IR 05000361/2012005

IR 05000361-12-005 and 05000362-12-005 - SONGS Integrated Resident and Regional Inspection Report, Follow-up of Events

ML13046A164
Person / Time
Site:	San Onofre
Issue date:	02/14/2013
From:	Ryan Lantz NRC Region 4
To:	Peter Dietrich Southern California Edison Co
Lantz R
References
IR-12-005
Download: ML13046A164 (32)

Text

UNITE D S TATE S NUC LEAR RE GULATOR Y C OMMI S SI ON ary 14, 2013

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000361/2012005 and 05000362/2012005

Dear Mr. Dietrich:

On December 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your San Onofre Nuclear Generating Station, Units 2 and 3, facility. The enclosed inspection report documents the inspection results which were discussed on January 8, 2013, with Mr. Doug Bauder and other members of your staff.

The inspection 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.

The NRC has determined that a traditional enforcement Severity Level IV violation occurred.

The NRC is treating this violation as a noncited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest this noncited violation, 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 DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; 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, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of

Southern California Edison Company -2-NRC's Agencywide Document Access and Management 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/

Ryan E. Lantz, Chief SONGS Project Branch Office of the Regional Administrator Dockets: 50-361, 50-362 Licenses: NPF-10, NPF-15

Enclosure:

NRC Inspection Report 05000361/2012005 and 05000362/2012005 w/attachment

REGION IV==

Docket: 50-361, 50-362 License: NPF-10, NPF-15 Report: 05000361/2012005 and 05000362/2012005 Licensee: Southern California Edison (SCE)

Facility: San Onofre Nuclear Generating Station, Units 2 and 3 Location: 5000 S. Pacific Coast Hwy San Clemente, CA Dates: September 24 through December 31, 2012 Inspectors: M. Bloodgood, Reactor Inspector J. Dykert, Project Engineer G. Guerra, Emergency Preparedness Inspector B. Parks, Project Engineer J. Reynoso, Resident Inspector N. Taylor, Senior Project Engineer G. Warnick, Senior Resident Inspector Approved Ryan E. Lantz, Chief By: SONGS Project Branch Office of the Regional Administrator Enclosure

SUMMARY OF FINDINGS

IR 05000361/2012005, 05000362/2012005; 09/24/2012 - 12/31/2012; San Onofre Nuclear

Generating Station, Units 2 and 3, Integrated Resident and Regional Report; Follow-up of Events.

The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609,

Significance Determination Process. The cross-cutting 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.

Cornerstone: Mitigating Systems

• Severity Level IV. The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.9, Completeness and Accuracy of Information, for the failure of the licensee to provide complete and accurate information in all material respects in operability and reportability review supporting documents. Specifically, on September 29, 2011, the licensee did not provide information that was complete and accurate in all material respects, in that Evaluation Report FAI/11-0655, Evaluation of Potential Cooling of the SONGS Steam Line for the AFW Turbine, used inaccurate information to inappropriately determine that the turbine-driven auxiliary feedwater pump was operable, the condition was not reportable per the requirements of 10 CFR 50.73, and the compensatory measures implemented on May 5, 2011, could be removed. The compensatory measures were improperly removed on October 27, 2011. This violation has been entered into the licensees corrective action program as Nuclear Notification NN 202280026.

The failure of the licensee to provide complete and accurate information related to the operability of the AFW system was a performance deficiency. The significance determination process is not suited to assess the significance of a violation of 10 CFR 50.9 because it affected the ability of the NRC to perform its regulatory oversight function and, as such, it was assessed using traditional enforcement. This violation was determined to be a Severity Level IV violation based on NRC Enforcement Policy examples provided in Section 6.9. No crosscutting aspect was assigned because the performance deficiency was assessed using traditional enforcement (Section 4OA3).

Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Unit 2 began the inspection period shutdown for refueling Outage R2C17 and remained shutdown for the duration of the inspection period.

Unit 3 began the inspection period shutdown for forced Outage F3C16 and remained shutdown for the duration of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of the adverse weather procedures for seasonal extremes (e.g., extreme high temperatures, extreme low temperatures, or hurricane season preparations). The inspectors verified that weather-related equipment deficiencies identified during the previous year were corrected prior to the onset of seasonal extremes and evaluated the implementation of the adverse weather preparation procedures and compensatory measures for the affected conditions before the onset of, and during, the adverse weather conditions.

During the inspection, the inspectors focused on plant-specific design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection and verified that operator actions were appropriate as specified by plant-specific procedures.

Specific documents reviewed during this inspection are listed in the attachment. The inspectors also reviewed corrective action program items to verify that plant personnel were identifying adverse weather issues at an appropriate threshold and entering them into their corrective action program in accordance with station corrective action procedures. The inspectors reviews focused specifically on the following plant systems:

• December 31, 2012, the inspectors completed a review of the licensee's winter seasonal readiness per Procedure SO23-XX-29.1, Seasonal Readiness, Revision 3 These activities constitute completion of one readiness for seasonal adverse weather sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

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

• October 3, 2012, Unit 2, shutdown cooling system while in mid-loop conditions to remove steam generator nozzle dams

• November 14, 2012, Unit 2, Train B emergency diesel generator

• December 6, 2012, Unit 3, emergency diesel generator Train A while Train B was out of service for a maintenance outage 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, the UFSAR, 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 inspected accessible portions of the systems to verify that system components and support equipment were aligned correctly and were 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 in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On November 27, 2012, the inspectors performed a complete system alignment inspection of the Unit 3 spent fuel pool cooling system alignment to verify the functional capability of the system. The inspectors selected this system because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment.

The inspectors inspected the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, and operability of support systems and to ensure that ancillary equipment or debris did not interfere with equipment operation. The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment alignment problems were being identified and appropriately resolved. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one complete system walkdown sample as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

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:

• November 14, 2010, Unit 2, main steam isolation valve area and adjacent safety equipment building

• November 20, 2012, Unit 2, containment building

• November 27, 2012, Unit 3, penetration and fuel handling building, elevation 63-6

• December 19, 2012, Units 2 and 3, saltwater cooling pump room and tunnel The inspectors reviewed areas to assess whether 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; fire detectors and sprinklers were unobstructed; 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 four quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the UFSAR, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected underground bunkers/manholes to verify the adequacy of sump pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the areas listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, and control circuits, and temporary or removable flood barriers. Specific documents reviewed during this inspection are listed in the attachment.

• December 18, 2012, Unit 2, cooling water heat exchanger rooms, shutdown cooling heat exchanger rooms, and spent fuel pool heat exchanger room

• December 20, 2012, Unit 2, diesel generator underground manhole system These activities constitute completion of one flood protection measures inspection sample and one annual bunker/manhole sample as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On September 28, 2012, the inspectors observed a crew of licensed operators in the plants simulator during just-in-time training for reactor coolant system draining. The inspectors assessed the following areas:

• Licensed operator performance

• The ability of the licensee to administer the evaluations

• The modeling and performance of the control room simulator

• The quality of post-scenario critiques

• Follow-up actions taken by the licensee for identified discrepancies These activities constitute completion of one quarterly licensed operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

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

• October 30, 2012, Unit 3, emergency diesel generator

• December 19, 2012, Units 2 and 3, completed a review of the saltwater cooling system, including the repeated inservice test failure of Saltwater Cooling Pump 2P114

• December 21, 2012, Units 2 and 3, issues related to emergency diesel generators 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 three quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the following assessments:

• October 10, 2012, Units 2 and 3, shutdown cooling piping high energy line break analysis operability determination

• November 2, 2012, Unit 3, saltwater cooling system debris mitigation

• November 29, 2012, Units 2 and 3, Train B toxic gas isolation system inoperable due to Train A control room emergency air cleanup system test

• December 4, 2012, Unit 2, high DC voltage on non-1E uninterruptible Battery Charger 2B015W The inspectors selected these operability and functionality assessments based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure technical specification operability was properly justified and to verify that 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 UFSAR 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. Additionally, the inspectors 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 evaluation inspection samples as defined in Inspection Procedure 71111.15-05.

b. Findings

No findings were identified.

1R18 Plant Modifications

Permanent Modifications

a. Inspection Scope

The inspectors reviewed key affected parameters associated with energy needs, materials, replacement components, timing, heat removal, control signals, equipment protection from hazards, operations, flow paths, pressure boundary, ventilation boundary, structural properties, process medium properties, licensing basis, and failure modes for the permanent modifications listed below.

• October 9-11, 2012, Unit 2, upgrade to vibration and loose parts monitoring system to include upper steam generator bundle The inspectors reviewed key parameters associated with energy needs, materials, replacement components, timing, heat removal, control signals, equipment protection from hazards, operations, flow paths, pressure boundary, ventilation boundary, structural properties, process medium properties, licensing basis, and failure modes for the permanent modification.

The inspectors verified that modification preparation, staging, and implementation did not impair emergency/abnormal operating procedure actions, key safety functions, or operator response to loss of key safety functions; postmodification testing will maintain the plant in a safe configuration during testing by verifying that unintended system interactions will not occur; systems, structures, and components performance characteristics still meet the design basis; the modification design assumptions were appropriate; the modification test acceptance criteria will be met; and licensee personnel identified and implemented appropriate corrective actions associated with permanent plant modifications. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample for permanent plant modifications as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

1R19 Postmaintenance Testing

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:

• October 3, 2012, Unit 3, functional testing of refueling machine following replacement of primary encoder

• October 24-25, 2012, Unit 2, visual evaluation of reactor head quick lock penetrations for the incore instrumentation at normal operating pressure and temperature

• November 6, 2012, Unit 3, Train A emergency diesel generator and actuator replacement

• November 13, 2012, Unit 3, Train A emergency diesel generator return to service following generator replacement

• November 26, 2012, Units 2 and 3, gas-driven, fire mounted Fire Pump B.5.b surveillance

• November 28, 2012, Unit 2, Train B emergency diesel generator

• November 28, 2012, Units 2 and 3, Train A control room emergency air cleanup system test

• December 18, 2012, Unit 3, Train B emergency diesel generator annunciator battery charger AC power failure

• December 26, 2012, Unit 3, Train A emergency diesel generator frequency meter troubleshooting and repair 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 UFSAR, 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 nine postmaintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the UFSAR, procedure requirements, and technical specifications to ensure that the 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.

• October 9, 2012, Unit 2, reactor coolant gas vent valve testing

• October 9, 2012, Unit 3, Train B emergency diesel generator monthly surveillance run

• October, 22, 2012, Unit 2, high pressure safety injection check valve testing

• October 25, 2012, Unit 2, saltwater Cooling Pump 3MP114 and valve testing

• December 3, 2012, Units 2 and 3, Train B emergency chilled water system inservice test

• December 17, 2012, Unit 3, Train A emergency diesel generator refueling interval test

• December 19, 2012, Unit 3, auxiliary Feedwater Pump 2MP-141 inservice test

• December 21, 2012, Unit 2, saltwater Cooling Pump 2MP-112 inservice test Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of eight surveillance testing inspection samples as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on October 25, 2012, 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 control room simulator 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 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 Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the 3rd Quarter 2012 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.

This review was performed as part of the inspectors normal plant status activities and, as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Safety System Functional Failures (MS05)

a. Inspection Scope

The inspectors sampled licensee submittals for the safety system functional failures performance indicator, Units 2 and 3, for the period from the fourth quarter 2011 through the third quarter 2012. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73. The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC integrated inspection reports for the period of October 2011 through September 2012, to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator, and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of two safety system functional failure samples as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action program at an appropriate threshold, adequate attention was being given to timely corrective actions, and adverse trends were identified and addressed.

The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions.

Minor issues entered into the licensees corrective action program because of the inspectors observations are included in the attached list of documents reviewed.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees corrective action program. The inspectors accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Semiannual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees corrective action program and associated documents to identify trends related to security officer fatigue that could indicate the existence of a more significant safety issue. The inspectors considered the results of daily corrective action item screening discussed in Section 4OA2.2, above, licensee trending efforts, and licensee human performance results. The inspectors nominally considered the 6-month period of May 2012 through November 2012; although, some examples expanded beyond those dates where the scope of the trend warranted.

The inspectors also included issues documented outside the normal corrective action program. The inspectors compared and contrasted their results with the results contained in the licensees corrective action program trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

These activities constitute completion of a single semiannual trend inspection sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

.4 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensees corrective action program, the inspectors selected a corrective action item documenting:

• December 21, 2012, Unit 2, Nuclear Notification NN 202195384, which documented unexpected conditions identified on non-1E Battery Charger 2B015W 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.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

.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.

• October 21, 2012, Unit 2, hydrogen leak to environment due to small valve leak at the hydrogen skid

• October 23, 2012, Unit 2, organizational response to hydraulic oil leak on main steam isolation valve Documents reviewed by the inspectors are listed in the attachment.

These activities constitute completion of two 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 Licensee Event Report 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.

(Closed) Licensee Event Report 05000361; 05000362/2012-001-00, AFW Pump Inoperable due to Postulated Flooding Event Results in Condition Prohibited by Technical Specifications

b. Findings

Introduction.

The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.9, Completeness and Accuracy of Information, for the failure of the licensee to provide complete and accurate information in all material respects in operability and reportability review supporting documents. Specifically, an engineering evaluation report failed to contain complete and accurate information with respect to equipment configuration, which resulted in incorrect operability and reportability determinations.

Description.

On May 4, 2011, the inspectors identified that, from November 12, 2010, until May 5, 2011, operations personnel failed to follow Procedure SO123-XV-52, Operability Determination and Functionality Assessments, Revision 18. Specifically, operations personnel did not properly establish compensatory measures for flood protection of safety-related components of the auxiliary feedwater (AFW) system for all postulated flood levels and conditions. The finding was documented as NCV 05000361;05000362/2011003-01, Inadequate Compensatory Measures for a Design Nonconformance. The licensee implemented adequate compensatory measures on May 5, 2011, to maintain operability of the turbine-driven AFW pump on each unit.

On September 1, 2011, the inspectors concluded that, from original construction until adequate compensatory measure were implemented on May 5, 2011, the licensee failed to ensure that all applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the steam supply piping to the AFW pump turbine was not adequately protected from all postulated flood levels and conditions. Specifically, in the extreme event that the thunderstorm probable maximum precipitation (PMP) occured, water could have reached the steam supply pipe, resulting in steam condensation inside the pipe which could have impacted AFW pump operability. The licensee communicated to the inspectors that the compensatory measures would remain in place until the design nonconformance was resolved in order for the system to remain operable. The finding was documented as NCV 05000361;05000362/2011004-02, Failure to Provide Adequate Flood Protection for the Auxiliary Feedwater Steam Supply Piping.

On September 29, 2011, operations personnel issued Prompt Operability Determination POD 201448584-38, which incorporated Evaluation Report FAI/11-0655, Evaluation of Potential Cooling of the SONGS Steam Line for the AFW Turbine, to determine that the AFW turbine was operable with the design nonconformance, the condition was not reportable per the requirements of 10 CFR 50.73, and the compensatory measures implemented on May 5, 2011, could be removed. The compensatory measures were removed on October 27, 2011. The inspectors reviewed the prompt operability determination and, based on the information provided, agreed with the licensees conclusions. Unit 2 entered Mode 5 on January 10, 2012, and Unit 3 entered Mode 5 on January 31, 2012, which established plant conditions that no longer required the AFW system to be operable.

On February 1, 2012, engineering personnel performed a planning walkdown for an engineering change package and identified that the insulation around the Unit 2 AFW steam line piping did not meet design configuration requirements. Specifically, the design required the use of mineral wool insulation; however, the steam line piping was configured with calcium silicate, fiberglass, and cera-blanket insulation. Unit 3 AFW steam line piping was subsequently inspected, which identified the same design configuration issues. Evaluation Report FAI/11-0655 incorrectly assumed that the piping insulation was mineral wool insulation as specified in the design and, as a result, concluded that the insulation was capable of preventing excessive condensation of the AFW supply steam when the line was submerged during a flood. The actual piping configuration of calcium silicate, fiberglass, and cera-blanket insulation had not been evaluated. The discovery of the condition revealed that Prompt Operability Determination POD 201448584-38, and supporting Evaluation Report FAI/11-0655, which determined that the AFW pump was operable during a flood, were no longer valid.

On February 9, 2012, engineering reperformed the evaluation using the as-found piping configuration and concluded that, during a postulated PMP event, the turbine-driven AFW pump turbine could potentially trip on overspeed due to excessive condensation in the steam supply line, rendering the pump inoperable.

The licensee restored compliance by replacing the insulation on the AFW steam supply piping with mineral wool, as designed.

The inspectors concluded that operations personnel, using inaccurate information, inappropriately determined that the AFW system was operable, the condition was not reportable, and the compensatory measures could be removed. The inaccurate information was provided to the inspectors which caused the NRC to inappropriately agree with the licensees conclusions.

Analysis.

The inspectors concluded that the failure of the licensee to provide complete and accurate information related to the operability of the AFW system was a performance deficiency. The significance determination process is not suited to assess the significance of a violation of 10 CFR 50.9 because it affected the ability of the NRC to perform its regulatory oversight function and, as such, it was assessed using traditional enforcement.

This violation was determined to be a Severity Level IV violation based on NRC Enforcement Policy examples provided in Section 6.9. No crosscutting aspect was assigned because the performance deficiency was assessed using traditional enforcement.

Enforcement.

Title 10 CFR 50.9, Completeness and Accuracy of Information, requires, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on September 29, 2011, the licensee did not provide information that was complete and accurate in all material respects. Specifically, Evaluation Report FAI/11-0655, Evaluation of Potential Cooling of the SONGS Steam Line for the AFW Turbine, used inaccurate information to inappropriately determine that the turbine-driven AFW pump was operable, the condition was not reportable per the requirements of 10 CFR 50.73, and the compensatory measures implemented on May 5, 2011, could be removed. The compensatory measures were improperly removed on October 27, 2011. Because this finding is of very low safety significance and has been entered into the licensees corrective action program as Nuclear Notification NN 202280026, this violation is being treated as a noncited violation in accordance with Section 2.3.2 of the Enforcement Policy:

NCV 05000361;05000362/2012005-01, Failure to Provide Complete and Accurate Information Regarding Auxiliary Feedwater System Operability.

4OA5 Other Activities

(Closed) Unresolved Item 05000362/2010009-01, Adequacy of Model Inputs Used in Restoration of Concrete Containment

a. Inspection Scope

On May 3, 2011, technical assistance was requested by inspectors on an unresolved item documented in NRC Inspection Report 05000362/2010009. The inspectors requested assistance to address technical questions regarding whether San Onofre Nuclear Generation Station (SONGS) was in compliance with its Final Safety Analysis Report (FSAR) commitments and requirements. The request for technical assistance was documented in Task Interface Agreement (TIA) 2011-008, San Onofre Nuclear Generation Station Use of American Concrete Institute Reports for Evaluations Related to Steam Generator Replacement Containment Restoration, dated May 3, 2011.

The inspectors reviewed the final response evaluation and conclusions on the technical questions associated with models and methodology for calculations pertaining to finite element techniques. The TIA final response was provided by letter dated December 4, 2012 (Agency-wide Documents Access and Management System Accession Number ML12292A624)

b. Observations and Findings

Change in Method of Evaluation from SAP to ANSYS. SAP and ANSYS are considered general-purpose finite element analysis programs used to perform engineering evaluations of structures. The final TIA response reviewed the use of these models by the licensee and documented a finding associated with 10 CFR 50.59 (d)(1), which requires a licensee to obtain a license amendment prior to implementing a proposed change if the change would result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses, where departure from a method of evaluation is either:

(i) changing any of the elements of the method described in the FSAR (as updated) unless the results of the analysis are conservative or essentially the same; or

(ii) changing from a method described in the FSAR to another method unless that method has been approved by NRC for the intended application. With respect to this requirement, the inspectors determined that the licensees decision to use ANSYS in lieu of SAP for the local analysis of the temporary steam generator replacement construction opening was changing a method described in the FSAR to another method, and not changing only an element of the method described in the FSAR. That determination is based in part on the definition in NEI 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, which states, Definition: Methods of evaluation means the calculational framework used for evaluating behavior or response of the facility or structures, systems and components.

The NRC staff determined that both ANSYS and SAP meet this definition, both are described in the FSAR as being used in establishing the design basis of the containment, and using ANSYS in lieu of SAP constitutes changing from a method described in the FSAR to another method. As a result, the licenses written evaluation required by 10 CFR 50.59(d)(1) was insufficient in that it did not provide an adequate basis for the determination that the change does not require a license amendment because the basis for whether the change involves a departure of the method of evaluation failed to evaluate the use of ANSYS in lieu of SAP against 10 CFR 50.59a(2)(ii), Change from a method described in the FSAR to another method unless that method has been approved by NRC for the intended application.

The inspectors reviewed documentation to determine if ANSYS had been approved for the similar applications. This review included Section 3.9.1.2.2.2.3 of the licensees FSAR, which described ANSYS as in the public domain, and Section 3.9.1.2.21.11, which describes ANSYS as well known by practitioners of structural analysis to be 3-D capable and, additionally, capable of performing a static analysis of liner elastic 3-D structures utilizing the finite element method.

Therefore, the inspectors determined that for the change from SAP to ANSYS, because ANSYS had been approved by NRC for the intended application, 10 CFR 50.59 (c)(2)(ii)did not require the licensee to obtain a license amendment prior to implementing the change. Because this violation impacted the regulatory process, the inspectors assessed it in accordance with the NRC Enforcement Policy, as directed by MC 0612, Appendix B, Issue Screening. That policy says that the NRC Enforcement Manual contains specific processes and guidance for implementing this Policy. In the NRC Enforcement Manual, Section 2.10.D.6 states, in part, that minor violations include the failure to meet 10 CFR 50.59 requirements that involve a change to the FSAR description where there was no reasonable likelihood that the change would ever require NRC approval per 10 CFR 50.59. As described above, the use of ANSYS in lieu of SAP did not require a license amendment prior to implementing the change, so with respect to Section 2.10.D.6 of the NRC Enforcement Manual, there is no reasonable likelihood that the use of ANSYS in lieu of SAP would ever require NRC approval per 10 CFR 50.59. Therefore, in accordance with Section 2.10.D.6 of the NRC Enforcement Manual, the inspectors determined that the licensees failure to provide an adequate written evaluation for their determination that the use of ANSYS in lieu of SAP did not require a license amendment prior to implementing the change was a minor violation of 10 CFR 50.59(d)(1) and not subject to enforcement action in accordance with the NRCs Enforcement Policy. This condition was documented in the corrective action program as Nuclear Notification NN 202235435.

The inspectors determined that Unresolved Item 05000362/2010009-01, Adequacy of Model Inputs Used in Restoration of Concrete Containment, is closed.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On November 29, 2012, the inspectors presented inspection results on the unresolved item to Ryan Treadway, Manager, Nuclear Regulatory Affairs, and members of the licensees staff.

The licensee acknowledged the results as presented.

On January 8, 2013, the inspectors presented the inspection results to Mr. D. Bauder, Site Vice President and Station Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Adler, Manager, Maintenance/Systems Engineering

P. Anderson, Technical Specialist, System Engineering

D. Asay, Technical Specialist, System Engineering

H. Burkland, Nuclear Engineer, Systems Engineering

R. Corbett, Director, Performance Improvement

R. Davis, Director, Nuclear Training

J. Davis, Manager, Operations

M. Demarco, SDG&E

J. Demlow, Supervisor, Chemistry

D. Evans, Manager, Security

O. Flores, Director, Nuclear Oversight

G. Kline, Senior Director, Engineering and Technical Services

M. Lewis, Manager, Health Phusics

D. Lindbeck, Manager, Onsite Emergency Preparedness

J. Madigan, Director, Nuclear Safety Culture

A. Martinez, Manager, Performance Improvement

T. McCool, Plant Manager

M. Pawlaczyk, Technical Specialist, Nuclear Regulatory Affairs

R. Pettus, Nuclear Regulatory Affairs

T. Rak, Manager, Design Engineering-Electrical

M. Russell, Technician Specialist, Health Physics

B. Scholler, Director, Maintenance & Construction

T. Simmons, Manager, Operations

R. St. Onge, Director, Nuclear Regulatory Affairs

R. Treadway, Manager, Nuclear Regulatory Affairs

J. Tupik, Manager, Work Control

D. Vanderwoude, Supervisor, Design Engineering

D. Yarbrough, Director, Operations

J. Bashore, Consultant

NRC Personnel

N. Taylor, Senior Project Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

05000361/2012-001 LER AFW Pump Inoperable due to Postulated Flooding Event Results

05000362/2012-001 in Condition Prohibited by Technical Specifications (Section 4OA3)

Attachment

05000362/2010009-01 URI Adequacy of Model Inputs Used in Restoration of Concrete Containment (Section 4OA5)

Opened and Closed

05000361/2012005-01 NCV Failure to Provide Complete and Accurate Information Regarding

05000362/2012005-01 Auxiliary Feedwater System Operability (Section 4OA3)