IR 05000206/1988010
| ML13316B914 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/10/1988 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Baskin K SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML13316B915 | List: |
| References | |
| EA-88-099, EA-88-99, TAC-67758, NUDOCS 8806230067 | |
| Download: ML13316B914 (4) | |
Text
0 EUNITED STATES NUCLEAR REGULATORY COMMISSION
REGION V
1450 MARIA LANE, SUITE 210 WALNUT CREEK, CALIFORNIA 94596-5368 JUN o01988 Docket No. 50-206 License No. DPR-13 EA 88-99 Southern California Edison Company Post Office Box 800 2244 Walnut Grove Avenue Rosemead, California 92770 Attention: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering, Safety, and Licensing Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NO. 50-206/88-10)
This refers to the special NRC inspection conducted between February 22 and March 30, 1988, of activities authorized by NRC License No. DPR-13. This inspection included a review of the program implemented at San Onofre Unit 1 Oto meet the environmental qualification (EQ) requirements of 10 CFR 50.49 for electrical equipment important to safety. This inspection identified instances in which important Unit 1 safety equipment had not been properly qualified in accordance with the requirements of 10 CFR 50.49. This inspection was documented in inspection report 50-206/88-10, forwarded to you on April 27, 198 The results of the inspection were discussed during a management conference on March 24, 1988, as documented in inspection report 50-206/88-11, forwarded to you on March 29, 198 The violations described in the enclosed Notice of Violation and Proposed Imposition of Civil. Penalty (Notice) involved a breakdown in your program to ensure compliance with the requirements of 10 CFR 50.49. As a result of this breakdown in controls, at the conclusion of this.inspection, 62 different components affecting important safety and accident mitigating equipment were not included in your EQ program (not included in the master EQ list or that qualification was not maintained due to maintenance/modification activities).
A total of 51 of these unqualified components required modification or replacement to comply with NRC requirements. The safety systems affected included Safety Injection, Feedwater, Auxiliary Feedwater, and Charging and Recirculatio We have concluded that your organization clearly should have known that the above-mentioned components were not environmentally qualified and/or not listed on the master EQ list since: (1) components were installed in the plant or redesigned after you had finalized the master EQ list in 1981 and which components at the time you recognized were required to perform safety-related
functions, but EQ evaluations for these components were not performed; (2) for components involving electrical interactions, you relied on 8806230067 880610 PDR ADOCK 05000206
Southern California Edison C JUN10 1988 electrical interactions reviews, such as for fire protection, but you failed to take reasonable action to assure that these reviews would in fact meet 10 CFR 50.49(b)(2) requirements; (3) components of systems which you recognized as performing safety-related functions or functions to support the operation of other safety-related equipment were not identified for environmental
.
qualification and had a reasonable evaluation been performed, these components would have been identified; and (4) one component was not maintained in the qualified (tested) configuratio The NRC is concerned that, although you had identified several significant EQ deficiencies prior to this NRC inspection (e.g., in September 1987, while performing a single failure analysis), you did not initiate a timely root cause assessment and corrective action program until the issue was raised by the NRC in February 1988. In addition, we are concerned that the EQ violations now of concern seem to reflect adversely on your control of engineering and technical work. Consequently, in your response, please provide an assessment of your controls to assure continuity of responsibility for engineering and technical wor Accordingly, to emphasize the importance of environmental qualification of electrical equipment and of the proper control of plant engineering work, I have been authorized, after consultation with the Director, Office of
Enforcement and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Enclosure 1), in the amount of One Hundred Fifty Thousand Dollars ($150,000) for the violations described in the enclosed Notice. In accordance with Generic Letter 88-07, "Modified Enforcement Policy Relating to 10 CFR 50.49," (Enclosure 2) the violations described in the enclosed Notice have been determined to be moderate, affecting several systems and components, and therefore is considered to be an EQ Category B problem. The base value of a civil penalty for an EQ Category B problem is $150,00 In determining the civil penalty amount,*the NRC considered the four factors set forth in the "Modified Enforcement Policy Relating to 10 CFR 50.49", for escalation and mitigation of the base civil penalty amount. These factors consist of (1) identification and prompt reporting of the EQ deficiencies (+/-50%); (2) best efforts to complete EQ within the deadline (+/-50%); (3)
corrective actions to result in full compliance (+/-50%); and (4) duration of a violation which is significantly below 100 days (-50%).
With respect to the first factor, only 25% mitigation is warranted because while you did identify some of the violations and had in place programs which could have led to the identification of the other violations, you had failed to take advantage of an opportunity to identify additional EQ deficiencies in September 1987 when problems in single failure analyses had pointed out that certain items had not been properly qualified. With respect to the second factor, neither mitigation nor escalation was considered appropriate because while some of your actions in the 1985-1986 time frame were adequate and the
Southern California Edison C JUN 1 C 1988 EQ inspection performed in 1985 generally showed adequate performance, your efforts in the EQ area did not include an evaluation of plant changes made after the development of the master EQ list in 1981. Such an evaluation would have been an integral part of an EQ program which would have represented best efforts to complete EQ within the deadline. With respect to the third factor, 25% escalation was warranted because while you delayed startup from the recent outage, you did not initiate prompt action when significant EQ deficiencies were identified and you had originally proposed to restart the plant while performing the analyses of electrical interactions until the NRC questioned the basis for doing so. With respect to the fourth factor, mitigation is inappropriate because the EQ violations existed in excess of 100 days. After applying the escalation and mitigation factors, the base civil penalty remains unchange You are required to respond to this letter and should follow the instructions specified in the enclosed Notice in preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with 10 CFR 2.790(a), a copy of this letter, the enclosure, and your response will be placed in the NRC Public Document Roo The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51
Sincerely, Re ginlAmnst1ao Enclosures:
1. Notice of Violation and Proposed Imposition of Civil Penalty 2. Generic Letter 88-07 cc w/enclosures:
D. J. Fogarty, Executive Vice President C. B. McCarthy, Vice President (San Clemente)
H. E. Morgan, Station Manager (San Clemente)
06/10/E8 09:40 NRC H1. WHITE FLINT BLD Southern California Edison C Enclosures:
1. Notice of Violation and Proposed Imposition of Civil Penalty 2. Generic Letter 88-07 cc w/enclosures:
D. J. Fogarty, Executive Vice President C. 8. McCarthy, Vice President (San Clemente)
H. E. Morgan, Station Manager (San Clemente)
bcc w/enclosures:
Project Inspector Resident Inspector State of California docket file G. Cook A. Johnson B. Faulkenberry J. Martin D. Persinko, NRR J. Zollicoffer M. Smith PDR SECY CA JMTaylor, DEDRO JLieberman, OE LChandler, OGC HWong, OE JMartin, RV Enforcement Coordinators RI, RII, RIII, RIV, RV TMurley, NRR BHayes,
SConnelly, OIA EJordan, AEOD FIngram, PA EA File Day File DCS fdE-RA:RV
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. E HWong JMartin LChandler JLi rman J
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