ML20247Q575
| ML20247Q575 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/22/1989 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8909290028 | |
| Download: ML20247Q575 (6) | |
Text
m MI!v
- y@ (;, M.
1, a
y ::w~
r/
s
-Southem Calibmia Edison Company 23 PARKE R STRE CT IRVtNE, CALIFQRNIA 92768
. vics sanc tiDa mer
.y
.mSemeOO September' 22,'1989-
.U.'S.'Guclear Regulatory. Commission
-Attention:
Document' Control Desk
' Washington, D.C. 20555 Gentlemen:.
Subject:
' Docket'Nos. 50-206 and 50-361
~ Reply to a Notice of Violation San Onofre Nuclear Generating Station,
-i
~ Units 1 and 2
Reference:
- Letter, Mr. P. H. Johnson (NRC) to Mr. Harold B. Ray (SCE), dated August 25, 1989 The Reference forwarded NRC Inspection Report Nos. 50-206/89-18 and 50-361/89-18 and a Notice'of Violation resulting from the routine inspection conducted by Messrs. C. W.
- Caldwell, F._R. Huey and A. L. Hon.
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 information, please so advise.
Very truly yours,
- 6. L 1
l Enclosure i
cc:
J. B. Martin, Regional Administrator, NRC Region V l
C. W.
Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3 1
8909290028 690922
[60l PDR-ADOCK 05000206 O
FDC I
g
= _ _ _ - _ _ _
O i
w-1
<~
l i
i ENCLOSURE REPLY TO A NOTICE OF VIOLATION Appendix A to Mr. Johnson's letter, dated August 25, 1989, states in part:
A.
" Technical Specification 6.8.1 requires that applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978 be established and implemented.
" Appendix A, Section 3.i, of Regulatory Guide 1.33 states that safety related activities for the main steam safety system should be covered by procedures.
"Section 6.4.1 of Operating Instruction SO23-3-2.18.1 (TCN 7-4),
' 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 coerable 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."
o l
L 1
. RESPONSE TO ITEM A 1.
Reasons for the violation. if admitted.
SCE admits that on July 19, 1989, the equalizing valve for ADV 2HV-8439 was left open in violation of procedure SO23-3-2.18.1.
On July 17, 1989, ADV 2HV-8419 was removed from service for routine maintenance, including replacement of the valve bonnet drain valve.
Due to steam. leakage on the ADV isolation valve, welding on the valve bonnet drain valve could not be performed.
To eliminate the steam leakage, the ADV isolation valve was tightened and an Operator was contacted to open ADV 2HV-8419.
When ADV 2HV-8419 was opened, the Operator only recorded on the Work Authorization Request (WAR) that he opened 2HV-8419 without also recording that the equalizing valve (S21301MU1264) had been opened in order to operate 2HV-8419.
Therefore, when preparing the WAR return-to-service section, closing 2HV-8419 was specified but S21301MU1264 was omitted.
As a result, 2HV-8419 was closed (since the WAR return-to-service section recorded the need to perform this action) but S21301MU1264 was not closed.
Based on discussions with the Operator involved, as well as other Operators, this event was caused by inattention to detail.
The Operator understood that he needed to document the manipulation of the equalizing valve, but failed to precisely record all the actions he had taken and simply documented that he had opened 2HV-8419.
In addition, SCE's investigation into this event concluded i
that: (1) the open equalizing valve could have gone I
undetected until the routine monthly surveillance identified the discrepancy (fortuitously, the open equalizing valve was discovered within the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> permitted to perform maintenance); and (2) although the current ADV operating instruction does not require a post-maintenance test of the ADVs operating instruction SO123-O-23.1 does contain a generic requirement to functionally stroke pneumatic valves after they have been operated manually, to verify they have been correctly returned to service.
i i L l
2.
Corrective stens that have been taken and the results achieved.
The equalizing valve was closed on July 20 following discovery of the condition and the valve was successfully tested.
The Operator received appropriate disciplinary action.
An Operational Divisional Investigation Report (ODIR) (2-89-13) was prepared and is being placed on the Priority Reading list for'all Operators.
A p.riority reading is being provided to all Operators o. tr.<a Sol 23-0-23.1 retest / functional test requirement.
In addition, the ODIR is being provided to the Nuclear Training Division for incorporation into the Operator training program.
The ADV Operating Instruction, SO23-3-2.18.1 is being revised to include a check of the equalizing valve position during the ADV surveillance testing and to require a remote functional stroke test of the valve following return to normal alignment after local mancal operation.
3.
Corrective steps that will be taken to avoid further violations.
Requalification Job Performance Measures will be upgraded,
-as necessary, to ensure periodic walk-through training on the programs established to ensure remote or automatic functions have been restored, if those functions are disabled either directly or as a consequence of maintenance or operational activity.
4.
Date when full compliance will be achieved.
Full compliance was achieved on July 20, 1989, when the equalizing valve was restored to the closed position.
Appendix A to Mr. Johnson's letter, dated August 25, 1989, states in part:
B.
"10CFR50, Appendix B, Criterion V,
' Instruction, Procedures, and Drawings,' 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.'
4
..+ r 4 -
I.
I "The San Onofre Unit 1 Q-List designates those structures, h
systems, and components which are required to be treated as. safety related.
This Q-List, M-37560, Revision 3, designates 4KV Switchgear Buses 1C and 2C to be. safety related and specifies IEEE 384-1977 as part of the principal design and construction codes or standards applicable to these systems and components.
I "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 1E circuits are not routed with associated cables of a redundant division, and (b) they are analyzed to demonstrate that Class 1E 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 $nvolved.
" Contrary to the above, on July 11, 1989, (a) four temporary instrument cables were determined to have been routed with redundant trains 1C and 2C of the Unit 1 4KV cables, and (b) an analysis had not been conducted to demonstrate that the associated Class 1E circuits were not degraded below an acceptable level.
"This is a Severity Level IV violation (Supplement I) applicable to Unit 1."
RESPONSE TO ITEM B 1.
Reasons for the violation, if admitted.
SCE admits that on July 11 temporary measuring and test equipment (M&TE) low energy signal cables were routed such that the temporary cables crossed beneath redundant trains without an attendant analysis to demonstrate that the associated Class 1E circuits were not degraded.
SCE procedures on the control of temporary cable routing were prepared based on the assumption that IEEE 384-1977 did not apply to temporary low energy signal cables.
As a result, SCE procedures did not address temporary M&TE signal cables based on the belief that: (1) there are no credible circumstances where low energy signal cables could degrade Class 1E power, instrument or control circuito; and (2) IEEE 384-1977 does not apply to low energy METE signal cables.
1
n
_ f...l.. _ ('T l,..
..I'l;,
, gjifj; #.-
-5
~ Consequently,.on_ April _22,- 1989, when a temporary low-n
. energy signal; cable was routed from 4KV cabinet 2C to a L
. recorder, there was'no procedural = requirement to perform L
an analysis on cable'trainsL1C and 2C.
f.
'2.
Corrective steosithat have been'taken and the results achieved.
The subject temporary low energy signal cables were
~, _
removed on July 19, 1989.
3.
' Corrective steos-that will be taken to avoid further violations.
-SCE is revising applicable procedures to clearly delineate
.when-an IEEE.384-1977-analysis is required for temporary low energy. cable installations.
These revision will be completed by October-31,.1989.
4.
Date when full como11ance will be achieved.
Full' compliance was achieved on July 19, 1989, when the subject cables were removed.
\\
l l
\\
l