ML102210095

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

ML102210095
Person / Time
Site:	San Onofre
Issue date:	08/09/2010
From:	Ridenoure R Southern California Edison Co
To:	Collins E Region 4 Administrator
References
EA-07-141, EA-07-232, IR-07-016, IR-07-017
Download: ML102210095 (7)

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SOUTHERN CALIFORNIA Ross T. Rideuoure l:ng--

il*ESGru" Seniol Vice Plesiclent and CNO San Onolie Nuclear Genelafing Station r\n /i.11lSON /N7T/lN.i?lON,il,!r Con)pany June 25, 2010 Elmo E. Collins, RegionalAdministrator, Region lV U.S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, Texas 7601 1-4125

Subject:

Docket Nos. E0-36i, 50-362, 50-206, and72-41 Response to Confirmatory Orde I EA 07-232 and Notice of Violation EA 0Z-141 Inspection Report Nos. os0oo361/200701 6, 0s00036 ztzoor016, 05000361 /20070i 7, and 05000362/2 OO7 O1T San Onofre Nuclear Generating Station

References:

See Attachment 1

Dear Mr. Collins:

on January 1 1, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Confirmatory order EA 07-232 to Southern California Edison Company (SCE) in resionse to willful violations thar occurred at San Onofre Nuclear Generating Station (SONGS) (Reference 1).

The Confirmatory Order requires that SCE complete 14 action items to address NRC concerns with willful violations at SONGS. SCE provided the NRC with its closure criteria for each of the 14 action items in References 4 and 8, and has completed each aciion item in accordance w1h these criteria' To date, the NRC has inspected and closed 12 of the 14 action items (References 5 and g)' Attachment 2 provides the terms and status of each action item.

The two remaining open Confirmatory Order actions include ltems 2c and 21. SCE has completed Item 2c, involving ethics training in 2008 - 2009, which is ready for NRC inspection.

This letter fulfills ltem 21, which requires SCE to provide the NRC with a letter discussing its basis pecify that: (1) ltems 1 through 2k meet their respective completion criteria and (2) the corrective bction$ haVe been determined to bd effeCtive in aCcofdande with the mbnitoring'p'iogia*--'

:As oiicussed above,:tiems t through zk were completedlin accordan.e wig, 6,e established closure criteria. To determine the effectiveness of SCE's corrective actions taken under the Confirmatory Order, SCE established a Monitoring Program as provided in References 6 and 7.

SCE used the collective results of the Monitoring erogrim (rathfr than any single component) to irr; iou;;;;ti,nu'it'

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Prog,rarn-and=theipr_6sults frgl,been l1sTgo ar:e_desGr.ibd:below;--

"-c"::jig?l.y=919:f orthe Monitorins Mail Stop D45 San. Clemente, CA, 9267?

(949) 368.6255 PAX 862s5 Fa,\:194$ Y68:6185-Ross.Ridenoure@sce.cour

Elmo E, Collins, Regional Administrator June 25, 2010 U.S. Nuclear Regulatory Commission

1. Targeted Surveillances SCE incorporated targeted surveillances into the SONGS oversight surveillance program that include periodic sampling of repetitive rounds and log-keeping activities associated with Security, Fire Watches, Operations, Health Physics, and conduct of on{he-job training. The intent of these surveillances is to provide reasonable assurance that actions to deter ind detect instances of deliberate non-compliance are effective and to serve as a deterrent to willful violations.

This targeted surveillance program has proven to be effective in detecting instances of deliberate non-compliance in the areas under surveillance. For exampte, in January 2A10, a deliberate non-compliance was identified when it was discovered that a non-licensed operator, on multiple occasions, did not complete a room inspection after reporting he did so. SCE took prompt correctlve actions in response to that event and notified the NRC resident inspector.

2. Reporting and Evaluation Process SCE instituted a reporting and evaluation process that screens and assesses Nuclear Notifications to identify whether a deliberate non-compliance may have occurred. Under this process, situations identified in which an individual (1) did not comply with a requirement and (2) it appears more likely than not that the individual made a conscious decision to violate a known requirement, are evaluated to identify deliberate non-compliance with site and/or NRC requirements.

SCE's reporting and evaluation.process has proven effective by identifying a number of instances in which the evidence suggested a deliberate non-compliance occurred. SCE took prompt action as warranted for each of these cases. SCE also used such instances as further opportunities to reinforce expectations to the site population.

SCE trends the results of these evaluations and recently performed a common cause evaluation after identifying an adverse trend in the number of deliberate non-compliance occurrences to determine whether additional actions are warranted. Results of the evaluation indicate that actions are in place to address deliberate non compliances, but ongoing monitoring programs to detect deliberate non-compliance should be continued.

The Monitoring Program included a provision to compare the results of the targeted surveillances (ltem 1 above) with the results of the reporting and evaluation process (this Iypes'qfgq1uals9libe-19.t..e..n-gn;copplianpeidentife.d'SCEcomp!eted![

identified no meaningfulgaps between the two programs.

3. EffedtivendSS RevieWs The following targeted effectiveness reviews were performed to gauge effectiveness of training and communigations associated with the Confirmatory Order action items.

- -" -;-:Krlowiedge tlspeeifii-to irai:ning-rertormeorin acioio Order were identified through post-training surveys. Gorrective actions to address the gaPq a19 ongoing, including remedialtraining and further enhancements to existing traininq proqrams.

Elmo E. Collins, Regional Administrator U.S. Nuclear Regulatory Commission June 25, 2010

' Focus group interviews, performed twice in 2009, indicated that, generally, personnel at SoNGS understand (1) the definition of a willfut viotation, (2);;qui;ements for procedure compliance at SONGS,. and (3) the potentiat consLquences of deliberate non-compliance' corrective actions to improve leadelship *ng"g"r.nt

-ongoing (committed, in Reference 1 1) and to resolve issues with the primai sof;ware toot (SAP) used for reporting at SONGS (committed in R"f"r"n" e 12), arefulfilling recommendations resulting from the Focus Group Interviews.

' Site-wide surveys from March 2009 through May 2010 indicated perceptions of.leadership engagement met the that worker established succes, .rit,.ri, throughout the survey period' ln addition, ongoing actions in this area to improve leadership engagement were committed inSCE's response to the 20Og NRb Mid-Cycle Performance Review Letter (Reference 11).

4. Performance Indicators Maintaining the underlying.safety culture at SoNGS is key to ensuring an environment that minimizes instances of deliberat-e non-compliance. Therefore, the Monitoring program included the following performance indicators to measure progress in addresling safety culture issues at SONGS.

Metrics Four metrics were selected to monitor progress of improvements in safety culture characteristics most likely to drive a reduciion in deliberate non-complianies.

' SCE is using the industrial safety indiqatol to provide an improving the safety culture at sbNos. This metric indication of progress in has demonstrateo an improving trend since July 2009,

' The indicator assoeiated with leadership engagement has since November 200g.

met its success criteria

' The indicators associated with procedure quality and procedure not yet meet their respective success criteiia. To some use and adherence do extent this is due to the fact that these indiq,alqp qle dfl;vqn bv. n119e,rs of issues identified-Tnisli-an expecled result from the. increased emphasis SCE has placed on these issues and l:99..:j?_9_l!j.F_ry?1y919". .gcE recosnizes that this is an area in which furrher as.committed .in.Reference 1 i.

Th-e l/onitoring Program has a provision to compare the results of the 2008 and 200g nuclear safety culture surveys and assessments to ioeniify trrnorlniu]"tv'.rrtrr";tiiit,,,i"r.

results of this survey cornparison indicate there wis no decline. *,"

implemeqti.legn scg o"u"iop"J ano is

, eetton.p,!an to.,addr:essfindings rne e-oOe surveyand assessment; which irom was committed to the NRC in a response to'ttie zo09 Mid-tycle performance Review letter (Reference 10). .:-' -'

Elmo E. Collins, Regional Administrator U.S. Nuclear Regulatory Commission June 25, 2010 Root Cause Evaluations (RCEs)

The SoNGS cause_ evaluation process was revised to include a separate Safety Culture Review for each RCE to identify significant safety culture event contributors.

In summary, SCE has completed the actions required by the Confirmatory order and determined the collective results of the Monitoring Program demonsirate that effective processes and procedures are in place to ensure that deliberate non-compliances are detected and addressed.

Additionally, ScE committed to implementing site-wide actlon plans to continue to improve the safety culture at SONGS and create an enviionment that results in minimal instances of deliberate non-compliance. Accordingly, SCE has concluded that the Confirmatory Order has been satisfied.

SCE recognizes that integrity and compliance are at the heart of nuclear safety, and remains committed to detecting, addressing, and preventing deliberate non-compliances.

There are no new commitments in this letter.

Attachments: Asstated.

cc: NRC Document Control Desk R. Hall, NRG Project Manager, San Onofre Units 2 and 3 G. G. warnick, NRC senior Resident Inspector, san onofre units 2 and 3

Attachment 1 References

)ocket Nos. 50-361, 50-362, 50-206, and 72-41

1. Letter, Mr. E. E. collins (NRc) to Mr. R. M. Rosenblum (scE), dated January 11, 2008, Confirmatory Order

2. Letter, Mr. J. T. Reilly (SCE) to U.-s. Nuclear Regulatory Cornmlssion Document Contro!

Desk, dated February 8, 2008, Response to the Confirmatory Order ltem 3 J. Letter, Mr. J. T. Reilly (SCE) to U.S. Nuclear Regulatory Commission Document Control Desk, dated February 28, 2008, Response to the Confirmatory Order ltem 2

4. Letter, Mr. A. E. Scherer (SCE) to U. S. NRC Document Control Desk, dated Novernber 14, 2008, Confirmatory Order Closure Criteria

5. Letter, Mr. A. Vegel (usNRc) to Mr. R. T. Ridenoure (scE), dated December 3, 200g, San Onofre Nuclear Generating Station Units 2 and 3 - NRC Problem ldentification and Resolution Inspection Report 05000361 /200801 2 and 0s00 s62tz0ae012, and Conf rm atory Order (EA-07 -232) Fol ow'u p I ns pection i I In this inspection report, the NRC closed B of the Confirmatory Order action items (ftems 1,2.d,2.e,2i ,2.i,2.j,2.k and 3).

o- Letter, Mr. R. T. Ridenoure (SCE) to U.S. NRC Document Control Desk, dated January 14,20A9, Confirmatory Order Status and Monitoring program

7. Letter, Mr. A. E. Scherer (SCE) to U. S. NRC Document Control Desk, dated May 29, 2009, Confirmatory Order Monitoring Program Update

8. Letter, Mr. A, E. Scherer (SCE) to U. S. NRC Document Control Desk, dated June 22,2009, Confirmatory Order ltem 29 Closure Criteria Update L Letter, Mr. A. Vegel (USNRC) to Mr. R. T. Ridenoure (SCE), dated July 31, 2009, San Onofre Nuclear Generating Station - NRC Integrated lnspection Report 05000361 i2009003 and 05000362/2009003 ln this inspection rqport, the NRC closed 4 of the Confirmatory Order action items (ftems 2.a,2.b,2.9 and 2.h).

11. Letter, Mr. R. T. nioenoure (SCe)to Mi. E, e. coitins (Nnc), dated October 30, 2000, Response to 2009 NRC Mid-Cycle Performance Review

12. Letter, Mr. R. T. Ridenoure (scE) to Mr. E. E. collins (NRc), dated March 31, 2010, Re_qpo-n

Attachment 2 Completion Status of Confirmatory Order Actions Docket Nos. 50-361, 50-362, 50-206, and 72-41 1 Common Cause Evaluation-"By January 31, 2008, SCE will Complete Closed 12103/08 perform a common cause evaluation of known recent events, (Ref. 5) actually or potentially involving willful events to determine the root and contributing causes for the collective issues. This evaluation will include an analysis to determine if any deficiencies of safety culture components, as defined by NRC's Inspection Manual Chapter (lMC) 0305, "Operating Reactor Assessment Program," were significant contributors. The results of this evaluation will be factored into the Corrective Action Program and addressed in other ongoing related efforts, as appropriate."

2a Corrective Action Plan & Monitoring Program-"By Complete Closed 07131109 February 29, 2008, SCE will provide the NRC with a Corrective (Ref. 3,6, 7) (Ref. 9)

Action Plan that includes the results of ltem 1 and provides the following key elements: A monitoring program to determine the effectiveness of the Corrective Action Plan developed pursuant to this ltem 2."

ZU Multi-Day Interventions-"By June 30, 2008, SCE will conduct Complete Closed 07/31/09 multi-day interventions that reinforce fundamental company (Ref. e) values. SCE will ensure that this effort includes the elements of a strong nuclear safety culture to prevent deliberate violations.

The intent of the interventions will be to focus leaders and managers on the importance of balancing accountability and encouraging workers to self-report errors and the importance of communicatinq this to their workers,"

2c Ethics Training for 2A08-2009*"SCE will expand the Complete Ready to Close Corporate Ethics Program to encompass longterm (i.e., greater than 90 days) managers and supervisors of independent contract workers at SONGS, who will be required io take the integrity training in 2008. SCE will conduct training for SONGS managers and supervisors in 2008 and other SCE SONGS emDlovees in 2009.'

2d 2008 Safety Gulture Assessment by 3rd Party-"SCE will Complete Closed 12103108 conduct a safety culture assessment by an independent third- (Ref.5) p.g(y qrganiZetlon by Ap.1il 1, 2008. By Jqle 30, 2008, t[9.

results of this assessment will be factored into the Corrective Action Program and addressed in other ongoing related efforts, Closed 12l03lOB

" (Ref. 5) ensurethat new and periodically retrained personnel clear.ly ,

understand that deliberate acts of non-compliance with regulations or procedures will not be tolerated and could result in a significant disciplinary action up to and including termination."

2t Trainin g o.n Tech n iq ues to Mp"n itpr Worker C. ompli ance---l By CompleJe Cfosed 12103108 September 30;2008;Se E will develop and.begincondueting ., " (Ref. 5) training for rnanagers and supervisors on techniques that can be used to monitor that workers are implementing procedures as instructed." ...  :..

Attachment 2 Completion Status of Confirmatory Order Actions Docket Nos. 50-361, 50-362, SO_200, and 72_41

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..ilii:i 2g f)ica inl i existinsoisdiprinarvp-roce?iff Complete Closed 07t31t\g in cases involving a deliberate misconduct_related

,[;,iJ";l;,:X:,:ilL:Tr1ffi Js (Ref. 9) violition.

This process will communicate to the workforce specific

^:.::j1tiq_lsciptinary.actions rhat may be taren in response to rntuat..ano/or repeat deliberate m isconduct by individuai contributors and supervisors/managers. Communication process enhancements.will focus personnel of on the importance of balancing accountability and encouraging workers to self_

report errors and the importance of communicating this with their workers."

2h Trrininn f^.

scEwiif revi,itn"soirtUl*ifi,fn',i1J"",i?"-.o?fi Sljltoou' Complete Closed A7Trcg Training (OJT)hainers and providjthis training (Ref. s) to ail OJT trainers and trainees. The revised oJT training wirr reinforce the responsibilities of the trainer and the trainees. Emphasis placed on the expectations of a trainer while wiil oe hisiher trainee is performing work durino an OJT session ,,

2i lnaAn?IlraQf-nrAn k Complete Closed l2tOAAB leye lo n_1d i m p re m e n t in ce n tives ro r o n -s ite lJilil"tJil,.: Jilr, to help scE address the issues that have resurted in (Ref. 5) deriberate misconduct-rerated viorations. rf scE is unabre to negotiate---

acceptable programs by a particular contractor, then scE will impose additional oversight to ensure the performan."

oitn" conttactor and its personnel meeis sneeificd nrirarir ,,

4 Perio.dic Sampling Complete Aprit 1, 2008, SCE will incorporate into the Closed 12t0gt}B lltjyltL"-"By SON.GS oversight surveillance program, periodic (Ref. 5) samptinj ot repetitive rounds and log keeping altivitids to provide reasonabre assurance that actions to deter and detect instances on-c91plia n ce a re effective. Th is ove rsig hi ri il - -

l^f^*1i!"-l{: 1 Incluoe sampling of SCE and contractor anJirritioc ,

2k Sifa-Uvi.ta n^*

rte-wid e com m un ication too rs tl*il'Ji *il"t conlfastArs el SONGS rhe need to qgmpti witn jqU rirles,

1. J,ilg: :pre s Complete Closed 12t03t}g (Ref. 5) regulations, and procedures and potential consequences when compliance does not occur.',

-Comnlafian'l.a t n;il" o'ili,. . # ffiffi #o:TrE lH&'ffi - --eomplete*-- --Ready to-Glose:

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reuerorscussing te its basis for concluding that the oider has been 9.atigfigd,"

3 Racnnnca.la-f ..c^^

i"r5*""ri'n;"#;'$';'ii,or11,ft"*"itnJil;flffiffi Gomplete Glosed 12t09/08 (Ref.2) (Ref. b)

.gpgr.at9 letter its respo_nse to the three issues addressed by the NRC in its retter dated septem ber 27, zoo7,

-NRC letter dated November ien oz -zezf iia'ior 2,2007, ten Oi-i+f l, tne extenito' which trainers may fail to folloW the orocecfirret rFrr riram.hro ^r ns_xi_zij,