ML20149E393

Notice of Violation & Proposed Imposition of Civil Penalty. Violation Noted:While in Mode 1,AFW Flow Path Was Not Operable & Automatic Delivery of Auxiliary Feedwater Would Not Have Been Assured

ML20149E393
Person / Time
Site:	San Onofre
Issue date:	09/17/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20149E307	List: IR 05000206/1986007 ML20149E303 ML20149E393 ML20149E399
References
FOIA-97-177 EA-86-097, EA-86-97, NUDOCS 9707180183
Download: ML20149E393 (3)

Text

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[ NOTICE OF VIOLATION l

• AND l PROPOSED IMPOSITION OF-CIVIL PENALTIES  :

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Southern California Edison Company .

Docket No. 50-206 San Onofre Unit 1 . License No. DPR-13 4

EA 86-97

-As a result of the inspection conducted during the period of February 12 - April  ;

25, 1986, certain violations of.NRC requirements wera identified. In l

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accordance with the " General Statement.of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the Nuclear Regulatory i Commission proposes to impose civil penalties pursuant to section 234 of the Atomic faergy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-295' and ,

The particular violations and associated civil penalties are set

.10 CFR 2.205.

forth below-J t (A. Technical Specification 3.4.3. A requires both steam generator auxiliary  :

1 -feedwater pumps and associated flow paths be operable in Modes 1, 2, and 3. i Contrary to the above, on November 21,.1985 while in Mode 1, the auxiliary feedwater flow path was not operable and automatic delivery of auxiliary  !

l feedwater would not have been assured. Flow was diverted from the steam l generators to the east flash evaporator condenser after a manual reactor ,

scram because five feedwater check valves failed to seat. I This is a Severity Level II violation (Supplement I).

' (Civil Penalty - $80,000).

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, B. 10 CFR Part 50, Appendix B, Criterion XI, Test Control, as implemented by the Southern California Edison Company Topical Report SCE-1-A, Section 17.2.11, requires that testing required to demonstrate that sttuctures, systems, and components will perform satisfactorily'in service is identified and performed in accordance with written test procedures and that the test program shall include, as appropriate, preoperational and L operational tests.

, Contrary to the above, the test program in effect prior to November 21, 1985-for check valves in the feedwater system did not assure that the valves would perform satisfactorily whfle in service in that on November-21, 1985, five check valves (FWS-345, -346, -398, -438, and -439) did not i.

prevent backflow through the feedwater system.

1 This-is a Severity Level III violation (Supplement I). ,

(Civil Penalty - $50,000). ,. .

C..'10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, as implemented by SCE-1-A, Section 17.2.16, requires that measures be

. established to assure that conditions adverse to quality, such as failures,

-malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly-identified and corrected. In the case of _

significant conditions adverse to quality, the measures shall assure that 1 a

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- Notico of Violat' ion -.2-

the cause of the condition is determined and corrective action taken to

preclude repetition.

2 Contrary to the above, the licensee's program failed to assure that' adequate corrective actions were taken when'a noise was identified on June 24, 1985 in the "B" feedwater line near check valve FWS-346. The investigations and l subsequent. reviews by the Onsite Review Committee on July 18, 1935 and the

- Nuclear Safety Group on September 3, 1985 failed to identify the potential

- for, or the safety consequences of, check valve failures which could cause the draining of the feedwater lines or diversion of auxiliary feedwater ficw from the steam generators. Also, corrective actions to investigate the.

valve conditions, planned for outages in August and September 1985, were not, conducted.

This is a Severity Level III violation (Supplement I).

(Civil Penalty $50,000).

' Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby required to submit to the Director, Office of Inspection and i Enforcement,-U. S. Nuclear Regulatory Commission, Washington, D.C. 20555 with.a copy to the Regional Administrator, U. S. Nuclear Regulatory Commission, Region V, within'30 days.of the date of this Notice a written statement or 4 explanation, including for each alleged violation: (1) admission or denial of the allegeri violation, (2) the reasons for the violation if admitted, (3) the

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corrective steps that have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the If an adequate reply is n 3

date when full compliance will be achieved. received within the time specified in this e of Inspection and Enforcement, may issue an order to show cause why the license .

should not be modified, suspended, or revoked or why such other actiori as may '

be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Sectio *n 182 of the Act, 42-U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201,. Southern California Edison Company may pay the civil penalties by letter addressed to the Director, Office of Inspection and Enforcement, with a check, draft, or money order payable to the Treasurer of the United States in the amount of One Hundred Eighty Thousand Dollars ($180,000) or may protest ,

imposition of the civil penalties in whole or in part by a written answer addressed to the Director, Office of Inspection and Enforcement. Should L Southern California Edison Company fail to answer within the time specified, the Director 0ffice of Inspection and Enforcement, will issue an. order imposing the civil penalties in the amount proposed above. Should Southern California Edison Company elect to file an answer in accordance with 10 CFR ,

- 2.205~ protesting the civit penalties, such answer may: (1) deny the violations

. listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error-in this Notice, or (4) show other reasons why the *

penalties should.not'be imposed. In addition to protesting the civil penalties

- in whole or in part, such answer may request remission or mitigation of the penalties.

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[ Notice of Violation In requesting mitigation of the proposed penalties, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the

! statement or explanation in reply pursuant to 10' CFR 2.201 but may incorporate

parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. Southern California Edison Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.

Upon failure to pay any civil penalties due which has been subsequently determined in accordance with the applicable provitions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the pehalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to section 234c of the Act, 42 U.S.C. 2282.

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pf, J . . artin Regional Admini rator Dated at Walnut Creek, California thisfZf day of September 1986 r

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