IR 05000361/2009302

NRC Examination Report 05000361/2009302; 05000362/2009302

ML093421443
Person / Time
Site:	San Onofre
Issue date:	12/08/2009
From:	Garchow S Operations Branch I
To:	Ridenoure R Southern California Edison Co
References
50-361/09-302, 50-362/09-302
Download: ML093421443 (12)

Text

December 8, 2009

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 - NRC EXAMINATION REPORT 05000361/2009302; 05000362/2009302

Dear Mr. Ridenoure:

On October 23, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at San Onofre Nuclear Generating Station, Units 2 and 3. The enclosed report documents the examination findings and licensing decisions. The preliminary examination findings were discussed on October 23, 2009, with Mr. Doug Bauder, Plant Manager, and other members of your staff. A telephonic exit meeting was conducted on November 5, 2009, with Mr. Bill Arbour, Operations Training Manager, who was provided the NRC licensing decisions.

The examination included the evaluation of eight applicants for reactor operator licenses, four applicants for instant senior reactor operator licenses and three applicants for upgrade senior reactor operator licenses. The license examiners determined that all of the applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. There were no post-examination comments submitted by your staff. The enclosure to this letter contains the details of this report.

No findings of significance were identified during this examination. However, the NRC identified a minor performance deficiency where equipment noun names in procedures did not match the installed equipment label plates. UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125 Southern California Edison Co. (SCE) - 2 -In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document 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/

Stephen M. Garchow, Acting Chief Operations Branch Division of Reactor Safety Dockets: 50-361; 50-362 Licenses: NPF-10; NPF-15

Enclosure:

NRC Examination Report 05000361/2009302; 05000362/2009302

REGION IV==

Dockets: 50-361, 50-362 Licenses: NPF-10, NPF-15 Report: 05000361/2009302; 05000362/2009302 Licensee: Southern California Edison Co. (SCE)

Facility: San Onofre Nuclear Generating Station, Units 2 and 3 Location: 5000 S. Pacific Coast Hwy. San Clemente, California Dates: October 19 - November 5, 2009 Inspectors: G. Apger, Chief Examiner B. Larson, Senior Operations Engineer P. Presby, Operations Engineer (RI) C. Osterholtz, Senior Operations Engineer Approved By: Stephen Garchow, Acting Chief Operations Branch Division of Reactor Safety

2 Enclosure

SUMMARY OF FINDINGS

ER05000361/2009302; 05000362/2009302; October 19 - November 5, 2009; San Onofre Nuclear Generating Station, Units 2 and 3; Initial Operator Licensing Examination Report.

NRC examiners evaluated the competency of eight applicants for reactor operator licenses, four applicants for instant senior reactor operator licenses and three applicants for upgrade senior reactor operator licenses at San Onofre Nuclear Generating Station, Units 2 and 3.

The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1. The written examination was administered by the licensee on October 28, 2009. NRC examiners administered the operating tests on October 19 - 23, 2009.

The examiners determined that all of the applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.

A. NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

The NRC identified a minor performance deficiency where equipment noun names in procedures did not match the label plates. Because this was identified during prior examinations as procedural "enhancement opportunities" for the licensee and the NRC again found these same problems, this minor performance deficiency is being documented within the Operator Knowledge and Performance section of this report.

B. Licensee-Identified Violations

None.

REPORT DETAILS

4OA5 Other Activities (Initial Operator License Examination)

.1 License Applications

a. Scope

NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. The examiners also audited three of the license applications in detail to confirm that they accurately reflected the subject applicant's qualifications. This audit focused on the applicant's experience and on-the-job training, including control manipulations that provided significant reactivity changes.

b. Findings

No findings of significance were identified.

.2 Examination Development

a. Scope

NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examination team conducted an onsite validation of the operating tests.

b. Findings

NRC examiners provided outline, draft examination and post-validation comments to the licensee. The licensee satisfactorily completed comment resolution prior to examination administration.

NRC examiners determined that the written examinations and operating tests initially submitted by the licensee were within the range of acceptability expected for a proposed examination.

.3 Operator Knowledge and Performance

a. Scope

On October 28, 2009, the licensee proctored the administration of the written examinations to all fifteen applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis to the NRC on November 2, 2009.

The NRC examination team administered the various portions of the operating tests to all fifteen applicants on October 19 - 23, 2009.

b. Findings

No findings of significance were identified.

All of the applicants passed the written examination and all parts of the operating test. The final written examinations and post-examination analysis may be accessed in the ADAMS system under the accession numbers noted in the attachment. There were no post-examination comments as indicated in the licensee submittal.

The examination team noted the following generic weaknesses:

• Upon a loss of lube oil to a main feedwater pump, applicants were hesitant to trip the pump turbine or did not know what alarm response procedure to use to address the issue.

• No action was taken to address pumping the contents of the main feedwater lube oil sump onto the floor.

• Reactor operator applicants did not notice or verbalize that the suction of the charging pumps had swapped to the reactor water storage tank upon volume control tank level instrument failure. This was a reactivity event.

• All senior reactor operator applicants displayed some weakness in technical specifications; however, there was an improvement from the previous examination. A contributing factor was poor procedure quality as it relates to addressing technical specifications.

The NRC did identify a minor performance deficiency where equipment noun names in procedures did not match the label plates:

-Technical Specification 5.5.1 states in part that written procedures are to be established, implemented and maintained covering the applicable procedures recommended in Regulatory Guide (RG) 1.33. Procedure SO123-XV-HU-1, Human Performance Program, Attachment 2, Human Performance Fundamentals, states that operators should stop and correct identified procedure errors prior to continuing use. SO123-XV-HU-3, Written Instruction Use and Adherence, step 6.18.2 describes how to make editorial corrections to procedures while in use.

Contrary to this, the examination team noted that none of the applicants, while using a procedure, would address editorial changes needed to correct noun names. The Operations Training Manager stated that notifications (as part of the corrective action program) were generated in the past to correct noun name inconsistencies in an on-going effort by him to align the facility with industry best-practices. However, within the operations department and the procedure writers group, there was a tendency to not change procedures so that equipment noun names match their label plates.

In an effort to explain this, the NRC chief examiner (CE) was given a copy of step 6.15.7.1 of procedure SO123-0-A4, Configuration Control. It states, in part, that existing ID Tags and ID Labels should NOT be changed to solely match the preferred conventions. The CE was told that procedures were not changed because of this statement. However, this statement addresses differences between equipment ID numbers and the preferred method of labeling (e.g., S21206MP012 and 2MP-012). Facility management agreed that it would be inappropriate to apply the Configuration 5 Enclosure Control instructions for equipment ID tags and labels when deciding whether to correct written procedures.

During the examination debrief, the CE was told that, due to examination security, some discrepancies that were noted during examination development could not be addressed until after the examination. However, the CE stated that the NRC consistently finds these procedural discrepancies on every examination due to a lack of effort by the licensee to identify and correct the problems. Facility management agreed with the CE.

Because the licensee is not maintaining their procedures in accordance with industry best-practices and their Human Performance procedures; and this was within the capability of licensee staff to identify and correct, this is a performance deficiency. The performance deficiency does affect the Procedure Quality attribute of the Initiating Events, Mitigating Systems and Barrier Integrity cornerstone objectives; however, because the cornerstone objectives have not been adversely affected and the licensee generated notifications as part of their corrective action process, the performance deficiency is minor.

.4 Simulation Facility Performance

a. Scope

The NRC examiners observed simulator performance with regard to plant fidelity during examination validation and administration.

b. Findings

No findings of significance were identified.

NRC examiners noted that a black dot was missing from the Santiago line annunciator window in the simulator; that the simulator log books did not match the actual unit; and, two Foxboro controller faceplates were misspelled. Notifications were generated.

.5 Examination Security

a. Scope

The NRC examiners reviewed examination security during both the onsite preparation week and examination administration week for compliance with 10 CFR 55.49 and NUREG-1021. Plans for simulator security and applicant control were reviewed and discussed with licensee personnel.

b. Findings

No findings of significance were identified.

6 Enclosure

4OA6 Meetings, Including Exit

The chief examiner presented the preliminary examination results to Messrs. Doug Bauder, Plant Manager, Mike Graham, Manager of Plant Operations, and other members of the staff on October 23, 2009. A telephonic exit was conducted on November 5, 2009, between Messrs. Gabriel Apger, Chief Examiner, and Bill Arbour, Operations Training Manager.

The licensee did not identify any information or materials used during the examination as proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

Bill Arbour, Operations Training Manager

Geoff Cook, Manager of Compliance

NRC Personnel

Greg Warnick, Senior Resident Inspector