ML082200447
| ML082200447 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/12/2008 |
| From: | Kalyanam N NRC/NRR/ADRO/DORL/LPLIV |
| To: | Ridenoure R Southern California Edison Co |
| Thadani, M C, NRR/DORL/LP4, 415-1476 | |
| References | |
| TAC MD9333, TAC MD9334 | |
| Download: ML082200447 (16) | |
Text
August 12, 2008 Mr. Ross T. Ridenoure 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 - AUDIT OF THE LICENSEE=S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD9333 AND MD9334)
Dear Mr. Ridenoure:
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, AGuidelines for Managing NRC Commitment Changes,@ contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees commitment management programs once every 3 years to determine whether the licensees programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
An audit of San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3),
commitment management program was performed at the plant site on July 28, 2008. The NRC staff concludes, based on the audit, that Southern California Edison (the licensee) has implemented NRC commitments on a timely basis, and (2) the licensee has implemented an effective program for managing NRC commitment changes at Songs 2 and 3. The details of the audit including the NRC staff observations and recommendations are set forth in the enclosed audit report.
The NRC staff appreciates the resources that were made available by your staff, both before and during the audit. If there are any questions, I can be contacted at (301) 415-1480.
Sincerely,
/RA/
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362
Enclosure:
Audit Report cc w/encl: See next page
ML082200447 OFFICE LPL4/PM LPL/4/LA LPL4/BC (A)
LPL4/PM NAME NKalyanam GLappert JDonohew Nkalyanam DATE 8/11/08 8/11/08 8/12/08 8/12/08
San Onofre Nuclear Generating Station (June 2008)
Units 2 and 3 cc:
Douglas K. Porter, Esquire Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770 Dr. David Spath, Chief Division of Drinking Water and Environmental Management California Dept. of Health Services 850 Marina Parkway, Bldg P, 2nd Floor Richmond, CA 94804 Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101 Mark L. Parsons Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522 Mr. Gary L. Nolff Assistant General Manager - Resources Riverside Public Utilities City of Riverside, California 3901 Orange Street Riverside, CA 92501 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Mr. Michael L. De Marco San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 Resident Inspector San Onofre Nuclear Generating Station c/o U.S. Nuclear Regulatory Commission Post Office Box 4329 San Clemente, CA 92674 Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672 Mr. James T. Reilly Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. James D. Boyd California State Liaison Officer Vice Chair and Commissioner California Energy Commission 1516 Ninth Street, MS 31 Sacramento, CA 95814 Mr. Gary Butner Acting Branch Chief Department of Public Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899-7414 Vice President and Site Manager Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. A. Edward Scherer Director, Nuclear Regulatory Affairs Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 DOCKET NOS. 50-361 AND 50-362
1.0 INTRODUCTION AND BACKGROUND
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, AGuidelines for Managing NRC Commitment Changes,@ contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees commitment management programs once every 3 years to determine whether the licensees programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
NEI-99-04 defines a Aregulatory commitment@ as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.
NRR guidelines direct the NRR Project Manager to audit the licensee=s commitment management program by assessing the adequacy of the licensee=s implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and licensing activities (bulletins, generic letters, etc.).
2.0 AUDIT PROCEDURE AND RESULTS An audit of the San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3),
commitment management program was performed at the plant site on July 28, 2008. The audit consisted of two parts: (1) verification of the licensee=s implementation of NRC commitments that have been completed, and (2) verification of the licensee=s program for managing changes to NRC commitments.
2.1 Verification of Licensees Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented those commitments made to the NRC as part of past licensing actions/activities. For commitments that had not yet been implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.
ENCLOSURE
2.1.1 Audit Scope The audit addressed a sample of commitments made, mostly during the review period of the last 3 years. Some in the sample were chosen by the NRC staff, and the rest jointly by the staff and the licensee. The audit focused on regulatory commitments made in writing to the NRC as a result of past licensing actions (amendments, exemptions, relief requests, etc.) or licensing activities (bulletins, generic letters, etc.).
The SONGS 2 and 3 Commitment Tracking System includes items that fall outside the definition of commitments defined above and the audit generally excluded these commitments which are internal to licensee processes:
- 1.
Commitments made on the licensee=s own initiative among internal organizational components.
- 2.
Commitments that pertain to milestones of licensing actions/activities (e.g., respond to an NRC request for additional information by a certain date).
- 3.
Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.
2.1.2 Audit Results Southern California Edison (the licensee) has implemented General Procedure SO123-XV-39, Regulatory Commitment Tracking (RCT) Program,@ which identifies the methods and site organization tools for managing development, review, and implementation of station commitments. A commitment tracking system (CTS) database, MOSAIC is currently used in conjunction with other information sources to address and track regulatory commitments. The licensee is, however, in the process of changing the CTS database to SAP.
The documents furnished by the licensee during the audit included summary sheets providing the status of the commitments and appropriate backup documentation, as needed (i.e., plant procedures, examination records, and/or other plant documentation). The NRC staff reviewed the documents and summarized the selected commitments information in the attachment to this audit report.
The staff audit was intended to confirm that the licensee has documented its implementation of its regulatory commitments made to the NRC staff as part of past licensing communications, and the commitments that had not yet been implemented or incorporated in design bases documents are captured in an effective manner for future implementation.
The NRC staff audit of the licensees commitment management program for SONGS 2 and 3 did not identify any regulatory commitments that were not satisfied or incorporated. The licensee has maintained the database well and the commitments selected for this audit were easily traceable in the database. In case the commitment was already incorporated, the database provided the status of the commitment providing reference to the implementation document.
Based on the results of the on-site audit, the NRC staff believes the licensee has implemented the regulatory commitments management program effectively in accordance with LIC-105, AManaging Regulatory Commitments Made by Licensees to the NRC,@ and consistent with NEI 99-04.
The attachment to this audit report contains details of the audit and a summary of the audit results.
2.2 Verification of the Licensee=s Program for Managing NRC Commitment Changes The focus of this part of the audit was to verify that the licensee has established administrative controls for satisfying, modifying, or deleting commitments made to the NRC.
The NRC staff found that the process sets forth the need for identifying, initiating, tracking, and reporting commitments, managing a change or deviation from a previously completed commitment.
As set forth in Section 2.1 above, the NRC staff found that the licensee had addressed each regulatory commitment selected for this audit. As a result of review of the licensees information, as well as information from other sources, the NRC staff found no reason to differ from the licensees reported status of the audited commitments. Thus, the NRC staff surmises that the procedure used by the licensee to manage commitments is appropriate and effective 2.2.1 Audit Results The licensee carries out its obligations under its regulatory commitments by the processes that are outlined in the procedures. Any changes to the commitments are processed through the established processes and changes are reported to the NRC in accordance with the recommendations of LIC-105. However, no commitment changes were identified during the audit (for the commitments included in the scope of review), except for a change to an implementation date Based on the results of the on-site audit, the NRC staff believes the licensee has implemented regulatory commitment changes appropriately, in accordance with LIC-105 and consistent with NEI 99-04.
Table 1 summarizes what the NRC staff observed as the current status of licensee commitments.
3.0 OBSERVATIONS AND RECOMMENDATIONS The NRC staff audit of Southern California Edisons commitment management program for SONGS 2 and 3 did not identify any regulatory commitments that were not satisfied or incorporated. The licensee has maintained the Regulatory Commitment Tracking (RCT)
Program at a more than satisfactory level and the commitments selected for this audit were easily traceable in the RCT. The RCT provided an accurate status of the commitment as per SCEs RCT Program, General Procedure Rev.9, SO123-XV-39 and provided the reference to the implementation document.
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit, (1) the licensee had implemented or is tracking for future implementation regulatory commitments; and (2) the licensee had implemented an effective program to manage regulatory commitment changes.
5.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Linda Conklin and Malcom McGawn Principal Contributors: N. Kalyanam G. Lappert Date: August 12, 2008
Attachment:
Summary of Audit Results
Page 1 of 6 REGULATORY COMMITMENTS AND
SUMMARY
OF AUDIT RESULTS PERFORMED ON JULY 28, 2008 SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 & 3 Letter Subject Commitment No.
(Action Request (AR) No.)
Description of Commitment Implementation Status Letter from Southern California Edison (SCE) to Nuclear Regulatory Commission (NRC), dated June 18, 2007 Request for Emergency Plan (EP) Change -
Increase in Emergency
Response
Organization (ERO)
Augmentation Time from 60 to 90 minutes.
060701155 060701155-01 060701155-02 060701155-03 060701155-04 060701155-05 060701155-06 060701155-07 060701155-08 Assess for Regulatory Commitments Enhance operator training Evaluate current operator training Revise EP Implementation Procedures (EPIPs)
Improve PIC data recovery rate Train the reactor operators Train the Plant Equipment Operators Revise the Emergency Plan The referenced letter has 3 commitments within the document.
The licensee has expanded the 3 commitments to 8 specific commitments for tracking the individual items.
The Application is under review by the NRC staff.
The ARs are accorded the OPEN status.
Letter from SCE to NRC dated February 19, 2008 Response to Request for Information (RAI) on Proposed Amendment Request for Degraded Voltage Setpoints 080101702-01
- 1) If the as-found relay setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the relay shall be evaluated to verify that it is functioning as required before returning the relay to service. If the as-found relay setpoint is not conservative with respect to the Allowable Value, the relay shall be declared inoperable.
- 2) The relay setpoint shall be reset to a value that is within the as-left tolerance of the nominal relay setpoint; otherwise, the relay shall be declared inoperable.
- 3) If the as-found trip setpoint (TSP) is found to be non-conservative with respect to the allowable value (AV) specified in the Technical Specifications (TSs), the relay Commitment 080101702-01 (which makes a new commitment and is tracked by 080101703) is closed Details of the commitments are under 080101703 (see Page 5 of 6 of this Table).
Page 2 of 6 shall be declared inoperable and the associated TS action statement followed.
- 4) If the as-found TSP is found to be conservative with respect to the AV, and outside the as-found predefined acceptance criteria band, but SCE is able to determine that the relay is functioning as required and can be reset to within the setting tolerance of the limiting TSP, or a value more conservative than the limiting TSP, then the relay may be considered operable. If it cannot be determined that the relay is functioning as required, it shall be declared inoperable and the associated TS actions followed.
- 5) If the as-found TSP is outside the as-found predefined acceptance criteria band, the condition shall be entered into the corrective action program for further evaluation.
License Amendment Request (LAR) dated December 6, 2005, from SCE to NRC LAR to Amend the TS to delete the requirements for fuel handling isolation signals and fuel handling building (FHB) post-accident cleanup filter systems 050900649
- 1. SCE will implement the approved amendment
- 3. SCE will implement a Licensee Controlled Specification change to add the operability and functional requirements of the isolation and cleanup systems to the Licensee Controlled Specifications (LCS).
CLOSED -
- a. USFAR Chapter 15 update completed on 1/29/07.
- b. Revised DBD-SO23-710 to remove the FHB isolation safety basis completed on 1/29/07.
- c. Revised system descriptions SD-SO23-435, 690 and 720 completed on 1/29/07.
LAR, Proposed Change Notice (PCN) 555, dated December 27, 2004 from SCE to NRC The LAR revises the SONGS 2 and 3 accident source term (AST) used in the design basis radiological consequences 041201316-01 041201316-02 041201316-03 041201316-04 041201316-05 041201316-06 041201316-07 Letter contains 5 commitments Following approval of this license amendment request:
- 1) Future revisions to Updated Final Safety Analyses Report (UFSAR) Chapter 15 design basis accident (DBA) control The referenced letter has 5 commitments within the document.
The licensee has expanded the 3 to 12 specific commitments for tracking the individual items.
- a. 041201316-01 is open
- b. 041201316-02 (Determine
Page 3 of 6 analyses.
041201316-08 041201316-09 041201316-10 041201316-11 041201316-12 room and offsite radiological consequence analyses will be performed using AST methodology.
- 2) The manual dose calculation methodology as described in EP Implementation Procedures and other EP guidance documents will be revised to reflect AST methodology.
- 3) Raddose V dose assessment software will be evaluated by June 30, 2005, to determine what specific changes may be warranted in order to maintain consistency with the manual dose assessment calculation methodology.
- 4) Future revisions to Accident Monitoring setpoint calculations will reflect the AST source term.
- 5) SCE will provide the revised UFSAR sections to the NRC as part of its normal UFSAR update required by 10 CFR 50.71 (e).
changes to Raddose V software) is closed
- c. 041201316-03 (Provide the UFSAR Update to NRC) is open
- d. 041201316-04 (Accident Monitoring calculations will reflect AST methodology) is closed
- e. 041201316-05 (Determination of Changes to Raddose V) is closed
- g. 041201316-07 (Revise EP Dose Assessment Methodology) )is closed
- h. 041201316-08 (Revise existing dose calculations) is closed
- j. 041201316-10 (Revise EPIPS) is closed
- k. 041201316-11 (Revise the current control room unfiltered leakage)is closed
- l. 041201316-12 is cancelled since it is a duplicate of 041201316-052 Letter dated October 20, 2006 from SCE to NRC original letter dated May 11, 2006 Additional information supporting the Third Ten-Year ISI interval Relief Request ISI-3-22 for Alternative to ASME Code Rules for the Inside Diameter Structural Weld Overlay Repair Process for Control Element 042002292-15 042002292-16 SCE will provide:
- 1) A comparison of the proposed inspection technique to the technique used in the Electric Power Research Institute (EPRI) Material Reliability Program (MRP)-
89 demonstration report, and
- 2) The results of the Westinghouse technical justification analysis of the capability to monitor the residual indication and detect future growth in a manner consistent with the original EPRI - MRP demonstration.
The 2 Commitments are cancelled since SCE did not repair the reactor vessel head during the outage and did not use ISI-3-22
Page 4 of 6 Drive Mechanism (CEDM) #56 Letters dated May 11, and November 20, 2006 from SCE to NRC (Unit 3)
ISI Interval RR ISI-3-1-21 for the Embedded Flaw Repair Process for CEDM # 56 041002292-19 041002292-20 Commitments made in letter dated May 11, 2006:
- 1) If the established inspection criterion described in the enclosed request is exceeded, SCE will perform additional repairs on CEDM # 56.
- 2) Inspection results will be included in the 60-day post refueling outage inspection report in accordance with NRC Order EA-03-009.
The 2 commitments were closed by:
- a. Letter dated June 1, 2007, indicating that CEDM # 56 is not a defect and SCE has found nothing in the evaluation process to date, to contradict that belief.
- b. Letter dated August 31, 2007, indicating SCE is changing the inspection classification of the indication in the RVHP for CEDM #
56 from a defect to no detectable defect (NDD).
Letter dated October 23, 2006 from SCE to NRC (Unit 2 and 3)
Additional Information Supporting the Third Ten-Year Inservice Inspection RR ISI 3-24 and ISI 3-25 for the Use of Structural Weld Overlay and Associated Alternative Repair Techniques 050701323-32 050701323-33 050701323-34 050701323-35 050701323-38 050701323-39 Commitment made:
A report that summarizes the results of the examinations will be submitted to the NRC within fourteen days of completion of the final Ultrasonic Testing (UT) examination.
041201316-08 (Revise existing dose calculations) is closed CLOSED - Letter from SCE to NRC dated November 20, 2006 submits a summary of the results of the UT Inspections on the 4 Pressurizer (PZR) nozzles.
- a. PZR spray nozzle to safe end (03-005-030)
- b. PZR safety nozzle to safe end (03-005-027)
- c. PZR safety nozzle to safe end (03-005-028) and
- d. PZR safety nozzle to safe end (03-005-029)
No suspected flaw indications, such as lack of bond, weld flaws, planar flaws, or laminar flaws, were observed during the examinations.
Page 5 of 6 Response to RAI, from SCE to NRC, letter dated February 19, 2008 LAR for Loss of Voltage Signal Relay Replacement 080101703 080101703-3 080101703-4 080101703-5
- 1) If the as-found relay setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the relay shall be evaluated to verify that it is functioning as required before returning the relay to service. If the as-found relay setpoint is not conservative with respect to the Allowable Value, the relay shall be declared inoperable.
- 2) The relay setpoint shall be reset to a value that is within the as-left tolerance of the nominal relay setpoint; otherwise, the relay shall be declared inoperable.
- 3) If the as-found trip setpoint (TSP) is found to be non-conservative with respect to the allowable value (AV) specified in the Technical Specifications (TSs), the relay shall be declared inoperable and the associated TS action statement followed.
- 4) If the as-found TSP is found to be conservative with respect to the AV, and outside the as-found predefined acceptance criteria band, but SCE is able to determine that the relay is functioning as required and can be reset to within the setting tolerance of the limiting TSP, or a value more conservative than the limiting TSP, then the relay may be considered operable. If it cannot be determined that the relay is functioning as required, it shall be declared inoperable and the associated TS actions followed.
- 5) If the as-found TSP is outside the as-found predefined acceptance criteria band, the condition shall be entered into the corrective action program for further evaluation.
CLOSED
- a. 080101703-2 (Evaluate commitments with NEI 06-02) is closed
- b. 080101703-3 (Revise Maintenance and Construction Services procedures) is closed
- c. 080101703-4 (Update LOVS procedures SO2(3)-II011) is closed
- d. 080101703-5 (Update SO123-I-1.3, 6.2.2.11, and 6.3.7.6) is closed
Page 6 of 6 Issuance of License Amendment Nos.
159 and 150 dated October 7, 1999 Hydrogen Control System 000801190 IF at some future time, the Hydrogen Recombiners and/or the Hydrogen Purge System becomes inoperable, and Southern California Edison decides to permanently cease repair efforts, Southern California Edison will then inform the NRC of that decision as committed to in the SCE to NRC letter of 7/19/99.
CLOSED Commitment has been closed with letter to NRC dated February 5, 2007, indicating that the commitment has been met.
Letter dated March 7, 2007 from SCE to NRC Inspection and Mitigation of Alloy 82/182 Pressurizer Butt Welds 050701323-54, 050701323-55, 050701323-56 Commitments made:
- 1. SCE will not operate SONGS Unit 2 and 3 after December 31, 2007, until SONGS Unit 2 and 3 1re in compliance with the MRP-139 guidance
- 2. Until the PZR surge line butt weld is successfully brought into compliance with MRP-139, the enhanced leakage monitoring program will be in place.
CLOSED
- a. Commitments on SONGS Unit 2 have been closed with letter to NRC dated February 8, 2008, Completion of Actions and Commitments from Confirmatory Action Letter Re: Alloy. 82/182 Pressurizer Butt Welds February 8, 2008
- b. Commitments on SONGS Unit 3 have been closed with letter to NRC dated December 24, 2007, Completion of Actions and Commitments from Confirmatory Action Letter Re: Alloy 82/182 Pressurizer Butt Welds December 24, 2007 Letter dated July 27, 2007 from SCE to NRC Response to RAI in support of Request to Revise Fuel Storage Pool Boron Concentrate 020200715-38 020200715-39 020200715-40 SCE will apply a 6.6% reduction to the CECOR Computer code determination of Fuel Assembly Burnup for all fuel assemblies prior to determination of the allowable storage location per the proposed technical specification 4.3.1 and licensee controlled specification 4.0.100.
CLOSED
- a. Precaution 4.46 and 4.5 and prerequisite 3.3.2 added in SO23-X-7 (revision 15).
- b. Precaution 4.25 and caution 2.22, and perquisite (3.3.2) added in SO23-X-7.2 Revision 14)
SNM database, revision 21 has been created.
- c. Commitment captured in TS 4.3.1.g.