ML20138Q048

Discusses Insp Repts 50-361/96-14 & 50-362/96-14 on 961020-1115 & Forwards Notice of Violation

ML20138Q048
Person / Time
Site:	San Onofre
Issue date:	03/03/1997
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Ray H SOUTHERN CALIFORNIA EDISON CO.
Shared Package
ML20138Q050	List: ML20138Q048 ML20138Q078
References
EA-96-466, NUDOCS 9703060096
Download: ML20138Q048 (7)

See also: IR 05000361/1996014

Text

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ga*% uNn Eo STATES

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March 3, 1997  !

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EA 96-466 l

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l Harold B. Ray, Executive Vice President  ;

Southern Califomia Edison Co.  !

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- San Onofre Nuclear Generating Station ,

P.O. Box 128 l

San Clemente, California 92674-0128 l

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SUBJECT: NOTICE OF VIOLATION  !

i (NRC SPECIAL INSPECTION REPORT 50-361/96-14; 50-362/96-14) l

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Dear Mr. Ray: ,

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This refers to the inspection conducted on October 20 through November 15,1996, at the r

San Onofre Nuclear Generating Station, Units 2 and 3 reactor facilities. The purpose of the

l special inspection was to review resident inspector findings concerning the implementation

l of the Maintenance Rule at San Onofre. The findings were discussed with your staff ,

l during an exit briefing on November 15,1996. The subject inspection report documented  ;

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j the NRC's findings and was issued on December 6,1996. A predecisional enforcement

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conference was held in the NRC's Region lY office in Arlington, Texas, on January 3,

1997. Southern California Edison provided further information in its letter to the NRC

dated January 8,1997.

Based on the information developed during the inspection, the information that you

provided during the conference, and the information contained in Edison's January 8 letter,

the NRC has determined that two violations of NRC requirements occurred. These

violations are cited in the enclosed Notice of Violation (Notice) and the circumstances

surrounding them were previously described in detail in the subject inspection report.

Neither of these violations had actual or potential safety significance and there were no

instances where structures, systems, and components (SSCs) failed to perform their

intended safety functions. The NRC has concluded that these violations do not indicate a

programmatic failure to implement the Maintenance Rule. Therefore, each of these

violations have been categorized in accordance with the " General Statement of Policy and

Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600 at Severity

Level IV. )

The first violation cited in the Notice involves the f ailure to adequately monitor the

performance of the common control room complex smoke exhaust dampers in that the

selected plant level performance criteria would not demonstrate approprim and effective

- preventive maintenance to reasonably assure the dampers remained ca; 2 of performing ,

l their intended function (s). Specifically, your staff had inappropriately set plant level criteria  !

as a means for monitoring the functional performance of the smoke dampers. At the

conference, your staff informed us that, for purposes of the Maintenance Rule, the San

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9703060096 970303

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Southern California Edison Co. -2- 1

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Onofre expert panel did not intend to include the smoke dampers as a risk significant l

system and that they had been included inadvertently. However, after questioning by  ;

NRC, you agreed that setting plant level criteria was not an appropriate means of

j monitoring the functional performance of the smoke dampers. As a result, you stated your

l intent to review other SSCs to ensure that appropriate criteria are used to monitor '

l functions. You also stated your intent to review the determination that the function (s) of

the smoke dampers is not risk significant.

The second violation involves the f ailure to demonstrate adequate monitonng. Specifically,

Southern California Edison f ailed to demonstrate that the performance criteria selected to

monitor reliability would ensure that SSCs remained capable of performing their intended

safety functions. At the conference, you disputed this violation and your position was that

Edison had used Probabilistic Risk Assessment (PRA) in almost all phases of the

development of the performance criteria (also stated in your January 8 letter). You also

noted that this issue was generic and more guidance was needed. We have carefully

considered your concerns in evaluating whether enforcement of this issue is warranted,

and have coordinated our decision with the Office of Nuclear Reactor Regulation and the

Office of Enforcement. We note that some licensees inspected (both during Maintenance

Rule pilot visits and subsequent baseline team inspections) have been found complying

with this requirement. Consistent with NRC's past enforcement actions at other plants

with this problem, NRC's position is that enforcement of this requirement is appropriate. l

Therefore, since your performance criteria for applicable risk-significant SSCs neither

explicitly considered nor were bounded by the appropriate risk determining analyses (e.g., l

considering start and run demands), the NRC has determined that citing a Severity LevelIV

{ violation is appropriate. j

At the conference, we also discussed a third apparent violation which involved the ,

apparent failure to have goals and monitoring requirements established and documented for l

13 risk-significant SSCs which had not met their established performance criteria. You I

disputed this violation stating that your goals for these SSCs were to reattain their

performance criteria and that your existing corrective action programs were adequate to

identify and correct the causes of failures. Although reattaining the performance criteria

might be an acceptable specific goal for monitoring the effectiveness of the corrective I

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action, it is not always appropriate. We noted that you did not establish specific goals for

monitoring the effectiveness of the corrective action, but the inspection did not identify a

specific instance where this led to a defective SSC. Noting the enhancements you have

made to your Maintenance Rule implementation through the use of MREs and the

conservative implementation of your program compared with industry guidance (length of i

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time SSCs are monitored), we have decided, in this case, your goals were adequate to

monitor the corrective action. Therefore, no enforcement action is appropriate at this time  ;

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and no citation will be issued; this issue will be identified as an inspection Followup Item

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(IFl 50-361/9614-01:50-362/9614-01), it will be evaluated during the Maintenance Rule

baseline team inspection.

l Regarding Edison's January 8 letter, we noted an area of possible misunderstanding. Ir.

particular, in Enclosure 1 to the letter, the first paragraph in Section lli states that "[dluring

j NRC Maintenance Rule baseline inspections at other sites, Edison believes licensees have

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Southern California Edison Co. -3-

been allowed 30 to 60 days assess [ sic] the SSCs from the end of the calendar quarter."

While some licensees may have been allowed such time to assess the performance of

SSCs,it should be noted that the time allowed for assessment must be consistent with

safety significance, and there are situations where this time period may not be appropriate.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. In addition, you should address what

corrective actions you have taken to enhance management controls over, and awareness

of, implementation of your Maintenance Rule program in response to your self-evaluation

findings. The NRC will use your response, in part, to determine whether further

enforcement action is necessary to ensure compliance with regulatory requirements.

in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,

its enclosure, and your response will be placed in the NRC Public Document Room.

Sincerely,

hW

J. E. Dyer

Acting Regional Administrator

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Docket Nos. 50-361;50-362

License Nos. NPF-10; NPF-15

Enclosure: Notice of Violation

cc w/ enclosure: l

Chairman, Board of Supervisors

County of San Diego

1600 Pacific Highway, Room 335

San Diego, California 92101

Alan R. Watts, Esq.

Rourke & Woodruff

701 S. Parker St. No. 7000 -

Orange, California 92668-4702

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Sherwin Harris, Resource Project Manager

Public Utilities Department

City of Riverside

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3900 Main Street

Riverside, California 92522

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Southern California Edison Co. -4-

R. W. Krieger, Vice President

Southern California Edison Company

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

j California Department of Health Services

{ P.O. Box 942732

Sacramento, California 94234-7320

Terry Winter, Manager

l Power Operations

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San Diego Gas & Electric Company '

1 P.O. Box 1831

San Diego, California 92112 i

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Mr. Steve Hsu

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! Radiological Health Branch

) State Department of Health Services

t P.O. Box 942732

Sacramento, California 94234

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i Mayor  ;

i City of San Clemente

100 Avenida Presidio

San Clemente, California 92672

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Mr. Truman Burns \Mr. Robert Kinosian '

California Public Utilities Commission

505 Van Ness, Rm. 4102

, San Francisco, California 94102

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DISTRIBUTION: j

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LPDR Enforcement Coordinators

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LJCallan, EDO (0-17G21) HBell, OlG (T-5D28)

HThompson, DEDR (0-17G21) GCaputo, 01 (0-3E4)

JLieberman, OE (0-7H5) EJordan, DEDO (0-17G21)

LChandler, OGC (0-15B18) LTremper, OC/LFDCB (T-9E10)

JGoldberg, OGC (0-15B18) MSatorious, OE (0-7H5)

Director, NRR (0-12C18) OE:EA (2) (0-7H5)

RZimmerman, NRR/ADP (0-12G18) NUDOCS

MFields, NRR/PDIV-2 (0-13E16) SBlack, NRR (0-10A19)

RCorreia, NRR (0-10A19)

RIV DISTRIBUTION:

E-mail to:

OEMAIL DChamberlain (DDC) MSatorious (MAS)

RCorreia (RPC) SBlack (SCB) IBarnes (IXB)

BHenderson (BWH) MHammond(MFH2) DKunihiro (DMK1)

CHackney (CAH) JHorner(JWH3) GMVasquez (GMV)

WBrown (WLB) JDyer(JED2) CPaulk (CJP)

KPerkins(KEP) AHowell ( ATH) JSloan (JAS7)

DKirsch (DFK) KBrockman(KEB) JRussell (JJR)

TPGwynn (TPG) DPowers (DAP) JWhittemore (JEW)

Copies to:

RIV Files

MIS Coordinator

ORA > Reading File

GSanborn> EAFile

DOCUMENT NAME: G:\EA\ DRAFT \EA96466.FNL

To receive copy of document, indicate in box: "C" = Copy without enclosures E" = Copy with enclosures N" = No copy

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OFFICIAL RECORD COPY

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SOUTHERN CALIFORNIA EDISON -5-

DISTRIBUTION:

PDR IE 14

LPDR Enforcement Coordinators

SECY Rl,Rll,Rlll

CA JGilliland, PA. (0-2G4)

JTaylor, EDO (0-17G21) HBell, OlG (T-5D28)

JMilhoan, DEDR (0-17G21) GCaputo, 01 (0-3E4)

JLieberman, OE (0-7H5) EJoroan, AEOD (T-4D18)

LChandler, OGC (0-15B18) LTremper, OC/LFDCB (T-9E10)

JGoldberg, OGC (0-15B18) OE: (0-7H5)

Director, NRR (0-12G18) OE:EA (2) (0-7H5)

RZimmerman, NRR/ADP (0-12G18) NUDOCS

MFields, NRR/PDIV-2 (0-13E16)

RIV DISTRIBUTION:

E-mail to:

OEMAll DChamberlain (DDC) MSatorious (MAS)

SJCollins (SJC1) RCorreia (RPC) SBlack (SCB)

BHenderson (BWH) MHammond(MFH2) DKunihiro (DMK1)  ;

CHackney (CAH) JHorner(JWH3) GMVasquez (GMV)

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KPerkins(KEP) AHowell (ATH) JSloan (JAS7) '

DKirsch (DFK) KBrockman(KEB) JRussell (JJR) i

TPGwynn (TPG) DPowers (DAP) JWhittemore (JEW) i

Cocies to:

RIV Files

MIS Coordinator

LJCallan> Reading File

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GSanborn> EAFile

DOCUMENT NAME: G:\EA\ DRAFT \EA96466.LTR

To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No, c,opy

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DISTRIBUTION:

PDR IE 14

LPDR Enforcement Coordinators

SECY RI,Ril,Rlll

CA JGilliland, PA (0-2G4)

JTaylor, EDO (0-17G21) HBell, OlG (T-5D28)

JMilhoan, DEDR (0-17G21) GCaputo, 01 (0-3E4)

JLieberman, OE (0-7H5) EJordan, AEOD (T-4D18)

LChandler, OGC (0-15B18) LTremper, OC/LFDCB (T-9E10)

JGoldberg, OGC (0-15B18) OE: (0-7H5)

Director, NRR (0-12G18) OE:EA (2) (0-7H5)

RZimmerman, NRR/ADP (0-12G18) NUDOCS

MFields, NRR/PDIV-2 (0-13E16)

RIV DISTRIBUTION:

E-mail to:

OEMAll DChamberlain (DDC) MSatorious (MAS)

SJCollins (SJC1) RCorreia (RPC) SBlack (SCB)

BHenderson (BWH) MHammond(MFH2) DKunihiro (DMK1)

CHackney (CAH) JHorner(JWH3) GMVasquez (GMV)

WBrown (WLB) JDyer(JED2) CPaulk (CJP)

KPerkins(KEP) AHowell (ATH) JSloan (JAS7)

DKirsch (DFK) KBrockman(KEB) JRussell (JJR)

TPGwynn (TPG) DPowers (DAP) JWhittemore (JEW)

Copies to: l

RIV Files

MIS Coordinator

LJCallan> Reading File

GSanborn > EAFile

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DOCUMENT NAME: G:\EA\ DRAFT \EA96466.LTR '

To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy wrth enclosures "N" = No copy

I;] DRS* DRS* C:MB' l RC* ]

GMVasquez JWhittemore CPaulk DAPowers WBrown

01/ /97 01/ /97 01/ /97 01/ /97 01/ /97

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01/ /97 01/ /97 01/ /97 01/ /97 01/ /97 I

OFFICIAL RECORD COPY

• previously concurred

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