IR 05000361/2008007

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Letter to Ross Ridenoure, Subject: San Onofre Nuclear Generating Station, Units 2 & 3 Site-Specific Implementation of B.5.B Phase 2 and 3 Mitigating Strategies Temporary Instruction Inspection (NRC Inspection Report 05000361/2008007 and 050
ML12118A141
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 10/03/2008
From: Ryan Lantz
Operations Branch IV
To: Ridenoure R
Southern California Edison Co
References
FOIA/PA-2011-0157 IR-08-007
Download: ML12118A141 (28)


Text

6YFIONI "U I SE IT- EDI ATI N UNITED STATES 0. NUCLEAR REGULATORY COMMISSION

REGION IV

612 EAST LAMAR BLVD. SUITE 400 4ý ARLINGTON, TEXAS 76011-A125 4L October 3, 2008 Mr. Ross 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: SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 -

SITE-SPECIFIC IMPLEMENTATION OF B.5.B PHASE 2 AND 3 MITIGATING STRATEGIES TEMPORARY INSTRUCTION INSPECTION (NRC INSPECTION REPORT 05000361/2008007 AND 05000362/2008007)

Dear Mr. Ridenoure:

On August 22, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed a site-specific implementation of 6.5.b, Phase 2 and 3, temporary instruction team inspection of your San Onofre Nuclear Generating Station, Units 2 and 3. The enclosed report documents the team's results, which were discussed on August 22, 2008, with Mr. A. Hochevar and other members of your staff.

The inspection examined activities conducted under your license as they relate to the implementation of B.5.b, Phase 2 and 3, mitigating strategies, your compliance with the Commission's rules and regulations, and with the condition of youroperating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.

Based on the results of this inspection, no findings of significance were identified.

\OFFI AL SE L'YSEC Information in this recor was delet4 _/

inaccordance with the Freed n wto Act, exemn tionS FOIA- r

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dM-IýýýL UýRl 4qAE61NFATI Southern California Edison Company -2 -

In accordance with 10 CFR 2,390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.cov/reading-rm/adams.html (the Public Electronic Reading Room). However, because of the sensitive information contained in the enclosure, and in accordance with 10 CFR 2.390, a copy of this letter's enclosure will not be available for public inspection.

Sincerely, IRA/

Ryan E. Lantz, Chief Operations Branch Division of Reactor Safety Dockets: 50-361; 50-362 Licenses: NPF-10; NPF-15 Nonpublic

Enclosure:

Inspection Report 05000361/2008007; 05000362/2008007 w/Attachment: Supplemental Information

REGION IV==

Docket: 50-361, 50-362 Licenses: NPF-10, NPF-15 Report No.: 05000361/2008007; 05000362/2008007 Licensee: Southern California Edison Co. (SCE)

Facility: San Onofre Nuclear Generating Station, Units 2, 3 Location: 5000 S. Pacific Coast Hwy.

San Clemente, California Dates: August 18-22, 2008 Inspectors: C. Osterholtz, Senior Resident Inspector, Projects Branch D M. Parker, Senior Engineer, Office of Nuclear Reactor Regulation M. Baquera, Reactor Inspector, Projects Branch D, Approved By: Ryan E. Lantz, Chief Operations Branch Division of Reactor Safety-1 - Enclosure OFFI SE ON - S URI TrED RMATION

OFF LUS N SUI-(ELA D FOýRAT N SUMMARY OF FINDINGS IR 05000361/2008007 and 05000362/2008007; 08/18/2008 - 08/22/2008; San Onofre Nuclear Generating Station; Temporary Instruction 2515/171, "Verification of Site Specific Implementation of B.5.b Phase 2 and 3 Mitigating Strategies."

This report covered a 5-day announced inspection in accordance with Temporary Instruction 2515/171, "Verification of Site Specific Implementation of B.5.b Phase 2 and 3 Mitigating Strategies." The inspection was conducted by a Region IV senior resident inspector, a Office of Nuclear Reactor Regulation inspector, and assistance was provided by one acting NRC site resident inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1 649, "Reactor Oversight Process,"

Revision 4, dated December 2006.

A. NRC-Identified and Self-Revealing Findings No findings of significance were identified.

B. Licensee-Identified Violations No findings of significance were identified.

-2- Enclosure O2F EnIINosure

Report Details 4. Other Activities 40A5 Other Activities (Temporary Instruction 2515/171)

The objective of Temporary Instruction 2515/171, "Verification of Site-Specific Implementation of B.5.b Phase 2 & 3 Mitigating Strategies," is to verify that the commitments for implementing the Phase 2 and 3 strategies were completed by the licensee. The strategies for pressurized water reactors, such as San Onofre Nuclear Generating Station, are listed in Table 1 of the temporary instruction. Inspection of all strategies listed in Table 1 was necessary to complete this temporary instruction. The team discussed the strategies with plant staff, reviewed documentation, and, where appropriate, performed plant walk downs to evaluate whether the strategies could be implemented as stated in the licensee's submittals and the NRC safety evaluation report.

For most strategies, this included verification that the strategy was feasible, procedures, and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the inspection activities are described below in the following sections.

I1 Proqram Reviews a. Inspection Scope Procedures: The team examined and discussed with various plant personnel all of the station's established guidelines and implementing procedures for the B.5.b mitigation strategies. The team assessed how the licensee coordinated and documented the interface and transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with equipment operators and licensed operators to examine the adequacy and completeness of the procedures; the familiarity of the operators with the procedure objectives and specific guidance; the staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios. The team also examined San Onofre Nuclear Generating Station's plans and guidance associated with coordination/ ,.,,,=

jcomcincieni wom iftieg~nato oT tne-B..b. mitigation strategies.

En.qineerinq Evaluations and Calculations: The team reviewed the licensee's supporting engineering evaluations and calculations prepared as the basis to provide assurance that thel (b)(7)(F)

-3- Enclosure F1\Aý IC -S ýCUIýTY- ýTE ýF ATl

SC IAU OýL ýSE ýRI - LA D RM ýN I(b)(7)(F) I by Nuclear Energy Institute 06-12, "B.5.b Phase 2 & 3 Submittal Guideline," Revision 2, dated December 2006. The team discussed these calculations and evaluations with the responsible engineers, independently reviewed the adequacy of selected calculations and engineering assumptions, and conducted field verifications to compare the assumed configurations with the as-found and postulated bounding configurations.

Maintenance and Testing of Equipment: The team reviewed licensee plans and programs for periodic maintenance and testing of the equipment specified for B.5.b applications to ensure continued reliability and minimum unavailability.

b. Findings-4- Enclosure 0 I ALU OLY- RITYRLAT I ORAON

A No findings of sig nificance were n (b)(7)(F)

,2 Individual Strategy Reviews

.2.1\ (b)(7)(F)

-5 - Enclosure FF IA USE LY SECURI -- LAT IN OR TI N

  • 1 a. Inspection Scope Through discussions with plant staff, review of documentation, and plant walk downs, the team examined the following areas of interest:

(b)(7)(F)

Adequacy of guidance provided in the plant procedure(s)

9 Adequacy of training provided to staff b. Findinqs No findings of significance were identified.

.2.2 (b)(7)(F)

a. Inspection Scope Through discussions with plant staff, review of documentation, and plant walk downs, the team examined the following areas of interest:

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b. Findings

.2.3 (b)(7)(F)

-7- Enclosure

a. Inspection Scope Through discussions with plant staff, review of documentation, and plant walk downs, where appropriate, the team examined the following areas of interest:

(b)(7)(F)

  • Adequacy of training and procedure guidance b. Findings No findings of significance were identified.

.2.4-8- Enclosure

.0 (b)(7)(F)

a. Inspection Scope Through review of documentation, the team verified that these "Additional Site-Specific Strategies" were viable.

b. Findings No findings of significance were identified.

.2.5 (b)(7)(F)

a. Inspection Scope Through discussions with plant staff and review of documentation, the team verified that San Onofre Nuclear Generating Station ýQ#jLtifiedj

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b. Findings No findings of significance were identified.

.2.6 (b)(7)(F)

a. Inspection Scope Through discussions with plant staff and review of documentation, the team verified that San Onofre Nuclear Generating Station has the ability for (b)(F)(F)

b. Findings-9- Enclosure

No findings of significance were identified.

.2,7 (b)(7)(F)

a. Inspection Scope Through discussions with plant staff and review of documentation, the team verified that San Onofre Nuclear Generating Station hadi (b)(7)(F)

rhhe team also verified that training had been provided to the appropriate staff.

b. Findings No findings of significance were identified.

.2,8 a. Inspection Scope Through discussions with plant staff and review of documentation, the team verified that Generating Station hadj (b)(7)(F)h 1San Onofre (b(7() The team verified that triighs

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Deen developed and provided to the plant staff.

b. Findinqgs-10- Enclosure-10- Enclosure

V/0 ý1 U SýON -- CCIý TYY- TT I1 ýOMM (b)(7)(F)

.2.9 a. Inspection Scope Through discussions with plant staff and review of do umentation, the team verified that b(b)(7)(F) 'h-e team also verified training had been developed and provided to the plantI b. Findingqs No findings of significance were noted.

.2.10 a. Inspection Scope Through discussions with plant staff, review of documentation and plant walk downs where appropriate, the team examined the following areas of interest:

  • (b)(7)(F)

0 Adequacy of training and procedure guidance-11 - Enclosure 4FICIAL EILY-ECURY-lLATbI 0 A

b. Findings No findings of significance were identified.

.2.11 a. Inspection Scope Through discussions with plant staff, review of documentation and plant walk downs where appropriate, the team examined the following areas of interest:

(b)(7)(F)

(

Adequacy of training b. Findings No findings of significance were identified. However, the team did make the following observation regarding thel(b)(7)(C)

(b)(7)(F)

-12- Enclosure

"0 I A ýUS ýON ý- SU ý- RA DI OR ýT

(b)(7)(F)

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.2.12 l, ,1 a. Inspection Scope Through discussions with plant staff, review of documentation and plant walk downs, where appropriate, the team examined the following areas of interest:

(b)(7)(F)

Adequacy of training and procedure guidance b. Findings No findings of significance were identified. However, h emnt (b)(7)(F)

I4C L U.EON Y -S CU ýY- LAT DIN O ýI

.2.13 (b)(7)(F)

a. Inspection Scope Through discussions with plant staff, review of documentation and plant walk downs, where appropriate, the team examined the following areas of interest:

[(b)(7)(F)

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  • Adequacy of training b. Findincis No findings of significance were identified. However, the team did make the following observation regarding the l(b)(7)(F)

(b)(7)(F)

-14- Enclosure 0 ICLUS Y-S TYRE DNF TI

.2.14 a. Inspection Scope Through discussions with plant staff, review of documentation and plant walk downs, where appropriate, the team examined the following areas of interest:

(b)(7)(F)

-15- Enclosure

N

'

  • (b)(7)(F)

0 Adequacy of training and procedure guidance b. Findings No findings of significance were identified. However, the team did make the following observation regarding (b)(7)(F)

(b)(7)(F)

.2.15 (b)(7)(F)

a. Ins oection Scorpe Through discussions with plant staff, review of documentation and plant walk downs, where appropriate, the team examined the following areas of interest:

0 (b)(7)(F)

S

-16- Enclosure FII 0 S I- L

" Equipment (valves, etc.) required to be operated to implement this strategy have been identified

" Adequacy of training and procedure guidance b. Findings No findings of significance were identified. However, the team did make the following observation regarding (b)(7)(C)

(b)(7)(F)

.2.16 a. Inspection Scope Through discussions with plant staff, review of documentation and plant walk downs, where appropriate, the team examined the following areas of interest:

9 (b)(7)(F)

- 17- Enclosure

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I(b)(7)(F)

0 0 Adequacy of training b. Findings No findings of significance were identified.

.2.17 Disposition of Site Specific Enhancement Strategies: Additional readily available measures and candidate enhancement strategies described in the safety evaluation report were documented by the licensee and reviewed by the staff. For those strategies determined to be viable, the licensee developed procedures and conducted training on their use.

a. Inspection Scope ] (b)(7)(F)

A total of jtb)(7)(F) amitig trategies are identified. LFlare identified as (b)(7)(F) implemented. --The remaining Iwere to be listed for reference in appropriate guidance documents. The team sample el(b)(7)(F) Iand confirmed that they were in fact either (b)(7)(F) or (b)(7)(F)

-18- Enclosure F L LY- 1 0

b. Findings No findings of significance were identified.

40A6 Meetings, Including Exit Exit Meeting Summary On August 22, 2008, the team presented the preliminary inspection results to Mr. A.

Hochevar and other San Onofre Nuclear Generating Station personnel. The team stated that they had reviewed proprietary information during the inspection and verified that all material had been returned to the licensee. The licensee acknowledged the inspection results as presented.

ATTACHMENT: SUPPLEMENTAL INFORMATION-19- Enclosure OFF IA USEO L -SECURI LATEDI M I N

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SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel R. Ridenoure, Vice President, Nuclear Generation B. Ashbrook, Manager, Emergency Preparedness D. Axline, Technical Specialist, Nuclear Regulatory Affairs B. Corbett, Manager, Performance Improvement J. Dahl, Manager, Design and Procedure Review D. Ensminger, Manager, Fire Protection Services J. Fee, Manager, Emergency Preparedness S. Gardner, Engineer, Nuclear Regulatory Affairs J. Hirsch, Manager, Maintenance K. Johnson, Manager, Design Engineering M. Johnson, Manager, Support Services L. Kelly, Engineer, Nuclear Regulatory Affairs M. Kelly, Engineer, Nuclear Regulatory Affairs M. McBrearty, Compliance Engineer, Nuclear Regulatory Affairs D. Pilmer, Project Manager, Nuclear Regulatory Affairs N. Quigley, Manager, Mechanical/Nuclear Maintenance Engineering J. Reilly, Vice-President, Engineering and Technical Services R. Richter, Engineering Supervisor, Fire Protection S. Root, Project Manager, Nuclear Regulatory Affairs A. Scherer, Manager, Nuclear Regulatory Affairs A. R. Shean, Manager, Nuclear Oversight R. St. Onge, Manager, Maintenance and Systems Engineering D. Pilmer, Project Manager, Nuclear Regulatory Affairs K. K. Strand, Manager, Site Emergency Preparedness T. Vogt, Manager, Special Projects K. Wells, Engineer, NSSS Systems D. Wilcoxin, Manager, Operations Training C. Williams, Manager, Compliance T. Yackle, Manager, Operations A-1 Attachment 0 FICI L U EONL - ECURI - ELAT I FOR AT N

LIST OF DOCUMENTS REVIEWED Calculations CALCULATION TITLE REVISION (b)(7)(F)

A-2 Attachment

Procedures PROCEDURE TITLE REVISION r(b)(7)(F)

A-3 Attachment

,r ,' I',

PROCEDURE TITLE REVISION (b)(7)(F)

Drawings and Diagrams DRAWING TITLE REVISION (b)(7)(F)

A-4 Attachment ICI U NL - CURl RELAT D FO A0

DRAWINGF TITLE REVISION (b)(7)(F)

A-5 Attachment

iI.

OF LClA /SE NLY - S RITY- LATE NFOR ATIO DRAWING TITLE REVISION (b)(7)(F)

Notifications (b)(7)(F)

Other Documents (b)(7)(F)

SO 123-0-Al, "Conduct of Operations", Revision 14 A-6 A tachment IT-LATýED ýFO ATIO O0ff ýIAL ýUSE ýON ý-SEC