ML070460445
| ML070460445 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/15/2007 |
| From: | Chamberlain D Division of Reactor Safety IV |
| To: | Rosenblum R Southern California Edison Co |
| References | |
| IR-06-010 | |
| Download: ML070460445 (10) | |
See also: IR 05000361/2006010
Text
February 15, 2007
Richard M. Rosenblum
Senior Vice President and
Chief Nuclear Officer
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
SUBJECT: SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 - NRC
INSPECTION REPORT 05000361/2006010; 05000362/2006010
Dear Mr. Rosenblum:
On August 18, 2006, the US Nuclear Regulatory Commission (NRC) completed an inspection
at your San Onofre Nuclear Generating Station, Units 2 and 3. The enclosed inspection report
documents the inspection results, which were discussed on February 15, 2007, with Mr. Rauch
and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license
associated with your plant-referenced simulator. Specifically, this inspection focused on
addressing an unresolved item (URI 05000361;362/2005302-02) related to the use of the plant
simulator for the administration of both the operating test and experience requirements. The
inspectors reviewed selected procedures and records and observed simulator testing.
Despite some analysis and documentation issues associated with Cycle 13 simulator testing,
the inspectors agreed with your determination that the San Onofre Nuclear Generating Station
simulator models for Cycle 13 had adequate fidelity for use in the administration of both the
operating test and experience requirements (control manipulation credits) and met the
requirements contained in 10 CFR 55.46(c)(3).
Southern California Edison Company
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In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRC's
document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Dwight D. Chamberlain, Director
Division of Reactor Safety
Dockets: 50-361; 50-362
Enclosure:
Inspection Report 05000361/2006010; 05000362/2006010
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
Assistant Director-Resources
City of Riverside
3900 Main Street
Riverside, CA 92522
Mark L. Parsons
Deputy City Attorney
City of Riverside
3900 Main Street
Riverside, CA 92522
Ray W. Waldo
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
8315 Century Park Ct. CP21G
San Diego, CA 92123-1548
Director, Radiological 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
James T. Reilly
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Daniel P. Breig
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Southern California Edison Company
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A. Edward Scherer
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Brian Katz
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Southern California Edison Company
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Electronic distribution by RIV:
Regional Administrator (BSM1)
DRP Director (ATH)
DRS Director (DDC)
DRS Deputy Director (RJC1)
Senior Resident Inspector (CCO1)
Branch Chief, DRP/D (TWP)
Senior Project Engineer, DRP/D (GEW)
Team Leader, DRP/TSS (RLN1)
RITS Coordinator (KEG)
V. Dricks, PAO (VLD)
D. Cullison, OEDO RIV Coordinator (DGC)
ROPreports
Site Secretary (vacant)
SUNSI Review Completed: Y______ADAMS: / Yes
G No Initials: _ATG__
/ Publicly Available G Non-Publicly Available G Sensitive
/ Non-Sensitive
OE:OB
OE:OB/RI
OE:IOLB/NRR
C:PBD
C:OB
D:DRS
KDClayton/lmb
PPresby
LVick
TPruett
AGody
DDChamberlain
/RA/
/RA/
Non-concur*
/RA/
/RA/
/RA/
8/18/06
8/19/06
10/19/2006
9/1/06
2/15/07
2/15/07
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
Enclosure
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ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Dockets:
50-361; 50-362
Licenses:
Report No.:
05000361/2006010; 05000362/2006010
Licensee:
Southern California Edison Co.
Facility:
San Onofre Nuclear Generating Station, Units 2 and 3
Location:
5000 S. Pacific Coast Hwy.
San Clemente, California
Dates:
Onsite inspection was March 13 - 17, 2006
In office inspection was March 6 through August 18, 2006
Inspectors:
K. D. Clayton, Operations Engineer, Operations Branch, Region IV
P. Presby, Operations Engineer, Operations Branch, Region I
Additional Review
By:
L. Vick, Operations Engineer, Initial Operator Licensing Branch
Office of Nuclear Reactor Regulation
Approved By:
Anthony T. Gody, Chief
Operations Branch
Division of Reactor Safety
Enclosure
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SUMMARY OF FINDINGS
IR 05000361/2006010; 05000362/2006010; March 13 - August 18, 2006; San Onofre Nuclear
Generating Station, Units 2 and 3: Biennial Licensed Operator Requalification (Simulator
Specific) Inspection (IP 71111.11B).
The report covered an 23-week period of onsite and offsite inspection by two operations
engineers. The NRC's program for overseeing the safe operation of commercial nuclear power
reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated
July 2000.
NRC-Identified and Self Revealing Findings
No findings of significance were identified.
Enclosure
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REPORT DETAILS
1
REACTOR SAFETY
40A5
OTHER
1.
(Closed) Unresolved Item (URI) 05000361;362/2005302-02, Adequacy of Plant-
Referenced Simulator to Conform with Simulator Requirements for Reactivity and
Control Manipulation Credits.
a.
Inspection Scope
Purpose
This inspection addressed an unresolved item documented in NRC Examination
Report 05000361;362/2005302 dated January 25, 2006. Specifically, the inspectors
assessed the adequacy of the San Onofre Nuclear Generating Station simulator facility
for use in reactivity/control manipulation credits on an initial operator license application
NRC Form 398, "Personal Qualification Statement-Licensee," as prescribed in
10 CFR 55.46, "Simulation facilities." The inspection was conducted through a review of
the licensees implementation of a preselected number of simulator scenarios and other
performance-based tests on the simulator and an in-office review of a sample of the
documentation for control manipulations, unit performance testing, and transient testing.
Background
While conducting onsite preparations for an initial licensing examination the week of
October 3, 2005, the inspectors reviewed data provided on NRC Form 398, "Personal
Qualification Statement - Licensee," for selected operator license candidates as
required by NUREG-1021, "Operator License Examination Standards for Power
Reactors," Revision 9. During the review, the inspectors noted that five operator license
candidates used the simulator extensively for meeting the significant control
manipulation requirements in 10 CFR 55.31(a)(5). Of the 25 reactivity credits required
for these five operators, 22 credits were taken on the simulator instead of the actual
plant. Use of the simulator for control manipulations is permitted, provided the
licensees simulator meets the requirements of 10 CFR 55.46(c)(3). Accordingly, the
inspectors expanded the pre-examination review to verify that the simulator met the
requirements of 10 CFR 55.46(c)(3). This review focused on the licensees
implementation of simulator testing in accordance with ANSI/ANS-3.5-1998, "Nuclear
Power Plant Simulators for Use in Operator Training and Examination." Specifically, the
inspectors reviewed 100 percent of the 2005 simulator testing records, which included
all transient and unit performance tests. The review identified one green finding
associated with the adequacy of simulator transient test documentation, which was
documented in NRC Examination Report 05000361;362/2005302. In addition to the
green finding, the inspectors identified an unresolved item (URI 05000361;362/2005302-
02) associated with adequacy of documentation of the scenarios associated with the
control manipulations. Specifically, the inspectors identified that the licensee had
retained a single-page sign-off sheet and a copy of the actual procedure used by the
operator candidates as the documentation required by 10 CFR 55.46(d)(1) for their
Enclosure
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scenario-based tests. Some of these scenario-based tests were used to validate the
actual control manipulation scenarios used by the aforementioned operator candidates.
This method of documenting scenario-based tests had been observed at other facilities
in the past and was the subject of considerable industry effort to improve documentation
of scenario-based tests at the time of the inspectors review. To verify that the simulator
had no significant fidelity issues under conditions similar to the aforementioned control
manipulations, the inspectors reviewed additional documentation which allowed a limited
assessment of simulator fidelity under conditions similar to those used for the control
manipulations. Specifically, the limited assessment conducted by the inspectors
included a comparison of simulator performance to the reference plant data collected
during startups. Despite the identified documentation issues, the inspectors found that
the simulator demonstrated adequate fidelity. Because no actual simulator fidelity
issues were identified during the initial review that affected the planned examination, the
initial license examination was conducted using the plant-referenced simulator. During
the examination, the applicants who demonstrated that they could safely operate the
facility and passed the examination, were issued licenses.
Followup Inspection
In order to address the unresolved item associated with documentation issues, the
inspectors conducted an onsite inspection in March 2006. While onsite, the inspectors
re-reviewed the raw data from the simulator and the reference plant for Cycle 13 and
conducted an independent analysis. While conducting this review, the inspectors
discussed the need for the licensees training staff to modify their data collection
methods to avoid the corruption they experienced in their original graphs, which was
responsible for creating confusion in understanding the validity of their testing. In
addition, the inspectors reviewed the fidelity of the simulator during low power physics
testing for both Cycles 13 and 14.
The inspectors observed the licensee operate the simulator during selected control
manipulations. The randomly selected scenarios were:
Scenario 1: 3 to 18 percent power increase
Scenario 2: 80 to 92 percent power increase
The inspectors controlled Scenario 1 by using actual plant data provided by the licensee
in order to match the time for the control rod pulls and boron dilutions. However, the
plant data used in the test was not correct and the test had to be rerun the following
week. Scenario 2 also could not be performed during the inspection week, because the
simulator had just undergone a major modeling upgrade and the corresponding initial
condition set for the simulator had not been created prior to the onsite portion of the
inspection. These tests were ran the following week by the licensee and the results
were submitted to the inspectors with the licensees analyses and conclusions. The
inspectors performed independent analyses to verify the results and confirm the
licensees conclusions.
Enclosure
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b.
Findings
Following the re-review of Cycle 13 data, the inspectors found that the simulator
demonstrated adequate fidelity when compared to the reference plant for Cycle 13. The
review of low power physics testing identified some differences between the simulator
and the reference plant, however, the inspectors found that the identified differences
between the simulator and the reference plant were transparent to the operators, would
not affect training or testing, and were minor. The inspectors agreed with the licensee's
conclusions that no significant fidelity issues existed in the data sets sampled for
Cycle 14.
Overall, the inspectors found that the San Onofre Nuclear Generating Station simulator
model fidelity was acceptable for use in the administration of both the operating test and
experience requirements in 10 CFR 55.31(a)(5) as described in 10 CFR 55.46(c)(3).
The inspectors agreed with the licensees determination that simulator fidelity was
adequate, and that significant control manipulations could be completed without
procedural exceptions, simulator performance exceptions, or deviations from the
approved training scenario. In addition, the inspectors agreed with the licensees
conclusion that the San Onofre Nuclear Generating Station plant-referenced simulator
utilized thermal-hydraulic models that adequately replicated the most recent core load.
No findings of significance were identified and the unresolved item was closed.
4OA6 Meetings, Including Exit
On March 17, 2006, the inspectors briefed Mr. K. Rauch and other members of his staff
on the results of the onsite portion of the licensed operator requalification simulator
inspection. A final telephonic exit was held with Mr. K. Rauch on February 15, 2007.
The licensee acknowledged the conclusions presented in both the briefing and the final
exit.
The inspectors confirmed that proprietary information was not provided or examined
during this inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Attachment
A-1
KEY POINTS OF CONTACT
Licensee Personnel
K. Rauch, Operations Training Manager
A. Hagemeyer, Operations Training Supervisor
J. Holt, Nuclear Regulatory Affairs
LIST OF ITEM CLOSED AND DISCUSSED
Closed
5000361;362/2005302-02
Adequacy of Plant-Referenced Simulator to
Conform with Simulator Requirements for
Reactivity and Control Manipulation Credits
LIST OF DOCUMENTS REVIEWED
Procedures
SIMTAG-400, "SONGS Simulator Core Physics Testing"
NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9
Plant Physics Data Book, Cycles 13 and 14
Reactivity manipulation packages for all 21 manipulation credits
Five applicants Initial Operator License Application Forms (NRC Form 398)
Simulator and Plant packages for 3 to 18 percent power increase (Cycle 13), two runs
Simulator and Plant packages for 80 to 92 percent power increase (Cycle 13)
ANSI/ANS 3.5-1998, "Nuclear Power Simulators for Use in Operator Training"
ANSI/ANS 19.6.1-1997, "Reload Startup Physics Tests for Pressurized Water Reactors"
SO23-XXXVII-1, "Low Power Physics Testing," Revision 3, used for Cycles 13 and 14
All Transient Test packages for 2005 and 2006 annual performance tests
All Steady State Test packages for 2005 and 2006 annual performance tests