ML20138Q048
| 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: |
| References | |
| EA-96-466, NUDOCS 9703060096 | |
| Download: ML20138Q048 (7) | |
See also: IR 05000361/1996014
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March 3, 1997
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EA 96-466
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Harold B. Ray, Executive Vice President
Southern Califomia 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:
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(NRC SPECIAL INSPECTION REPORT 50-361/96-14; 50-362/96-14)
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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
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San Onofre Nuclear Generating Station, Units 2 and 3 reactor facilities. The purpose of the
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special inspection was to review resident inspector findings concerning the implementation
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of the Maintenance Rule at San Onofre. The findings were discussed with your staff
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during an exit briefing on November 15,1996. The subject inspection report documented
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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.
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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;
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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
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conference, your staff informed us that, for purposes of the Maintenance Rule, the San
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9703060096 970303
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ADOCK 05000361
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Southern California Edison Co.
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Onofre expert panel did not intend to include the smoke dampers as a risk significant
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
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monitoring the functional performance of the smoke dampers. As a result, you stated your
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intent to review other SSCs to ensure that appropriate criteria are used to monitor
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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.
Therefore, since your performance criteria for applicable risk-significant SSCs neither
explicitly considered nor were bounded by the appropriate risk determining analyses (e.g.,
considering start and run demands), the NRC has determined that citing a Severity LevelIV
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violation is appropriate.
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At the conference, we also discussed a third apparent violation which involved the
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apparent failure to have goals and monitoring requirements established and documented for
13 risk-significant SSCs which had not met their established performance criteria. You
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
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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
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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.
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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
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NRC Maintenance Rule baseline inspections at other sites, Edison believes licensees have
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Southern California Edison Co.
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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
Enclosure: Notice of Violation
cc w/ enclosure:
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
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Orange, California 92668-4702
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Sherwin Harris, Resource Project Manager
Public Utilities Department
City of Riverside
3900 Main Street
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Riverside, California 92522
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Southern California Edison Co.
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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
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Environmental Management
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California Department of Health Services
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P.O. Box 942732
Sacramento, California 94234-7320
Terry Winter, Manager
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Power Operations
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San Diego Gas & Electric Company
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P.O. Box 1831
San Diego, California 92112
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Mr. Steve Hsu
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Radiological Health Branch
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State Department of Health Services
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P.O. Box 942732
Sacramento, California 94234
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Mayor
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City of San Clemente
100 Avenida Presidio
San Clemente, California 92672
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Mr. Truman Burns \\Mr. Robert Kinosian
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California Public Utilities Commission
505 Van Ness, Rm. 4102
San Francisco, California 94102
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Southern California Edison Co.
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DISTRIBUTION:
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Enforcement Coordinators
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JGilliland, PA (0-2G4)
LJCallan, EDO (0-17G21)
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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
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SOUTHERN CALIFORNIA EDISON
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DISTRIBUTION:
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Enforcement Coordinators
SECY
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LChandler, OGC (0-15B18)
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JGoldberg, OGC (0-15B18)
OE: (0-7H5)
Director, NRR (0-12G18)
OE:EA (2) (0-7H5)
RZimmerman, NRR/ADP (0-12G18)
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MFields, NRR/PDIV-2 (0-13E16)
RIV DISTRIBUTION:
E-mail to:
OEMAll
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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)
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JSloan (JAS7)
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RIV Files
MIS Coordinator
LJCallan> Reading File
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DOCUMENT NAME: G:\\EA\\ DRAFT \\EA96466.LTR
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DISTRIBUTION:
IE 14
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Enforcement Coordinators
SECY
RI,Ril,Rlll
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JGilliland, PA (0-2G4)
JTaylor, EDO (0-17G21)
HBell, OlG (T-5D28)
JMilhoan, DEDR (0-17G21)
GCaputo, 01 (0-3E4)
JLieberman, OE (0-7H5)
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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)
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DOCUMENT NAME: G:\\EA\\ DRAFT \\EA96466.LTR
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OFFICIAL RECORD COPY
- previously concurred
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