IR 05000361/2002011
| ML030230243 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/23/2003 |
| From: | Gody A Division of Reactor Safety IV |
| To: | Ray H Southern California Edison Co |
| References | |
| IR-02-011 | |
| Download: ML030230243 (15) | |
Text
January 23, 2003
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 - NRC INSPECTION REPORT 50-361/02-11; 50-362/02-11
Dear Mr. Ray:
On December 12, 2002, the NRC completed an inspection at your San Onofre Nuclear Generating Station, Units 2 and 3. The enclosed report documents the inspection findings, which were discussed on December 12, 2002, with Mr. D. E. Nunn and other members of your staff.
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel.
On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated, and resolved within the problem identification and resolution program.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Anthony Gody, Chief Operations Branch Division of Reactor Safety
Southern California Edison Co.
-2-Dockets: 50-361; 50-362 Licenses: NPF-10; NPF-15 cc:
Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, California 92101 Gary L. Nolff Power Projects/Contracts Manager Riverside Public Utilities 2911 Adams Street Riverside, California 92504 Eileen M. Teichert, Esq.
Supervising Deputy City Attorney City of Riverside 3900 Main Street Riverside, California 92522 Joseph J. Wambold, Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, California 92674-0128 David Spath, Chief Division of Drinking Water and Environmental Management California Department of Health Services P.O. Box 942732 Sacramento, California 94234-7320 Michael R. Olson San Onofre Liaison San Diego Gas & Electric Company P.O. Box 1831 San Diego, California 92112-4150 Ed Bailey, Radiation Control Program Director Radiologic Health Branch California Department of Health Services P.O. Box 942732 (MS 178)
Sacramento, California 94234-7320
Southern California Edison Co.
-3-Mayor City of San Clemente 100 Avenida Presidio San Clemente, California 92672 James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 34)
Sacramento, California 95814 Douglas K. Porter, Esq.
Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Dwight E. Nunn, Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, California 92674-0128 Dr. Raymond Waldo Southern California Edison Company San Onofre Nuclear Generating Station P. O. Box 128 San Clemente, California 92674-0128 A. Edward Scherer Southern California Edison San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, California 92674-0128
Southern California Edison Co.
-4-Electronic distribution by RIV:
Regional Administrator (EWM)
DRP Director (ATH)
DRS Director (DDC)
Senior Resident Inspector (CCO1)
Branch Chief, DRP/C (CEJ1)
Senior Project Engineer, DRP/C (WCW)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (NBH)
Scott Morris (SAM1)
SONGS Site Secretary (SFN1)
R:\\_SO23\\2002\\so211rp-pcg.wpd SOE:OB SOE:OB SOE:OB RI:PBC C:OB C:PBC C:OB PCGage/lmb GWJohnston GEWerner MASitek ATGody CEJohnson ATGody
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
01/08/03 01/08/03 01/08/03 01/08/03 01/22/03 01/22/03 01/22/03 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Dockets:
50-361; 50-362 Licenses:
50-361/02-11; 50-362/02-11 Licensee:
Southern California Edison Co.
Facility:
San Onofre Nuclear Generating Station, Units 2 and 3 Location:
5000 S. Pacific Coast Hwy.
San Clemente, California Dates:
December 2-12, 2002 Inspectors:
P. C. Gage, Senior Operations Engineer, Operations Branch G. W. Johnston, Senior Operations Engineer, Operations Branch G. E. Werner, Senior Operations Engineer, Operations Branch M. A. Sitek, Resident Inspector, Reactor Project Branch C Approved By:
Anthony T. Gody, Chief Operations Branch Division of Reactor Safety
-2-SUMMARY OF FINDINGS IR 05000361/02-11; 05000362/02-11 San Onofre Nuclear Generating Station, Units 2 and 3; annual baseline inspection of the identification and resolution of problems.
The inspection was conducted by three senior operations engineers and one resident inspector.
No findings of significance was identified.
A.
NRC-Identified Finding Identification and Resolution of Problems The licensee was effective at identifying problems and placing them into the corrective action program. The licensees effectiveness at problem identification was evidenced by the relatively few deficiencies identified by external organizations (including the NRC)
that had not been previously identified by the licensee, during the review period. The licensee effectively used risk in prioritizing the extent to which individual problems would be evaluated and in establishing schedules for implementing corrective actions.
However, one of the apparent cause evaluations reviewed was found to be deficient, in that, it lacked sufficient depth to determine the extent of condition of the finding.
Corrective actions, when specified, were generally implemented in a timely manner.
Licensee audits and assessments were found to be effective and highlighted a similar concern in the root cause area. On the basis of interviews conducted during this inspection, workers at the site felt free to input safety findings into the problem identification and resolution program.
B.
Licensee-Identified Finding A violation of very low safety significance, identified by the licensee, had been reviewed by the team. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and the corrective action tracking number is listed in Section 4OA7 of this report.
Report Details 4OA2 Identification and Resolution of Problems a.
Effectiveness of Problem Identification (1)
Inspection Scope The team reviewed items selected across the seven cornerstones of safety to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. Specifically, the teams review included a selection of 75 action requests that had been opened or closed or that related to issues of regulatory noncompliance since July 1, 2001. The team also reviewed a total of 6 licensee audit, assessment, and surveillance reports related to the problem identification and resolution program. The effectiveness of the audits and assessments was evaluated by comparing the audit and assessment results against self-revealing and NRC-identified findings.
The team evaluated the action requests to determine the licensees threshold for identifying problems and entering them into the corrective action program. Also, the team evaluated the licensees efforts in establishing the scope of problems by reviewing pertinent work orders, engineering modification packages, self-assessment results, and action plans. The action requests and other documents listed in Attachment 1 were used to facilitate the review.
The team also conducted plant walkdowns and interviewed plant personnel to identify other processes by which problems and issues could be identified.
(2)
Issues The team determined that the licensee was effective at identifying problems and entering them into the corrective action program. This was evidenced by the relatively few deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee during the review period. Licensee audits and self assessments were of sufficient breadth and depth and identified issues similar to those that were self-revealing or raised during NRC inspections. The team identified no instances where conditions adverse to quality were being handled outside the corrective action program.
The quarterly self assessment for six different divisions of the site organization were reviewed by the team to determine the extent of the licensees internal self-assessment program. These self assessments were reviewed with regard to depth of programmatic assessment, thoroughness of measurement of corrective action implementation, and generation of corrective actions. In general the self assessments met expectations of facility management and exhibited an improvement over the previous inspection period.
The team identified no significant findings related to effectiveness of problem identification.
-2-b.
Prioritization and Evaluation of Issues (1)
Inspection Scope The team reviewed 75 action requests and supporting documentation, including analyses of the problem causes, to ascertain whether the licensees evaluation of the problems identified considered the full extent of conditions, generic implications, common causes, and previous occurrences. In addition, the team reviewed the licensees evaluation of selected industry experience information, including operating event reports and NRC and vendor generic notices, to assess if issues applicable to the San Onofre Nuclear Generating Station were appropriately addressed. In addition, the team also reviewed selected action requests to ascertain satisfaction of the provisions of 10 CFR Part 50, Appendix B, regarding timeliness of corrective action for those action requests applying to degraded or nonconforming structures, systems, and components.
The team also interviewed engineering and technical personnel concerning the actions taken on action requests. Specific items reviewed are listed in the attachment to this report.
(2)
Issues The inspectors reviewed the licensees root cause evaluations related to Level 1 action requests, and several others of lower significance, to determine that the analyses were conducted with regard to accepted industry practices and in accordance with facility procedures. The inspectors noted that the root cause evaluations were thorough in exploring the root causes of identified significant conditions adverse to quality. In general, the corresponding corrective actions were appropriate to address the identified root cause.
The inspectors noted in several instances where a concerted effort by the licensee was utilized in the determination of root causes for conditions adverse to quality. This root cause effort involved an extensive review of related industry experience to capture all pertinent issues with the associated facility identified conditions. These reviews included several types of root cause analysis methods and were not subjective.
The team found that the licensee effectively prioritized and evaluated issues with some exceptions. The team noted that the licensee typically investigated issues with sufficient depth and breadth to determine both the scope and extent of condition and in accordance with the issues safety significance.
The licensee had procedures in place to prioritize issues, but on numerous occasions, the inspectors identified that licensee personnel routinely changed due dates (over 20 action requests had due dates changed) with little or no documented justification.
Procedure SO123-XV-50, Corrective Action Process, Revision 4, allows the problem owners to change due dates, even for the most significant action requests that involve root cause evaluations. No examples of improperly delayed corrective actions for safety related equipment were identified.
-3-As part of their own self-analysis, the licensee recently identified that apparent cause evaluation quality lacked consistency. These concerns were identified in Action Requests 020100546, 020201269, 020301266, and 020301188. Starting November 2002, the licensee formed an Executive Corrective Action Review Board (Action Request 020201269, Assignment 8), which consisted of senior management, to review all apparent and root cause evaluations. This board was formed in an attempt to improve ownership and accountability of apparent cause evaluation quality. The team noted that the quality of the apparent cause evaluations were considerably more variable and less consistent than the root cause evaluations, even though similar methodology was provided in a common procedure to perform either evaluation type.
The major differences included that the apparent cause evaluations were typically performed by an individual, instead of a group, and that the assigned individuals training or experience would therefore vary accordingly.
The team identified one example were the licensee failed to effectively evaluate the extent of an identified condition adverse to quality. In January 2000, Diesel Generator 2G003 failed to synchronize to the bus on three different attempts. The licensee identified that a blown fuse in the non-safety-related synchronization matcher isolation circuitry caused these failures (Action Request 000100755). During troubleshooting attempts, the licensee identified that the installed fuse was different than specified in the Nuclear Consolidated Data Base; therefore, the licensee conducted failure analysis on this fuse. The failure was caused by internal corrosion, which corroded the fuse filament in two.
Based on the corrosion and recommendations of the apparent cause evaluation, the licensee decided to remove the six remaining fuses (Action Request 000100755-05, Assignment 7) from the other three diesel generators and perform failure analysis on those fuses. This analysis was assigned the lowest priority and was due for completion by December 11, 2001. However, the fuses were not given to the failure analysis group until March 21, 2002 and at the start of this inspection, the analysis was not documented in the action request. The analysis was completed on August 7, 2002, but was not documented until December 6, 2002, after discussions with the NRC inspectors. The six fuses were tested and destructively examined and only light surface corrosion, characterized as normal, was identified on the fuse filaments.
As part of the review of the apparent cause evaluation, the team reviewed the generic issue evaluation. The team determined that the generic review failed to determine where else the fuses were used in plant equipment, especially in safety-related circuits.
When asked by the team where else this fuse type was installed at the facility, the licensee identified that this type of fuse could be used in approximately 200 safety-related applications. Since the licensee had not performed such a determination prior to the teams inquiry, the extent of the safety-related applications had not been documented within the effected action request. The team determined that the failure to do an adequate generic review caused the low priority to be assigned in Assignment 7 of the action request. The team considered this issue as an example of inadequate documentation of a condition adverse to quality, and demonstrated untimely evaluation and resolution of issues. Since the fuse failure did not affect a safety-related application and since it was not a significant condition adverse to quality, and to date no additional
-4-or repetitive failures had resulted, no violation of regulatory requirements occurred. The team noted that if affected components fail, consideration of the missed opportunity to capture problem could lead to potential regulatory issues for corrective actions.
Based on a review of the licensees records, the team concluded that overall the licensee effectively prioritized and evaluated issues with some exceptions noted. For the more risk significant action requests, the team determined that the evaluations were of sufficient depth, the root cause determinations were accurate, and risk aspects of the conditions had been appropriately considered. For the minor risk significant action requests, the licensees implementation of a senior management review board is expected to improve apparent cause evaluation quality.
No findings of significance were identified.
c.
Effectiveness of Corrective Actions (1)
Inspection Scope The team reviewed the action requests, audits, assessments, and trending reports described in Section 4OA2.a.(1) above to verify that corrective actions, related to the issues, were identified and implemented in a timely manner commensurate with safety, including corrective actions to address common cause or generic concerns. The team also conducted plant walkdowns and interviewed plant personnel to independently verify and assess the effectiveness of corrective actions implemented by the licensee. A listing of specific documents reviewed during the inspection is included in the attachment to this report.
(2)
Issues Based on a review of the licensees documents and interviews with licensee personnel, the team concluded that the licensee effectively implemented corrective actions commensurate with safety.
No findings of significance were identified.
d.
Assessment of Safety-Conscious Work Environment (1)
Inspection Scope The team interviewed several members of the licensee's staff, which represented a cross-section of functional organizations and supervisory and non-supervisory personnel, regarding their willingness to identify safety issues. These interviews assessed whether conditions existed that would challenge the establishment of a safety-conscious work environment.
-5-(2)
Issues The team concluded, based on information collected from these interviews, that employees were willing to identify issues and accepted the responsibility to pro-actively identify and enter safety issues into the corrective action program. This employee willingness to identify issues was reflected by the fact that over 20,000 action requests had been generated in the 15-month period covered by the inspection.
No findings of significance were identified.
4OA6 Exit Meeting The team discussed these findings with Mr. D.E. Nunn, Vice President of Engineering and Technical Services, and other members of the licensees staff on December 12, 2002. Licensee management provided no further comment on the findings.
Licensee management did not identify any materials examined during the inspection as proprietary.
4OA7 Licensee Identified Violation The following violation of very low safety significance (green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an noncited violation.
The regulations in 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, require, in part, that licensees establish measures to ensure that conditions adverse to quality, such as, failures, malfunctions, and deficiencies are promptly identified and corrected. On January 15, 2002, the licensee identified a deficient quarterly surveillance test method used on check valves in the service water system. The service water system provides seal water to the Unit 2 and 3 saltwater cooling pumps. This deficiency was entered in the licensees corrective action program as Action Request 020100712.
However, the licensee failed to verify the adequacy of the surveillance test method and did not take effective corrective actions to prevent reuse of the inadequate surveillance test until October 3, 2002. The failure to promptly correct the deficiency is considered of very low significance, and is being treated as a noncited violation because the deficient surveillance did not affect saltwater cooling pump operability. The licensee was performing a root cause evaluation for the corrective action deficiency, which was tracked in Assignment 13 of Action Request 020100712.
ATTACHMENT 1 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee D. Axline, Licensing Engineer C. Anderson, Manager, Emergency Preparedness D. Brieg, Manager, Maintenance Engineering G. Broussard, Supervisor, Security M. Carr, Manager, Probability Risk Assessment G. Cook, Supervisor, Compliance M. Cooper, Manager, Plant Operations W. Frick, Manager, Nuclear Safety Concerns M. Lewis, Technical Specialist, Health Physics C. McAndrews, Manager, Nuclear Oversight A. Newcomber, Quality Assurance Auditor, Nuclear Oversight and Assessment D. Nunn, Vice President, Engineering and Technical Services J. Osborne, Engineer R. Richter, Fire Protection Supervisor, Maintenance Engineering A. Scherer, Manager, Nuclear Oversight and Regulatory Affairs P. Shaffer, Supervisor, Plant Maintenance J. Thomas, Engineer, Nuclear Oversight and Assessment M. Tolson, Fire Protection Engineer, Maintenance Engineering C. Williams, Supervisor, Nuclear Regulatory Affairs NRC A. Gody, Chief, Operations Branch C. Osterholtz, Senior Resident Inspector DOCUMENTS REVIEWED The following documents were selected and reviewed by the team to accomplish the objectives and scope of the inspection and to support any findings:
Procedures:
SO123-CA-1, Corrective Action Program, Revision 3 SO123-I-1.3, Work Activity Guidelines, Revision 10 SO123-VII-8.16.3, Radiological Control of Radioactive Tooling and Equipment, Revision 3 SO123-VII-20.9.2, Material Release Surveys, Revision 4 SO23-XV-34, ASME Section XI Repair and Replacement Program, Revision 6 SO123-XV-50, Corrective Action Process, Revision 4 SO123-XV-50.39, Cause Evaluations Standards, Methods, and Instructions, Revision 3 SO123-XV-52, Operability Assessments and Reportability Evaluations, Revision 3 SO123-XX-1, Action Request/Maintenance Order Initiation and Processing, Revision 14 SO123-XXIV-37.30.41, Specifications/Mini-Specifications, Revision 2 SO23-3-3.60.4, Saltwater Cooling Pump and Valve Testing, Revision 4
-2-Action Requests:
990601321 000100755 000300456 000401086 000401144 000401454 000800974 001001889 001001889 001101632 001200130 001200130 010100770 010101660 010101660 010300419 010300938 010400541 010500112 010501240 010501285 010700225 010700685 010700755 010800044 010800405 010800910 010801261 010801261 010801436 010801558 010900154 010900606 010901163 011000571 011001062 011001703 011200247 011200956 011200965 018010525 020100138 020100140 020100514 020100534 020100546 020100712 020100757 020101560 020200469 020201269 020201440 020300034 020300169 020301188 020301266 020301315 020500176 020500880 020501002 020601156 020601312 020602197 020701529 020701633 020800629 020801647 020900889 020901304 021000346 021000723 021000730 021100079 021100192 021100605 Maintenance Orders:
01050191000 01100460000 01102593000 02020333000 02050119001 02110202000 02110203000 02110205000 Self Assessments:
Plant Status Control Directed Assessment January 2001, and 4th Quarter 2001 Health Physics Division Self Assessment Report 3rd Quarter 2002 Site Emergency Preparedness Division Report fourth Quarter 2001 Security Division Self Assessment Report 2nd Quarter 2002 Nuclear Training Division Self Assessment Report 3rd Quarter 2002 Engineering Division Self Assessment Report 2nd Quarter 2002 Licensee Event Reports 050-362/2001-002-00 050-361, 362/2001-003-00 050-361, 362/2002-001-00 050-362/2002-001-00 Miscellaneous:
NORAD Guidelines Corrective Action Followup (CAF), Revision 6 Design Basis Documentation, DBD-S023-410, Figure D-1, Saltwater Cooling System Unit 2" Design Basis Documentation, DBD-S023-410, Figure D-2, Saltwater Cooling System Unit 3"