IR 05000361/1997022
| ML20247K238 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/11/1998 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| RTR-REGGD-01.160, RTR-REGGD-1.160 50-361-97-22, 50-362-97-22, EA-98-035, EA-98-35, NUDOCS 9805220045 | |
| Download: ML20247K238 (5) | |
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SUBJECT:
RESPONSE TO NRC INSPECTION REPORT 50-361/97-22; 50-362/97-22 AND
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DENIAL OF NOTICE OF VIOLATION
Dear Mr. Ray:
This is in reference to your letter dated April 9,1998, in which the Southem Califomia Edison Co. (SCE) denied a violation of 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of j
Maintenance at Nuclear Power Plants." Your letter was in response to a Notice of Violation issued March 2,1998, in, conjunction with NRC Inspection Report 50-361;-362/97-22. The
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violation was concemed with your failure to include in the scope of your program, the nonradioactive sump system. In denying Violation 50-361;-362/9722-01, your cover letter referenced the requirements of NUMARC 93-01, " Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 2, and Regulatory Guide 1.160," Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"
Revision 2. The enclosure specifically referenced NUMARC 93-01, Section 8.2.1.3, in part, and Regulatory Guide 1.160, Rev;sion 2, paragraph 1.1.3.
Your basis for disputing the violation included a characterization of the emergency operating instruction mandated manipulation of this system as a prudent, post-accident cleanup step to minimize the spread of contamination that has already occurred. In previous discussion with l
your staff, our team was informed that failure to direct the sump discharge to the liquid radioactive waste system could result in the release of contaminated liquid and entrained or
dissolved gaseous fission products to the open turbine buildings. The severity of any potential
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release was never quantified to us. In order to conclude that this system need not be included within the scope of the Maintenance Rule, we would need to understand the basis for concluding l
that any potential release would not be significant under the design basis conditions.
i Your letter further stated that Procedure SO1231XIV-5.3.1, " Scoping for the Maintenance Rule,"
requires that a structure, system, or component be placed in scope if it provides "the total, or a substantial fraction of the total * of a mitigation function. It was your opinion that the turbine building sump system would not mitigate an effluent release and that the realignment of the sump discharge was not significant with respect to release mitigation. As indicated above, for us to determine if this system does not require monitoring by your Maintenance Rule program, we request that you provide us the degree of total release mitigation the sump system provides.
g5220045990511 ADOCK 05000361 G
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Southern Califomia Edison Co.
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Additionally, SCE indicated that a radiation monitor and discharge valve provide monitoring, alarm, and isolation of the system from the circulating water system outfall upon elevated radiological readings at the discharge to the outfall. Wa understand and agree with your description of how a release to the circulating water system outfall is terminated. We also note that the monitoring and isolation functions are in the scope of your Maintenance Rule program.
I SCE further stated that you enhanced the program definition of " significance" and "significant I
value"; however, SCE did not provide the specific information about any program changes. We request that you provide details regarding the specific changes made to your program.
SCE's assertion that the realignment of the sump discharge is not significant to release mitigation refers the Safety Evaluation Report, Sections 2.4.9 and 15.4.12. We do not understand how they pertain to the issue under review.
With respect to your violation response, which indicated that the turbine building sump system release mitigation function was placed in scope as of July 10,1996, and removed in October 1997, we note this information was not provided to our inspection team during the onsite portion of the inspection. Please provide us with copies of your records that document these actions.
We request that you provide the information requested above relating to your response to the violation within 30 days of receipt of this letter. If you have questions about this letter, please l
contact Dr. Dale A. Powers at 817/860-8195.
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For your completed and planned corrective actions related to the violation that you were not required to respond to and that you did not dispute, we will review the implementation of those l
corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely, tl h Arthur T. Howell111, Director j
Division of Reactor Safety Docket Nos.: 50-361;50-362 License Nos.: NPF-10; NPF-15 cc:
Chairman, Board of Supevisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, California 92101
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Southem Califomia Edison Co.
-3-Alan R. Watts, Esq.
Woodruff, Spradlin & Smart 701 S. Parker St. Suite 7000 Orange, Califomia 92868-4720 Sherwin Harris, Resource Project Manager Public Utilities Department City of Riverside 3900 Main Street
' Riverside, California 92522-R. W. Krieger, Vice President Southem Califomia Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, Califomia 92674-0128 Stephen A. Woods, Senior Health Physicist Division of Drinking Water and Environmental Management Nuclear Emergency Response Program Califomia Department of Health Services P.O. Box 942732, M/S 396 Sacramento, California 94334-7320 Mr. Gary D. Cotton, Sr. Vice President Energy Supply San Diego Gas & Electric Company P. O. Box 1831 San Diego, Califomia 92112-4150 Mr. Steve Hsu Radiological Health Branch State Department of Health Services P.O. Box 942732 Sacramento, California 94234 Mayor City of San Clemente 100 Avenida Presidio San Clemente, Califomia 92672
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Southern California Edison Co.
-4-Mr. Truman Burns \\Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Rm. 4102 San Francisco, Califomia 94102
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Southern California Edison Co.
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Regional Administrator Resident inspector DRS Director DRS Deputy Director
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DRP Director DRS-PSB
Branch Chief (DRP/F, WCFO)
MIS System Senior Project inspector (DRP/F, WCFO)
RIV File Branch Chief (DRP/TSS)
WCFO File G. Sanbom DE EA File 98-035 RIV Al 98-150 (C. Gordon)
RIV Al 98-150 (C. Goines)
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