IR 05000361/1998005
| ML20247P505 | |
| Person / Time | |
|---|---|
| Site: | San Onofre |
| Issue date: | 05/21/1998 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML20247P510 | List: |
| References | |
| 50-361-98-05, 50-361-98-5, 50-362-98-05, 50-362-98-5, EA-98-226, EA-98-227, NUDOCS 9805280031 | |
| Download: ML20247P505 (6) | |
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UNITED STATES l
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NUCLEAR REGULATORY COMMISSION
SUBJECT:
NRC SPECIAL INSPECTION REPORT 50-361/98-05; 50-362/98-05
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Dear Mr. Ray:
This refers to the inspection conducted on March 23 through April 17,1998, at your San Onofre Nuclear Generating Station, Units 2 and 3 reactor facilities. The purpose of the inspection was to review the circumstances surrounding the inoperability of the Unit 2 turbine-driven auxiliary feedwater pump, discovered in December 1997, and the apparent inoperability of both trains of the emergency core cooling system in January 1998. The enclosed report presents the results of this inspection.
Based on the inspection findings discussed in Section E8 of this report, one apparent violation was identified (EA 98-226). It is being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. The apparent violation involved the concurrent inoperability of both trains of the Unit 2 emergency core cooling and containment spray systems, a condition which resulted in the loss of the ability to perform a safety function for approximately 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br />. The "B" trains of these systems were made inoperable as a result of corrective maintenance which was initiated on the "B" component cooling water heat exchanger; the
"A" trains were found, after the fact, to have been inoperable as a result of the inoperability of emergency sump outlet valve,2HV9305. The circumstances surrounding this apparent violation, the significance of the issues, and your corrective actions were described in Licensee Event Report 50-361/1993-003-00 and in a letter to the NRC dated April 7,1998. Additionally, these issues were discussed with members of your staff at the inspection exit meeting on April 17,1998, and during a subsequent telephone call on May 19,1998.
In your April 7 letter, you stated that the inoperability of the motor-operated emergency sump outlet valve was due to a failure of the associated reversing linestarter. You also stated that the failure mechanism has been attributed to soil stabilization activities outside of the Protected Area, circa 1980, which generated a fine aerosol grit, and that the presence of the grit could not
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l have been identified by accepted industry quality assurance inspection techniques.
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Southem Califomia E'dison Co.
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We believe that the NRO is aware of the technical information related to the actions taken in response to this occurrence; however, there remain questions conceming the quality assurance l
controls that were required and the actions that were in place to preserve and protect the l
' equipment during the time when the grit was introduced into the linestarters. As you know, the
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NRC's Enforcement Policy states in Section VI.A that licensees are not ordinarily cited for
. violations resulting from' matters not within their control, such as equipment failures that were not avoidable by reasonable licensee quality assurance measures or management controls. For this reason, the NRC needs to understand the totality of opportunities which you had to preclude, detect and correct the condition. Additionally, it is essential to also understand whether other equipment may be affected by the presence of the grit.
To reach an appropriate regulatory decision, it may or may not be necessary to conduct a predecisional enforcement conference. Therefore, before the NRC makes its enforcement decision, we are providing you an opportunity to either: (1) respond in writing to the apparent violation addressed in this inspection report within 30 days of the date of this letter, or (2) -
I request a predecisional enforcement conference. Whether you respond in writing or request a conference, please provide additional information to support your position that this was not a matter that was avoidable by reasonable quality assurance measures or management controls.
. Additionally, we request that you provide your perspective on whether there were prior opportunities to detect and correct the condition that rendered the linestarter inoperable, and whether other equipment could be affected by this condition. Please contact Dennis Kirsch at
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(925) 975-0290 within 7 days of the date of this letter to notify the NRC of your intended method.
. of response.
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If you respond in writing, your response should be clearly marked as a " Response to an
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Apparent Violation in inspection Report Nos. 50-361/98-05 and 50-362/98-05" and should :
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include (1) the reason for the apparent violation, or, if contested, the basis for disputing the j
apparent violation, (2) the corrective action steps that have been taken and the results achieved,
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. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response should be submitted under oath or affirmation and i
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may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response. If an adequate response is not received within the l
time specified or an extension of time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a predecisional enforcement conference.
In addition, please be advised that the number and characterization of apparent violations described in the enclosed inspection report may change as a result of further NRC review. You.
l will be advised by separate correspondence of the results of our deliberations on this matter,~
l in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and your response (if you choose to provide one) will be placed in the NRC Public
L Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without '
redaction.
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l Southem Califomia Edison Co.
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Sincerely,
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s P. S, n;n rector s'
Division of Reacto(Projects Docket Nos.: 50-361
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50-362 License Nos.: NPF 10
. NPF 15 dnclosure; Inspection Report 50-361/98-05; 50-362/98-05 cc w/ enclosure:
Chairman, Board of Supervisors l
County of San Diego l
1600 Pacific Highway, Room 335 San Diego, Califomia 92101
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Alan R. Watts, Esq.
Woodruff, Spradlin & Smart l
701 S. Parker St. Suite 7000
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l Orange, Califomia 92868-4720 Sherwin Harris, Resource Project Manager Public Utilities Department
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City of Riverside 3900 Main Street l-Riverside, Califomia 92522 i
R. W. Krieger, Vice President
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Southem Califomia Edison Company l
San Onofre Nuclear Generating Station P.O. Box 128 l
San Clemente, California 92674-0128 l
l Stephen A. Woods, Senior Health Physicist
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Division of Drinking Water and Environmental Management Nuclear Emergency Response Program California Department of Health Services P.O. Box 942732, M/S 396 Sacramento, Califomia 94334-7320 t
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Southem Califomia Edison Co.
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Mr. Gary D. Cotton, Sr. Vice President Energy Supply
. San Dego Gas & Electric Company P. O. Box 1831 San Diego, Califomia 92112-4150 Mr. Steve Hsu
Radiological Health Branch State Department of Health Services I
P.O. Box 942732 Sacramento, Califomia 94234 Mayor City of San Clemente 100 Avenida Presidio San Clemente, Califomia 92672
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Mr. Truman Bums \\Mr. Robert Kinosian Califomia Public Utilities Commission 505 Van Ness, Rm. 4102 San Francisco, Ca!!fomia 94102
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Southern California Edison Co.
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