ML20247B131

Notice of Violation from Insp on 890617-0729.Violations Noted:Adv HV-8419 Manually Closed at Local Station,Returned to Automatic Svc & Declared Operable W/Controller Equalizing Valve Left Open

ML20247B131
Person / Time
Site:	San Onofre
Issue date:	08/25/1989
From:	Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20247B124	List: IR 05000206/1989018 ML20247B118 ML20247B131
References
50-206-89-18, 50-361-89-18, NUDOCS 8909120357
Download: ML20247B131 (2)

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l APPENDIX A NOTICE OF VIOLATION Southern California Edison Company Docket No. 50-206 50-361 San Onofre Units 1, 2 and 3 License No. DPR-13 NPF-10 During an NRC inspection conducted on June 17 through July 29, 1989, viola-tions of NRC requirements were identified. In accordance with 10 CFR Part 2, Appendix C, " General Statement of Policy and Procedure for NRC Enforcement Actions," the violations are listed below:

A. Technical Specification 6.8.1 requires that applicable procedures recom-mended in Appendix A of Regulatory Guide 1.33, Revision 2. February, 1978 be established and implemented.

Appendix A, Section 3.1, of Regulatory Guide 1.33 states that safety related activities for the main steam system should be covered by written procedures.

Section 6.4.1 of Operating Instruction 5023-3-2.18.1(TCN7-4),

" Atmospheric Dump Valve Operation," specifies that the atmospheric dump valve (ADV) controller equalizing valve shall be closed when automatic operation of the ADV is restored and local manual operation is no longer required.

Contrary to the above, on July 19, 1989, ADV HV-8419 was manually closed at the local station, returned to automatic service, and declared operable with the controller equalizing valve, S21301MU1264, left open.

As a result, the ADV was inoperable.

This is a Severity Level IV violation (Supplement I) applicable to Unit 2.

B. 10CFR50, Appendix B, Criterion V, " Instruction, Procedures, and Draw-ings," states that " 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."

The San Onofre Unit 10-List designates those structures, systems and components which are required to be treated as safety related. This 0-list, M-37560, Revision 3, designates 4KV Switchgear Buses IC and 2C to be safety related and specifies IEEE 384-1977 as part of the princi-pal design and construction codes or standards applicable to these systems and components.

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IEEE 384-1977, Paragraph 4.6.1(4) specifies that " Low energy non-Class.1E instrumentation and control circuits are not required to be physically separated or electrically isolated from associated circuits provided (a) the non-Class IE circuits are not routed with associated cables of a redundant division, and (b) they are analyzed to demonstrate that Class IE circuits are not degraded below an acceptable level. As part of the analysis, consideration shall be given to potential energy and identification of the circuits involved."

Contrary to above, on July 11, 1989 (a) four temporary instrument cables were determined to have been routed with redundant trains IC and 2C of the Unit 1 Class IE 4KV cables, and (b) an analysis had not been conducted to demonstrate that the associated Class IE circuits were not degraded below an acceptable-level.

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

Pursunt 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.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region V, and a copy to the NRC Senior Resident Inspector, San Onofre, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a

" 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 P. H. fghnson, Acting Chief React (f Projects Branch California

' this f46 day ofDated th Walnut Creek, d .1989 at 0

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