ML20085G364
| ML20085G364 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/13/1995 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9506200175 | |
| Download: ML20085G364 (5) | |
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Southem Calibmia Edson Company l
23 PARKER STREET
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. IRVINE, CALIFORNIA 92718 RICHARD M. ROSENSU;M TELEp*40NR.
June 13, 1995
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U. S. Nucle 3r Regulatory Commission 1
Document Control Desk l
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20555
Dear Sir:
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, Mr. A. Bill Beach (USNRC) to Mr. Harold B. Ray (Edison), dated May 3, 1995 The referenced letter provided the results of a routine resident inspection (50-361/95-02 and 50-362/95-02) by Messrs. J. Sloan, J. Russell, and D. Solorio for January 29 - March 11, 1995, at the San Onofre Nuclear Generating Station, Units 2/3.
The enclosure to tue reference transmitted a Notice of Violation.
The enclosure.to this letter provides Edison's reply to the subject Notice of l
Violation.
As discussed with Mr. Brad Olson, G C Region IV, on June 8, 1995, the NOV Response due date was extende,:t t o June 13, 1995, in order to provide a complete response.
If you have any further questions, please contact me.
Sincerely,
/"
jy s
i Enclosure c
cc:
L. J. Callan, Regional Administrator, NRC Region IV l
A. B. ' Beach, Director, Division of Reactor Projects, Region IV K. E.
Perkins,-Jr.,. Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, _ San Onofre Units 2 and 3 l
M. B. Fields, NRC Project Manager, San'Onofre Units ? and 3 1
9506200175 950613 PDR ADOCK 05000361 i
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p i ENCLOSURE Reply to a Notice of Violation 1.
Violation A Violation A involved operators rendering a feedwater. isolation j
valve inoperable when it was required to.be operable during the
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refueling outage shutdown.'
The violation occurred when plant 1 operators' soft seated.the main feedwater isolation valves (MFIV) -
in Mode 3.
The operators did not recognize (cognitive error) that soft seated MFIVs would be inoperable.
Edison has counseled the individuals involved to. ensure'thei'r p
full' understanding that soft-seating-these valves (i.e. MFIVs'and MFBVs)' renders them inoperable, and has revised'the procedure for MFIV operation to clearly state that soft seated. valves are inoperable.
Additionally, the other operators have been reminded of the MFIV operability requirements.
Full compliance was achieved on February 12, 1995,- when the Unit.
entered Mode 5 and the MFIVslwere no' longer required to be~
c operable.
'2.
Violation B Violation B involved operators who engaged in a potentially distracting activity.
The violation occurred as an NRC inspector
,l observed an onshift control room operator showing.another l
operator three 45-rpm phonograph records in'the-Unit-3 control room.
The operators knew of the procedural requirements prohibiting distracting non-work related activities in the control room.
They misjudged the. appropriateness of looking at the phonograph records for a few moments.
Edison expects an appropriate level of decorum in the control room at all times.
The control room operator who brought the records into the control room'was coached on this' error.
Operators have been assigned a priority reading assignment which reemphasizes. proper control room decorum.
The Shift Superintendents have discussed the control room-decorum incidents l
with their respective operating crews.
In. addition, Edison is placing more emphasis on control room formality, and will continue to monitor control room decorum to judge the effectiveness of our corrective actions.
Full compliance was achieved on February 27,-1995, when the phonograph records were put away.
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Violation C Violation C involved placing a spent fuel assembly into the wrong 4j:
location in the spent-fuel pool.
The violation occurred when' personnel failed to properly execute procedure SO23-X-7, " Nuclear i
Fuel Movement for Refueling Cycles," as a. result of inadequate; j
communications.
Information exchanges between the Spent'Fucl '
1 Handling Machine -(SFH) operator and the. Control Room Engineer i.
(CRE) were not clear or complete enough to effectively 1
communicate.the SFH machine bridge coordinates.
Edison expects j.
meticulous handling of fuel.assembliessin full compliance with-written, approved procedures.
In addition,Linitial on-shift communications were inadequate,<in that the shift superintendent and'other appropriate management were not promptly notified.
When management became aware of the
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1 event later that same shift, fuel. movements were stopped and the crew was assembled for a~ debrief.
i As_ corrective action, management has reemphasized the.following
.to all refueling crews:
the importance of safety,
- the expectations of management,
- the importance of complete,. clear, and concise communication, the importance of the_self-check. concept (STOP),
- the'importance of procedural ~ comp 14 ance, and
- the importance of the CRE repeating back'the complete coordinates.
Refueling training will be modified to emphasize the importance of complete.and formal communications.
In addition, the complete coordinates will be recorded on-the Fuel Movement Sequence Data Sheet.
Edison evaluated the safety significance of mispositioning a spent fuel assembly in the spent fuel-pool..The evaluation determined that at the Technical Specification 1 required minimum boron concentration of 1850 ppm, there w0suno potential for_a misplaced fuel assembly to-lead to a criticality accident.
The K-eff would have remained less than or ecual to 0.95, including all uncertainties.
Full compliance was achieved on February 25, 1995,.when the mispositioned fuel assembly was placed in the correct location.
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_. 4.
Violation D Violation D involved the failure to promptly document and correct a condition adverse to quality.
The violation occurred when Edison personnel failed to generate a nonconformance report (NCR) in a timely manner.
The NCR should have been written to document the operability basis for the Amerace relay auxiliary contacts and mounting configurations on July 13, 1993.
On May 28, 1993, Edison's Procurement Engineering (PE) department discovered an Amerace (the Agastat relay manufacturer)
Certificate of Compliance, for relays supplied directly to SONGS, did not encompass auxiliary contacts and relay orientation.
The same relays had been supplied to SONGS by various original equipment manufacturers as sub-components of equipment which had been seismically qualified as a whole such as switchgear and electrical control panels.
Because this model relay had been previously supplied as part of original, seismically-qualified equipment, Edison believed the relays would perform their design function, and the absence of Amerace seismic qualification of certain component aspects did not imply a functional inability to perform as required.
In order to make certain such was the case, Edison developed a program to confirm the seismic qualification of the replacement relays, and to determine if any replacement relays had been installed in the plant in safety-related applications.
In summary, the fact that the Amerace Certificate of Compliance did not encompass auxiliary contacts and relay orientation was initially considered to be an administrative documentation problem.
During execution of the program on July 13, 1993, Edison determined several replacement Agastat relays were being uti'.ized in plant safety-related applications.
In retrospect, Edisor should have written an NCR at that time to' document that replacement relays with incomplete seismic qualification documentation had been installed in the plant and to document our judgment that the replacement relays were capable of performing their safety function.
It is Edison's policy to initiate a station NCR to address operability and disposition actions promptly upon determining a nonconforming condition impacts components installed in plant applications, such as the qualification issue in this case.
In this instance, that was not done until a station NCR was issued in February 1994.
As corrective action, appropriate procedural revisions were made to provide a timely, formal mechanism for NEDO's involvement in such problem resolution.
In addition, on June 9, 1995, a second example of untimely NCR issuance was identified during an NRC i
inspection (Report No. 50-361 & 362/95-12).
As a result of the June-9 finding, Edison has expanded the proposed NEDO and PE training on these procedure changes and the requirements for timaly issuance of NCRs to include Station Technical,
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Maintenance, and Quality Control personnel.
Full compliance was achieved on February 1, 1994, when an NCR was issued to document the Agastat relay discrepancies.