ML20199J111
| ML20199J111 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/30/1998 |
| From: | Nunn D SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-361-97-15, 50-362-97-15, NUDOCS 9802050221 | |
| Download: ML20199J111 (2) | |
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l W EDISON 02 2-An I.DISOY lATI RAM 10ML Compan3 January 30,1998 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
Suoject:
Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3
References:
(1) Letter, Mr. A. T. Howell ill (USNRC) to Mr. Harold B. Ray (SCE),
dated September 10,1997 (2) Letter, Mr. Harold B. Ray (SCE) to Mr. E. W. Merschoff (USNRC),
dated October 24,1997 (3) Letter, Mr. E. W. Mychoff (USNRC) to Mr. Harold B. Ray (SCE),
dated January 15,19 )8 Reference 1 transmitted the results of NRC Inspection Report No. 50-361/97-15 and 50-362/97-15, conducted June 30 through July 3,1997, at the San Onofre Nuclear Generating Station, Units 2 and 3. The enclosure to Reference 1 also transmitted a Notice of Violation (9715-01). This violation involved the failure to adequately evaluate the appropriateness of the performance of preventive maintenance prior to placing the Unit 3 reactor coolant system (RCS) under a 10 CFR 50.65(a)(2) category.
Reference 2 transmitted SCE's original response to the Notice of Violation. In that response it was stated that SCE believes no violation of the Maintenance Rule occurred. Notwithstanding this conclusion, in accordance with your guidance in Reference 3, we are providing the following response to bring the issue to closure. As noted in References 2 and 3, the reason for the violation was that the failure history screening performed as part of the Maintenence Rule implementation prior to July 10, 1996, did not include a review of construction work orders (CWOs). Thus, SCE's decision to place the RCS under 10 CFR 50.65(a)(2) was based on incomplete data.
As corrective' actions SCE has: 1) completed a review of CWOs implemented since July 1993 and determined that this was an isolated occurrence; 2) changed the Maintenanco Rule monthly review process to include CWO's; 3) placed the reactor coolant systems of both units in Category (a)(1) as a result of occurrences of RCS t.
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pressure boundary leakage, including nozzle leakage; and 4) revised the Alloy 600 program plan,90022, " Susceptibility of Reactor Coolant System Alloy 600 Nozzles to Primary Water Stress Corrosion Cracking and Replacement Program," to implement a strategy to replace penetrations over time. As noted in Reference 3, we plan to complete all instrument nozzle repairs by the end of the Cycle 10 refueling outages.
No further corrective actions are planned, and the date of full compliance was July 23, 1997, when the Unit 3 RCS was placed in Category (a)(1).
If you have any further questions, please contact me.
Sincerely, S&E, k
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Dwight E. Nunn ec:
E. W. Merschoff, Regional Administrator, NRC Ragion IV W
K. E. Perkins, Director, Walnut Creak Field Office, NRC Region IV M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 J. A. Sloan, NRC Senior Resident inspector, San Onafre Units 2 and 3
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