ML20050D277
| ML20050D277 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/29/1982 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20050D269 | List: |
| References | |
| NUDOCS 8204120122 | |
| Download: ML20050D277 (4) | |
Text
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Southem Califomia Edison Comha?1$4R 3,1
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ROSEMEAD, CALWORNIA 91770 T. PAPM v.cre <,on,
March 29, 1982 U. S. Nuclear Regulatory Commission Of fice of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, Ca. 94596-5368 Attention:
Mr. R. H. Engelken, Director Docket No. 50-206 San Onofre - Unit 1
Dear Mr. Engelken:
Your letter of March 3,1982 forwarded IE Inspection Report No. 50-206/82-04 and a Notice of Violation resulting from the January 4-29, 1982 routine surveillances of the Resident Inspector.
Enclosure (I) of this letter provides our response to the Notice of Violation contained in Appendix A of the subject report.
If I trust the enclosure responds adequately to all aspects of the Violation.
you have any questions or if we can provide additional information, please let me k n ow.
Subscribed on this S7 day of
, 1982.
g[ A vf,* CAUTORm[ } $$
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(.""' h L. T. Papay Vice Presiden Southern California Edison Conpany Subsc7ggworn togefore me this 23 day,of((a rc/,1982.
1 omcllhT' fC l^ ' f' y l " W /
L WM. R. HORSLEY
' NOWY PUBUC CAur0W A Nota ry Public in and~foffthe County 1 h-F*[gogg j
of Los Angeles, State of California g,
g My Commission Expires Dec 16.1993 +
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Enclosure I L. F. Miller (NRC Site Inspector - San Onofre Unit 1) cc:
8204120122 820405 PDR ADOCK 05000206 0
P{ER
ENCLOSURE I Response to the Items of Non-Corpliance identified in Appendix A to IE Inspection Report 50-206/82-04.
ITEM A "10 CFR 50 Appendix B, ' Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. '
Criterion III, Design Control, requires that field changes shall be subject to design control measures commensurate with those applied to the original design; and Criterion XI, Test Control, requires testing to demonstrate that systems will perform satisfactorily in service.
The licensee's Quality Assurance Manual implements these requirements in Paragraph 5.1.1 by endorsing ANSI N 18.7-1976. Paragraph 5.2.7 of that standard requires that means for assuring the quality of modification activities and measures to document the performance thereof shall be established.
Contrary to these requirements, the seal flushing line to each refueling water pump (line 8007 on Drawing 568776-17) was cut between April 25,1980, and January 18, 1981, thereby creating two unmonitored potential leakage points from the recirculation loop outside of containment. No design review or post-modification testing was performed for this modification.
This is a Severity Level 4 violation.
(Supplement I)"
RESPONSE
1.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED A Proposed Facility Alteration was approved on January 20, 1982 in accordance with the requirements of Engineering Procedure 50123-V-4.14 for the removal of piping associated with the abandoned seal water supply lines to the Refueling Water Pumps.
The seal water supply block valves and attached piping were removed and a threaded plug installed in each pump casing.
The existing cut ends of the remaining portions of the seal water supply lines were closed off with threaded pipe caps and the piping abandoned in place.
The work associated with this f acility alteration was completed on January 21, 1982. The installation of the plugs in the pump casings eliminates these potentially unmonitored leakage paths for the recirculation loop outside containment.
Prior to the commencement of any modification activities, a test was conducted to determine if there was any leakage from the cut piping with the Refueling Water Pumps in operation.
No leakage was observed.
O ENCLOSURE I RESPONSE TO ITEM A (continued) 2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-C OMPLI ANCE Although previous design control procedures provided adequate guidance for planned modification review, implementation and testing, they were not properly conplied with for the incident identified in the subject Notice of Violation. Engineering Procedure S01-V-3.11, " Proposed Facility Change", issued Janua ry 27, 1982, is the current design control procedure for Unit I and supercedes previous versions.
This procedure facilitates the implementation of both major and minor plant modifications by describing the requirements and detailing the entire process for initiation, review and approval of proposed changes.
Adherence to the guidance and instructions contained in S01-V-3.11 will ensure that all modifications to plant equipment are reviewed, approved and completed properly.
To further enphasize the need for procedural compliance, the Maintenance Department will conduct documented training on proposed facility change control.
The Engineering Department will provide a written memo to all their personnel on this same subject requiring the exercise of careful discipline even for minor changes such as the one identified in the notice of violation. These items will be acconplished by May 21, 1982.
The response to this Notice of Violation will be reviewed by the Onsite Review Committee to provide additional managerial emphasis on the avoidance of problems of this type.
This review will be accomplished by May 21, 1982.
3.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on January 21, 1982 when approved modifications to the Refueling Water Pump seal water supply lines were conpleted and documented in accordance with existing procedu ral requirements.
t
ENCLOSURE I '
ITEM B
" Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained that meet or exceed the i
requirements and recommendations of Section 5.1 and 5.3 of ANSI N 18.7-1976, ' Administrative Controls for Nuclea r Power Plant s. ' ANSI N 18.7-1976, Paragraph 5.3.2, ' Procedure Content,' requires that proce-dures contain, where applicable, acceptance criteria against which the i
success or f ailure of test-type activity would be judged.
Contrary to this requirement, the reactor plant instrument calibration procedure, 501-II-1.4, performed in May and June,1981, did not cortain acceptance criteria for instrumentation trip setpoints.
This is a Severity Level l
5 violation. (Supplement I)"
i
RESPONSE
1.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED San Onofre Nuclear Generating Station Unit 1 Instrument and Test Procedure S01-11-1.4, " Reactor Plant Instrumentation Calibration (Refueling Interval)," Revision 6, was issued on March 4,1982 to include instrumentation trip setpoints and associated acceptance criteri a.
2.
CORRECTIVE. STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF i
NON-COMPLI ANCE A review is in progress of all other I t, C Technical Specifica-tion Calibration procedures to locate other cases where this condition may exist.
Corrections will be made if other cases are encountered.
The necessity to include set points and associated acceptance criteria will be reviewed with the recently organized Station l
Procedires Group to ensure that information of this type is included in future test procedures and revisions.
3.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l
Full corpliance was achieved on March 4,1982 with the issuance of Revision 6 to Instrument and Test Procedure S01-11-1.4,
" Reactor Plant Instrumentation Calibration (Refueling Interval)".
1 The procedure review will be conpleted by June 16, 1982.
3785
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