ML20198S583
| ML20198S583 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/07/1997 |
| From: | Nunn D SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-361-97-19, 50-362-97-19, NUDOCS 9711140061 | |
| Download: ML20198S583 (9) | |
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A,, nummn gwmm c-sn, November 7,1997 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3
References:
(1)
Letter, Mr. Dennis F. Kirsch (USNRC) to Mr. Harold B. Ray (SCE),
dated October 10,1997 (2)
Letter, Mr. A. Bill Beach (USNRC) to Mr R. P. Barkhurst (Entergy Operations), dated April 3,1992 Reference 1 transmitted the results of NRC Inspection Report No. 50-361/97-19 and 50-362/97-19, conducted August 17 through September 27,1997, at Southern California Edison's (SCE), San Onofre Nuclear Generating Station, Units 2 and 3. The onclosure to Reference 1 also transmitted a Notice of Violation containing two violations (97019-03 and 05). These violations involved: (1) a violation for procurement and use of a faulty steam generator manway gasket, and (2) a violation for not having a seismic semi-tractor disabled with a locking device as required by procedure.
SCE requests NRC re-consideration of both violations, as follows:
With regard to Violation A (97019-03), SCE requests withdrawal of the violation / [
1.
involving the steam generator manway gasket based on:
A.
The steam generator gasket is nonsai'ety-related and not subject to 10 CFR 50, Appendix B requirements, J 201 B.
Tiie plant was not operated (i.e., never proceeded beyond Mode 3) wsh g
the improper gasket installed, and C.
The installatioi. of the improper gasket did not result in a steam generator failure to perform its safety-related function.
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1 Document Control Derk November 7,1997 Further, it should be noted a similar condition, i.e., inadequate procurement of steam generator primary manway gaskets, occurred at the Waterford Nuclear Power Piont, which was evaluated by the NRC and docketed in NRC inspection report 50-3ts?)92-03 (Reference 2). In that inctance, the report documerJed the fact the licensee did not consider their steam generator manway gaskets to be safety-related, and the NRC did not issue enforcement action. SCE believes issuance of the current violation constitutes inconsistent application of the enforcement policy as no violation of regulatory requirements occurred.
II.
With regard to Violation B (97019-05), for the seismic semi-tractor violation, SCE requests recharacterization of the violation. SCE believes the violation should have been charccterized as a " minor violation" in accordance with the NRC's Enforcement Policy. Enclosure 2 provides a discussion of the basis for this position.
Notwithstanding the above requests, Enclosure 1 provides SCE's response to the violations (97019-03 and 05).
If you have any further questions, please contact me.
Sincerely,
/
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An
Enclosures:
As stated cc:
E. W. Merschoff, Regional Administrator, NRC Region IV K. E. Perkins, Director, Walnut Creek Field Office, NRC Region IV D. F. Kirsch, Chief, Branch F Division of Reactor Projects, NRC Region IV M, B. Fields, NRC Project Manager, San Onofre Units 2 and 3 J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 2 and 3
I ENCLOSURE 1 REPLY TO A NOTICE OF VIOLATION The enclosure to Mr. D. F. Kirsch's letter dated October 10,1997, states, in part:
VIOLATION A "A.
10 CFR 50, Appendix B, Criterion IV, requires that measures shall be established to assure that applicable rege!atory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material.
" Contrary to the above, on August 8,1996, Purchase Order X3115902 was issued to procure ten gaskets, intended to be Combustion Engineering part Nurnber 119-07 steam generator primary manway cover gaskets, without sufficient technical requirements (pressure rating and other original equipment manufacturer gasket specifications). As a result, following receipt, acceptance, and installation of one of the gaskets, the gasket failed and caused a leaking condition on the Unit 2 Steam Generator 2EO89 cold leg primary manway cover.
I "This is a Level IV violation (Supplement 1) applicable to Unit 2 (Violation 361/97019-03)."
lli.
Reason for the Violation The steam generator manway gaskets are nonsafety-related equipment and 10 CFR 50, Appendix B requirements do not apply to these gaskets.
2.
Corrective Actions Taken and the Results Achieved As discussed in the inspection report, the following corrective actions were taken:
The procurement and installation of all nonsafety-related gaskets identified by an original equipment manufacturer / original equipment supplier (OEM/OES) part number, and installed in safety-related components that could be exposed to reactor coolant system pressure were reviewed to ensure each gasket was obtained from the OEM/OES.
All automated procurement, and any new blanket purchase order releases for any nonsafety-related parts of safety-related components (310/313 material codes), were halted effective March 27,1997. Any requisition for such parts was required to be reviewed by procurement engineering prior to being placed on a purchase order to ensure that the purchase order
ENCLOSURE 1 contained all necessary provisions for the part. Where OEM/OES part numbered items could not be obtained, engineering evaluations of proposed substitutes was required.
The description field on all nonsafety-related piece parts (310/313 material codes) were revised on the " Corporate Materials Management System" to include a statement that roads "DO NOT SUBSTITUTE" and "OEM/OES REQUIRED."
The classification of steam generator and prescurizer manway cover gaskets was changed to " Augmented Quality Class" material, which added technical and quality assurance requirements on all future purchases. This provision includes receiving inspection and traceability requirements.
However, as defined, Augmented Quality Class material is still nonsafety-related for which 10 CFR 50, Appendix B regulatory requirements do not apply.
A comprehensive review of all current purchase orders for all nonsafety-related parts of safety related components cther than gaskets was performed to identify any parts, other than gaskets, that may have been similarly purchased from a supplier other than the OEM/OES.
1.
Corrective Actions That Will be Taken No further corrective actions are planned.
4.
Date When Full Compliance Will be Achieved The gasket was replaced with an OEM gasket meeting all applicable design requirements on March 26,1997.
VIOL.ATION B The enclosure to Mr. D. F. Kirsch's letter dated October 10,1997, states, in part:
"B.
Units 2 and 3 Technical Specification 5.5.1.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, recommends administrative procedures for security..
l' ENCLOSURE 1
" Security Procedure SO123-IV-4.4, " Security Lock and Key Control,"
Revision 3, Attachment 6, Step C.1, requires, in part, that operators shall disable a vehicle with a vehicle locking device when the vehicle is not operator occupied inside the protected area.
" Contrary to the above, on August 25,1997, a firefighter left a semitractor running, with the driver side door open, and climbed on top of an unattached tanker approximately 30 feet away. The fire fighter failed to disable the vehicle with a vehicle locking device while the vehicle was not operator occupied inside the protected area.
"This is a Severity Level IV violation (Supplement Ill) applicable to Units 2 and 3 (Violation 361; 362/97019-05)."
1.
Reason for the Violation The reason for the violation was inadequate training and inadequate program implementation, in that the fire fighters thought the existing practice for conducting the tractor, pump and tanker inspection was acceptable without paying strict attention to the requirements of the procedure for use of vehicle locking devices (VLD).
2.
Corrective Actions Taken and the Results Achieved As discussed in the inspection report, SCE trained all fire fighters on the importance of procedural compliance and emphasized the personal responsibility of understanding requirements and following them.
3.
Corrective Actions That Will Be Taken increased observations of the use of VLDs will be made through supervisory observations. This effort will be completed by December 31,1997.
SCE will conduct a review of the existing requirement for the use of VLDs to determine if it will continue this 'beyond regulatory requirements' practice. This review will be completed by February 28,1998.
4.
Date When Full Compliance Will be Achieved Full compliance was achieved on August 25,1997, when the firefighter returned to the cab of the vehicle and restored the "op trator occupied" status.
ENCLOSURE 2 VIOLATION LEVEL ASSESSMENT SCE believes violation !0:361;362/97019-05, on a seismic semi-tractor not being secured with a locking devica in accordance with procedures, should h ve been characterized as a "minot violation" in accordance with the NRC Enforcement Policy.
NRC NUREG/BR-0195, "NRC Enforcement Manual," Revision 1, Section 6.3.1.1, Page 4, provides guiaance on how " minor violations" should be determined. This 1
section cf the manual contains six criteria to be considered when reviewing an issue for characterization as a minor violation.
The six minor-violation criteria are noted below, followed by SCE's response to each criteria:
?
{
1.
Does the violation have any actual impact (or any realistic potential for impact) on safety?
Response
The dris r of the tractor had stepped cway to check tanker level (se; photograph). The unattended tractor did not resett in any actual impact on plant operations or plant personnel, and had no realistic potential for impact on safety. The driver of the tractor was approximately 30 feet away frnm the and had a line of sight to the tractor. Further, there '
a:
significant decrease in security effectiveness nor w, any significant increase in probability of the creatior, credible threat. Specifically, the threat of an insider attacking the driver was not significantly different whether he was in the cab or in the immediate vicinity of the tractor.
2.
Does the violation suggest a programmatic problem that could have a realistic potential safety or regulatory impact?
t
Response
10 CFR 73.55(d)(4) states, in part; ".. The licensee shall exercise positive control over all such designatcd vehicles to assure that they are used only by authorized persons und for authorized purposes."
"Pos'tive control" typically (at most facilities) only means a program of key logout and authorization verification.
SCE's implementation of the 10 CFR requirement, pursuant to SCE procedure SO123-IV-4.4, Attachment 6, states; in part, "1. Disable vehicle with VLD when vehicle is not operator 1
l l
ENCLOSURE 2 occupied." Thus, SCE has tePen a more conservative.
- approach than that required by 10 CFR.
SCE is reviewing the need to continue to invoke this VLD requ!roment which is beyond regulatory requirements as discussed above, and it does not appear a determination of regulatory impact could be concluded in view of the allowances provided by 10 CFR requirements for this area.
- N(.' withstanding this, SCE acknowledges that a violation of the strictest possible procedural interpretation occurred, and
- is taking action to reinforce procedural compliance as discussed in the violation response.
3.
Could the violation be viewed as a possible precursor to a significant event?
Response
This violation would not be viewed as a precursor to a more significant event. In order for this to occur an individual would need direct knowledge of when the activity would take p'act,,
position themselves to take action, and then overcome the driver who was still in sight of the tractor. While then some compromise variables to be considered, it is not apparent this issue would be a precursor to a mort significant event.
4.
If the violation recurred, would its recurrence be a more significant concern?
Response
As noted above, SCE'e local requirement is beyond that required by 10 CFR in that SCE could reduce its present procedural requirement and still be in compliance with the Coda. Therefore, it cannot be concluded that recurrence of the violation (failure to use a VLD) wou'd result in a more significant concem.
5.
If inadvertently left uncorrected, would this violation become a more significant safety and regulatory concem?
Response
As stated above the local VLD requirement is more conservative than what is required by 10 CFR. Based on
- g..
O,-
ENCLOSURE 2 what the Code requires, it door not appear that failure to correct this problem would lead to a significant safety or regulatory concern, in that this was a failure to meet a condition beyond that required by the Rule.
6.
Are there associated circumstances that add regulatory concern to this violation (e.g., apparent willfulness, licensee refusal to comply, management involvement, etc.)?
Response
There was no willfulness on the past of the fire fighter involved with this issue. The individual thought he was properly doing what the procedure required, as the inspection report rioted.
Upon identification of the issue, SCE personnel immediately took "ecessary short-term correc,tive actions to prevent recurreria (i.e., SCE did not refuse to comply). In addition, at the time of tne event, no management or supervision was directly involved with the noncompliance.
SCE believes this particular evant meets all the criteria noted above as outlined in the enforcement policy, As noted above, the procedural requirement to install a locking device whenever the vehicle is no:" operator occupied" provides additional, conservative margin to vehicle control, beyond those requirements specified in 10 CFR 73.55(d)(4).
Accordingly, SCE notes, that notwithstanding the failurt h install e VLD violates the procedure as Mitten, the NRC regulatory guidance on tria control of vehicles was always :naintained.
d ENCLOGURE 2 A
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s FIRE FIGHTER ON TOP OF TANKER VIEW LOOKING SOUTH 0 _.
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