ML043140405
| ML043140405 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/09/2004 |
| From: | Kennedy K NRC/RGN-IV/DRP/RPB-C |
| To: | Ray H Southern California Edison Co |
| References | |
| IR-04-004 | |
| Download: ML043140405 (29) | |
See also: IR 05000361/2004004
Text
November 9, 2004
Harold B. Ray, Executive Vice President
San Onofre, Units 2 and 3
Southern California Edison Co.
P.O. Box 128, Mail Stop D-3-F
San Clemente, CA 92674-0128
SUBJECT: SAN ONOFRE NUCLEAR GENERATING STATION - NRC INTEGRATED
INSPECTION REPORT 05000361/2004004; 050000362/2004004
Dear Mr. Ray:
On September 26, 2004, 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 report documents the inspection findings, which were discussed on July 1, July 30,
August 5, and September 24, 2004, with Mr. J. Wambold and other members of your staff.
The inspection examined activities conducted under your licenses as they relate to safety and
compliance with the Commission's rules and regulations and with the conditions of your
licenses. The inspectors reviewed selected procedures and records, observed activities, and
interviewed personnel.
Based on the results of this inspection, the NRC has identified one issue that was evaluated
under the risk significance determination process as having very low safety significance
(Green). The NRC has also determined that a violation was associated with this issue. The
violation is being treated as a noncited violation (NCV), consistent with Section VI.A of the
Enforcement Policy. The NCV is described in the subject inspection report. Additionally, two
licensee-identified violations, which were determined to be of very low safety significance, are
listed in Section 4OA7 of this report. If you contest the violation or significance of the NCV, 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, U.S. Nuclear
Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011;
the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC
20555-0001; and the NRC Resident Inspector at the San Onofre Nuclear Generating Station,
Units 2 and 3, facility.
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 made available electronically for public inspection
in the NRC Public Document Room or from the Publicly Available Records (PARS) component
Southern California Edison Company -2-
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).
Sincerely,
/RA/
K. M. Kennedy, Chief
Project Branch C
Division of Reactor Projects
Dockets: 50-361
50-362
Licenses: NPF-10
Enclosure:
NRC Inspection Report 05000361/2004004; 05000362/2004004
w/Attachment: Supplemental Information
cc w/enclosure:
Chairman, Board of Supervisors
County of San Diego
1600 Pacific Highway, Room 335
San Diego, CA 92101
Gary L. Nolff
Power Projects/Contracts Manager
Riverside Public Utilities
2911 Adams Street
Riverside, CA 92504
Eileen M. Teichert, Esq.
Supervising Deputy City Attorney
City of Riverside
3900 Main Street
Riverside, CA 92522
Joseph J. Wambold, Vice President
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Southern California Edison Company -3-
David Spath, Chief
Division of Drinking Water and
Environmental Management
California Department of Health Services
P.O. Box 942732
Sacramento, CA 94234-7320
Michael R. Olson
San Onofre Liaison
San Diego Gas & Electric Company
P.O. Box 1831
San Diego, CA 92112-4150
Ed Bailey, Chief
Radiologic Health Branch
State Department of Health Services
P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414
Mayor
City of San Clemente
100 Avenida Presidio
San Clemente, CA 92672
James D. Boyd, Commissioner
California Energy Commission
1516 Ninth Street (MS 34)
Sacramento, CA 95814
Douglas K. Porter, Esq.
Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, CA 91770
Dwight E. Nunn, Vice President
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Dr. Raymond Waldo
Southern California Edison Company
San Onofre Nuclear Generating Station
P. O. Box 128
San Clemente, CA 92674-0128
Southern California Edison Company -4-
A. Edward Scherer
Southern California Edison
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Chief, Technological Services Branch
FEMA Region IX
1111 Broadway, Suite 1200
Oakland, CA 94607-4052
Southern California Edison Company -5-
Electronic distribution by RIV:
Regional Administrator (BSM1)
DRP Director (ATH)
DRS Director (DDC)
DRS Deputy Director (GLS)
Senior Resident Inspector (CCO1)
Branch Chief, DRP/C (KMK)
Senior Project Engineer, DRP/C (WCW)
Team Leader, DRP/TSS (RVA)
RITS Coordinator (KEG)
Matt Mitchell, OEDO RIV Coordinator (MAM4)
SONGS Site Secretary (SFN1)
Acting Site Secretary (VLH)
Dale Thatcher (DFT)
W. A. Maier, RSLO (WAM)
ADAMS: /Yes G No Initials: __wcw____
/ Publicly Available G Non-Publicly Available G Sensitive / Non-Sensitive
R:\_SO23\2004\SO2004-04R-CCO.wpd
RIV:RI:DRP/C SRI:DRP/C C:DRS/PSB C:DRS/OB
MASitek CCOsterholtz MPShannon ATGody
E - WCWalker E - WCWalker LRicketson for /RA/
11/3/04 11/3/04 11/4/04 11/3/04
C:DRS/EB C:DRS/PEB C:DRP/C
JAClark LJSmith KMKennedy
LEEllershaw for /RA/ /RA/
11/3/04 11/3/04 11/9/04
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Dockets: 50-361, 50-362
Report: 05000361/2004004 and 5000362/2004004
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 27 through September 26, 2004
Inspectors: C. C. Osterholtz, Senior Resident Inspector, Project Branch C, DRP
M. A. Sitek, Resident Inspector, Project Branch C, DRP
D. R. Carter, Health Physicist, Plant Support Branch, DRS
P. J. Elkmann, Emergency Preparedness Inspector, Operations Br., DRS
R. P. Mullikin, Senior Reactor Inspector, Plant Engineering Branch, DRS
N. L. Salgado, Senior Resident Inspector, Project Branch D, DRP
Approved By: Kriss M. Kennedy, Chief
Project Branch C
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000361/2004004, 05000362/2004004; 06/27 - 09/26/04; San Onofre Nuclear Generating
Station, Units 2 & 3; Integrated Resident and Regional Report; Operability Evaluation.
This report covered a 3-month period of inspection by Resident and Regional office inspectors.
One Green noncited violation was identified. The significance of most findings is indicated by
their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance
Determination Process." Findings for which the significance determination process does not
apply may be Green or be assigned a severity level after NRC management's review. The
NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green. The inspectors identified a noncited violation of Technical
Specification 5.5.1.1 from a self-revealing finding because the licensee failed to
provide adequate instructions in a maintenance order for the replacement of a
power indicating lamp in a power supply associated with the Unit 2 Train A
emergency diesel generator. The implementation of the inadequate
maintenance order resulted in the unplanned inoperability of the Unit 2 Train A
emergency diesel generator for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
The finding was determined to be more than minor because it affected the
procedure quality attribute of the mitigating systems cornerstone. The finding
was determined to have very low safety significance (Green) because the
inadequate maintenance order instructions did not result in an actual loss of
safety function. In addition, the fuel transfer pumps were still capable of being
started locally through manual operator action (Section 1R15).
B. Licensee-Identified Violations
Violations of very low safety significance which were identified by the licensee have
been reviewed by the inspectors. Corrective actions taken or planned by the licensee
have been entered into the licensee's corrective action program. These violations and
the associated corrective actions are listed in Section 4OA7 of this report.
Enclosure
REPORT DETAILS
Summary of Plant Status
Unit 2 began the inspection period at approximately 100 percent reactor power and remained at
that power level throughout the inspection period.
Unit 3 began the inspection period at approximately 100 percent reactor power. On
September 10, 2004, Unit 3 was reduced to approximately 85 percent reactor power in order to
address minor intermittent saltwater inleakage into the feedwater system from the condenser.
The circulating water pump associated with the northwest condenser hotwell was taken out of
service and four condenser tubes were plugged. The inleakage stopped and Unit 3 was
returned to approximately 100 percent reactor power on September 12, 2004, where it
remained through the end of the inspection period.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection (71111.01)
a. Inspection Scope
The inspectors reviewed the design features and procedures for protecting Units 2
and 3 mitigating systems from the adverse effects of high winds and temperatures
(three inspection samples).
The inspectors reviewed Procedure S023-13-8, Severe Weather, Revision 3,
interviewed licensee personnel, and directly observed systems and plant conditions.
The inspectors reviewed licensee actions to minimize the occurrence and impact of
brush fires that are likely to occur during high temperatures and/or high winds. The
inspectors examined: (1) brush growth and clearance, (2) fire department equipment
and training, (3) fire department coordination with offsite firefighting organizations, and
(4) past history of brush fire impact on the facility. The inspectors also reviewed
Procedure S0123-XIII-4.10.7, Fire Department Offsite Response Procedure, Revision
3. In addition, the inspectors walked down areas around Units 2 and 3 to determine the
potential hazard associated with wind-generated missiles.
The inspectors also reviewed the following three systems to ensure that their safety
functions were adequately protected against high temperatures:
- Auxiliary Feedwater System
- Safety Injection System
Enclosure
-2-
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
a. Inspection Scope
1. Partial System Walkdowns. The inspectors performed three partial walkdowns during
this inspection period (three inspection samples). To evaluate the operability of the
selected train or system when the redundant train or system was inoperable or out of
service, the inspectors verified correct valve and power alignments by comparing
positions of valves, switches, and electrical power breakers to the procedures listed
below as well as applicable chapters of the Updated Final Safety Analysis Report:
- On July 6, the inspectors walked down the Unit 2 Train B EDG while the Train A
EDG was out of service for planned maintenance.
- On August 20, the inspectors walked down the Unit 2 Train A EDG while the
Train B EDG was out of service for planned maintenance.
- On September 1, the inspectors walked down the Unit 3 Train A component
cooling water system while the Train B component cooling water system was out
of service for planned maintenance.
b. Findings
No findings of significance were identified
1R05 Fire Protection (71111.05)
a. Inspection Scope
The inspectors performed routine fire inspection tours and reviewed relevant records for
the following six plant areas important to reactor safety (six inspection samples):
- Unit 3 Train A EDG
- Unit 3 Train B EDG
- Unit 2 B009 battery room
- Unit 2 B010 battery room
- Unit 2 saltwater cooling pump room
- Unit 3 Saltwater cooling pump room
Enclosure
-3-
The inspectors observed the material condition of plant fire protection equipment, the
control of transient combustibles, and the operational status of barriers. The inspectors
compared in-plant observations with the commitments in portions of the Updated Fire
Hazards Analysis Report.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures (71111.06)
a. Inspection Scope
The inspectors performed an annual visual inspection of the plant intake structure
(Units 2 and 3) to determine the operational status of seals, barriers, sumps, drains, and
alarms to identify the existence of any unanalyzed flooding hazards (one inspection
sample). The inspectors also reviewed Updated Safety Analysis Report Chapter 3.4,
Water Level (Flood) Design, Revision 13.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification (71111.11Q)
a. Inspection Scope
The inspectors reviewed licensed operator requalification training activities (one
inspection sample), including the licensed operators performance and the evaluators
critique. The inspectors compared performance in the simulator on August 26, 2004,
with performance observed in the control room during this inspection period.
The inspectors observed high-risk operator actions, operator activities associated with
the emergency plan, and reviewed previous lessons-learned items. These items were
evaluated to ensure that operator performance was consistent with protection of the
reactor core during postulated accidents.
b. Findings
No findings of significance were identified.
Enclosure
-4-
1R12 Maintenance Effectiveness (71111.12)
1. Routine Maintenance Effectiveness
a. Inspection Scope
The inspectors independently verified that the licensee appropriately handled safety
significant component performance associated with saltwater cooling check valves (one
inspection sample). The inspectors reviewed AR 040500132 and discussed the plan for
modifying the check valves with engineering and maintenance personnel.
b. Findings
No findings of significance were identified.
2. Periodic Evaluation Reviews
a. Inspection Scope
The inspectors reviewed the San Onofre Nuclear Generating Station report
documenting the performance of the last maintenance rule periodic effectiveness
evaluation to confirm that it was performed in accordance with 10 CFR 50.65(a)(3) (one
inspection sample). The licensees periodic evaluation covered the period from July 1,
2001, through June 30, 2003.
The inspectors reviewed the handling of risk significant structures, systems, and
components with degraded performance or degraded condition to assess the
effectiveness of the licensees evaluation and the resulting corrective actions.
Inspection Procedure 71111.12, Maintenance Effectiveness, requires 3-5 risk
significant examples. The inspectors reviewed five examples: 4 kv system, dc system,
component cooling water system, containment isolation system, and radiation
monitoring system. Additionally, the performance of nonrisk-significant functions were
monitored using plant level criteria.
The inspectors evaluated the use of performance history and industry experience to
adjust the preventive maintenance requirements to adjust (a)(1) goals and to adjust the
(a)(2) performance criteria. The inspectors assessed the licensees adjustment of the
scope of the maintenance rule, the licensees adjustment of the definition of
maintenance rule functional failures, the licensees adjustment of definitions of
available/unavailable hours and required hours, and the licensees review and
adjustment of condition-monitoring parameters and action levels.
The inspectors also reviewed the conclusions reached by licensee personnel with regard
to the balance of reliability and unavailability for specific maintenance rule functions.
This review was conducted by examining the licensees evaluation of all risk significant
functions that had exceeded performance criteria during the evaluation period.
Enclosure
-5-
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation (71111.13)
a. Inspection Scope
The inspectors verified the accuracy and completeness of risk assessment documents
and that the licensees maintenance risk assessment program was being appropriately
implemented. The inspectors also ensured that plant personnel were aware of the
appropriate licensee established risk categories for maintenance activities, according to
the risk assessment results and licensee program procedures.
The inspectors also reviewed selected emergent work items to ensure that overall plant
risk was being properly managed and that appropriate corrective actions were being
properly implemented.
The inspectors reviewed the effectiveness of risk assessment and risk management for
the following four activities (four inspection samples):
- Unit 3 Train A EDG 3G002 automatic voltage regulator series boost capacitor
failure (AR 040700701)
- Unit 3 Train B Component Cooling Water Heat Exchanger 3E002 tube leak
(AR 040900059)
- Unit 2 Train B Charging Pump 2P192 water in crankcase oil (AR 040900660)
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15)
1. Unit 2 Train A EDG 2G002 Loss of Fuel Oil Storage Tank Level Indication
a. Inspection Scope
The inspectors reviewed Unit 2 EDG 2G002 operability following the loss of the
automatic functions of the fuel oil transfer system during a maintenance activity (one
inspection sample).
Enclosure
-6-
b. Findings
Introduction. A Green, self-revealing, noncited violation of Technical Specification (TS)
5.5.1.1, was identified for the implementation of an inadequate maintenance order which
rendered EDG 2G002 inoperable for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Description. On August 3, 2004, a technician performed maintenance on the Train A
EDG 2G002 fuel storage tank level instrument power supply under maintenance
order (MO) 03081421000. The scope of the work in the MO required the technician to
replace the power supply power indicating lamp with a WAMCO B2A-R lamp. The
technician used a WAMCO B2A lamp instead, which did not include a dropping resistor
in the base of the lamp. As a result, a fuse in the fuel storage tank level instrument
power supply blew, causing the low-low level cutout for the fuel transfer pumps to
deenergize. The inability of the fuel transfer pumps to automatically start led operations
personnel to declare EDG 2G002 inoperable and to enter the action statements for
TS 3.8.1, AC Sources - Operating, in accordance with the applicable annunciator
response procedure. Maintenance personnel subsequently recognized that the
incorrect lamp was installed and returned the power supply to its original configuration,
which allowed operators to exit the TS action statements after approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
The licensee determined that the technician was confused by the instructions in the MO
and that the instructions in the MO were contradictory and inaccurate. Specifically, the
MO problem statement implies that the WAMCO B2A lamp is the correct part, while at
the same time instructing the technician to use a WAMCO B2A-R lamp. Furthermore, in
the planning phase of the MO, the licensee did not recognize the impact that the lamp
replacement activity could have on EDG operability.
Analysis. The failure of the licensee to provide clear instructions in the MO was
considered to be a performance deficiency. The finding was determined to be more
than minor because it affected the procedure quality attribute of the mitigating systems
cornerstone. Based on the results of the significance determination process (Phase 1
evaluation), the finding was determined to have very low safety significance (Green)
because the inadequate MO instructions did not result in an actual loss of safety
function. In addition, the fuel transfer pumps were still capable of being started locally
through manual operator action.
Enforcement. TS 5.5.1.1 states, in part, that written procedures shall be established,
implemented, and maintained covering the applicable procedures recommended in
Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33,
Section 9, Procedures for Performing Maintenance, specifies that maintenance that
can affect the performance of safety-related equipment should be properly preplanned
and performed in accordance with documented instructions appropriate to the
circumstances. Contrary to this criterion, on August 3, 2004, the licensee failed to
provide adequate instructions in an MO for the replacement of a power indicating lamp
in a power supply associated with the Unit 2 Train A EDG. This violation of the TSs is
being treated as a noncited violation (NCV 05000361/2004004-01, failure to provide
Enclosure
-7-
adequate instructions for EDG maintenance) consistent with Section VI.A of the
Enforcement Policy. This violation is in the licensees corrective action program as
AR 040800105.
2. Routine Operability Evaluation Reviews
a. Inspection Scope
The inspectors reviewed selected operability evaluations to evaluate technical adequacy
and to verify that operability was justified. The inspectors considered the impact on
compensatory measures for each condition being evaluated, and referenced the
Updated Final Safety Analysis Report and TSs. The inspectors also discussed the
evaluations with cognizant licensee personnel.
The inspectors reviewed four operability evaluations (four inspection samples) and
cause assessments documented in the following ARs to ensure the operability was
properly justified:
- AR 040801442, Unit 3 Component Cooling Water cross-train leakage
- AR 040501377, Control Room Tracer Gas Testing (Units 2 and 3)
- AR 040500047, Unit 2 High Pressure Safety Injection Valve HV-9332 degraded
position indication
- AR 021001266, Unit 3 main steam isolation valve operability with degraded
dump valve solenoids
b. Findings
No findings of significance were identified.
1R16 Operator Workarounds (71111.16)
a. Inspection Scope
The inspectors reviewed the following two operator workarounds (two inspection
samples) to determine if the functional capability of the system or human reliability in
responding to an initiating event was affected by the workaround. The inspectors
evaluated the effect that the operator workaround had on the operator's ability to
implement abnormal or emergency operating procedures.
- Verification of increase in amperage of Unit 3 electrical Bus 3B04 with
postaccident cleanup Unit 3ME370 in service with a degraded air flow chart
recorder
Enclosure
-8-
- Manual tripping of the Group 1 set of Unit 3 main transformer cooling fans
following a main transformer fault without the use of the automatic trip function of
Relay 49X-1
b. Findings
No findings of significance were identified.
1R19 Postmaintenance Testing (71111.19)
a. Inspection Scope
The inspectors observed and/or reviewed postmaintenance testing for the following
seven activities (seven inspection samples) to verify that the test procedures and
activities adequately demonstrated system operability:
- Unit 3 containment emergency suction line fill verification per Procedure SO23-5-
1.3, Plant Startup from Cold Shutdown to Hot Standby, Revision 25, performed
on February 9, 2003
- Unit 2 containment emergency suction line fill verification per Procedure SO23-3-
2.7.2, Filling the Containment Emergency Sump Suction Lines, Revision 11,
performed on March 2, 2004
- Unit 2 Inverter Power Supply Bus 2Y02 postmaintenance test per
Procedure SO23-6-17, Swapping Kirk Keyed Alternate Power Supply Breakers
When Both Vital Buses are Energized from the Inverters, Revision 10,
performed on July 21, 2004
- Unit 3 Inverter Power Supply Bus 3Y04 postmaintenance test per
Procedure SO23-6-17, Swapping Kirk Keyed Alternate Power Supply Breakers
When Both Vital Buses are Energized from the Inverters, Revision 10,
performed on July 21, 2004
- Unit 3 Pressurizer Surge Line Isolation Valve 3HV0513 postmaintenance test per
MO 04030211000, performed on August 4, 2004
- Unit 3 Train A Component Cooling Water Heat Exchanger 3E001
postmaintenance test per Procedure SO23-2-8.1, Draining and Returning to
Service CCW HX E001 Saltwater Side and SWC System Piping, Revision 2,
performed on August 12, 2004
- Unit 2 EDG 2G002 postmaintenance test per Procedure SO23-3-3.23, Diesel
Generator G003 Semi-annual Surveillance, Revision 23, performed on
August 20, 2004
Enclosure
-9-
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors observed and/or reviewed performance and documentation for the
following four surveillance tests (four inspection samples) to verify that the structures,
systems, and components were capable of performing their intended safety functions
and to assess their operational readiness:
- Unit 3 Train A EDG 3G002 24-month surveillance per Procedure SO23-3-3.23.1,
Diesel Generator Refueling Interval Tests, Revision 20, performed July 14,
2004
- Unit 3 turbine-driven Auxiliary Feedwater Pump 3P140 quarterly surveillance per
Procedure SO23-3-3.60.6, Auxiliary Feedwater Pump and Valve Testing,
Revision 10, performed on July 21, 2004
- Unit 2 Battery B010 12-month surveillance per Procedure SO123-I-2.6, Battery
Performance Test and Rapid Recharge, Revision 7, performed on September 6,
2004
- Unit 2 Battery B009 12-month surveillance per Procedure SO123-I-2.6, Battery
Performance Test and Rapid Recharge, Revision 7, performed on
September 20, 2004
b. Findings
No findings of significance were identified.
1R23 Temporary Plant Modifications (71111.23)
a. Inspection Scope
The inspectors reviewed the following three temporary plant modifications (three
inspection samples) to verify that the safety functions of safety systems were not
affected:
- Temporary Engineering Change Package 030301058-7, Change Input to
3PV0100B Positioner (Unit 3)
- Temporary Engineering Change Package 040701007-1, Conduct Performance
Test on Battery 2B009 By Utilizing Battery B00X (Unit 2)
Enclosure
-10-
- Temporary Engineering Change Package 040701007-2, Conduct Performance
Test on Battery 2B010 By Utilizing Battery B00X (Unit 2)
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert Notification System Testing (71114.02)
a. Inspection Scope
The inspector discussed with licensee staff the status of offsite siren systems to
determine the adequacy of the licensees methods for testing the alert and notification
system in accordance with 10 CFR Part 50, Appendix E. The licensees alert and
notification system testing program was compared with criteria in NUREG-0654,
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants, Revision 1, with Federal Emergency
Management Agency Report REP-10, Guide for the Evaluation of Alert and Notification
Systems for Nuclear Power Plants, and the licensees current Federal Emergency
Management Agency approved alert and notification system design report. The
inspector also reviewed Procedures SO123-VIII-0.301, Emergency
Telecommunications Testing, Revision 10, and SO123-VIII-0.302, Onsite Emergency
Siren System Test, Revision 3.
b. Findings
No findings of significance were identified.
1EP3 Emergency Response Organization Augmentation Testing (71114.03)
a. Inspection Scope
The inspector discussed with licensee staff the status and configuration of primary and
backup systems for staffing licensee emergency response facilities in accordance with
the licensee emergency plan and the requirements of 10 CFR Part 50 Appendix E. The
licensees emergency recall system was compared with criteria in NUREG-0654,
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants, Revision 1. The inspector also
compared the recall system to the requirements of Procedures SO123-VIII-30.7,
Emergency Notifications, Revision 4, and SO123-VIII-0.201, Emergency Plan
Equipment Surveillance Program, Revision 13. The inspector also reviewed the results
of 19 emergency response organization pager and recall tests conducted February 2003
through March 2004.
Enclosure
-11-
b. Findings
No findings of significance were identified.
1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies (71114.05)
a. Inspection Scope
The inspector reviewed documents related to the licensees corrective action program,
as described in the attachment, to determine the licensees ability to identify and correct
problems in accordance with 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E.
b. Findings
No findings of significance were identified.
1EP6 Drill Evaluation (71114.06)
a. Inspection Scope
The inspectors observed one (one inspection sample) emergency preparedness drill to
evaluate the drill conduct and the adequacy of the licensees performance critique. The
inspectors observed one site-wide drill from the simulator, Technical Support Center,
and Emergency Operating Facility on June 30, 2004.
b. Findings
No findings of significance were identified.
2. RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS2 ALARA (as Low as is Reasonably Achievable) Planning and Controls (71121.02)
a. Inspection Scope
The inspector assessed licensee performance with respect to maintaining individual and
collective radiation exposures ALARA. The inspector used the requirements in 10 CFR
Part 20 and the licensees procedures required by TSs as criteria for determining
compliance. The inspector interviewed licensee personnel and reviewed:
- Current 3-year rolling average collective exposure
Enclosure
-12-
- Five outage maintenance work activities scheduled during the inspection period
and associated work activity exposure estimates which were likely to result in the
highest personnel collective exposures
- Site-specific trends in collective exposures, plant historical data, and source-term
measurements
- Site-specific ALARA procedures
- ALARA work activity evaluations, exposure estimates, and exposure mitigation
requirements
- Interfaces between operations, radiation protection, and maintenance planning
- Integration of ALARA requirements into work procedure and radiation exposure
permit documents
- Shielding requests and dose/benefit analyses
- Postjob (work activity) reviews
- Method for adjusting exposure estimates, or replanning work, when unexpected
changes in scope or emergent work were encountered
- Exposures of individuals from selected work groups
- Radiation worker and radiation protection technician performance during work
activities in radiation areas or high radiation areas
- Declared pregnant workers during the current assessment period, monitoring
controls, and the exposure results
- Corrective action documents related to the ALARA program and followup
activities, such as initial problem identification, characterization, tracking, and
resolution
The inspector completed 8 of the required 15 samples and 6 of the optional samples.
b. Findings
No findings of significance were identified.
Enclosure
-13-
4. OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
a. Inspection Scope
The inspectors sampled licensee submittals for the five performance indicators listed
below for the period October 1, 2003, through June 30, 2004, for Units 2 and 3. The
definitions and guidance of Nuclear Energy Institute 99-02, Regulatory Assessment
Indicator Guideline, Revision 2, were used to verify the licensees basis for reporting
each data element in order to verify the accuracy of performance indicator data reported
during the assessment period. Licensee performance indicator data were also reviewed
against the requirements of Procedures SO23-NI-1, NRC Performance Indicator
Program, Revision 3, and SO23-XV-24, Quarterly NRC Performance Indicator
Process, Revision 2.
Reactor Safety Cornerstone
- Drill and Exercise Performance
- Emergency Response Organization Participation
- Alert and Notification System Reliability
- Shutdown Cooling Unavailability (MS3)
- Auxiliary Feedwater Unavailability (MS4)
The inspectors reviewed 100 percent of drill and exercise scenarios and licensed
operator simulator training sessions, notification forms, and attendance and critique
records associated with training sessions, drills, and exercises conducted during the
verification period. The inspectors reviewed emergency responder drill participation
records and rosters. The inspectors reviewed alert and notification system testing
procedures, maintenance records, and a 100 percent sample of siren test records. The
inspector also interviewed licensee personnel responsible for collecting and evaluating
performance indicator data.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems (71152)
1. Maintenance Rule Review
a. Inspection Scope
The inspectors evaluated the use of the corrective action system within the
maintenance rule program for issues associated with risk significant systems. The
review was accomplished by the examination of a sample of corrective action
Enclosure
-14-
documents, maintenance work items, and other documents listed in the attachment.
The purpose of the review was to establish that the corrective action program was
entered at the appropriate threshold for the purpose of:
- Implementation of the corrective action process when a performance criterion
was exceeded
- Correction of performance-related issues or conditions identified during the
periodic evaluation
- Correction of generic issues or conditions identified during programmatic
assessments, audits, or surveillances.
The purpose of the review was to determine that the identification of problems and
implementation of corrective actions were acceptable.
b. Findings
No findings of significance were identified.
2. ALARA Review
a. Inspection Scope
Section 2OS2 evaluated the effectiveness of the licensee's problem identification and
resolution processes regarding exposure tracking, higher than planned exposure levels,
and radiation worker practices. The inspectors reviewed the corrective action documents
listed in the attachment against the licensees problem identification and resolution
program requirements.
b. Findings
No findings of significance were identified.
3. Emergency Planning Review
a. Inspection Scope
The inspector selected 24 ARs (corrective action program inputs) for detailed review
based on their linkage with event classification, notification of offsite authorities, and
processes for providing protective action recommendations. The reports were reviewed
to ensure that the full extent of the issues were identified, an appropriate evaluation was
performed, and appropriate corrective actions were specified and prioritized. The
inspector evaluated the ARs against the requirements of Procedures SO123-XV-50,
Enclosure
-15-
Corrective Action Process, Revision 4, SO123-XX-1, Action Request/Maintenance
Order Initiation Process, Revision 15-2, and SO123-XV-50.39, Cause Evaluation
Standards, Methods, and Instructions, Revision 4-1.
b. Findings
No findings of significance were identified.
4. Annual Sample Review
a. Inspection Scope
The inspectors selected AR 040900011 for a detailed review. This AR was written in
response to a Unit 3 Loop 1 reactor coolant hot leg instrument failing to stay in
calibration.
b. Findings and Observations
No findings of significance were identified. However, the inspectors noted that
AR 040900011 had been closed without any corrective actions identified or documented.
AR 040900011 indicated that the Unit 3 loop one reactor coolant hot leg instrument failed
to stay in calibration after two attempts. The AR had been closed with only the words
This was determined to be a non problem. After interviewing several licensee
personnel, the inspectors discovered that the reason the hot leg instrument was not
staying in calibration was because a test technician incorrectly attached a test decade
box to the instrument during calibration. The licensee discovered and corrected the
problem, but did not consider any corrective actions to prevent recurrence. Licensee
management indicated that this did not meet expectations and indicated that the AR
would be reopened to reference the MO that described the problem and that Lessons
Learned training would be provided to the maintenance staff on the issue to help prevent
recurrence. The inspectors considered the licensees followup actions appropriate.
5. Quarterly Review of Corrective Action Documents
a. Inspection Scope
The inspectors reviewed a selection of ARs written during this period to determine if: the
licensee was entering conditions adverse to quality into the corrective action program at
an appropriate threshold; the ARs were appropriately categorized and dispositioned in
accordance with the licensee's procedures; and, in the case of significant conditions
adverse to quality, the licensee's root cause determination and extent of condition
evaluation were accurate and of sufficient depth to prevent recurrence of the condition.
b. Findings
No findings of significance were identified.
Enclosure
-16-
4OA3 Event Followup (71153)
1. (Closed) Licensee Event Report (LER) 05000361/2004-001-00: Personnel Error Results
in TS Violation During Movement of Irradiated Fuel
On March 7, 2004, the licensee identified that TS 3.7.14, Fuel Handling Building Post-
Accident Cleanup Filter System [PACU], was violated during the movement of irradiated
fuel. The Train B PACU was inoperable at the time of the fuel movement and the Train A
PACU was operating in the parallel mode as opposed to the isolate mode that was
required by TS 3.7.14. Fuel movement occurred for approximately 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> before the
condition was recognized. Fuel movement was immediately suspended and the Train A
PACU was placed in the isolate mode. The cause of the event was attributed to
operations personnel failing to review the procedure that established the requirements for
the movement of irradiated fuel. The procedure contained steps that would have directed
the operators to place the Train A PACU in the isolate mode of operation. The
inspectors reviewed the LER and no new findings were identified. The inspectors
considered this issue to be minor because:
- The fuel handling accident analysis does not credit the PACU operation for dose
mitigation.
- One train of PACU was operating to mitigate a fuel handling accident.
- One FHIS channel was operable and able to isolate the FHB if a fuel handling
accident occurred.
- This event was not caused by nor did it result in a safety system functional
failure (SSFF). This event did not impact the ability to shut down the unit or mitigate
the consequences of an accident.
This finding constitutes a violation of minor significance that is not subject to enforcement
action in accordance with Section IV of the NRCs Enforcement Policy. The licensee also
documented the issue in AR 040300624.
2. (Closed) LER 05000361;362/2004-003-00: Momentary Loss of Operability of the Offsite
Power Grid due to 230 kV Transmission Line Fault in Arizona
On June 14, 2004, offsite power frequency dropped below the TS minimum of 59.7 Hz
for approximately 2 minutes due to a grid disturbance that occurred in Arizona. The
lowest frequency recorded during the dip in frequency was 59.5 Hz. The inspectors
considered operator response to the event appropriate, and the momentary dip in
frequency did not disturb plant operation. This LER is closed.
Enclosure
-17-
4OA5 Other
1. Temporary Instruction (TI) 2515/154, Spent Fuel Material Control and Accounting at
Nuclear Power Plants
a. Inspection Scope
The inspectors completed TI 2515/154, Spent Fuel Material Control and Accounting at
Nuclear Power Plants.
b. Findings
No findings of significance were identified.
2. Third-Party Reviews
The inspectors reviewed a third-party assessment dated July 15, 2004. The biennial
assessment was performed from June 7-18, 2004. The inspectors noted that the
assessment was consistent with performance observed by the NRC staff.
4OA6 Meetings, Including Exit
On July 1, July 30, August 5, and September 24, 2004, the Resident and Regional office
inspectors presented the inspection results to Mr. J. Wambold, Mr. D. Nunn, and others
who acknowledged the findings. The inspectors subsequently asked the licensee
whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identified.
4OA7 Licensee-Identified Violations
The following violations of very low significance (Green) were identified by the licensee
and are violations of NRC requirements which meet the criteria of Section VI of the
NRC Enforcement Policy, NUREG-1600, for being dispositioned as noncited
violations (NCV).
- 10 CFR 50.54(q) requires, in part, that a licensee follow and maintain in effect
emergency plans which meet the standards in §50.47(b) and the requirements in
Appendix E. 10 CFR Part 50, Appendix E, IV.A.2(b), requires that the licensees
emergency plan provide a detailed discussion of plant staff emergency assignments
and the duties of individuals assigned to the licensee's emergency organization.
Contrary to this, the licensees emergency plan did not describe the duties and
responsibilities of some emergency response organization positions. Specifically, the
duties and responsibilities of 5 minimum staff positions and 51 additional responders
were not described in the licensees emergency plan. This was identified in the
Enclosure
-18-
licensees corrective action program in ARs 031200669-18 and 031200669-19. This
finding is of very low safety significance because it did not represent functional
failures of planning standards 10 CFR 50.47(b)(1) or 50.47(b)(2).
- 10 CFR 50.47(b)(14) requires that deficiencies identified as a result of exercises or
drills are corrected. 10 CFR 50.54(q) requires, in part, that the licensee follow and
maintain in effect emergency plans which meet the standards in §50.47(b) and the
requirements in Appendix E. 10 CFR Part 50, Appendix E, IV.F.2(g), requires that all
exercises and drills provide for formal critiques and that any identified weaknesses or
deficiencies be corrected. Contrary to this, the licensee did not enter all identified
weaknesses and deficiencies into its corrective action program. This was identified in
the licensees corrective action program as Apparent Cause Evaluation 040600717.
This finding is of very low safety significance because it did not represent a functional
failure of planning standard 10 CFR 50.47(b)(14).
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
R. Allen, Supervisor, Reliability Engineering
C. Anderson, Manager, Site Emergency Preparedness
D. Axline, Licensing Engineer, Nuclear Regulatory Affairs
D. Brieg, Manager, Maintenance Engineering
G. Cook, Supervisor, Compliance
M. Cooper, Manager, Plant Operations
B. Culverhouse, Supervisor, Offsite Emergency Planning
M. Goettel, Manager, Business Planning and Financial Services
M. Love, Manager, Maintenance
J. Madigan, Manager, Health Physics
C. McAndrews, Manager, Nuclear Oversight and Assessment
M. McBrearty, Engineer, Nuclear Regulatory Assurance
D. Nunn, Vice President, Engineering and Technical Services
N. Quigley, Manager, Mechanical/Nuclear Maintenance Engineering
J. Ramsdell, Maintenance Rule Coordinator
D. Richards, Supervisor, Onsite Emergency Planning
A. Scherer, Manager, Nuclear Regulatory Affairs
M. Short, Manager, Systems Engineering
T. Vogt, Manager, Operations
R. Waldo, Station Manager
J. Wambold, Vice President, Nuclear Generation
C. Williams, Supervisor, Compliance
T. Yackle, Manager, Design Engineering
NRC Personnel
Christian Araguas, Nuclear Safety Professional Development Program Participant
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000361/2004004-01 NCV Failure to provide adequate instructions for EDG
maintenance (Section 1R15)
Closed
05000361/2004-001-00 LER Personnel Error Results in Technical Specification
Violation During Movement of Irradiated Fuel
A-1 Enclosure
05000361;362/2004-003-00 LER Momentary Loss of Operability of the Offsite Power
Grid due to 230 kV Transmission Line Fault in
Discussed
None
LIST OF DOCUMENTS REVIEWED
In addition to the documents listed in the inspection report, the following documents were
selected and reviewed by the inspectors to accomplish the objectives and scope of the
inspection and to support any findings:
Section 1R04: Equipment Alignments
Procedure SO23-2-12.1, Component Cooling Water System Alignments, Revision 6
Procedure SO23-2-17, Component Cooling Water System Operation, Revision 18
Operations Division Manual 5, Operator Rounds, Revision 0
Procedure SO23-3-3.23, Diesel Generator Monthly and Semi-annual Testing, Revision 23
Piping and Instrumentation Diagram 40127ASO3, Component Cooling Water System No.
1203, Revision 27
Section 1R12: Maintenance Implementation
Action Requests
010301123, 020101538, 020800755, 021100192, 021201039, 030202033, 030401327,
030801357, 031101252, 031101253, and 040101394
Maintenance Rule Function Reports
125/250V DC
4160V AC Power
Component Cooling Water
Containment Isolation
Radiation Monitoring - Area, Process, and Effluent
Procedures
SO123-CA-1, Corrective Action Program, Revision 3
SO123-XV-5.3, Maintenance Rule Program, Revision 6
SO123-XV-50, Corrective Action Process, Revision 4
A-2 Enclosure
Miscellaneous Documents
Independent Assessment of Maintenance Rule Implementation, performed April 19-30, 2004
Maintenance Rule Evaluation (MRE) Guideline, Revision 5
Maintenance Rule Expert Panel Meeting Minutes from March 21, 2002, through May 20, 2004
SONGS Maintenance Rule Program (a)(3) Periodic Assessment (3rd Quarter 2001 through 2nd
Quarter 2003), dated October 31, 2003
SONGS System Health Reports (Quarter 2004-1) for DC Power Systems, 4 KV System,
Containment Leak Rate Testing Program, and Component Cooling System
Section 2OS2: ALARA Planning and Controls (71121.02)
Corrective Action Documents and Requests
030201607, 031001084, 030901392, 040100520, 04011521, 040101248, 040101448,
040101751, 040201832, 040500617, 040300392, 040300629, 04021480, 040300629,
040401695, 040401811, 040500671, and 040501354
Audits and Surveillances
Division Self-Assessment Report for the Fourth Quarter 2003
Unit 2 Cycle 13 ALARA In-Progress Reviews
1EP2 Alert Notification System Testing
Procedures:
SO123-XVIII-10, Siren - Community Alert Siren System - System Description and Operational
Guide, Revision 5
SO123-XVIII-10.1, Siren - Community Alert Siren System - Biweekly Silent Test, Revision 4-2
SO123-XVIII-10.3, Siren - Community Alert Siren System - Quarterly Growl Test, Revision 5-3
SO123-XVIII-10.4, Siren - Community Alert Siren System Response to a Report of an
Inadvertent Siren Activation, Revision 3
SO123-XVIII-10.5, Siren - Community Alert Siren System Annual Activation Test Procedures,
Revision 4-1
Section 1EP5: Correction of Emergency Preparedness Weaknesses and Deficiencies
Audit SCES-013-03, Emergency Preparedness, November 27, 2001, through November 26,
2003
Surveillance SOS-064-02, ERO Assignments, October 8, 2002
Surveillance SOS-073-02, Emergency Planning Drills, September 25, 2002
Surveillance SOS-074-62, EOF Emergency Facility Systems, November 29, 2002
Surveillance SOS-077-01, Emergency Plan and ODCM Controls, July 24, 2001
SEP Division Quarterly Self Assessments (8) for the period Second Quarter 2002 through First
Quarter 2004
EP NRC Readiness Review, AR 040600717-10
EP Directed Self Assessment, December 2003 through February 2004
Corrective Action Reports:
021000183 030102372 030700521 030900659 031001265
021000230 030400904 030800139 030901063 040400027
021100577 030501440 030801075 030901063 040400160
021200220 030600920 030900463 031001051 040500381
030100232
Drill Reports:
2003 Environmental Monitoring Drill Critique Report
Critique Report 0203-0205
Critique Report 0206
Critique Report 0302-0305, Revision 1
Critique Report 0306
Critique Report 0307
Critique Report 0312
Procedures:
SO123-CA-1, Corrective Action Program, Revision 3-1
SO123-NP-1, Offsite Emergency Planning Responsibilities and Offsite Interfaces,
Revision 5-3
SO123-XII-18.1, Audit Program, Revisions 8 and 8-2
SO123-SA-1, Self Assessment Program, Revision 2
SO123-VIII-1, Recognition and Classification of Emergencies, Revision 21
SO123-VIII-10.3, Protective Action Recommendations, Revision 8
SO123-VIII-30.7, Emergency Notifications, Revision 4
A-4 Enclosure
SO123-VIII-0.100, Maintenance and Control of Emergency Planning Documents, Revision 7
SO123-VIII-0.200, Emergency Plan Drills and Exercises, Revision 8
LIST OF ACRONYMS
ALARA as low as is reasonably achievable
AR Action Request
CFR Code of Federal Regulations
EDG emergency diesel generator
FEMA Federal Emergency Management Agency
LER licensee event report
MO maintenance order
NCV noncited violation
PACU postaccident cleanup filter system
TI temporary instruction
TS Technical Specification
A-5 Enclosure