IR 05000361/2012004

IR 05000361-12-004, 05000362-12-004; 06/24/2012 - 09/23/2012; San Onofre Nuclear Generating Station, Units 2 & 3, Integrated Resident and Regional Report; Correction of Emerg. Prep. Weaknesses and Deficiencies, Rad. Solid Waste Processing a

ML12312A385
Person / Time
Site:	San Onofre
Issue date:	11/07/2012
From:	Ryan Lantz NRC/RGN-IV/DRP/RPB-D
To:	Peter Dietrich Southern California Edison Co
References
IR-12-004
Download: ML12312A385 (80)

Text

UNITE D S TATE S NUC LEAR RE GULATOR Y C OMMI S SI ON ber 7, 2012

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000361/2012004 and 05000362/2012004

Dear Mr. Dietrich:

On September 23, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your San Onofre Nuclear Generating Station Units 2 and 3 facility. The enclosed inspection report documents the inspection results which were discussed on October 2, 2012, with you and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

One NRC identified finding of very low safety significance (Green) was identified during this inspection. This finding was determined to involve a violation of NRC requirements.

Additionally, the NRC has determined that a traditional enforcement Severity Level IV violation occurred. Further, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest these non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at San Onofre Nuclear Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC Resident Inspector at San Onofre Nuclear Generating Station. 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/

Ryan E. Lantz, Chief Project Branch D Division of Reactor Projects Docket Nos.: 50-361, 50-362 License Nos: NPF-10, NPF-15

Enclosure:

Inspection Report 05000361/2012004 and 05000362/2012004 w/ Attachments:

1. Supplemental Information 2. Information Request for inspection activities documented in 71111.11 3. Information Request for inspection activities documented in 71124.05-71124.08

REGION IV==

Docket: 50-361, 50-362 License: NPF-10, NPF-15 Report: 05000361/2012004 and 05000362/2012004 Licensee: Southern California Edison (SCE)

Facility: San Onofre Nuclear Generating Station, Units 2 and 3 Location: 5000 S. Pacific Coast Hwy San Clemente, CA Dates: June 24 through September 23, 2012 Inspectors: L. Carson II, Senior Health Physicist B. Correll, Reactor Inspector P. Elkman, Senior Emergency Preparedness Inspector N. Greene, PhD, Health Physicist R. Kopriva, Senior Reactor Inspector J. Laughlin, Emergency Preparedness Inspector J. ODonnell, Health Physicist B. Parks, Project Engineer J. Reynoso, Resident Inspector L. Ricketson, P.E., Senior Health Physicist E. Schrader, Emergency Preparedness Specialist N. Taylor, Senior Project Engineer G. Warnick, Senior Resident Inspector M. Young, Reactor Inspector Approved Ryan E. Lantz, By: Project Branch D Division of Reactor Projects-1- Enclosure

SUMMARY OF FINDINGS

IR 05000361/2012004, 05000362/2012004; 06/24/2012 - 09/23/2012; San Onofre Nuclear

Generating Station, Units 2 and 3, Integrated Resident and Regional Report; Correction of Emerg. Prep. Weaknesses and Deficiencies, Rad. Solid Waste Processing and Rad. Mat.

Handling, Storage, and Transportation.

The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. One Green non-cited violation and one Severity Level IV violation of significance were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609,

Significance Determination Process. The cross-cutting aspect is determined using Inspection Manual Chapter 0310, Components Within the Cross Cutting Areas. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

Cornerstone: Public Radiation Safety

• SLIV. The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71, Maintenance of Records, Making of Reports, paragraph (e) which states, in part, Each person licensed to operate a nuclear power reactor shall update periodically, the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. Contrary to the above, from 1985 to June 2012, the licensee failed to update the Final Safety Analysis Report to assure that the information included in the report contains the latest information developed. Specifically, since its construction in 1985, the licensee stored a significant source of radioactivity in the Multi-Purpose Handling Facility (South Yard Storage Facility), but failed to describe the source, volume, and storage of radioactive equipment in the Final Safety Analysis Report. The licensee has entered this violation into their corrective action program as Nuclear Notification NN 202076593.

The inspectors determined that the failure to update the Final Safety Analysis Report as required by 10 CFR 50.71(e), Maintenance of Records, Making of Reports is a performance deficiency. This performance deficiency was dispositioned using traditional enforcement because failing to update a Final Safety Analysis Report had the potential to adversely impact the NRCs ability to perform its regulatory function. The performance deficiency is characterized as a Severity Level IV violation in accordance with the NRC Enforcement Policy,

Section 6.1.d.3. Since this issue was dispositioned using traditional enforcement, there is no cross-cutting aspect (Section 2RS08).

Cornerstone: Emergency Preparedness

Green.

The inspectors identified a non-cited violation of 10 CFR 50.47(b)(14) for failure to correct weaknesses or deficiencies that are identified in formal critiques of drills or exercises. The licensee did not take corrective actions for fourteen weaknesses in site assembly and evacuation, tracking of non-licensed operators, and provision of radiation protection to non-licensed operators, identified in critiques between September 2010 and June 2012. The failure to correct weaknesses identified in drills and exercises was a performance deficiency within the licensees control. This failure has been entered into the licensees corrective action program as Nuclear Notifications NNs 201974817, 201811829, and 201645589 This finding is more than minor because it affected the emergency response organization cornerstone attribute. The finding was evaluated using the Emergency Preparedness Significance Determination Process and determined to be of very low safety significance because it was a failure to comply and was not a loss of planning standard function. The finding was not a loss of planning standard function because the weaknesess that were not corrected were not associated with risk significant planning standards. This finding was assigned a corrective action cross-cutting aspect because San Onofre did not take corrective actions for numerous drill weaknesses in a timely manner commensurate with their safety significance P.1(d) (Section 1EP5).

Licensee-Identified Violations

A violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking number (Nuclear Notification NN 201841920) is listed in Section 4OA7.

REPORT DETAILS

Summary of Plant Status

Unit 2 began the inspection period shutdown for refueling outage R2C17 and remained shutdown for the duration of the inspection period.

Unit 3 began the inspection period shutdown for forced outage F3C16 and remained shutdown for the duration of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness to Cope with External Flooding

a. Inspection Scope

The inspectors evaluated the design, material condition, and procedures for coping with the design basis probable maximum flood. The evaluation included a review to check for deviations from the descriptions provided in the Updated Final Safety Analysis Report (UFSAR) for features intended to mitigate the potential for flooding from external factors.

As part of this evaluation, the inspectors checked for obstructions that could prevent draining, checked that the roofs did not contain obvious loose items that could clog drains in the event of heavy precipitation, and determined that barriers required to mitigate the flood were in place and operable. Specific documents reviewed during this inspection are listed in the attachment.

• July 27 - August 6, 2012, Unit 2, underground electric cable tunnel penetrations at elevation 9 foot-6 inches

• August 9, 2012, Units 2 and 3, emergency diesel generator building and tank building These activities constitute completion of two external flooding samples as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• July 10, 2012, Unit 2, shutdown cooling system during draining of reactor coolant system

• August 17, 2012, Unit 3, train A auxiliary feedwater system

• September 4, 2012, Unit 3, emergency diesel generator 3G002

• September 13, 2012, Unit 3, spent fuel pool cooling alignment The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• July 11, 2012, Units 2 and 3, auxiliary control building

• July 19, 2012, Unit 2, auxiliary control building 50 foot elevation

• August 3, 2012, Unit 3, containment building all elevations

• September 12, 2012, Unit 3, fuel handling building (all zones)

• September 12, 2012, Unit 3, spent fuel pool cooling pump and heat exchanger rooms The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees corrective action program.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

On July 16, 2012, the inspectors observed a fire brigade activation fire brigade activation in which the licensee simulated a fire in Unit 3 turbine building near generator hydrogen gas control cubicle 3L004. The observation evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:

(1) proper wearing of turnout gear and self-contained breathing apparatus;

(2) proper use and layout of fire hoses;

(3) employment of appropriate fire fighting techniques;

(4) sufficient firefighting equipment brought to the scene;

(5) effectiveness of fire brigade leader communications, command, and control;

(6) search for victims and propagation of the fire into other plant areas;

(7) smoke removal operations;

(8) utilization of preplanned strategies; (9)adherence to the pre planned drill scenario; and

(10) drill objectives.

These activities constitute completion of one annual fire-protection inspection sample as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the UFSAR, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected underground bunkers/manholes to verify the adequacy of sump pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the areas listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, and control circuits, and temporary or removable flood barriers. Specific documents reviewed during this inspection are listed in the attachment.

• August 26, 2012, Units 2 and 3, saltwater and condensate intake area These activities constitute completion of one flood protection measures inspection sample as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On September 19, 2012, the inspectors observed a crew of licensed operators in the plants simulator during requalification training for plant start up. The inspectors assessed the following areas:

• Licensed operator performance

• The modeling and performance of the control room simulator

• Follow-up actions taken by the licensee for identified discrepancies These activities constitute completion of one quarterly licensed operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk significant systems:

• September 4, 2012, Unit 3, completed review of emergency diesel generator 3G003 train B for use of compensatory measures with air-start receivers out of service

• September 20, 2012, Units 2 and 3, completed review of the 10 CFR 50.65(a)(3)

Periodic Evaluation The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

• Scoping of systems in accordance with 10 CFR 50.65(b)

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)

• Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of two quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• August 7, 2012, Unit 3, train B 480V bus breaker clean and inspect planned maintenance The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one maintenance risk assessments and emergent work control inspection sample as defined in Inspection Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the following assessments:

• July 20, 2012, Unit 3, completed review of operability evaluation for emergency diesel generator 3G003 train B air-start receiver tank T0338 air leak

• July 15, 2012, Units 2 and 3, saltwater cooling train postulated degradation following seismic event due to inadvertent circulating water gate failure

• August 7, 2012, Unit 3, safety-related 480V bus voltage control The inspectors selected these operability and functionality assessments based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure technical specification operability was properly justified and to verify the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three operability evaluations inspection samples as defined in Inspection Procedure 71111.15-05.

b. Findings

No findings were identified.

1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications

.1 Evaluations of Changes, Tests, or Experiments

a. Inspection Scope

The inspectors reviewed seven evaluations to determine whether the changes to the facility or procedures, as described in the UFSAR, had been reviewed and documented in accordance with 10 CFR 50.59 requirements. The inspectors verified that, when changes, tests, or experiments were made, evaluations were performed in accordance with 10 CFR 50.59 and licensee personnel had appropriately concluded that the change, test or experiment could be accomplished without obtaining a license amendment. The inspectors also verified that safety issues related to the changes, tests, or experiments were resolved. The inspectors compared the safety evaluations and supporting documents to the guidance and methods provided in Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, as endorsed by NRC Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, to determine the adequacy of the safety evaluations.

The inspectors reviewed 29 samples of changes, tests, and experiments that licensee personnel determined did not require evaluations and verified that the licensee personnels conclusions were correct and consistent with 10 CFR 50.59.

The inspectors also verified that calculations, analyses, design change documentation, procedures, the UFSAR, the technical specifications, and plant drawings used to support the changes were accurate after the changes had been made. Documents reviewed are listed in the attachment.

These activities constitute completion of seven samples of evaluations and 29 samples of changes, tests, and experiments that were screened out by licensee personnel as defined in Inspection Procedure 71111.17-04.

b. Findings

No findings were identified.

.2 Permanent Plant Modifications

a. Inspection Scope

The inspectors verified that calculations, analyses, design change documentation, procedures, the UFSAR, the technical specifications, and plant drawings used to support the modifications were accurate after the modifications had been made. The inspectors verified that modifications were consistent with the plants licensing and design bases.

The inspectors confirmed that revised calculations and analyses demonstrated that the modifications did not adversely impact plant safety. Additionally, inspectors interviewed design and system engineers to assess the adequacy of the modifications.

The inspectors reviewed thirteen permanent plant modifications, and specific documents reviewed during this inspection are listed in the attachment.

.2.1 Disable Unit 3 Emergency Diesel Generator 3G003 Stator Temperature High Trip Circuit

The inspectors reviewed Engineering Change Package NECP 070400701-25, implemented to address a problem with the emergency diesel generator high stator temperature trip circuitry. The trip is a noncritical protective trip of the emergency diesel generator. The circuitry had caused two spurious trips of the emergency diesel generators, and two other instances where erratic behavior was identified prior to tripping of the generators. The modification removed the high temperature trip; however it maintained the high stator temperature alarm to alert operators. The inspectors verified the trip was removed and ensured the modification was in accordance with design.

.2.2 Replace Salt Water Cooling Pumps

The inspectors reviewed Engineering Change Package NECP 020700918-5, implemented to replace the existing 316L stainless steel salt water cooling pumps with 6% molybdenum alloy. The existing salt water cooling pumps required frequent overhaul due to corrosion, and the replacement pumps are made a more corrosion resistant material which will provide more reliability. The inspectors reviewed the design differences between the replacement and the existing pumps, and reviewed the submergence calculations to verify that the new pumps would continue to meet the safety analysis. The inspectors walked down the salt water cooling pumps to ensure installation of the modification was in accordance with design.

.2.3 Remove the Level Switch Low-Low Trip for Emergency Diesel Generator Fuel Oil

Transfer Pumps (Normal and Standby)

The inspectors reviewed Engineering Change Package NECP 800071684, implemented to address a problem with the emergency diesel generator fuel oil transfer pumps, both normal and standby, tripping on low-low level. The pumps were designed with a low-low level trip to protect the pumps under a low fuel oil condition. Currently, the trip level is sensed by a common level transmitter. If the level transmitter were to fail, there is a potential to lose both fuel oil transfer pumps and prevent one fuel storage tank from being pumped to the day tank. The modification removed the low-low level trip from both the normal and standby fuel oil transfer pumps. The inspectors reviewed the procedure and design changes to ensure that the removal of the trip set points would not alter the function of the pumps as described in the safety analysis. The inspectors reviewed electrical schematics, both prior to and after the modification, to determine that the low-low fuel oil tank level would not trip the fuel oil transfer pumps. Additionally, the inspectors performed a field walk down of fuel oil transfer pumps cubicles 2BD23 and 2BD24 to visually inspect that the field wiring was installed in accordance with the design.

.2.4 Unit 3 AFW Pump Constant Level Oiler Replacement

The inspectors reviewed Engineering Change Package NECP 060400870-10, implemented to address an upgrade to the constant level oilers for the Unit 3 auxiliary feedwater pumps. The existing constant level oilers do not have an acceptable range of adjustment. The design change installed a Trico closed system with sight gauge constant level oiler to ensure that the proper lubrication is applied to the pump. The inspectors reviewed the seismic design differences between the replacement and the existing constant level oiler, and verified the new oiler is capable of lubricating the pump bearings. The inspectors walked down all of the Unit 3 auxiliary feedwater pumps to ensure installation of the modification was in accordance with design.

.2.5 2G003 Emergency Diesel Generator Annunciator Manual Transfer Switch, Capacitors

and Fuses The inspectors reviewed Engineering Change Package NECP 800578751, implemented in support of NECP 800611702 (Section 2.9) to provide a manual transfer switch, filter capacitors, and fuses in the diesel generator control panel power supplies for the local annunciator panel. The modification changed the power supply to the diesel control panel annunciator to a non-class 1E supply, added filter capacitors and fuses to address a failure mechanism that occurred on December 12, 2009, which caused the diesel generator to be declared inoperable. This design change enabled the licensee to power the annunciator panel from isolated power supplies to prevent annunciator failures from affecting the operability of the diesel generator. The inspectors performed a field walk down of the transfer switch and reviewed the local annunciator response procedure to verify proper procedural guidance associated with the transfer switch operation.

.2.6 Replace Existing Q-Panel 15kVA XFMR with a New Model Per SEE 070029

The inspectors reviewed Engineering Change Package NECP 070200268, implemented to replace the existing 15 kVA T033 MCC BQ to Q033 Transformer, with a new 15 kVA Square D transformer. The design function of the transformer is to provide 120/208 Volt power to various 1E distribution panels. The inspectors reviewed calculations to ensure impedance values and power capability of the new transformer does not adversely affect the component design function. This modification was an equivalent equipment substitution and did not adversely affect the system or components.

.2.7 Control Circuit Changes High Pressure Safety Injection Pump 3P018

The inspectors reviewed Engineering Change Package NECP 800530463, implemented to modify the control circuit for high pressure safety injection pump 3P018. The modification changed the number of indicating lights in series with the breaker trip coil to prevent spurious breaker trips of a new Nuclear Logistics Inc (NLI) breaker. The modification was necessary due to the new NLI breaker trip coil resistance being higher than the existing breakers trip coil resistance. The inspectors reviewed the tests performed by NLI to confirm the maximum number of indicating lights that could be in series with the trip coil to be two indicating lights. The inspectors reviewed the control circuit schematics and compared the post-modification schematics to the control circuit wiring prior to the modification to ensure there were no more than two indicating lights in series with the trip coil.

.2.8 Replace 480V Charging Pump Breakers 2B0613 & 2B0617

The inspectors reviewed Engineering Change Package NECP 800706338, implemented to replace train B charging pump breakers 2B0613 and 2B0617. The modification replaced the existing ABB circuit breaker with new Square D/NLI breakers that utilize a Micrologic trip device. The existing ABB breaker trip device is unable to be adjusted low enough to protect the charging pump cables. The modification also altered the number of indicating lights in series with the trip circuit (similar to the modification discussed in section 2.7). The inspectors reviewed the schematics to verify the circuit modification correctly modified the indicating lights, and verified proper circuit coordination between the breaker trip settings and cable damage criteria.

.2.9 Battery Charger for Emergency Diesel Generator 2G002 Annunciator Power

The inspectors reviewed Engineering Change Package NECP 800611702, implemented to install a battery charger with a self-contained battery bank to provide non-class 1E electrical power to the diesel control panel annunciator circuits. This modification, in conjunction with Engineering Change Package NECP 800578751 (section 2.5), prevents a failure in the diesel control panel annunciator power supply from affecting emergency diesel generator operability. The inspectors reviewed the modification for isolation characteristics and proper sizing of the charger and battery bank. The inspectors also performed a field walk down to inspect the battery charger and associated battery for verification of proper installation and operation.

.2.10 Replace Valve S2.ECCS.2HV9328 - Low Pressure Safety Injection Header to Reactor

Coolant System Loop 2A The inspectors reviewed Engineering Change Package NECP 800350419, implemented to replace motor operated valve 2HV9328. The reason for the valve replacement was that water from safety injection tank S21204MT009 was leaking past check valve S21204MU074 and motor operated valve 2HV9328.

The replacement Target Rock valve 2HV9328 was an equivalent replacement in accordance with Substitution Equivalency Evaluation SEE-01-0031. The new valve has the form, fit, and function as the original valve. The replacement valve did not include the Limitorque motor operator, as the existing motor operator was reused. The revised drawing showed that the new valve weighed more than the old valve. Engineering Change Notice ECN D0019442 was issued against Calculation M-120-017-AA, Revision 8, to account for the weight increase. Pipe supports impacted by the design load increase were re-evaluated in Calculation P-450-1.044, Revision 15. The old valve and replacement valve were constructed to Quality Control II, Seismic I requirements.

The weight increase of the replacement valve did not adversely impact the seismic analysis or change the valves center of gravity per the civil engineering analysis performed.

.2.11 Diesel Fuel Change to Ultra Low Sulfur Diesel Fuel

The inspectors reviewed Engineering Change Package NECP 040301409-3, implemented to change the emergency diesel generator fuel oil to ultralow sulfur diesel fuel. The functional objective of the change to ultralow sulfur diesel fuel was to assure that all affected documentation was changed and proper engineering evaluations were performed so that San Onofre Nuclear Generating Station would be ready to purchase/accept ultralow sulfur diesel fuel starting June 2006, as mandated by California Air Pollution Control Regulations. The calculation showed that to accept the ultralow sulfur diesel fuel, the minimum diesel fuel volumes required to meet the Technical Specifications surveillance requirements were increased. This engineering change package changed the set-points for minimum volume requirements in the storage tanks and the day tanks, and set-point changes were included in the engineering package for implementation.

The inspectors verified the minimum volume required for both the day tanks and the main storage tanks with the new fuel was performed in accordance with NRC Regulatory Guide 1.137, Revision 1 and ANSI N195/ANS59.51 standards. There was no impact on the electrical loading and plant safety-related battery load profile was not affected.

.2.12 U3 Replacement of Pressurizer Heaters

The inspectors reviewed Engineering Change Package NECP 071100597-18, implemented to replace certain pressurizer heaters. As of May 1, 2008, four pressurizer heaters were out of service and/or degraded, and needed to be replaced. In addition, two pressurizer heaters of the old Thermocoax first generation still remain in the plant.

This type of heater had been deemed to be defective based on past experience and root cause evaluations, and also need to be replaced.

The functional objective of replacing the pressurizer heaters was to restore the total available heat input of the system to original design requirements and to improve the reliability of the system. The safety function of the heaters is to maintain the reactor coolant system pressure boundary requirements. The inspectors reviewed design changes including a redesigned finned receptacle with a ceramic insulator and added distance between the pressurizer wall (heat source) and the receptacle, as well as improved curing process of the epoxy resin filler. The new Therocoax heaters are equivalent and improved replacements of the existing heaters. This change did not affect the bounding technical requirements, the design basis functions, or any operational characteristics of the heaters and/or associated electrical and mechanical equipment. The safety function was not affected or compromised by the implementation of the modification.

.2.13 Replace existing Shutdown Cooling Suction/Isolation Motor Operated Valve 2HV9337

Motor The inspectors reviewed Engineering Change Package NECP 800580980, implemented to replace the shutdown cooling suction isolation motor-operated valve (MOV) 2HV9337 motor. The licensee reviewed NRC Information Notice IN 2006-26, Failure of Magnesium Rotors in Motor-Operated Valve Actuators, and identified MOV 2HV9337 motor as being susceptible to the degradation identified in the information notice. The industry had experienced recent failures of motor-operated valve actuators attributed to the oxidation and corrosion of the magnesium motor rotor fan blades and shorting ring from exposure to high humidity and temperatures. The three main failure mechanisms are galvanic corrosion, general corrosion, and thermally induced stress. The replacement motor is constructed of aluminum rotor bars instead of aluminum/magnesium rotor bars of the existing motor.

Engineering Design Change Package NECP 800580980, replaced the existing shutdown cooling suction isolation MOV 2HV9337 9.9hp motor with a new Reliance electric motor per Substitution Equivalency Evaluation SEE-070058. The inspectors verified that the design change did not adversely impact existing plant design requirements for all operating modes, and did not impact intended and unintended equipment operation. There was no change in the design base safety function of shutdown cooling suction isolation MOV 2HV9337, which is to isolate the shutdown cooling system from the reactor coolant system during normal power operation. The motor was evaluated and environmentally qualified to demonstrate that the motor was compatible and interchangeable with the original equipment. The new motor is 25 lbs heavier and did not adversely impact the seismic analysis or change the motor operated valves center of gravity per the civil engineering analysis performed.

These activities constitute completion of thirteen samples of permanent plant modifications as defined in Inspection Procedure 71111.17-04.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• September 4, 2012, Unit 3, return to service testing for work performed per Maintenance Order MO 800941351 on emergency diesel generator 3G002

• September 6, 2012, Units 2 and 3, fire protection water pump MP224 post-maintenance testing

• September 11, 2012, Units 2 and 3, toxic gas monitor post-maintenance testing

• September 13, 2012, Unit 3, mechanical seal and oil supply piping replacement in spent fuel pool cooling pump 3MP010

• September 13, 2012, Unit 3, 42X relay replacement in spent fuel pool cooling pump 3MP010

• September 18, 2012, Unit 3, containment spray pump post-maintenance performance test

• September 18, 2012, Unit 2, testing for engineered safeguards feature subgroup relay 2L034K109 replacement The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

• The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

• Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate The inspectors evaluated the activities against the technical specifications, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of seven post-maintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

.1 Refueling Outage

a. Inspection Scope

The inspectors reviewed the outage safety plan and contingency plans for the Unit 2 refueling outage R2C17, which started January 9, 2012, to confirm that licensee personnel had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense in depth. During the refueling outage, the inspectors monitored licensee controls over the outage activities listed below.

• Configuration management, including maintenance of defense in depth, is commensurate with the outage safety plan for key safety functions and compliance with the applicable technical specifications when taking equipment out of service

• Clearance activities, including confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing

• Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication, accounting for instrument error

• Status and configuration of electrical systems to ensure that technical specifications and outage safety-plan requirements were met, and controls over switchyard activities

• Monitoring of decay heat removal processes, systems, and components

• Verification that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system

• Reactor water inventory controls, including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss

• Controls over activities that could affect reactivity

• Maintenance of secondary containment as required by the technical specifications

• Licensee identification and resolution of problems related to refueling outage activities Specific documents reviewed during this inspection are listed in the attachment.

Refueling Outage R2C17 was still in progress at the end of this inspection period.

Consequently, these activities constitute only a partial completion of one refueling outage and other outage inspection sample as defined in Inspection Procedure 71111.20-05.

b. Findings

No findings were identified.

.2 Forced Outage

a. Inspection Scope

The inspectors reviewed the outage safety plan and contingency plans for the Unit 3 forced outage F3C16, which started January 31, 2012, to confirm that licensee personnel had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense-in-depth. During the forced outage, the inspectors monitored licensee controls over the outage activities listed below.

• Configuration management, including maintenance of defense-in-depth, is commensurate with the outage safety plan for key safety functions and compliance with the applicable technical specifications when taking equipment out of service

• Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication, accounting for instrument error

• Status and configuration of electrical systems to ensure that technical specifications and outage safety-plan requirements were met, and controls over switchyard activities

• Monitoring of decay heat removal processes, systems, and components

• Reactor water inventory controls, including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss

• Controls over activities that could affect reactivity

• Maintenance of secondary containment as required by the technical specifications

• Licensee identification and resolution of problems related to refueling outage activities Specific documents reviewed during this inspection are listed in the attachment The forced outage F3C16 was still in progress at the end of this inspection period.

Consequently, these activities constitute only a partial completion of one forced outage and other outage inspection sample as defined in Inspection Procedure 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the UFSAR, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

• Reference setting data

• Annunciators and alarms setpoints The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

• August 6-7, 2012, Unit 3, emergency diesel generator 3G003 train B air-start receiver pressure verification

• August 13, 2012, Unit 3, semi-annual testing of emergency diesel generator 3G003 train B

• September 11, 2012, Unit 2, containment spray pump train B in-service test

• September 12, 2012, Unit 3, electrical bus 3B002 train B battery charger test

• September 16, 2012, Unit 2, saltwater cooling system train B in-service test Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five surveillance testing inspection samples as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

1EP2 Alert Notification System Testing

a. Inspection Scope

The inspectors discussed with licensee staff the operability of offsite siren emergency warning systems and backup alerting methods, to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50, Appendix E. The licensees alert and notification system testing program was compared with criteria in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1; FEMA Report REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants; and the licensees current FEMA-approved alert and notification system design report, San Onofre Generating Station System Design Report, Alert and Notification System, revision dated December 8, 2010. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.02-05.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Augmentation Testing

a. Inspection Scope

The inspectors discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to determine the adequacy of licensee methods for staffing primary and alternate emergency response facilities in accordance with their emergency plan. The inspectors also reviewed the training provided the on-shift emergency response staff to ensure timely augmentation under all conditions, and selected nuclear notifications (entries in the licensee corrective action program) related to emergency response augmentation. The inspectors reviewed the documents and references listed in the attachment to this report, to evaluate the licensees ability to staff the emergency response facilities in accordance with the licensees emergency plan and the requirements of 10 CFR Part 50, Appendix E. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.03-05.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The NSIR Headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS accession number ML121850028, ML12202A642, and ML12202A639 as listed in the Attachment.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment.

These activities constitute completion of eight samples as defined in Inspection Procedure 71114.04-05.

b. Findings

No findings were identified.

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies

a. Inspection Scope

The inspectors reviewed:

• Licensee corrective action program requirements in Procedures SO123-XV-50, Corrective Action Program, Revision 25, SO123-XV-50.CAP-1, Writing Nuclear Notifications for Problem Identification and Resolution, Revision 8, and SO123-XV-50.CAP-2, SONGS Nuclear Notification Screening, Revision 12;

• Summaries of four hundred eighty corrective action program entries (nuclear notifications) assigned to the emergency preparedness department and emergency response organization between September 2010 and June 2012;

• Licensee audits, assessments, drill evaluations, and post-event after action reports prepared between June 2010 and June 2012;

• Memorandum of Understanding between the licensee and offsite agencies and organizations relied upon to support site emergency response efforts;

• Licensee procedures and training for the evaluation of changes to the site emergency plans;

• Maintenance records for equipment relied upon to support site emergency response efforts; and,

• Alternate facilities for the licensees Technical Support Center and Operations Support Center.

The inspectors selected thirty-nine nuclear notifications for detailed review against the program requirements. The inspectors evaluated the response to issues entered into the site corrective action program to determine the licensees ability to identify, evaluate, and correct problems in accordance with the licensee program requirements, planning standard 10 CFR 50.47(b)(14), and 10 CFR Part 50, Appendix E. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.05-05.

b. Findings

Introduction.

A Green non-cited violation was identified for the licensees failure to correct performance weaknesses identified during site drills conducted between June 2010 and October 2011, as required by 10 CFR 50.47(b)(14).

Description.

The NRC identified fourteen examples of performance weaknesses identified by San Onofre as a result of drills and exercises that were not corrected in accordance with their safety significance.

The inspectors reviewed eleven drill evaluation reports for drills conducted between June 2010 and October 2011. The inspectors identified the licensees threshold for a weakness was identical to the NRCs definition of a weakness in Manual Chapter 0609, Appendix B, Section 2. The licensee drill reports identified thirty-three weaknesses associated with ten drills. The inspectors verified that all performance issues identified in drill evaluation reports had been entered into the licensees corrective action system.

The inspectors discussed with licensee staff the status of fourteen weaknesses in implementing site assembly and evacuation, tracking non-licensed operators in the plant during emergencies, and providing radiation protection to non-licensed operators. The corrective action program entries (nuclear notifications) for these weaknesses were assigned corrective action significance 4, Low Level Problem, Take Action/Trend, and were closed without specific corrective actions having been taken.

The inspectors also reviewed:

• Nuclear Notification NN 201599988, EP - Drill Recurring Issues, initiated August 11, 2011;

• Common Cause Evaluation CCE 201974817, EP Repeat Issues, initiated May 7, 2012, and completed June 19, 2012;

• Nuclear Notification NN 201984321, Drill and Exercise Performance, initiated May 14, 2012; and,

• Nuclear Notification NN 201984814, Lack of Division Support to resolve drill performance issues, initiated May 14, 2012.

The licensee noted continuing negative trends in drill and exercise performance, and determined that an ongoing emphasis on using human performance tools had failed to reverse the observed trend(s).

The inspectors reviewed post-event after action reports (critiques) for emergencies declared on July 16, 2011, November 1, 2011, and April 20, 2012, and identified weaknesses that had been critiqued by the licensee. The inspectors verified that all weaknesses occurring in emergency events had been entered into the licensees corrective action program. The inspectors noted that the licensee did not apply the same evaluation methodology to event critiques that was applied to drills and exercises.

While event performance was adequately critiqued, performance was not characterized as adequate, needing improvement, weak, or deficient. Performance issues arising from events that warranted designation as a weakness were also assigned corrective action significance 4. Some event performance issues had been closed to trend without specific corrective actions having been taken.

The inspectors concluded the licensee failed to correct identified performance weaknesses, in part, because:

• The licensee did not identify the safety significance (e.g. demonstrated with issues, weakness, deficiency) of performance issues in their drill evaluation or after-action reports;

• The licensee did not identify the safety significance of performance issues in their corrective action system;

• The licensee routinely assigned corrective actions for weaknesses the same corrective action program significance level as corrective actions for less safety-significant issues;

• The licensee did not track the status of weaknesses after issues were identified; and,

• The emergency preparedness department did not clearly understand the need to take action to correct individual weaknesses.

Analysis.

The inspectors determined the failure to correct weaknesses identified as a result of emergency preparedness drills is a performance deficiency within the licensees control. The failure to correct weak performance affecting implementation of the site emergency plan had a credible impact on the emergency preparedness cornerstone objective. This finding is more than minor because it affected the emergency response organization cornerstone attribute. The finding was associated with a violation of NRC requirements. This finding was evaluated using the Emergency Preparedness Significance Determination Process and was determined to be of very low safety significance (Green) because it was a failure to comply and was not a loss of planning standard function. The finding was not a loss of planning standard function because the weaknesess that were not corrected were not associated with risk significant planning standards. This finding was assigned a corrective action cross-cutting aspect within the problem identification and resolution area, because San Onofre did not take corrective actions for drill weaknesses in a timely manner commensurate with their safety significance P.1(d).

Enforcement.

Title 10 of the Code of Federal Regulations, Part 50.47(b)(14) states in part that deficiencies identified as a result of exercises or drills are (will be) corrected.

Appendix E to Part 50, IV.F(2)(g) states in part that weakness or deficiencies that are identified in a critique of exercises, drills or training must be corrected. Contrary to the above, between September 2010 and June 2012, San Onofre failed to correct weaknesses or deficiencies identified in critiques of exercises, drills or training.

Specifically, the licensee did not take corrective actions for fourteen weaknesses in implementation of site assembly and evacuation, tracking of non-licensed operators, and the provision of radiation protection to non-licensed operators. These performance weaknesses were identified by the licensee in drills conducted between June 2010 and October 2011. Because this failure is of very low safety significance and has been entered into the licensees corrective action program as Nuclear Notifications NNs 201974817, 201811829, and 201645589, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000361;05000362/2012004-01, Failure to Correct Drill Performance Weaknesses.

1EP6 Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on August 28, 2012, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in both the Technical Support Center and Emergency Operations Facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

This area was inspected to verify the licensee is assuring the accuracy and operability of radiation monitoring instruments that are used to:

(1) monitor areas, materials, and workers to ensure a radiologically safe work environment; and

(2) detect and quantify radioactive process streams and effluent releases. The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance.

During the inspection, the inspectors interviewed licensee personnel, performed walkdowns of various portions of the plant, and reviewed the following items:

• Selected plant configurations and alignments of process, postaccident, and effluent monitors with descriptions in the Final Safety Analysis Report and the offsite dose calculation manual

• Select instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks

• Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, postaccident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, continuous air monitors

• Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.05-05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

This area was inspected to:

(1) ensure the gaseous and liquid effluent processing systems are maintained so radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure;

(2) ensure abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, are controlled in accordance with the applicable regulatory requirements and licensee procedures;

(3) verify the licensees quality control program ensures the radioactive effluent sampling and analysis requirements are satisfied so discharges of radioactive materials are adequately quantified and evaluated; and

(4) verify the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190; the Offsite Dose Calculation Manual, and licensee procedures required by the Technical Specifications as criteria for determining compliance. The inspectors interviewed licensee personnel and reviewed and/or observed the following items:

• Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection, if any

• Effluent program implementing procedures, including sampling, monitor setpoint determinations and dose calculations

• Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, and significant changes to their effluent release points, if any, and associated 10 CFR 50.59 reviews

• Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis)

• Controls used to ensure representative sampling and appropriate compensatory sampling

• Results of the inter-laboratory comparison program

• Effluent stack flow rates

• Surveillance test results of technical specification-required ventilation effluent discharge systems since the previous inspection

• Significant changes in reported dose values, if any

• A selection of radioactive liquid and gaseous waste discharge permits

• Part 61 analyses and methods used to determine which isotopes are included in the source term

• Offsite dose calculation manual changes, if any

• Meteorological dispersion and deposition factors

• Latest land use census

• Records of abnormal gaseous or liquid tank discharges, if any

• Groundwater monitoring results

• Changes to the licensees written program for indentifying and controlling contaminated spills/leaks to groundwater, if any

• Identified leakage or spill events and entries made into 10 CFR 50.75(g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term

• Offsite notifications, and reports of events associated with spills, leaks, or groundwater monitoring results, if any

• Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample, as defined in Inspection Procedure 71124.06-05.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

a. Inspection Scope

This area was inspected to:

(1) ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program;

(2) verify that the radiological environmental monitoring program is implemented consistent with the licensees technical specifications and/or offsite dose calculation manual, and to validate that the radioactive effluent release program meets the design objective contained in Appendix I to 10 CFR Part 50; and

(3) ensure that the radiological environmental monitoring program monitors non-effluent exposure pathways, is based on sound principles and assumptions, and validates that doses to members of the public are within the dose limits of 10 CFR Part 20 and 40 CFR Part 190, as applicable. The inspectors reviewed and/or observed the following items:

• Annual environmental monitoring reports and offsite dose calculation manual

• Selected air sampling and thermoluminescence dosimeter monitoring stations

• Collection and preparation of environmental samples

• Operability, calibration, and maintenance of meteorological instruments

• Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement

• Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach ground water

• Records required by 10 CFR 50.75(g)

• Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection

• Calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation

• Interlaboratory comparison program results

• Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.07-05.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

This area was inspected to verify the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180 for determining compliance. The inspectors interviewed licensee personnel and reviewed the following items:

• The solid radioactive waste system description, process control program, and the scope of the licensees audit program

• Control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition

• Changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in place

• Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

• Processes for waste classification including use of scaling factors and 10 CFR Part 61 analysis

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest

• Audits, self-assessments, reports, and corrective action reports radioactive solid waste processing, and radioactive material handling, storage, and transportation performed since the last inspection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.08-05.

b. Findings

Introduction.

The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.71(e), Maintenance of Records, Making of Reports for failure to update the Final Safety Analysis Report associated with the Multi-Purpose Handling Facility.

Description.

In 1985, the licensee built the Multi-Purpose Handling Facility for interim storage of solid, low-level radioactive waste. This facility is also known as the South Yard Facility. From the licensees estimation, the storage facility contains approximately 538 curies of radioactive material. During the June 2012 radiation safety inspection, NRC inspectors toured this facility and identified that this significant source of radioactivity was not adequately described in Chapter 11.4, Solid Waste Management System, of the licensees Final Safety Analysis Report in accordance with the level of detail described in Regulatory Guide 1.70, Revision 2, Standard, Format, and Content of a Safety Analysis Report. The licensee confirmed that they were committed to following this guidance. Specifically, the licensee failed to describe the source, volume, and storage of radioactive material contained in the Multi-Purpose Handling Facility in the Final Safety Analysis Report. This issue was entered into the licensees corrective action program as Nuclear Notification NN 202076593.

Analysis.

The inspectors determined that the failure to update the Final Safety Analysis Report as required by 10 CFR 50.71(e), Maintenance of Records, Making of Reports is a performance deficiency. This performance deficiency was dispositioned using traditional enforcement because failing to update a Final Safety Analysis Report had the potential to adversely impact the NRCs ability to perform its regulatory function. The performance deficiency is characterized as a Severity Level IV violation in accordance with the NRC Enforcement Policy, Section 6.1.d.3. Since this issue was dispositioned using traditional enforcement, there is no cross-cutting aspect.

Enforcement.

10 CFR 50.71 (e), states, in part, that each person licensed to operate a nuclear power reactor shall update periodically the Updated Safety Analysis Report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. Contrary to the above, from 1985 to June 2012, the licensee failed to update the Final Safety Analysis Report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed.

Specifically, since its construction in 1985, the licensee stored a significant source of radioactivity in the Multi-Purpose Handling Facility, but failed to describe the source, volume, and storage of radioactive equipment in the updated Final Safety Analysis Report. The licensee has entered this violation into their corrective action program as Nuclear Notification NN 202076593. This violation is characterized as a Severity Level IV violation in accordance with the NRC Enforcement Policy, Section 6.1.d.3. This violation is being treated as a non-cited violation in accordance with the NRC Enforcement Policy, Section 2.3.2: NCV 05000361;05000362/2012004-02, Failure to Update the Final Safety Analysis Report for Solid Radioactive Waste.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the 2nd Quarter 2012 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.

This review was performed as part of the inspectors normal plant status activities and, as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index - Residual Heat Removal System (MS09)

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - residual heat removal system performance indicator for Units 2 and 3, for the period from the 3rd quarter 2011 through January 2012. Based on the lack of critical hours since January 2012, this performance indicator became invalid since unavailability is only counted if the reactor is critical. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of July 2011 through March 2012 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of two mitigating systems performance index -

residual heat removal systems sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index - Cooling Water Systems (MS10)

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - cooling water systems performance indicator for Units 2 and 3, for the period from the 3rd quarter 2011 through January 2012. Based on the lack of critical hours since January 2012, this performance indicator became invalid since unavailability is only counted if the reactor is critical. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of July 2011 through June 2012 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of two mitigating systems performance index -

cooling water system samples as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.4 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill and Exercise Performance, performance indicator for the period April 2011 through March 2012. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used.

The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator; assessments of performance indicator opportunities during predesignated control room simulator training sessions, performance during the 2011 biennial exercise, and performance during other drills. The specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the drill/exercise performance sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.5 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspectors sampled licensee submittals for the Emergency Response Organization Drill Participation performance indicator for the period April 2011 through March 2012.

To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, was used. The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance.

Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator, rosters of personnel assigned to key emergency response organization positions, and exercise participation records. The specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the emergency response organization drill participation sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.6 Alert and Notification System (EP03)

a. Inspection Scope

The inspectors sampled licensee submittals for the Alert and Notification System performance indicator for the period April 2011 through March 2012. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, was used.

The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator and the results of periodic alert notification system operability tests. The specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the alert and notification system sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensees corrective action program because of the inspectors observations are included in the attached list of documents reviewed.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees corrective action program. The inspectors accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensee's minor deficiency monitoring program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on equipment issues, but also considered the results of daily corrective action item screening, performance improvement, and performance monitoring results. The inspectors nominally considered the 6-month period of February 2012 through August 2012, although some examples expanded beyond those dates where the scope of the trend warranted.

The inspectors also included issues documented in the corrective action program in minor deficiencies problem lists, annual performance review, periodic cross-functional reviews, and system health reports. The inspectors reviewed the minor deficiency process to ensure items were clearly identified to ensure proper tracking. The inspectors compared and contrasted their results with the results contained in the licensee's formal tracking and monitoring programs. The corrective actions associated with a sample of the issues identified in the trending reports were reviewed for adequacy.

These activities constitute completion of one single semi-annual trend inspection sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion

Event Follow-up

a. Inspection Scope

The inspectors reviewed the below listed events for plant status and mitigating actions to:

(1) provide input in determining the appropriate agency response in accordance with Management Directive 8.3, NRC Incident Investigation Program;

(2) evaluate performance of mitigating systems and licensee actions; and

(3) confirm that the licensee properly classified the event in accordance with emergency action level procedures and made timely notifications to NRC and state/governments, as required.

• June 28, 2012, Unit 2, event follow up on inadvertent leakage from the reactor coolant system to the refueling water storage tank during safety injection valve testing

• August 26, 2012, Units 2 and 3, response to Notice of Unusual Event declaration due to seismic activity felt onsite Documents reviewed by the inspectors are listed in the attachment.

These activities constitute completion of two inspection samples as defined in Inspection Procedure 71153-05.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 (Open) Temporary Instruction 2515/187 - Inspection of Near-Term Task Force

Recommendation 2.3 Flooding Walkdowns

a. Inspection Scope

Inspectors verified that licensees walkdown packages contained the elements as specified in NEI 12-07 Walkdown Guidance document:

The inspectors accompanied the licensee on their walkdown of Unit 2 underground electric cable tunnel penetrations at elevation 9 foot-6 inches, Unit 3 emergency diesel generator building, and Unit 2 tank building and verified that the licensee confirmed the following flood protection features:

• Visual inspection of the flood protection feature was performed if the flood protection feature was relevant. External visual inspection for indications of degradation that would prevent its credited function from being performed was performed.

• Reasonable simulation.

• Critical SSC dimensions were measured.

• Available physical margin, where applicable, was determined.

• Flood protection feature functionality was determined using either visual observation or by review of other documents.

The inspectors verified that noncompliances with current licensing requirements, and issues identified in accordance with the 10 CFR 50.54(f) letter, Item 2.g of Enclosure 4, were entered into the licensee's corrective action program. In addition, issues identified in response to Item 2.g that could challenge risk significant equipment and the licensees ability to mitigate the consequences will be subject to additional NRC evaluation.

b. Findings

No findings were identified.

.2 (Open) Temporary Instruction 2515/188 - Inspection of Near-Term Task Force

Recommendation 2.3 Seismic Walkdowns

a. Inspection Scope

The inspectors accompanied the licensee on their seismic walkdowns of the Unit 3 auxiliary feedwater pump building and Unit 3 emergency diesel generator building, and verified that the licensee confirmed that the following seismic features associated with auxiliary feedwater system train A components; and emergency diesel generator 3G002 electrical bus 3BD and transformer panel were free of potential adverse seismic conditions:

• Anchorage was free of bent, broken, missing or loose hardware.

• Anchorage was free of corrosion that is more than mild surface oxidation.

• Anchorage was free of visible cracks in the concrete near the anchors.

• Anchorage configuration was consistent with plant documentation.

• SSCs will not be damaged from impact by nearby equipment or structures.

• Overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls are secure and not likely to collapse onto the equipment.

• Attached lines have adequate flexibility to avoid damage.

• The area appears to be free of potentially adverse seismic interactions that could cause flooding or spray in the area.

• The area appears to be free of potentially adverse seismic interactions that could cause a fire in the area.

• The area appears to be free of potentially adverse seismic interactions associated with housekeeping practices, storage of portable equipment, and temporary installations (e.g., scaffolding, lead shielding).

Observations made during the walkdown that could not be determined to be acceptable were entered into the licensees corrective action program for evaluation.

Additionally, inspectors verified that items that could allow the spent fuel pool to drain down rapidly were added to the seismic walkdown equipment list (SWEL) and these items were walked down by the licensee.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On June 27, 2012, regional inspectors presented the IR17 inspection results to Mr. G. Kline, Senior Director, Engineering & Technical Services, and other members of the licensees staff.

The licensee acknowledged the results as presented. While some proprietary information was reviewed during this inspection, no proprietary information was included in this report.

On June 29, 2012, regional inspectors presented the results of the onsite inspection of the licensees emergency preparedness program to Mr. T. McCool, Plant Manager, and other members of the licensees staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary or sensitive. One sensitive document was identified.

On July 26, 2012, regional inspectors presented the results of the radiation safety inspection to Mr. T. McCool, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On October 2, 2012, the resident inspectors presented the inspection results to Mr. P. Dietrich, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation.

• The licensee identified a Green non-cited violation of Technical Specification 5.5.2.3(c), in part, for failure to monitor and sample radioactive liquid effluents with the methodology in accordance with the offsite dose calculation manual.

Specifically, the offsite dose calculation manual, Section 4.1.1 and Table 4-1, address the requirements for compensatory sampling when the turbine plant sump sample compositor is inoperable. Contrary to these requirements, on February 1 and 2, 2012, the licensee failed to restart the compositor and obtain samples for the weekly composite sample as required. The finding was more than minor because it adversely affected the Public Radiation Safety Cornerstone with the potential for an unmonitored release of radioactive materials via liquid effluents. The licensee entered this issue into their corrective action program as Nuclear Notification NN 201841920.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

P. Anderson, Technical Specialist, System Engineering

D. Asay, Technical Specialist, System Engineering

D. Axline, Project Manager, Nuclear Regulatory Affairs

H. Burkland, Nuclear Engineer, Systems Engineering

C. Cates, Manager, Site Recovery

R. Corbett, Director, Performance Improvement

B. Culverhouse, Manager, Offsite Emergency Planning

R. Davis, Director, Nuclear Training

M. Demarco, SDG&E

J. Demlow, Supervisor, Chemistry

D. Evans, Manager, Security

N. Hansen, Environmental Services Technician, Radiation Protection

J. Hurlocker, Supervisor, Shipping and Receiving, Health Physics

K. Johnson, Manager, Design Engineering

G. Kline, Senior Director, Engineering and Technical Services

M. Lewis, Manager, Health Physics

D. Lindbeck, Manager, Onsite Emergency Preparedness

A. Martinez, Manager, Performance Improvement

T. McCool, Plant Manager

M. Pawlaczyk, Technical Specialist - Regulatory Affairs

R. Pettus, Nuclear Regulatory Affairs

T. Rak, Manager, Design Engineering-Electrical

M. Russell, Technician Specialist, Health Physics

B. Sholler, Director, Maintenance & Construction

A. Sistos, Supervisor, Nuclear Oversight

C. Stone, Supervisor of Radioactive Materials Control and Health Physics

R. Treadway, Manager, Nuclear Regulatory Affairs

D. Vanderwoude, Supervisor, Design Engineering

B. Winn, Director, Nuclear Financial Management

D. Yarbrough, Director, Operations

J. Bashore, Consultant

NRC Personnel

N. Taylor, Senior Project Engineer

Attachment 1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

2515/187 TI Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns (Section 4OA5)

2515/188 TI Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns (Section 4OA5)

Opened and Closed

05000361/2012004-01, NCV Failure to Correct Drill Performance Weaknesses (Section

05000362/2012004-01 1EP5)

05000361-2012004-02, SLIV Failure to Update the Final Safety Analysis Report for Solid

05000362-2012004-02 Radioactive Waste (Section 2RS8)