ML20236A101

Responds to NRC Re Violations Noted in Insp Repts 50-206/87-14,50-361/87-13 & 50-362/87-15.Corrective Actions: Personnel Reinstructed as to Requirement for & Importance of Responsibility to Ensure Compliance W/Seismic Procedures

ML20236A101
Person / Time
Site:	San Onofre
Issue date:	10/16/1987
From:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8710220026
Download: ML20236A101 (7)

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,f~8F USHRC-OS Southem Califomia Edison CfD ' A O 0 \\

P. O. DO X 8 0 0 2244 WALNUT GROVE AVENUE ROSEMCAD, CALIFORNIA 9t770 MENNETH R BASMIN TCLEPHONC

"" a"oom October 16,:1987 a + m *oi l

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U. S. Nuclear Regulatory Commission Attention: -Document Control Desk Hashington, D.C.

20555 Gentlemen:

Subject:

Docket Nos. 50-206, 50-361 and 50-362 San Onofre Nuclear Generating Station I

Units 1,_2 and 3

Reference:

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

dated September 1, 1987 The referenced letter forwarded NRC Inspection Report'Nos. 50-206/87-14, 50-361/87-13 and 50-362/87-15 and a Notice of Violation relating to housekeeping deficiencies identified during the period. December 1986 through February 1987.

In'accordance with 10 CFR 2.~201, the enclosure to this letter l

provides the Southern California Edison (SCE) response to the Notice of l

Violation. As discussed with Mr. R. P. Zimmerman (USNRC. Region V) on.

September 29, 1987, additional time was required in order'to provide _a complete response.

i In addition to forwarding _the Notice of. Violation, the referenced letter requested a response to an NRC concern that planned revisions to existing l

Station procedures would reduce the effectiveness of our housekeeping l

program.

The letter indicates that the NRC perceives that SCE_apparently intends that the changes would reduce the risk of enforcement action resulting from noncompliance with these procedures. With respect.to. housekeeping,.SCF-remains committed to continuing to improve the standards which are maintained throughout San Onofre and it is not SCE's intention to reduce' the effectiveness of any of its programs in' order to reduce the risk of enforcement action.

8710220026 871016 o\\

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Document Control Desk October 16, 1987 As indicated in the attached response'to'the Notice of Violation SCE agrees with the NRC conclusion that the discrepancies cited indicate weakness and the need for improved performance in the areas. identified by the Notice of Violation.

Based on'our review of the program implementation'in general, and the extensive discussions held.with NRC inspectors since the discrepancies were identified early this year, SCE has concluded that changes to our procedures are required, and these changes will be made.

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I A~ contributing cause of the discrepancies identified in the Notice of i

Violation was that the specific, _ detailed requirements of the procedures.in existence were not consistent with management intent in all cases..: Changes ~to I

the procedures are needed so that the housekeeping program'can be implemented by.first line supervision as intended by management.

In summary, we conclude that the changes.we are making to the housekeeping procedures at San Onofre will make the program more effective. Should you i

have any further questions or require' additional information, please do not I

hesitate to call me.

l Very truly yours, w'

Enclosure cc:

J. O. Bradfute, NRR Project Manager, San Onofre Unit 1 H. Rood, NRR, Senior Project Manager, San Onofre Units 2 and 3 J. B. Martin, Regional Administrator, NRC Region V F. R. Huey, NRC Senior Resident Inspector,-San Onofre Units 1, 2 and 3 j

l Enclosure

-l Response to the Notice of Violation contained in the letter from Mr. R.

P..

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Zimmerman (NRC) dated September 1, 1987.

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Mr. Zimmerman's letter states in part:

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10. CFR 50, Appendix B, Cri terion II, states in' part:

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'The quality assuran'ce program shall provide. control over activities affecting the quality of the. identified structures, systems and components, to an extent consistent with their importance to-l safety. Activities affecting quality shall be accomplished under I"

suitable controlled conditions. Controlled conditions include the use of appropriate equipment, suitable environmental condition for~

accomplishing the activity, such as adequate cleanness;....'

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"10 CFR 50, Appendix B, Criterion V, states in part:

' Activities affecting quality shall be prescribed by documented instructions, procedures or drawings; of a type appropriate to the circumstances and shall be accomplished in accordance with these 1

instructions, procedures or drawings....'

" Southern California Edison Topical Quality Assurance Manual (TQAM),

i Chapter 4C, states that:

'l.0... Housekeeping requirements and practices shall be controlled j

in accordance with written procedures and instructions to assure

'l that safety related areas and items are adequately protected from J

environmental degradation due to construction, maintenance, inspection, test or other work activities.

'3.0 Hork activities shall be planned and implemented in the manner which assures that satisfactory housekeeping practices are provided. Consideration for housekeeping should include provisions-for waste removal; orderly storage of material in use;....'

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Administrative Procedure S0123-VI-23.0, ' Implementation of Site l

Housekeeping and Cleanness Control,' defines the following-requi rements:

'6.3.1 The foundation of the housekeeping policy at SONGS is that each individual shall ' clean as they go.'

That means not allowing conditions to degenerate beyond that which can be handled on'a shift to shift cleanup.. Hork sites will be cleaned and straightened at least once each eight hour shi f t.

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'6.3.6 Hoses, temporary power cables, portable gear, tools, l

debris, scaffolds and excess material used in plant work l

areas shall be removed or properly stored and identified when n,ot in use.

'6.3.7 Trash, debris and unused equipment shall not be allowed to accumulate in any work area and, as a minimum, shall be

'l removed to the larger outside trash receptacles or

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locations established for Health Physics release surveys l

once per working shift in areas of work activity and as appropriate in other areas...'

" Contrary to the above, on January 18, 1987, the following items were l

present in Unit 3 Train A ESF pump room in the Safety Equipment l

Building: 4 large bags of contaminated PCs, several yellow poly bags, tools, air hoses, scaffolding, tape, oil, electric cords, kim wipes, wire, two dollies, flashlights and trash.

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General Administrative Order S0123-GAD-3, ' Site Housekeeping and Cleanness Control,' defines the following requirement:

'IV.A 7 Ensure equipment utilized during act'ivities such as maintenance, testing and inspection shall not be located or left unsecured such that during a seismic event their-collapse or movement could adversely affect safety related equipment.'

" Contrary to the above:

o On December 24, 1986, a grounding truck was not secured in the Unit 1 4 kV switchgear room during Mode 1 operation.

o On February 18, 1987, breaker.11C08 was left unsecured in the corridor between Train A and Train 8 switchgear in the Unit 1 4 kV room while the unit was in Mode 1 operation.

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Administrative Procedure S0123-VI-23.0, ' Implementation of Site Housekeeping and Cleanness Control,' defines the following requirements:

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'6.3.11 Tool cabinets, instrument skids of other such temporary items which could become a hazard to safety related l

equipment or personnel during a seismic event must be l

securely fastened or moved to a more suitable location.

'6.3.18 Compressed gas bottles in or about safety related I

structures, systems or components must be firmly secured or stored in a permanent structure (non-mobile racks) when not in use..."

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" Maintenance Procedure S0123-I-1.20. Seismic Controls During Maintenance,-Testing and Inspections,' defines the following l

requirements:

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'6.1.1 Precautions shall be taken to ensure that no tool, material-or.any other item capable of damaging a safety related '

piece of equipment e allowed to impact any safety related equipment.

'6.4.2 Hooks on cranes, hoists, chainfalls and all other lifting devices, whether permanently or temporarily installedithat are located in safety related areas, shall have;their hook fully retracted when.not in use..There.snall. be no rigging attached to the hook. ' Any dangling part of the lifting; device, such asithe chain'on a chainfall, shall be. securely-attached to part of the permanent. building structure.such.

j as a column.

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'6.9.1 (Pressurized cylinders are) acceptable in safety related areas.provided they are stored in a permanent rack'or temporary cylinders are secured at the top and bottom.

" Contrary to the above:

l o On February 5, 1987, a battery tool cabinet was not properly secured in the Unit i battery inverter room.

o On February 10, 1987, a chainfall block was improperly secured to safety related conduit (JZBR12) associated with a level switch in the room for HPSI pump 3P-018.

o On February 19, 1987, several items of-' unsecured temporary test.

equipment and tools were unattended in the vicinity'of containment J

airborne radiation monitor 2RE-7804-1 in the Unit 2, 45 foot penetration area, o On February 19, a breaker maintenance truck was chained to the DC distribution panel in the Unit 1 battery inverter. room.

i o On February 3, 1987, numerou's nitrogen bottles were'not properly 1

stored adjacent to safety related equipment associated.with the Unit 1 backup nitrogen system for reactor coolant pump seal supply.

valves'(RCP-FCVill5E).

These bottles were not in permanent storage.

racks nor were they" secured in two places.

"This is a Severity Level IV violation (Supplement I) applicable'to Units 1, 2 and 3."

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RESPONSE

1.

Reasons for the violation The deficiencies identified.above resulted from the following:

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o Insufficient. training of personnel to ensure proper understanding i

and implementation of SCE's housekeeping and seismic. standards.

o Failure to'effect timely corrective action when housekeeping inspections identify deficiencies.

a o Failure to recognize the need to increase'the number of housekeeping inspections consistent with the increase in work activities that occur during an outage.

2.

Corrective steps.taken and the results achieved.

By February 28, 1987, the identified deficiencies were corrected by either removing the item, properly securing the item or returning it to its designated location.

Additional corrective actions have been taken as follows:

o Appropriate supervisory personnel have been reinstructed as to the requirements for and importance of their responsibility to ensure compliance with seismic and housekeeping procedures.

Procedures are i

i being revised to eliminate unnecessary, ambiguous or unachievable

guidance, o Housekeeping inspectors have received additional instruction on seismic restraint standards.

9 o An additional housekeeping inspector, dedicated to the inspection of outage activities, is assigned at the initiation of.each outage.-

1 o Communication of and followup for identified housekeeping i

deficiencies have been strengthened through-the publication (via-the site wide computerized. Electronic Mail System) of a seismic /

housekeeping deficiency list.

SCE believes that these corrective actions have'significantly improved the housekeeping at San Onofre.

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Corrective' steps that will be taken to avoid further violations Additional training of appropriate personnel and supervision i_s being.

developed, and will be implemented by early 1988, to ensure a consistent.

understanding and commitment to compliance with housekeeping requirements.

This training will include.:

(a) a videotape for maintenance personnel _to illustrate housekeeping' standards in_the work place (i.e., proper securing of items;'use'of chainfalls; removal of L

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. trash; " clean as you go;" storage-of nitrogen bottles; etc.); and, (b) an updated version of the general employee housekeeping videotape to illustrate good housekeeping practices (to be included in the annual red badge retraining program).

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Date When full compliance will be achieved Full compliance was achieved on February 28,1987,.when the identified conditions were corrected.

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