IR 05000362/1987025

Discusses Insp Rept 50-362/87-25 on 870803-28 & Forwards Notice of Violation.Importance of Consistent Mgt Attention to 10CFR50.59 Emphasized.Util Encouraged to Continue Involvement in Efforts Ongoing by NUMARC

ML20196D446
Person / Time
Site:	San Onofre
Issue date:	02/10/1988
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
Shared Package
ML20196D451	List: ML20196D446 ML20196D489
References
NUDOCS 8802170144
Download: ML20196D446 (2)

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FEH 101988 Docket-No.-50-362-Southern California Edison Company P. O. Box 800

'2244 Walnut Grove Avenue Rosemead, California 92770 Attentien: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering, Safety, and Licensing Gentlemen:

This refers to the special inspection conducted by Messrs. A. Johnson, P.' Johnson, and J. Tatum of this office on August 3 through 28, 1987, as documented in NRC Inspection Report No. 50-362/87-25. This report addressed maintenance activities performed on main feedwater isolation valve (MFIV)

3HV-4048 and atmospheric dump valve (ADV) 3HV-8419. Our letter dated September 1, 1987, which forwarded this inspection report, stated that enforcement action relating to this inspection, if appropriate, would'be the subject of separate correspondenc After consideration of the findings presented in the referenced inspection report, the NRC has made the following determinations:

• As stated in the NRC Inspection Manual Part 9800 ."Maintenance activities which do not result in a change to a system (permanent or temporary) ...

do not require a written safety evaluation to meet 10 CFR 50.59 requirements." Therefore, enforcement action against 10 CFR 50.59 is not appropriat * Blocking open MFIV 3HV-4048 for maintenance was contrary to Sections 3. and 3.0.3 of the San Onofre 3 Technical Specifications. Making the valve inoperable placed the containment isolation actuation system into a condition not addressed by the Action Statements of Section 3.3.2, at which time Section 3.0.3 became effective. Failure to take action pursuant to the requirements of Section 3.0.3 was a violation, and is addressed in the enclosed Notice af Violatio * No violation of NRC reporting requirements occurre Although a violation against 10 CFR 50.59 was not cited for making the MFIV nnd ADV inoperable, we believe that such actions must be carefully evaluated against the FSAR and controlled in accordance with established programatic requirements. We emphasize the importance of consistent management attention to this matter, and encourage your continued involvement in efforts presently ongoing by NUMARC and NSAC to provide additional industry guidance on the implementation of 10 CFR 50.5 PDR ADOCK 05000:M2 PDR G

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' Southern California Edison' Company -2 '

As discussed above, it appears.that certain of your activities was not conducted in full compliance with NRC requirements, as set forth in the enclosed Notice of Violation; Your response to this Notice is to be submitted in'accordance with the provisions of 10 CFR 2.201 as statedLin the enclosed Notice of Violatio In accordance with 10 CFR 2.790(a), a copy of this letter, the enclosure, and your response will be placed in the NRC Public Document Roo 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 96-51 ..

Should you have any questions regarding this matter, we will be pleased to discuss them with yo

Sincerely, I

D. F. Kirsch, Director Division of Reactor Safety and Projects Enclosure: Notice of Violation i cc w/ enclosure:

D. J. Fogarty. Executive Vice President l

C. B. McCarthy, Jr., Vice President - Site Manager H.E. Morgan,StationManager(SanClemente)

State of California bec w/ enclosure P. Johnson R. Huey R. Zimerman A. Chaffee A. Johnson J. Tatum J. Crews a

C. Caldwell i

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