ML20207K974

Responds to NRC Re Violations Noted in Insp Rept 50-362/88-22.Corrective Actions:Appropriate Personnel Counseled Re Thorough Check of Caution Tags Prior to Granting Permission for Work Authorizations

ML20207K974
Person / Time
Site:	San Onofre
Issue date:	10/11/1988
From:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8810170116
Download: ML20207K974 (4)

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October 11, 1988 ,

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U. S. Nuclear Regulatory Comission i Attention: Document Control Desk Washington, D.C. 20555 Gentlemen: ,

Subject:

Docket No. 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Unit 3

Reference:

Letter, Mr. R. J. Pate (NRC) to Mr. Kenneth P. Baskin (SCE),

dated September 9, 1988 ,

The above referenced letter forwarded NRC Inspection Report No. 50-362/88-22 and a Notice of Violation resulting from the special announced inspection conducted by Mr. C. Clark during the period of July 18 through August 5  !

1988. In accordance with 10 CFR 2.201, the enclosure to this letter provides the Southern California Edison (SCE) reply to the subject Notice of Violation.

If you require any additional inforhation, please so advise.

Very truly yours.

(e ino W

l Enclosure cc: J. B. Martin, Regional Administrator, NRC Region V  ;

F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3 >

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8810170116 881011 l PDR ADOCK 05000362 i o PNV i

ENCLOSURE RESPONSE TO NOTICE Of VIOLATION Appendix A to Mr. R. J. Pate's letter, dated September 9, 1988, states in part:

"As a result of the inspection conducted during the period of July 18 through August 5, 1988, and in accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' 10 CFR Part 2, Appendix C (1987), the following violation was identified:

' Technical Specification 6.8.1.c requires that written procedures be established, implemented and maintained covering surveillance and test activities of safety related equipment.

' Engineering Procedure 503-V-3.12. Temporary Change Notice (TCN) 1-1, specified containment integrated leakage rate test requirements. In particular, step 2.1 of attachment 5 of the procedure required that:

' Caution tags shall be completed and placed on the valves, identified below, during the test valve lineup. (See section 4.0 and 5.0 of this attachment)' valves. 3 LV-0110 A and B were in the lineup and were to remain closed.

' Contrary to the above, while performing the containment integrated leakage rate test (ILRT) during the period between July 18 through July 21, 1988, caution tags were not placed on valves 3 LV-0110 A and B.

As a result, valve 3 LV-0110A was opened to allow maintenance unrelated to the ILRT, which in turn permitted an uncontrolled loss of approximately 250 gallons of water from the shutdown cooling system.

"This is a Severity Level IV violation applicable to Unit 3 (Supplement 1)."

RESPONSE:.

1. Reasons for the violation. if admitted.

SCE admits that while performing the July 18-21, 1988 ILRT, Pressurizer Level Control valves 3LV-0110A and B were not caution tagged.

As stated above, the Unit 3 ILRT procedure, 503-V-3.12, Step ? 1, requires that caution tags be placed on the valves (emphasis added).

However, it was the intent of the procedure to place the caution tags at locations where the valve could be normally operated from, depending on the type of valve involved, as follows:

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a. Manual Valves - Caution tag to be hung on the valve.

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b. Motor Operated Valves - Caution tags to be placed on the ,

control board in the the control room (or wherever the l controller switch is Incated) and at the electrical breaker.

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c. Air Operated Valves - Caution tag to be placed at the i controller switch location where the valve is remotely operated. I Prior the the July 18 ILRT, a caution tag for air operated valves 3LV-0110A & B was placed on Controller LIC-0110, which is located in the Control Room. Controller LIC-0110 is the location where the valves 3LV-0110A and B are normally operated. .

Ouring the ILRT on July 21, a work authorization was in process to calibrate the actua'. ors /positioners for 3LV-0110A and 8, which had been l replaced earlier in the outag), and to stroke the valve. The work l' author 12ation process required Control Room permission to manipulate the valve. The intent of requiring Control Room review and approval is to ensure that maintenance activities do not adversely impact plant '

operations, i i

When the Control Operator reviewed the work authorization request, the l Control Operator went to the Control Board to verify no ILRT caution tags were in effect. The Control Operator erred in not checking Controller  !

LIC-0110. Instead, the Control Operator checked the valve selector '

switch (3HS-0110F) and not finding a caution tag, granted permission for i the work authorization, t

As noted above, during the stroking of the valve an uncontrolled loss of l approximately 250 gallons of water occurred. The Control Operator noticed Pressurizer level decreasing, reviewed the control board indications, noted 3LV-0110A open, and directed the valve to be closed. [

The caution tag was then recognized by the Control Operator on Controller j LIC-0110. t in sumary, the Control Operator erred in not checking the proper location for the caution tag, which would have then resulted in a delay  ;

of the work authorization permission until after the ILRT. In addition, had a caution tag been placed on the valve itself, it is possible that personnel would have contacted the Control Room prior to stroking the valve, resulting in recognition that the work authorization should not have been granted during the ILRT.

2. Corrective steos thtt have been taken and the results achieved. l l

Appropriate personnel were counseled regarding the need to thoroughly check for caution tags prior to granting permissions for work authorizations.

3. Cone c tly e_s t erLiha t_xilLbLt aken_to_aro1Lfu r_thenyls11tiom Since the ILRT valve lineup is not a normal valve lineup that operations personnel are familiar with, the ILRT procedures for all three Units will be revised such that all valves required to be in a specific position for an ILRT will be caution tagged, as follows:

(a) Manual Valves - A single caution tag will be placed on the valve's handwheel.

(b) Remotely Operated Valves - Caution tags will be placed on al) locations where the valve could be manipulated by normal means and on the valve itself.

(c) There will be procedural signoffs, by the person (s) placing or removing the caution tag, that the caution tags have been placed on the valve itself and at all locations where the valve could be manipulated by normal means.

The next scheduled ILRT is to be performed on Unit 1 in 1990. The aforementioned procedural changes will be completed by June 30, 1989.

4. Date_whtn_fulLcompliance_will be_achievet l

l Full compliance was achieved on July 21, 1988, when valve 3LV-0110A was i returned to the closed position. l l