ML12095A287
| ML12095A287 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/02/2012 |
| From: | St.Onge R Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML12095A287 (5) | |
Text
JSOUTHERN CALIFORNIA EDISON An EDISON INTERNATIONALS Company Richard I. St. Onge Director, Nuclear Regulatory Affairs and Emergency Planning 10 CFR 50.4 April 2, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
Docket Nos. 50-206, 50-361, 50-362, and 72-41 Summary Report of Commitment Changes Implemented During the Period From March 18, 2011, Through March 28, 2012 San Onofre Nuclear Generating Station (SONGS) Units 1, 2 and 3, and the Independent Spent Fuel Storage Installation
Dear Sir or Madam:
The purpose of this letter is to provide a summary of commitments changed during the period from March 18, 2011, through March 28, 2012, pursuant to the guidance in Nuclear Energy Institute (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes," Revision 0.
No changes were made to regulatory commitments; however, changes were made to proposed actions described in previous correspondence to the NRC related to safety culture issues.
Although not considered formal regulatory commitments, SONGS has included these changes for your information in Attachment 1.
This letter does not Contain any new commitments. If you have any questions or would like any additional information, please contact Mr. Ryan I. Treadway at (949) 368-9985.
ly,
Attachment:
As stated cc:
E. E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, SONGS Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3 J. C. Shepherd, NRC Project Manager, San Onofre Unit 1 C. Staab, NRC Project Manager, San Onofre ISFSI P.O. Box 128 San Clemente, CA 92672
ATTACHMENT 1 -
SUMMARY
OF CHANGES TO PROPOSED ACTIONS DESCRIBED IN PREVIOUS CORRESPONDENCE TO NRC IMPLEMENTED DURING THE PERIOD FROM MARCH 18, 2011 THROUGH MARCH 28, 2012 SONGS Tracking Nos.
Source(s)
Proposed Action Change Summary and Basis for Change Change #327 NRCTS 2009-10-024 SIBP 4.3.3.A NN 201709846 SCE letter to NRC, dated October 30, 2009, Response to NRC Mid-Cycle Performance Review Letter SCE letter to NRC, dated October 12, 2010, Response to the NRC Letter Regarding Mid-cycle Performance Review and Inspection Plan The following action was stated in the October 30, 2009, letter: "(CAPR) Develop [and implement] a case study presentation that incorporate 10CFR50, Appendix B, Criterion V (for procedure usage), the safety culture aspect of decision making, risk associated with task performance, and events where workers made decisions to not follow the process (e.g.
the battery event for notification of the control room) to illustrate the importance of using human performance tools to minimize the chance of an error leading to a significant event. Initiate the first presentation by 3/30/2010. Included with this corrective action presentation is a requirement to address the same topics annually through the end of 2011 for supervisors and above."
The words "and implement" were previously added to the action in the October 12, 2010, letter to the NRC.
The action was modified to provide more in-depth training and consolidate with Institute of Nuclear Power Operations (INPO) Significant Operating Experience Report (SOER) 10-02 training actions. The modified action is as follows:
"Develop and implement a case study presentation that incorporates 10CFR50, Appendix B, Criterion V (for procedure usage), the safety culture aspect of decision making, risk associated with task performance, and events where workers made decisions to not follow the process (e.g.
the battery event for notification of the control room) to illustrate the importance of using human performance tools to minimize the chance of an error leading to a significant event. Initiate the first presentation by 3/30/2010. From 2011 forward, this action will rely upon the station 's commitment for case study training for leadership according to its response to INPO SOER 10-02, Recommendation 1.a. This aspect of ongoing case study sessions after 2010 is beyond the scope of this CAPR and not subject to Closure Review or Effectiveness Review requirements for the CAPR."
Page 1 of 4
ATTACHMENT 1 -
SUMMARY
OF CHANGES TO PROPOSED ACTIONS DESCRIBED IN PREVIOUS CORRESPONDENCE TO NRC IMPLEMENTED DURING THE PERIOD FROM MARCH 18, 2011 THROUGH MARCH 28, 2012 SONGS Tracking Nos.
Source(s)
Proposed Action Change Summary and Basis for Change Change #328 NRCTS 2009-04-021 SIBP 5.5.1.A NN 201575187 NN 201406432 SCE letter to NRC, dated April 21, 2009 Response to Annual Assessment Letter SCE letter to NRC, dated October 30, 2009, Response to NRC Mid-Cycle Performance Review Letter SCE Letter to the NRC, dated March 31, 2010 Response to NRC Mid-Cycle Performance Review Letter SCE Letter to the NRC, dated March 25, 2011 Summary Report of Commitment Changes Implemented During the Period From December 19, 2008, Through March 17, 2011 The original proposed action was stated in the April 21 and October 30, 2009, letters to the NRC.
Subsequently, the action statement was modified and the due date was changed from December 31, 2009 to December 31, 2010, in SCE letter to NRC, dated March 31, 2010. Finally, in a letter dated March 25, 2011, the due date was extended to May 8, 2011 to allow additional time to meet the action closure criteria.
The revised action was stated as follows:
"As an interim action, the station is using external personnel with cause evaluation experience, including experience with evaluation of extent of cause and extent of condition, to coach station personnel in achieving industry levels of cause evaluation timeliness and quality. This action will close when station performance is satisfactory and sustainable per metrics established for timeliness and quality and without the assistance of external personnel. The metrics will monitor the station's ability to perform evaluations within 30 days, and achieve quality using cause evaluation grading criteria with independent review."
The action was modified again to delete the reference to specific metric criteria because the performance indicators, CE Quality and RCE and ACE timeliness already establish performance measures for satisfactory performance. In addition, the due date was extended to January 13, 2012 to allow additional time to meet the closure criteria.
The modified action is as follows:
"As an interim action, the station is using external personnel with cause evaluation experience, including experience with evaluation of extent of cause and extent of condition, to coach station personnel in achieving industry levels of cause evaluation timeliness and quality."
Page 2 of 4
ATTACHMENT 1 -
SUMMARY
OF CHANGES TO PROPOSED ACTIONS DESCRIBED IN PREVIOUS CORRESPONDENCE TO NRC IMPLEMENTED DURING THE PERIOD FROM MARCH 18, 2011 THROUGH MARCH 28, 2012 SONGS Tracking Nos.
Source(s)
Proposed Action Change Summary and Basis for Change Change #329 NRCTS 2009-04-067 SIBP 4.2.11.S NN 201502562 SCE letter to NRC, dated April 21, 2009 Response to Annual Assessment Letter The following action was stated in the April 21, 2009, letter to the NRC:
"SCE is also establishing a process for periodic evaluation of effectiveness in improving PI&R and HU performance, which will be governed by a formal procedure. Under this process:
- 1. Quarterly effectiveness reviews will be conducted of progress in improving PI&R and HU performance.
- 2. The quarterly effectiveness reviews will consider the timeliness and quality of improvement implementation, and will include examination of metrics, CAP data, and assessment/inspection results related to each area.
- 3. Each review will be conducted by an Effectiveness Review Board (ERB) consisting of a senior member of SONGS management not directly responsible for the implementation of the HU or PI&R action plan; the Director, Special Projects or designee, and an experienced non-SCE member. Prior to the quarterly reviews, the ERB will be provided with a report summarizing action completion, progress, and challenges in each area. The owner of each plan will also make a formal presentation to the ERB using a prescribed agenda.
- 4. During its reviews, the ERB will identify any "check and adjust" actions needed to meet improvement goals, and the completion of those actions will be tracked to completion. "
The wording of the statement under number 3 was modified to delete "...and an experienced non-SCE member."
This change was made because after 2 years with an experienced non-SCE member on the board, SCE is ready to take full ownership and accountability of the effectiveness review process.
Page 3 of 4
ATTACHMENT 1 -
SUMMARY
OF CHANGES TO PROPOSED ACTIONS DESCRIBED IN PREVIOUS CORRESPONDENCE TO NRC IMPLEMENTED DURING THE PERIOD FROM MARCH 18, 2011 THROUGH MARCH 28, 2012 SONGS Tracking Nos.
Source(s)
Proposed Action Change Summary and Basis for Change Change #330 SCE letter to NRC, SCE submitted a letter, dated October 12, 2010, to The description of the Labor Grievance metric NRCTS 2010-10-177 dated October 12, the NRC in response to the September 1, 2010 was modified to the following:
NN 201454669-0002 2010, Response to the Mid-cycle Performance Review letter.
NRC Letter Regarding "Labor Grievances - The number of new Mid-cycle On page 10 of the October 12, 2010 letter, the grievances received each month that may Performance Review following description was provided for the Labor indicate an impact to the Safety Conscious and Inspection Plan Grievance metric to be used as a performance Work Environment."
measure for the SCWE Crosscutting Theme:
The new metric provides management a "Labor Grievances - The number of open second and significantly improved snap-shot of current third step grievances that map to GWE trend codes."
issues. By assessing each grievance and focusing on potential SCWE impact, rather than the more general work environment issues, management has greater visibility of potential workforce trends and their extent.
Change #331 SCE letter to NRC, The original proposed action was stated in the April The wording of this action was modified to NRCTS 2009-10-083 dated April 21, 2009, 21, 2009 letter and subsequently modified in the indicate the metric "CAP Notifications/Orders NN 201723984 Response to Annual October 30, 2009 letter as follows:
>=2 Years Backlog/Workoff" was superseded Assessment Letter by the following metrics that are currently "SCE has established a set of performance metrics to monitored in the station Management Review SCE letter to NRC, measure progress in improving PI&R at SONGS.
Meeting:
dated October 30, These metrics include:
2009, Response to (1) Corrective Actions - Open & percent NRC Mid-Cycle 0
Notifications Generated and Open overdue Performance Review 0
CAPRs Open and Open > 180 Days (2) Corrective Actions - Average age Letter 0
Cause Evaluation Corrective Actions Open and (3) Cause Evaluation Corrective Actions Open Percent Overdue and Percent Overdue Corrective Actions Open and Percent Overdue (4) Condition Reports Generated Average Time to Perform Cause Evaluations (5) Condition Reports Open Cause Evaluation Quality (6) Plant Maintenance Total Backlog CAP Notifications/Orders >=2 Years Backlog/Workoff Closure Review Results Operability Determination Quality" Page 4 of 4