Text

IR 05000361-10-004 & 05000362-10-004, on 06/24/10 - 09/23/10, San Onofre Nuclear Generating Station
	ML103070317
Person / Time
Site:	San Onofre
Issue date:	11/03/2010
From:	Ryan Lantz; NRC/RGN-IV/DRP/RPB-D
To:	Sheppard J; Southern California Edison Co
References
	FOIA/PA-2011-0157 IR-10-004
	Download: ML103070317 (47)
	v • d • e

UNITED STATES NU C LE AR RE G ULATO RY C O M M I S S I O N ber 3, 2010

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000361/2010004 and 05000362/2010004

Dear Mr. Sheppard:

On September 23, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your San Onofre Nuclear Generating Station, Units 2 and 3 facility. The enclosed integrated inspection report documents the inspection findings, which were discussed on September 24, 2010, with you, and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents two NRC-identified findings and one self-revealing finding of very low safety significance (Green). All three of these findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as noncited violations, consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the violations or the significance of the noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E.

Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the San Onofre Nuclear Generating Station facility. In addition, if you disagree with the crosscutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at San Onofre Nuclear Generating Station.

In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs 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).

Southern California Edison Company -2-

Sincerely,

/RA/

Ryan E. Lantz, Chief Project Branch D Division of Reactor Projects Docket Nos. 50-361, 50-362 License Nos. NPF-10, NPF-15

Enclosure:

NRC Inspection Report 05000361/2010004 and 05000362/2010004 w/Attachment: Supplemental Information

Southern California Edison Company -3-

REGION IV==

Docket: 50-361, 50-362 License: NPF-10, NPF-15 Report: 05000361/2010004 and 05000362/2010004 Licensee: Southern California Edison Co. (SCE)

Facility: San Onofre Nuclear Generating Station, Units 2 and 3 Location: 5000 S. Pacific Coast Hwy San Clemente, California Dates: June 24, 2010 through September 23, 2010 Inspectors: C. Alldredge, Reactor Inspector P. Elkmann, Senior Emergency Preparedness Inspector G. Guerra, CHP, Emergency Preparedness Inspector J. Josey, Resident Inspector C. Osterholtz, Senior Operations Engineer R. Pelton, Training and Assessment Specialist J. Reynoso, Resident Inspector E. Ruesch, Resident Inspector D. Stearns, Health Physicist G. Tutak, Resident Inspector G. Warnick, Senior Resident Inspector Approved By: Ryan E. Lantz Project Branch D Division of Reactor Projects-1- Enclosure

SUMMARY OF FINDINGS

IR 05000361/2010004, 05000362/2010004; 06/24/2010 - 09/23/2010; San Onofre Nuclear

Generating Station, Units 2 and 3; Integrated Resident and Regional Report; Maint. Risk Assess. & Emerg. Work Contr., Op Eval., Ident. & Resolution of Problems.

The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. Three Green noncited violations of significance were identified. The significance of most findings is indicated by their color (Green,

White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process. The crosscutting aspect is determined using Inspection Manual Chapter 0310,

Components Within the Cross Cutting Areas. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a noncited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure of maintenance personnel to follow the requirements of station procedures while performing work on containment sump pump discharge isolation valve 2HV5803.

Specifically, on January 21, 2010, while performing scheduled maintenance activities on the valve maintenance personnel identified the need to perform a modification to the electrical wiring of the valve. When the modification was implemented on January 25, 2010, maintenance personnel failed to follow the requirements of procedures SO123-II-15.3, Temporary System Alteration and Restoration Form, Revision 17, and SO123-XXIV-10.1, Preparation, Review,

Approval, Issuance, Implementation, and Closure of Engineering Change Packages (NECPs) and Engineering Change Notices (ECNs), Revision 21, and did not have an implementing work order to affect a design change on valve 2HV5803. Planned corrective action is still being evaluated by the licensee. This issue was entered into the licensees corrective action program as Nuclear Notifications NNs 201061230, 200767264 and 200964035.

The performance deficiency was determined to be more than minor and is therefore a finding because if left uncorrected, the continued practice of circumventing site procedural requirements by craft personnel during maintenance or design modification work on safety-related equipment would have the potential to leave more risk significant equipment in a degraded or inoperable condition without documentation and without the knowledge and approval of site management and operations personnel. The finding was associated with the design control attribute of the Mitigating Systems Cornerstone. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4)

did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding was determined to have a crosscutting aspect in the area of human performance, associated with work practices component, in that the licensee failed to define and effectively communicate expectations regarding procedural compliance, and that personnel follow procedures H.4(b) (Section 1R13).

Green.

A self-revealing noncited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, was identified for the licensees failure to promptly identify and correct a condition adverse to quality associated with safety-related emergency ventilation fans. Specifically, the licensee did not adequately identify a degrading material condition on the emergency ventilation fan nose cones that resulted in failure of the emergency diesel generator train B vaneaxial fan on July 12, 2010. The licensees apparent cause evaluation developed corrective actions to periodically replace safety-related emergency ventilation fans at a 12 year interval. This issue was entered into the licensees corrective action program as Nuclear Notifications NNs 201009885 and 201088409.

The performance deficiency is more than minor and is therefore a finding because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding was determined to have very low safety significance because the finding:

(1) is not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather imitating event. Since the inadequate corrective actions were developed in 2003 and the licensees corrective action program has improved with respect to extent of condition reviews, the inspectors determined that this finding was not reflective of current performance, and therefore, did not have a crosscutting aspect associated with it (Section 1R15).

Green.

The inspectors identified a noncited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, for failure of electrical maintenance management personnel to adequately ensure that training was provided to electrical maintenance workers on techniques to prevent loose electrical connections. This training was a required action as described in root cause evaluation RCE 050601315 written in response to a June 2005 failure of an emergency diesel generator surveillance test due to a loose electrical connection in an emergency supply fan for the Unit 3 train B emergency diesel generator. The licensee entered this finding into their corrective action program as Nuclear Notifications NNs 200986184 and 200992291.

The failure of electrical maintenance management personnel to adequately implement corrective actions as prescribed by a root cause evaluation was a performance deficiency. The performance deficiency is more than minor and is therefore a finding because it is associated with the human performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609,

Significance Determination Process, Phase 1 Worksheets, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a lo`ss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. Since this finding is associated with a 2005 root cause evaluation, that required training as part of the corrective action followup and there have been changes to the licensees corrective action program, the inspectors determined that this was not reflective of current performance and therefore did not have a crosscutting aspect associated with it (Section 4OA2).

REPORT DETAILS

Summary of Plant Status

Unit 2 remained at essentially full power for the entire inspection period.

Unit 3 began the inspection period at full power. On September 19, 2010, the plant began a planned power coast down of one percent per day because of fuel depletion. At the end of the inspection period power was 94 percent.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignments

Main article: IP 71111.04

Partial Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

August 2, 2010, Unit 3, emergency diesel generator train B

September 1, 2010, Unit 2, auxiliary feedwater train A

September 14, 2010, Unit 3, battery charger train B The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three partial system walkdown samples as defined by IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

July 30,2010, Unit 3, auxiliary feedwater pump room area

August 5, 2010, Unit 3, safety equipment building, rooms 6 through 14 and 16 through 26

August 19, 2010, Unit 2, fuel handling building

September 4, 2010, Unit 3, containment penetration and fuel handling, 63 foot-6 inch elevation

September 5, 2010, Unit 3, main steam isolation valve area The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed, that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees corrective action program.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five quarterly fire-protection inspection samples as defined by IP 71111.05-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11

a. Inspection Scope

On July 27, 2010, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator annual requalification dynamic evaluation examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

Licensed operator performance

Crews clarity and formality of communications

Crews ability to take timely actions in the conservative direction

Crews prioritization, interpretation, and verification of annunciator alarms

Crews correct use and implementation of abnormal and emergency procedures

Control board manipulations

Oversight and direction from supervisors

Crews ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications The inspectors compared the crews performance in these areas to pre-established operator action expectations and successful critical task completion requirements.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one quarterly licensed-operator requalification program sample as defined in IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk significant systems:

August 2-4, 2010, Units 2 and 3, maintenance of safety-related emergency ventilation vaneaxial fans The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

Implementing appropriate work practices

Identifying and addressing common cause failures

Scoping of systems in accordance with 10 CFR 50.65(b)

Characterizing system reliability issues for performance

Charging unavailability for performance

Trending key parameters for condition monitoring

Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or (a)(2)

Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one quarterly maintenance effectiveness sample as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

July 28-29, 2010, Unit 3, movement of tendon gallery hatches near reserve auxiliary transformer 3XR3

August 12, 2010, Unit 2, emergent maintenance activities on containment sump pump discharge isolation valve 2HV5803

September 2, 2010, Unit 3, test plan to troubleshoot 100 percent positive electrical DC ground on bus 3D5

The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three maintenance risk assessments and emergent work control inspection samples as defined by IP 71111.13-05.

b. Findings

Introduction.

The inspectors identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure of maintenance personnel to follow the requirements of station procedures while performing work on containment sump pump discharge isolation valve 2HV5803.

Description.

On January 21, 2010, while performing scheduled maintenance activities on valve 2HV5803, maintenance personnel identified an electrical lead incorrectly terminated on the valves torque switch, contrary to vendor recommendations. Nuclear Notification NN 200757360 was written to capture this issue in the corrective action program, and recommended that the torque switch be replaced and a permanent plant modification be made to the electrical wiring of the valve so that the identified lead would no longer be landed on the torque switch.

On January 25, 2010, Engineering Change Package ECP 800445897 was issued along with the revised wiring diagram which had been changed to reflect the new wiring detail.

Maintenance personnel then re-terminated the leads of the valve using procedure SO123-II-15.3, Temporary System Alteration and Restoration Form, Revision 17.

On January 26, 2010, after the completion of all work activities and postmaintenance testing, including the implementation of the wiring modification, but prior to the valve being released back to operations, maintenance personnel became aware that a work order was required to implement these wiring changes. Work Order WO 800448701 was issued on January 27, 2010, and subsequently closed on the same day after verification wiring was installed per the correct design configuration. Nuclear Notification NN 200767264 was written to capture this issue in the corrective action program. The licensee subsequently closed Nuclear Notification NN 200767264 on February 6, 2010, stating that nothing had been done incorrectly.

The inspectors reviewed this issue and questioned the licensees determination that nothing had been done incorrectly. During their review the inspectors noted that procedure SO123-II-15.3 Section 1.1.1.1 stated, in part, This procedure is not applicable when alterations are permanent. and section 4.1 stated, in part, When equipment is returned to its owner it must be restored to the As-Found condition unless an alteration is documented by procedure SO123-XV-5.1, Temporary Modification

Control. Also, the inspectors noted that procedure SO123-XXIV-10.1, Preparation, Review, Approval, Issuance, Implementation, and Closure of Engineering Change Packages (NECPs) and Engineering Change Notices (ECNs), Revision 21, section 6.3.1 stated, in part, The responsible work organization implements field changes according to approved nuclear engineering change package and appropriate procedures including generating work documents.

As such, the inspectors determined that maintenance personnel had failed to follow station procedures during this activity. Specifically, the inspectors determined that procedure SO123-II-15.3 was not an appropriate procedure for re-terminating the valve since this modification was to be permanent, and procedure SO-XXIV-10.1 required that a work order be generated to perform design changes. The inspectors informed the licensee of their concerns and the licensee initiated Nuclear Notification NN 200964035 to capture this concern in the corrective action program.

Analysis.

The failure of maintenance personnel to follow the requirements of procedures SO123-II-15.3 and SO123-XXIV-10.1 was a performance deficiency. The performance deficiency was determined to be more than minor and is therefore a finding because if left uncorrected, the continued practice of circumventing site procedural requirements by craft personnel during maintenance or design modification work on safety-related equipment would have the potential to leave more risk significant equipment in a degraded or inoperable condition without required documentation and without the knowledge and approval of site management and operations personnel. The finding is associated with the design control attribute of the Mitigating Systems Cornerstone.

Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding was determined to have very low safety significance because the finding:

(1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality;

(2) did not represent an actual loss of safety function of the system or train;

(3) did not result in the loss of one or more trains of nontechnical specification equipment; and

(4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding was determined to have a crosscutting aspect in the area of human performance, associated with the work practices component, in that the licensee failed to define and effectively communicate expectations regarding procedural compliance, and that personnel follow procedures

H.4(b).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions and drawings. Procedure SO123-II-15.3 did not allow station personnel to perform alterations to plant equipment that would be permanent, and procedure SO123-XXIV-10.1 required that a work order be generated prior to performing design change activities. Contrary to the above, on January 25, 2010, maintenance personnel failed to follow these procedures, in that, they implemented a permanent design change to valve 2HV5803 using procedure SO123-II-15.3, without an implementing work order as required by procedure SO123-XXIV-10.1.

Because this finding is of very low safety significance and has been entered into the licensees corrective action program as Nuclear Notifications NNs 201061230, 200767264 and 200964035, this violation is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000361/2010004-01, Failure to Follow Procedures While Implementing a Design Change.

1R15 Operability Evaluations

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed the following issues:

June 30, 2010, Unit 2, saltwater water cooling pump train B in alarm following inservice testing

July 12-13, 2010, Unit 2, emergency diesel generator train B building emergency ventilation fan 2MA276 failure

August 11-12, 2010, Unit 2, charging line to reactor coolant loop 1A control valve, 2HV9204, chronic boric acid packing leak

August 30, 2010, Unit 3, component cooling water train B, incorrect weld cut on heat exchanger vent valve pipe The inspectors selected these potential operability issues based on the risk-significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and Updated Safety Analysis Report to the licensees evaluations, to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. The inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four operability evaluations inspection samples as defined in IP 71111.15-05.

b. Findings

Introduction.

A self-revealing Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to promptly identify and correct a condition adverse to quality associated with safety-related emergency ventilation fans. Specifically, the licensee did not adequately identify a degrading material condition on the emergency ventilation fan nose cones that resulted in failure of the Unit 2 emergency diesel generator train B ventilation fan on July 12, 2010.

Description.

While performing work on ventilation dampers in the Unit 2 saltwater cooling pump room in July 2003, maintenance personnel identified the fan nose cone on saltwater cooling pump room fan 2MA370 was severely corroded. The discovery of this condition resulted in additional inspections of all saltwater cooling pump room safety-related emergency ventilation fans. Between July 2003 and July 2007 all of the

saltwater cooling pump room emergency ventilation fan nose cones inspected were subsequently replaced as a result of degradation caused by marine environment corrosion.

Additional corrective actions included a maintenance program to perform visual inspections of the nose cones of other safety-related ventilation fans. In addition, the preventative maintenance frequency was established to ensure inspection of the nose cones was completed every six years. In May 2007, both of the Unit 2 train B emergency diesel generator ventilation fans were inspected. However, the visual inspections were inadequate and failed to detect the degrading condition of the nose cone associated with the exposure of the emergency ventilation fan components to a marine environment. As a result, the material condition of the ventilation fan continued to degrade, such that on July 12, 2010, following the start of the emergency diesel generator for a routine surveillance run, emergency ventilation vaneaxial fan 2MA276 failed after starting. The nose cone mounted on the front of the fan hub broke away from the mounting ring and was drawn into rotating fan blades, resulting in a loud noise and smoke. The equipment operator present in the emergency diesel generator room immediately secured the running diesel generator and informed the control room.

Subsequent troubleshooting determined that the nose cone material condition had degraded due to galvanic corrosion caused by long term exposure to the marine environment.

All safety-related emergency ventilation fans with direct exposure to the marine environment were inspected and replaced as necessary, between July 19 and July 27, 2010. An apparent cause evaluation was performed in Nuclear Notification NN 201009885 and determined the cause was inadequate preventative maintenance.

The degradation was a result of accelerated galvanic corrosion of the nose cone section of the emergency ventilation fan. The majority of the corrosion was initiated on the back side of the nose cone hub, and consequently, the visual inspections performed between July 2003 and July 12, 2010, were not adequate to detect the degradation of the hub material.

Analysis.

The failure of the licensee to identify and correct a condition adverse to quality associated with safety-related emergency ventilation fans in a timely manner, was a performance deficiency. The performance deficiency is more than minor and is therefore a finding because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding is determined to have very low safety significance because the finding:

(1) is not a design or qualification issue confirmed not to result in a loss of operability or functionality;

(2) did not represent an actual loss of safety function of the system or train;

(3) did not result in the loss of one or more trains of nontechnical specification equipment; and

(4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather imitating event. Since the inadequate corrective actions were developed in 2003 and the licensees corrective action program has improved with respect to extent of condition reviews, the inspectors determined that this finding was not reflective of current performance, and therefore, did not have a crosscutting aspect associated with it.

Enforcement.

Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.

Maintenance Order SO123-MA-1, Maintenance Program, Revision 5,Section IV A.1, required, in part, a maintenance program be established and implemented to ensure structures, systems, and components important to safety are maintained in a condition that allows them to perform their intended functions.

Contrary to the above, between July 2003 and July 2010, the licensee failed to adequately correct the adverse condition of degrading emergency ventilation fan nose cones. Specifically, the licensee failed to ensure the preventative maintenance inspections were thorough enough to detect and prevent the corrosion of fan nose cones caused by the exposure to a marine environment, which resulted in an emergency ventilation fan failure in July 2010. The licensee has implemented corrective actions to replace safety-related emergency ventilation fans at 12 year intervals. Because the finding is of very low safety significance and has been entered into the licensees corrective action program as Nuclear Notifications NNs 201009885 and 201088409 this violation is being treated as a noncited violation consistent with Section VI.A.1 of the Enforcement Policy: NCV 05000361;05000362/2010004-02, Failure to Promptly Identify and Correct a Condition Adverse to Quality Associated with Safety-related Emergency Ventilation Fans.

1R19 Postmaintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed the following postmaintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

July 16, 2010, Unit 2, testing of emergency ventilation fan 2MA276 following corrective maintenance

August 12, 2010, Unit 2, auxiliary feedwater system 2HY8200 solenoid valve replacement The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate The inspectors evaluated the activities against the technical specifications, the Updated Final Safety Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with postmaintenance tests to determine whether the licensee was identifying problems and entering them in the

corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of two postmaintenance testing inspection samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors reviewed the Updated Final Safety Analysis Report, procedure requirements, and technical specifications to ensure that the four surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

Preconditioning

Evaluation of testing impact on the plant

Acceptance criteria

Test equipment

Procedures

Jumper/lifted lead controls

Test data

Testing frequency and method demonstrated technical specification operability

Test equipment removal

Restoration of plant systems

Fulfillment of ASME Code requirements

Updating of performance indicator data

Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

Reference setting data

Annunciators and alarms setpoints

The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

June 30, 2010, Unit 2, saltwater cooling pump P307 inservice pump test

August 16, 2010, Unit 3, reactor coolant system leak rate test

September 15, 2010, Unit 3, containment spray pump and valve train B test Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three surveillance testing inspection samples as defined in IP 71111.22-05.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP2 Alert Notification System Testing

Main article: IP 71114.02

a. Inspection Scope

The inspectors discussed with licensee staff the operability of offsite siren emergency warning systems, and backup alerting methods, to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50, Appendix E. The licensee=s alert and notification system testing program was compared with criteria in NUREG-0654, ACriteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,@

Revision 1; FEMA Report REP-10, AGuide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants@; and the licensee=s current FEMA-approved alert and notification system design report, dated February 10, 2010, with modification letter, dated March 24, 2010. Other specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.02-05.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Augmentation Testing

Main article: IP 71114.03

a. Inspection Scope

The inspectors discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to determine the adequacy of licensee methods for staffing emergency response facilities in accordance with their emergency plan. The inspectors evaluated the licensee=s ability to staff the emergency response facilities in accordance with the licensees emergency plan and the

requirements of 10 CFR Part 50, Appendix E. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.03-05.

b. Findings

No findings were identified.

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies

Main article: IP 71114.05

a. Inspection Scope

The inspectors reviewed the licensee=s corrective action program requirements as documented in site Procedures SO123-XV-50, Corrective Action Program, Revision 19, SO123-XV-50.CAP-1, Writing Nuclear Notifications for Problem Identification and Resolution, Revision 4, and SO123-XV-50.CAP-4, Implementing Corrective Actions, Revision 5. The inspectors reviewed summaries of corrective action program documents assigned to the emergency preparedness department and emergency response organization between April 2009 and July 2010. Specific corrective action documents selected for detailed review against the program requirements are listed in the attachment to this report. The inspectors evaluated the response to the corrective action requests to determine the licensee=s ability to identify, evaluate, and correct problems in accordance with the licensee program requirements, planning standard 10 CFR 50.47(b)(14), and 10 CFR Part 50, Appendix E. The inspectors observed the August 24, 2010, post-audit exit meeting conducted by the site Quality Assurance Department for Audit SCES-09-10, Emergency Preparedness Program. The inspectors also reviewed licensee audits, assessments, drill reports, and after action reports to determine whether the licensee was identifying weaknesses and deficiencies in the emergency preparedness program. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.05-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Main article: IP 71114.06

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on July 14, 2010, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Technical Support Center and Emergency Operating Facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The

inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstone: Occupational and Public Radiation Safety

2RS7 Radiological Environmental Monitoring Program

Main article: IP 71124.07

a. Inspection Scope

This area was inspected to:

(1) ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program;

(2) verify that the radiological environmental monitoring program is implemented consistent with the licensees technical specifications and/or offsite dose calculation manual, and to validate that the radioactive effluent release program meets the design objective contained in Appendix I to 10 CFR Part 50; and

(3) ensure that the radiological environmental monitoring program monitors noneffluent exposure pathways, is based on sound principles and assumptions, and validates that doses to members of the public are within the dose limits of 10 CFR Part 20 and 40 CFR Part 190, as applicable. The inspectors reviewed and/or observed the following items:

Annual environmental monitoring reports and offsite dose calculation manual

Selected air sampling and thermoluminescence dosimeter monitoring stations

Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach ground water

Records required by 10 CFR 50.75(g)

Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection

Calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation

Interlaboratory comparison program results

Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.07-05.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

This area was inspected to verify the effectiveness of the licensee=s programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 10 CFR Parts 20, 61, and 71 and the Department of Transportation regulations contained in 49 CFR Parts 171-180 for determining compliance. The inspectors interviewed licensee personnel and reviewed the following items:

The solid radioactive waste system description, process control program, and the scope of the licensee=s audit program

Control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition

Changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in place

Radiochemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

Processes for waste classification including use of scaling factors and 10 CFR Part 61 analysis

Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest

Audits, self-assessments, reports, and corrective action reports radioactive solid waste processing, and radioactive material handling, storage, and transportation performed since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.08-05.

4OA2 Identification and Resolution of Problems

b. Observations and Findings

Overall, the licensees recovery plan appeared to address the appropriate deficiencies necessary for performance improvement. However, the inspectors also determined that some deficiencies existed associated with the implementation of the recovery plan.

All maintenance personnel interviewed indicated their initial training on the Systems Application and Products computer software system used for implementation of the corrective action program was inadequate. The inspectors determined that the licensee generated some initiatives in response to previously identified knowledge gaps in the use of the Systems Application and Products operating system that came to light as a result of focus group interviews conducted by the NRC in February 2009 (see NRC Inspection Report 05000361/2009009 and 05000362/2009009, Section 4OA2.2). These initiatives included distributing a written survey among the maintenance staff to poll them on what additional training should be considered, as well as providing a method to generate nuclear notifications in hardcopy in lieu of a computer. However, the inspectors determined that no lesson plan or training schedule had yet been generated to perform

the appropriate training. The licensee committed to having a lesson plan and training schedule in place by August 15, 2010. The inspectors considered the elapsed time to take action against the Systems Application and Products computer software knowledge gap deficiency to be excessive, as the deficient Systems Application and Products computer software training took place approximately two years ago during the summer of 2008. The licensee responded to this concern by generating Nuclear Notification NN 200980063.

The inspectors determined that training implemented in response to licensee identified knowledge gaps in mechanical maintenance and configuration control appropriately included the pertinent information and work techniques to address the deficiencies identified. However, the resolutions to the identified deficiencies appeared narrowly focused, as they did not incorporate lessons learned from previous related occurrences at San Onofre, some that resulted in violations of NRC requirements. The licensee responded to this concern by generating Nuclear Notification NN 200984342.

The inspectors noted that maintenance personnel currently have no individual training plans or goals leading to full qualification. The inspectors concluded that such tools would be essential in ensuring successful implementation of a new maintenance training program. The inspectors also determined that maintenance personnel were unable to individually determine what training was currently available without outside assistance.

The licensee responded to these concerns by committing to developing individual training plans for maintenance personnel and by generating Nuclear Notification NN 200984403.

The inspectors determined that the reviewed licensee generated training evaluations were cursory and lacked detail. Performance and training effectiveness evaluation forms contained checklists as part of the evaluation. The inspectors noted that no details were provided when the checklist box item was adversely marked. The inspectors concluded that the deficiencies identified in the training evaluations could not be fully resolved without some explanation as to what contributed to the deficiency. The licensee responded to this concern by generating Nuclear Notification NN 200984340.

Failure to Provide Training Mandated by a Root Cause Evaluation

Introduction.

The inspectors identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failure of electrical maintenance management personnel to adequately ensure that training was provided to electrical maintenance workers on techniques to prevent loose electrical connections. This training was a required action as described in Root Cause Evaluation RCE 050601315 written in response to a June 2005 failure of an emergency diesel generator surveillance test due to a loose electrical connection in an emergency supply fan for the Unit 3 train B emergency diesel generator.

Description.

Between June 21 and June 25, 2010, the inspectors performed a review of training records associated with maintaining the proficiency of electrical maintenance personnel through continuing training based on past plant occurrences. The inspectors asked to review the training records associated with training prescribed by a root cause evaluation performed as result of an emergency diesel generator surveillance test failure in June 2005 due to a loose electrical connection in an electrical breaker for the emergency diesel generator room supply fan.

The training prescribed by the root cause evaluation was to educate electrical maintenance personnel on techniques to prevent inadvertent loose connections.

Specifically, the practice of performing a wiggle test to ensure a secure connection was being abandoned in favor of tightness verification using primarily a screwdriver in contact with the connection. The root cause evaluation also prescribed that electrical maintenance procedures be modified to include a precaution to prevent over-tightening and stripping of connections, and to direct that the wiggle test could cause electrical connections to become loose. The inspectors verified that the procedure enhancements had been incorporated, but could find no evidence of a lesson plan, training records, or any other documentation that any training as prescribed by the root cause evaluation ever took place. The licensee could provide no immediate explanation why the training did not take place. The licensee generated Nuclear Notification NN 200986184 in response to this issue. The inspectors noted that the missed training would have addressed maintenance techniques that could lead to loose electrical connections on breakers for safety related equipment. The licensee indicated that the training would be scheduled and implemented per the original requirements of the root cause evaluation as part of their corrective actions.

During their initial investigation, the licensee discovered that Root Cause Evaluation RCE 050601315 had been audited for completeness in November 2009. The auditors verified that the requirement for electrical maintenance procedures to be enhanced was performed. However, the audit was absent any comment or verification that the required training was scheduled or implemented, apparently due to an oversight by the auditors.

The licensee generated a second Nuclear Notification NN 200992291 to address this issue. The licensee indicated that other root cause evaluations would be reviewed for completeness as part of the corrective action.

Analysis.

The failure of electrical maintenance management personnel to adequately implement corrective actions as prescribed by a root cause evaluation was a performance deficiency. The performance deficiency is more than minor and therefore a finding because it is associated with the human performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding was determined to have very low safety significance because the finding:

(1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality;

(2) did not represent an actual loss of safety function of the system or train;

(3) did not result in the loss of one or more trains of nontechnical specification equipment; and

(4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. Since this finding is associated with a 2005 root cause evaluation, that required training as part of the corrective action followup and there have been changes to the licensees corrective action program, the inspectors determined that this was not reflective of current performance and therefore did not have a crosscutting aspect associated with it.

Enforcement.

Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, from June 2005 to June 2010, the licensee failed to assure that a condition adverse to quality was corrected. Specifically,

electrical maintenance management personnel failed to adequately ensure that training for electrical maintenance workers on loose electrical connections took place as prescribed by a root cause evaluation generated in response to an emergency diesel generator surveillance test failure. The root cause evaluation indicated that this training was necessary to aid in preventing future malfunctions and failures of safety-related equipment. Because this finding is of very low safety significance and has been entered into the licensees corrective action program as Nuclear Notifications NNs 200986184 and 200992291, this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000361;05000362/2010004-03, Failure to Provide Training Mandated by a Root Cause Evaluation.

.4 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensees corrective action program, the inspectors recognized a corrective action item documenting the issues listed below. The inspectors considered the following during the review of the licensees actions: (1)complete and accurate identification of the problem in a timely manner;

(2) evaluation and disposition of operability/reportability issues;

(3) consideration of extent of condition, generic implications, common cause, and previous occurrences;

(4) classification and prioritization of the resolution of the problem;

(5) identification of root and contributing causes of the problem;

(6) identification of corrective actions; and

(7) completion of corrective actions in a timely manner.

July 13, 2010, missed licensee event report as documented in Nuclear Notification NN 201038508 These activities constitute completion of one in-depth problem identification and resolution sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

.5 Review of Operator Workarounds

a. Inspection Scope

The inspectors conducted a cumulative review of operator workarounds on August 30, 2010, for Units 2 and 3, and assessed the effectiveness of the operator workaround program to verify that the licensee was: 1) identifying operator workaround problems at an appropriate threshold; 2) entering them into the corrective action program; and 3)identifying and implementing appropriate corrective actions. The review included walkdowns of the control room panels, interviews with licensed operators and reviews of the control room discrepancies list, the lit annunciators list, the operator burden list, and the operator workaround list.

These activities constitute completion of one review of operator workarounds sample as defined in IP 71152-05.

b. Findings

No findings were identified.

4OA3 Event Follow-up

Main article: IP 71153

.1 Event Follow Up

a. Inspection Scope

The inspectors reviewed the below listed events for plant status and mitigating actions to:

(1) provide input in determining the appropriate agency response in accordance with Management Directive 8.3, NRC Incident Investigation Program;

(2) evaluate performance of mitigating systems and licensee actions; and

(3) confirm that the licensee properly classified the event in accordance with emergency action level procedures and made timely notifications to NRC and state/governments, as required.

July 7, 2010, Units 2 and 3, ground motion detected on site requiring entry into abnormal operating instruction SO23-13-3, "Earthquake," Revision 13

July 12, 2010, Unit 2, Management Directive 8.3 review of failure of a train B emergency diesel generator building emergency ventilation fan 2MA276

July 21, 2010, Units 2 and 3, sea grass intrusion impact on saltwater cooling system and main condenser differential pressure

August 16-18, 2010, Unit 3, reactor coolant leakage identified in charging pump discharge piping and isolated Documents reviewed by the inspectors are listed in the attachment.

These activities constitute completion of four inspection samples as defined in Inspection Procedure 71153-05.

b. Findings

No findings were identified.

.2 Event Report Review

a. Inspection Scope

The inspectors reviewed the below listed Licensee Event Reports and related documents to assess:

(1) the accuracy of the Licensee Event Report:

(2) the appropriateness of corrective actions;

(3) violations of requirements; and

(4) generic issues.

b. Observations and Findings

(Closed) Licensee Event Reports 05000361/2008-008-00 and 05000361/2008-008-01,

Missed Technical Specification Surveillance Requirement on Spare Station Battery The inspector reviewed the information the licensee provided to describe and analyze this event. On July 15, 2008, station backup battery B00X was declared operable and placed in service to allow work on station battery 2B008. On July 17, 2008, station battery 2B008 was returned to service and backup battery B00X was removed from service. On October 23, 2008, the licensee identified that when B00X was placed in service on July 15, it did not have a current quarterly surveillance for Surveillance Requirement 3.8.6.2. The required surveillance was successfully performed on July 26, 2008. This event was caused by a combination of an incorrect test procedure and failure to properly implement a transition plan for scheduling surveillances from the MOSAIC system to the Enterprise Resource Planning System. The licensee performed an extent of condition review and identified other examples of missed surveillances due to improper implementation of the transition. The other examples were subsequently successfully completed. The failure to meet surveillance test frequency is being treated as a minor violation because the subsequent surveillances were successfully performed and demonstrated that the equipment was capable of performing their safety functions.

This failure to comply with technical specification requirement constitutes a violation of minor significance that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. This Licensee Event Report and Supplement -01 are closed.

4OA5 Other Activities

.1 (Closed) Temporary Instruction 2515/173, Review of the Implementation of the Industry

Groundwater Protection Voluntary Initiative

a. Inspection Scope

An NRC assessment was performed of the licensees groundwater protection program to determine whether the licensee implemented the voluntary Industry Groundwater Protection Initiative, dated August 2007 (Nuclear Energy Institute 07-07, ADAMS Accession Number ML072610036). The inspectors interviewed personnel, performed walkdowns of selected areas, and reviewed the following items:

Records of the site characterization of geology and hydrology

Evaluations of systems, structures, and or components that contain or could contain licensed material and evaluations of work practices that involved licensed material for which there is a credible mechanism for the licensed material to reach the groundwater

Implementation of an onsite groundwater monitoring program to monitor for potential licensed radioactive leakage into groundwater

Procedures for the decision making process for potential remediation of leaks and spills, including consideration of the long-term decommissioning impacts

Records of leaks and spills recorded, if any, in the licensees decommissioning files in accordance with 10 CFR 50.75(g)

Protocols for notification to the local and state officials, and to the NRC regarding detection of leaks and spills

Protocols and/or procedures for 30-day reports if an onsite groundwater sample exceeds the criteria in the radiological environmental monitoring program

Groundwater monitoring results as reported in the annual effluent and/or environmental monitoring report

Licensee and industry assessments of implementation of the groundwater protection initiative

b. Findings

No findings were identified.

.2 (Closed) Temporary Instruction 2515/180, Inspection of Procedures and Processes for

Managing Fatigue

a. Inspection Scope

The objective of this Temporary Instruction was to determine if licensees implementation procedures and processes required by 10 CFR 26, Subpart I, Managing Fatigue are in place to reasonably ensure the requirements specified in Subpart I are being addressed.

The Temporary Instruction applies to all operating nuclear power reactor licensees but is intended to be performed for one site per utility. The inspector interfaced with the appropriate station staff to obtain and review station policies, procedures and processes necessary to complete all portions of this Temporary Instruction.

b. Findings

No findings were identified.

.3 Institute of Nuclear Power Operations (INPO) Assessment Review

The inspectors reviewed the Institute for Nuclear Power Operations (INPO) Biennial Evaluation and Assessment Report for SONGS. The inspectors noted that the INPO report was generally commensurate with NRC assessment of performance and that no significant safety issues requiring separate NRC follow-up were identified.

4OA6 Meetings

Exit Meeting Summary

On June 29, 2010, the operation engineer inspectors presented their inspection results of training records to Mr. G. Cook, Manager, Compliance, by telephone.

On August 6, 2010, the inspectors presented the results of the radiation safety inspections to Mr. D. Bauder, Vice President and Station Manager, and other members of the licensee staff.

The licensee acknowledged the issues presented.

On August 12, 2010, reactor inspectors presented their maintenance procedure follow-up inspection results to Mr. R. St. Onge, Director of Nuclear Regulatory Affairs, and Mr. E. Hubley, Director of Maintenance and Construction, along with members of their staff.

On August 27, 2010, the inspectors presented the results of the inspection of the onsite emergency preparedness program to Mr. R. Ridenoure, Senior Vice President and Chief Nuclear Officer, and other members of the licensees staff. The licensee acknowledged the issues presented.

On September 24, 2010, the inspectors presented the results of the resident inspections to Mr. J. Sheppard, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Adler, Manager, Maintenance/Systems Engineering

B. Arbour, Operator Continuing Training Supervisor

J. Armas, Supervisor, Maintenance Engineering Fluid Process

D. Axline, Technical Specialist, Nuclear Regulatory Affairs

D. Bauder, Plant Manager

B. Corbett, Manger, Performance Improvement

G. Cook, Manager, Compliance, Nuclear Regulatory Affairs

B. Culverhouse, Manager, Offsite Emergency Preparedness

K. Gallion, Manager, Onsite Emergency Preparedness

M. Goettel, Director, Site Support

M. Graham, Manager, Plant Operations

A. Gray, Supervisor, Special Projects

N. Hansen, Environmental Specialist

R. Heckler, Manager, Environmental

E. Hubley, Director, Maintenance/Construction

J. Hurlocker, Supervisor, Radioactive Material

G. Johnson, Jr., Senior Nuclear Engineer, Maintenance/Systems Engineering

K. Johnson, Manager, Design Engineering

L. Kelly, Engineer, Nuclear Regulatory Affairs

M. Lewis, Manager, Health Physics

D. Spires, Director, Work Control

J. Madigan, Manager, Health Physics

M. McBrearty, Licensing Engineer, Nuclear Regulatory Affairs

T. McCool, Plant Manager

A. Meichler, Mechanical/System Engineering Supervisor

R. Nielsen, Supervisor, Nuclear Oversight

N. Quigley, Manager, Maintenance/System Engineering

R. Richter, Engineering Supervisor, Fire Protection

C. Ryan, Manager, Maintenance & Construction Services

A. Shean, Manager, Nuclear Oversight Division

R. St. Onge, Director Nuclear Regulatory Affairs

J. Todd, Manager, Security

NRC Personnel

M. Runyan, Senior Reactor Analyst

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000361/2010004-01 NCV Failure to Follow Procedures While Implementing a Design Change (Section 1R13)

05000361/2010004-02 NCV Failure to Promptly Identify and Correct a Condition Adverse

05000362/2010004-02 to Quality Associated with Safety-related Emergency Ventilation Fans (Section 1R15)

05000361/2010004-03 NCV Failure to Provide Training Mandated by a Root Cause

05000362/2010004-03 Evaluation (Section 4OA2)

Closed

05000361/2008-008-00 LER Missed Technical Specification Surveillance Requirement on

05000361/2008-008-01 Spare Station Battery (Section 4OA3)

LIST OF DOCUMENTS REVIEWED