ML20076J226
| ML20076J226 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/16/1983 |
| From: | Fogarty D SOUTHERN CALIFORNIA EDISON CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20076J219 | List: |
| References | |
| NUDOCS 8306200381 | |
| Download: ML20076J226 (7) | |
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RO. BOX 800 2244 WALNUT GROVE AVENUE DAvlO J. FooARTY T E LE PHON E sascuteva weCE psf 3sDffet 313 572 2796 May 16, 1983 U.S. tiuclear Regulatory Comission Office of Inspection and Enforcement pegion V 1450 Maria Lane, suite 210 Walnut Creek, California 94596-5368 Attention:
Mr. J. B. Martin, Regional Administrator
Dear Sir:
Subject:
Docket tios. 50-361 and 50-362 IE Inspection Reports 50-361/83-13, and 50-362/83-12 Response to 110tice of Violation San Onofre teclear Generating. Station, Units 2 si 3 Mr. ':'. W. Bishop's letter of April 14, 1983, issued IE Inspection Reports 50-361/83-13,50-362/83-12 and forwarded a tbtice of Violation resulting from the mrch 12, through March 25, 1983 inspaction conducted by Messrs.
D. M. Sternberg, D. F. Kirsch, !!. L. Canter, A. E. Chaffee and L. F. Miller.
Purst. ant to 10 CFR 2.201, the enclosure, " Response to 110tice of Violation,"
provides the Southern California Edison Company response to the tbtice of Violation contained in Appendix A of Mr. Bishop's letter of April 14, 1983.
!!otwithstanding the fact that the surveillance testing of reactor trip breakers on mrch 25, 1982 and July 12,.1982, have been reported, SCE believes that characterization of this matter as an item of nonconpliance, as is represented by Item A of the tbtice of Violation, is not warranted. '1he significance of the results of the 1982 surveillance tests could not be,_
_recogni::ed as warranting reporting until the significance of such results was made clear by the failures and subsequent evaluation of failures of reactor trip breakers on March 1,1983, and March 8,1983.
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Mr. J. B. Martin May 16, 1983 he Technical Specification Section (6.9.1.12.1) cited in Part A of Appendix A to Mr. Bishop's April 14, 1983 letter is highly subjective. A review of the Work Orders and other related documentation associated with the events of March 25, 1982, and July 12, 1982, resulted in our concluding these events were routine adjustments of the UV coil voltage settings. Moreover, since proper operation of the UV coil is not required for the Reactor Trip Breaker to meet its design basis assumed in the accident analyses presented !n the Final Safety Analysis Report, UV coil problems observed on March 25, 1983 and July 12, 1983 did not constitute " Performance of...conponents that requires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analysis..."
I trust the enclosure responds adequately to all aspects of the violation.
If you have any questions or if we can provide additional information, please let me know.
Sincerely, Enclosure cc:
A. E. Chaffee (USNRC Resident Inspector, Units 2 and 3)
L. P. Miller (USNRC Resident Inspector, Unit 1)
R. Pate (USNRC Resident Inspector, Unis 2 and 3)
P. J. Stewart (USNRC Resident Inspector, Unita 2 and 3)
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l Contrary to the above requ...
these failures had been reported to u s
'Ihis is a Severity Invel IV violation (Supplement I)."
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ENCWSURE RESPONSE 'IO N0 RICE OF VIOLATION (10 CFR 2.201)
In accordance with 10 CFR 2.201, this enclosure provides the Southern California Edison Company's ("SCE") response to Notice of Violation contained in the enclosure to Mr. T. W. Bishop's letter of April 14, 1983.
Appendix A to Mr. Bishop's letter of April 14, 1983 states:
"A.
Technical Specification 6.9.1.11 states, in part, that 'The REPORTABLE OCCURRENCES of Specifications 6.9.1.12 and 6.9.1.13 below, including corrective actions and measures to prevent recurrence, shall be reported to the NRC...'
Technical Specification 6.9.1.12 lists the types of events which shall be reported by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Director of the Regional Office, or his designee, and confirmed by telegram, mailgram or facsimile no later that the first working day following the event, with a written followup report within 14 days.
'Itchnical Specificaton 6.9.1.12.1 describes a type of event which shall be reported pursuant to Technical Specification 6.9.1.12 and states as follows:
' Performance of structures, systems, or conponents that requires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analyses in the safety analysis report or Technical Specification bases; or discovery during unit life of conditions not specifically considered in the safety analyses report or Technical Specifications that require remedial action or corrective measures to prevent the existence or develognent of an unsafe condition.'
On March 25, 1982, surveillance testing of the reactor trip breakers identified that trip circuit breakers ('ICB) Nos. 4, 6 and 7 would not trip insnediately when the undervoltage trip device was deenergized. On July 12, 1982, surveillance testing of the reactor trip breakers identified that 'ICB Nos. 4 and 7 would not trip when the undervoltage trip device was deenergized.
Contrary to the above requirements, as of March 15, 1983, neither of these failures had been reported to the NRC.
'Ihis is a Severity Level IV violation (Supplement I)."
RESPONSE
- 1. CDRRECTIVE STEPS WIICH IIAVE BEEN TAKEN AND RESULTS AOIIEVED Inasmuch as reports, pursuant to Technical Specification 6.9.1.12.1, for the March 25, 1982 and July 12, 1982 surveillance testing were made prior to issuance of this Notice of Violation, no further corrective steps for the cited violation are required.
- 2. CORRECTIVE STEPS WIICII WILL BE TAKEN 'IO AVOID FUlmIER VIOLATIONS At the time of the March 25, 1982 and July 12, 1982 surveillance testing, procedural requirements were not in place to ensure that Nonconformance Reports (!CRS) generated as a result of test results were systematically evaluated for reportability. Although such procedural requirements were adopted in November, 1982 (and were subsequently strengthened by revision to Engineering Procedure SO123-V-5.1 on April 28, 1983), previously dispositioned NCRs were not re-evaluated for the purpose of determining reportability. liowever, these NCRs generated before Novenber,1982 have now been reviewed and reportability assessments made.
(Reference NRC Open Item 50-361/83-13-03). Also training of appropriate personnel in Technical Specification reporting criteria and NCR evaluations was conpleted on April 29, 1983 (Reference NRC Open Item 50-361/81-13-02)
- 3. DATE WIEN FULL COMPLIANCE WILL BE ACllIEVED Full compliance was achieved on April 12, 1983 when all reports concerning the subject failures were submitted to the NRC.
' Appendix A of Mr. Bishop's letter of April 14, 1983 states:
"B.10CFR 50.34, ' Contents of application; technical information,' requires that each licensee submit information which describes the managerial and administrative controls to be used to assure safe operation.
SCE-1-A, ' Quality Assurance Program', is thte licensee's topical report which describes these controls. Chapter 5-C, " Maintenance Program",
paragraph 3.0, states, in part:
'A preventative maintenance program shall be established and maintained which describes the frequency and type of maintenance to be performed. It shall include the considerations described in paragraph 2.0 above...
l Among the considerations listed in paragraph 2.0 are:
i
'h.
%e equipnent supplier's suggested maintenance schedules and requirements
'i.
% e maintenance history of the equipment.
Station Order SO123-M-5, Revision 2, ' General Maintenance Order', states, in paragraph 6.3.2, that:
'We scheduled preventive maintenance program shall consist of routine maintenance reconsnended by equipment vendors and experience with conparable equipment. W e program should reflect service conditions of the particular components, should be revised and updated as experience I
is gained with the equipment, and shall prescribe the frequency and type of maintenance to be performed.
Station Order SO123-M-4, Revision 0, ' Preventive Maintenance Program, paragraph 6.2.3, states that:
'W e program (s) shall be updated to conform to current industry standards, i.e. Bulletins, vendor technical information, IEEE Stds.,
t ANSI Stds., or other reference documents relative to the subject.
l Contrary to these requirements, on March 15, 1983, the licensee's preventive maintenance program did not fully inplement General Electric Service Alert Ietter No.175 (CPPD)9.3 in that the program only provided for inspection of the breakers each refueling. %e General Electric Service Alert Imtter requires that the frequency of inspection should be increased until it can be verified that the revitalization of lubrication is effective for the normal maintenance interval.
.o 2.
Furthermore, Station Maintenance Procedure MPES-008, ' Maintenance Procedure for Undervoltage Tripping Device of the Reactor Trip Switchgear",
did not check for excessive clearance between the undervoltage trip device armature and rivet as required by Paragraph 1 of the letter. W is General Electric Service Alert Letter was provided by IE Bulletin 79-09.
W is is a Severity Level IV violation (Supplement 1).
_ RESPONSE
- 1. CORRECTIVE STEPS WIICH HAVE BEEN TAKEN AND RESULTS ACHIEVED h e Station Maintenance procedure for preventive maintenance of the RTBs (SO23-I-4.66) has been completely rewritten. W e finalized version of the procedure represents the consensus input and agreement of the vendors (CE and GE), SCE Apparatus Department, and all pertinent Station departments. Specifically, the procedure calls for an initial periodicity of three (3) months for certain critical sections of the procedure (as recomended by GE). W e periodicity of other sections of the procedure are based on conservative recomendations by the vendor.
In addition, the procedure contains a section which specifies the process by which the condition of the RrBs (as determined by Preventative Maintenance (PM) results and surveillance results) will be assessed for purposes of determining proper PM frequency. Wis section also cites the Supervisor of Maintenance Engineering as responsible for making this assessment. Win assessment will primarily verify the effectiveness of the lubrication of the RTBs.
Based on this assessment, appropriate changes to PM frequency (shorter or longer) will be determined in accordance with pertinent vendor information.
MPES-008 has been cancelled and the the requirements of Paragragh 1 of I
the GE Service Alert Letter have been properly incorporated in SO23-I-4.66.
2.
CORRECTIVE STEPS MIICH WILL BE TAKEN 'IO AVOID FURTHER VIOLATION Corrective action to avoid further violation of the nature represented by this violation (failure to appropriately incorporate, in Station documents, information from various sources) was identified in the report entitled " Reactor Trip Breakers," forwarded by SCE's letter to the NRC dated April 15, 1983.
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- ' Ibis corrective action includes:
- 1. Continue the implementation of the comprehensive configuration control progran to manage all vendor-supplied information.
(Section IV.D.7.c and Section V.B.1)
- 2. Provide additional training in the use of existing procedures to control vendor-supplied information.
(Section IV.D.7.c)
- 3. Provide training which will review the need to identify all pertinent vendor-supplied information for work order planning when procedures are not available.
(Section V.B.2)
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DATE MIEN FULL COMPLIANCE WILL BE AOIIEVD Full compliance was achieved after issuance of the Procedure SO23-I-4.66 (Rev. 1) on May 3, 1983.
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