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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P7111999-10-26026 October 1999 Informs That Licensee 990330 Response to GL 97-06 Provides Reasonable Assurance That Condition of Licensee Steam Generator Internals Is in Compliance with Current Licensing Bases for Plant ML20217K3571999-10-21021 October 1999 Discusses Use of SONGS as Generic Safety Issue 191 Ref Plant.Future Requests for Info & Addl Coordination Activities Be Handled Through D Evans of Organization.With Diskette ML20217K8541999-10-21021 October 1999 Forwards Revised Pages to ERDS Data Point Library,Per Requirements of 10CFR50,App E,Section VI.3.a.Described Unit 2 & 3 Changes for 2/3R7813 Were Completed on 990924 ML20217L9491999-10-21021 October 1999 Forwards SONGS Emergency Response Telephone Directory, for Oct-Dec 1999 ML20217J8631999-10-15015 October 1999 Forwards Insp Repts 50-361/99-12 & 50-362/99-12 on 990808- 0918.One Violation Identified Involving Inoperability of Emergency Diesel Generator in Excess of Allowed Outage Time ML20217E3221999-10-13013 October 1999 Forwards MORs for Sept 1999 for Songs,Units 2 & 3.No Challenges Were Noted to Psvs for Either Units 2 or 3 ML20217E7671999-10-12012 October 1999 Forwards Rev 62 to NRC Approved Aug 1983, Physical Security Plan,Songs,Units 1,2 & 3, IAW 10CFR50.54(p).Changes,as Described in Encls 1 & 2,do Not Reduce Effectiveness of Plan.Encl Withheld,Per 10CFR73.21 ML20217B5981999-10-0606 October 1999 Informs That Staff Concluded That All Requested Info for GL 98-01, Year 2000 Readiness in Us Nuclear Power Plants, Provided for San Onofre Nuclear Generating Station,Units 2 & 3 ML20216H8741999-09-29029 September 1999 Provides Requested Written Response to GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Lab Testing of Charcoal Adsorber Samples for Creacus & Pacu Satisfies Listed Requirements ML20216H8541999-09-29029 September 1999 Submits Encl Request for Relief from ASME Code,Section III Requirements in 10CFR50.55(a)(3) to Use Mechanical Nozzle Seal Assembly as Alternate ASME Code Replacement at SONGS, Units 2 & 3 for Period of Operation Beginning with Cycle 11 ML20216J2631999-09-28028 September 1999 Forwards Copy of Final Accident Sequence Precursor (ASP) Analysis of Operational Event at Songs,Unit 2,reported in LER 361/98-003 ML20212H4461999-09-28028 September 1999 Forwards Suppl Info,As Discussed with NRC During 990812 Telcon,To Support Risk Informed Inservice Testing & GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20212G5611999-09-24024 September 1999 Informs NRC That SCE Remains Committed to Performing Eddy Current Examinations of 100% of Reactor Vessel Head Penetrations at Songs,Unit 3.Exams Will Not Be Performed During Cycle 11 RFO 05000361/LER-1999-005, Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments1999-09-23023 September 1999 Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments ML20212D9921999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of San Onofre.Nrc Plan to Conduct Core Insps & One Safety Issues Evaluation of MOVs at Facility Over Next 7 Months. Details of Insp Plan Through March 2000 Encl ML20212A4061999-09-14014 September 1999 Forwards Revised Pages to ERDS Data Point Library.Described Unit 2 Changes for 2R7817 & 2R7828 Were Completed on 990818 & Unit 3 Change for 3R7828 Was Completed on 990903 ML20216E6031999-09-10010 September 1999 Provides Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Dtd 990820.Schedule Shown on Attachment 1, Operator Licensing Exam Data, Provides Util Best Estimate Through Cy 2003 ML20217B9011999-09-10010 September 1999 Responds to Which Addressed Concerns Re Y2K Issue & Stockpiling of Potassium Iodide (Ki) Tablets by Informing That San Onofre Nuclear Station Already Completed All Work Required to Be Ready for Y2K Transition ML20211K4191999-09-0303 September 1999 Final Response to FOIA Request for Documents.Documents Listed in App a Being Withheld in Part (Ref FOIA Exemptions 5 & 7) ML20211N0261999-09-0303 September 1999 Forwards Exemption from Certain Requirements of 10CFR50.44 & 10CFR50,app A,General Design Criterion 41 in Response to Util Request of 980910,as Supplemented 990719 & SER 05000206/LER-1999-001, Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 31999-08-31031 August 1999 Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 3 ML20211H3321999-08-30030 August 1999 Discusses 1999 Emergency Preparedness Exercise Extent of Play & Objectives.Based on Review,Nrc Has Determined That Exercise Extent of Play & Objectives Are Appropriate to Meet Emergency Plan Requirements ML20211J7151999-08-27027 August 1999 Forwards Insp Repts 50-361/99-09 & 50-362/99-09 on 990627- 0807.Two Violations Being Treated as non-cited Violations ML20211H8561999-08-23023 August 1999 Forwards SE Accepting Licensee 970625 Requests for Relief RR-E-2-03 - RR-E-2-04 from Exam Requirements of Applicable ASME Code,Section Xi,For First Containment ISI Interval ML20211J5821999-08-23023 August 1999 Corrected Copy of ,Changing Application Date from 970625 to 990625.Ltr Forwarded SE Accepting Licensee 990625 Requests for Relief RR-E-2-03 - RR-E-2-08 from Exam Requirements of Applicable ASME Code,Section XI as Listed ML20210V4271999-08-16016 August 1999 Forwards Proprietary Certified Renewal Applications for SROs a Harkness,R Grabo & T Vogt & RO D Carter,Submitted on Facsimile Form NRC-398 & Certified NRC Form 396.Encls Withheld ML20210R6681999-08-13013 August 1999 Forwards Response to NRC RAI Re SCE License Amend Applications 173 & 159 for Songs,Units 2 & 3,proposed Change Number 485,which Requests Addition of SR to TS 3.3.9, CR Isolation Signal ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210Q6451999-08-12012 August 1999 Forwards Monthly Operating Repts for July 1999 for SONGS, Units 2 & 3,per TS 5.7.1.4.There Were No Challenges to Pressurizer Safety Valves for Either Units ML20210P5711999-08-11011 August 1999 Forwards Amend Application Number 189 for License NPF-10 & Amend Application Number 174 to License NPF-15,replacing Analytical Limits Currently Specified as Acceptance Criteria with Allowable Values,Per Encl Calculation E4C-098 ML20210P4681999-08-11011 August 1999 Forwards COLR for Cycle 10 for Songs,Units 2 & 3,IAW TS Section 5.7.1.5.d, Colr. Changes to COLR Parameters Have Been Conducted IAW Approved COLR Methodologies & All Applicable Limits of Safety Analysis Were Met ML20210P6221999-08-10010 August 1999 Forwards Replacement Pages for Attachments E & F of Amend Application Numbers 168 & 154 for Songs,Units 2 & 3.Pages Are Provided to Correct Errors to Pagination & Headings in 970618 Submittal ML20210N9721999-08-10010 August 1999 Responds to Appeal of FOIA Request for Documents Re Osre Issue.No Osre Visit Scheduled for Sept 1996 at Plant,Per 990722 Telcon.V Dricks,In Ofc of Public Affairs Should Be Contacted Re Osre Issue ML20210N0901999-08-0909 August 1999 Informs That 990312 Application Requested Amends to Licenses DPR-13,NPF-10 & NPF-15,respectively,being Treated as Withdrawn.Proposed Change Would Have Modified Facility TSs Pertaining to SONGS Physical Security Plan ML20210N5051999-08-0909 August 1999 Forwards Cycle 10 Update to TS Bases,Which Have Been Revised Between 980101-990630,per 10CFR50.71(e) 05000361/LER-1999-004, Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl1999-08-0606 August 1999 Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl ML20210L2311999-08-0505 August 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements,For Songs,Unit 3.Rept Covers 970916 Through 990509,date Unit 3 Returned to Service Following Cycle 10 Refueling Outage ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20216D9671999-07-29029 July 1999 Provides Response to RAI to Support Proposed TS Change 460 Re Containment Isolation Valve Completion Time for SONGS, Units 2 & 3.Rev 3 to Abnormal Operating Instruction SO23-13-14, Reactor Coolant Leak, Encl ML20210C1821999-07-22022 July 1999 Forwards Rept Providing Results of Insp of Eggcrate Tube Supports Done on Secondary Side of Sgs,Using Remote Controlled Visual Equipment ML20210B2451999-07-21021 July 1999 Forwards Response to NRC 990615 RAI Re GL 95-07, Pressure Locking & Thermal Bldg of SR Power-Operated Gate Valves, for Songs,Units 2 & 3 ML20210B9891999-07-20020 July 1999 Ack Receipt of Transmitting Plant Emergency Plan Implementing Procedure SO123-VIII-1, Recognition & Classification of Emergencies ML20209J5241999-07-19019 July 1999 Provides Clarification of Util Intentions Re Disposition of Systems for Which Exemption & TS Changes Were Requested in Licensee .Deferment of Action Re Hydrogen Monitors,Encl ML20210N2881999-07-19019 July 1999 Forwards Rev 61 to Physical Security Plan,Rev 21 to Safeguards Contingency Plan & Rev 20 to Security Force Training & Qualification Plan,Per 10CFR50.54(p),for Plant. Screening Criteria Forms Encl.Plans Withheld ML20210A2911999-07-19019 July 1999 Submits Withdrawal Request Submitted by Ltr Dtd 990312, Requesting NRC Approval of Revs to Physical Security Plan & Safeguards Contingency Plan Tactical Response Plan ML20209G3421999-07-15015 July 1999 Forwards Table of 16 Affected Tube Locations in SG E089, Discovered During Cycle 10 Outage Insp,Which Were Probably Not Examined by Bobbin During Cycle Outage Insp ML20209D8051999-07-12012 July 1999 Discusses Licensee Response to RAI Re GL 92-01,Rev 1,Suppl 1, Rc Structural Integrity, Issue on 950519 to Plant. NRC Revised Info in Reactor Vessel Integrity Database & Is Releasing It as Rvid Version 2 ML20209F5681999-07-0909 July 1999 Forwards Insp Repts 50-361/99-08 & 50-362/99-08 on 990516- 0626.One Violation Identified & Being Treated as Noncited Violation,Consistent with App C of Enforcement Policy ML20209C1571999-07-0202 July 1999 Forwards Response to NRC RAI Re SCE Submittal Dtd 980710,re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20196K6721999-07-0202 July 1999 Discusses 990628 Meeting Conducted in Region IV Office Re Status of San Onofre Nuclear Generating Station Emergency Preparedness Program.List of Attendees & Licensee Presentation Encl 1999-09-03
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217L9491999-10-21021 October 1999 Forwards SONGS Emergency Response Telephone Directory, for Oct-Dec 1999 ML20217K3571999-10-21021 October 1999 Discusses Use of SONGS as Generic Safety Issue 191 Ref Plant.Future Requests for Info & Addl Coordination Activities Be Handled Through D Evans of Organization.With Diskette ML20217K8541999-10-21021 October 1999 Forwards Revised Pages to ERDS Data Point Library,Per Requirements of 10CFR50,App E,Section VI.3.a.Described Unit 2 & 3 Changes for 2/3R7813 Were Completed on 990924 ML20217E3221999-10-13013 October 1999 Forwards MORs for Sept 1999 for Songs,Units 2 & 3.No Challenges Were Noted to Psvs for Either Units 2 or 3 ML20217E7671999-10-12012 October 1999 Forwards Rev 62 to NRC Approved Aug 1983, Physical Security Plan,Songs,Units 1,2 & 3, IAW 10CFR50.54(p).Changes,as Described in Encls 1 & 2,do Not Reduce Effectiveness of Plan.Encl Withheld,Per 10CFR73.21 ML20216H8741999-09-29029 September 1999 Provides Requested Written Response to GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Lab Testing of Charcoal Adsorber Samples for Creacus & Pacu Satisfies Listed Requirements ML20216H8541999-09-29029 September 1999 Submits Encl Request for Relief from ASME Code,Section III Requirements in 10CFR50.55(a)(3) to Use Mechanical Nozzle Seal Assembly as Alternate ASME Code Replacement at SONGS, Units 2 & 3 for Period of Operation Beginning with Cycle 11 ML20212H4461999-09-28028 September 1999 Forwards Suppl Info,As Discussed with NRC During 990812 Telcon,To Support Risk Informed Inservice Testing & GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20212G5611999-09-24024 September 1999 Informs NRC That SCE Remains Committed to Performing Eddy Current Examinations of 100% of Reactor Vessel Head Penetrations at Songs,Unit 3.Exams Will Not Be Performed During Cycle 11 RFO 05000361/LER-1999-005, Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments1999-09-23023 September 1999 Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments ML20212A4061999-09-14014 September 1999 Forwards Revised Pages to ERDS Data Point Library.Described Unit 2 Changes for 2R7817 & 2R7828 Were Completed on 990818 & Unit 3 Change for 3R7828 Was Completed on 990903 ML20216E6031999-09-10010 September 1999 Provides Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Dtd 990820.Schedule Shown on Attachment 1, Operator Licensing Exam Data, Provides Util Best Estimate Through Cy 2003 05000206/LER-1999-001, Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 31999-08-31031 August 1999 Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 3 ML20210V4271999-08-16016 August 1999 Forwards Proprietary Certified Renewal Applications for SROs a Harkness,R Grabo & T Vogt & RO D Carter,Submitted on Facsimile Form NRC-398 & Certified NRC Form 396.Encls Withheld ML20210R6681999-08-13013 August 1999 Forwards Response to NRC RAI Re SCE License Amend Applications 173 & 159 for Songs,Units 2 & 3,proposed Change Number 485,which Requests Addition of SR to TS 3.3.9, CR Isolation Signal ML20210Q6451999-08-12012 August 1999 Forwards Monthly Operating Repts for July 1999 for SONGS, Units 2 & 3,per TS 5.7.1.4.There Were No Challenges to Pressurizer Safety Valves for Either Units ML20210P5711999-08-11011 August 1999 Forwards Amend Application Number 189 for License NPF-10 & Amend Application Number 174 to License NPF-15,replacing Analytical Limits Currently Specified as Acceptance Criteria with Allowable Values,Per Encl Calculation E4C-098 ML20210P4681999-08-11011 August 1999 Forwards COLR for Cycle 10 for Songs,Units 2 & 3,IAW TS Section 5.7.1.5.d, Colr. Changes to COLR Parameters Have Been Conducted IAW Approved COLR Methodologies & All Applicable Limits of Safety Analysis Were Met ML20210P6221999-08-10010 August 1999 Forwards Replacement Pages for Attachments E & F of Amend Application Numbers 168 & 154 for Songs,Units 2 & 3.Pages Are Provided to Correct Errors to Pagination & Headings in 970618 Submittal ML20210N5051999-08-0909 August 1999 Forwards Cycle 10 Update to TS Bases,Which Have Been Revised Between 980101-990630,per 10CFR50.71(e) 05000361/LER-1999-004, Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl1999-08-0606 August 1999 Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl ML20210L2311999-08-0505 August 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements,For Songs,Unit 3.Rept Covers 970916 Through 990509,date Unit 3 Returned to Service Following Cycle 10 Refueling Outage ML20216D9671999-07-29029 July 1999 Provides Response to RAI to Support Proposed TS Change 460 Re Containment Isolation Valve Completion Time for SONGS, Units 2 & 3.Rev 3 to Abnormal Operating Instruction SO23-13-14, Reactor Coolant Leak, Encl ML20210C1821999-07-22022 July 1999 Forwards Rept Providing Results of Insp of Eggcrate Tube Supports Done on Secondary Side of Sgs,Using Remote Controlled Visual Equipment ML20210B2451999-07-21021 July 1999 Forwards Response to NRC 990615 RAI Re GL 95-07, Pressure Locking & Thermal Bldg of SR Power-Operated Gate Valves, for Songs,Units 2 & 3 ML20210A2911999-07-19019 July 1999 Submits Withdrawal Request Submitted by Ltr Dtd 990312, Requesting NRC Approval of Revs to Physical Security Plan & Safeguards Contingency Plan Tactical Response Plan ML20210N2881999-07-19019 July 1999 Forwards Rev 61 to Physical Security Plan,Rev 21 to Safeguards Contingency Plan & Rev 20 to Security Force Training & Qualification Plan,Per 10CFR50.54(p),for Plant. Screening Criteria Forms Encl.Plans Withheld ML20209J5241999-07-19019 July 1999 Provides Clarification of Util Intentions Re Disposition of Systems for Which Exemption & TS Changes Were Requested in Licensee .Deferment of Action Re Hydrogen Monitors,Encl ML20209G3421999-07-15015 July 1999 Forwards Table of 16 Affected Tube Locations in SG E089, Discovered During Cycle 10 Outage Insp,Which Were Probably Not Examined by Bobbin During Cycle Outage Insp ML20209C1571999-07-0202 July 1999 Forwards Response to NRC RAI Re SCE Submittal Dtd 980710,re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20210N9871999-07-0101 July 1999 Appeals Denial of Documents Re Sept 1996 Osre for San Onofre Nuclear Generating Station.Requests Copies of Sept 1996 Osre Rept & Any More Recent Osre Repts ML20209B3571999-06-28028 June 1999 Submits Response to GL 98-01,Suppl 1 Y2K Readiness of Computer Sys at Nuclear Power Plants. GL 98-01 Requested Response on Status of Facility Y2K Readiness by 990701. Disclosure Encl ML20209B4831999-06-25025 June 1999 Requests NRC Approval of Six Relief Requests from ASME Code Requirement for Containment ISI Exams.Six Relief Requests, Provided as Enclosures 1-6,are as Listed ML20196A9801999-06-17017 June 1999 Responds to NRC 990420 RAI Re Proposed risk-informed Inservice Testing & GL 96-05 Programs at Songs,Units 2 & 3. Revised Pages to risk-informed Inservice Testing Program, Encl ML20195G8091999-06-14014 June 1999 Forwards Response to RAI Made During 990511 Telcon Re LARs 184 & 170 for SONGS Units 2 & 3.Amend Applications Proposed Restriction on Operation with Channel of RAS or Efas in Tripped Condition ML20195K4201999-06-11011 June 1999 Forwards LERs 99-003-00 & 99-004-00 Re Manual Esfas (Reactor Trips) Due to Problems with Main Feedwater Control.Two Events Are Being Reported Separately Because Actual Causes Are Considered Different & Independent of Each Other ML20195H1561999-06-10010 June 1999 Forwards MORs for May 1999 for Songs,Units 2 & 3.There Were No Challenges to Pressurizer Safety Valves for Either Unit 2 & 3 ML20195E4981999-06-0808 June 1999 Forwards Application for Amends 188 & 173 to Licenses NPF-10 & NPF-15 for SONGS Units 2 & 3,respectively.Amends Would Revise TS 3.5.2,3.1.9,3.7.1 & 5.1.7.5 Re Small Break LOCA Charging Flow & Main Steam Safety Valve Setpoints ML20196L3191999-05-24024 May 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements for Songs,Unit 2.Rept Covers Period of 970916-990226 ML20207A3831999-05-24024 May 1999 Responds to NRC 990326 RAI on DG Srs.Proposed to Add Listed Sentence to TS Bases for SRs 3.8.1.7,3.8.1.12 & 3.8.1.15,as Result of Discussion with NRC During 990427 Telcon ML20211K4261999-05-18018 May 1999 FOIA Request for Documents Re San Onofre OI Repts 4-98-041, 4-98-043 & 4-98-045 ML20206S7161999-05-17017 May 1999 Forwards MORs for Apr 1999 for Songs,Units 2 & 3.There Were No Challenges to Pressurizer Safety Valves for Either Unit 2 or 3 ML20206N4711999-05-13013 May 1999 Provides Info Requested by NRC Re Reduced Pressurizer Water Vol Change Amends Application 172 & 158 for Songs,Units 2 & 3,respectively.Proposed Change Will Reduce Pressurizer Water Level Required for Operability ML20206M7791999-05-13013 May 1999 Informs NRC of Changes Being Made to Emergency Response Data Sys (ERDS) at SONGS Unit 3.Revised Page to ERDS Data Point Library Is Provided in Encl ML20206K6891999-05-11011 May 1999 Forwards Approved Amends to NPDES Permits CA0108073,Order 94-49 & CA0108181,Order 94-50 & State Water Resources Board Resolution ML20206M0681999-05-10010 May 1999 Submits Correction to Info Contained in Licensee to NRC Re Proposed TS Change Number NPF-10/15-475.Stated Info Was Incorrect in That Overtime Provisions Were Not Contained in TR at Time of Was Submitted ML20206H0451999-05-0404 May 1999 Forwards Annual Financial Repts for Listed Licensees of Songs,Units 1,2 & 3.Each Rept Includes Appropriate Certified Financial Statement Required by 10CFR50.71(b) ML20206H1931999-05-0303 May 1999 Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl ML20206C5151999-04-29029 April 1999 Forwards 1998 Radiological Environ Operating Rept for Songs,Units 1,2 & 3. Annual Radiological Environ Operating Rept Covers Operation of Songs,Units 1,2 & 3 During CY98 & Includes Summaries Interpretations & Analysis of Trends ML20206E5851999-04-29029 April 1999 Forwards Annual Radioactive Effluent Release Rept for 1998 for SONGS Units 1,2 & 3. Also Encl Are Rev 13 to Unit 1 ODCM & Rev 31 to Units 2 & 3 Odcm 1999-09-29
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059C1071990-08-24024 August 1990 Forwards Addenda 10-1A,10-1B & 10-1C to Physical Security Plan.Encls Withheld (Ref 10CFR73.21) ML20059E6951990-08-24024 August 1990 Forwards Rev 30 to Physical Security Plan.Rev Withheld (Ref 10CFR73.21) ML20059B8861990-08-22022 August 1990 Advises That Dl Hill Employment W/Util Terminated,Effective 900817.Operator License OP-50333 Expired ML13302B3411990-08-21021 August 1990 Responds to NRC Bulletin 88-010 Re Nonconforming molded-case Circuit Breakers (Mccbs).Affected MCCBs Purchased for Use in safety-related Applications,Including MCCBs Used W/Motor Controllers.Outage Rept Encl,Per 890330 Ltr ML20064A2161990-08-16016 August 1990 Responds to NRC Re Violations Noted in Insp Repts 50-361/90-16 & 50-362/90-16.Reply to Notice of Violation Not Required Due to Sufficient Info Provided in ,Per 900807 Discussion W/R Huey ML13309A9211990-08-14014 August 1990 Forwards Monthly Operating Repts for Jul 1990 for San Onofre Units 2 & 3,revised Unit 2 Monthly Operating Rept for June 1990 & Rev 22 to ODCM ML20058Q2961990-08-14014 August 1990 Forwards Util & June 1990 NPDES Monitoring Rept. W/O Rept ML20058N0371990-08-0909 August 1990 Advises That on 900713,new Land Use Located W/Calculated Dose Greater than Value Currently Calculated.New Location Results in Annual Dose Increase of 27% for Units 2 & 3 & 39% Increase for Unit 1 ML20056A1781990-08-0202 August 1990 Discusses Review of Possibility of Accelerating Schedule for Performing & Submitting Results of Individual Plant Exams for Units 1,2 & 3.Util Believes That Submittal Schedule for Unit 1 Can Be Accelerated to 920102 ML18041A2221990-07-31031 July 1990 Responds to NRC 900518 Ltr Re Violations Noted in Insp Repts 50-206/90-10,50-361/90-10 & 50-362/90-10.Corrective Action: computer-based Mgt Sys Will Be Developed to Permit Incoming Revised Info to Be Matched W/Documents Requiring Review ML20055H9641990-07-27027 July 1990 Responds to NRC Re Violations Noted During Special Safety Sys Functional Insp on 891030-1130.Corrective Action:Util Will Review & Revise Operating & Calibr Procedures by 901031 ML20055H5731990-07-24024 July 1990 Provides Notification of Completion of Installation of Backup Nitrogen Sys Isolation Check Valves & Test Connections at Facility ML20055H2631990-07-23023 July 1990 Discusses Model 3RE-7870 Not Being Declared Operable Due to Lack of Process Flow.Monitor Failed on 900708.Caused by Moisture Intrusion Into Housing.All Affected Components Repaired or Replaced ML20055F1901990-07-0909 July 1990 Informs That Ej Schoonover Employment W/Util Terminated, Effective 900629 ML20044A4121990-06-27027 June 1990 Requests Approval of Use of Plugs Fabricated of nickel-chromiun-iron Uns N-06690 Matl to Plug Tubes in Plant Steam Generators.Change to Use Alloy 690 Tube Plugs Results from Matl Corrosion Consideration ML20056A8841990-06-25025 June 1990 Responds to NRC Forwarding Insp Repts 50-206/90-10,50-361/90-10 & 50-362/90-10.Results of Review of Awareness & Response to Industry Check Valve Concerns & Evaluation of Need to Establish Dedicated Program Provided ML20043H7851990-06-19019 June 1990 Informs That Jl Mullins Employment W/Util Terminated Effective 900608.Operator License OP-50089-2 Expired ML20043H5101990-06-19019 June 1990 Informs That Wk Giffrow Employment W/Util Terminated. Operator License OP-50050-2 Expired ML13304A4861990-06-0404 June 1990 Forwards Evaluation of Unisolable Piping from RCS W/Potential for Leakage Induced Thermal Stresses in Response to NRC Bulletin 88-008 SONGS 2 & 3, in Response to Request ML20043B4911990-05-22022 May 1990 Submits Rept:On 900507,eddy Current Insp of Steam Generator Tubing Completed.Of 2,106 Tubes Inspected in Steam Generator E-088 No Tubes Found Defective.One Tube in Steam Generator E-089 Found Defective & Plugged ML20043B1411990-05-17017 May 1990 Informs That Senior Reactor Operator License No Longer Needed for JW Ryder,Effective 900425.License SOP-50288 Expired on 900425 ML13309A9151990-05-14014 May 1990 Forwards Monthly Operating Repts for Apr 1990 for San Onofre Nuclear Generating Station Units 2 & 3 ML20043A0051990-05-0404 May 1990 Informs of Expiration of WR Seiler Senior Reactor Operator License,Effective 900502 ML20042G6531990-05-0303 May 1990 Forwards Addendum 10-1B to Physical Security Plan.Encl Withheld (Ref 10CFR73.21) ML20042F7101990-05-0202 May 1990 Informs That Gb Swift Transferred to Position Not Requiring Operator License,Effective 900423 & License Expired,Per 10CFR55.55(a) ML20012E8341990-03-29029 March 1990 Advises That Reactor Operator License OP-50072-2 Expired on 900312 & No Longer Needed ML13303B1981990-03-12012 March 1990 Forwards Table Re FSAR Chapter 15 Design Basis Event & Rev 0 to M-89047, Instrument Drift Study San Onofre Nuclear Generating Station Units 2 & 3, in Support of Proposed Change Notices 275 & 280,per NRC Request ML20012B6701990-03-12012 March 1990 Advises That Response to SSFI Repts 50-361/89-200 & 50-362/89-200 Will Be Provided by 900412 Due to Unexpected Diversion of Resources to Address Other Issues Such as Trip of Unit 3 on 900223 & Safety Valve Evaluations ML13304A4591990-03-0707 March 1990 Forwards Rev 0 to M 86420, Spurious Actuation Evaluation Component Cooling Water Sys - Operability Assessment. ML20012B8061990-03-0505 March 1990 Responds to NRC 900205 Ltr Re Violations Noted in Insp Repts 50-361/89-33 & 50-362/89-33.Corrective Actions:Action Taken W/Responsible Supervisor to Ensure That Health Physics Technician Overtime Controlled & Authorized ML13304A4551990-02-16016 February 1990 Forwards Rev 6 to Spent Fuel Pool Reracking Licensing Rept. Encl 1 Lists Summary of Rev 6 Changes & Encl 2 Lists Changes (Insert Pages) to Rev 5 Reracking Licensing Rept ML20006E8801990-02-14014 February 1990 Informs That Dl Daily Employment W/Util Terminated Effective 900209.License SOP-50229-1 Expired ML20006D9661990-02-0707 February 1990 Advises That Listed Individuals No Longer Require Senior Reactor Operator Licenses,Effective on 900117 ML20011E5041990-02-0707 February 1990 Informs of Termination of Rl Sprague Employment W/Util, Effective 900125 ML13303B1871990-01-18018 January 1990 Forwards Rev 5 to Amend Applications 64 & 78 to Licenses NPF-10 & NPF-15,respectively,re Spent Fuel Pool Reracking. New Racks Will Increase Number of Storage Locations in Each Spent Fuel Pool from 800 to 1,542 Elements ML20011F0381990-01-18018 January 1990 Documents Commitment Re Impact of outage-related Overtime, Based on Interview at Site on 900112.Util Will Not Schedule Heavy Use of Overtime for Duration of Refueling Outage for Personnel Addressed by Tech Specs Assigned to Unit ML13303B1791990-01-0808 January 1990 Forwards Amend Applications 70 & 56 to Licenses NPF-10 & NPF-15,respectively,revising Tech Spec 3/4.3.3.5, Remote Shutdown to Increase Interval for Refueling Surveillance Tests to Nominally 24 Months & Max of 30 Months ML13303B1841990-01-0808 January 1990 Forwards Amend Applications 69 & 55 to Licenses NPF-10 & NPF-15,respectively,consisting of Proposed Tech Spec Change NPF-10/15-275 Re Refueling Interval Surveillances ML19332F0631989-12-0505 December 1989 Informs of Termination of MP Mcdonnell Employment W/Util, Effective 891128 ML19332F1181989-12-0505 December 1989 Provides Schedule for Installation of Diverse Emergency Feedwater Actuation Sys at Plant,Per 890808 Commitment. Schedule for Significant Conceptual Engineering Tasks Completed & Major Tasks to Be Completed Summarized ML20005D7331989-12-0505 December 1989 Advises That RW Dougherty Transferred to Position within Util Which Does Not Require Reactor Operator License, Effective 891204.License OP-50193-1 Expired ML19332D8731989-11-27027 November 1989 Responds to NRC 891027 Ltr Re Violations Noted in Insp Repts 50-361/89-24 & 50-362/89-24.Corrective Actions:Temporary Cables Passing Through Doorway Removed & Maint Order Revised & Reissued to Incorporate Creacus Boundary Requirements ML19332D3261989-11-20020 November 1989 Responds to NRC 891027 Ltr Re Violations Noted in Insp Repts 50-361/89-24 & 50-362/89-24.Corrective Actions:Requirements of Tech Spec 3.0.3 Applied & Applicability Reinforced W/Appropriate Personnel ML19332F4321989-11-15015 November 1989 Forwards Addendums 10-1B & 10-1C to Physical Security Plan. Encl Withheld (Ref 10CFR73.21) ML13304A4381989-11-0909 November 1989 Forwards Proprietary WNEP-8926 & Nonproprietary WNEP-8930, San Onofre Units 2 & 3 Fuel Rack Seismic Analysis for Final Pool Layout. Util Application for Withholding Ltr, CAW-89-104,Proprietary Info Notice & Affidavit Also Encl ML13303B1621989-11-0202 November 1989 Forwards Rev 4 to Amend Applications 78 & 64 to Licenses NPF-10 & NPF-15,respectively,re Spent Fuel Reracking & Proposed Tech Spec on Request from Staff Requiring Min Spent Fuel Pool Boron Concentration ML19325D9781989-10-19019 October 1989 Discusses Completion of Steam Generator Tubing Insp.Total of 4,316 Tubes Inspected & 62 Tubes Removed from Svc by Mechanical Plugging.Insp Significantly Exceeded Amount of Tubing Required to Be Inspected ML19325D1881989-10-0606 October 1989 Informs of Termination of Employment of RA Barnes as Licensed Senior Reactor Operator on 890929 ML20248G6821989-09-29029 September 1989 Advises That Wj Kirkpatrick Employment Terminated on 890922 & License Expired ML20248H1101989-09-29029 September 1989 Advises That Wc Kingsley Employment W/Util Terminated, Effective 890915 1990-08-09
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_f~DY Southem Califomia Edison Company P. O. BOX 128 SAN CLEMENTE, CALIFORNIA 92672 H ARO LO B. R AY vtCE PRESIDENT & SITE MANAGER TELEPHONE
.AN oNon E May 20, 1986 a+=7o U. S. Nuclear Regulatory Commission $,
Office of Inspection and Enforcement -
t' Region V 1450 Maria Lane, Suite 210 a Walnut Creek, California 94596-5368 7 9, - i V. '
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p Attention: Mr. J. B. Martin, Regional Administrator a
Dear Sir:
Subject:
Docket Nos. 50-361 and 50-362 I. E. Inspection Reports 50-361/86-08 and 50-362/86-08 Response to Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3 1
l Mr. A. E. Chaffee's letter of April 25, 1986, issued IE Inspection 1 Reports 50-206/86-09, 50-361/86-08 and 50-362/86-08, and forwarded a Notice of Violation (NOV) resulting from the February 15 through March 27, 1986 inspection conducted by Messrs. F. R. Huey, J. P. Stewart, A. J. D'Angelo, J. E. Tatum and Ms. R. C. Tang.
The enclosure to this letter provides the Southern California Edison Company response to the Notice of Violation contained in Appendix A of Mr. Chaffee's letter of April 25, 1986. Although action has been taken in response to the conditions observed by the NRC, we respectfully request that the Notice of Violation be withdrawn. As discussed in the enclosure, we do not believe the requirements referenced as the bases for the Notice of Violation are applicable to the conditions observed, and we do not believe that the conditions warrant issuance of a Notice of Violation on any other bases.
If you have any questions, or if we can provide additional information, please let me know.
Sincerely,
Enclosure:
As stated cc: F. R. Huey (USNRC Senior Resident Inspector, Units 1, 2 and 3) 8607080072 860702 PDR ADOCK 05000361 0 PDR ~ _
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ENCLOSURE Response to the Notice of Violation contained in Appeadix A to A. E. Chaffee's letter of April 25, 1986.
Appendix A to Mr. Chaffee's letter of April 25, 1986, states:
"A. 10 CFR 50, Appendix B,_ Criterion V, states in part that, ' Activities affecting quality shall be prescribed by documented instructions, procedures,'or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. . . '
" Southern Calffornia Edison Topical Quality Assurance Manual (TQAM),
Chapter 4-C, states in part that:
1.0 Housekeeping requirements and practices shall be controlled in accordance with written procedures and instructions ...
3.0 Work activities shall be planned and implemented in a manner which assures that satisfactory housekeeping.
i practices are provided. Consideration for housekeeping should include provisions for waste removal; orderly storage of material in use;
" Administrative procedure S0123-GAO-3 (sic) titled, ' Site Housekeeping and Cleanliness Control,' defines the following requirements:
IV.A.2. Laydown and storage areas shall be kept clean and orderly; excess material shall not be allowed to accumulate.
IV.A.4. All passageways and aisles shall be kept clear.
" Fire Protection Procedure, 50123-XIII-13 titled, ' Weekly Inspection for the Control of Combustibles and Transient Fire Loads,' which implements Site Order S0123-GAO-3 (sic), states, in part, 6.2.9 All ... wood stored or used in the Protected Area shall be self-extinguishing, fire retardant or treated with fire retardant material and should be approved for intended use.
"S0123-XVI-2.0, ' Safe Practices for Storage and Handling of Compressed Gas Cylinders,'-states: l 6.1.4.1 Cylinders not securely stored in permanent areas -
shall be secured at two (2) points; the attachments !
must be at least 1/2 inch manila rope or equivalent. I l
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ENCLOSURE (Continued)
" Contrary to the 'above, during the period of March 10-20,.1986, the following conditions were observed on the 37 foot level-in the Units 2 and 3 Radwaste Building.
Areas adjacent to _ corridors '318 and_320 were' not kept clean and orderly, excessive materials had accumulated:in these areas and
, ' adjacent passageways were not kept clear. ' Specifically:
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- 1. Approximately 100 bags of. assorted combustible materials, 8 unused wooden pallets,10 empty .
1 cardboard drums,10 empty cardboard boxes and 50 cubic feet of lumber were not in use or properly stored.
- 2. The access area'to corridor 318 was filled with-materials stacked 30 inches in height, and corridor 3?0 had been reduced from nine to two feet in width by improper storage of excessive materials.
- 3. Housekeeping control tags were not affixed-to several compressed air cylinders and wooden pallets, which were not in use.
Eight wooden pallets, which were not fire retardant or treated, were stored and not in use for a period of at 'least 10 days.
Ten compressed gas cylinders were not secured at two points,
! but only loosely supported at one point.
"This is a Severity Level IV Violation (Supplement 1) applicable to Units 2 and 3."
RESPONSE _
- 1. FACT AND CIRCUMSTANCES HOUSEKEEPING l
Waste and other materials, which require removal from work areas, are l
. controlled by Station Housekeeping in accordance with procedure 50123-GAD-3, " Site Housekeeping and Cleanness Control." S0123-GAD-3 states in part.(emphasis added):
"(III.8) . . . All Site supervisory personnel are responsible for l
-ensuring that the following are accomplished: 1. Work Sites under l their supervision are kept as clean and safe as is feasible for the type of work being performed . . ."
"(III.F) . . . Manager, Station Emergency Preparedness is responsible for ensuring compliance with Station housekeeping and cleanliness procedures as they relate to the-following: 1.. Adhering to the fire prevention and protection measures."
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ENCLOSURE (Continued)
Under this procedure, site personnel implement a " clean as you go" philosophy. Waste materials are collected, bagged or palletized, and are removed from the work area as rapidly as possible by Station Housekeeping. Periodic walkdowns of the plant are conducted by fire protection personnel to ensure identification and evaluation of housekeeping conditions to ensure fire prevention and protection measures remain effective. This program has been effective over the past year.
As noted by the inspector in the subject inspection report, he stated housekeeping was " good in most of the areas toured."
If the material is in a Health Physics (HP) control zone, in accordance with procedure 50123-VII-7.3.1, the material must be surveyed in order to prevent radioactively contaminated material from leaving the facility.
Waste found in HP control zones is moved to either the 70 foot or 37 foot elevations, where HP crews survey the material, segregating contaminated from non-contaminated waste. This program has been effective in reducing solid radwaste volume. However, the 70 foot elevation is a major access / egress passage and in November 1985, the 37 foot elevation was selected as the overflow HP survey location.
In January and February 1986, Health Physics personnel conducted refresher training classes for Project and Maintenance personnel on the
" clean as you go" responsibilities. As a result, site personnel rigorously implemented housekeeping cleanup activities, and a noticeable increase in material moved to the 37 foot elevation for HP survey occurred.
In early March 1986: Unit 3 was returning to service from an outage; Unit 2 was preparing for an upcoming outage; miscellaneous material stored in bins, cages and rooms in all levels of Units 2 and 3, which was no longer being used, was identified as needing to be removed; and, the 68 foot elevation locker room was remodeled, generating significant construction debris. These activities were recognized as producing a great influx of material into the housekeeping process, with the majority of waste being removed from inside the HP control zone.
Project and Maintenance personnel interfaced with Health Physics and Fire Protection personnel, informing them of the impending increase in the waste material generation rate. Housekeeping personnel staged the overflow material in the 37 foot elevation staging area where HP personnel surveyed it consistent'with other assigned duties. This location is not a storage area and was not being utilized for permanent or long term retention. Staging in such a manner denotes a temporary backlog situation where material accumulates, awaiting survey and subsequent release to a storage area or release for disposal.
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ENCLOSURE (Continued)
In accordance with the previously quoted S0123-GAD-3, " . . . All Site supervisory personnel are responsible for ensuring that the following are accomplished: 1. Work Sites under their supervision are kept as clean and safe as is feasible for the type of work being performed . . . ", Further controls are applied to specific types of work sites in Section IV.A.2, of S0123-GAD-3 which states "Laydown and storage areas shall be kept clean and orderly; excess material shall not be allcwed to accumulate. "
Step IV.A.2 in Procedure S0123-GAD-3, addresses the interim storage of materials utilized in locations where a specific type of work activity is performed. This step was specifically developed to address concerns arising from the interim storage of materials required for construction and major maintenance activities, and is in accordance with TQAM Chapter 4-C which states in part ". . . orderly storage of material in use. . ." (emphasis added).
As cited above, this step does not address the temporary staging of materials such as the subject materials, which require surveys prior to being released from a radiological zone. Rather, general housekeeping standards that ensure "high standards of cleanliness" and " proper storage" would apply to a staging area. Although there was more material in the 37 foot elevation staging area than is SCE's normal practice, the quantities were not particularly unusual for such an area during a time when one unit was returning to service while the other unit was preparing for an outage. This material was stacked in an orderly manner and was roped or taped off, as circumstances permitted.
As previously quoted, 50123-GAD-3 states in part:
"(III.F) . . . Manager, Station Emergency Preparedness is responsible for ensuring compliance with Station housekeeping and cleanliness procedures as they relate to the following:
- 1. h hering to the fire prevention and protection measures . .
and " IV.A.4 All passageways and aisles shall be kept clear."
In compliance with this cited procedural step, the Manager, Station Emergency Preparedness (EP) assesses the impact of staged material on the Station's fire prevention and protection program. This is accomplished through walkdowns conducted by Emergency Services personnel (i.e. fire fighters) knowledgeable in this programmatic area.
These personnel (in consultation with a fire protection engineer) initially reviewed the location and fire loading of the 37 foot elevation as a staging area. Their review ensured that the use of this staging area would not result in an excess fire load or preclude the fire brigade from responding to a fire. The temporary impeding of access in the hallways for material staging was evaluated as acceptable by Emergency Preparedness.
In effect, although the area is architecturally a hallway, it had purposefully been redesignated as a staging area for this material. It is a suitable area for this purpose, and no other suitable area was available.
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i ENCLOSURE (Continued)
At no time during the period when the material was being accumulated did the staging area fire rating exceed 10% of the maximum allowable combustible fire load. At no time was the fire brigade's ability to respond to a fire impaired (it should be noted that dual alternate routing always existed). Additionally, there is no safety related equipment in this area. Therefore, the staging area was a well considered, fully evaluated solution to a temporary increase in material staged, awaiting HP survey.
Material generated as a result of the Unit 3 outage was placed in the staging area, subsequently surveyed by HP, and was removed for disposal or to storage areas outside the HP control zones. During each shift, additional materials were accumulated and taken to the 37 foot elevation for HP survey. Around March 1,1986, a prior backlog of material was surveyed and all material was completely removed from the staging area.
Subsequent to the March 1, 1986 removal, an increasing backlog was indicated in EP reports datad March 4 and 10, 1986. The fire protection personnel performing the daily surveillances were not fire protection engineers. Their reports are intended to identify areas which are in turn evaluated by fire protection engineers and Health Physics personnel. As was noted in the NRC inspection report, these requests prompted Fire Protection Engineering reevaluations to ensure there were no fire brigade response impacts or quantities exceeding the combustible fire load rating (there were none).
Further, Health Physics personnel continuously tracked and assessed the material. There was no safety significance to the backlog, and HP personnel prioritized the work commensurate with its overall significance.
Between March 10 and March 20, 1986, the NRC Resident Inspector observed the activities in the staging area, and obtained Fire Safety Reports identifying the area as a concern. On March 20, 1986, the inspector contacted Fire Protection and Quality Control personnel concerning the apparent non-compliance in the staging area. On March 21 and 22, HP personnel stopped all other non-critical activities and commenced surveying and releasing the material. This activity was completed by March 26, 1986. Housekeeping personnel subsequently removed the material for disposal.
SCE acknowledges that the quantity of material on the 37 foot elevation of the radwaste building exceeded that which we would have preferred to have in the area. However, SCE concludes that: (1) no unsafe condition existed; (2) there was no safety significance to the staging of the material; (3) procedural steps in 50123-GAD-3 were not violated in the staging area. On the contrary, SCE was in compliance with the aforementioned procedure which controls housekeeping in the plant work areas, and SCE actively monitored the status of the housekeeping in the staging area.
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ENCLOSURE (Continued)
WOODEN PALLETS Procedure S0123-XIII-13, Section 6.2.9, is quoted below in its entirety:
"All plastic covering sheets and wood stored or used in the Protected Area shall be self-extinguishing, fire retardant or treated.with fire retardant material and should be approved for intended use.
" NOTE: Ladders and trash receptacles are not considered transient fire loads because of their small contribution to fire loading and their regular removal."
Section 6.2.9 was written to address the use of wood that was to be placed permanently in the plant or whose use was more than transitory in nature. Our construction and maintenance efforts frequently require the use of lumber for e:. tended periods of time. As a prudent measure to ensure the lumber does not unnecessarily increase the fire hazard in the area, only treated wood is used for these activities. It is not a general industry practice to use treated wood for packaging or palletized materials as the wood becomes more brittle. It is not now, nor has it ever been, SCE's intention to apply this requirement to wooden pallets.
On the contrary, as indicated in the note to Section 6.2.9, the procedure is not applicable to certain wooden items. The wooden pallets, similar to trash receptacles, ladders and other temporary use wooden items, are of small contribution to the fire loading. Wooden pallets are regularly removed, and are in fact used to remove waste material. Therefore, the presence of wooden pallets at the staging area is expected, and the use without fire retardant is permissible.
COMPRESSED GAS CYLINDERS 4
Procedure 50123-XVI-2.0, " Safe Practices for Storage and Handling of Compressed Gas Cylinders", is an industrial safety procedure. In accordance with CAL /0SHA and the SCE Accident Prevention Manual, the procedure provides information for the safe storage and handling of compressed gas cylinders.
50123-XVI-2.0 (the current issue is Rev. O, TCN 0-3, issued January 15, 1986) contains the explicit statement that it is not QA affecting. As such, this procedure falls outside of the scope of 10 CFR 50, Appendix B, Criterion V, which controls " Activities affecting quality. . ." , with quality assurance being defined as "all those planned and systematic actions necessary to provide adequate confidence that a structure, system or component will perform satisfactorily in service." SCE considers that these non-safety related areas have been outside the scope of NRC ,
noncompliance sanctions for failure to follow procedures. In any case, '
Severity Level V would appear to apply, even if procedural compliance in !
this area were considered subject to NRC sanctions.
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SCE does maintain and fully implement a QA affecting procedure relating to the use of gas cylinders around safety related equipment:
S0123-VI-23.0, " Implementation of Site Housekeeping and Cleanness Controls". Section 6.3.17 states, " Compressed gas bottles in or about safety-related structures, systems, or components must be firmly secured or stored in a permanent structure (non-mobile racks) when not in use."
SCE acknowledges that the gas cylinders noted (which coincidently contained non-flammable gas) were not " firmly" secured. However, the staging area does not contain any safety related equipment. Furthermore, each gas cylinder had its nozzle cover in place, thereby preventing the bottle from losing its contents or becoming a missile from a stem break should the bottle fall. There was no safety significance to the subject cylinders being loosely secured.
- 2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As previously stated, by March 26, 1986, the material was surveyed and -
removed.
As directed by Health Physics supervision, wooden pallets are now removed daily for reuse. The gas bottles were secured with two ropes by March 26, 1986, and a permanent gas bottle storage rack has been installed in the 37 foot elevation.
On May 5, 1986, procedure S0123-GAD-3 was revised to explicitly delineate different criteria for the appropriate housekeeping controls for the Health Physics survey staging areas, differentiating them from laydown and storage area housekeeping controls, provided appropriate fire protection evaluations are performed.
These corrective actions were taken as a matter of good practice and in response to concerns expressed by the NRC inspector. The conditions which existed are not considered to have violated NRC requirements.
Notwithstanding this, if procedural adherence is considered to be a generic issue in this case, unrelated to the lack of safety significance of the conditions observed, then SCE considers that Severity Level V violation would be the most severe classification warranted. Because the conditions were intentionally established for the reasons described above, this case is not considered to be a repetition of any prior violation of NRC requirements related to housekeeping.
- 3. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are required.
- 4. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED SCE does not consider that a condition of noncompliance existed. As discussed above, actions were taken to modify the conditions noted by March 26, 1986.
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