ML20077L589
| ML20077L589 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/03/1995 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9501110419 | |
| Download: ML20077L589 (2) | |
Text
%
fdIF Southem Calihmia Edison Company U3 PARKER $TREET 1RVINE, CALirORNIA 92768 RICHARD M. ROS '.NSLUM T E LE p*CN E
- m. m.,
January 3, 1995 U.
S.
Nuclear Regulatory Commission Document Control Desk Washington, D.
C.
20555
Subject:
Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3
Reference:
Letter, A. Bill Beach (USNRC) to Mr. Harold B. Ray (SCE), dated December 12, 1994 The above referenced letter provided the results of the routine inspection conducted by Messrs. J. Sloan, J. Russell, and D.
Solorio from September 25 through November 5, 1994, at the San Onofre Nuclear Generati~ng Station, Units 2 and 3.
The enclosure to the referenced letter also transmitted a Notice of Violation.
This letter provides the Southern California Edison reply to the subject Notice of Violation.
j l
The enclosure to the reference letter states in part:
Technical Specification (TS) 6.2.2, " Unit Staff," Section (b) requires that when "the unit is in MODE 1,2,3, or 4, at least one licensed i
Senior Reactor Operator shall be in the control i
roou area identified as such on Table 6.2-1."
i Table 6.2-1 identifies the control room area as "shown in Figure 6.2-3."
Contrary to the above, on October 23, 1994, the l
inspector identified that for a brie period of time there was no Senior Reactor Operator in the control room area identified in TS 6.2.2, Figure 6.2-3.
At the time of the violation, the Operators had briefly stepped to the Work Authorization Control (WAC) desk.
The control room area (CRA) boundary near the WAC desk is not visually marked by floor tape or other
~ 9501110419 950103 PDR ADDCK 05000361 k.._ _
p
(
an[
demarcation devices.
Consequently, the Senior Reactor Operators (SRO), one of whom was a Control Room Supervisor (CRS), did not realize they had inadvertently stepped outside the existing Figure 6.2-3 defined CRA, and it was not immediately recognized that TS 6.2.2 had been violated.
Edison has concluded the absence of a visual demarcation of the CRA boundary was the primary reason for the Violation.
- Also, training on the CRA boundaries was minimal.
Specifically, the CRS qualification manual contains the requirement to " Discuss the s
limitations imposed on the Shift Superintendent and the CRS for movement about the station per SO123-0-30."
However, the procedure only referenced TS Figure 6.2-3 and did not specifically alert the Operators to the differences in the boundary defined by the Figure and areas remodeled since initia]
construction.
For corrective actions, Edison has enhanced Station Procedure SO123-0-30, " Shift Manning", to clarify and place limits more restrictive than the Technical Specifications on the allowable movement of the SROs in the CRA to assure they remain in audible t
range of the reactor operator at the controls.
These limits have been visually marked using signs placed on doors and tape / paint placed on floors.
In addition, all SROs have been coached regarding the CRA boundary and the actions required prior to leaving the CRA, and a pre-shift brief was conducted for each operating crew.
Full compliance was achieved on October 23, 1994, when the SRO with the control room command function returned to the TS Figure 6.2-3 defined CRA.
If you have any questions, please call me.
A
/
Sincerely,
/
$N )
cc:
L. J. Callan, Regional Administrator, NRC Region IV A. B. Beach, Director, Division of Reactor Projects, NRC Region IV K.
E. Perkins, Jr., Director, Walnut Creek Fiold Office, NRC Region IV J. A.
Sloan, NRC Senior Resident Inspector, San Onofre Units 2&3 M.
B. Fields, NRC Project Manager, San Onofre Units 2 and 3
..