ML102210099

Response to NRC Mid-Cycle Performance Review Letter

ML102210099
Person / Time
Site:	San Onofre
Issue date:	03/31/2010
From:	Ridenoure R Edison International Co, Southern California Edison Co
To:	Collins E Region 4 Administrator
References
Download: ML102210099 (9)

Text

{{#Wiki_filter:SOUTHERN CALIFORNIA FDflSON-An trDl,lON I N?'ER N ATI O NALG Conpany March 31, 2010 Elmo E. Collins, RegionalAdministrator, Region lV U,S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, Texas 760 1 1-4125 Subjecfi Docket Nos. 50-361 and S0-3G2 Response to NRC Mid-Cycle Performance Review Letter for the San Onofre Nuclear Generating Station- ,Modifications to Submittals Dated October 29, 2009, and October 30, 2009

References:

(1) NRC Letter, dated september 1,200g, Mid-cycle Review and lnspection Plan-San Onofre Nuclear Generating Station (SONGS), from E.E. Collins, Regional Administrator, NRC Region IV, to R.T. Ridenoure, Chief Nuclear Officer of SCE. (2) SCE Letter, dated October 29,2009,Independent Safety culture Assessment Results and Action plans (Response to NRC lvlid-Cycle Performance Review Letterfor SONGS), from R,T, Ridenoure, Chief Nuclear Officer of SCE, to e.f, Coilins, Regional Administrator, NRC Region lV. (3) SCE Letter, dated October 30, 2009, Response to NRC Mid_ Cycle Perfgrmance Review Letter for SONGS, from R.T. Ridenoure, Chief Nuclear Officer of SCE, to E.E. Collins, Regional Administrator, NRC Region lV.

Dear Mr. Collins:

ln its 2009 Mid-Cycle Review (Reference 1) for the San Onofre Nuclear Generating Station (SONGS), the U.S. Nuclear Regulatory Commission (NRC) requested the following; (1) the results of the 2009 independent safety culture' assessment of SONGS and any associated action plans and projected completion dates; and (2) an update of the status of corrective aitions planned to address the crosscutting areas of human performance (HU) and problem identification and resolution (Pl&R). Southern California Edison Company (SCE) --responde-{le=thsss=req,uests-inJetter,s-dated=Oetober2'h2OOg'(Reference2l-ana-October 30, 2009 (Reference 3), respectively. Mail Stop D45 P.O. Box 128 San Clernente, CA92672 (949) 368-62s5 PAX 86255 Fax: (949) 368-6183 Ross,Ridenoute@sce,com Ross T. Ridenoure Senior Vice Plesident ond CNO San Onofre Nuclear Generating Station

Elmo E. Collins, Regional Administrator U.S. Nuclear Regulatory Commission March 31, 2010 This letter modifies portions of the safety culture, HU and Pl&R plans found in References 2 and 3. Specifically: . Enclosure 1 of this letter modifies certain safety culture actions and due dates set forth in Attachment 1 to Reference 2. . Enclosure2ofthis lettermodifies one HU action setforth in Attachment 1 to Reference 3. Enclosure 2 also includes new actions for Initiative 6-Conservative Decision Making : I mprove understanding of conservative decision making principles and reinforce conservative decision making behaviors. . Enclosure 3 of this letter modifies certain Pl&R actions and due dates set forth in Attachment 3 to Reference 3. Enclosure 3 also includes new actions for Initiative 9 - Trending: Actions to improve trending of station data and response to adverse trends. The modifications and additions in Enclosures 1-3 are shown in "Track Changes" format to indicate the changes that have been made._ There were other cases in which actions or Closure Review Boards were completed late; however, since those actions were subsequently completed, they have not been included in this letter. We recognize that failing to meet action completion dates is unacceptable. I have discussed this issue with the SONGS Senior Leadership Team and they clearly understand that this performance will not be tolerated. We also recognize the need to improve the quality of action closure packages, and this is one of the behaviors that we will change during 2010. Please feelfree to contact me or Mr. Richard St. Onge should you have any questions or require fufiher information.

Enclosures:

As stated. cc: NRC Documenf R. Hall, NRC Project Manager, San Onofre Unit 2 and 3 G, G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 Sincerely,

Modifications to Safetv Culture Plan Submitted on October 29,2009 This Enclosure provides the modifications to the Safety Culture Plan submitted on October 29,2OAg. The rnodifications are shown in "Track Changes" format to indicate the changes that have been made. The actions are correlated to the Areas in which they relate. These conelations are provided in bold parentheticals following each action. Pedorm a follow-up assessment in each of the groups identified in the ?009 independent nuclear safety culture assessment as having specific safety culture issues warranting particular attention. These assessments will evaluate the effectiveness of actions to address the issues in each group, and will include pailicipation by at least one non-SONGS individualwith experience in. evaluaiing safeiy culture and safety conscious work environment issues. fArea 1: Accountability and Disciplined Follow-Throuqh] og/31/10 s7/31/1s To allow time to coordinaie the Focus Group assessment activities with the related assessment frorn the SCWE root cause. +ing i gRBeDevelop and implem reduce.tirne for completion oL Closure Review Boards (CRBs) so that ihev are norrnally completed within 30 days of action completion as indicated in SAP. Establish mechanism io provide visibility and accountabitity for items not adhering to the schedule. [Area 1; Accountability and Disciplined Follow-Throughl 07131110 ewal+s Failed Closure Fleview Board based on failure to meet goals for completion of CRBs in a timelv fashion.

The new due date aligns with supporting developmeni of the 2011 strategic Plan, Review and upgrade the strategic improvemenVbusiness planning process so that it clearly defines roles and responsibilities of participants and explicitly considers: (1 ) cumulative impact of concurrent improvement actions; (2) input from appropriate site stakeholders; and (3) a longer (2-3 year) time horizon, fArea 2: Change Management and Site Engagement; Area 4: Functions and Roles of Key Programs; Area 5: Consistent Strategic Vision and Due date change atigns with a major site-wide process/organizaiional redesign. 07131111 0e/30/+0 Perform a review and revision (or replacement) of top level SONGS site governance documents that define roles, responsibilities and functions of key departmenis and programs, [Area 4: Functions and Roles of Key Proglqrne Failed closure review based on fact thai action's objectives were being addressed via implernentation of specific actions rather than presenting a "project plan," Additional time is needed to resubmit revised closure package and to permit CRB review, a411.5110 a2l15l1+ Establish a project plan and schedule for resolving SAP issues that includes: mechanisms for employee input on problems and solutions; definition of end-state desired pedormance; implementation of improvements; and evaluation of effectiveness. [Area 4: Functions and Roles of Key Programsl

EnclosureZ... Modification & Additions to Human Performance (HU) Plan Submitted on October 30' 2009 A,, Modification The following provid:es a modification to the HU Plan submitted on October 30, 2009. The modification is shown in "Track Changes" format to indicate the changes that have been made. The action is correlated to the lnitiative in which it relates. This correlation is provided in bold parentheticals following the action. June 30, 201 0 Clarification of how leader observation and coaching skills iraining will be provided. Develop and siart implementgflql ol training for leader observation and coaching skills. This training is beinq presented as part oflhe mqlti-week Leadership Academv sessions. and will be provided over a multi-vear period, flnitiative 4: - lmprove Leadership En gagement to Strengthen Workforce Accountabil 4 -l

B, Additional Actions ln its submitial, dated October 30, 2009, Souihern California Edison Company noted that Initiative o-Conservaiive Decision Making, was under development and initial actions to be included within it would be establlshed by January 23,2010. The following actions have been added to lnitiative 6, (CAPR) Revise SO123-XV-52, Functionality Assessments and Operability Determinations to incorporate industry benchmarking and include: Clarity and accuracy of process actions in an executable siep format; the transfer of departmental ownership of ihe process to Operations; incorporation of the INPO Principles for an Effective Operational Decision Marking; an appropriate operability ehecklist; real-time, in-line expert independent review of PODs and periodic quality checks of lODs; appropriate linkages to other'processes'(e.g', the Operational Decision Making Process). June 1,2010 (CAPR) Develop a decision-rnaking modelthat includes: roles, responsibil ities, systematic process, conservative assurn ptions, communication and effectiveness reviews. This model should emphasize that individuals (workers, supervisors, and managers) make decisions on a daily basis that have the ability to affect safe reliable operation and/or requlatory compliance' May 19, 2010 (CAPn) Revise SO123-XV-52, Functionality Assessments and Operability Determinations to incorporate a review of indusiry procedures and include: Define the term "conservative" in relation to assumptions regarding degradation, initial conditions, and time/conditions for when the function is required; Require review of sou rce docu m ents f or imryr ed iate operab il ity determ ination ; Gonsideration ol all modes of system operation and consideration of diff erent accident/transient scenarios; Consideration of potential degraded condition from an abiliiy to monitor, control, and predict further degradation; Establish independent review of PODs and periodic qualitv checks of lODs. June 30, 2010 Modifications & Additions to Problem ldentification and Resolution (Pl&R) Plan Submitted on October 30,2009 A. Modifications and Date Changes The following prcrvides the modifications and date changes to the Pl&R Plan submitted on October 30, 2009, The modifications and date changes are shown in "Track Changes" format to indicate the changes thht have been made, The actions are correlated tc the Initiatives in which they relate, These correlations are provided in bold paren.*heticals following each action. Establish response tearn training and provide to selected station personnel, including definition of (1) personnelio be trained, (2) initial training req uirem enis, (3) coniinuin g training requirements, and (4)timing and frequency of training, as nocessary, flnitiative 4: Response Teamsl June 15,2010 DeeemberJ;e009 - Failed Closure Review Board {CRB) due to failure to train entire defined pooulation (although enough were trained to implement the emergency resoonse-team orocess). ,\\s an interim. aclion, the station is using external personnel with cause evaluation .experience, including experience with gvaluation of extent of cause and extent of

condition, to coach station personnel in achieving indusirv levels of cause evaluation timeliness and qualityr. This action will close when staiion performance is satisfactory and sustainable per metrics established for ii m el i n ess and q ual ity.-and+*ilheut*he aesisiaree ef eldqffialf'EOnR{, The rnetrics will monitor the station's ability to perforrn evaluations within 30 35 days, and achieve quality using caube evaluation grading criteria wiih independent review.

Initiative 5: Gause Evaluationsl December 31, 2010 re-evaluation for continued need Deeembel-#009 r+evaluatienfr ee*incd-f;ed Clarification and due date extension based on decision to extend conlractor support, based on need to support cause evaluation timeliness and quality goals. Divisions that are currently not meeting ACE timeliness goals will develop actions plans-to drive improvement in ACE timeliness to less than or equal to.40 days (end of year goal), [nitiative 5: Cduse Evaluations] A[iril 15:,2010 ' Deeember+g;-20+S Clarifi:cation based on fact that'40-day goal was met via implementation of specific hctions rather than forfial plans, Goal was actually met by December 10.2009. due-date. -- Additionaltirne is to permit CRB re-review ba,ged on revised languaqe. Modified action so that CAP Corrective Action Review Board will review CAPRs rather than CRB. lnitiate and incorporate a process for performing a review of closures of RCE corrective aciions to prevent recurrence (CAPRs) elesures-to ensure both aciions and documentation medt station expectations and standardsi Thb Glosure Revielv-Beard will review these eA elesures as seen as reasenably-praeil iew Bear*guidetine: SSPG S01 "3iQ-1, This review will be determined to ncj longer be required when effectiveness measures indicate that CA closures consistently meet expectaiions. Initiatlve 6: Corrective Action lrnplementation and Closurel [NOTE: The action below is being added to address quallty of other RCE correciive actions July 30, 2009 [original action was completed-commitment being changed for long:1stt1 Develop ajrd implement process for , reviewinq other coirective aclio '(r.e.. those corrective actions'aside from co_rjective.actions io plevenl iecurrgnce). [nitiative 6: Corieclive Action ,lmplementation and Closurel [NOTE: This is a new action June 30,2010 New action td establish focused team for review ol non-CAPR RCE corrective actions rather than CRB, Establish corrective action implementation and closure training and provide to selected station personnel, including def inition of (1) personnelto be trained, (2) initialtraining requirements, (3) coniinuing training requirements, and (4)fiming and f requency of training, as necessary..This training will include use of the SMARTS criteria in establishing corrective actions, establishing due dates, justifying schedule extensiqns, and doeumenting closure. [nitiative 6: Corrective Action lmplementation and Closurel October 30, 2010 Eembr:l.;.2ggg Failed CRB due to need to expand population of individuals trained. CAP Coordinators and Corrective Action Review Board Members were trained prior to Decernber 31, 2009, but not all required managers and supervisors were trained by that date. Divisiohs that are not cunently meeiing Nuclear Notification backlog goals will develop actiong plan+to meet divisional goals. [nitiative 6: Corrective Action lmplementation and Closurel April 15.2010 Deeember-+O'-gg9 Failed CRB due tc fact that initial actions to reduce goals had not been put into divisional plans. Actions succeedecl in meeting 2009 Backlog has since risen above 2009 goal. Actions being developed to meet 2010

Failed CRB based on failure to meet goals for completion of CRBs in a timely fashion, ' Julv 31, 201Q eebFsary++2S+0 irins + Develop and implement aciions to reduce tirne fgr compleiion of Closure Review Boards (ORBs) so that thev are normally completed within 30 days of action completion as indicated in SAP, Establish mechanism to provide visibility and accountability for items not adhering to ihe schedule. Ilnitiative 6: Corrective Action lmplementation and Closure B. Additional Actions ln iis subrnittal, dated October 30, 2009, Southern California Edison Company noted that Initiative g-Trending, was under development and initial actions to be included within it would be established by {a,quary.23, 2010, The following actions have been added to lnitiative 9. June 30, 201 0 Develop Trending Training to [nclude: (1) Division trending responsibilities, (2) Trending applicabil ity and timeliness standards, (3) Trend Code structure, (4) Trend code modification, (5) Entering trending data into ActionlVay, (6)Adverse trend identification, and (7)Tronding June 30, 201 0 Develop a Personnel Qualification Standard (POS) for designated trending personnel. The PQS is to include: (a) Classroom training, and (b) Completion oi a praciical demonstration with Performance }}