ML20238F367

Notice of Violation from Insp on 870208-0404.Violations Noted:Four Bags of Contaminated Pcs,Several Yellow Poly Bags,Tools,Air Hoses,Scaffolding,Tape,Oil,Electric Cords,Kim Wipes,Wire & Dollies Found Present in Train a ESF Pump Room

ML20238F367
Person / Time
Site:	San Onofre
Issue date:	09/01/1987
From:	Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20238F356	List: IR 05000206/1987014 ML20238F353 ML20238F367
References
50-206-87-14, 50-361-87-13, 50-362-87-15, NUDOCS 8709160108
Download: ML20238F367 (4)

Text

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• APPENDIX A

) NOTICE OF VIOLATION Southern California Edison Company Docket No. 50-206 50-361 50-362 San Onofre Units 1, 2 and 3 License No. DPR-13 s NPF-10 NPF-15 During an NRC inspection conducted during the period of February 8,1987 through April 4, 1987, 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 (1987), the violations are listed below:

A. 10 CFR 50, Appendix B, Criterion II, states in part: I 1

"The quality assurance program shall provide control over activities l affecting the quality of the identified structures, systems and components, to an extent consistent with their importance to safety.

Activities affecting quality shall be accomplished under suitably l controlled conditions. Controlled conditions include the use of j appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanness;...."

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

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" 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 instructions, procedures or drawings...."

Southern California Edison Topical Quality Assurance Manual (TQAM),

Chapter 4C, states that:

1.0.... Housekeeping requirements and practices shall be controlled in accordance with written procedures and instructions to assure that safety related areas and items are adequately protected from environmental degradation due to construction, maintenance, inspection, test or other work activities.

3.0 Work activities shall be planned and implemented in a manner which assures that satisfactory housekeeping practices are provided.

Consideration for housekeeping should include provisions for waste removal; orderly storage of material in use;. . . .

1. Administrative Procedure 50123-VI-23.0, " Implementation of Site Housekeeping and Cleanness Control," defines the following requirements:

870916010s e709o1 PDR G ADOCK 05000206 PDR

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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. Work sites will be cleaned and straightened at least once each eight hour shift.

6.3.6 Hoses, temporary power cables, portable gear, tools, debris, scaffolds, and excess material used in plant work arcas shall be removed or properly stored and identified when not 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 removed to the larger outside trash receptacles or locations established for Health Physics release surveys once per working shift in areas of work activity and as appropriate in other areas.....

Contrary to the above, on January 18, 1987, following items were present in Unit 3 Train A ESF pump room in the Safety Equipment Building: 4 large bags of contaminated P.C.s. several yellow poly bags, tools, air hoses, scaffolding, tape, oil, electric cords., kim wipes, wire, two dollies, flashlights and trash.

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

IV.A.7. Ensure equipment utilized during activities 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 4KV switchgear room during Mode 1 operation.

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

3. Administrative Procedure 50123-VI-23.0, " Implementation of Site Housekeeping and Cleanness Control," defines the following l 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 equipment or personnel during a seismic event must t be securely fastened or moved to a more suitable location.

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a: 3 t-6.3.18 ' Compressed gas bottles in or about safety related structures, systems or. components,must be firmly secured or stored in.a permanent structure (non mobile racks) when not in'use....

Maintenance Procedure 50123-I-1.20, " Seismic Controls During Maintenance, Testing, and Inspections," defines the following 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 be allowed to impact any safety; related equipment.

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

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: j On February 5,1987, a battery tool cabinet was not proparly secured in the Unit 1 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 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 #1 battery inverter room.

o On February 3, 1987, numerous nitrogen bottles were not properly stored adjacent to safety related equipment associated with the Unit 1 backup nitrogen system for reactor coolant pump seal supply valves (RCP-FCV1115E). 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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Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby required to submit a written statement or explanation to the U.S. l l Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC l 20555 with a copy to the Regional Administrator, Region V, and a copy to the l l NRC Senior Resident Inspector, San Onofre, within 30 days of the date of the l letter transmitting this Notice. This reply should be clearly marked as a i

" Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown.

FOR THE NUCLEAR REGULATORY COMMISSION

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hR.P.Zmmerman, Chief React Projects Branch Dated at Walnut Creek, California this 1st day of September 1987

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