ML090640307

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Annual Assessment Letter and Inspection Plan 2008
ML090640307
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 03/04/2009
From: Collins E
Region 1 Administrator
To: Ridenoure R
Southern California Edison Co
References
FOIA/PA-2011-0157
Download: ML090640307 (12)
v • d • e


Text

UNITED STATES NU C LE AR RE G ULATO RY C O M M I S S I O N R E GI ON I V 612 EAST LAMAR BLVD , SU ITE 400 AR LIN GTON , TEXAS 76011-4125 March 4, 2009 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:

ANNUAL ASSESSMENT LETTER - SAN ONOFRE NUCLEAR GENERATING STATION (NRC INSPECTION REPORTS 05000361/2009001 and 05000362/2009001

Dear Mr. Ridenoure,

On February 11, 2009, the NRC staff completed its performance review of Southern California Edison (SCE) San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. Our technical staff reviewed performance indicators (PIs) for the last two quarters and inspection results over the previous twelve months. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as Official Use Only - Security-Related Information will include the security cornerstone review and resultant inspection plan.

Although SONGS Units 2 and 3 operated in a manner that preserved public health and safety and fully met all cornerstone objectives, the NRC is concerned that continuing performance problems are not being effectively addressed. The Midcycle Assessment of SONGS was the second assessment cycle where substantive cross-cutting issues were identified in human performance and problem identification and resolution. We conducted a public meeting following the Midcycle Assessment to discuss your improvement initiatives in both areas. The effectiveness of your initiatives have not been evident and this annual assessment is the third cycle where substantive cross-cutting issues were identified in human performance and problem identification and resolution. As a result, the NRC is requesting you perform specific actions described later in this letter. Additionally, the NRC plans to perform additional inspection activities to assess your effectiveness in addressing these performance deficiencies.

Unit 2 Plant performance for the most recent quarter transitioned from the Licensee Response column to the Regulatory Response column of the NRC=s Action Matrix, because of one White finding, in the Mitigating Systems cornerstone. The finding involved the failure to establish appropriate instructions for replacement of a safety-related battery output breaker. Unit 3 Plant performance was within the Licensee Response Column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green).

Southern California Edison During this assessment period, the NRC identified 15 Green Findings and one White finding with cross-cutting aspects in the human performance area. In our annual assessment letter dated March 3, 2008, we advised you of a substantive cross-cutting issue in the component of resources involving the theme of failing to provide adequate procedures or work instructions.

Our assessment determined that the criteria to close this cross-cutting theme have not been met since your corrective actions have not demonstrated sustained improved performance. In the most recent quarter two findings were identified, one being of low to moderate safety significance (White) as previously discussed. Based on this cross-cutting theme being open for three consecutive assessment cycles the NRC is requesting you perform additional actions as discussed later in this letter.

Additionally, during this assessment period the staff identified an additional theme in the area of human performance involving ineffective use of human error prevention techniques. Five findings were identified during the assessment period affecting the Mitigating Systems and Initiating Events cornerstones. Examples of these human performance findings include instances of operator errors involving reactivity management and instances of failures to follow procedural guidance during surveillance, troubleshooting, and nuclear fuel movement activities.

This human performance substantive cross-cutting issue will remain open until we determine that corrective actions have been effective and have resulted in sustained improved performance.

During this assessment period, the NRC identified eight Green findings with cross-cutting aspects in the problem identification and resolution area. In our annual assessment letter dated March 3, 2008, we advised you of a cross-cutting theme in the component of the corrective action program involving instances of failing to thoroughly evaluate problems such that the resolutions effectively address causes and extent of conditions. During this assessment period seven Green Findings were related to this theme. Your staff has taken corrective actions to address these issues; however, these corrective actions have not resulted in adequate performance improvement. Therefore, this problem identification and resolution substantive cross-cutting issue will remain open until we determine that corrective actions have been effective and have resulted in sustained improved performance. Based on this cross-cutting theme also being open for three consecutive assessment cycles the NRC is requesting you perform additional actions as discussed later in this letter.

On January 11, 2008, the NRC issued SCE Confirmatory Order EA 07-232. The Order was issued in response to the identification of several instances of willful violations. The Order specified specific actions that SCE committed to perform to address potential safety culture issues. On October 3, 2008, the NRC performed a team inspection that reviewed your corrective actions associated with the Order. For a significant number of items the team was unable to determine that your staff had taken sufficient actions, therefore these items still remain open. On January 14, 2009, the NRC received your letter providing a status report regarding your schedule for completion of the open Order items. The NRC plans to perform an additional inspection in June of 2009 to follow up on these Order items.

During this assessment period, known performance problems have persisted and new performance problems have emerged. These are a White finding moving Unit 2 to the Regulatory Response Column of the NRCs Action Matrix; three consecutive

Southern California Edison assessment cycles with substantive cross-cutting issues not being effectively addressed in the areas of human performance and problem identification and resolution; and the identification of an additional substantive cross-cutting theme during this assessment period in the human performance area related to effective use of human area prevention techniques. Accordingly the NRC is requesting the following:

1) That you provide a written response to this letter describing the status of your corrective actions planned to address the human performance and the problem identification and resolution cross-cutting issues, including schedules, milestones, and performance monitoring metrics.
2) That you support a public meeting to discuss your improvement initiatives for the areas discussed in this letter.
3) That you perform an independent assessment of the safety culture at SONGS as described in NRC Manual Chapter 0305 Operating Reactor Assessment Program, on the basis of having two substantive cross-cutting issues open for three consecutive assessment periods.
4) That you submit to us written notice stating when you are ready for a 95001 Inspection for One or Two White Inputs in a Strategic Performance Area inspection to review your actions involving the White finding associated with the degraded safety related battery breaker.

Additionally, the NRC plans to perform a focused problem identification and resolution team inspection in June of 2009 to assess your improvement initiatives addressing the open substantive cross cutting issues. Also, as previously discussed, the NRC plans to review the remaining open items associated with the Confirmatory Order issued in January of 2008 during this inspection.

This assessment letter advises you of our planned inspection effort resulting from the end-of-cycle review. The enclosed inspection plan details the inspections, less those related to physical protection scheduled through June 30, 2010. The NRC also plans to perform Inspection Procedure 50001, Steam Generator Replacement Inspection for SONGS Unit 2.

The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the midcycle review.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made 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.qov/reading-rm/adams.html (the Public Electronic Reading Room).

Southern California Edison If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Michael Hay at (817) 860-8173 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Elmo E. Collins Regional Administrator Dockets: 50-361; 50-362 Licenses: NPF-10; NPF-15

Southern California Edison

Enclosure:

San Onofre Inspection/Activity Plan 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 Chief, Division of Drinking Water and Environmental Management California Department of Health Services 850 Marina Parkway, Bldg P, 2nd Floor Richmond, CA 94804 Michael J. DeMarco San Onofre Liaison San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 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 Albert R. Hochevar Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92675

Southern California Edison A. Edward Scherer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899-7414 Mr. Mike Short Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Chief, Technological Hazards Branch FEMA Region 9 1111 Broadway, Suite 1200 Oakland, CA 94607-4052 Walter F. Ekard Chief Administrative Officer San Diego County 1600 Pacific Coast Highway, Suite 209 San Diego, CA 92101 The Honorable Lisa Bartlett, Mayor City of Dana Point 33282 Golden Lantern, Suite 203 Dana Point, CA 92629 The Honorable Mark Nielsen, Mayor City of San Juan Capistrano 32400 Paseo Adelanto San Juan Capistrano, CA 92675

Southern California Edison Doug C. Chotkevys, City Manager City of Dana Point 33282 Golden Lantern, Suite 203 Dana Point, CA 92629 David Adams, City Manager City of San Juan Capistrano 32400 Paseo Adelanto San Juan Capistrano, CA 92675 Jeremy Kirchner, Emergency Services Coordinator City of Dana Point 33282 Golden Lantern, Suite 203 Dana Point, CA 92629 The Honorable Lori Donchak, Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672 Nancy Ward, Administrator Federal Emergency Management Agency, Region IX 1111 Broadway, Suite 1200 Oakland, CA 94607-4052 George Scarbrough, City Manager City of San Clemente 100 Avenida Presidio San Clemente, CA 92672 Penny Leinwander, Senior Health Physicist Department of Health Services Environmental Management Branch 1616 Capitol Avenue, MS 7405 Sacramento, CA 95899-7413 Benjamin Tong, Manager Radiological Preparedness Unit Governors Office of Emergency Services 3650 Schriever Avenue Mather, CA 95655 Susan Asturias, Sr. Emergency Services Coordinator San Diego County Office of Emergency Services 5555 Overland Avenue, Suite 1911 San Diego, CA 92123

Southern California Edison Michele Skiermont Radiological Coordinator Governor's Office of Emergency Services Radiological Preparedness Unit 3650 Schriever Avenue Mather, CA 95655 Vicki Osborn Senior Program Coordinator Orange County Sheriffs Department/

Emergency Management Bureau 2644 Santiago Canyon Road Silverado, CA 92676 Jim Russell, Emergency Planning Officer City of San Clemente 910 Calle Negocio, Suite 100 San Clemente, CA 92673 Mike Cantor; Emergency Planning Officer City of San Juan Capistrano 32400 Paseo Adelanto San Juan Capistrano, CA 92675 Ziad Mazboudi, Senior Civil Engineer City of San Juan Capistrano 32400 Paseo Adelanto San Juan Capistrano, CA 92675-3679 Rich Haydon, District Superintendent Orange Coast District California Department of Parks & Recreation 3030 Avenida del Presidente San Clemente, CA 92672 Steve Long, Chief Ranger Orange Coast District California Department of Parks & Recreation 3030 Avenida del Presidente San Clemente, CA 92672 Terre Duensing, Emergency Manager Orange County Sheriffs Department Emergency Management Bureau 2644 Santiago Canyon Road Silverado, CA 92676

Southern California Edison Lynne Seabloom Emergency Preparedness Coordinator Oceanside Fire Department 300 N. Coast Highway Oceanside, CA 92054 Terry Garrison, Fire Chief Oceanside Fire Department 300 N. Coast Highway.

Oceanside, CA 92054 Mike Drake Deputy Assistant Chief of Staff Operations and Training Marine Corps Base P.O. Box 555021 Camp Pendleton, CA 92055-5021 Patricia Gentry, REHS Program Manager Environmental Health County of Orange 1241 E. Dyer Road, Suite 120 Santa Ana, CA 92705

Southern California Edison Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.goV)

DRP Director (Roy.Caniano@nrc.gov)

DRP Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (Greg.Warnick@nrc.gov)

Branch Chief, DRP/(Michael.Hay@nrc.gov)

Senior Project Engineer, DRP/(Don.Allen@nrc.gov)

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Regional State Liaison Officer (Bill.Maier@nrc.gov)

RA Secretary (Lucy.Owen@nrc.gov)

DRA Secretary (Judy.Kilcrease@nrc.gov)

Branch Chief, DRS/EB1 (Thomas.Farnholtz@nrc.gov)

Branch Chief, DRS/EB2 (Neil.OKeefe@nrc.gov)

Branch Chief, DRS/PSB1 (Michael.Shannon@nrc.gov)

Branch Chief, DRS/PSB2 (Greg.Werner@nrc.gov)

Branch Chief, DRS/OB (Bernard.Stapleton@nrc.gov)

OEDO RIV Coordinator, Primary (Shawn.Williams@nrc.gov)

OEDO RIV Coordinator, Backup (Eugene.Guthrie@nrc.gov)

OEDO, TRPS (Tamara.Bloomer@nrc.gov)

Deputy Director, DIRS, NRR (Frederick.Brown@nrc.gov)

Director, DORL, NRR (Joseph Giitter@nrc.gov)

Deputy Director, DORL, NRR (Timothy.McGinty@nrc.gov)

Chief, PLB IV, DORL, NRR (Thomas.Hiltz@nrc.gov)

NRR Project Manager (Fred.Lyon@nrc.gov)

RidsNrrDirslpab Resource@nrc.gov ROPreports.Resource@nrc.gov mortensengk@INPO.org File located: R:\Reactors\EOC letters\2008\Songs.doc SUNSI Rev Compl. 7 Yes No ADAMS 7 Yes No Reviewer Initials MCH Publicly Avail 7 Yes No Sensitive Yes 7 No Sens. Type Initials MCH RIV:C:DRP/D D:DRS D:DRP DRA RA MCHay RCaniano DChamberlain CCasto ECollins

/RA/ /RA/ /RA/ /RA/ /RA/

2/23/2009 2/24/2009 2/24/2009 2/25/2009 2/25/2009 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Page 1 of 2 San Onofre 02/23/2009 12:38:08 Inspection / Activity Plan Report 22 03/01/2009 - 06/30/2010 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site X02454 - RETAKE EXAM 2 2 12/01/2008 03/31/2009 X02454 RETAKE EXAM-SONGS UNIT 2(5/26/09)

X02454 - RETAKE EXAM 4 2 12/01/2008 03/31/2009 X02454 RETAKE EXAM-SONGS UNIT 2(5/26/09)

X02455 - RETAKE EXAM 2 3 12/01/2008 03/31/2009 X02455 RETAKE EXAM- SONGS UNIT 3(5/26/09)

X02455 - RETAKE EXAM 2 3 12/01/2008 03/31/2009 X02455 RETAKE EXAM- SONGS UNIT 3(5/26/09)

X02455 - RETAKE EXAM 2 3 12/01/2008 03/31/2009 X02455 RETAKE EXAM- SONGS UNIT 3(5/26/09)

SGR-U2 - STEAM GENERATOR REPLACEMENT - UNIT 2 1 2 09/27/2009 12/31/2009 IP 50001 Steam Generator Replacement Inspection RE-TAKE - SRO RE-TAKE EXAM 2 2 02/03/2009 03/31/2009 X02454 RETAKE EXAM-SONGS UNIT 2(5/26/09)

X02454 - RETAKE EXAM 2 2 02/03/2009 03/31/2009 X02454 RETAKE EXAM-SONGS UNIT 2(5/26/09)

X02455 - RETAKE EXAM 2 3 02/03/2009 03/31/2009 X02455 RETAKE EXAM- SONGS UNIT 3(5/26/09)

RP-ORS3 - OCCUPATIONAL RADIATION SAFETY - ALARA 1 2, 3 04/06/2009 04/10/2009 IP 7112101 Access Control to Radiologically Significant Areas 2, 3 04/06/2009 04/10/2009 IP 7112102 ALARA Planning and Controls 2 04/06/2009 04/10/2009 IP 71151-OR01 Occupational Exposure Control Effectiveness 3 04/06/2009 04/10/2009 IP 71151-PR01 RETS/ODCM Radiological Effluent BI - PI&R AND CONFIRMATORY ORDER INSPECTION 2 2, 3 06/08/2009 06/12/2009 IP 71152B Identification and Resolution of Problems EB2-07T - TRIENNIAL HEAT SINK INSPECTION 2 2, 3 08/17/2009 08/21/2009 IP 7111107T Heat Sink Performance EP1 - EP EXERCISE INSPECTION 3 2, 3 09/20/2009 09/25/2009 IP 2515/175 Emergency Response Organization, Drill/Exercise Performance Indicator, Program Review 2, 3 09/20/2009 09/25/2009 IP 7111401 Exercise Evaluation 2, 3 09/20/2009 09/25/2009 IP 7111404 Emergency Action Level and Emergency Plan Changes 2, 3 09/20/2009 09/25/2009 IP 71151 Performance Indicator Verification EB1-08P - U2 INSERVICE INSPECTION 1 3 10/19/2009 11/27/2009 IP 2515/172 Reactor Coolant System Dissimiliar Metal Butt Welds 3 10/19/2009 11/27/2009 IP 7111108P Inservice Inspection Activities - PWR This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 San Onofre 02/23/2009 12:38:08 Inspection / Activity Plan Report 22 03/01/2009 - 06/30/2010 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site EXAM - INITIAL EXAM 8 2 10/19/2009 10/30/2009 X02416 INITIAL EXAM UNIT 2-SANO (10/2009) 3 10/19/2009 10/30/2009 X02417 INITIAL EXAM UNIT 3-SANO (10/2009)

EB1-17T - 50.59 & MODS 3 2, 3 12/07/2009 12/18/2009 IP 7111117T Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications RP-ORS5 - OCCUPATIONAL RADIATION SAFETY - ALARA 1 2, 3 12/07/2009 12/11/2009 IP 7112101 Access Control to Radiologically Significant Areas 2, 3 12/07/2009 12/11/2009 IP 7112102 ALARA Planning and Controls 2, 3 12/07/2009 12/11/2009 IP 71151 Performance Indicator Verification PSB2-52B - BIENNIAL PI&R 4 2, 3 02/08/2010 02/12/2010 IP 71152B Identification and Resolution of Problems 2, 3 02/22/2010 02/26/2010 IP 71152B Identification and Resolution of Problems EB2-05T - TRIENNIAL FIRE PROTECTION 4 2, 3 06/14/2010 06/18/2010 IP 7111105T Fire Protection [Triennial]

2, 3 06/28/2010 07/02/2010 IP 7111105T Fire Protection [Triennial]

This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

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