ML20248C361

Notice of Violation from Insp on 980315-0425.Violation Noted:Instrument & Control Technicians Failed to Implement Procedure SO123-II-9-3

ML20248C361
Person / Time
Site:	San Onofre
Issue date:	05/27/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20248C337	List: IR 05000361/1998004 ML20248C333 ML20248C361
References
50-361-98-04, 50-361-98-4, 50-362-98-04, 50-362-98-4, NUDOCS 9806020131
Download: ML20248C361 (3)

Text

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ENCLOSURE.1 -

NOTICE OF VIOLATION Southern California Edison Co. Docket Nos.: 50-361 San Onofre Nuclear Generating Station 50-362 License Nos.: NPF-10 NPF-15 During an NRC inspection conducted on March 15 through April 25,1998, four violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. - Unit 3 Technical Specification 5.5.1.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 133,

Appendix A, recommends procedures for procedure adherence.

l Procedure SO123-0-20, "Use of Procedures," Revision 6, Step 6.2.12, states, in part, that procedure steps shall be followed in the exact sequence written unless otherwise l allowed. Procedure SO23-3-3.31.9, "RCS Pressure Isolation Valve Testing Hydro Pump l Method Cold Shutdown and Refueling Interval," Revision 4, in part, included four steps, l Steps 2.9.7 through Steps 2.9.10, that were required to be performed in the exact sequence as written.

, Contrary to the above, on March 24,1998, two reactor operators failed to perform

! Procedure SO23-3-3.31.9, Steps 2.9.7 through 2.9.10, in the enact sequence as written, and instead performed Steps 2.9.9 and 2.9.10 prior to Step 2.9.7. This action resulted in a slight draining and depressurization of two safety injection tanks.

This is a Severity Level IV violation (Supplement 1) applicable to Unit 3 (Violation 362/98004-03). 1 i

B. Unit 2 Technical Specification 5.5.1.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in l Regulatory Guide 1.33, Revision 2 Appendix A, February 1978. Regulatory Guide 1.33,

Appendix A, recommends procedures for maintenance.

l l Procedure S0123-11-9.3, "Foxboro Spec 200 Micro System Verification and l Configuration," Temporary Change Notice 3-1, Step 6.1.7, states, "As required by the

! Maintenance Order, perform only the applicable subsections .

Maintenance Order 98021495 directed, in part, to investigate a report that Controller 2 HIC 0100A showed no indication for valve controller demand and that the signal indicated greater than 15 percent. ,

Contrary to the above, on March 5,1998, Instrument and Control technicians failed to i implement Procedure SO123-ll-9.3. The technicians performed Section 6.5, l 9906020131 990527

PDR ADOCK 05000361 ,

I G PDR I

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" Downloading a CCC Database From a Disk to a Controller," which was not a section applicable to Maintenance Order 98021495, in order to investigate the report that Controller 2 HIC 0100A showed no indication for valve controller demand and that the signalindicated greater than 15 percent. The error resulted in a complete loss of automatic pressurizer pressure control.

This is a Severity Level IV violation (Supplement 1) applicable to Unit 2 (Violation 361/98004-04).

C. 10 CFR 50.59(b)(1) requires, in part, that the licensee shall maintain records of changes to the facility to the extent that these changes constitute changes to the facility as described in the safety analysis report. These records must include a written safety evaluation that provides the bases for the determination that the cha.%e does not involve an unreviewed safety question.

The Updated Final Safety Analysis Report, Table 5.2-4, " Reactor Coolant System Materials," includes a list of steam generator materials and does not include cord in the steam generator tube.

Contrary to the above, on March 20,1998, the licensee made s change to the steam generator configuration, as described in the Updated Final Safety Analysis Report, by leaving approximately 60 feet of cord material containing low levels of corrosives in a steam generator tube being plugged, and did not perform a written safety evaluation.

Subsequently, the licensee performed a unit startup on March 27,1998, and, after questioning by inspectors, performed an evaluation on April 1,1998.

This is a Severity Lovel IV violation (Supplement 1) applicable to Unit 3 (Violation 362/98004-05).

D. Unit 3 Technical Specification 5.5.1.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, recommends procedures for contamination control.

Procedure SO123-Vil-20.10.6, "High Contamination Area Control," Revision 1, Step 6.5.2.1 directs personnel to " survey contaminated tools and equipment removed from high contamination areas or contamination area buffer zones not contaminated with hot particles for distributed contamination" in accordance with the licensee's surveying procedure.

Contrary to the above, on March 16,1998, contract maintenance workers removed tools from a high contaminated area and did not have the tools surveyed for distributed

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contamination until prompted by the inspectors.

This is a Severity Level IV violation (Supplemertt IV) applicable to Unit 3 (Violation 362/98004-06).

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O The NRC has concluded that information regarding the reasons for the violations, the corrective actions taken and planned to correct the violations and prevent recurrences, and the date when full compliance was achieved are already adequately addressed on the docket in NRC Inspection Report 50-361: 362/98-04. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, you are required to submit a written statement or explanation to the U.S. Nuclear R' .ulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 wnn a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice of Violation (Notice), 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 applicable violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (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. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time. 1 If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response, if any, will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal mrivacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the

! disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

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Dated at Arlington, Texas  !

this 27th day of May 1998 4

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