ML13316C016
| ML13316C016 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/26/1989 |
| From: | Mendonca M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Baskin K SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML13316C017 | List: |
| References | |
| NUDOCS 8906090066 | |
| Download: ML13316C016 (3) | |
See also: IR 05000206/1989011
Text
o
RUNITED
STATES
0
NUCLEAR REGULATORY COMMISSION
REGION V
1450 MARIA LANE, SUITE 210
SWALNUTE
K CAIFORNIA 94596
Docket Nos. 50-206, 50-361, 50-362
Southern California Edison Company
P. 0. Box 800
2244 Walnut Grove Avenue
Rosemead, California 92770
Attention: Mr. Kenneth P. Baskin, Vice President
Nuclear Engineering Safety and Licensing
Gentlemen:
Subject:
NRC Inspection of San Onofre Nuclear Generating Station
This letter refers to the inspection conducted by Mr.. C. W. Caldwell of this
office on March 13 through 17 and April 3 through 7, 1989, of activities
authorized.by NRC License Nos. DPR-13, NPF-10, and NPF-15 and to the discussion
of our findings held by Mr. Caldwell with Mr. H. E. Morgan and other members of
the San Onofre staff at the conclusion of the inspection.
Areas examined during this inspection are described in the enclosed inspection
report. Within these areas, the inspection consisted of selective
examinations of procedures and representative records, interviews with
personnel, and observations by the inspector.
Based on the results of this inspection, it appears that one of your
activities was not conducted in full compliance with NRC requirements, as set
forth in the Notice of Violation, enclosed herewith as Appendix A.
Your response to this Notice is to be submitted in accordance with the
provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violation.
As discussed in Paragraph 4.a of the enclosed report, concerns were raised
regarding conditions related to a 10 CFR Part 21 Report on unqualified connectors
for the excore neutron monitors. In particular, it did not appear that a
sufficiently critical evaluation was made of the operability of the excore
neutron monitors during a design basis accident, nor were suitable compensatory
measures established as follows:
-
The justification for continued operation credited alternate instrumentation
for accomplishing the safety function despite the fact that none of the
alternate instrumentation (for monitoring other process variables) provides
real-time core reactivity information.
-
No administrative controls were established to ensure proper post-accident
reactivity monitoring (e.g., control room operators were not notified of
the potential for these monitors to fail during post accident conditions).
In addition, there did not appear to be a sufficiently critical review by safety
oversight groups of the nonconformance report (NCR) that was issued for this
condition. These concerns were discussed during the exit meeting conducted on
March 17, 1989 in which SCE committed to revising the NCR and providing
justification for continued operation (UCO) with the excore neutron monitors
inoperable for post accident conditions.
8906090066 890526
ADOCK 05000206
R
0
PNU
-2-
!S~
~
A revised NCR was sent to the NRC on March 23, 1989. It was reviewed and also
considered inadequate in that the safety evaluation and JCO relied on
Technical Specification instrumentation/parameters for post-accident monitoring
that were considered during the original safety analysis. This did not
account for the fact that the excore neutron monitors were designated as the
primary core reactivity monitoring instrumentation per SCE's commitments to
Regulatory Guide 1.97. In addition, the NRC was concerned that the final
disposition of the revised NCR identified that these unqualified connectors
would be repaired or replaced as necessary prior to return to service from the
Cycle V refueling outage. This was not considered prudent in light of the
fact that the next refueling outage for Unit 3 is scheduled for fall 1990.
These concerns were discussed in the followup exit meeting of April 10, 1989.
During that meeting, SCE representatives committed to perform a reevaluation
of the ability of other designated equipment to accomplish the safety function
of monitoring core reactivity and to reassess the plans for repair or replacement
of the unqualified connectors. The licensee revised the NCR and JCO to
implement compensatory measures and to inspect/replace (as necessary) the
connectors during the next outage of sufficient duration after receiving a
qualified unit. The revised NCR and JCO were reviewed by the NRC on
April 14, 1989 and found acceptable.
In accordance with 10 CFR 2.790 (a), a copy of this letter and the enclosure
will be placed in the NRC Public Document Room.
The response directed by the accompanying Notice is not subject to the
clearance procedures 6f the Office of Management and Budget as required by the
Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely,
M. M. Mendonca, Acting Chief,
Reactor Projects Branch
Enclosure:
1. Appendix A, Notice Of Violation
2. Inspection Reports
Nos. 50-206/89-11
50-361/89-11
50-362/89-11
cc w/Enclosures:
Dr. L. T. Papay, Senior Vice President
D. J. Fogarty, Executive Vice President
C. B. McCarthy, Jr., Vice President - Site Manager (San Clemente)
H. E. Morgan, Station Manager (San Clemente)
State of California
Region V,?
-
VI
CCaldweT
PJ
n"
on
AJohnson
MMendonca
5/2/89
5/44&/89
5/
/89
5//,/89
ST COPY] JEQST COPY] [R
EST COPY
EST COPY
KYES /N~. YES // NO
(ES/ /NO
YES /NO
YES/N
bcc w/enclosures:
Project Inspector
Resident Inspector
docket file
G. Cook
A. Johnson
B. Faulkenberry
J. Martin
R. Nease, NRR
bcc w/o enclosure 2:
M. Smith
J. Zollicoffer