ML20203L897

Ack Receipt of 971024 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-361/97-15 & 50-362/97-15 on 970630-0703

ML20203L897
Person / Time
Site:	San Onofre
Issue date:	03/04/1998
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Ray H SOUTHERN CALIFORNIA EDISON CO.
References
50-361-97-15, 50-362-97-15, EA-97-414, NUDOCS 9803060289
Download: ML20203L897 (3)

See also: IR 05000361/1997015

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March 4, 1998

EA 97-414

Harold B. Ray, Executive Vice President

Southem Califomia Edison Co.

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, Califomia 92674-0128

SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50-361/9715; 50-362/9715

Dear Mr. Ray:

,

Thank you for your letters of October 24,1997, and January 30,1998, in response to

our letter and Notice of Violation of September 10,1997, and letter of January 15,1998,

concerning the failure to adequately evaluate the appropriateness of the performance of

prev 6ntive maintenance prior to placing the Unit 3 reactor coolant system under a 10 CFR 50.65(a)(2) category. We have reviewed your reply and find it responsive to the concems raised

in our Notice of Violation. We will review the implementation of your corrective actions during a

future inspection to determine that full compliance has been achieved and will be :naintained.

Sincerely,

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Howell 111, Direc or

Division of Reactor Safety

Docket Nos.: 50-361;50-362

License Nos.: NPF 10; NPF e5

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Gentlemen:

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Subject:

Docket Nos. 50-361 and 50 362

Reply to a Notice of Violation

San Onofre Nuclear Generating Station, Units 2 and 3

References: (1) Lette,', Mr. A. T. Howall 111 (USNRC) to Mr. Harold B. Ray (f 3E),

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. Merschoff (USNRC) to Mr. Harold B. Ray (SCE),

dated January 15,1998

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 Maintenance 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 sinca

July 1993 and determined that this was an isolated occurrence; 2) changed the

Maintenance 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 occurrence- 1 RCS

P.O,Ikn 128

San Clemente. CA 92674-0128

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pret sure boundary leakage, including nozzle leakage; and 4) revised the Alloy 600

prog'am 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 allinstrument 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.

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Sincerely,

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Dwight E. Nunn

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

J. A. Sloan, NRC Senior Resident in:pector, San Onofre Units 2 and 3

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