ML20217N441
| ML20217N441 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/15/1997 |
| From: | Nunn D SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-361-97-12, 50-362-97-12, NUDOCS 9708260171 | |
| Download: ML20217N441 (3) | |
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soum-mmom EDISON CLM-An LDISON IhTER%ATIONAL Company August 15,1997 U. S. Nuclear Regulatory Commission -
Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Reply to a Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3
Reference:
Letter, Mr. Thomas P. Gwynn (USNRC) to Mr. Harold B. Ray (Edison),
dated July 22,1997 The referend letter transmitted the results of NRC Inspection Report No.
50-361/97-12 and 50-362/97-12, conducted May 18 through July 5,1997, at the San Onofre Nuclear Generating Station, Units 2 and 3. The enclosure to the referenced letter contained a Notice of Violation containing two violations (97012-05 and 97012-08).- The violations involved: 1) a failure to submit a licensee event report within 30 days, as required by 10 CFR 50.73(a)(2)(1)(B), and 2) a failure of a licensee -
supervisor, in the protected area, to have custody of his card-key badge. Because the NRC had completed it's review of the corrective actions for the second violation (97012-08), no response to that violation is required. The enclosure to this letter
- provides Edison's reply to the first violation, 97012-05.
-if you have any further questions, please contact me.
Sincerely,
,i Enclosure cc:
E. W. Merschoff, Regional Administrator, NRC Region IV K E. Perkins, Director, Walnut Creek Field Office, NRC Region IV M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 D-J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 1,2 and 3
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t ENCLOSURE REPLY TO A NOTICE OF VIOLATION The enclosure to Mr. T. P. Gwynn's letter dated July 22,1997, states, in part:
"10 CFR 50.73(d) requires, in part, that licensee event reports must be submitted within 30 days of discovery of a reportable event.
" Contrary to the above, on January 24,1997, a Station Technical engineer identified that surveillance tests of the containment purge exhaust radiation monitors in Units 2 and 3 had not been performed as required by Technical Specifications, and the licensee failed to submit.1 icensee event report within f
30 days, as required by 10 CFR 50.73(a)(2)(1)(B). The licensee submitted the licensee event report on April 23,1997.
l "This is a Severity Leval IV violation (Supplement 1) applicable to Units 2 and 3 (Violation 361; 362/97012-05)."
1.
Reason for the Violation The reasons for the violation were personal error and ineffective communication, as follows:
On January 24,1997, AR 970101498 was generated. On January 28,1997, an Initial 1
Root Cause (IRC) report was included in the Action Request (AR) which suggested -
there had been a failure to perform adequate surveillance testing on the containment purge monitoring system, as required by the Technical Specifications (TS) in effect at that time.
On January 29,1997, due to personal error, the individual performing the reportability assessment for AR 970101498 failed to review the IRC portion of the AR. However,-
- the individual did contact the Station Technical engineer on January 29,1997, for additional information about this condition. The individual and the engineer failed to communicate effectively regarding the facts and circumstances surrounding the period of inoperability. The engineer assumed that all the information on the AR had been reviewed, and therefore, failed to communicate he was aware that TS surveillance
--requirements had not been met in 1989, for approximately a year. In addition, the individual performing the reportability evaluation also approved as the independent reviewer, contrary to management expectations (i.e., there was no second check of the
- reportability assessment).
As noted in the violation, on April 23, _1997, Licensee Event Report 2-97-007 was submitted to the NRC.
O-ENCLOSURE 2.
Corrective Actions Taken and the Results Achieved August 15,1997
. The following corrective actions have been taken: 1) the reportability assessor was
= coached on the importance of attsntion to detail and the STOP (Stop, Think, Observe, Perform) method of.self checking,2) the Manager, Compliance, reemphasized ta Compliance Department personnel the need for an independent review of each reportability assessment, and 3) a human factors event report (ER 970700184) was.
Initiated to assess this event.
3.
Corrective Actions That Will be Taken ER 970700184 will be required reading for all reportability assessors, training will be given on information available in AR assignments (e.g., IRC, etc.), and appropriate personnel will receive training in techniques to improve communications when performing reportability determinations. These actions will be completed by September 30,1997.
4.
Date When Full Compliance Will be Achieved Full compliance was achieved on April 23,1997, when Licensee Event Report 2-97-007 was submitted to the NRC.
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