ML11269A152: Difference between revisions

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| issue date = 06/21/2010
| issue date = 06/21/2010
| title = Memorandum to Leigh Trocine from Michael T. Markley, Subject: G20100287/EDATS: OEDO-2010-0358 - Briefing Package for Drop-In Visit on June 28, 2010, by Executives of Southern California Edison Company with Commissioner Apostolakis, Executiv
| title = Memorandum to Leigh Trocine from Michael T. Markley, Subject: G20100287/EDATS: OEDO-2010-0358 - Briefing Package for Drop-In Visit on June 28, 2010, by Executives of Southern California Edison Company with Commissioner Apostolakis, Executiv
| author name = Markley M T
| author name = Markley M
| author affiliation = NRC/NRR/DORL/LPLIV
| author affiliation = NRC/NRR/DORL/LPLIV
| addressee name = Trocine L
| addressee name = Trocine L
Line 72: Line 72:
The colored PI and inspection findings for this station can be viewed at the URLs listed below.SONGS, Unit 2: httro:lwww.nrc.aov/NRR/OVERSIGHTIASSESS/SANO2/sano2 chart.html SONGS, Unit 3: htto://www.nrc.aov/NRR/OVERSIGHT/ASSESS/SANO3/sano3 chart.html 44JýIAL ýUO IY -"tTIVE TE A LýFOýR6N  
The colored PI and inspection findings for this station can be viewed at the URLs listed below.SONGS, Unit 2: httro:lwww.nrc.aov/NRR/OVERSIGHTIASSESS/SANO2/sano2 chart.html SONGS, Unit 3: htto://www.nrc.aov/NRR/OVERSIGHT/ASSESS/SANO3/sano3 chart.html 44JýIAL ýUO IY -"tTIVE TE A LýFOýR6N  
--O1,96A US ONLY S TAB 6 Current Issues San Onofre Nuclear Generating Station A. EXPECTED DISCUSSION TOPICS The licensee proposed the following topics for discussion:
--O1,96A US ONLY S TAB 6 Current Issues San Onofre Nuclear Generating Station A. EXPECTED DISCUSSION TOPICS The licensee proposed the following topics for discussion:
Overview of San Onofre Nuclear Generating Station Performance History Current Regulatory Status Station Recovery Process/Strategy Upcoming Unit 3 Steam Generator Replacement Safety Conscious Work Environment Update Overview of San Onofre Nuclear Generating Station (SONGS) Units 2 and 3: Performance History and Current Regulatory Status On March 3, 2010, the NRC issued its annual assessment letter to SCE for its performance during calendar year 2009 at SONGS Units 2 and 3 (ADAMS Accession No. ML1 00621410).
Overview of San Onofre Nuclear Generating Station Performance History Current Regulatory Status Station Recovery Process/Strategy Upcoming Unit 3 Steam Generator Replacement Safety Conscious Work Environment Update Overview of San Onofre Nuclear Generating Station (SONGS) Units 2 and 3: Performance History and Current Regulatory Status On March 3, 2010, the NRC issued its annual assessment letter to SCE for its performance during calendar year 2009 at SONGS Units 2 and 3 (ADAMS Accession No. ML100621410).
The NRC staff noted that this is fifth consecutive cycle where substantive cross-cutting issues were identified in the areas of Human Performance (HP) and Problem Identification and Resolution (PI&R) and that corrective actions taken by the licensee to address these substantive cross-cutting issues have been ineffective.
The NRC staff noted that this is fifth consecutive cycle where substantive cross-cutting issues were identified in the areas of Human Performance (HP) and Problem Identification and Resolution (PI&R) and that corrective actions taken by the licensee to address these substantive cross-cutting issues have been ineffective.
The NRC noted that, while existing performance problems have persisted at the site, new ones have emerged.Throughout 2009, the licensee continued to have performance problems that challenged the operation of both units in the areas of HP and PI&R. Examples of these problems include the isolation of power to the wrong train of the emergency core coolant system (ECCS); a reactor trip caused by the failure to follow heat treat procedures and a poor pre-job briefing, and inadequate contractor oversight to ensure procedural adherence that resulted in multiple, repeat, small fires during containment tendon cutting operations.
The NRC noted that, while existing performance problems have persisted at the site, new ones have emerged.Throughout 2009, the licensee continued to have performance problems that challenged the operation of both units in the areas of HP and PI&R. Examples of these problems include the isolation of power to the wrong train of the emergency core coolant system (ECCS); a reactor trip caused by the failure to follow heat treat procedures and a poor pre-job briefing, and inadequate contractor oversight to ensure procedural adherence that resulted in multiple, repeat, small fires during containment tendon cutting operations.
In 2009, the licensee's performance resulted in an increased number of NRC findings in the areas of PI&R and HP. These substantive cross-cutting issues remain open, with additional themes being identified in each area. The licensee had initiated root cause evaluations for each of the identified themes, but corrective actions have been ineffective to date. Performance problems continue to be identified by the NRC. As of the 2009 mid-cycle assessment, four themes were open; three in HP and one in PI&R. At end of cycle 2009, three additional themes were identified, one in HP and two in PI&R, with the previous four remaining open. The current total of seven open themes is the most that any plant has had in the history of the NRC's ROP evaluation process. Detailed -information on the current ROP assessment for SONGS Units 2 and 3 is provided in Tab 5.(4)6_FPiYA -ý" C.ENSI 4fýý I \TO
In 2009, the licensee's performance resulted in an increased number of NRC findings in the areas of PI&R and HP. These substantive cross-cutting issues remain open, with additional themes being identified in each area. The licensee had initiated root cause evaluations for each of the identified themes, but corrective actions have been ineffective to date. Performance problems continue to be identified by the NRC. As of the 2009 mid-cycle assessment, four themes were open; three in HP and one in PI&R. At end of cycle 2009, three additional themes were identified, one in HP and two in PI&R, with the previous four remaining open. The current total of seven open themes is the most that any plant has had in the history of the NRC's ROP evaluation process. Detailed -information on the current ROP assessment for SONGS Units 2 and 3 is provided in Tab 5.(4)6_FPiYA -ý" C.ENSI 4fýý I \TO
_FAI AU NL -SEU E-2-Station Recovery Process/Strategv SCE plans to discuss its ongoing performance improvement efforts at SONGS. SCE developed a Site Integrated Improvement Plan (SLIP) in 2008, in part, to address the performance issues identified through NRC inspection findings and in the NRC's Confirmatory Order dated January 11, 2008 (ADAMS Accession No. ML0801 10380). SCE has revised and expanded the SLIP, to adjust for those previous actions that have been ineffective, and to incorporate recently identified issues (for example, the inclusion of a new Safety Culture Improvement Plan).Overall, the NRC staff remains concerned about the slow progress of the licensee's improvement efforts.Steam Generator Replacement SCE installed replacement steam generators (RSG) at Unit 2 during the recent refueling outage and will install RSGs in Unit 3 during the fall 2010 refueling outage. The RSGs were fabricated for both units by Mitsubishi Heavy Industries (MHI) in Japan. The Unit 2 RSGs were transported to the site in February 2009; the Unit 3 RSGs are scheduled for shipment in mid-2010. In March 2009, during examination of the Unit 3 RSGs in Japan, MHI detected cracking in a weld joint between the divider plate and steel head in both Unit 3 RSGs. MHI's final root cause assessment indicated that the defects were caused by the use of an air carbon-arc gouging technique on the Unit 3 RSG welds; a different process than that used for the fabrication of the Unit 2 RSGs welds. The licensee inspected the Unit 2 RSGs at the plant site and confirmed that there were no similar weld defects prior to their installation.
_FAI AU NL -SEU E-2-Station Recovery Process/Strategv SCE plans to discuss its ongoing performance improvement efforts at SONGS. SCE developed a Site Integrated Improvement Plan (SLIP) in 2008, in part, to address the performance issues identified through NRC inspection findings and in the NRC's Confirmatory Order dated January 11, 2008 (ADAMS Accession No. ML080110380). SCE has revised and expanded the SLIP, to adjust for those previous actions that have been ineffective, and to incorporate recently identified issues (for example, the inclusion of a new Safety Culture Improvement Plan).Overall, the NRC staff remains concerned about the slow progress of the licensee's improvement efforts.Steam Generator Replacement SCE installed replacement steam generators (RSG) at Unit 2 during the recent refueling outage and will install RSGs in Unit 3 during the fall 2010 refueling outage. The RSGs were fabricated for both units by Mitsubishi Heavy Industries (MHI) in Japan. The Unit 2 RSGs were transported to the site in February 2009; the Unit 3 RSGs are scheduled for shipment in mid-2010. In March 2009, during examination of the Unit 3 RSGs in Japan, MHI detected cracking in a weld joint between the divider plate and steel head in both Unit 3 RSGs. MHI's final root cause assessment indicated that the defects were caused by the use of an air carbon-arc gouging technique on the Unit 3 RSG welds; a different process than that used for the fabrication of the Unit 2 RSGs welds. The licensee inspected the Unit 2 RSGs at the plant site and confirmed that there were no similar weld defects prior to their installation.
MHI has repaired and retested the Unit 3 RSGs.The steam generator (SG) replacement for both units requires that a large opening (roughly 28'by 28') be cut through the containment structure to allow the passage of the old and new SGs.The Unit 2 SG replacement activities have been completed, and the containment was restored and tested prior to returning the unit to operation.
MHI has repaired and retested the Unit 3 RSGs.The steam generator (SG) replacement for both units requires that a large opening (roughly 28'by 28') be cut through the containment structure to allow the passage of the old and new SGs.The Unit 2 SG replacement activities have been completed, and the containment was restored and tested prior to returning the unit to operation.
NRC inspectors noted some problems with work control during containment tendon removal, with design control regarding the re-welding of the containment rebar, and with quality control of concrete used in restoration of the containment structure.
NRC inspectors noted some problems with work control during containment tendon removal, with design control regarding the re-welding of the containment rebar, and with quality control of concrete used in restoration of the containment structure.

Revision as of 09:40, 29 June 2019

Memorandum to Leigh Trocine from Michael T. Markley, Subject: G20100287/EDATS: OEDO-2010-0358 - Briefing Package for Drop-In Visit on June 28, 2010, by Executives of Southern California Edison Company with Commissioner Apostolakis, Executiv
ML11269A152
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 06/21/2010
From: Markley M
Plant Licensing Branch IV
To: Trocine L
NRC/EDO
References
FOIA/PA-2011-0159, TAC ME3892, G20100287, OEDO-2010-0358
Download: ML11269A152 (20)


Text

June 21, 2010 MEMORANDUM TO: Leigh Trocine Regional Coordinator, RIV Office of Executive Director for Operations FROM: Michael T. Markley, Chief /RA/Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

G20100287/EDATS:

OEDO-2010-0358

-BRIEFING PACKAGE FOR DROP-IN VISIT ON JUNE 28, 2010, BY EXECUTIVES OF SOUTHERN CALIFORNIA EDISON COMPANY WITH COMMISSIONER APOSTOLAKIS, EXECUTIVE DIRECTOR FOR OPERATIONS, DEPUTY EXECUTIVE DIRECTOR FOR REACTOR AND PREPAREDNESS PROGRAMS, AND DIRECTORS, OFFICES OF NUCLEAR REACTOR REGULATION AND NUCLEAR SECURITY AND INCIDENT RESPONSE (TAC NO. ME3892)Enclosed is the briefing package in support of the drop-in visit by Mr. Ross T. Ridenoure, Senior Vice President and Chief Nuclear Officer, Southern California Edison Company (SCE); and Mr.Richard J. St. Onge, Director, Nuclear Regulatory Affairs, SCE. The SCE representatives will meet with Commissioner George E. Apostolakis, the Executive Director for Operations, R.William Borchardt, the Deputy Executive Director for Reactor and Preparedness Programs, Martin J. Virgilio, the Director of the Office of Nuclear Reactor Regulation, Eric J. Leeds, and the Director of the Office of Nuclear Security and Incident Response, James T. Wiggins, regarding San Onofre Nuclear Generating Station, Units 2 and 3.If you need any additional information, please contact Randy Hall at 301-415-4032 or by e-mail at randy.hal!@nrc.gov.

Docket Nos. 50-361 and 50-362

Enclosure:

Briefing Package cc w/encl: intOrIaIl tc iis recod W S E. Leeds, NRR I. a=*nnce with t J. Wiggins, NSIR Nct e C,,1 B. Boger, NRR EW-, J. Guitter, NRR R. Lantz, RIV E. Williamson, OGC 1 USE' ~NL -/SEN T ERAFOR AjJN lbnCIA 21,N -0 f June 21, 2010 MEMORANDUM TO: FROM: Leigh Trocine Regional Coordinator, RIV Office of Executive Director for Operations Michael T. Markley, Chief /RA/Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

G20100287/EDATS:

OEDO-2010-0358

-BRIEFING PACKAGE FOR DROP-IN VISIT ON JUNE 28, 2010, BY EXECUTIVES OF SOUTHERN CALIFORNIA EDISON COMPANY WITH COMMISSIONER APOSTOLAKIS, EXECUTIVE DIRECTOR FOR OPERATIONS, DEPUTY EXECUTIVE DIRECTOR FOR REACTOR AND PREPAREDNESS PROGRAMS, AND DIRECTORS, OFFICES OF NUCLEAR REACTOR REGULATION AND NUCLEAR SECURITY AND INCIDENT RESPONSE (TAC NO. ME3892)Enclosed is the briefing package in support of the drop-in visit by Mr..Ross T. Ridenoure, Senior Vice President and Chief Nuclear Officer, Southern California Edison Company (SCE); and Mr.Richard J. St. Onge, Director, Nuclear Regulatory Affairs, SCE. The SCE representatives will meet with Commissioner George E. Apostolakis, the Executive Director for Operations, R.William Borchardt, the Deputy Executive Director for Reactor and Preparedness Programs, Martin J. Virgilio, the Director of the Office of Nuclear Reactor Regulation, Eric J. Leeds, and the Director of the Office of Nuclear Security and Incident Response, James T. Wiggins, regarding San Onofre Nuclear Generating Station, Units 2 and 3.If you need any additional information, please contact Randy Hall at 301-415-4032 or by e-mail at randv.hall@nrc.gov.

Docket Nos. 50-361 and 50-362

Enclosure:

Briefing Package cc w/encl: E. Leeds, NRR J. Wiggins, NSIR B. Boger, NRR J. Giitter, NRR R. Lantz, RIV E. Williamson, OGC DISTRIBUTION:

G20100287/EDATS:

OEDO-2010-0358 NON-PUBLIC RidsNrrDorlLpl4 Resource LPLIV Reading File RidsNrrLAJBurkhardt Resource RidsEdoMailCenter Resource RidsNrrPMSanOnofre Resource RidsNrrOd Resource RidsNrrMailCenter Resource RidsNrrDorl Resource RidsNsirOd Resource FAST Resource RidsOgcRp Resource RidsRgn4MailCenter Resource ADAMS Accession Nos,: Pkg ML101620239, Incoming ML101310556, Briefing ML101620256 EDO Closeout E-mail ML101820443

  • Concurrence by E-mail OFFICE NRR/DORULPL4/PM NRR/DORLILPL4/LA RIV/DRP/RPD-B/BC NRR/DORLULPL4/BC NAME RHall JBurkhardt RLantz MMarkley DATE 6/15/10 6/11/10 6/18/10 6/21/10 OFFICIAL RECORD COPY/ALSE NLYE EN SI IV ET TE A F ýM ItOý (F/ IC IA L L, ý-S N &I V ENT\&L IF' xfTy C UNI STATES NUcmEA REdblAToRY COMMIsSION Protecting People a.nd ;the E-t;ronmen',t SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3 DROP-IN VISIT JUNE 28, 2010 CONTENTS TAB A G E N D A .......................................................................................................

..1A FACILITY DATA F a c ility D a ta ........................................................................................

..3 FACILITY PERFORMANCE Reactor Oversight Process Information

......................

5 Current Issues ........................................

6 FACILITY MANAGEMENT DATA Facility O rganization

...........................................................................

..7 Biographical Data of Principal Managers ..........................................

8#?N; ALUi',9LYý-

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,6-Ff ý LS 014k!;,-ýSýIE INT -kkWrNE0,Rr I'PON TAB 1A Drop-In Visit Aqenda June 28, 2010 ITINERARY TIME PERSON VISITED CONTACT EXTENSION PERSON _____Executive Director for Operations, R. William Borchardt Deputy Executive Director for Reactor and 10:00 a.m. -Preparedness Programs, Martin J. Virgilio Renee Taylor 301-415-1700 10:30 a.m. Director of the Office of Nuclear Reactor Regulation, Eric J. Leeds Director of the Office of Nuclear Security and Incident Response, James T. Wiggins 11:00a.m.

-Commissioner George E. Apostofakis Kathleen Blake 301-415-1810 11:30 a.m. I 0 0 0 0 0 0 0 VISITORS REPRESENTING SOUTHERN CALIFORNIA EDISON COMPANY (SCE)San Onofre Nuclear Generating Station Units 2 and 3 Ross T. Ridenoure, Senior Vice President and Chief Nuclear Officer, SCE Richard J. St. Onge, Director, Nuclear Regulatory Affairs, SCE TOPICS OF DISCUSSION Overview of San Onofre Nuclear Generating Station Performance History Current Regulatory Status Station Recovery Process/Strategy Upcoming Unit 3 Steam Generator Replacement Safety Conscious Work Environment Update OfF'11Cý'\\

"-S SI TIIýERNAC

'NX0 M QN/'N FICI U '(S In E INO TAB 3 Facility Data Utility: Location: County: San Onofre Nuclear Generating Station Southern California Edison (SCE)*4 miles southeast of San Clemente, California San Diego County, California Unit 1** Unit 2 Unit 3 Docket Nos.License Nos.Construction Permit Full Power License Commercial Operation Expiration Date 50-206 DPR-13 1963 03/27/1967 01/01/1968 11/30/1992**

50-361 NPF-10 10/18/1973 09/07/1982 08/08/1983 02/16/2022 Units 2 and 3 50-362 NPF-15 10/18/1973 09/16/1983 04/01/1984 11/15/2022 Plant Characteristics Reactor Type: Containment Type: Thermal Power Limit: Architect/Engineer:

NSSS Vendor: Turbine Generator:

Condenser Cooling Method: Ultimate Heat Sink for ECCS CE 2-loop Large Dry 3438 MWt (1070/1080 MWe)Bechtel Combustion Engineering English Electric Once Through Pacific Ocean* San Onofre Nuclear Generating Station is jointly owned by SCE (78.21 %), San Diego Gas & Electric (20%), and the city of Riverside (1.79%). SCE is authorized to act as agent for the other co-owners and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.** Unit 1, a Westinghouse 3-loop pressurized water reactor constructed by Bechtel and rated at 1347 MWt, began commercial operation on January 1, 1968, and permanently ceased operation on November 30, 1992. The unit was initially placed in SAFSTOR until 2000 when active decommissioning (DECON) began.'Q LY -'EN IVE TE AL FO A ON PkPA1 E LY_ EITlI A NýF AT. TAB 5 Reactor Oversight Process (ROP) Information San Onofre Nuclear Generating Station Current ROP Assessment Status The U.S. Nuclear Regulatory Commission (NRC) issued its annual assessment letter for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 on March 3, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100621410).

The NRC staff noted that SONGS Units 2 and 3 operated in a manner that preserved public health and safety and fully met all cornerstone objectives.

However, the NRC continues to identify performance problems in the areas of Human Performance (HP) and Problem Identification and Resolution (PI&R). This is the fifth consecutive assessment cycle where substantive cross-cutting issues were identified in both of these cross-cutting areas. Corrective actions taken by the licensee to address these substantive cross-cutting issues have been largely ineffective.

Plant performance for Unit 2 for the most recent quarter was within the Regulatory Response Column (Column 2) of the NRC's Action Matrix based on one White finding in the Mitigating Systems cornerstone.

The finding involved the failure to establish appropriate instructions for replacement of a safety-related battery output breaker resulting in the battery being inoperable between March 2004 and March 2008. In December 2009, the NRC conducted supplemental NRC Inspection Manual Inspection Procedure (IP) 95001, "Inspection for One or Two White Inputs in a Strategic Performance Area," and concluded that the White finding will remain open because some corrective actions were not fully developed and because of a lack of assurance that corrective actions will be effective.

Unit 3 plant performance remained in the Licensee Response Column (Column 1) of the NRC's Action Matrix, based on all inspection findings having very low safety significance (Green) and all performance indicators (PI) indicating performance at a level requiring no additional NRC oversight (Green).As a result of the continuing problems in HP and PI&R, the NRC plans to conduct additional inspections, above the baseline inspection program, to evaluate the effectiveness of the licensee's performance improvement efforts in these areas. Region IV has also supplemented the on-site NRC staff with a third resident inspector to support the increased level of oversight for the near-term.

Current HP cross-cutting themes are as follows:* Failing to provide adequate design documentation, procedures, and work instructions (Resources component)

  • Ineffective use of human error prevention techniques (Work practices component)
  • Failing to use conservative assumptions (Decision making component)" Weaknesses in ensuring supervisory and management oversight of work activities (Work practices component) fFl I1 U S ýN -SN NSI ET TE ýAL OM ý Current PI&R cross-cutting themes are as follows:* Failing to thoroughly evaluate problems such that the resolutions effectively address the causes and extent of conditions (Corrective action program component)
  • Weaknesses in implementing the corrective action program with a low threshold for identifying issues (Corrective action program component)" Weaknesses in taking appropriate corrective actions to address safety issues in a timely manner commensurate with their safety significance (Corrective action program component)

A high number of allegations have been generated regarding SONGS. The current number is roughly ten times the national median. On March 2, 2010 (ADAMS Accession No. ML100601272), the NRC issued a chilling effect letter resulting from NRC's assessment of the licensee's safety conscious work environment.

On January 11, 2008 (ADAMS Accession No. ML080110380), the NRC issued a Confirmatory Orderas the result of a successful alternative dispute resolution mediation session related to falsification of firewatch certification sheets. Corrective actions have been taken, and some have been effective.

The NRC will perform a follow-up inspection to determine whether the terms of the Order have been satisfied.

The colored PI and inspection findings for this station can be viewed at the URLs listed below.SONGS, Unit 2: httro:lwww.nrc.aov/NRR/OVERSIGHTIASSESS/SANO2/sano2 chart.html SONGS, Unit 3: htto://www.nrc.aov/NRR/OVERSIGHT/ASSESS/SANO3/sano3 chart.html 44JýIAL ýUO IY -"tTIVE TE A LýFOýR6N

--O1,96A US ONLY S TAB 6 Current Issues San Onofre Nuclear Generating Station A. EXPECTED DISCUSSION TOPICS The licensee proposed the following topics for discussion:

Overview of San Onofre Nuclear Generating Station Performance History Current Regulatory Status Station Recovery Process/Strategy Upcoming Unit 3 Steam Generator Replacement Safety Conscious Work Environment Update Overview of San Onofre Nuclear Generating Station (SONGS) Units 2 and 3: Performance History and Current Regulatory Status On March 3, 2010, the NRC issued its annual assessment letter to SCE for its performance during calendar year 2009 at SONGS Units 2 and 3 (ADAMS Accession No. ML100621410).

The NRC staff noted that this is fifth consecutive cycle where substantive cross-cutting issues were identified in the areas of Human Performance (HP) and Problem Identification and Resolution (PI&R) and that corrective actions taken by the licensee to address these substantive cross-cutting issues have been ineffective.

The NRC noted that, while existing performance problems have persisted at the site, new ones have emerged.Throughout 2009, the licensee continued to have performance problems that challenged the operation of both units in the areas of HP and PI&R. Examples of these problems include the isolation of power to the wrong train of the emergency core coolant system (ECCS); a reactor trip caused by the failure to follow heat treat procedures and a poor pre-job briefing, and inadequate contractor oversight to ensure procedural adherence that resulted in multiple, repeat, small fires during containment tendon cutting operations.

In 2009, the licensee's performance resulted in an increased number of NRC findings in the areas of PI&R and HP. These substantive cross-cutting issues remain open, with additional themes being identified in each area. The licensee had initiated root cause evaluations for each of the identified themes, but corrective actions have been ineffective to date. Performance problems continue to be identified by the NRC. As of the 2009 mid-cycle assessment, four themes were open; three in HP and one in PI&R. At end of cycle 2009, three additional themes were identified, one in HP and two in PI&R, with the previous four remaining open. The current total of seven open themes is the most that any plant has had in the history of the NRC's ROP evaluation process. Detailed -information on the current ROP assessment for SONGS Units 2 and 3 is provided in Tab 5.(4)6_FPiYA -ý" C.ENSI 4fýý I \TO

_FAI AU NL -SEU E-2-Station Recovery Process/Strategv SCE plans to discuss its ongoing performance improvement efforts at SONGS. SCE developed a Site Integrated Improvement Plan (SLIP) in 2008, in part, to address the performance issues identified through NRC inspection findings and in the NRC's Confirmatory Order dated January 11, 2008 (ADAMS Accession No. ML080110380). SCE has revised and expanded the SLIP, to adjust for those previous actions that have been ineffective, and to incorporate recently identified issues (for example, the inclusion of a new Safety Culture Improvement Plan).Overall, the NRC staff remains concerned about the slow progress of the licensee's improvement efforts.Steam Generator Replacement SCE installed replacement steam generators (RSG) at Unit 2 during the recent refueling outage and will install RSGs in Unit 3 during the fall 2010 refueling outage. The RSGs were fabricated for both units by Mitsubishi Heavy Industries (MHI) in Japan. The Unit 2 RSGs were transported to the site in February 2009; the Unit 3 RSGs are scheduled for shipment in mid-2010. In March 2009, during examination of the Unit 3 RSGs in Japan, MHI detected cracking in a weld joint between the divider plate and steel head in both Unit 3 RSGs. MHI's final root cause assessment indicated that the defects were caused by the use of an air carbon-arc gouging technique on the Unit 3 RSG welds; a different process than that used for the fabrication of the Unit 2 RSGs welds. The licensee inspected the Unit 2 RSGs at the plant site and confirmed that there were no similar weld defects prior to their installation.

MHI has repaired and retested the Unit 3 RSGs.The steam generator (SG) replacement for both units requires that a large opening (roughly 28'by 28') be cut through the containment structure to allow the passage of the old and new SGs.The Unit 2 SG replacement activities have been completed, and the containment was restored and tested prior to returning the unit to operation.

NRC inspectors noted some problems with work control during containment tendon removal, with design control regarding the re-welding of the containment rebar, and with quality control of concrete used in restoration of the containment structure.

Safety Conscious Work Environment Update (SCWE)In November 2009, the NRC conducted a focused PI&R inspection to evaluate the licensee's progress in addressing the open substantive cross-cutting issues as well as to review the results of the licensee's safety culture survey. During this inspection, the NRC also conducted focus group interviews as an independent check on the licensee's results, which indicated an SCWE concern at SONGS. In February 2010, the NRC conducted additional focus group interviews of approximately 400 licensee and contractor personnel.

These interviews confirmed previous NRC inspection observations of SCWE concerns at SONGS. NRC determined that SCWE issues as well as internal communication issues continue to be significant contributors to the failure of SCE to effectively address the long-standing substantive cross-cutting issues.The NRC concluded that some employees in multiple workgroups at SONGS have the perception that they are not free to raise safety concerns using all available avenues and that management has not been effective in encouraging employees to use all available avenues O'FF "IrUS Vý- S NSITEl TERNAIý)LF RMJON without fear of retaliation.

This conclusion resulted from numerous observations including (1) employees expressing difficulty or inability to use the corrective action program, (2) a lack of knowledge or mistrust of the Nuclear Safety Concerns Program (NSCP), (3) the substantiated case of a supervisor creating a chilled work environment in his/her work group, and (4) a perceived fear of retaliation for raising safety concerns.The NRC issued a chilling effect letter on March 2, 2010 (ADAMS Accession No. ML100601272), as a result of NRC's assessment of the licensee's SCWE. The purpose of the chilling effect letter is to verify that the licensee is taking appropriate actions to ensure that SONGS is a workplace that fosters an environment where employees feel free, and are encouraged, to raise safety concerns.

The chilling effect letter requested SCE to take 13 specific actions to respond to the identified SCWE concerns.Through several inspections and interviews with hundreds of plant employees through focus groups, the NRC staff determined that safety concerns are being raised by SONGS personnel through some communication avenues despite the staffs concerns regarding the chilled work environment.

The NRC has not identified any safety issues that were not reported by some available avenue. The NRC determined that some employees do not consider certain avenues available, such as discussing a concern with their immediate supervisor, but would find an alternate avenue to communicate their safety concerns.Operating Status Unit 2 is currently operating at 100 percent power. The unit returned to operation on April 8, 2010, following an extended outage. Major outage activities included the replacement of both SGs. The outage, originally scheduled to last approximately 3 months, exceeded 6 months ,'in duration due, in part,_to several emergent issues- .i,.4'-(b)(5)Unit 3 is currently operating at 100 percent power. The next refueling outage is scheduled to commence on October 10, 2010. This outage will include replacement of both SGs similar to what was accomplished in Unit 2. The start of the Unit 3 outage has been delayed by approximately 2 weeks from its original schedule.

This delay is intended, in part, to provide time to implement actions designed to prevent problems with work planning and execution, design control, and contractor oversight similar to those experienced during the Unit 2 outage.B. OTHER TOPICS OF INTEREST Plant Equipment Issues" Degraded connection between battery and output breaker. White finding from December 2008 left open because corrective actions not fully developed and there was a lack of assurance that corrective actions would be effective." Schedule 10 piping integrity issues. Multiple instances of piping degradation identified on refueling water tank to ECCS/charging suction piping in both Units 2 and 3.PFIIL SE ONLX.,-SE TVEI-?RNýAL IlNýM/T%4 QýlYQ\USE)YL

\ S4'STYVE!InN II N A~lO-4-Inspections focused on adequacy of past corrective actions for identified deficiencies, adequacy of past inspections, ongoing operability evaluations, and corrective actions going forward.Current Licensing Issues On March 16, 2010 (ADAMS Accession No. ML100630514), the NRC staff granted SCE an exemption to certain new security requirements in Title 10 of the Code of Federal Regulations, Section 73.55, "Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage," issued by NRC in a final rule dated March 27, 2009 (74 FR 13926). The exemption allowed SCE to extend the implementation date from the current deadline of March 31, 2010, to October 31, 2010, for one specific requirement and to January 31, 2011, for a second specific requirement.

The exemption will allow the licensee sufficient time to complete the modifications designed to update aging security equipment and incorporate state-of-the-art technology to meet the new regulatory requirements.

On December 15 and 17, 2009 (ADAMS Accession Nos. ML093220105 and ML090860415, respectively), the NRC staff approved a license amendment and a related exemption, respectively, which allow SCE to use an alternative computer code to perform nuclear design calculations.

The amendment and exemption also allow SCE to use a limited number of Areva Lead Fuel Assemblies in SONGS Units 2 and 3 over the next three operating cycles.On March 22, 2010 (ADAMS Accession No. ML100620983), the NRC staff approved changes to the emergency action levels (EAL) for SONGS in support of the conversion from the current EAL scheme to a scheme based on Nuclear Energy Institute (NEI) 99-01, "Methodology for Development of Emergency Action Levels," Revision 5, dated February 22, 2008.SCE plans to submit a license amendment request in late 2010 for a major upgrade to the SONGS technical specifications to better align with the current Combustion Engineering Improved Standard Technical Specifications.

Management Changes SCE has made many senior management changes over the past 2 years. These changes include the positions of Senior Vice President and Chief Nuclear Officer (Ross Ridenoure);

Site Vice President (Doug Bauder); Director, Operations (Bruce MacKissock);

Director, Maintenance and Construction (Ed Hubley); Director, Work Control (David Spires): Director, Recovery (Jim Madigan);

and Director, Nuclear Regulatory Affairs (Rich St. Onge). The organization chart provided in Tab 7 shows the large number of management changes and further indicates that many of the new managers came from outside of SCE.License Renewal Activities SCE has not formally announced its intent to seek renewal of the operating licenses for SONGS Units 2 and 3. However, SONGS is a participant in the Strategic Teaming and Resource Sharing (STARS) group of utilities, and STARS has notified the NRC staff that several unspecified members intend to submit renewal applications in FY 2013.\ /l~j~ usENL --SEN ITIV.E ERN -!-_

S -S -5F-5-Open Investigations The following are examples of items under review by the Office of Investigations (01): (b)(7)(A)Open Allegations The NRC has received a significant increase in allegations from onsite sources at SONGS to nearly ten times the industry median (4) in 2009. During this time, there was a significant increase in chilling effect, discrimination, and anonymous concerns raised to the NRC as compared to prior years. These allegations were received from multiple onsite organizations.

S 0 S S There are currently 31 open allegations at SONGS.A large number of these were originated during the Unit 2 SG replacement outage.There are approximately 18 allegations associated with SCWE concerns at SONGS.There are approximately 18 allegations associated with 01 investigations or alternate dispute resolution.

Harassment And Intimidation Issues As discussed in Section A above, the NRC issued a chilling effect letter on March 2, 2010, after a spike in the number of allegations and after the NRC performed an assessment of SCWE issues at SONGS.Congressional Interest There has been a high level of Congressional interest in SONGS. The Office of Congressional Affairs staff has responded to recent inquiries from Congressman Calvert's (R-CA) office, Congressman Markey's (D-MA) office, and staff from the Senate Committee on Environment and Public Works, chaired by Senator Boxer (D-CA). The primary issues of interest include the work environment and high number of allegations at the site and the delays in restarting Unit 2.On August 6, 2009 (ADAMS Accession No. ML092050535), the Executive Director for Operations responded to a letter from Senator Boxer concerning the SG replacement activities at Unit 2.ITIVN Iit -~ f T IVNfto r NT-6-State Issues State and local officials have also expressed recent interest in activities at SONGS. On February 24, 2010, Region IV staff briefed staff from the California Energy Commission on SONGS performance and safety culture issues. On February 2, 2010, the NRC Senior Resident Inspector made a presentation to the San Clemente City Council on the NRC's regulatory role and its views on SCE's safety performance at SONGS.2.206 Petitions None.Selected News Articles Several recent print and online news articles discussed performance at SONGS, including safety culture issues and the NRC's March 2, 2010, chilling effects letter. Another more recent article discussed new regulations to be imposed by the state of California on coastal power plants requiring a phase out of once-through cooling systems. Summaries of selected articles are provided below.California To Phase Out Once-Through Cooling For Plants. San Luis Obispo (CA) New Times (5/5/2010, Rigley, 42K) reports, "The State Water Resources Control Board unanimously approved regulations that require 19 coastal power plants to phase out once-through cooling," which the article described as the "preferred" system for coastal plants. The ruling was made to prevent ocean life from being drawn into intake pumps. Although some plants now have until 2015 to comply, "nuclear power plant operators, however, got a bit more leeway from the water board. Board members required that an independent third party of nuclear experts review the cost feasibility and come back with results in three years." This may "lead to a 'variance' for nuclear power plant operators, Pacific Gas and Electric spokeswoman Cindy Pollard said." Reuters (5/6/2010) notes some of the plants are possibly closing because of the ruling. The measure includes both of California's nuclear power plants. NPR (5/5/2010) "Morning Edition," in a report from KQED, notes "Alternatives to once-through cooling are expensive, especially at nuclear power plants like San Onofre," owned by Southern California Edison. Spokesperson Mike Hertel said, "I want to stress that we don't think it's even feasible.

But if it were, it would cost in the range of say $2.5 billion to $3 billion." Hertel "says it's too soon to say how the industry here will respond." According to the KPBS-Radio (5/5, Joyce) website, "Instead of a complete cooling system overhaul, plant operators favor greater flexibility to outfit their existing equipment with environmentally-friendly features." Hertel "said there simply is no room on the San Onofre site to install a cooling tower, which is the mechanism preferred by environmental advocates." San Onofre Operators Say They Are Working To Improve Plant Performance.

The San Diego Union-Tribune (3/26/2010, Burge, 278K) reported that San Onofre station operators"faced a skeptical public and hard questions" from NRC "regulators this week about when the plant is going to fix long-standing weaknesses in its safety culture. Plant managers admitted the plant has problems but told" NRC "officials that they've established new procedures to fix them.The NRC and representatives of Southern California Edison, the plant's operator, held a public meeting Wednesday at the Doubletree Guest Suites in Dana Point. About 175 people -- many of Pf~:" __ n E6fVU~tA:ýE AjN_ them plant workers -- attended." The Union-Tribune added, "Chuck Casto, an NRC deputy regional administrator, said the plant's lapses were of a low to moderate risk and didn't jeopardize public safety, but 'we're still not satisfied with the progress (San Onofre) has made."'But, San Onofre's chief nuclear officer Ross Ridenoure, said "the plant is committed to protecting public health and safety, and 'we're disappointed in the rate of our performance improvement."'

NRC To Perform Extra Inspections of San Onofre. The North County (CA) Times (3/25/2010, Sisson) reported that the NRC "will perform several extra inspections and will keep an additional resident inspector at San Onofre Nuclear Generating Station this year because of ongoing performance issues at the seaside plant." The Times notes that "regulators met with Southern California Edison managers for the nuclear plant's annual performance meeting Wednesday in a Dana Point hotel. For several years now, the plant and Edison have been under heightened scrutiny for an employee culture that does not hold closely enough to strict nuclear industry standards," although the inspectors "have also insisted that all problems so far have been of a 'low safety significance' that does not put the public's safety in jeopardy." Greg Warnick, "the plant's chief resident inspector for the NRC, told the large public audience that he considers the problems at San Onofre insignificant from a safety standpoint, but they are still important because they seem to run throughout the organization's work force. 'We are concerned that they could grow into bigger things if they're not corrected,'

Warnick said." Group Wants "Open And Transparent" Review Of San Onofre Station Problems.

In a letter to the editor of the North County (CA) Times (3/8/2010), Nancy Casady, president of the Alliance for Nuclear Responsibility, wrote, "Whether it was sirens blasting in the middle of the night or the recent news headlines about safety violations and delays in the repairs to the San Onofre Nuclear Generating Station, area residents have increasing concerns over the state of nuclear power in southern California.

The Alliance for Nuclear Responsibility believes the problems at SONGS deserve to be reviewed in an open and transparent process by state agencies, elected representatives, all first responders, and the Nuclear Regulatory Commission." NRC Warns Southern California Edison On San Onofre Station Safety Culture. The San Clemente (CA) Times (3/3/2010, Garrett) reports that the NRC "issued a stern warning to the management of Southern California Edison's San Onofre Nuclear Generating Station (SONGS)to improve work environment procedures or face 'additional action to ensure safe plant operations,'

said Lara Uselding, a public affairs officer with the NRC." In its letter, which the Times notes includes the words "Chilling Effect" in the title, the NRC outlines a "strict timeline by which it wants to see that 'Southern California Edison is taking appropriate actions to ensure that the San Onofre Nuclear Generating Station facility is a workplace that fosters an environment where employees feel free, and are encouraged, to raise safety concerns."'

The NRC detailed a "strict action outline, demanding results first in 30 days for SCE to detail actions it will take to improve existing Safety Conscious Work Environment issues, followed by a public hearing in six months to assess how SCE has responded to the action plan." NRC Inspectors Interviewed 500 SONGS Workers. According to the North County (CA)Times (3/3/2010, Sisson), "During a series of meetings, the most recent in early February, commission inspectors interviewed a total of 500 workers spread across numerous departments" at San Onofre and while they "all said they knew how to report problems and would do so if necessary, about 5 percent said they feared retaliation from plant supervisors." 04PY TI T N- The NRC letter says some employees "have the perception that they are not free to raise safety concerns using all available avenues." Web Site launched for SONGS. The Dana Point (CA) Times (3/1/2010, Garrett) reported that Southern California Edison launched a community information Web site for San Onofre Nuclear Generating Station, on February 22, 1010, in "response to recent calls for more information and better communication for the public following two accidental siren soundings in San Clemente.The site includes quick updates on important developments and addresses rumors that could cause public concern, spokesman Gil Alexander said." San Onofre Memo Says Employees Fear Retaliation.

The North County (CA) Times (2/20/2010, Sisson) reported, "An internal memo from Southern California Edison, leaked to a San Clemente activist group, indicates that fear of retaliation still exists at San Onofre Nuclear Generating Station, despite repeated public statements calling for openness by top plant leadership." The memo was released by the group, San Clemente Green and "appears to have been written by an Edison employee" ahead of a meeting between Edison executives and NRC inspectors who conducted an inspection at San Onofre in November.

According to the memo,"25 percent of those surveyed said they fear retaliation from plant management for raising safety concerns to federal regulators." Significant Reportable Events and Activities None.OlF IC'IAL U1SE 6 ENiiVkITIVERTNALI

ýR1WAT-ff TAB 7 FACILITY ORGANIZATION SAN ONOFRE NUCLEAR GENERATING STATION* M o E*rr* tfmoo (b)(6)- I (b)(6).--AWlJl 4%VRAVjMMMNNMMWý

ýHhh TAB 8 Bionraphical Data of Principal Mana-gers (as provided by the licensee)The biographical data for the following visitors are attached: " Ross T. Ridenoure, Senior Vice President and Chief Nuclear Officer, SCE" Richard J. St. Onge, Director, Nuclear Regulatory Affairs, SCE Ross Ridenoure Senior Vice President and Chief Nuclear Officer, San Onofre Nuclear Generating Station Southern California Edison In June 2008, Ross Ridenoure became the senior vice president, chief nuclear officer, and site manager for Southern California Edison (SCE), responsible for all aspects of the company's nuclear business, including operations, engineering, oversight, and regulatory activities of the company's San Onofre Nuclear Generating Station (SONGS) located in north San Diego County.In December 2007, Ridenoure was named vice president and site manager at SONGS, the largest single source of electricity generation in Southern California.

Prior to joining SCE, Ridenoure was a vice president and chief nuclear officer with the Omaha Public Power District, where he had overall responsibility for the Fort Calhoun Nuclear Station.Prior to joining the Omaha Public Power District, Ridenoure served on nuclear-powered submarines for eight years in the United States Navy. He recently retired from the Navy after more than 29 years of active and reserve service.Ridenoure is the chairman of the board of directors for the Utilities Services Alliance and a member of the Institute of Nuclear Power Operations executive advisory group and SCE's nuclear oversight board. Additionally, he has served as a nuclear operations instructor for Illinois Power and for the Westinghouse Electric Company, a leading manufacturer of nuclear power plant equipment.

Ridenoure holds undergraduate degrees in sociology and nuclear engineering technology from Excelsior College and an MBA from the University of Nebraska. URichard J. St. Onue...............

ml Director, Nuclear Regulatory Affairs Southern California Edison Mr. Richard St. Onge is currently the Director of Regulatory Affairs at the San Onofre Nuclear Generating Station (SONGS), which is owned and operated by Southern California Edison (SCE). Previously, Mr. St. Onge held the position of Director, Maintenance and Systems Engineering at SONGS. He has been a licensed Senior Reactor Operator/Control Room Supervisor at the facility.

Mr. St. Onge has held various other positions:

with a NSSS supplier (Combustion Engineering), at the Pilgrim Nuclear Station, and in reactor refueling services, plant, system and design engineering.

Mr. St. Onge is a Registered Professional Engineer, State of California, Nuclear Engineering.

Mr. St. Onge also is an Executive Member of the Operations

& Power Division of the American Nuclear Society. Mr. St. Onge holds a Bachelor of Science Degree in Nuclear Engineering and a Masters Degree in Business Administration.