ML20135D671
| ML20135D671 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/06/1996 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML20135D674 | List: |
| References | |
| EA-96-466, NUDOCS 9612100084 | |
| Download: ML20135D671 (6) | |
See also: IR 05000361/1996014
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN IV
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611 RYAN PLAZA DRIVE, SUITE 400
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AR LINGToN. T E X AS 760118064
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DEC - 61996
EA 96-466
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Harold B. Ray, Executive Vice President
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Southern California Edison Co.
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San Onofre Nuclear Generating Station
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P.O. Box 128
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San Clemente, California 92674-0128
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SUBJECT: NRC INSPECTION REPORT 50-361/96-14; 50-362/96-14
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Dear Mr. Ray:
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An NRC special inspection was conducted to review resident inspector findings concerning
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the implementation of the Maintenance Rule program at San Onofre. The inspection
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included activities onsite between October 20-25,1996, at your San Onofre Nuclear
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Generating Station, Units 2 and 3 reactor facilities, with continuing in-office review through
November 14,1996. The in-office review primarily focused on a letter dated October 31,
1996, from Mr. G. T. Gibson, Manager, Compliance, to Mr. Kenneth E. Brockman, Acting
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Director, Division of Reactor Safety, in response to a debrief of inspection observations.
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An exit meeting was held onsite on November 15,1996, during which your staff
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acknowledged the failure to document goals for those structures, systems, or components
that did not meet the established performance criteria, but disagreed with the apparent
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violations discussed. The enclosed report presents the scope and results of that
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inspection.
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. As a result of the inspection, including the review of the information provided in your
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October 31,1996, letter, we are concerned that a breakdown in your program for the
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implementation of 10 CFR 50.65, the " Maintenance Rule," occurred, resulting in multiple
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examples of the f ailure to establish goals and performance criteria for structures, systema,
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or components under 10 CFR 50.65 on July 10,1996, and continuing untilidentified by
the NRC resident inspector. This inspection result is disappointing since it appears that
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maintenance performed on equipment has been generally effective. Our concern is the
implementation of your Maintenance Rule program, which is designed to ensure effective
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monitoring of maintenance performance,
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Based on the results of this inspection, three apparent violations were identified and are
being considered for escalated enforcement action in accordance with the " General
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Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),
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NUREG-1600. Accordingly, no Notice of Violation is presently being issued for these
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inspection findings. 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.
9612100084 961206
ADOCK 05000361
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San Onofre Nuclear Generating Station
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We have reviewed yoor staff's disagreement with the apparent violations and determined
that sufficient evider'
of the violations exists to support the need for a predecisional
enforcement contorence. The date for the conference to discuss these apparent violations
will be coordinated with your staff. The decision to hold a predecisional enforcement
conference does not mean that the NRC has determined that a violation has occurred or
that enforcement action will be taken. This conference is being held to obtain information
to enable the NRC to make an enforcement decision, such as a common understanding of
the facts, root causes, missed opportunities to identify the apparent violations sooner,
corrective actions, significance of the issues, and the need for lasting and effective
corrective action.
At the conference, we would like to establish a common understanding of the apparent
violations and the implication of the violations for your overall Maintenance Rule program
implementation. Since NRC has not performed its baseline inspection of the Maintenance
Rule implementation at San Onofre, it is of particular importance that you discuss the
broader implications of the inspection findings. In addition, this is an opportunity for you
to point out any errors in our inspection report and to provide any information concerning
your perspectives on 1) the severity of the violations,2) the application of the factors that
the NRC considers when it determines the amount of a civil penalty that may be assessed
in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other application
of the Enforcement Policy to this case, including the exercise of discretion in accordance
with Section Vll and the application of interim enforcement guidance (see Enclosure 2).
You will be advised by separate correspondence of the results of our deliberations on this
matter. No response regarding these apparent violations is required at this time.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter
and its enclosure will be placed in the NRC Public Document Room (PDR).
Should you have any questions concerning this inspection, we will be pleased to discuss
them with you.
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Sincerely,
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z"lTh'omas P. Gwynn, Dire tor
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Division of Reacto
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Docket Nos.: 50-361;50-362
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San Onofre Nuclear Generating Station
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Enclosure:
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NRC Inspection Report 50-361/96 14;50-362/96-14
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EGM 96-002," Enforcement Guidance Memorandum Interim Guidance for 10 CFR 50.65 - the Maintenance Rule, issued August 21,1996
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cc w/ enclosures:
Chairman, Board of Supervisms
County of San Diego
1600 Pacific Highway, Room 335
San Diego, California 92101
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Alan R. Watts, Esq.
Rourke & Woodruff
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701 S. Parker St. No. 7000
Orange, California 92668-4702
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Sherwin Harris, Resource Project Manager
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Public Utilities Department
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City of Riverside
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3900 Main Street
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Riverside, California 92522
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R. W. Krieger, Vice President
Southern California Edison Company
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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
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San Onofre Nuclear Generating Station
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Mr. Steve Hsu
Radiological Health Branch
State Department of Health Services
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P.O. Box 942732
Sacramento, California 94234
Mayor
City of San Clemente
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
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E-Mail report to Don Taylor (DRT)
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E-Mail report to D. Nelson (DJN)
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E-Mail report to Richard Correia (RPC)
E-Mail report to Don Taylor (DRT)
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L. J. Callan
Resident inspector
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)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
G. F. Sanborn, EO
J. Lieberman (OE, MS:7-H5)
OE:EA File, MS:7-H5
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DOCUMENT NAME: R:\\_SO23\\SO614RP.CJP
To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
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