ML20212E534

Notice of Violation from Insp on 860922-1003.App B Lists Areas Inspected & Results

ML20212E534
Person / Time
Site:	San Onofre
Issue date:	12/17/1986
From:	Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20212E526	List: ML20212E522 ML20212E534 ML20212E553
References
50-361-86-25, NUDOCS 8701050347
Download: ML20212E534 (4)

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APPENDIX A -

. NOTICE OF VIOLATION Southern California Edison Company Docket No. 50-361

' San Onofre Unit 2 License No. NPF-10 As a result of the inspection conducted on September 22, - October 3, 1986 and in accordance with NRC Enforcement Policy, 10 CFR Part 2, Appendix C, the following violation was identified:

10 CFR 50, Appendix B, Criterion V, and paragraph 17.1.5 of Southern Ca!.ifornia Edison Topic Report, SCE-1A, Quality Assurance Program, state that activities affecting quality shall be accomplished in accordance with prescribed instructions, procedures and drawings.

Be:htel~ Raceway Input Data Document - 347.00, Revision 106, dated January 6, 1986, requires the entire length of cable tray U21GATA3 to have a type 3 fire barrier (one inch of blanketing material) installed.

Contrary to the above, as of September 29, 1986, cable tray U2IGATA3 did not have a type 3 fire barrier installed over approximately 15 feet of the raceway.

This is a Severity Level IV Violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby required to submit to this office within thirty days of the date of this-Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2)  !

correctiveLateps which will be taken to avoid further items of noncompliance; I and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

DEC 171986 gyA Dated Stuart Richards, Chief

( Engineering Section l

l 8701050347 861217 PDR ADOCK 05000361 G PDR

APPENDIX B Areas Inspected and Results Operating Experience Review Program The program for evaluation of industry operational experience, implemented primarily by the Independent Safety Engineering Group (ISEG), was reviewed by examining a sample of ISEG evaluations. The evaluations were reviewed for technical adequacy, level of detail, and timeliness. In general, the evaluations addressed issues of limited scope such as NRC Information Notices and INPO Significant Event Reports. Those reviews were considered acceptable.

However, for the evaluation of large, complex, multi-faceted events, a concern was identified whether certain critical details would receive sufficient evaluation and attention. For example, although the licensee's review of the Davis-Besse event was not complete, it appeared unlikely that significant details associated with difficulties encountered by operators in resetting the turbine driven auxiliary feedwater pump turbine overspeed trip would be 1 addressed. An additional finding included the observation that ISEG informally tracked implementation of its recommendations; rather than through procedural requirements formalizing the process.

Walkdown of Rancho Seco Overcooling Event Based on a review of NUREG 1195, a similar scenario of events was developed to determine whether weaknesses identified at Rancho Seco were also evident within the licensee's program at SONGS. It was determined that, when presented with a postulated event based on actual industry operating experiences involving failures beyond the design bases of the plant, certain i common weaknesses were found indicating a need for improvement in the licensee's readiness for manual operation of plant equipment.

! Remote Valve Position Indication The adequacy of. valve position indication in the Control Room and at the remote shutdown panel was examined with an emphasis on the operation of controllers and on valves that do not have direct position feedback in the Control Room. Operators were found to be knowledgeable about valves that displayed demand position and the need to use alternate means to verify actual position. Controller indications were considered clear and unambiguous, with no human factor concerns identified.

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NRC Bulletin'85-03, Motor Operated Valve' Common Mode Failures During Plant Transients Due To Improper Switch Settings The review included: the program for establishing the maximum differential pressure expected during operation of safety related valves during normal and abnormal events; the program for establishing the baseline data used in determining switch settings; the program and implementing procedures for motor operated valve testing; and, the licensee's response to the Bulletin.

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The implementation of the program was found to be acceptable. Testing personnel appeared adequately trained and knowledgeable of the equipment used during valve testing. The NRR staff's review of the technical adequacy of the Bulletin response has not yet been completed.

Potential for Loss of Shutdown Cooling The objectives of the review were: to evaluate the susceptibility of SONGS Units 2'and 3 shutdown ecoling system (SDCS) to a single failure which could result in inadvertent automatic closure of SDCS pump suction / isolation valves; to assess the effectiveness of the licensee's actions in response to lessons-learned from industry experiences where SDC was lost; and to review the details associated with a loss of SDC at SONGS reported in LER 86-07.

Results of the review determined that the SDCS did not appear to be susceptible to a single failure which could result in a loss of SDC. The

-licensee's evaluations of lessons learned, including the instance addressed in the subject LER, were considered adequate. Recommendations and commitments made by the licensee based on those internal reviews were found to be technically sound and appropriately implemented.

Spurious Engineered Safety Features Actuation Due To The Radiation Monitoring System (RMS) and Toxic Gas Isolation Systems (TGIS)

Spurious actuations of the RMS and TGIS have occurred since the issuance of the Unit 2 operating license. The licensee's actions to identify the causes and correct the deficiencies were evaluated.

The licensee's corrective actions, which included design upgrades to both systems, were found to be appropriate. The hardware changes appeared to have resulted in an improvement, although additional operating history is necessary to judge the full effectiveness.

Control Air System Moisture Buildup The control air system was reviewed to determine whether the licensee has implemented a program that effectively prevents and/or identifies and corrects moisture accumulation in the control air lines. Based on a review of the systems concur design features, preventive maintenance procedures, a walkdown of the system, and discussions with cognizant personnel, it was concluded that moisture accumulation had not been a recent problem, and appropriate measures to preclude moisture accumulation were in place.

Station Batteries and Inverters The evaluation included: system walkdowns; review of maintenance procedures and surveillance testing records; and evaluation of operational problems associated with the batteries and inverters.

In general, the maintenance and testing program was found to be acceptable.

Findings associated with the inverter review included: a concern regarding elevated internal cabirst temperatures; a design modification which feeds two

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branch circuits from a corson fused circuit protective device tssembly being not in accordance with the National Electric Code and Underwriter Laboratory Standard; difficulty encountered in operating the manual transfer switch; the need for formal training for test technicians; and close monitoring of future load increases.

Plant Tours Observations noted during' plant tours indicated that although adequate procedural controls appeared to exist governing the performance of periodic tours by plant personnel, including management, greater attentiveness and aggressiveness on plant rounds and tours is warranted. This conclusion was based on the discovery of a number of conditions, which could reasonably have been expected to have been identified and corrected by the licensee.

Examples of several of the conditions identified included: a corroded snubber

'which was subsequently tested and found to be frozen; a missing fire barrier from a cable raceway - for which a violation is being issued; and, a number of discrepant conditions associated with material condition of components in the auxiliary feedwater system.

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