ML20238F353

Forwards Insp Repts 50-206/87-14,50-361/87-13 & 50-362/87-15 on 870524-0704 & Notice of Violation.Util Requested to Address Concern of Placing More Emphasis on Eliminating Enforcement Action than Implementing Program

ML20238F353
Person / Time
Site:	San Onofre
Issue date:	09/01/1987
From:	Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
Shared Package
ML20238F356	List: IR 05000206/1987014 ML20238F353 ML20238F367
References
NUDOCS 8709160100
Download: ML20238F353 (3)

See also: IR 05000206/1987014

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SEP 11987

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Docket Nos. 50-206, 50-361, 50-362

Southern California Edison Coapany

P. O. Box 800

2244 Walnut Grove Avenue

Rosemead, California 92770

Attention: Mr. Henr>eth P. Baskin, Vice President

Nuclaar Engineering Safety and Licensing

Gentlemen:

This refers to the routinc inspection conducted by Messrs. F. R. Huey, J. E.

Tatum, and A. L. Hon of this rnice during the period of May 24 through

July 4,1987 of activitirc aWhorized by NRC License Nos. OPR-13, NPF-10 and

NPF-15 and to t h discussion Of our findings held by the inspectors with Mr.

H. B. Ray and other members of the Southern California Edison (SCE) staff at

the conclusion of the inspection.

'. Areas examined during this int,pection are described in the enclosed inspection

report. Within these areas, the irspection consisted uf selective

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, examinations of procedures and representative records, interviews with

personnel, and observat ons by the inspectors.

As previously discussed in inspection report 50-206/87-03 and in paragraph 9.d

of the enclosed report", it appears that certain of your activities were not

conducted in full compliance with NRC requirements, as set ferth in the Notice

of Violation, enclosed herewith as Appendix A. -

During the exit interview at which the proposed Notice of Violation involving

station housekeeping was discussed, SCE management identified an intent to

revise existing station housekeeping procedures to delete specific

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quantitative stadards associated with housekeeping requirements. These

changes would apoarently p4co increased reliance on first iine supervision,

which our inspection staff does not consider to have been fully effective in

maintaining hous m oping standards under t.he more specific exirting program.

The SCE staff stated that this intended action was in response to what SCE

considers to be unwarranted NRC enforcement actions related to violation of

station procedures which M5 believes ar.t more restrictive than the

requirements intended by NRC regulations. However, we believe the

discrepancies cited in the enclosed Notice of Violation indicate weakness and

a need for improved performance in the areas identified. It is of concern to

the NRC that SCE appears to be placing more emphasis on eliminating the risk

of enf orcement action than on the aggressive implementation of an existing

program which has been satisfactorily implemented in the past. .SCE is

e requested to specifically address this conce n in their response to the

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proposed Notice of Violation.

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G709160100 97090;

PDR ADOCK 05000206

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SEP 11987

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Your response to' this Notice is' to be submitted in accordance with the

provisions of 10 CFR 2.201 as stated in Appendix A',, Notice of Violation.

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In accordance with 10 CFR 2.790(a), a copy of this letter..the enclosure, and

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your response wil1 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 concerning this insp'ection, we will be glad to

' discuss them with you.

Sincerely, ,

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R.',P.

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Zimmerman, C ief

Reactor Projects Branch

. Encl osures:' '

.1. Notice of V'iolation

2. Inspection Reports:

'Nos. 50-206/87-14, 50-361/87-13, 50-362/87-15

3. Safety System Availability Tables-

cc w/ enclosures:

.D. J. Fogarty, Executive Vice President

H. B. Ray,' Vice President (San Clemente)

H. E. Morgan, Station Manager (San Clemente)

State of California-

, bec w/ enclosures: .

'RSB/ Document Control Desk (RIDS) (IE01)

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, docket file

G. Cook

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B.LFaulkenberry

J.' Martin

. Project Inspector.-

' Resident Inspector

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bec w/o enclosures 2 and'3:

J. Zo111 coffer

M. Smith.

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