ML13081A142

the Independent Spent Fuel Storage Installation - Summary Report of Commitment Changes Implemented During the Period from March 29, 2012, Through March 01, 2013

ML13081A142
Person / Time
Site:	San Onofre
Issue date:	03/08/2013
From:	St.Onge R Southern California Edison Co
To:	NRC/FSME, Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
Download: ML13081A142 (6)

Text

SOUTHERN CALIFORNIA Richard [, St. Onge EDISON Director, Nuclear Regulatory Affairs and Emergency Planning An EDISON INTERNATIONAL Company 10 CFR 50.4 March 8, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C . 20555-0001

Subject:

Docket Nos. 50-206, 50-361, 50-362, and 72-41 Summary Report of Commitment Changes Implemented During the Period From March 29, 2012, Through March 01, 2013 San Onofre Nuclear Generating Station (SONGS) Units 1, 2 and 3, and the Independent Spent Fuel Storage Installation Dea r Sir or Mada m:

Pursuant to the guidance in Nuclear Energy Institute (NEI) 99-04, "Guidelines for Managing NRC Commitme nt Changes ," Revision 0, attached is a summary of comm itments changed during the period from March 29 , 2012 through March 01 , 2013. These commitment changes were evaluated by SONGS as not requ iring prior NRC approval. This letter provides NRC notification of these changes .

Attachme nt 1 includes a summary of regulatory commitment changes and a basis for each change. In addition , Attachment 2 provides a summary of changes to several voluntary commitments described in previous correspondence to the NRC. Althoug h not considered formal regulato ry commitments, SONGS has included these changes for your information.

This letter does not contain any new commitments . If you have any questions or would like any additional information , please contact Lee Kelly at (949) 368-6657.

Sincerely, Attachments: As Stated cc: E. E. Collins , Regional Adm inistrator, NRC Region IV R. Hall , NRC Project Manager, San Onofre Units 2 and 3 B. Benney, NRC Project Manager, San Onofre Units 2 and 3 G. G. Warn ick , NRC Senior Res ident Inspector, San Onofre Units 2 and 3 P.O. Box 128 San Clemente, CA 92672

ATTACHMENT 1-

SUMMARY

REPORT OF REGULATORY COMMITMENT CHANGES IMPLEMENTED DURING THE PERIOD FROM MARCH 29, 2012 THROUGH MARCH 01, 2013 SONGS Tracking Nos. Source(s) Proposed Action Change Summary and Basis for Change NRCTS 2007-04-001 SCE letter to NRC, The following action was stated in the April 16, 2007 The action was modified to allow alternate NN 202315010 dated April 16, 2007 , NOV response letter to NRC. methods of confirming proper area checks .

Reply to a Notice of The revised commitment wording is as Violation ; EA-06-303 follows :

Inspection Report No. "Corrective actions will be taken to provide a more 5000361/2007402 and positive confirmation of proper check performance, a "Corrective actions will be taken to provide a 5000362/2007402 San long-term project was created to use hand-held more positive confirmation of proper area Onofre Nuclear computers , in conjunction with bar codes, to check performance. "

Generation Station , document area checks electronically."

Units 2 and 3 Page 1 of 1

ATTACHMENT 2 -

SUMMARY

OF CHANGES TO VOLUNTARY COMMITMENTS DESCRIBED IN PREVIOUS CORRESPONDENCE TO NRC IMPLEMENTED DURING THE PERIOD FROM MARCH 29, 2012 THROUGH MARCH 01, 2013 SONGS Tracking Nos. Source(s) Proposed Action Change Summary and Basis for Change NRCTS 2009-10-025 SCE letter to NRC, dated October The following action was stated in Remove commitment from procedure NN202312775 29,2009, Independent Safety the October 29, 2009, letter to the S0123-XV-50.7 Change Management.

Culture Assessment Results and NRC.

Action Plans (Response to NRC The Performance Improvement Mid-Cycle Performance Review Organization Chart no longer has a change Letter) "Appoint a site leader to drive the management leader position. The Manage r applicat ion of change of Organizational Effectiveness will perform management." similar duties . SONGS procedure governing change management (S0123-XV-50.7) ensures this responsibility is implemented at SONGS .

NRCTS 2010-10-131 SCE letter to NRC, dated March The following action was stated in Revise the action to state:

NN 201989673 31,2010, Response to NRC to the October 12, 2010 , letter to the "After CARB approval of an RCE, evaluate SIBP 5.23.1.0 NRC Mid-Cycle Performance NRC. the need for a Change Management Plan, Review Letter - Modifications to IF required Submittals Then submit the Change Management Plan "Issue an approved Change to CARB for review in accordance with SCE letter to NRC, dated October Management Plan in accordance S0123-XV-50.7."

12,2010, Response to the NRC with procedure S0123-XV-50.7 Letter Regarding Midcycle (Change Management) with in 15 Removing the 15 day requirement allows Performance Review and calendar days , after CARB the RCE team and CARB the ability to Inspection Plan approval of the RCE and determine the appropriate time period to submitted to CARB for review , that complete this evaluation and submit it to address potential resources , CARB.

priority, and cost challenges throughout the station and includes , as appropriate, a training needs analys is."

[CARB - Corrective Action Review Board RCE - Root Cause Evaluation Page 1 of 4

ATTACHMENT 2 -

SUMMARY

OF CHANGES TO VOLUNTARY COMMITMENTS DESCRIBED IN PREVIOUS CORRESPONDENCE TO NRC IMPLEMENTED DURING THE PERIOD FROM MARCH 29, 2012 THROUGH MARCH 01, 2013 SONGS Tracking Nos. Source(s) Proposed Action Change Summary and Basis for Change NRCTS 2010-10-132 SCE letter to NRC, dated October The following action was stated in Revise the action to state :

NN 201872119-119 12, 2010, Response to the NRC the October 12, 2010, letter to the "Periodic update by MANAGEMENT SIBP 5.23.1.E Letter Regarding Midcycle NRC. SPONSOR(s) on their assigned RCE that Performance Review and is being conducted ."

Inspection Plan "Weekly update by Management Sponsor on their assigned RCE that is being conducted. " The Performance Improvement Division consistently monito rs the open CAP items, and works with the individual work groups to ensure timely and quality products are submitted to the CARB members in accordance with the CAP program requirements .

NRCTS 2010-10-133 SCE letter to NRC, dated October The following action was stated in Revise the action to state:

NN 201872119 -120 12,2010, Response to the NRC the Octobe r 12, 2010 , letter to the "Periodic review of open RCEs , ACEs ,

SIBP 5.23.1.F Letter Regarding Midcycle NRC. EFRs, and CAPRs completed but NOT yet Performance Review and reviewed by CARB" Inspection Plan "Weekly review of open RCEs, ACEs , EFRs, and CAPRs The Performance Improvement Division completed but not yet reviewed by consistently monitors the open CAP items, CARB " and works with the individ ual work groups to ensure timely and quality products are submitted to the CARB members in accordance with the CAP program requirements .

Page 2 of 4

ATTACHMENT 2 -

SUMMARY

OF CHANGES TO VOLUNTARY COMMITMENTS DESCRIBED IN PREVIOUS CORRESPONDENCE TO NRC IMPLEMENTED DURING THE PERIOD FROM MARCH 29, 2012 THROUGH MARCH 01, 2013 SONGS Tracking Nos. Source(s) Proposed Action Change Summary and Basis for Change NRCTS 2010-03-007 SCE letter to NRC, dated October The original proposed action was The commitment has been changed as NN 20 1994125-004 12,2010, Response to the NRC stated in the March 31, 2010 letter follows: "(CA PR) Revise S0123-XV-52 ,

SIBP 4.6.1.A and 4.21.1.A Letter Regarding Midcycle to NRC. Subsequently, the due Functio nality Assessments and Operab ility Performance Review and date was changed from January Determinations to incorporate industry Inspection Plan 23, 2010 June 1, 20 10, in SCE benchmarking and include: Clarity and letter to NRC, dated March 31, accuracy of process actions in an SCE letter to NRC, dated March 2010. The commitment was executable step format; the transfer of 31,2010, Response to NRC to reiterated in the October 12, 2010 depart menta l ownership of the process to NRC Mid-Cycle Performa nce letter, as follows : Operatio ns; incorporation of the INPO Review Letter - Modifications to Principles for an Effective Operational Submittals "(CAPR) Revise S0123-XV-52, Decision Making; an appropr iate Functionality Assessments and operabil ity checklist; real time, in line Operab ility Determinations to expert independent review of PODs and incorporate industry benchma rking periodic quality checks of 10Ds; appropr iate and include: Clarity and accuracy linkages to other processes (e.g., the of process actions in an Operational Decision Making Process)"

executable step format; the transfer of departmen tal SCE Management has determined that the ownership of the process to POD Real Time in-line review requirement Operations; incorpo ration of the is no longer necessary due to procedure INPO Principles for an Effective and traini ng enhancements , along with the Operational Decision Marking; an implemen tation of the operability appropriate opera bility checklist; determination quality review panel.

real-time, in-line expert independent review of PODs and periodic quality checks of 10Ds; appropriate linkages to other processes (e.g., the Operational Decision Making Process )"

Page 3 of 4

ATTACHMENT 2 -

SUMMARY

OF CHANGES TO VOLUNTARY COMMITMENTS DESCRIBED IN PREVIOUS CORRESPONDENCE TO NRC IMPLEMENTED DURING THE PERIOD FROM MARCH 29, 2012 THROUGH MARCH 01, 2013 SONGS Tracking Nos. Source(s) Proposed Action Change Summary and Basis for Change NRCTS 2008-02-019 SCE letter to NRC, dated The following action was stated This action was removed from the NN 202135160 February 2, 2008 , Response to SCE letter to NRC, dated surveillance program .

SIBP 9.7.2.F Confirmatory Order Item 2 with February 2, 2008.

Corrective Action Plan and The surveillance program has provided Monitoring Program "By April 1, 2008, SCE will reasonab le assurance that actions to deter incorporate into the SONGS and detect instances of deliberate non-oversight surveillance program , compliance are effective. In addition, in a periodic sampling of repetitive NRC letter dated 02/10/11 , the NRC rounds and log keeping activities determined that SCE has satisfied the to provide reasonable assurance terms of the Confirmatory Order. Therefore, that actions to deter and detect based on these results and NRC's instances of deliberate non- determination that the terms of the compliance are effective. This Confirmatory Order have been satisfied, oversight will include sampling of continuation of these surveillances is no SCE and contractor activities. (CO longer warranted.

Item 2.j)"

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