ML071440214
| ML071440214 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde, San Onofre  |
| Issue date: | 05/24/2007 |
| From: | Howell A NRC/RGN-IV/DRP |
| To: | Mills G - No Known Affiliation |
| References | |
| Download: ML071440214 (3) | |
Text
May 24, 2007 Glen R. Mills P.O. Box 3393 Mission Viejo, CA 92690
SUBJECT:
MARCH 26, 2007, LETTER TO THE OFFICE OF THE INSPECTOR GENERAL REGARDING SAN ONOFRE NUCLEAR GENERATING STATION NUCLEAR SAFETY CONCERNS
Dear Mr. Mills:
I want to thank you for your letter dated March 26, 2007, to the Office of the Inspector General, U.S. Nuclear Regulatory Commission (NRC). Taking the time to make us aware of your concern is important to us, and the NRC believes that public participation is key to an informed community.
Your concern was referred to the NRC Region IV office because it involved the San Onofre Nuclear Generating Station (SONGS) and the Palo Verde Nuclear Generating Station (PVNGS), for which Region IV has primary oversight.
In your letter, you compared the performance of the SONGS plants to that of the PVNGS plants and questioned why they are being treated differently. You also pointed out that PVNGS improvement plans have not resulted in a sustained performance improvement.
The NRC evaluates all plants using the same Action Matrix concept provided in the operating reactor assessment program. The NRC does not directly compare performance between plants.
PVNGS has had a number of findings that were determined to be greater than very low safety significance. Many of these findings were identified by the NRC through our inspections. As a result of these findings, the NRC has responded by increasing the regulatory oversight and performing additional focused inspections to determine the extent of the problems. Most recently, PVNGS, Unit 3 was placed into the Multiple/Repetitive Degraded Cornerstone column, which is the highest level of oversight, short of ordering a facility to shut down. This action was based on having one Yellow finding open since the fourth quarter of 2004 affecting all units, and one White finding affecting Unit 3 in the fourth quarter of 2006. The Yellow finding involved not maintaining portions of containment sump safety injection piping filled with water, and the White finding involved failures of components needed for the proper functioning of the Train 3A emergency diesel generator. For plants being placed in the Multiple/Repetitive Degraded Cornerstone column, the Action Matrix provides an expectation for the licensee to perform an evaluation of the root and contributing causes for both the individual and collective issues. This evaluation may consist of a third-party assessment. The licensee is also expected to perform an independent assessment of their safety culture. The licensee is expected to place identified deficiencies in their corrective action program and measure their performance improvement. NRC will then perform an intensive inspection to ensure the resulting improvement plan is sufficiently detailed and extensive. The NRC will conduct periodic follow-on inspections to verify the adequacy of those corrective actions.
Letter to: G. Mills Similarly, SONGS has had some performance issues. However, all the inspection findings and performance indicators remain in the lowest level of safety significance. Our annual assessment letter for SONGS (dated March 2, 2007, ML070610604) indicated that there are some specific areas of NRC concern, particularly in the area of human performance. However, these have not manifested themselves in safety-significant ways. The NRC has adjusted the focus of the baseline inspections to address these areas, and we have engaged the licensee to ensure they continue its improvement efforts.
The NRC inspection program is based on a graded approach. All plants receive the same basic inspection, termed "baseline inspections." During these inspections, the NRC may identify findings which we evaluate for safety significance. As long as the findings are determined to be of very low safety significance, the NRC will perform baseline inspections. As plant performance declines and we identify findings that are greater than very low safety significance, the NRC will supplement the baseline inspection program with additional inspections. The greater the safety significance of the findings, the greater the NRC's regulatory response.
You can read more about this process, known as the Reactor Oversight Process (ROP), on the NRCs public website, at http://www.nrc.gov/. This website explains how the NRC inspects plants and has links to recent reports on plant performance. Inspection findings and performance indicator results are summarized, including a description of the safety significance.
Also, you can access our performance assessment letters, which are issued twice per year.
These assessments are used to evaluate inspection findings and performance indicators in order to determine whether increased inspection focus is needed. The assessment letters provide a concise overview of plant performance, as well as placing this performance in a safety context.
Your letter requested a clarification about whether the NRC has a policy on requiring plants to remain shut down based on performance. This is an action that is within the NRC's legal authority. Our ROP provides the guidance for this action. The key attribute to be considered is the impact of plant performance on public health and safety, and economic considerations are not included.
The NRC plans to hold a public annual assessment meeting on July 12, 2007, at 6:30 p.m. at the Country Plaza Inn, 35 Via Pico Plaza, San Clemente, CA, to discuss SONGS 2006 performance. I encourage you to continue your participation by attending these public meetings, so you can stay informed about SONGS performance.
Should you have any questions concerning this letter please call me at (800) 952-9677, extension 248.
Sincerely,
/RA AVegel for/
Arthur T. Howell III Director, Division of Reactor Projects NRC Region IV bcc:
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