IR 05000361/2012008

IR 05000361-12-008, 05000362-12-008; 05/21/ 2012 - 06/8/2012; San Onofre Nuclear Generating Station Biennial Baseline Inspection of the Identification and Resolution of Problems

ML12205A416
Person / Time
Site:	San Onofre
Issue date:	07/23/2012
From:	Powers D Division of Reactor Safety IV
To:	Peter Dietrich Southern California Edison Co
vlm/Powers D
References
IR-12-008
Download: ML12205A416 (20)

Text

July 23, 2012

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000361/2012008 AND 05000362/2012008

Dear Mr. Dietrich:

On June 8, 2012, the U.S. Nuclear Regulatory Commission completed a Problem Identification and Resolution biennial inspection at your San Onofre Nuclear Generating Station. The enclosed inspection report documents the inspection results that were discussed with you and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commission's rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at San Onofre Nuclear Generating Station was effective. Licensee identified problems were entered into the corrective action program at a low threshold. Problems were effectively prioritized and evaluated commensurate with the safety significance. Corrective actions were effectively implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Lessons learned from industry-operating experience were effectively reviewed and applied, when appropriate. Audits and self-assessments were effectively used to identify problems and appropriate actions. Finally, the team verified that the licensee had established a safety-conscious work environment where workers felt free to raise safety concerns without fear of retaliation.

UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV1600 EAST LAMAR BLVDARLINGTON, TEXAS 76011-4511 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Dr. Dale A. Powers, Acting Chief Technical Support Branch Docket Nos.: 05000361, 05000362 License Nos: NPF-10, NPF-15 Enclosure: 1. Inspection Report 05000361/2012008 and 05000362/2012008 w/ Attachment: Supplemental Information

Electronic Distribution to SONGS

ML12205A166 SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials HAF Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials HAF SRI:DRS/TSB RI:DRS/EB1 RI:DRP/ANO OE:DRS/OB PE:DRP/PBD Acting C:DRS/TSB HAFreeman JDBraisted JRotton DGStrickland DDYou DAPowers /RA/ /E-Mail/ /E-mail/ /E-mail/ Per Telecon /RA/ 7/23/2012 7/23/2012 7/23/2012 7/23/2012 7/23/2012 7/23/2012 C:DRP/PBD Acting C:DRS/TSB RELantz DAPowers /NHT for/ /RA/ 7/23/2012 7/23/2012

- 1 - Enclosure OFFICIAL RECORD COPY U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000361, 05000362 License: NPF-10, NPF-15 Report: 05000361/2012008 and 05000362/2012008 Licensee: Southern California Edison Facility: San Onofre Nuclear Generating Station Location: 4 miles SE of San Clemente, California Dates: May 21 through June 8, 2012 Team Leader: Harry A. Freeman, Senior Reactor Inspector Inspectors:

Dr. Jonathan D. Braisted, Reactor Inspector Jeff Rotton, Resident Inspector Duane G. Strickland, Operations Engineer David D. You, Project Engineer Approved By: Dr. Dale A. Powers, Acting Chief Technical Support Branch Division of Reactor Safety

- 2 - Enclosure

SUMMARY OF FINDINGS

IR 05000361/2012008 and 05000362/2012008; May 21, 2012 - June 8, 2012; San Onofre Nuclear Generating Station "Biennial Baseline Inspection of the Identification and Resolution of Problems."

The team inspection was performed by a senior reactor inspector, a reactor inspector, an operations engineer, a resident inspector, and a project engineer. No findings of significance were identified during this inspection.

Identification and Resolution of Problems The team reviewed approximately 250 condition reports, work orders, engineering evaluations, root and apparent cause evaluations, and other supporting documentation to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, self-assessments, trending reports and metrics, and various other documents related to the corrective action program.

On the basis of the activities selected for review, the team concluded that implementation of the problem and identification process and the corrective action program at the San Onofre Nuclear Generating Station was effective. The licensee had a very low threshold for identifying problems and entering them in the corrective action program as evidenced by a high number of nuclear notifications generated (roughly 45,000) per year. Items were screened and prioritized in a timely manner using established criteria and were evaluated commensurate with their safety significance. The team concluded the licensee's overall implementation of actions to correct issues and prevent recurrence of issues was effective. The licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies. On the basis of focus group and individual interviews conducted during the inspection, the team concluded that the safety-conscious work environment had significantly improved since the last biennial inspection and that workers felt free to raise nuclear safety concerns via various methods without fear of retaliation.

The licensee appropriately evaluated industry-operating experience for relevance to the facility and had entered applicable items in the corrective action program. The licensee used industry-operating experience when performing root cause and apparent cause evaluations. The licensee performed effective quality assurance audits and self-assessments, as demonstrated by self identification of poor corrective action program performance and identification of ineffective corrective actions.

A. NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

The team based the following conclusions on the sample of corrective action documents that were initiated in the assessment period, which ranged from June 18, 2010, to the end of the on-site portion of this inspection on June 8, 2012.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed approximately 250 nuclear notifications including associated root cause, apparent cause, and direct cause evaluations, from approximately 94,000 that had been issued between June 18, 2010, and June 8, 2012, to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, operability determinations, self-assessments, trending reports and metrics, and various other documents related to the corrective action program. The team evaluated the licensee's efforts in establishing the scope of problems by reviewing selected logs, work requests, self-assessment results, audits, system health reports, action plans, and results from surveillance tests and preventive maintenance tasks. The team reviewed work requests and attended the licensee's daily action review committee pre-screening and the management review committee meetings to assess the reporting threshold, prioritization efforts, and significance determination process, as well as observing the interfaces with the operability assessment and work control processes, when applicable. The team's review included verifying the licensee considered the full extent of cause and extent of condition for problems, as well as how the licensee assessed generic implications and previous occurrences. The team assessed the timeliness and effectiveness of corrective actions, completed or planned, and looked for additional examples of similar problems.

The team also reviewed corrective action documents that addressed past NRC-identified violations to ensure that the corrective action addressed the issues as described in the inspection reports. The inspectors reviewed a sample of corrective actions closed to other corrective action documents to ensure that corrective actions were appropriate and timely.

The team considered risk insights from both the NRC's and San Onofre Nuclear Generating Station risk assessments to focus the sample selection and plant tours on risk significant systems and components. The team selected the following risk significant systems: safety and non-safety related inverters and battery chargers, and emergency core cooling systems pumps.

The samples reviewed by the team focused on, but were not limited to, these systems. The team also expanded their review to include five years of evaluations involving the inverters and battery chargers to determine whether problems were being effectively addressed. The team conducted a walkdown of these systems to assess whether problems were identified and entered into the corrective action program.

b.

Assessments 1. Assessment - Effectiveness of Problem Identification

The team concluded that the licensee identified issues and adverse conditions in accordance with the licensee's corrective action program guidance and NRC requirements. The team noted that licensee personnel had a very low threshold for entering issues into nuclear notification system (corrective action program) as evidenced by the more than 94 thousand notifications issued during the two year review cycle. The team did not identify any deficiencies in the area of problem identification for the samples reviewed.

2.

Assessment - Effectiveness of Prioritization and Evaluation of Issues The team concluded that the licensee in general effectively prioritized and evaluated conditions adverse to quality. The team found that even with the high number of notifications initiated on a daily basis, licensee's daily action review committee pre-screening and the management review committees effectively assessed each condition adverse to quality. The team reviewed a number of notifications that involved operability reviews to assess the quality, timeliness, and prioritization of operability assessments. In general, both immediate and prompt operability assessments reviewed were adequately completed in a timely manner.

3.

Assessment - Effectiveness of Corrective Action Program Overall, the team concluded that the licensee had an effective corrective action program where conditions adverse to quality were promptly identified, prioritized, evaluated, and corrected in a timely manner commensurate to safety significance.

The team identified two adverse trends indicative of the program's effectiveness that were resolved by the licensee over the inspection period. The first trend involved a large number of deficiencies identified for failure to adequately control contractors. The licensee initiated process changes in the Fall of 2011 that reduced the number of errors significantly. The second trend involved work hour rule violations. Again, the licensee initiated process changes and significantly reduced the number of violations and eliminated repetition of minimum days off violations.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team examined the licensee's program for reviewing industry-operating experience, including reviewing the governing procedure and self-assessments.

A sample size of 14 operating experience notifications that had been issued during the assessment period were reviewed to assess whether the licensee had appropriately evaluated the notifications for relevance to the facility. The team then examined whether the licensee has entered those items into its corrective action program and assigned actions to address the issues. The team reviewed a sample of root cause evaluations and corrective action documents to verify if the licensee had appropriately included industry-operating experience.

b.

Assessment Overall, the team determined that the licensee was adequately evaluating industry-operating experience for relevance to the facility. Corrective action documents considered operating experience in the cause and resolution evaluations. The licensee had entered applicable items in the corrective action program in accordance with station procedures. Both internal and external operating experience was being incorporated into lessons learned for training and pre-job briefs.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample of licensee self-assessments, surveillances, and audits to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The team reviewed audit reports to assess the effectiveness of assessments in specific areas. The team evaluated the use of self- and third party assessments, the role of the quality assurance department, and the role of the performance improvement group related to licensee performance. The specific self-assessment documents reviewed are listed in the Attachment.

b. Assessment The team concluded that the licensee had an effective self-assessment and audit process. Licensee management was involved with developing tactical self-assessments. The team determined self-assessments were self-critical and thorough enough to identify deficiencies.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspection team conducted six focus group interviews with typically ten individuals per group. The focus groups consisted of workers from the nuclear boiler and condenser, design engineering, health physics, instrumentation and controls, project management, and operations organizations. Individuals were randomly selected by the NRC to assure representative outcomes for the interviews. The inspection team also conducted individual interviews. The interviewees represented various functional organizations and ranged across contractor, staff, and supervisor levels. The team conducted these interviews to assess whether conditions existed that would challenge the establishment of a safety-conscious work environment at San Onofre Nuclear Generating Station.

b. Assessment The inspection team concluded that the licensee had established a safety-conscious work environment where individuals felt free to raise safety concerns both to the licensee and to the NRC without fear of retaliation. Responses to questions and topics during the focus group sessions did not reveal any sense that safety was not the highest priority. All organizations indicated that the work environment had changed significantly from just over two years ago when the NRC identified a challenged safety-conscious work environment and issued a chilling effects letter. On the basis of focus group and individual interviews conducted during the inspection, the team concluded that the safety-conscious work environment had significantly improved since the last biennial inspection and that workers felt free to raise nuclear safety concerns via various methods without fear of retaliation.

4OA6 Meetings

Exit Meeting Summary

On June 8, 2012, the team presented the inspection results to Mr. Peter Dietrich, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee staff acknowledged the issues presented. The inspectors asked the licensee staff whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations

None ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

P. Dietrich - CNO D. Bauder - VP, Station Manager T. McCool - Plant Manager

R. Corbett - Director, Performance Improvement

R. St. Onge - Director, Regulatory Affairs

D. Yarbrough - Director, Operations

J. Madigan - Director, Nuclear Safety Culture

B. Sholler - Director, Maintenance

B. Winn - Director, Finance Management

E. Avella - Director, Project Management Organization

J. Pyles - Director, IT/BI

R. Davis - Director, Nuclear Training

T. Gallaher - Manager, CAP

L. Mosher - Manager, Corporate Communications

K. Johnson - Manager, Design Engineering

O. Thomsen - Manager, Nuclear Fuels

M. Stevens - Nuclear Engineer, Inspections

J. Demlow - Supervisor, Chemistry

R. McWey - Manager, Project Oversight

M. DeMarco - Liaison, SDG&E

A. Martinez - Manager, Self-Assessments

L. Kelly - Manager, Compliance

M. Cuarenta - Technical Specialist, CAP

J. Bashore - Contractor C. Cates - Manager, Site Recovery

D. Abell - CAPCO Program Owner C. Hurn - ARC/MRC Program Owner D. Piper - Technical Specialist, Security

L. Murriel - Manager, Business Administration

M. Pawlaczyk - Technical Specialist, Inspections

NRC personnel

D. Powers - Acting Chief, Technical Support Branch G. Warnick - Senior Resident Inspector J. Reynoso - Resident Inspector

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

None

Opened and Closed

None

Closed

None

Discussed

None