IR 05000361/1996014
| ML20148D282 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/27/1997 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| 50-361-96-14, 50-362-96-14, EA-96-466, NUDOCS 9705300137 | |
| Download: ML20148D282 (4) | |
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SUBJECT:
NRC INSPECTION REPORT 50-361/96-14; 50-362/96-14
Dear Mr. Ray:
Thank you for your letter of April 1,1997, in response to our letter and Notice of Violation dated March 3,1997. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Vk,iation. We will review the implementation of your corrective actions during a fe'ure i:1spection to determine that full compliance has been achieved and will be maintained.
We noted that your response letter stated that the NRC Maintenance Rule Baseline Team inspection was scheduled for July 28,1997. We understand that your staff has been informed that our currently scheduled inspection date is the week of December 1,1997.
Sincerely,
a , k Arthur T. Howell Ill, Director i Division of Reactor Safety Docket Nos.. 50-361; 50-362 License Nos.: NPF-10; NPF-15 cc: Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, California 92101 _ bhllffff , 9705300137 970527 PDR ADOCK 05000361 G PDR
. . , '8 S,udiern California Edison Co.
-2-Alan R. Watts, Esq.
! Woodruff, Spradlin & Smart 701 S. Parker St. Suite 7000 Orange, California 92868-4720 Sherwin Harris, Resource Project Manager Public Utilities Department City af Riverside 3900 Main Street Riverside, California 92522 R. W. K.eger, Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, California 92674-0128 Dr. Harvey Collins, Chief Division of Drinking Water and Environmental Management California Department of Health Services P.O. Box 942732 Sacramento, California 94234-7320 Terry Winter, Manager Power Operations San Diego Gas & Electric Company P.O. Box 1831 San Diego, California 92112 Mr. Steve Hsu Radiological Health Branch State Department of Health Services F.O. Box 942732 Sacramento, California 94234 Mayor City of San C'emente 100 Avenida Presidio San Clemente, California 92672 Mr. Truman Burns \\Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Rm. 4102 San Francisco, California 94102 .. - _ _ _ _ _ _
. . . - Southern California Edison Co.
-3-E-Mail report to T. Boyce (THB) E-Mail report to NRR Event Tracking System (IPAS) E-Mail report to Document Control Desk (DOCDESK) E-Mail report to Richard Correia (RPC) E-Mail report to Frank Talbot (FXT) bec to DCD (IE01) bec distrib. by RIV: Regional Administrator Resident inspector i DRP Director DRS-PSB Branch Chief (DRP/F, WCFO) MIS System Senior Project inspector (DRP/F, WCFO) RIV File Branch Chief (DRP/TSS) M. Hammond (PAO, WCFO) WCFO File G. Sanborn OE Case File: EA 96-466 M. Vasquez DOCUMENT NAME: R:\\SO614AK.CJP To receive copy of document. Indicate in box: "C" = Copy wahout enclosures "E" = Copy with enclosures {N" = N copy RI:MB
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mU O - $OU1Hf RN CALIFORNM R. W. Krieger se E,DISON " " " ""' Nuclear Generation An Lul50N INTtJNATIONAL Company . - _ - l ~ jl[ APR 2 21997 d[;,- April 1,1997 U. S. Nuclear Regulatory Commission [ Document Control Desk L - FEGIONIV -J Washington, D.C. 20555 Subject: Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3 References: (1) Letter from Mr. J. E. Dyer (NRC) to Mr. Harold (SCE), dated March 3,1997 (Notice of Violation, NRC Special Inspection Report 50-361/362 96-14) (2) Letter from Mr. T. P. Gwynn (NRC) to Mr. Harold (SCE), dated December 6,1996 (NRC Inspection Report 50-361/362 96-14) (3) Letter from Mr. Dwight E. Nunn (SCE) to Mr. S. J. Collins, dated January 8,1997 (Request for Additional Information - Maintenance Rule implementation San Onofre Nuclear Generating Station, Units 2 and 3) (4) Letter from Mr. G. T. Gibson (SCE) to Mr. K. E. Brockman (NRC), dated October 31,1996 (San Onofre Nuclear Generating Station's Response to NRC Inspectors Follow-up on Unresolved item (50-361 (362)/96009-03)) s Reference 1 transmitted a Notice of Violation resulting from NRC Inspection Report (IR) No. 50-361/362-96-14 (Reference 2), conducted by Messrs. C. J. Paulk and J. E.
Wittemore on October 20 through November 15,1996, at the San Onofre Nuclear Generating Stat %n, Units 2 and 3. The Notice of Violation contains two cited violations (9614-02 and 04). The violatiens involve: (1) a failure to have adequate smoke / exhaust damper performanca criteria; and (2) a failure to have adequate performance / criteria to monitor reliability for risk significant structures, systems, and components C i (SSC).
.,__/___MM
In accordance with Reference 1, the Enclosure to this letter provides Edison's reply to the Notice of Violation.
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\\ o o . . . - .. ' , ' Document Control Desk-2- , The Reference 1 cover letter states, "In addition, you should address what corrective actions you have taken to enhance management controls over, and awareness of, implementation of your Maintenance Rule program in response to your self-evaluation findings." The self evaluation conducted by San Onofre identified weaknesses in the Maintenance Rule project's management and oversight in monitoring associated activities and schedules.
To address the project management concerns, an inter-divisional middle management team was established to review the existing Maintenance Rule program and identify enhancements to the program. This team (Maintenance Rule Implementation Team) is continuing to identify and implement program enhancements based on industry experience. To enhance management oversight of the Maintenance Rule, a steering committee of division managers was established. This committee provides guidance to ,, and reviews program policies deveicoed by the implementation team.
If you have any questions, please contact me.
Sincerely
' l - Q) . @ Enclosure cc: E. W. Merschoff, Regional Administrator, NRC Region IV A. T. Howell lil, Director, Division of Reactor Safety, NRC Region IV i K. E. Perkins Jr., Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 2 & 3 , M. B. Fields, NRC Project Manager, San Onofre Units 2 & 3 L - - - _ _ _
. O O - - . . . ,' ENCLOSURE , VIOLATION A The enclosure to Mr. J. E. Dyer's letter dated March 3,1997, states, in part: "10 CFR 50.65(a)(1) states, in part, that each holder of an operating license... shall monitor the performance or condition of structures, systems, or components (SSCs) against licensee-established goals.. and that such goals shall be established commensurate with safety.
"10 CFR 50.65(a)(2) states, in part, that monitoring under (a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance such that the SSC remains capable of performing its intended function. Paragraph (c) states that '[t]he requirements of this section shall be implemented by each licensee no later than July 10,1996.' " San Onofre Nuclear Generating Station Procedure S0123-XIV-5.3, ' Maintenance Rule Program implementation,' Revision 0, Temporary Change Notice 0-3, Section 6.3.3, implements, in part, the requirements of (a)(2) above. Section 6.3.3 states, in part, that for nonrisk-significant SSCs the plant level performance criteria will be unplanned automatic reactor scrams, unplanned capability loss factor, unplanned safety system actuation, unplanned shutdown safety functional events, abnormal radiological releases, and core damage frequency.
" Contrary to the above, since September 20,1996, the licensee failed to adequately monitor the performance of the Common Control Room Complex Smoke Exhaust Dampers in that none of the performance criteria designated in Procedure SO123-XIV-5.3 were adequate to demonstrate that the dampers' performance was effectively controlled through appropriate preventive maintenance. (01014) "This is a Severity Level IV violation (Supplement 1). (50-361/9614-02; 50-362/9614-02)" RESPONSE TO VIOLATION A 1. Reason for the Violation As noted in References 3 and 4, the Smoke Dampers were initially scoped within the Control Room HVAC Emergency System. The Control Room HVAC Emergency System was identified as risk significant based on Expert Paneljudgment. However, after a more detailed review, the Expert Panel concluded the smoke dampers did not - l l ,
_ _ _. - - O O - - . . . " Enclosure-2- , , support functions for which the Control Room HVAC Emergency System was judged risk significant. Consequently, the smoke dampers were reclassified as non-risk significant. As such, they were to be monitored under plant level performance criteria.
The reason for the violation was Edison believed the smoke dampers did not require any specific performance criteria because they were non-risk significant. In Reference 3, Edison agreed that the use of plant level performance criteria (i.e., unplanned automatic reactor scrams, unplanned capability loss factor, unplanned safety system actuation, unplanned shutdown safety functional events, abnormal radiological releases, and core damage frequency) was not sufficient to ensure the smoke damper's function would be maintained.
2. Corrective Actions Taken and Results Achieved As noted in Reference 3, Edison has taken corrective action to revise the preventive maintenance program for the smoke dampers. As these are newly initiated activities, the corrective action effectiveness can not yet be assessed.
3. Corrective Actions That Will Be Taken to Avoid Further Violations As committed to in Reference 3, Edison agreed to develop specific criteria for the smoke dampers. In addition, Edison agreed to reexamine our use of plant-level performance criteria. This review will confirm that non-risk significant functions provided by SSCs within the maintenance rule scope are monitored by appropriate plant level or specific performance criteria.
4. Date When Full Compliance Will be Achieved As noted in Reference 3, Edison will be prepared to discuss the smoke damper criteria, and the results of our reexamination of the use of plant-level performance criteria, during the NRC Maintenance Rule baseline inspection currently scheduled for July 28, 1997.
VIOLATION B The enclosure to Mr. J. E. Dyer's letter dated March 3,1997, states, in part: "10 CFR 50.65(a) (1) states, in part, that each holder of an operating license.. shall monitor the performance or condition of SSCs against licensee-established goals. and that such goals shall be established commensurate with safety.
"10 CFR 50.65(a)(2) states, in part, that monitoring under (a)(1) is not required where it has been demonstrated that the performance or condition of a SSC is being effectively L . . _
O O - - . . ' Enclosure-3- , , controlled through the performance of appropriate preventive maintenance such that the SSC remains capable of performing its intended safety function. Paragraph (c) statcs that '[t]he requirements of this section shall be implemented by each licensee no later than July 10,1996.' " Regulatory Guide 1.160, ' Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,' Revision 1, endorses NUMARC 93-01, ' Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,' Revision 0, as an acceptable method for implementing the requirements of 10 CFR 50.65. Regulatory Guide 1.160 states that the methods described in the guide will be used in the evaluation of the effectiveness of maintenance activities of licensees who are required to comply with 10 CFR 50.65 unless a licensee has proposed an acceptable alternative method of compliance.
"NUMARC 93-01, Section 9.3.2, states, in part, that performance criteria for evaluating SSCs are necessary to identify the standard against which performance is to be measured. Criteria are established to provide a basis for determining satisfactory performance... (for SSCs monitored under (a)(2)). Additionally, Section 9.3.2 states that performance criteria for risk significant SSCs be established to assure that reliability and availability assumptions used in the plant specific probabilistic risk assessment, individual plant examination, or other risk determining analysis are maintained or adjusted when necessary.
" Contrary to 10 CFR 50.65(a)(2), as of October 22,1996, the licensee, in choosing the NUMARC approach, failed to demonstrate that the performance or condition of SSCs was effectively controlled through the performance of appropriate preventive maintenance in that the licensee did not demonstrate that the performance criteria used to monitor reliability would ensure that the SSCs remained capable of performing their intended safety function. Specifically, in accordance with NUMARC 93-01, for those risk significant SSCs within the scope of 10 CFR 50.65, the licensee established performance criteria to monitor reliability that neither considered, nor were bounded by, the safety significance defined by the licensee's plant-specific probabilistic risk assessment, individual plant examination, or other risk determining analysis for those SSCs. The licensee had not proposed an acceptable alternative to demonstrate compliance with 10 CFR 50.65(a)(2). (02014) 'This is a Severity Level IV violation (Supplement 1).
(50-361/9614-04;50-362/9614-04)"
O O - - . . , ~ Enclosure-4- , , RESPONSE TO VIOLATION B 1. Reason for the Violation As noted in References 3 and 4, the Maintenance Rule is the first performance-based rule and, as a result, acceptable methods to achieve compliance with the rule were not completely understood between the industry and the NRC. Edison believed it implemented the rule in accordance with industry guidance acceptable to the NRC.
" Edison notes, as evidenced by similar violations at other facilities, the misunderstanding of NRC expectations was generally industry-wide. Edison notes these expectations were not delineated in either 10 CFR 50.65 or Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."
Therefore, the reason for the violation was misunderstanding of NRC expectations.
2. Corrective Actions Taken and Results Achieved A review of recent NRC and industry guidance on the subject was performed. As a result, an understanding was gained of the NRC expectations regarding the linking of reliability performance criteria to the PRA/IPE/IPEEE. Edison now understands a more exact correlation between reliability performance criteria and the PRA is expected.
In order to determine reliability performance criteria commensurate with safety, a plan has been developed to determine the link between counting functional failures and the reliability assumptions used in the PRA for risk significant SSCs at San Onofre. This requires determining the ratio of allowed functional failures to an estimated number of demands and operating hours during a given time period. For those risk significant SSCs having reliability performance criteria not bounded by the PRA, a calculation will be performed to demonstrate that use of the selected reliability performance criteria results in insignificant increases in risk.
3. Corrective Actions That Will Be Taken to Avoid Further Violations Edison continues to maintain initiatives to better understand the NRC's expectations for maintenance rule compliance, including: o attending or monitoring industry meetings (NEl and NRC); o active networking with industry peers; and o monitoring results of the maintenance rule baseline inspections.
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O O - A i Enclosure-5- , , 4. Date When Full Compliance Will be Achieved The linking of the reliability performance criteria to the PRA/IPE/IEEE, and associated procedure changes, are anticipated to be completed by the NRC baseline inspection at San Onofre currently scheduled to begin July 28,1997. }}