United States Nuclear Regulatory Commission - Protecting People and the Environment

EA-98-563 - San Onofre 2 & 3 (Southern California Edison Co.)

March 16, 1999

EA 98-563

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: NOTICE OF VIOLATION
(NRC Special Inspection Report No. 50-361/98-18; 50-362/98-18)

Dear Mr. Ray:

This refers to the special inspection completed on December 18, 1998, at the San Onofre Nuclear Generating Station. The purpose of the inspection was to determine the circumstances surrounding the inoperability of the Train B emergency chilled water system during two, extended periods in August and September 1998. Southern California Edison Co. (SCE) identified one occurrence on September 25, 1998, and the other on October 21, 1998. The results of the inspection were issued in a report dated January 15, 1999. In the letter transmitting the report, the NRC informed SCE that escalated enforcement action was being considered for an apparent violation of plant Technical Specifications. SCE responded to the apparent violation in two letters dated February 11 and February 16, 1999.

Based on the information developed during the inspection and after consideration of the information that SCE provided in its responses, the NRC has determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The issue involves SCE's identification that the Train B emergency chilled water system had been inoperable in excess of the action times required by the technical specification on two separate occasions. The train was inoperable for 22 days due to maintenance, an incorrectly set electrical demand switch, and noncondensable gases in the refrigerant on the first occasion. The train was inoperable for 26 days due to maintenance and a miswired low chilled water temperature cutout switch on the second occasion.

Despite SCE's probabilistic risk assessment that the issue represented a "small" increase in core damage risk, the issue is significant because on both occasions, one train of a safety-related system was rendered inoperable for a period of time far in excess of the Technical Specification action time while both units were operating in Mode 1. The emergency chilled water system provides cooling water to the heating, ventilation, and air conditioning systems, which in turn removes heat from the safety-related equipment rooms and provides cooling for habitability concerns, during emergency conditions. Therefore, this violation has been categorized in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600 at Severity Level III.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level III violation. Because SONGS has been the subject of escalated enforcement action within the last 2 years, (1) the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. The NRC concluded that identification credit was warranted. SCE identified the first inoperable period while reviewing plant records, and identified the second inoperable period when the chiller failed to start during a surveillance test. The NRC also concluded that credit was warranted for corrective actions. As discussed in the subject inspection report, your corrective actions included revising your maintenance procedures concerning the electrical demand setting, adding a postmaintenance test requirement following dynamic calibration, and changing how you handle lifted leads to electrical components.

Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in Inspection Report Nos. 50-361/98-18; 50-362/98-18, in Licensee Event Reports 98-020 and 98-021, and in your correspondence dated February 11 and 16, 1999. Therefore, SCE is not required to respond to this letter 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 specified in the enclosed Notice.

SCE provided several "corrections/clarifications" to NRC's inspection report in its February 16 letter, but noted that there were no material issues in dispute. The NRC will address SCE's comments in separate correspondence.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room.


Sincerely,

Org signed by

Ellis W. Merschoff
Regional Administrator



Docket Nos.: 50-361
                      50-362
License Nos.: NPF-10
                       NPF-15

Enclosure: Notice of Violation

cc w/Enclosure:

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, California 92522

R. W. Krieger, Vice President
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, California 92674-0128

Stephen A. Woods, Senior Health Physicist
Division of Drinking Water and
Environmental Management
Nuclear Emergency Response Program
California Department of Health Services
P.O. Box 942732, M/S 396
Sacramento, California 94334-7320

Mr. Michael R. Olson
Sr. Energy Administrator
San Diego Gas & Electric Company
P. O. Box 1831
San Diego, California 92112-4150

Mr. Steve Hsu
Radiological Health Branch
State Department of Health Services
P.O. Box 942732
Sacramento, California 94234

Mayor
City of San Clemente
100 Avenida Presidio
San Clemente, California 92672

Mr. Truman Burns\Mr. Robert Kinosian
California Public Utilities Commission
505 Van Ness, Rm. 4102
San Francisco, California 94102


ENCLOSURE

NOTICE OF VIOLATION

Southern California Edison Co.
San Onofre Nuclear Generating Station

Docket Nos.: 50-361 and 50-362
License Nos.: NPF-10; NPF-15
EA 98-563


During an NRC inspection conducted on November 9 through December 18, 1998, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

San Onofre, Units 2 and 3, Technical Specification 3.7.10 requires that while either unit is in Modes 1, 2, 3, or 4, two emergency chilled water trains shall be operable. The action statement requires that, with one emergency chilled water train inoperable, the train be restored to operable status within 7 days or that the units be in Mode 3 in 6 hours and in Mode 5 in 36 hours.

Contrary to the above, the Train B emergency chilled water system was inoperable on two separate periods (August 6 through 26, 1998, and September 4 through September 25, 1998), while Units 2 and 3 were in Mode 1, and action was not taken to either restore the train to operable status within 7 days or place the units in Mode 5 within the following 36 hours. The train was inoperable during the first period due to maintenance, an incorrectly set electrical demand switch, and noncondensable gases in the refrigerant; during the second period due to maintenance, and a miswired low chilled water temperature cutout switch. (01013)

This is a Severity Level III violation (Supplement I).

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance was achieved is already adequately addressed on the docket in Inspection Report Nos. 50-361/98-18; 50-362/98-18, in Licensee Event Reports 98-020 and 98-021, and in your correspondence dated February 11 and 16, 1999. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN:  Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

If you choose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated this 16th day of March 1999


1. A Severity Level III violation was issued on February 18, 1998, (EA 97-585).

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