05000361/FIN-2008015-01
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | This refers to the investigation completed on July 8, 2008, by the NRC Office of Investigations at San Onofre Nuclear Generating Station to determine whether two instrumentation and control technicians employed by San Onofre Nuclear Generating Station willfully failed to follow blowdown bypass procedures. This letter represents the subject inspection report documenting the results of that investigation. Based on the results of the investigation, the NRC determined that a willful violation of requirements occurred. The violation is categorized as a Severity Level IV violation. Specifically, on August 2, 2005, two Instrumentation and Controls technicians failed to follow procedure SO23-11-9.712, Revision 5, Surveillance Requirement Steam Generator E088 and E089 Blowdown Bypass Channel Functional Test, which required in step 6.2.2 On FY4077, disconnect input lead 9 from the (+) terminal and input lead 10 from the (-) terminal. Contrary to procedure requirements, when the Instrumentation and Controls technicians could not locate the terminals identified in the procedure they decided to disconnect the leads upstream in the circuit at TB101 (terminals 7 and 8), which they believed were equivalent points and would accomplish the same intent. However, they were incorrect and their actions resulted in an unexpected alarm when the electrical circuit was broken. The Confirmatory Order, dated January 11, 2008, that resulted from an alternative dispute resolution (ADR) mediation session involving willful violations, states in part, that for a period of 6 months following issuance of the Order, the NRC will grant enforcement discretion if the NRC concludes that the provisions of Section VII.B.4 of the Enforcement Policy have been met. NRC review of the violation concluded that the five criteria in Section VII.B.4 of the Enforcement Policy for exercising discretion are met, in that the violation: (a) was licensee-identified; (b) had the same or similar root cause as the original violations; (c) did not substantially change the safety significance or the character of the regulatory concern arising out of the previously identified willful violations; (d) was immediately corrected; and (e) would not be categorized as a Severity level I violation. The licensee has taken substantial corrective actions to address the specific aspects of the violations as documented in the Confirmatory Order, including: (1) performing a common cause evaluation involving the willful events to determine the root and contributing causes for the collective issues, (2) entering corrective actions for the root and contributing causes into the corrective action program, (3) conducting an independent safety culture assessment and incorporating the results into the corrective action program, (4) conducting ethics and integrity training for managers, supervisors and other employees, and (5) performing periodic sampling of repetitive rounds and log-keeping to deter and detect instances of noncompliance. The NRC plans to assess the adequacy of these corrective actions during upcoming inspections. Based upon our review of these facts, the NRC is granting enforcement discretion, and will take no enforcement action for this violation. |
| Site: | San Onofre  |
|---|---|
| Report | IR 05000361/2008015 Section 4OA7 |
| Date counted | Sep 30, 2008 (2008Q3) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | D Allen K Fuller M Haire M Hay |
| INPO aspect | |
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Finding - San Onofre - IR 05000361/2008015 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (San Onofre) @ 2008Q3
Self-Identified List (San Onofre)
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