ML20204B320

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Discusses Insp Repts 50-361/98-18 & 50-362/98-18 on 981109-1218 & Forwards NOV Re Util Identification That Train B Emergency Chilled Water Sys Had Been Inoperable in Excess of Action Times Required by TS on Two Occasions
ML20204B320
Person / Time
Site: San Onofre  
Issue date: 03/16/1999
From: Merschoff E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Ray H
SOUTHERN CALIFORNIA EDISON CO.
Shared Package
ML20204B328 List:
References
50-361-98-18, 50-362-98-18, EA-98-563, NUDOCS 9903220073
Download: ML20204B320 (6)


See also: IR 05000361/1998018

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGloN IV

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611 RYAN PLAZA DRIVE, SUITE 400

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ARLINGTON, TEXAS 76011-8064

March 16, 1999

EA 98-563

Harold B. Ray, Executive Vice President

Southern California Edison Co.

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, California 92674-0128

SUBJECT:

NOTICE OF VIOLATION

(NRC Special Inspection Report No. 50-361/98-18; 50-362/98-18)

Dear Mr. Ray:

This refers to the special inspection completed on December 18,1998, at the San Onofre

Nuclear Generating Station. The purpose of tha inspection was to determine the circumstancs

surrounding the inoperability of the Train B emergency chilled water system during two,

extended periods in August and September 1998. Southern California Edison Co. (SCE)

identified one occurrence on September 25,1998, and the other on October 21,1998. The

results of the inspection were issued in a report dated January 15,1999. In the letter

transmitting the report, the NRC informed SCE that escalated enforcement action was being

considered for an apparent violation of plant Technical Specifications. SCE responded to the

apparent violation in two letters dated February 11 and February 16,1999.

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Based on the information developed during the inspection and after consideration of the

information that SCE provided in its responses, the NRC has determined that a violation of

NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice)

and the circumstances surrounding it are described in detail in the subject inspection report.

The issue involves SCE's identification that the Train B emergency chilled water system had

been inoperable in excess of the action times required by the technical specification on two

separate occasions. The train was inoperable for 22 days due to maintenance, an inconectly

set electrical demand switch, and noncondensable gases in the refrigerant on the first occasion.

The train was inoperable for 26 days due to maintenance and a miswired low chilled water

temperature cutout switch on the second occasion.

Despite SCE's probabilistic risk assessment that the issue represented a "small" increase in

core damage risk, the issue is significant because on both occasions, one train of a safety-

related system was rendered inoperable for a period of time far in excess of the Technical

Specification action time while both units were operating in Mode 1. The emergency chilled

water system provides cooling water to the heating, ventilation, and air conditioning systems,

which in turn removes heat frot the safety-related equipment rooms and provides cooling for

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habitability concerns, during emergency conditions. Therefore, this violation has been

categorized in accordance with the " General Statement of Policy and Procedure for NRC

Enforcement Actions"(Enforcement Policy), NUREG-1600 at Severity LevelIll.

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in accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is

considered for a Severity Level lli violation. Because' SONGS has been the subject of

9903220073 990316

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Southern California Edison Co.

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escalated enforcement action within D.9 last 2 years,' the NRC considered whether credit was

warranted for identification and Corrective Action in accordance with the civil penalty

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assessment process in Section VI.B.2 of the Enforcement Policy. The NRC concluded that

identification credit was warranted. SCE identified the first inoperable period while reviewing

plant records, and identified the second inoperable period when the chiller failed to start during

a surveillance test. The NRC also concluded that credit was warranted for corrective actions.

As discussed in the subject inspection report, your corrective actions included revising your

maintenance procedures concerning the electrical. demand setting, adding a postmaintenance

test requirement following dynamic calibration, and changing how you handle lifted leads to

electrical components.

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Therefore, to encourage prompt identification and comprehensive correction of violations, I

have been authorized, after consultation with the Director, Office of Enforcement, not to

propose a civil penalty in this case. However, significant violations in the future could result in a

civil penalty.

The NRC has concluded that information regarding the reason for the violation, the corrective

actions taken and planned to correct the violation and prevent recurrence, and the date when

full compliance was achieved, is already adequately addressed on the docket in Inspection

Report Nos. 50-361/98-18; 50-362/98-18, in Licensee Event Reports98-020 and 98-021, and in

your correspondence dated February 11 and 16,1999. Therefore, SCE is not required to

respond to this letter unless the description therein does not accurate'y reflect your corrective

actions or your position. In that case, or if you choose to provide additional information, you

should follow the instructions specified in the enclosed Notice.

SCE provided several " corrections / clarifications" to NRC's inspection report in its February 16

letter, but noted that there were no materialissues in dispute. The NRC will address SCE's

comments in separate correspondence,

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,

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Ellis W. Mers

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Regional Administrator

Docket Nos.: 50-361

50-362

License Nos.: NPF-10

NPF-15

' A Severity Level 111 violation was issued on February 18.1998. (EA 97-585)

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Southern California Edison Co.

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Enclosure: Notice of Violation

cc w/ Enclosure:

Chairman, Board of Supervisors

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County of San Diego

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1600 Pacific Highway, Room 335

San Diego, California 92101

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Alan R. Watts, Esq.

Woodruff, Spradlin & Smart

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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

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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

Stephen A. Woods, Senior Health Physicist

Division of Drinking Water and

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Environmental Management

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Nuclear Emergency Responso Program

California Department of Health Services

P.O. Box 942732, M/S 396

Sacramento, California 94334-7320

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Mr. Michael R. Olson

Sr. Energy Administrator

San Diego Gas & Electric Company

P. O. Box 1831

San Diego, California 92112-4150

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Mr. Steve Hsu

Radiological Health Branch

State Department of Health Services

P.O. Box 942732

Sacramento, California 94234

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Southern California Edison Co.

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Mayor

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100 Avenida Presidio

San Clemente, California 92672

Mr. Truman Burns \\Mr. Robert Kinosian

Califomia Public Utilities Commission

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505 Van Ness, Rm. 4102

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San Francisco, California 94102

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