ML20195F289
| ML20195F289 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/12/1998 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| 50-361-98-05, 50-361-98-5, 50-362-98-05, 50-362-98-5, EA-98-226, NUDOCS 9811190228 | |
| Download: ML20195F289 (6) | |
See also: IR 05000361/1998005
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UNITED STATES
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flovember 12, 1998-
EA 98-226
Harold B. Ray, Executive Vice President
Southorn California Edison Co.
San Onofre Nuclear Generating Station -
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P.O. Box 128
San Clemente, California 92674-0128
SUBJECT:
EXERCISE OF ENFORCEMENT DISCRETION
(NRC INSPECTION REPORT NO. 50 361/98-05; 50-362/98-05)
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Dear Mr. Ray:
This is in reference to the letter from Dwight Nunn, Vice President, Engineering and Technical
Support, dated June 22,1998, which was submitted in response to the referenced NRC
inspection report issued on May 21,1998. The inspection report described an apparent
violation of San Onofre Nuclear Generating Station technical specifications End informed you
that the NRC was considering escalated enforcement action. Southern California Edison (SCE)
was given a choice of responding to the apparent violation in writing or requasting a
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predecisional enforcement conference. Mr. Nunn's letter provided SCE's written response to
the apparent violation.
The apparent violation, which SCE identified when replacing reversing linestarters, was caused
by the failure of a reversing linestarter associated with the Train A motor-operated, containment
emergency sump outlet valve. With this valve unable to open on a containment sump
recirculation actuation signal, and with the Train B recirculation system unavailable due to
planned maintenance, San Onofre was operated for a period of approximately 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> in
January 1998 with no post-accident recirculation capability available, contrary to the
requirements of the plant's technical specifications.
In its May 21,1998 letter, the NRC asked SCE to provide information to support its position that
the linestaner failure was not avoidable by reasonable quality assurance measures or
management controls,' whether there were prior opportunities to detect and correct the
condition that rendered the linestarter inoperable, and whether other equipment could be
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affected by this condition.
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9811190228 981112
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ADOCK 05000361
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'The " General Statement of Policy and Procedure for NRC Enforcement Actions,"
(Enforcement Policy) NUREG-1600, Revision 1, states that the NRC may ref rain from issuing
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enforement action for violations resulting from matters not within a licensee's control, such as
equipment failures that were not avoidable by reasonable quality assurance measures or
managemeat controls.
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Southern Ca;ifornia Edison Co.
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SCE provided detailed information in response to each of these concerns. In its June 22,1998
letter, and as earlier reported to the NRC on March 9,1998 in Licensee Event Report (LER)98-003, SCE attributed the linestarter f ailure to a fine aerosol grit deposited during construction
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activities prior to plant startup. SCE stated that the grit, which was indistinguishable from
common dust to the naked eye, caused a mechanical interlock on the linestarter to jam,
rendering it and the associated emergency sump outlet valve inoperabic. SCE noted that it
found this condition during the planned replacement of the mechanicalinterlock on the
linestarter, and that SCE conducted an extensive root cause analysis to determine the cause of
the failure. SCE noted that the failed interlock had been installed more than 20 years ago and
is conservatively estimated to have had more than 100 successful actuations prior to being
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found in the failed condition. In addition, SCE noted that there are 172 reversing linestarters
with the same type of mechanicalinterlock and that there have been more than 17,000
successful actuations with only one f ailure due to grit.
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SCE also stated in its June 22 letter and attachments that SCE's quality assurance and
management controls of activities during plant construction were consistent with NRC and
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industry standards, that it complied with preventive maintenance and surveillance requirements
associated with the linestarters, and that there were no overlooked opportunities to detect and
correct the condition that rendered the linestarter inoperable. Finally, SCE stated that there is
no other plant equipment affected by this condition.
The NRC has completed its review of the information provided by SCE. We note that given the
loss of function of this safety system, this violation would normally have been categorized at
Severity Level 11 in accordance with the Enforcement Policy. However, the event involved the
only known failure of a linestarter due to grit in approximately 16 years of plant operation,
indicating that this failure was isolated. Further, the risk significance was lessened by the
relatively short duration of the loss of safety function (approximately 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br />) and the recovery
potential by plant personnel. Based on these considerations, the NRC has concluded that this
issue is more appropriately classified at Severity Level 111.
However, we acknowledge that the failure was discovered by SCE during planned replacement
of linestarters, and the issue was aggressively pursued by SCE to determine the root cause.
We agree with SCE's conclusion that this failure was not likely to have been prevented by
reasonable quality assurance activities and other management controls. Therefore, af ter
consultation with the Director, Office of Enforcement and the Deputy Executive Director for
Regulatory Effectiveness, and in accordance with Section Vll.B.6 of the NRC's Enforcement
Policy, the NRC is exercising its enforcement discretion to not propose a civil penalty and to not
cite the violation in this case.
Please contact Mr. Thomas P. Gwynn of my staff at (817) 860-8248 if you have any further
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questions about this matter.
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Southern California Edison Co.
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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice, a copy of this letter will be
placed in the NRC Public Document Room.
Sincerely,
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Ellis W. Mersc
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Regional Adm' Tistrator
Docket Nos.: 50-361
50-362
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License Nos.: NPF-10
NPF-15
cc:
Chairman, Board of Supervisors
County of San Diego
1600 Pacific Highway, Room 335
San Diego, California 92101
Alan R. Watts, Esq.
Woodruff, Spradlin & Smart
701 S. Parker St. Suite 7000
Orange, California 92868-4720
Sherwin Harris, Resource Project Manager
Public Utilities Department
City of Riverside
3900 Main Street
Riverside, California 92522
R. W. Krieger, Vice President
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, California 92674-0128
Stephen A. Woods, Senior Health Physicist
Division of Drinking Water and
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Environmental Management
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Nuclear Emergency Response Program
California Department of Health Services
P.O. Box 942732, M/S 396
Sacramento, California 94334-7320
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Southern California Edison Co.
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Mr. Gary D. Cotton, Sr. Vice President
Energy Supply
San Diego Gas & Electric Company
P. O. Box 1831
San Diego, California 92112-4150
Mr. Steve Hsu
Radiological Health Branch
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State Department of Health Services
P.O. Box 942732
. Sacramento, California 94234
Mayor
City of San Clemente
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100 Avenida Presidio
San Clemente, California 92672
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Mr. Truman Burns \\Mr. Robert Kinostan
California Public Utilities Commission
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505 Van Ness, Rm. 4102
San Francisco, California 94102
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Southern California Edison Co.
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