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Category:Enforcement Action
MONTHYEARIR 05000361/20180052019-03-25025 March 2019 Notice of Violation and Proposed Imposition of Civil Penalty and NRC Special Inspection Report 050-00206/2018-005, 050-00361/2018-005, 050-00362/2018-005, 072-00041/2018-001 ML19080A2082019-03-25025 March 2019 Notice of Violation and Proposed Imposition of Civil Penalty and NRC Special Inspection Report 050-00206/2018-005, 050-00361/2018-005, 050-00362/2018-005, 072-00041/2018-001 ML18332A3572018-11-28028 November 2018 EA-18-155, Southern California Edison Company; San Onofre Nuclear Generating Station - NRC Special Inspection Report 050-00206/2018-005, 050-00361/2018-005, 050-00362/2018-005, 072-00041/2018-001 and Notice of Violation IR 05000361/20110022011-05-0505 May 2011 IR 05000361-11-002, 05000362-11-002; 01/01/2011 03/24/2011; San Onofre Nuclear Generating Station, Units 2 and 3, Integrated Resident and Regional Report; Adverse Weather, Operability Evaluation IR 05000361/20104032010-12-15015 December 2010 IR 05000361-10-403 & IR 05000362-10-403, on 10/07/10, San Onofre ML1021104452010-07-30030 July 2010 IR 05000361-10-006; 05000362-10-006; on 10/01/2008 - 04/23/2010: San Onofre Nuclear Generating Station Biennial Baseline Inspection of the Identification and Resolution of Problems ML1006012722010-03-0202 March 2010 Work Environment Issues at San Onofre Nuclear Generating Station - Chilling Effect ML0934503682009-12-0909 December 2009 Generation Station, Units 2 and 3 Reply to Notice of Violation Regarding Inspection Report 05000361-09-004 and 05000362-09-004 ML0800804272008-01-0808 January 2008 EN-08-002 Southern California Edison Company (Sce), Confirmatory Order (Effective Immediately) (EA-07-232) 2019-03-25
[Table view] Category:Letter
MONTHYEARML24022A1492024-01-17017 January 2024 Independent Spent Fuel Storage Installation, Revision 4 to the Physical Security Plan IR 05000361/20230062023-11-29029 November 2023 NRC Inspection Report 05000361/2023-006 and 05000362/2023-006 ML23333A0682023-11-22022 November 2023 (SONGS) Units 1, 2, 3 and Independent Spent Fuel Storage Installation - Notification of Change in Nuclear Officer IR 05000361/20230052023-10-11011 October 2023 NRC Inspection Report 05000361/2023005 and 05000362/2023005 ML23276A5942023-09-28028 September 2023 and Independent Spent Fuel Storage Installation - Supplement to Decommissioning Funding Status Reports ML23268A0922023-09-20020 September 2023 Generation Station, Units 1, 2 and 3, and the Independent Spent Fuel Storage Facility (ISFSI) - Re-Registration of Dry Fuel Storage Casks for Amended Certificate of Compliance No. 1040 IR 05000361/20230012023-09-13013 September 2023 NRC Inspection Report 05000361 2023-001 and 05000362 2023-004 ML23240A5372023-08-18018 August 2023 Confirmatory Survey Activities Summary and Results for the Unit 2 and 3 Intake Structures at the San Onofre Nuclear Generating Station San Clemente CA ML23129A1802023-06-14014 June 2023 Cover Letter to State of CA on Draft EA Regarding San Onofre ISFSI Updated DFPs IR 05000361/20230032023-05-31031 May 2023 NRC Inspection Report 05000361/2023003 and 05000362/2023003 IR 05000361/20230022023-05-23023 May 2023 NRC Inspection Report 05000361/2023-002 and 05000362/2023-002 ML23137A1032023-05-11011 May 2023 (Songs), Units 1, 2 and 3, and Independent Spent Fuel Storage Installation - 2022 Annual Radiological Environmental Operating Report ML23123A0932023-04-28028 April 2023 (Songs), Units 1, 2 and 3, Submittal of Annual Radioactive Effluent Release Report - 2022 ML23230A0882023-04-10010 April 2023 Independent Spent Fuel Storage Installation - Decommissioning Quality Assurance Plan ML23094A1272023-03-29029 March 2023 Independent Spent Fuel Storage Installation - 10 CFR 50.82(a)(8)(v and VII) and 10 CFR 72.30(c) Decommissioning Funding Status Report 2021 ML23094A1332023-03-29029 March 2023 Nuclear Property Insurance ML23062A1172023-02-28028 February 2023 Generation Station Units 1, 2 and 3, Annual Radioactive Effluent Release Report for Independent Spent Fuel Storage Installation - 2022 ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML23059A2812023-02-22022 February 2023 (Songs), Units 1, 2 and 3, 2022 Annual Turtle Incidental Take Report ML23046A3792023-02-22022 February 2023 NRC Inspection Report 050-00361/2023-001 and 050-00362/2023-001 ML23045A2022023-02-0909 February 2023 Submittal of Annual Corporate Financial Reports for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 for Fy Ending June 30, 2022 ML22287A1352023-01-0505 January 2023 Issuance of Exemption from Title 10 of the Code of Federal Regulations Part 72.106(B), Independent Spent Fuel Storage Installation Controlled Area Boundary (L-2021-LLE-0056) ML22348A0622023-01-0404 January 2023 NRC to SCE, Transmittal of the National Marine Fisheries Service'S December 12, 2022, Letter of Concurrence for Decommissioning of San Onofre Nuclear Generating Statiion, Units 2 and 3 IR 05000206/20220062022-12-15015 December 2022 NRC Inspection Report 05000206/2022006, 05000361/2022-006, and 05000362/2022-006 ML22347A2122022-12-12012 December 2022 NMFS to NRC, Endangered Species Act Section 7(a)(2) Concurrence Letter for Decommissioning of the San Onofre Nuclear Generating Station ML22340A6652022-12-0505 December 2022 Letter from John Fassell, Chief; Re., State of California Department of Public Health Review and Comments on SONGS Draft Environmental Assessment ML22333A8192022-11-21021 November 2022 Submittal of San Onofre Nuclear Generating Station, Units 2 and 3, Defueled Safety Analysis Report, Revised November 2022 IR 05000361/20220052022-11-17017 November 2022 NRC Inspection Report 05000361/2022-005 and 05000362/2022-005 ML22301A1462022-10-20020 October 2022 Report of Violations of the National Pollutant Discharge Elimination System Permit San Onofre Nuclear Generating Station (Songs), Units 2 and 3 ML22277A0162022-09-29029 September 2022 Independent Spent Fuel Storage Installation Response to Request for Additional Information Regarding Request for Exemption from 10 CFR 72.106(b) IR 05000361/20220042022-09-26026 September 2022 NRC Inspection Report 05000361/2022-004 and 05000362/2022-004 ML22238A0552022-08-29029 August 2022 U.S. Nuclear Regulatory Commission'S Analysis of Southern California Edison'S Decommissioning Funding Status Report for San Onofre Nuclear Generating Station, Units 1, 2, and 3 ML22234A1602022-07-31031 July 2022 Final Report Per 10 CFR Part 21, Degraded Snubber SF1154 Hydraulic Fluid Batch No. 18CLVS431 ML22207B8612022-07-26026 July 2022 NRC (Public) Inspection Report 05000361/2022003; 05000362/2022003 IR 05000361/20220032022-07-26026 July 2022 NRC Inspection Report (Public) 05000361-2022003 and 05000362-2022003 (002) IR 05000361/20220022022-05-12012 May 2022 NRC Inspection Report 05000361/2022-002 and 05000362/2022-002 ML22136A0842022-05-12012 May 2022 Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report ML22122A0402022-04-28028 April 2022 (Songs), Units 1, 2 and 3 - Annual Radioactive Effluent Release Report - 2021 ML22105A5662022-04-0505 April 2022 20053 Letter - OI Closure to Licensee - Wrongdoing Signed ML22081A1692022-03-31031 March 2022 SONGS Application Acceptance Proposed Exemption from Title 10 of the CFR, Part 72.106(b), ISFSI Controlled Boundary IR 05000206/20214022022-03-24024 March 2022 Notice of Violation, NRC Inspection Report 05000206/2021402, 05000361/2021402, 05000362/2021402, and 07200041/2021401; and Investigation Report 4-2021-004- Public- Cover Letter ML22084A0552022-03-23023 March 2022 10 CFR 50.82(a)(8Xv and VII) and 10 CFR 72.30(c) Decommissioning Funding Status Report 2021 San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation IR 05000361/20220012022-03-14014 March 2022 NRC Inspection Report 05000361/2022-001; 05000362/2022-001 ML22066B0242022-03-0303 March 2022 (Songs), Units 1, 2, and 3, and the Independent Spent Fuel Storage Installation - Revision 2 to the ISFSI-Only Emergency Plan and Associated Changes to Emergency Plan Implementing Procedures ML22062B0282022-02-28028 February 2022 and Independent Spent Fuel Storage Installation (Isfsi), Response to Request for Supplemental Information Regarding Request for Exemption from 10 CFR 72.106(b) ML22059B0392022-02-25025 February 2022 International, Proprietary Information to Support SCE Exemption ML22060A1132022-02-24024 February 2022 Nuclear Property Insurance ML22060A1152022-02-24024 February 2022 Generation Station Units 1, 2 and 3, Annual Radioactive Effluent Release Report for Independent Spent Fuel Storage Installation - 2021 ML22048B4972022-02-15015 February 2022 (Songs), Units 1, 2 and 3 - 2021 Annual Turtle Incidental Take Report ML22031A1112022-01-26026 January 2022 (Songs), Units 2 and 3 - Annual Corporate Financial Reports 2024-01-17
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARML19116A0562019-04-23023 April 2019 ISFSI, Reply to a Notice of Violation, EA-18-155, and Statement of Method of Payment ML18362A1482018-12-26026 December 2018 Reply to a Notice of Violation, EA-18-155, San Onofre Nuclear Generating Station (Songs), Units 1, 2, 3, and ISFSI ML14024A3902014-01-22022 January 2014 Reply to a Notice of Violation; EA 13-083 ML14013A2602013-09-23023 September 2013 Reply to a Notice of Violation: EA 10-191, Revision I ML1117104842011-06-17017 June 2011 Response to Apparent Notice of Violation, IR 05000361-11-012 and 50000362-11-012, EA-11-083 ML1030205272010-10-29029 October 2010 Reply to a Notice of Violation: EA 10-191 ML1024301132010-08-30030 August 2010 Reply to Notice of Violation EA-10-125 ML1022100952010-08-0909 August 2010 Response to Confirmatory Order EA 07-232 and Notice of Violation EA 07-141, Inspection Report Nos. 05000361-07-016, 05000362-07-016, 05000361-07-017, Anbd 05000362-07-017 ML0934503682009-12-0909 December 2009 Generation Station, Units 2 and 3 Reply to Notice of Violation Regarding Inspection Report 05000361-09-004 and 05000362-09-004 ML0903703592009-02-0606 February 2009 Response to Notice of Violation and NRC Inspection Report 05000361/200813; 05000362/2008013 ML0903505052009-01-19019 January 2009 Reply to Notice of Violation; EA-08-296, Inspection Report No. 05000361/2008013 and 05000362/2008013 IR 05000361/20080132009-01-19019 January 2009 Reply to Notice of Violation; EA-08-296, Inspection Report No. 05000361/2008013 and 05000362/2008013 ML0902100762009-01-14014 January 2009 Generation Station Response to Confirmatory Order EA 07-232 and Notice of Violation EA 07-141 IR 05000361/20070052008-03-24024 March 2008 Reply to Notice of Violation; EA-08-051, Inspection Report Nos. 05000361-07-005 and 05000362-07-005 ML0809100652008-03-24024 March 2008 Reply to Notice of Violation; EA-08-051, Inspection Report Nos. 05000361-07-005 and 05000362-07-005 ML0733106132007-11-20020 November 2007 Reply to a Notice of Violation; EA-07-141, Inspection Report No. 05000361-07-017 ML0711401702007-04-16016 April 2007 Reply to a Notice of Violation; EA-06-303, IR 05000361-07-402 and 05000362-07-402, (Cover Letter Only) ML0621903162006-08-0202 August 2006 Day Response to Inspection Report No. 50-206/2006-011 2019-04-23
[Table view] |
Text
J Ross T. Ridenoure EDISON SOUTHERN CALIFORNIA Senior Vice President and CNO San Onofre Nuclear Generating Station An EDISON INTERNATIONAL Company December 9, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Subject:
Docket Nos. 50-361 and 50-362 Reply to Notice of Violation; EA-09-270 Inspection Report No. 05000361/2009004 and 05000362/2009004 San Onofre Nuclear Generation Station, Units 2 and 3
References:
Letter from Mr. M. C. Hay (NRC) to Ross T. Ridenoure (SCE) dated November 05, 2009
Dear Sir or Madam:
The reference letter transmitted the results of NRC Inspection Report No.
05000361/2009004 and 05000362/2009004 to Southern California Edison (SCE). The NRC Integrated Inspection was conducted between June 24, 2009 through September 23, 2009 at San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. The referenced report also transmitted a Notice of Violation (EA-09-270). The attachment to this letter provides the required response to the Notice of Violation.
If you have any questions, please feel free to contact me or Mr. R. St Onge.
Sincerely,
,cb,.c ~ 7 f~'aLvove I 10J ST,*177O p40,,4V.*-
Enclosure:
As stated cc: E. E. Collins, Regional Administrator, NRC Region IV G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 Mail Stop D45 P.O. Box 128 San Clemente, CA 92672 (949) 368-6255 PAX 86255 Fax: (949) 368-6183 I
Ross.Ridenoure@sce.com
~V4t~.
Enclosure Page 1 of 3 ENCLOSURE REPLY TO A NOTICE OF VIOLATION The Enclosure to Mr. M. C. Hay's letter dated November 05, 2009, states in part:
During an NRC inspection conducted on June 24 through September 23, 2009, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Title 10 CFR 50.65(a)(4), states in part, that before performing maintenance activities (including but not limited to surveillance, postmaintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.
Contrary to the above, on August 25-27, 2009, work control and operations personnel failed to adequately assess and manage the increase in risk associated with maintenance activities. Specifically, maintenance activities in or near the electrical switchyard and offsite power components were not included in the on-line risk assessment.
This violation is associated with a Green Significance Determination Process finding.
Enclosure Page 2 of 3 SCE RESPONSE TO VIOLATION BACKGROUND AND EVENT
SUMMARY
SCE performed Steam Generator Replacement Project (SGRP) activities near the Reserve Auxiliary Transformers (RATs) without Plant Operations and Work Control performing a risk assessment and identifying any necessary risk management actions before performing the work. The consequences of this event include the potential to cause a loss of offsite power event and reduce equipment availability to mitigate the consequences of an accident.
As discussed with the Nuclear Regulatory Commission during the Residents Inspection Exit meeting on September 24, 2009, SCE does not contest the violation or the NRC's determination of its significance.
- 1. Reason for the Violation SCE risk assessment and management procedures did not provide clear directions for consistent risk assessment and risk management of work activities as required by 10CFR50.65(a)(4). SCE programs addressed the risk of working on important to safety equipment, but the programs were not adequate in fully assessing the potential risk impact of work in the vicinity of important to safety equipment. The SGRP risk management scope considered the risk associated with specific project activities, but did not fully consider all Maintenance Rule requirements such as the qualitative risk associated with working around, but not on, important to safety systems, structures, and components (SSCs).
SCE processes, procedures, and practices for assessing and managing risk were not appropriately integrated across the station and station personnel did not fully understand the qualitative risk aspects of 10CFR50.65(a)(4). The SCE work management process did not provide consistent risk assessment and risk management of SGRP work activities in that only a small number of selected activities were reviewed. The Shift Technical Advisor (STA) reviewed work activities daily to assess risk per the Maintenance Rule; however, this review did not include most SGRP work activities. This led to maintenance activities near offsite power components not being included in the on-line risk assessment.
- 2. Corrective Actions Taken and Results Achieved On August 25, 2009, SCE activated the "High Impact Switchyard Maintenance" activity option in the Safety Monitor software. This Safety Monitor selection conservatively raises the baseline probability of the loss of offsite power due to switchyard activities, which establishes an increased risk profile. The Safety Monitor is a real time risk assessment tool that assesses plant risk for various configurations based on equipment out of service, system alignments, and environmental conditions such as high impact switchyard activities.
On August 28, 2009, SCE increased the emphasis on risk sensitive activities, including SGRP activities, in the SONGS Daily Planning Meeting. SGRP activities were added as an agenda discussion item for the Daily Planning Meeting to ensure potential risk affecting activities were routinely discussed. These discussions include crane activities in the switchyard/reserve auxiliary transformers area for which Operations activates the "High Impact Switchyard Maintenance" activity option in the Safety Monitor.
Enclosure Page 3 of 3 On September 8, 2009, SCE revised Work Control procedure S023-XX-8, "Integrated Risk Assessment." This revision added multiple attachments to provide specific direction for assessing and managing risk associated with plant activities. The added attachments include checklists for assessing individual activities, assessing scheduled activities in aggregate, and providing specific tools for use in managing identified risk significant activities. Additionally, management approval requirements for medium and high risk activities were added. The procedure revision also included questions designed to identify and manage additional types of risk, including Nuclear, Industrial, Radiological, Corporate, and Environmental risk.
- 3. Corrective Actions That Will Be Taken SCE is developing an Integrated Risk Assessment and Management Program to better ensure compliance with 10CFR50.65(a)(4). This program will provide an integrated process to ensure risk is managed using current industry practices, by identifying all activities that have the potential to impact important to safety equipment and putting in place appropriate contingency plans and mitigating actions before maintenance activities are started. The risk assessment and management program will assess and manage risk at the task level as well as the aggregate risk associated with outage windows or on-line work weeks, and will ensure emergent work is evaluated appropriately.
SCE revised the Work Control Integrated Risk Assessment procedure SO23-XX-8 to improve its risk management processes. Lessons learned during the implementation of this revision are being captured and assessed to further clarify and improve the risk assessment guidance.
These actions are included in the Change Management Plan for Integrated Risk Assessment and Management.
SCE is performing a Training Needs Analysis to identify improvements needed in Work Control, Operations, Maintenance and Engineering training relating to 10CFR50.65(a)(4) risk assessment requirements. SCE will implement appropriate training to address knowledge weaknesses in areas identified in the Training Needs Analysis assessments.
The Nuclear Oversight Department (NOD) is developing an oversight plan to verify the effectiveness of the actions taken to implement the Integrated Risk-Assessment and Management Program.
Individually, these corrective actions are ongoing and will be completed in accordance with the dates established by the Station's Corrective Action Program. These actions are scheduled to be completed by 07/31/2010.
- 4. Date When Full Compliance Will Be Achieved On August 25, 2009, SCE activated the "High Impact Switchyard Maintenance" activity option in the Safety Monitor software to address the nonconformance identified by the NRC Resident inspectors. On August 28, 2009 SGRP activities were added as an agenda discussion item for the Daily Planning Meeting to ensure potential risk affecting activities were routinely discussed.
These discussions include crane activities in the switchyard/reserve auxiliary transformers area for which Operations activates the "High Impact Switchyard Maintenance" activity option in the Safety Monitor. Full compliance with 10CFR50.65(a)(4) was achieved August 28, 2009 when these two activities were put in place to address the quantitative and qualitative risk associated with maintenance activities in or near the electrical switchyard and offsite power components.