay A.
'.6 Verify the following:
' 6.1 The CSAS Trip Path 1 Indicators on the Local Status Panel and Remote Control Module A are illuminated.
'.6.2 The CSAS Acuuntion Relay Indicating Lights (1,3)A and (1,3)B are illuminated on the Local Status Panel.
'.7 At the Actuation Roset Panel Bay A, Rotate the LOCK / UNLOCK key switch to the number 2 (sic) position.'
" Contrary to the above, on November 20, 1990, instrument and control technicians conducting this surveillance procedure L
did not accomplish the specified actions to reset Trip Path 1 before testing trip path 2, resulting in an inadvertent I
actuation of containment spray.
l "This item is a Severity Level IV violation (Supplement I)."
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' REPLY TO NOTICE OF VIOLATION h 'il 2, 1991
RESPONSE
1.
R9. Mons for thq. y,Mp%im Failure tolo11ew Proegditrfa On November 20, 1990, a lead technician and throo other technicians were conducting a 31 day logie matrix functional zurveillanco test.
The load technician located near che PPS panels directed the activities of the other technicians via toicphone headsets:
one of the throo other technicians was positionef at the PPS pan 21s and performed manipulations of the panf1s' controls; the second technician was positioned at the ;' nit 2 control room panol 2CPJ A and veriflod the occurrence of and reset control roo. u nunciations; and the third technician obtained voltage ag ar. -tments from the ESFAS paneln 2LO34 and 2LO35, assistc. tho technician at the PPS panels, and performed the documented second person verification when required by the test proceduro.
While directing the test by reading the surveillanco proceduro steps to the other techniciarm, the load technician inadvertently skipped two pages.
The omitted pages ir.cluded the section for rosetting the first trip channel.
In addition, the technician responsible for performing second person verification, only ensured verification steps called out by the lead technician were performed.
This was consistent with tha verification process required by the Maintenance Administrative Procedure SO123-I-1.7.
Consequently, the technician did not votify if the lead technician called out all verification stops listed in the proceduro.
Thorofore, ho did not notice the omission of the verification steps which would havc cnsured the first trip channel was reset.
A cor.*ributing factor to the omission was the technicians setting a goal to complete the testing prior to attending scheduled training that afternoon.
This self-imposed goal was bas 9d on_their desire to complete the surveillanco instead of turning the work over to the incoming shift.
t As a result of the omission, the instructions for rosetting the first trip channel were not performed prior to setting the trip selector switch for the next trip channel to the trip position.
This satisfied the 2 out of 4 trip logic and initiated the containment Spray System (CSS), Safety i
Injection System (SIS), and containment cooling System (CCS) at 0946 on November 20, 1990.
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' REPLY TO NOTICE OT V.'OLATION April 2, 1991 2.
Corrective steps that have be3n taken and_th, results A9.hiDY_9Jb.
Procedurdi Como11ance The I&C organization developed and implemented more detailed guidelinen governing the planning and execution of surveillance testing of Plant protection System (PPS),
o Engineered Safety Feature Actuation System (ESFAS), and other critical plant components.
These guidelines are discussed with the technicians prior to starting work (e.g.
i tailboards on MATRIX, PPS CHANNEL, and SAFETY CHANNEL surveillance testing).
These guidelines enhance the existing surveillance testing methodology by formalizing:
- 1) the roles and respons.bilities of the technicians involved in the testing, 2) communications between those involved in the testing, and 3) the requirement for technicians to-monitor and control their pace during testing.
I&C personnel 4nvolved in the event received appropriate disciplinary action for-failing to fully adhere to
- procedural requirements. while performing surveillance activities.
In accordance with Maintenance Incident Investigation Report,-MIIR-90-035, this= event was reviewed with all Unit 2 and 3 1&c personnel stressing the importance of procedural compliance and attention to detaji while performing surveillance activities.
Evaluation of Work Verification Process-Maintenance Division Management conducted an evaluation of the work verification process and determined the process needed to be enhanced.
As a result, the Maintenance administrative procedure " MAINTENANCE ORDER PREPARATION, USE AND SCHEDULING," SO123-I-1.7, was revised on March 14, 1991, to add requirements for an. Independent critical Component-Checker.
This Independent Critical' Component checker is not allowed
- to have any direct responsibility for the performance of the action _being checked.
Specifically, when incorrect
- performance of a maintenance activity has the potential to cause'an immediate plant transient or actuation of an.
' engineered safety feature system, an independent check of the procedure steps performed will be made prior to continuing the maintenance activity.
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' REPLY TO NOTICE OF VIOLATION April 2, 1991 3.
ggrrocti.y3_stens that _ vill be tAken to avoid further violations 2 Procedure Revisions The five procedures affecting PPS CHANNEL and MATRIX testing, SO23-II-1.1.1 through SO23-II-1.1.5, will be revised by June 30, 1991, to include
- 1) the detailed I&C guidelines mentioned above in item 2, Procedural comp)iance, and 2) specific sign-offs for the Independent critical Component Checker.
Sign-offs already exist in the procedures for the " verified by" initialn of a verification checker who is not required I
to be independent of the work activity.
This verification checker will continue to be utilized and is now called a Critical Comlonent checker.
Similar revisions will be completed by September 30, 1991, for the Unit 1 procedure, S01-11-1.1.
1 The " SONGS MAINTENANCE PROCEDURE WRITERS GUIDE," MPG-001, and "I&C/ET PROCEDURES GROUP PROCEDURE AUTHOR'S GUIDE," PAG-001, will be revised by April 30, 1991, to include instructions for establishing independent verification
. criteria in maintenance procedures during procedure preparation, revisions,-and Annual / Biennial procedure reviews.
The revision of MPG-001 AND PAG-001 will ensure that when applicable Maintenance procedures are updated during the annual / biennial review process or procedure revisions,. the Independent critical Component Checker requirements are included.
Reauired Readina By April 3, 1991, Unit 1 I&C personnel will complete a i
required reading assignment of MIIR-90-035 which documents the event.
Caution Statement The San Gnofre Maintenance Management system (SOMMS) will be revised by-August 31, 1991, to include a caution statement at the beginning of the Work Plan in Maintenance Ordern,MO) and Construction Work Orders (CWO) for components which can initiate a plant transient or activato an engineered safety feature system (critical components).
The statement will remind the MO/CWO Planner and Foreman that a Critical Component Checker may be required for the work activity.
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e RE,'LY TO liOTICE OF VIOLATIoli April 2, 1991 4.
Date when full compliance will be achieved.
Full compliance with the procedure was achieved on November 21, 1990, when the surveillance test of the Redet:r Diant Protection System was successfully completed.
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