Text

Forwards Insp Repts 50-361/98-04 & 50-362/98-04 & Notice of Violation Re Failure to Follow Procedures That Resulted in Minor Pressure & Level Transient in Two Safety Injection Tanks
	ML20248C333
Person / Time
Site:	San Onofre
Issue date:	05/27/1998
From:	Gwynn T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Ray H; SOUTHERN NUCLEAR OPERATING CO.
Shared Package
ML20248C337	List: IR 05000361/1998004; ML20248C333; ML20248C361;
References
	50-361-98-04, 50-361-98-4, 50-362-98-04, 50-362-98-4, EA-98-230, NUDOCS 9806020124
	Download: ML20248C333 (6)
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NUCLEAR REGULATORY COMMISSION

REGION IV

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611 RYAN PLAZA DRIVE, SUITE 400

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MAY 2 71998

EA 98-233

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: NRC INSPECTION REPORT 50-331/98-04; 50-362/98-04 AND NOTICE OF

VIOLATION

Dear Mr. Ray:

From March 15 through April'25,1998, a routine inspection was conducted at your San Onofre

Nuclear Generating Station, Units 2 and 3 reactor facilities. The enclosed report presents the

scope and results of that inspection.

During the 6-week penod covered by this inspection, your conduct of activities at the San Onofre

facilities was generally characterized by safety-conscious operation, sound engineering and

maintenance practices, and careful radiological work controls.

Four violations of NRC requirements were identified during this inspection. We have carefully

considered the perspectives you expressed at the exit meeting in arriving at our enforcement

decisions. We encourage open communication, as occurred during the exit meeting, to facilitate

a mutual understanding of the facts, your perspectives regarding the issues, and the basis for

our regulatory conclusions. We understand that you do not dispute the facts as discussed at the

exit meeting. The disagreement centered around the application of NRC's Enforcement Policy.

I personally discussed these issues with Mr. Russ Kneger of your staff to ensure a mutual

understanding of the issues. Subsequent to that discussion, my resolutica of the concerns

expressed at the exit meeting, as documented below, was reviewed by NRC's Office of

Enforcement to ensure the proper application of the Enforcement Policy.

Violation A, regarding a failure to follow procedures that resulted in a minor pressure and level

transient in two safety injection tanks had only negligible safety consequence. However, the

regulatory significance of the procedure noncompliance in this instance was not minor, because

the potential impact of consciously deviating from approved procedures without appropriate

review was of regulatory concem. In applying the guidance of Enforcement Guidance

Memoranda 97-12 and 97-12A to this issue, the NRC determined that the criteria for a noncited

violation were not met in that the noncompliance was revealed through a self-disclosing event

and that the cauce of the event was obvious.

9906020124 990527

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Violation B, regarding another procedural compliance issue resulting from a cognitive

maintenance error, was also not considered minor becauee prompt operator response was

required to mitigate the reactor coolant system pressure transient induced by the maintenance

error. in applying the guidance of Enforcement Guidance Memoranda 97-12 and 97-12A to this

issue, the NRC determined that the criteria for a noncited violation were not met in that the

noncompliance was revealed through a self-disclosing event and that the cause of the event

was obvious.-

Violation C, regarding a failure to perform a safety evaluation required by 10 CFR 50.59, was

determined not to be minor because a plant modification was actually completed without

appropriate evaluation. Because the failure was identified by the NRC, the criteria for a noncited

violation were not met.

Violation D, regarding the failure to comply with contamination control procedures, was not

considered to be minor because of the potential spread of contamination, particularly if the

incident recurred several times. Because the failure was identified by the NRC, the criteria for a

noncited violation were not met.

The NRC has concluded that the information regarding the rcasons for the violations, the

corrective actions taken and planned to correct the violations and prevent recurrences are

already adequately addressed on the docket in the enclosed inspection report. T'1erefore, you

.

are not required to respond to this letter in regards to the violations unless the description therein

does not accurately reflect your corrective actions or your position. In that case, or if you choose

to provide additional information, you should follow the instructions in the enclosed Notice.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of thia letter, its

enclosures, and your response will b3 placed in the NRC Public Document Room.

Should you have any questions conceming this inspection, we will be pleased to discuss them

with you.

Si re

,

Thomas P. Gwyn Dir or

Division of Reactor jects

Docket Nos.: 50-361

50-362

License Nos.: NPF-10

NPF-15 .i

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_ _ _ _ - - _ _ _ _ _ _ . _. . _ _ _ _ _ _ -_ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

Southem California Edison Co. -3-

Enclosu es:

1. Notice of Violation

2. NRC Inspection Report

50-361/98-04;50-362/98-04

cc w/ enclosures:

Chairman, Board of Supervisors

County of San Diego

1600 Pacific Highway, Room 335

San Diego, California 92101

Alan R. Watts, Esq.

Woodruff, Spradlin & Smart

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, Califomia 92522

R. W. Krieger, Vice President

Southern Califomia Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, Califomia 92674-0128

Stephen A. Woods., Senior Health Physicist

Division of Drinking Water and

Environmental Management

Nuclear Emergency Response Program

Califomia Department of Health Services

P.O. Box 942732, M/S 396

Sacramento, California 94334-7320

Mr. Gary D. Cotton, Sr. Vice President i

! Energy Supply

San Diego Gas & Electric Company

l P. O. Box 1831 l

l San Diego, California 92112-4150

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m.,

.

Southem California Edison Co. -4-

, Mr. Steve Hsu

l Radiological Health Branch

State Department of Health Services

! P.O. Box 942732

Sacramento, Califomia 94234

Mayor

City of San Clemente

'100 Avenida Presidio

San Clemente, Califomia 92672

Mr. Truman Bums \Mr. Robert Kinosian

California Public Utilities Commission

. 505 Van Ness, Rm. 4102

San Francisco, Califomia 94102

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Southern California Edison Co. 4-

MAY 2 71998

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E-Mail report to T. Frye (TJF)

E-Mail report to D. Lange (DJL)

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Branch Chief (DRP/TSS) G. F. Sanborn, EO

WCFO File J. Lieberman, OE, MS: 7-H5

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MAY 2 71998

E-Mail report to T. Frye (TJF)

E-Mail report to D. Lange (DJL)

E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

bec to DCD (IE01)

bec distr;b. by RIV:

Regional Administrator Resident inspector

DRP Director DRS-PSB

Branch Chief (DRP/F, WCFO) MIS System

Senior Project inspector (DRP/F, WCFO) RIV File

Branch Chief (DRP/TSS) G. F. Sanborn, EO

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OE:EA File, MS: 7-HS

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ML20248C333

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