ML20206R942
| ML20206R942 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/20/1986 |
| From: | Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20206R930 | List: |
| References | |
| 50-361-86-11, 50-362-86-11, NUDOCS 8607070265 | |
| Download: ML20206R942 (2) | |
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1 APPENDIX A NOTICE OF VIOLATION Southern California Edison Company Docket No. 50-361, 50-362 San Onofre Units 2 and 3 License Nos. NPF-10, NPF-15 As a result of the inspection conducted during the period of March 28 through May 12, 1986 certain violations of NRC requirements were identified.
In accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2 Appendix C, as revised, 49 FR 8583 (March 8, 1984), the violations are set forth below:
A.
10 CFR Part 50, Appendix B, Criterion V, states in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions, procedures, or d;awings."
The San Onofre Quality Assurance Program, described in the Topical Quality Assurance Manual defines quality-affecting activities as follows:
" Quality-Affecting Activities - Activities of people which either do or could influence quality of safety-related items or work, including... constructing,... erecting, installing, inspecting, testing, operating,... or modifying. This also includes activities required by the Station Technical Specifications or otherwise licensed by the NRC."
Operability of the shutdown cooling system is required by the San Onofre Unit 2 technical specifications Limiting Condition for Operation (LCO) 3.4.1.4.2.
The Topical Quality Assurance Manual, Chapter IC, Quality Planning (Instructions and Procedures) states:
1.0
" Activities affecting quality shall be planned and performed in a controlled manner in accordance with the provisions of applicable procedures and instructions.
Contrary to the above, on March 22, 1986, a tygon tube was installed on the hot leg of Reactor Coolant System (RCS) loop No. 1, and used to measure the water level in the RCS. This activity was performed without the use of a written procedure. On March 26, 1986, while plant operators were using the installed tygon tubing for reactor vessel water level indication during RCS draining and fill evolutions, an error of twelve inches was experienced in the tygon tube level indication. This condition resulted in draining the water in the RCS six inches below that allowed by the RCS draining procedure, causing inoperability of the shutdown cooling system for approximately 47 minutes.
This is a Severity Level IV Violation (Supplement 1) applicable to Unit 2.
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B.
Paragraph 6.8 of the Technical Specifications states that written l
procedures shall be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Revision 2, dated February 1978 states that procedures should be written for activities carried out during the operations phase of nuclear power plants including " Hot Standby to Minimum Load (nuclear start-up)."
The San Onofre Nuclear Generating Station Topical Quality Assurance Manual, Chapter 5-F, section 4.0 states:
" Operating procedures shall be provided...that include starting the reactor from cold or hot conditions..."
Operating Instruction S023-3-1.1, TCN 8-10 dated December 20, 1985, titled: Reactor Start-up, reads:
"6.22 Closely monitor all channels of nuclear instrumentation and CEA (control element assembly) position while starting up the reactor.
"6.23.6 Periodically stop CEA withdrawal and wait until the Nuclear Instrumentation trends can be determined."
Contrary to the above, during start-up of the Unit 3 reactor on April 13, 1986, all channels of nuclear instrumentation were not closely monitored l
for approximately 6 minutes prior to reactor criticality, and CEA withdrawal was not stopped for sufficient duration to determine nuclear instrumentation trends. As a result, reactor criticality was not recognized by plant operators and reactor power increased approximately 2 decades further than specified in the reactor start-up procedure, I
resulting in a reactor trip. A factor which contributed significantly to this event was the use of incorrect xenon data to compute the estimated critical position for the startup.
This is a Severity Level IV Violation (Supplement 1) applicable to Unit 3.
Pursuant to the provisions of 10 CFR 2.201, Southern Cslifornia Edison Company is hereby required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in response to each of the above violations, including: (1) the corrective steps which have been-taken and the i
results achieved, (2) corrective steps which will be taken to avoid further violations, (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
JUN 2 01986 Dated P.H.Afhnson, Chief React # Projects Section 3 l
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