ML20196D489

Notice of Violation from Insp on 870803-28.Violation Noted: Specified ESFAS Response Time of 10.9 Could Not Be Satisfied for 3HV-4048 & Action Not Initiated within 1 H to Place Unit in Mode in Which Spec Does Not Apply

ML20196D489
Person / Time
Site:	San Onofre
Issue date:	02/10/1988
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20196D451	List: ML20196D446 ML20196D489
References
50-362-87-25, NUDOCS 8802170154
Download: ML20196D489 (2)

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NOTICE OF VIOLATION Southern California Edison Company Docket No. 50-362 San Onofre Unit 3 License No. NPF-15 During an NRC inspection conducted on August 3 through August 28, 1987 a violation of.NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Fart 2, Appendix C (1987), the violation is listed below:

Section 3.3.2 of the San Onofre 3 Technical Specifications states that Engineered Safety Feature Actuation System (ESFAS) instrumentation channels shall be OPERABLE with RESPONSE TIMES as shown in Table 3.3-5.

Table 3.3-5 specifies that the "Steam Generator Pressure - Low" signal, which actuates main feedwater isolation valve (MFIV) 3HV-4048, shall have a response time of 10.9 seconds. Definition 1.12 of the Technical Specifications defines ENGINEERED SAFETY FEATURE RESPONSE TIME to be the time interval from when the monitored parameter exceeds its actuation setpoint until the valve travels to its required position. No ACTION statement is provided in Section 3.3.2 or Table 3.3-5 to prescribe remedial measures when the requirement cannot be satisfied.

Section 3.0.3 of the Technical Specifications states that "When a limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour, action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in: 1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."

Contrary to the above requirements, MFIV 3HV-4048 was made inoperable by 1 being physically blocked open on April 10, 1987 and again on April 24, 1987, for periods of approximately 8.5 and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, respectively. During these periods, the specified ESFAS response time of 10.9 seconds could not be satisfied for 3HV-4048, and action was not initiated within one hour to place the unit in a MODE in which the specification does not apply.

This is a Severity Level IV Violation (Supplement I) applicable to Unit 3.

Pursuant to the provisions of 10 CFR 2.201, Southern California Edison is hereby required to submit a written statement or explanation to the U. S.

Nuclear Regulatory Commission, ATTN: Document Control Desk Washington, DC 20555 with a copy to the Regional Administrator, Region V, anct a copy to the NRC Resident Inspector, San Onofre Nuclear Generating Station, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not 8802170154 880210 DR ADOCK050g32

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. received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown.

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• FOR THE NUCLEAR REGULATORY COMMISSION

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D. F. KWsch, Director Division of Reactor Safety & Projects Dated at Walnut Creek, California this 3 day of February 1988 e

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