ML20196D446
| ML20196D446 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/10/1988 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Baskin K SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML20196D451 | List: |
| References | |
| NUDOCS 8802170144 | |
| Download: ML20196D446 (2) | |
See also: IR 05000362/1987025
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FEH 101988
Docket-No.-50-362-
Southern California Edison Company
P. O. Box 800
'2244 Walnut Grove Avenue
Rosemead, California 92770
Attentien: Mr. Kenneth P. Baskin, Vice President
Nuclear Engineering, Safety, and Licensing
Gentlemen:
This refers to the special inspection conducted by Messrs. A. Johnson,
P.' Johnson, and J. Tatum of this office on August 3 through 28, 1987, as
documented in NRC Inspection Report No. 50-362/87-25. This report addressed
maintenance activities performed on main feedwater isolation valve (MFIV)
3HV-4048 and atmospheric dump valve (ADV) 3HV-8419. Our letter dated
September 1, 1987, which forwarded this inspection report, stated that
enforcement action relating to this inspection, if appropriate, would'be the
subject of separate correspondence.
After consideration of the findings presented in the referenced inspection
report, the NRC has made the following determinations:
- As stated in the NRC Inspection Manual Part 9800 ."Maintenance activities
which do not result in a change to a system (permanent or temporary) ...
do not require a written safety evaluation to meet 10 CFR 50.59
requirements." Therefore, enforcement action against 10 CFR 50.59 is
not appropriate.
- Blocking open MFIV 3HV-4048 for maintenance was contrary to Sections 3.3.2
and 3.0.3 of the San Onofre 3 Technical Specifications. Making the valve
inoperable placed the containment isolation actuation system into a
condition not addressed by the Action Statements of Section 3.3.2, at
which time Section 3.0.3 became effective.
Failure to take action
pursuant to the requirements of Section 3.0.3 was a violation, and is
addressed in the enclosed Notice af Violation.
- No violation of NRC reporting requirements occurred.
Although a violation against 10 CFR 50.59 was not cited for making the MFIV
nnd ADV inoperable, we believe that such actions must be carefully evaluated
against the FSAR and controlled in accordance with established programatic
requirements. We emphasize the importance of consistent management attention
to this matter, and encourage your continued involvement in efforts presently
ongoing by NUMARC and NSAC to provide additional industry guidance on the
implementation of 10 CFR 50.59.
8802170144 880210
ADOCK 05000:M2
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' Southern California Edison' Company
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As discussed above, it appears.that certain of your activities was not
conducted in full compliance with NRC requirements, as set forth in the
enclosed Notice of Violation; Your response to this Notice is to be submitted
in'accordance with the provisions of 10 CFR 2.201 as statedLin the enclosed
In accordance with 10 CFR 2.790(a), a copy of this letter, the enclosure, and
your response will be placed in the NRC Public Document Room.
The response directed by this letter and the accompanying Notice are not
subject'to the clearance procedures of the Office of Management and Budget as
required by the Paperwork Reduction Act of 1980, PL 96-511.
..
Should you have any questions regarding this matter, we will be pleased to
discuss them with you.
Sincerely,
I
D. F. Kirsch, Director
Division of Reactor Safety
and Projects
Enclosure: Notice of Violation
i
cc w/ enclosure:
D. J. Fogarty. Executive Vice President
C. B. McCarthy, Jr., Vice President - Site Manager
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H.E. Morgan,StationManager(SanClemente)
State of California
bec w/ enclosure
P. Johnson
R. Huey
R. Zimerman
A. Chaffee
A. Johnson
J. Tatum
J. Crews
C. Caldwell
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