IR 05000206/1990008
| ML20042F182 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/30/1990 |
| From: | Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| NUDOCS 9005070350 | |
| Download: ML20042F182 (1) | |
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APR 8 0191D
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Docket Nos.,50-206, 50-361 and 50-362'
Soutbren California. Edison Company l
7'Irvine Operations Center
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23 Parker Street
.Irvine California 92718 Attention: 'Mr; Harold B. Ray,5Vice' President - _
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Nuclear Engineering,, Safety and Licensing Department-Gentlemen:
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Thank you 'for your letter of April l 17,' 1990'-in response to our Notice-of
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Violation and Inspection Report Nos. 50-206/90-08 50-361/90-08, and
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'50-362/90-08,. dated March 19, 1990, informing us of the steps you'have.taken
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Your corrective actions appear satisfactory.and will'be verified during a l
future inspection.
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Your cooperation is apprec'iated.
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Sincerely,
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L G. P. Yuhas, Chief-
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g. Radiological.Protsction-Branch
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.bcc-w/ copy of ltr. dated:4/17/90:
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Resident Inspect'or
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Project Inspector'
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G. Cook-
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y B. Faulkenberry l
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J. Martin L
A. Johnson
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bec w/o_ copy'of ltr._ dated 4/17/90:
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M. Smith J. Zo111 coffer
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REGION V
KPrendergast GPYuhas t/p/90 i /'D/90 R ' UEST COPY EST COPY
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9005070350'900430
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DR ADOCK 05000206 bhh PDC
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Southem Callbmin Edison Company
83 PAMMEM BTMCET
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(MVINE. CALIFORNIA 98716 HAMOLD S. A AY t e ks poson s
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April 17, 1990 i
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8. Nuclear Regulatory Commission Attention Document Control Desk Washington, D.C.
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Gentlemen
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Subject Docket Nos. 50-206, 50-361,-and 50-362
Reply to a Notice of Violation San Onofra Nuclear Generatina Station Unita 1,
2, and 3
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'l Reference Letter, Mr. G. P. Yuhas (NRC) to Mr. Harold B. Ray
(SCE), dated March 19, 1990
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The Reference forwarded NRC Inspection Report No. 90-08 and a Notice of Violation (NOV) resulting from the routine: inspection conducted by Mr. K. M. Prendergast during the period of February-26 through March 2, 1990.
In accordance with 10;CFR 2.201~, the enclosure to this letter provides the Southern california' Edison
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If you have any questions, or if you-require additional
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information, please let me know.
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Sincerely, l
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- Enclosure
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- cot John B. Martin, Regional Administrator, NRC Region V C. W. Caldwell, NRC Senior Resident Inspector, San Onofre
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ENCLOSURE
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REPLY To A NOTICE OF VIOLATION i
Appendix A to Mr. Yuhas' letter dated March 19, 1990, states.in-i part:
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Technical Specification 6.8.1 requires. written procedures'to L
lbe established,-implemented, and maintained covering the
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Emergency Plan implementing-procedure Sol 23-VIII-0.200,
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' Emergency Plan Drills,' Revision 1, dated October-24, 1988,-
Attachment 1, requires:a post-accident campling system r
(PASS) drill to be performed annually.
Contrary'to the above, the licensee-failed to performed
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l (sic) the, annual' PASS drill as required by'the above stated procedure.
The last PASS drill was conducted December 6, 1988.
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j This is a severity level IV violation'(Supplement VIII)."
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RESPONSE
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Ramanna for the violation, if admitted An annual post accident sampling system (PASS) drill', as-
-specified-in Station _ Emergency Plan Implementing Procedure
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80123-VIII-0.200,
"Emergency Plan Drills," was not performed in 1989.
The drill was missed as a result of personnel error-involving the failure to follow So123-VIII-0.200 as written.
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A PASS drill had been planned for late 1989, to'be? held separately from quarterly drills.
The intent of this drill was to satisfy all annual and biennial post accident.
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sampling-related requirements of the San Onofre Nuclear ^
Generating Station (SONGS) Emergency Plan.
Following the last' quarterly drill on October 23, 1989, an internal request was made to cancel the biennial PASS cask portion of the drill for.1989.
In response to this request,
'e the individual cognizant for reviewing' drill requirements failed to refer to So123-VIII-0.200, relying-only on a-l review of the Emergency Plan itself.
This Emergency Plan
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review overlooked the annual post accident sampling procedure drill requirement, consequently, because a i
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Reply to a Notice of Violation
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biennial PASS cask drill had been completed in December
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1988, the 1989 Crill.was cancelled due to-the mistaken belief that only a biennial requirement existed which did
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p not need'to be satisfied until 1990.
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corrective stans'that have baan caken and the results f
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achieved I
l-The individualLwho performed the Emergency Plan review and
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erroneously concluded that no annual post accident sampling
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drill-requirements' existed is no longer employed by-SCE;
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p however, in the future, requests for drill cancellation or postponement will be approved by the manager responsible for c
drill execution.
While investigating the circumstances leading to.the missed
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post. accident sampling drill, Lit was noted that 80123-VIII-0.200 does-not contain all appropriate requirements
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l specified in the Emergency Plan. cS0123-VIII-0.200, l
HRaergency Plan Drills,"' Revision'1, does not address the-E existence of.both post accident. sampling-related drills, l:
each having differing 1 frequencies and specifications:.the L
procedures drill (required annually) and tho' cask drill j-(required biennially).
In recognition of this procedure weakness, a review of.the'
SONGS Emergency Plan has been initiated to ensure all
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required drills have been identified and-properly
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characterized.in implementing ~ procedures. 1Upon completien of the review of the Emergency. Plan, Sol 23-VIII-0.200 will be revised accordingly.
The Emergency Plan review, and resulting changes.to 80123-VIII-0.200,.will'be completed by_
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May 15, 1990.
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Correctiva stens that will be-taken to avoid'further violations
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An annual post accident sampling procedures drill will be completed by May 15, 1990
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Data when full como11ance will be achieved Full compliance will be achieved'on May.15, 1990, by which time the annual post accident sampling procedures drill will have been completed.
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