IR 05000361/2006010
| ML070460445 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/15/2007 |
| From: | Chamberlain D D Division of Reactor Safety IV |
| To: | Rosenblum R M Southern California Edison Co |
| References | |
| IR-06-010 | |
| Download: ML070460445 (10) | |
Text
February 15, 2007
Richard M. RosenblumSenior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128
SUBJECT: SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 - NRCINSPECTION REPORT 05000361/2006010; 05000362/2006010
Dear Mr. Rosenblum:
On August 18, 2006, the US Nuclear Regulatory Commission (NRC) completed an inspectionat your San Onofre Nuclear Generating Station, Units 2 and 3. The enclosed inspection report documents the inspection results, which were discussed on February 15, 2007, with Mr. Rauch and other members of your staff. This inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license associated with your plant-referenced simulator. Specifically, this inspection focused on addressing an unresolved item (URI 05000361;362/2005302-02) related to the use of the plant simulator for the administration of both the operating test and experience requirements. The inspectors reviewed selected procedures and records and observed simulator testing. Despite some analysis and documentation issues associated with Cycle 13 simulator testing,the inspectors agreed with your determination that the San Onofre Nuclear Generating Station simulator models for Cycle 13 had adequate fidelity for use in the administration of both the operating test and experience requirements (control manipulation credits) and met the requirements contained in 10 CFR 55.46(c)(3).
Southern California Edison Company-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/Dwight D. Chamberlain, DirectorDivision of Reactor SafetyDockets: 50-361; 50-362Licenses: NPF-10; NPF-15
Enclosure:
Inspection Report 05000361/2006010; 05000362/2006010 w/Attachment - Supplemental Informationcc w/enclosure:Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101Gary L. NolffAssistant Director-Resources City of Riverside 3900 Main Street Riverside, CA 92522Mark L. ParsonsDeputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522Ray W. WaldoSouthern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Southern California Edison Company-3-David Spath, ChiefDivision of Drinking Water and Environmental Management California Department of Health Services P.O. Box 942732 Sacramento, CA 94234-7320Michael R. OlsonSan Onofre Liaison San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548Director, Radiological Health BranchState Department of Health Services P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672James D. Boyd, CommissionerCalifornia Energy Commission 1516 Ninth Street (MS 34)
Sacramento, CA 95814Douglas K. Porter, Esq.Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770James T. ReillySouthern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128Daniel P. BreigSouthern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Southern California Edison Company-4-A. Edward SchererSouthern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128Brian KatzSouthern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Southern California Edison Company-5-Electronic distribution by RIV:Regional Administrator (BSM1)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (CCO1)Branch Chief, DRP/D (TWP)Senior Project Engineer, DRP/D (GEW)Team Leader, DRP/TSS (RLN1)RITS Coordinator (KEG)DRS STA (DAP)V. Dricks, PAO (VLD)D. Cullison, OEDO RIV Coordinator (DGC)ROPreportsSite Secretary (vacant)SUNSI Review Completed: Y______ADAMS: Yes G No Initials: _ATG__ Publicly Available G Non-Publicly Available G Sensitive Non-SensitiveOE:OBOE:OB/RIOE:IOLB/NRRC:PBDC:OBD:DRSKDClayton/lmbPPresbyLVickTPruettAGodyDDChamberlain/RA//RA/Non-concur*/RA//RA//RA/8/18/068/19/0610/19/20069/1/062/15/072/15/07OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax* ML0629204872* ML070460459 Enclosure-1-ENCLOSUREU.S. NUCLEAR REGULATORY COMMISSION REGION IV Dockets:50-361; 50-362Licenses:NPF-10; NPF-10 Report No.:05000361/2006010; 05000362/2006010 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:Onsite inspection was March 13 - 17, 2006In office inspection was March 6 through August 18, 2006 Inspectors:K. D. Clayton, Operations Engineer, Operations Branch, Region IVP. Presby, Operations Engineer, Operations Branch, Region IAdditional ReviewBy:L. Vick, Operations Engineer, Initial Operator Licensing BranchOffice of Nuclear Reactor RegulationApproved By:Anthony T. Gody, ChiefOperations Branch Division of Reactor Safety Enclosure-2-
SUMMARY OF FINDINGS
IR 05000361/2006010; 05000362/2006010; March 13 - August 18, 2006; San Onofre NuclearGenerating Station, Units 2 and 3: Biennial Licensed Operator Requalification (Simulator
Specific) Inspection (IP 71111.11B).The report covered an 23-week period of onsite and offsite inspection by two operationsengineers. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.
NRC-Identified and Self Revealing Findings
No findings of significance were identified.
Enclosure-3-
REPORT DETAILS
1REACTOR SAFETY 40A5OTHER1.(Closed) Unresolved Item (URI) 05000361;362/2005302-02, Adequacy of Plant-Referenced Simulator to Conform with Simulator Requirements for Reactivity and Control Manipulation Credits.
a. Inspection Scope
PurposeThis inspection addressed an unresolved item documented in NRC ExaminationReport 05000361;362/2005302 dated January 25, 2006. Specifically, the inspectors assessed the adequacy of the San Onofre Nuclear Generating Station simulator facility for use in reactivity/control manipulation credits on an initial operator license application NRC Form 398, "Personal Qualification Statement-Licensee," as prescribed in 10 CFR 55.46, "Simulation facilities." The inspection was conducted through a review of the licensee's implementation of a preselected number of simulator scenarios and other performance-based tests on the simulator and an in-office review of a sample of the documentation for control manipulations, unit performance testing, and transient testing.BackgroundWhile conducting onsite preparations for an initial licensing examination the week ofOctober 3, 2005, the inspectors reviewed data provided on NRC Form 398, "Personal Qualification Statement - Licensee," for selected operator license candidates as required by NUREG-1021, "Operator License Examination Standards for Power Reactors," Revision 9. During the review, the inspectors noted that five operator license candidates used the simulator extensively for meeting the significant control manipulation requirements in 10 CFR 55.31(a)(5). Of the 25 reactivity credits required for these five operators, 22 credits were taken on the simulator instead of the actual plant. Use of the simulator for control manipulations is permitted, provided the licensee's simulator meets the requirements of 10 CFR 55.46(c)(3). Accordingly, the inspectors expanded the pre-examination review to verify that the simulator met the requirements of 10 CFR 55.46(c)(3). This review focused on the licensee's implementation of simulator testing in accordance with ANSI/ANS-3.5-1998, "Nuclear Power Plant Simulators for Use in Operator Training and Examination." Specifically, the inspectors reviewed 100 percent of the 2005 simulator testing records, which included all transient and unit performance tests. The review identified one green finding associated with the adequacy of simulator transient test documentation, which was documented in NRC Examination Report 05000361;362/2005302. In addition to the green finding, the inspectors identified an unresolved item (URI 05000361;362/2005302-02) associated with adequacy of documentation of the scenarios associated with the control manipulations. Specifically, the inspectors identified that the licensee hadretained a single-page sign-off sheet and a copy of the actual procedure used by the operator candidates as the documentation required by 10 CFR 55.46(d)(1) for their
-4-scenario-based tests. Some of these scenario-based tests were used to validate theactual control manipulation scenarios used by the aforementioned operator candidates.
This method of documenting scenario-based tests had been observed at other facilities in the past and was the subject of considerable industry effort to improve documentation of scenario-based tests at the time of the inspectors review. To verify that the simulator had no significant fidelity issues under conditions similar to the aforementioned control manipulations, the inspectors reviewed additional documentation which allowed a limited assessment of simulator fidelity under conditions similar to those used for the control manipulations. Specifically, the limited assessment conducted by the inspectors included a comparison of simulator performance to the reference plant data collected during startups. Despite the identified documentation issues, the inspectors found that the simulator demonstrated adequate fidelity. Because no actual simulator fidelity issues were identified during the initial review that affected the planned examination, the initial license examination was conducted using the plant-referenced simulator. During the examination, the applicants who demonstrated that they could safely operate the facility and passed the examination, were issued licenses. Followup InspectionIn order to address the unresolved item associated with documentation issues, theinspectors conducted an onsite inspection in March 2006. While onsite, the inspectorsre-reviewed the raw data from the simulator and the reference plant for Cycle 13 and conducted an independent analysis. While conducting this review, the inspectors discussed the need for the licensee's training staff to modify their data collection methods to avoid the corruption they experienced in their original graphs, which was responsible for creating confusion in understanding the validity of their testing. In addition, the inspectors reviewed the fidelity of the simulator during low power physics testing for both Cycles 13 and 14.The inspectors observed the licensee operate the simulator during selected controlmanipulations. The randomly selected scenarios were:*Scenario 1: 3 to 18 percent power increase*Scenario 2: 80 to 92 percent power increaseThe inspectors controlled Scenario 1 by using actual plant data provided by the licenseein order to match the time for the control rod pulls and boron dilutions. However, the plant data used in the test was not correct and the test had to be rerun the following week. Scenario 2 also could not be performed during the inspection week, because the simulator had just undergone a major modeling upgrade and the corresponding initial condition set for the simulator had not been created prior to the onsite portion of the inspection. These tests were ran the following week by the licensee and the results were submitted to the inspectors with the licensee's analyses and conclusions. The inspectors performed independent analyses to verify the results and confirm the
licensee's conclusions.
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b. Findings
Following the re-review of Cycle 13 data, the inspectors found that the simulator demonstrated adequate fidelity when compared to the reference plant for Cycle 13. The review of low power physics testing identified some differences between the simulator and the reference plant, however, the inspectors found that the identified differences between the simulator and the reference plant were transparent to the operators, would not affect training or testing, and were minor. The inspectors agreed with the licensee's conclusions that no significant fidelity issues existed in the data sets sampled for Cycle 14.Overall, the inspectors found that the San Onofre Nuclear Generating Station simulatormodel fidelity was acceptable for use in the administration of both the operating test and experience requirements in 10 CFR 55.31(a)(5) as described in 10 CFR 55.46(c)(3).
The inspectors agreed with the licensee's determination that simulator fidelity was adequate, and that significant control manipulations could be completed without procedural exceptions, simulator performance exceptions, or deviations from the approved training scenario. In addition, the inspectors agreed with the licensee's conclusion that the San Onofre Nuclear Generating Station plant-referenced simulator utilized thermal-hydraulic models that adequately replicated the most recent core load.No findings of significance were identified and the unresolved item was closed.4OA6Meetings, Including ExitOn March 17, 2006, the inspectors briefed Mr. K. Rauch and other members of his staffon the results of the onsite portion of the licensed operator requalification simulator inspection. A final telephonic exit was held with Mr. K. Rauch on February 15, 2007.
The licensee acknowledged the conclusions presented in both the briefing and the final exit. The inspectors confirmed that proprietary information was not provided or examinedduring this inspection.ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- K. Rauch, Operations Training Manager
- A. Hagemeyer, Operations Training Supervisor
- J. Holt, Nuclear Regulatory AffairsLIST OF ITEM CLOSED AND DISCUSSED
Closed5000361;362/2005302-02URIAdequacy of Plant-Referenced Simulator toConform with Simulator Requirements for
Reactivity and Control Manipulation Credits
LIST OF DOCUMENTS REVIEWED
ProceduresSIMTAG-400, "SONGS Simulator Core Physics Testing"
- NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9
- Plant Physics Data Book, Cycles 13 and 14
- Reactivity manipulation packages for all 21 manipulation credits Five applicants' Initial Operator License Application Forms (NRC Form 398)
- Simulator and Plant packages for 3 to 18 percent power increase (Cycle 13), two runs Simulator and Plant packages for 80 to 92 percent power increase (Cycle 13)
- ANSI/ANS 3.5-1998, "Nuclear Power Simulators for Use in Operator Training"ANSI/ANS 19.6.1-1997, "Reload Startup Physics Tests for Pressurized Water Reactors"
- SO23-XXXVII-1, "Low Power Physics Testing," Revision 3, used for Cycles 13 and 14All Transient Test packages for 2005 and 2006 annual performance tests All Steady State Test packages for 2005 and 2006 annual performance tests