ML081150838
| ML081150838 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/23/2008 |
| From: | Chamberlain D NRC/RGN-IV/DRP |
| To: | Rosenblum R Southern California Edison Co |
| References | |
| EA-08-142, EA-08-143 IR-07-005 | |
| Download: ML081150838 (6) | |
See also: IR 05000361/2007005
Text
UNITED STATES
NU CLE AR RE GU LATOR Y C O M M I S S I O N
R EGI ON I V
611 R YAN PLAZA D R IV E, SU ITE 400
AR LI N GTON , TEXAS 76011-4005
April 23, 2008
Richard M. Rosenblum
Senior Vice President and
Chief Nuclear Officer
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
SUBJECT: RESPONSE TO NOTICE OF VIOLATION REPLY AND DENIED VIOLATIONS
NRC INSPECTION REPORT 05000361-362/2007005
Dear Mr. Rosenblum:
Thank you for your March 24, 2008 letter of reply (ADAMS; ML0809100650) to our
February 13, 2008 inspection report (ML080440436) and Notice of Violation (NOV)
concerning the failure to preclude repetition of the premature tripping of thermal overloads
for safety-related equipment. Enclosure 2 of your reply contained a request for withdrawal of
noncited violation NCV 05000362/2007005-02, Failure to Implement Procedural
Requirements for Modifications in the Auxiliary Feedwater Steam Supply Trench.
Enclosure 3 of your reply contained a request for conversion of NCV 05000361;
05000362/2007-005-01, Failure to Properly Implement Maintenance Rule Requirements for
Emergency Diesel Generators, to a minor violation.
We have reviewed your reply to the NOV and find it responsive to the concerns. We will
review the implementation of your corrective actions during a future inspection to determine
that full compliance has been achieved and will be maintained.
We have also reviewed the denial of the two other noncited violations. Our comments and
conclusions are addressed below.
NCV 05000362/2007005-02, Failure to Implement Procedural Requirements for Modifications
in the Auxiliary Feedwater Steam Supply Trench:
The referenced report stated:
"TS 5.5.1.1 requires that written procedures be established, implemented, and
maintained for activities specified in Appendix A, Typical Procedures for Pressurized
Water Reactors and Boiling Water Reactors, of Regulatory Guide 1.33, 'Quality
Assurance Program Requirements (Operations), dated February 1978. Regulatory Guide 1.33,
Appendix A, Section 9.e recommends general procedures for the control of
maintenance and modification work. Contrary to this requirement, on May 11, 2007, the
licensee failed to implement appropriate procedures to control modification work in the
Southern California Edison -2-
Unit 2 auxiliary feedwater steam supply trench to ensure the trench would not fill up with
water and render the Unit 2 turbine-driven auxiliary, feedwater pump inoperable."
In Enclosure 2 of your reply, you stated there were four reasons that you requested withdrawal
of the above noncited violation. They were:
- You stated that 10 CFR Part 50, Appendix B, and Regulatory Guide 1.33 were not
applicable, because the trench eductor was not safety-related;
- You stated there was no indication that the sump pump would not perform its function;
- You indicated the temporary modification followed your stations procedures; and
- You stated the NRCs postulated scenario was highly unlikely.
The regional staff, in consultation with NRCs Office of Enforcement, has reviewed these
reasons and the supporting information. We have concluded that the original noncited violation
is still applicable (EA-08-142). Specifically:
- While the eductor, and the temporary sump pump, would not be considered safety-
related components themselves, the auxiliary feedwater (AFW) pump is considered a
safety-related component. The violation comes from our concern with the adequate
confidence of the safety-related pumps operation. It is apparent that keeping the trench
from filling up with water, and rendering the AFW pump inoperable, is important to
safety. In your response you stated you recognized that the AFW pump operation would
be adversely affected if the trench filled. You therefore installed equipment to control
level in the trench, and you provided operator rounds to check its status. We concluded
that Regulatory Guide 1.33, specifically, Section 9.e that recommends procedures to
control modification activities, is applicable to this issue and required by Technical
Specification 5.5.1.1.
- We determined that the inspectors conclusion, that conditions could exceed the
temporary sump pumps operating limits, was reasonable. The inspector verified the
vendor specified limit of the temporary sump pump was 140°F. As you stated in your
response, your as-found readings were 133 and 134°F. We believe that minor variations
in the amounts and source of the leakage could reasonably cause the 140°F limit value
to be exceeded.
- We concluded that your evaluation of the environmental conditions of the modification,
while it may have been conducted under your procedure or process, was inadequate.
Again, your temporary modification review did not identify that the vendor limit of the
pump could be exceeded. Nor did it address that if it failed it could cause the failure of
the safety-related AFW pump. Consequently, we still conclude that you did not
adequately implement your temporary modification process in that the engineering
evaluation of the modification was inadequate.
- We concluded that the postulated scenario was possible. We also found some
statements in your letter to be confusing. You stated that at the time of the report, the
only appreciable leak present was 1 drop per second (from a 1/2 inch globe valve), and
Southern California Edison -3-
that the trenchs volume was 32 cubic feet. You stated it would take months to fill up the
trench. However, you then stated that operators had been operating the sump pump for
several minutes every three or four days. You also stated that if leakage and water
accumulation had become excessive, operators could have taken additional corrective
actions to address the problem. However, with there being about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> between
operator rounds, excessive leakage would probably result in the trench filling. We
calculated that a leak rate of approximately 0.33 gallons per minute would fill the trench
in less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> calling into question the operability of the AFW pump.
NCV 05000361;05000362/2007005-01, Failure to Properly Implement Maintenance Rule
Requirements for Emergency Diesel Generators:
The referenced report stated:
"The inspectors identified a Green noncited violation of 10 CFR 50.65(a)(2) associated with the
failure to include Units 2 and 3 emergency diesel generator (EDG) automatic voltage
regulator (AVR) deficiencies as functional failures in the maintenance rule program. The
inspectors noted that the voltage regulator deficiencies should have placed the emergency
diesel generators into Maintenance Rule 10 CFR 50.65(a)(1) status approximately 6 months
after the failures occurred. This caused a lapse in the determination of appropriate system
monitoring and goal setting to maintain system reliability."
In Enclosure 3 of your reply, you stated you agreed the emergency diesel generator component
failures should have been classified as a Maintenance Rule Functional Failure (MRFF), and the
system should have been placed into 10 CFR 50.65(a)(1) goal setting. However, you further
stated you believed this was a minor violation. You therefore requested we withdraw the
noncited violation.
The regional staff, in consultation with NRCs Office of Enforcement, has reviewed your request
and the supporting information. We have concluded that the original noncited violation is still
applicable (EA-08-143). Specifically:
Section 7 of NRC Manual Chapter 0612, Appendix E, Maintenance Rule Examples,
indicates that violations involving 10 CFR 50.65(a)(1) are almost never minor because
licensees only carry maintenance rule SSCs in (a)(1) status when there have already
been significant equipment problems. Violations of 10 CFR 50.65(a)(2), involving the
failure to demonstrate effective control of performance or condition and not putting the
affected SSC in (a)(1), are not minor because they necessarily involve degraded SSC
performance or condition.
We concluded that the emergency diesel generators are very important to the safe
operation of San Onofre Nuclear Generating Station. The fact that functional failures in
these systems were not reviewed for proper system goal setting (i.e., consideration
under 10 CFR 50.65(a)(1) status) for 6 months was therefore a violation of more than
minor significance.
Based on our reviews, as described above, the NRC has concluded that both of the original
noncited violations are still applicable.
Southern California Edison -4-
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be
made available electronically for public inspection in the NRC Public Document Room or from
the Publicly Available Records (PARS) component of NRCs document system (ADAMS),
accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Dwight D. Chamberlain, Director
Division of Reactor Projects
Docket: 50-361/362
License: DPF-10/15
cc:
Chairman, Board of Supervisors
County of San Diego
1600 Pacific Highway, Room 335
San Diego, CA 92101
Gary L. Nolff
Assistant Director-Resources
City of Riverside
3900 Main Street
Riverside, CA 92522
Mark L. Parsons
Deputy City Attorney
City of Riverside
3900 Main Street
Riverside, CA 92522
Dr. David Spath, Chief
Division of Drinking Water and
Environmental Management
California Department of Health Services
850 Marina Parkway, Bldg P, 2nd Floor
Richmond, CA 94804
Michael J. DeMarco
San Onofre Liaison
San Diego Gas & Electric Company
8315 Century Park Ct. CP21G
San Diego, CA 92123-1548
Southern California Edison -5-
Director, Radiological Health Branch
State Department of Health Services
P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414
Mayor
City of San Clemente
100 Avenida Presidio
San Clemente, CA 92672
James D. Boyd, Commissioner
California Energy Commission
1516 Ninth Street (MS 34)
Sacramento, CA 95814
Douglas K. Porter, Esq.
Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, CA 91770
A. Edward Scherer
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Mr. Steve Hsu
Department of Health Services
Radiologic Health Branch
MS 7610, P.O. Box 997414
Sacramento, CA 95899-7414
Mr. James T. Reilly
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Chief, Radiological Emergency Preparedness Section
National Preparedness Directorate
Technological Hazards Division
Department of Homeland Security
1111 Broadway, Suite 1200
Oakland, CA 94607-4052
Ross T. Ridenoure
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Southern California Edison -6-
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (Clyde.Osterholtz@nrc.gov)
Branch Chief, DRP/D (Michael.Hay@nrc.gov)
Senior Project Engineer, DRP/D (Greg.Werner@nrc.gov)
Senior Project Engineer, DRP/D (Geoff.Miller@nrc.gov)
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Only inspection reports to the following:
D. Adams, OEDO RIV Coordinator (John.Adams@nrc.gov)
ROPreports
SO Site Secretary (Heather.Hutchinson@nrc.gov))
SUNSI Review Completed: _JAC__ ADAMS: Yes No Initials: _JAC_
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
R:\_Reactors\SONGS\2008\SONGS NOV Reply 03-24-2008.doc ADAMS ML081150838
C:DRP/E C:DRP/D ACES/OE D:DRP
JAClark MCHay GMVasquez DDChamberlain
/RA/ /RA/ /RA/ /RA/
04/14/2008 04/14/2008 04/22/2008 04/23/2008
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax