ML20086S215
| ML20086S215 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/20/1991 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9201030075 | |
| Download: ML20086S215 (5) | |
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Southom Califomla Edison Company 83 Pae. HEP %fMitt IRviNE. C A Lif L % 1 99716
.............+.m g9 U. S. Nuclear Regulatory Commission Attention:
Document control Desk Washington, D. C.
20555 Gentlement
Subject:
Docket No. 50-362 Reply to a Hotico of Violation San Onofro Nuclear Generating Station, Unit 3 Rotorenco Lotter from Mr.
D. F. Kirsch (USNRC) to Harold D. Ray (SCE), dated. November 26, 1991 The referenced lotter forwarded a Notico of Violation resulting from the announced routino NRC fire protection inspection conducted from October 7, 1991 to October 11 1991, at the San Onofro Nuclear Generating Station, Units 1, 2, and 3.
This inspection was documented in NRC Inspection Report Hos. 50-206/91-32, 50-361/91-32, and 50-362/91-32.
In accordance with 10 CFR 2.201, the onclosure to thit letter provides the Southern California Edison (SCE) reply to the Notico of Violation.
If you have any questions regarding SCE's response to the Notico of Violation or require additional information, plonco call me.
Sincoroly, Y
/
Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region.V C. W. Caldwell, NRC Senior Resident Inspector, San Onofre Units-1, 2 and 3 300GG3
[)[6)3 no1020 ova m 220 _
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e fdN ENCLOSURE l
Rgolv to a Notice of Violation The enclosure to Mr. Kirsch' letter dated November-26,-1991, states in part "Section 6.8.1 of the Technical Specifications for San onofra Unit 3,-requires that written Nuclear Generation Station,inplemented, and maintained covering procedures be established,.
the activities referenced in Appendix
'A' of Regulatory Guide' t
1.33.
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" Regulatory Guide 1.33, Revision 2, February 1978, Paragraph j
1.C., recommends ' Administrative Procedures for Equipment Control,' and paragraph 3, recommends ' Procedures for Startup, operation, and Shutdown of Safety-Related.PWR Systems.'
" Regulatory Guide 1.33, Revision 2,_ February 1978, is implemented j
hy General Fire Protection Procedure SO23-XV-4.'67, entitled
' Seismic. Tractor, Pump, and-Tanker Inspcotion.'
The procedure specifies that 1% inch shackles be used for anchor restraint-numbers 10: through 17.
The-procedure also requires that i
equipment.not be stored within 15 feet of.the seismic fire i
tanker.
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" Contrary to the above, on October 8,fl991t-
?
1)
The seismic tie down hardware was of improper configuration l
in that two anchor restraints had 1 inch: shackles instead of the required 1\\ inch-shackles.-
1
- 2)
A large equipment skid was" located within'approximately 10:
j feet'of tho' seismic tanker, t
"This is a LSeverity Level ~ V : violation (Supplement I), applicable i
to Unit 3."
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e REPLY TO A NOTICE OF VIObATION December 20, 1991 Brannnan DAq}iground Each solamic tanker is rostrained from movement during a design basis carthquako (DBE) by 8 rostraints.
Each restraint consists of a turnbuckle with the lower and fastened to the ground anchor plato by a 1-3/8 inch bolt and nut.
The upper and of tuo turnbucklo is connected to a 1-3/8 inch link which in turn is connected to a 1-1/2 inch shackle.
A bolt with a nut and cotter pin is used to faston the shackle to the seismic tanker.
Thoro are three seismic tankers.
Two poismic tankors each wore noted with one rostraint turnbuckle fastened to the ground anchor plato using a 1 inch bolt (roforrod to in the NOV as "1 inch shacklos").
The remaining 7 rostraints Woro fastened to the ground anchor platos with 1-3/8 inch bolts.
1.
Rc.amons fo_r the-yiolation.
EtiR119..AtD_tIAiAt_HRIdMAtt IDAd211uato Procedtiral controls Proceduro SO23-XV-4.67, " Seismic Tractor, Pump, and Tanker Inspection," is used to control both the configuration of the seismic tank ? rostraints as well as inspections of the tankers.
A ruview of the proceduro datormined that it did not provido adequato acceptanco critoria for onsoring that correct seismic restraint hardware in used when activities affecting the soismic tankers require the removal and romssembly of the tankers' seismic rostraints.
Egismic ExclusipfLigne Lack of Warnina li19ns and Zone Markinos A hydro rig (" largo equipment skid") was parked less than 15 foot from the seismic tanker due to the absence of warning signs and the lack of noismic zona markings on the pavement around the seismic tanker.
REPLY TO A NOTICE OF VIOLATION ~ December 20, 1991 2.
.Catrective stenGL that have been taken and the resulta achieved.
Riijmic Rattraint HarJht.att Evaluation of Undernized Bolts Calculation number DO-1120 Revision 2 was issued on December 2, 1991 to address the effect of the 1 inch bolts on the restraint of the two seismic tankers.
The calculation verified that 7 of B restraints fastened to ground anchor plates with 1-3/8 inch bolts was sufficient to rostrain a seismic tanker during a design basis earthquake (DDE).
Correction of Restraint Confinurationg i
The 1 inch bolts in the restraints for the two seismic tankers were replaced on December 13, 1991 with.'.-3/8 inch bolts.
All of the restraint hardware for the three seismic tankers were also inspected and eny discrepancies were corrected as necessary.
Procedure Revisions Procedure SO23-XV-4.67 was revised to more clearly specify the configuration of the tankers' restraint hardware.
The procedure now specifies a 1-3/8 inch bolt is required to fasten the turnbuckle to the ground anchor plate.
In addition, the revised procedure includes the size and material specifications for all of the restraint hardware and a schematic to aid in the removal and reassembly of the seismic restraint hardware.
R.eismic Exclusion Zone Removal of Hydro Rio The hydrn rig was moved out of the 15 foot seismic exclusion zone on October 8, 1991, the same day it was discovered.
Revised Procedunga Procedure SO23-XV-4.67, was revised on October 25, 1991.
Procedure SO123-XV-4.13, " Weekly Inspection for the Control of Combustibles and Transient Fire Loads," was also revised on October 25, 1991.
The revisions to the procedures added criteria that ensures the seismic exclusion zone is kept free of objects and equipment.
The revisions also require that weekly inspections of seismic tankers-include a documented verification of compliance with the I
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v 7:""
REPLY TO A NOTICE OF VIOLATION -42 December 20, 1991 criteria.
The revision to SO23-XV-4.67 alno requires this verification be performed when the seismic tractor and any of the tankers are going to be stored, relocated, or removed from service.
3.
Corrective stens that will be taken to avoid furtner yiolations.
Egismic Restraint EarlWAtt No forther corrective actions are deemed necessary in order to avoid further violations.
311smic Exclusion _Eone Installation of Seismic Exclusion Zone Warnina Signs seismic exclusion zone warning signs are being installed on the seismic tankers and tractor.
This will be completed by-December 31, 1991.
The signs identify the exclusion zone distance of 15 feet for all objects.
The signs also identify that in addition to the 15 foot exclusion distance, all objects must be located at a distance greater than twice the object's height, hddition of Seismic Exclusion Zone Markinas Red-lines indicating the seismic exclusion zone are being painted on the alternate and permanent parking locations for the seismic tankers and tractors.- All of the
-parking locations will be completed within 45 days following the completion of the Unit 3 cycle 6. refueling outage.
These red lines will clearly-indicate the boundaries of the 15 foot seismic exclusion zone.
4.
Date when full comoliance will be achieved.
seismic Reg _traint Hardware Full compliance was achieved'on DecemberL13,~1991, when the 1 inch bolts in the restraints for'the two seismic' tankers were replaced with 1-3/8 inch bolts, seismic Exclusion Bone Full. compliance was achieved on october 8, 1991.when' the' hydro rig was removet from the vicinity of the seismic-
-tanker and no longer extended'into the:15 foot seismic.
exclusion zone.
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