ML102810670
| ML102810670 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/07/2010 |
| From: | Hay M Division of Reactor Safety IV |
| To: | Sheppard J Southern California Edison Co |
| References | |
| FOIA/PA-2011-0221 IR-10-006 | |
| Download: ML102810670 (6) | |
See also: IR 05000361/2010006
Text
October 7, 2010
Mr. James J. Sheppard
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:
ERRATA - SAN ONOFRE NUCLEAR GENERATING STATION -
NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION
REPORT 05000361/2010006; 05000362/2010006 AND NOTICE OF VIOLATION
Dear Mr. Sheppard:
Please replace page 10 of the Summary of Findings section as well as page 38 of the Report
Details in NRC Inspection Report 05000361/2010006; 05000362/2010006, dated July 30, 2010,
with the enclosed revised pages. These changes are needed to correct a typographical error
listing the crosscutting aspect of the finding involving inadequate procedures for radiation
monitoring of the component cooling water. Specifically, the error is that the crosscutting aspect
is listed as P.1(c), when it should be P.1(a). The description of the crosscutting aspect is
correct.
Sincerely,
/RA/ Dale A. Powers for
Michael C. Hay, Chief
Technical Support Branch
Division of Reactor Safety
Dockets: 50-361; 50-362
UNITED STATES
NUCLEAR REGULATORY COMMISSION
R E GI ON I V
612 EAST LAMAR BLVD, SUITE 400
ARLINGTON, TEXAS 76011-4125
Southern California Edison Company
- 2 -
cc:
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
Gary H. Yamamoto, P.E., Chief
Division of Drinking Water and
Environmental Management
1616 Capitol Avenue, MS 7400
P.O. Box 997377
Sacramento, CA 95899-7377
Michael L. DeMarco
San Onofre Liaison
San Diego Gas & Electric Company
8315 Century Park Ct. CP21C
San Diego, CA 92123-1548
Director, Radiological Health Branch
State Department of Health Services
P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414
The Mayor of the City of San Clemente
100 Avenida Presidio
San Clemente, CA 92672
James D. Boyd, Commissioner
California Energy Commission
1516 Ninth Street (MS 34)
Sacramento, CA 95814
Southern California Edison Company
- 3 -
Douglas K. Porter, Esquire
Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, CA 91770
Doug Bauder
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Steve Hsu
Department of Health Services
Radiologic Health Branch
MS 7610, P.O. Box 997414
Sacramento, CA 95899-7414
R. St. Onge
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
Chief, Technological Hazards Branch
FEMA Region IX
1111 Broadway, Suite 1200
Oakland, CA 94607-4052
Institute of Nuclear Power Operations (INPO)
Records Center
700 Galleria Parkway SE, Suite 100
Atlanta, GA 30339
Southern California Edison Compan
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10/4/2010
10/7/2010
OFFICIAL RECORD COPY
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-10- Enclosure 2
Notification 200871387, and actions were implemented to require periodic
grab sampling of the train which was not being monitored.
The inspectors determined that this finding was more than minor because
this issue impacted the Public Radiation Protection Cornerstone and its
objective to ensure adequate protection of public health and safety from
exposure to radioactive materials released into the public domain as a
result of routine civilian nuclear reactor operation. Specifically, the
radiation monitors for component cooling water were not sufficient to
ensure adequate release measurements. The inspectors evaluated the
significance of this finding using Phase 1 of Inspection Manual Chapter 0609.04 and determined that the finding screened to Inspection
Manual Chapter 0609, Appendix D, Public Radiation Safety Significance
Determination Process. The inspectors evaluated the significance of this
finding using Inspection Manual Chapter 0609, Appendix D, and
determined that the finding was of very low safety significance (Green)
because dose did not exceed Appendix I criteria. This finding was
determined to have a crosscutting aspect in the area of problem
identification and resolution associated with the corrective action program
in that the plant operators did not have a low threshold for identifying
deficiencies in procedures. P.1(a)(Section 4OA2.5g)
Cornerstone: Miscellaneous
Severity Level IV. The inspectors identified a Severity Level IV noncited
violation of 10 CFR 50.73, Licensee Event Report System, in which the
licensee failed to submit a licensee event report within 60 days following
discovery of an event meeting the reportability criteria. On
January 26, 2010, the valve which isolates nonseismic piping from
condensate storage tank T-120 failed its in-service test when the hand
wheel stem snapped after a leveraging device was used in an attempt to
close the valve. This isolation valve, 2HV5715, must be closed within 90
minutes of an operating basis earthquake in order to prevent the loss of
condensate storage tank T-120 water inventory from a line break in the
nonseismic portion of the condensate system. The failure of this valve
resulted in a condition prohibited by Technical Specification 3.7.6 and
therefore was reportable. This finding was entered into the licensees
corrective action program as Nuclear Notification 200888616, and the
licensee was taking actions to send a licensee event report to the NRC
for this event.
The inspectors determined that traditional enforcement was applicable to
this issue because the NRC's regulatory ability was affected. Specifically,
the NRC relies on the licensee to identify and report conditions or events
meeting the criteria specified in regulations in order to perform its
regulatory function. The inspectors determined that this finding was not
suitable for evaluation using the significance determination process, and
-38- Enclosure 2
sufficient to ensure adequate release measurements. The inspectors evaluated
the significance of this finding using Phase 1 of Inspection Manual
Chapter 0609.04 and determined that the finding screened to Inspection Manual
Chapter 0609, Appendix D, Public Radiation Safety Significance Determination
Process. The inspectors evaluated the significance of this finding using
Inspection Manual Chapter 0609, Appendix D, and determined that the finding
was of very low safety significance because dose did not exceed Appendix I
criteria. This finding was determined to have a crosscutting aspect in the area of
problem identification and resolution associated with the corrective action
program in that plant operators did not have a low threshold for identifying
deficiencies in procedures. P.1(a)
Enforcement. Technical Specification 5.5.1.1.a. requires, in part, that written
procedures be established, implemented, and maintained covering the activities
specified in Appendix A, Typical Procedures for Pressurized Water Reactors
and Boiling Water Reactors, of Regulatory Guide 1.33, Quality Assurance
Program Requirements (Operations), dated February 1978; Section 7.g requires
procedures for radiation monitoring operation. Contrary to the above, prior to
April 22, 2010, the licensee failed to establish procedures for component cooling
water system alignments that would prevent unmonitored leakage to the
environment through leakage into the Salt Water Cooling system. Because the
violation was of very low safety significance and was entered into the corrective
action program as Nuclear Notification 200871387, this violation is being treated
as noncited violation, consistent with the NRC Enforcement Policy VI.A:
NCV 05000361/2010006-07, Failure to Establish Component Cooling Water
Radiation Monitoring Procedures.
h.
Failure to Revise Procedures with Known Technical Errors
Introduction. The inspectors identified a cited violation of Technical
Specification 5.5.1.1a for the failure to maintain written procedures covered in
Regulatory Guide 1.33. Specifically, as of April 2010, the licensee failed to
properly control procedure changes associated with plant modifications resulting
in procedures with known technical deficiencies being used at the facility.
Description. On April 8, 2010, the inspectors reviewed corrective actions from
two previous noncited violations for the licensees failure to maintain procedures.
The first noncited violation was 05000361:05000362/2009003-02 and was
associated with the licensees failure to implement controls over its backlog of
procedure change requests such that procedures with known technical
deficiencies were in use in the field (before being revised). The second noncited
violation was 05000361:05000362/2009009-02 and also involved the licensees
failure to implement controls over its backlog of procedure change requests such
that procedures with known technical deficiencies were in use in the field.
During this inspection, the inspectors identified that the backlog of procedure
change requests had increased to 3,389. The inspectors identified that most of
these procedure changes were appropriately classified according to the TEAM