IR 05000361/2012004: Difference between revisions

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| number = ML12312A385
| number = ML12312A385
| issue date = 11/07/2012
| issue date = 11/07/2012
| title = 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 and Rad..
| title = 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 Processi
| author name = Lantz R E
| author name = Lantz R E
| author affiliation = NRC/RGN-IV/DRP/RPB-D
| author affiliation = NRC/RGN-IV/DRP/RPB-D

Revision as of 11:04, 14 February 2018

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


Text

November 7, 2012

Mr. Peter Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT: SAN ONOFRE NUCLEAR GENERATING STATION - 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 Commission's 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 cc w/ encl: Electronic Distribution

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.

A. NRC-Identified Findings and Self-Revealing Findings

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 NRC's 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 licensee's control. This failure has been entered into the licensee's 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).

B. 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 licensee's 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

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:

  • 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 licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's 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 plant's 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 licensee's 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 plant's 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
  • Characterizing system reliability issues for performance
  • Charging unavailability for performance
  • Trending key parameters for condition monitoring
  • 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 licensee's 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 personnel's 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 plant's 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 breaker's 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 valve's 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 valve's 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 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
  • 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
  • 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
  • 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
  • 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.
  • 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. Cornerstone: Emergency Preparedness

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 licensee's 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 licensee's 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 licensee's ability to staff the emergency response facilities in accordance with the licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's threshold for a weakness was identical to the NRC's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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
  • 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 licensee's 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 licensee's 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:

  • 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
  • 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

a. Inspection Scope

This area was inspected to verify the effectiveness of the licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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 NRC's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's corrective action program. The inspectors accomplished this through review of the station's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's emergency preparedness program to Mr. T. McCool, Plant Manager, and other members of the licensee's 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.

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.

A1-

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,
05000362/2012004-01 NCV Failure to Correct Drill Performance Weaknesses (Section 1EP5)
05000361-2012004-02,
05000362-2012004-02 SLIV Failure to Update the Final Safety Analysis Report for Solid Radioactive Waste (Section 2RS8)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

PROCEDURES NUMBER TITLE REVISION SO23-XV-93 Fukushima Event Response-Walkdown Inspection Process 0 SO23-XV-94 Fukushima Event Response-Scoping and Evaluation 0 SO123-XV-HU-2 Technical Task Pre-Job Briefing Checklist 12 NUCLEAR NOTIFICATIONS NUMBER
202085502
202094916
202094872
202095950
202095706
202096036
202096309
DRAWINGS NUMBER TITLE REVISION SO23-411-22-73 Penetrations Seals Locations 6
10300 Safety Equipment Building Elevation (-)5'-3" 9
23-411-22-98-3 Penetration Seals - Diesel Generator Building Unit 3
23-411-22-84-5 Penetration Seals - Storage Tank Building Unit 2
40455-9 Bechtel Area 2C12 Piping Plan Elev. 29'-0" and up
MISCELLANEOUS
Attachment 1 NUMBER TITLE
NEI 12-07 Visual Inspection

Section 1R04: Equipment Alignment

PROCEDURES NUMBER TITLE REVISION SO23-3-2.6 Shutdown Cooling System Operation 34
SO23-3-1.8 Draining the RCS to a Reduced Inventory Condition 37
SO23-XV-95 Fukushima Event Response 0 SO23-2-13 Diesel Generator Operation 58 SO23-3-3.23 Diesel Generator Monthly and Semi-Annual Testing 61
SO23-3-2.11 Spent Fuel Pool Operations 35
NUCLEAR NOTIFICATIONS NUMBER
201882364
200522544
200946008
DRAWINGS NUMBER TITLE REVISION 4009 Unit 3 General Arrangement Elevation 45'-0" - 30'-0"
40122B Unit 2 Fuel Pool Cooling System 29
MISCELLANEOUS NUMBER TITLE S3.AFWS.S31305MP140 Seismic Walkdown Checklist - Turbine auxilliary feedwater Pump 3P140 - Unit 3 S3.AFWS.3HV4716 Seismic Walkdown Checklist - Turbine Pump Stop Valve - Unit 3
S3.AFWS.3HV4706 Seismic Walkdown Checklist - Flow Control Valve (3P140) - Unit 3 S3.AFWS.3SV4700 Seismic Walkdown Checklist - Turbine Pump Governor Unit 3 S3.ECCS.3HV9301 Seismic Walkdown Checklist - refueling water storage tank Isolation Valve - Unit 3 S3.FPCS.S31219MP011 Seismic Walkdown Checklist - Spent Fuel Makeup Pump - Unit 3
S3.AFWS.3L298C Seismic Walkdown Checklist - TDAFW Control Panel - Unit 3
S3.AFWS.S31305MK007 Seismic Walkdown Checklist - AFT Pump 3P140 Turbine - Unit 3
Attachment 1
Area Walk-By Checklist -Tank Building - Unit 3

Section 1R05: Fire Protection

NUCLEAR NOTIFICATIONS NUMBER
201711909
201745227
201595343
DRAWINGS NUMBER TITLE REVISION 23AC23.DWG Unit 2/3 Auxiliary Control 50'-0" Elevation Pre-Fire Plan 9 23AC24.DWG Unit 2/3 Auxiliary Control 70'-0" Elevation Pre-Fire Plan 8 23AC25.DWG Unit 2/3 Auxiliary Control 85'-0" Elevation Pre-Fire Plan 5

2TB1 4.DWG

SONGS Pre-Fire Plans 6
3-033A SONGS Pre-Fire Plans 6
3-033 SONGS Pre-Fire Plans 5 3-034 SONGS Pre-Fire Plan for Unit 3: Penetration and Fuel Handling -18'3" to 23'6" 5 3-035 SONGS Pre-Fire Plan for Unit 3: Penetration and Fuel Handling 30'0" 6 3-036 SONGS Pre-Fire Plan for Unit 3: Penetration and Fuel Handling 45'0" 5 3-037 SONGS Pre-Fire Plan for Unit 3: Penetration and Fuel Handling 63'6" 7 MISCELLANEOUS NUMBER TITLE DATE
IPE-HC-019 Hi Temperature in 4kV Switchgear Room, Operator Action Summary Data Sheet June 20, 2006
IPE-BE-IE-012 Loss of Switchgear Room HVAC Initiating Event Frequency Analysis August 28, 2006
Updated Fire Hazards Analysis August 2001 NUREG 0712 Safety Evaluation Report February 1981
SOG-TR-0033 SONGS Fire Department Quarterly Pre-Fire Plan Walkdown Guideline December 30, 2009
Attachment 1

Section 1R06: Flood Protection Measures

PROCEDURES NUMBER TITLE REVISION SO23-V-3.20 Post Earthquake Engineering Analysis 9 SO23-13-3 Earthquake
AOI 18
DRAWINGS NUMBER TITLE REVISION 23IN19.DWG Unit 2/3 Saltwater pipe tunnel, saltwater intake area, Elevation (-)9' to 9' 7

Section 1R12: Maintenance Effectiveness

PROCEDURES NUMBER TITLE REVISION SO23-XX-10 Maintenance Risk Management Program Implementation 9 NUCLEAR NOTIFICATIONS NUMBER
202116058
WORK ORDERS NUMBER
800905092
MISCELLANEOUS NUMBER TITLE REVISION
Periodic Assessment Maintenance Rule Program, SONGS Units 2 and 3 July 2009 through June 2011
Technical Program Health Report 4th Quarter 2011
Technical Program Health Report 1st Quarter 2012
Independent Assessment of Maintenance Rule Program January 10-14, 2011 Surveillance Report SOS-009-
Maintenance Rule Program

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

Attachment 1 PROCEDURES NUMBER TITLE REVISION SO23-XX-8 Integrated Risk Management 13 WORK ORDERS NUMBER
800542651 800905092

Section 1R15: Operability Evaluations

NUCLEAR NOTIFICATIONS NUMBER
202016015
201414842
202015297
202001887
201992920
202046835
CALCULATIONS NUMBER TITLE REVISION M-0010-004 Unit 2/3 EDG Sizing Air Receivers 1 MISCELLANEOUS NUMBER TITLE REVISION
DBD-SO23-750 Emergency Diesel Generator Design Basis Documents 4

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

PROCEDURES NUMBER TITLE REVISION
SD-SO23-750 Emergency Diesel Generators
21 SO123-III-6.6 Diesel Fuel Oil Testing Program 23 SO123-XV-44 10
CFR 50.59 and 72.48 Program 14 SO123-XV-44.1 10
CFR 50.59 Resource Manual 3
SO123-XV-44.1 10
CFR 50.59 Program Resource Manual 6
SO123-XV-51 Site Program Impact (SPI) Assessment and Resolution 16
Attachment 1 SO123-XXIV-10.1 Engineering Design Change Process - NECPs 28 SO123-XXIV-10.9 Design Process Flow and Controls 8
SO123-XXIV-7.15 Preparation and Verification of Design Calculations 12 SO123-XXIX-2.16 Modification Problem Reports 11 SO23-2-13 Section 6.13 Placing 2(3)B026, Battery Charger, in Service 57
SO23-405-33-M112 Hydraulic Performance Test Procedure 0
SO23-5-2.35.1 Diesel Generator G-002 Local Annunciator Panel L160 Alarm Response 11 SO23-5-2.35.1 Diesel Generator G-002 Local Annunciator Panel L160 Alarm Response 19 SO23-5-2.35.2 Diesel Generator G-003 Local Annunciator Panel L161 Alarm Response 12 SO23-5-2.35.2 Diesel Generator G-003 Local Annunciator Panel L161 Alarm Response 21 SO23-XX-28 On-Line Work Management Process 11
SO3-15-63.B Annunciator Panel 63B, Train "A" Switchgear 14
SO3-15-63.B Annunciator Panel 63B, Train "A" Switchgear 24
SO3-15-63.C Annunciator Panel 63C, Train "B" Switchgear/Transformers 12
SO3-15-63.C Annunciator Panel 63C, Train "B" Switchgear/Transformers 19 NUCLEAR NOTIFICATIONS NUMBER
070400701
201623994
201696670
202035567*
200567612
201668189
202031945*
202037219*
201450136
DRAWINGS NUMBER TITLE REVISION
Attachment 1 ECN D0040262 for 32644 Reactor HP Safety Injection Pump P019 14 SO23-302-2-395 Connection Diagram Bus 3A06 Cubicle 14 11 SO23-302-2-395 Connection Diagram Bus 3A06 Cubicle 14 12 SO23-405-6-135 Constant Level Oiler Piping Detail 3
ECN D0010097 of LOOP

2LT5 906-2 Diesel 2G003 Fuel Storage Tank Level 5

ECN D0010094 of LOOP 2LT5903-1 Diesel 2G002 Fuel Storage Tank Level 4 22000 Circulating Water System General Arrangement Plan
1 22002 Intake Structure Equipment Arrangement Sections 0
2030 Intake Structure General Arrangement Isometric 1 ECN D0010069 of 30324 Diesel Generator Diesel Fuel Transfer Pump (P093) 22 ECN D0010070 of 30325 Diesel Generator Diesel Fuel Transfer Pump (P094) 18 ECN D0010071 of 30326 Diesel Generator Diesel Fuel Transfer Pump (P095) 21 ECN D0010074 of 30327 Diesel Generator Diesel Fuel Transfer Pump (P096) 20 ECN D0010075 of 31651 Control Building Process Instrument Panel 2L188 6 31786 Wiring Diagram Diesel Generator building Motor Control Center 2BD 14 ECN D0010076 of 31786 Wiring Diagram Diesel Generator Building Motor Control Center 2BD 11 32334 Elementary Diagram Diesel Generator 3G003 Protection DC System 25
Attachment 1 32644 Reactor HP Safety Injection Pump P019 14 ECN D0040254 for 32645 Reactor HP Safety Injection Pump P018 12 ECN D0040256 for 32665 Reactor HP Safety Injection Pump P018 13 41108 Salt Water Cooling Pump 33WX-1 Stage Vertical Circulator 6% Moly Material 4
5104307 Offshore Intake Structure Riser 3
5104346 Plan & Profile of Unit 2 Offshore Intake & Diffuser Outfall System 1 CALCULATIONS NUMBER TITLE REVISION E4C-0115 Non-1E 480V Loadcenter Protection Calculation 2 E4C-017 125V Battery DC System Sizing 20 E4C-017.1 Class 1E 125V DC System Data/Loading 4 E4C-051 600V Power Cable Ampacity for 480V Loadcenter w/Maintained Spacing 15 E4C-086 SONGS 2&3 Data Development and Documentation 6 E4C-092 Short Circuit Studies 6
E4C-099 480V Power Circuit Breaker Settings
2 E4C-099 480V Power Circuit Breaker Settings 3 E4C-131 125V DC Control Circuit Analysis for Class 1E 4KV and 480V Circuit Breaker Operation 1 J-JEA-001 TLU and Setpoints for DG Day Tank Level Instruments 1 J-JEA-002 Fuel Oil Level Setpoints for EDG Storage Tanks 1 M-0016-006 DG Fuel Oil Day Tank Storage Requirements 1
Attachment 1 M-0016-008 DG On Site Fuel Requirements 3 SO23-302-2A-M37 NLI Calculation for Indicating Lights with 5GSB2 Replacement Breaker Trip Coil 0 SO23-405-33-M126 SWC Submergence Test 0 EVALUATIONS NUMBER TITLE DATE
200649423 10
CFR 50.59 Program Issues January 14, 2010
201083068 Need Comp measures for 1E room coolers November 5, 2010
201104972 LCS: Implement SER Related to Amend #208/200 December 22, 2010201286253 Investigation of U3C15 Transformer Configuration February 7, 2011
201627832 Validate the CCW NCL cross-tie contingency
December 29, 2011
800162499 U3 Reactivity Management (DCS) March 4, 2011
800231042 DU2 Remove
Train B H2 Recombiner February 3, 2010
800274160 Error in "Loss of HVAC" computer program June 30, 2010
800414778 Modify LCS 3.7.106 Bases: when mode N/A July 1, 2011
800636071 U2 6.9kV Bus RAT Breaker Temp ECP January 17, 2011
MODIFICATIONS (DESIGN CHANGE PACKAGES) NUMBER TITLE REVISION / DATE 020700918-5 Replace salt water cooling pumps December 2, 2006 040301409-3 Diesel fuel change to ULSD fuel May 18, 2006 040800988-4 Replacement of buried 10 inch Clow gate valves March 16, 2005
060400870-10 Unit 3 AFW pump constant level oiler replacement May 20, 2008
Attachment 1 060500268-4 Modify the set point on 2/3PSV 5435A & B to 225 psi from 245 psi.+ the set point on pressure stop switches need to be modified to+2450 psi from 2800 psi. April 18, 2008
070200268 Replace Existing Q-Panel 15KVA XFMR 00
070400701-25 Disable Unit 3 Emergency Diesel Generator 3G003 Stator+Temperature High Trip Circuit May 8, 2008
071100597-18 U3 Replacement of Pressurizer Heaters May 22, 2008
800071684 NECP
800071684, Remove the level switch low-low tip for diesel+P094 (3LSLL5906Y2), P095 (3LSLL5906X2) and P096

(3LSLL5903X1)+generator fuel transfer pumps P093

(3LSLL5903Y1) May 20, 2009

800350419 Replace valve S2.ECCS.2HV9328 LPSI Header to RCS Loop 2A September 21, 2009
800530463 Control Circuit Changes HPSI Pump 3P018 0
800578751 2G003 NECP to Install Manual Transfer SW 0
800580980 Replace existing shutdown cooling suction + isolation MOV 2HV9337 motor PER
SEE 070058 Mach 24, 2011
800611702 EDG 2G002/3G003 EDG Battery Charger 0
800702598 Replace 480V Charging Pump breakers 0 MISCELLANEOUS NUMBER TITLE DATE
201450136 Replace 480V breakers with ABB breakers August 15, 2011
201623994 Class 1E Batteries - Capacity and Margin September 3, 2011
201697003 Revise UFSAR 9.1.4.2.3.4.1 use Computer November 14, 2011201825450 Screen needed for CCW Makeup January 26, 2012
201840078 Sealant usage on CCW pumps March 18, 2012
Attachment 1
800071281 Replace U3 AFW Governor January 21, 2011
800126250
080300355 Mod to U3 DGFO Flow inst March 8, 2011
800162890
051200478-12 U2 Reactivity Mgmnt Improve October 13, 2009
800175671 Steam Blowdown Piping Mods ECP 2 October 9, 2009
800334497 Upgrade NECP
800072755 to permanent September 18, 2009
800394628 Add Vent Valves on line
ML-242 and
NL-244 January 12, 2010
800415568 Document the seal welding of the ball valve January 11, 2010
800416837 ADV Quarterly IST test method change December 29, 2009
800427168 Repair boric acid leaks in Schedule 10S pipes December 23, 2009201083068 Need Comp measures for 1E room coolers November 5, 2010
201697003 Revise UFSAR 9.1.4.2.3.4.1 use Computer November 14, 2011
201825450 Screen needed for CCW Makeup January 26, 2012
800071683 U2 Mod Fuel Oil Storage Tank Pump Trip Removal April 30, 2009
800187778 Mod to Limit Pressure Increase in LPSI Header August 1, 2011
800334497 Upgrade NECP
800072755 to permanent September 18, 2009800438037 Undersize wall on S3-1219-ML-057 January 8, 2010
800445994 TS Bases changed inappropriately January 21, 2010
800446211 Replace elbow material on S31401ML019 January 26, 2010
800453513 EDG 2G002 Replacement
NECP
800453513 December 10, 2010
800492759 Replace valve MU133 and remove TECP May 10, 2010
800530465 Control Circuit Changes HPSI Pump 3P019 April 26, 2012
800585806 Alternate Unit 2 Containment Vent Temperature January 7, 2011
800612859 Charger 2B025 Load not accounted for April 25, 2011
Attachment 1
800635038 Replace Obsolete Valve S31319MR430 January 20, 2011
800694218 Issue As-Built NECP for UFSAR Section 8 May 3, 2011
800743821 TOL Upsize EDG Air Compressor Motor 3BHX10 October 18, 2011
800753592 Replace ABB 4KV breaker with NLI vacuum breakers November 3, 2011
800822652 Intake tsunami protection not per UFSAR January 9, 2012
800849623 RWSTs: Evaluation for tornado February 27, 2012
MISCELLANEOUS NUMBER TITLE REVISION / DATE 1814-AS726-M0002 Trico Closed System with Sight Gauge/Constant Level Oiler 0 1814-AS726-M0003 Introduction to Constant Level Lubrication 0
FS-060400870 AFW Constant Oiler Field Support March 6, 2008SO23-405-33-M11 Design Differences Salt Water Cooling Pumps 0 SO23-405-33-M118 SWC Pump Performance Test Data 1 SO23-405-33-M119 SWC Pump Performance Test Data 0 SO23-405-33-M121 SWC Performance Pump Test Data 0 SO23-405-33-M95 Review of Flowserve Modal Analysis of Salt Water Cooling Pumps 0 SO23-405-33-M96 Installation, Operation & Maintenance Instruction Manual - Salt Water Cooling Pumps 4 T90071 10
CFR 50.59 Screener Training 2011 T90072 10
CFR 50.59 Evaluator Initial Qualification Training 2011
TE 960115 Constant Level Oiler 2
Attachment 1

Section 1R19: Postmaintenance Testing

PROCEDURES SO23-I-8.93
SO123-II-11.152 Goulds Model 3405 Pump Overhaul
Circuit Device Tests and Overall Functional Test May 5, 2010
23 SO123-XX-5 Work Clearance Application / Work Clearance Document / Work Authorization Record 43 SO23-2-13 Diesel Generator Operation 58 SO23-I-5.16 Jockey Fire Pump Overhaul 8 SO23-3-3.21.1 Once a Day Surveillances (Monitors) 29 SO23-3-3.60.7 Containment Spray Pump Comprehensive Test 15
SO23-3-3.43.7 ESF Subgroup Relays K-109A and K-104A Test 10
NUCLEAR NOTIFICATIONS NUMBER
202117246
202099981
201588961
201569055
201700354
202144748
WORK ORDERS NUMBER
800938832
800882982
800632110
800274493
800308115
800743165
800314860
800358670
800539346
800913632
MISCELLANEOUS NUMBER TITLE DATE
Control Room Logs September 2, 2012 3-EDGS-12027-C17-3G002 Work Authorization Record
3-EDGS-12024-C17-MP997 Work Authorization Record
WAR 2-PPSY-12009 2L034K109 MDR Relay Replacement September 12, 2012 NECP
800874598
Replace Existing Relay 3BZ22-42Z with
0 a New Model
MDR-4085-SCE-0 Relay
SEE 100016 "Critical A" Units 2&3
MDR-4085-SCE-0
0
Latching Relay Attachment 1

Section 1R22: Surveillance Testing

PROCEDURES NUMBER TITLE REVISION SO23-2-13 Diesel Generator Operations 57 SO23-3-3.23 Diesel Generator Monthly and Semi-Annual Testing 61
SO23-I-9.98 Battery - Charger Performance Test 3
SO23-3-3.60.7 Containment Spray Pump 2(3)MP-012 Group B Inservice and Valve Testing 15 SO23-3-3.18 Component Water/Saltwater Cooling System Tests 14 NUCLEAR NOTIFICATIONS NUMBER
202089297
202091363
202098426
201076628
202111670 WORK ORDERS NUMBER
800905092
800584259
DRAWINGS NUMBER TITLE REVISION 40126A P&I Diagram Saltwater Cooling 28
CALCULATIONS NUMBER TITLE REVISION / DATE M-0010-004 Sizing Emergency Diesel Generator Air Receivers March 30, 1994
M-0010-005 Emergency Diesel Generator Compressors Recharge 0
Operator Logs August 13, 2012
MISCELLANEOUS NUMBER TITLE REVISION Work Authorization Record WAR 3-480V-12025-H 0

Section 1EP2: Alert Notification System Testing

PROCEDURES NUMBER TITLE REVISION
Attachment 1 SO123-VIII-0.301 Emergency Telecommunications Testing 5 NUCLEAR NOTIFICATIONS NUMBER
201397091

Section 1EP3: Emergency Response Organization Augmentation Testing

PROCEDURES NUMBER TITLE REVISION SO123-VIII-0.201 Emergency Plan Equipment Surveillance Program 23 SO123-VIII-30.7 Emergency Notifications 16 NUCLEAR NOTIFICATIONS NUMBER
201359307
201363962
201418379
201452464
201544582
201563039
201629550
201672661
201850033
201873796
201917797
201953843
201980230 201988448

Section 1EP4: Emergency Action Level and Emergency Plan Changes

PROCEDURES NUMBER TITLE REVISION
Emergency Plan 32 SO123-VIII-1 Recognition and Classification of Emergencies 7 SO123-VIII-10.1 Station Emergency Director Duties 23
EPSD-1 Emergency Action Level Technical Bases 6
EPSD-1 5.1 Section 5.1-Category A - Abnormal Rad Levels/Radiological Effluent 4
EPSD-1 5.4 Section 5.4-Category F - Fission Product Barrier Degradation 5
EPSD-1 5.5 Section 5.5-Category H - Hazards and Other Conditions Affecting Plant Safety 5
EPSD-1 5.6 Section 5.6-Category S - System Malfunction 6

Section 1EP5: Maintenance of Emergency Preparedness

PROCEDURES
Attachment 1 NUMBER TITLE REVISION / DATE SO123-EP-1 SONGS Emergency Plan Implementation 8
SO123-NP-1 Offsite Emergency Planning Responsibilities and Offsite Interfaces 8 SO123-0-A2 Operations Division Procedure 31 SO123-OP-1 Operations Order: Operations Division Program 9
SO123-VIII-0.100 Maintenance and Control of Emergency Planning Documents 13, 14, 15 SO123-VIII-0.200 Emergency Plan Drills and Exercises 12 SO123-VIII-0.201 Emergency Plan Equipment Surveillance Program 20-23 SO123-VIII-10.5 Event Close Out and Recovery 4
SO123-VIII-10.6 Emergency Response Actions for a declared Security Event 3 SO123-XV-SA-3 Trend Coding and Analysis 6-1 SO123-XXI-1.11.3 Emergency Plan Training Program Description 23 SO23-13-25 Operator Actions during Security Events 17
After-Action Report for the Emergency on July 16, 2011
After-Action Report for the Emergency on November 1, 2011
After-Action Report for the Emergency on April 20, 2012
SCES-009-10 Audit Report: Emergency Preparedness Program October 12, 2010
SCES-012-11 Audit Report: Emergency Preparedness Program September 29, 2011
NUCLEAR NOTIFICATIONS NUMBER
201793916
201974817
201811829
201135750
201645589
201120621
201155833
201162644
201170368
201212827
201224683
201261199
201268078
201275215
201319127
201356899
201372884
201417282
201410295
201417328
201421703
201482249
201497245
201505721
201563654
201563745
201563800
201563862
201564243
201570800
201585117
201599988
201603344
201621978
201705333
201715759
201722342
201731164
201713841
201742638
Attachment 1
201748069
201748133
201748264
201758631
201782291
201891264
201930288
201940461
201953973
201954119
201954232
201957623
201973128
201984321
201984814
201998006
202042522
202042541
202044191
202044210
2044230
MISCELLANEOUS TITLE DATE Evaluation Report for the Drill conducted June 2, 2010 August 6, 2010
Evaluation Report for the Drill conducted June 9, 2010 June 15, 2010 Evaluation Report for the Drill conducted June 16, 2010 June 25, 2010 Evaluation Report for the Drill conducted July 14, 2010 September 1, 2010
Evaluation Report for the Drill conducted September 22, 2010 November 17, 2010
Evaluation Report for the Drill conducted November 24, 2010 January 19, 2011
Evaluation Report for the Drill conducted December 10, 2010 January 19, 2011 Evaluation Report for the Drill conducted March 8, 2011 May 18, 2011 Evaluation Report for the Drill conducted April 12, 2011
Evaluation Report for the Drill conducted June 15, 2011
Evaluation Report for the Drill conducted July 13, 2011
Evaluation Report for the Drill conducted August 10, 2011 September 22, 2011
Evaluation Report for the Drill conducted August 15, 2011
Evaluation Report for the Drill conducted October 26, 2011
Evaluation Report for the Drill conducted Apri 4, 2012 May 16, 2012

Section 1EP6: Drill Evaluation

NUCLEAR NOTIFICATIONS NUMBER
202121461

Section 2RS5: Radiation Monitoring Instrumentation

PROCEDURES NUMBER TITLE REVISION SO123-VII-20.14.1 Health Physics Instrumentation Program 9
Attachment 1 SO123-VII-20.14.6.1 Calibration Of NE IPM8M Personnel Monitor 11 SO123-VII-20.14.6.2 Calibration Of NE
SAM-9,
SAM-11 And
SAM-12 Small Article Monitors 11 SO123-VII-20.7.2 Canberra Whole Body Counters 6 SO123-III-0.7 ISS2 Effluent Quality Assurance and Chemistry Quality Control Programs 35 SO23-XXV-4.19 Surveillance Requirement Plant Vent Stack/Waste Gas Holdup System Loop 2/3RE7808g Channel Calibration 9 SO23-XXV-9.309 Plant Vent Stack/Waste Gas Holdup System Loop 2/3re7808g Electronic And Transfer Isotopic Calibration 3 NUCLEAR NOTIFICATIONS NUMBER
201548397
201610643
201638628
201651523
CALIBRATION RECORDS NUMBER TITLE DATE 8111 MGPI Telepole July 19,2012
8067 MGPI Telepole June 28, 2012
567
SAC-4 June 28, 2012
380
BC-4 September 7, 2012
636 Thermo-NE Small Article Monitor (SAM-11) July 10, 2012 282 Thermo-NE Small Article Monitor (SAM-9) March 11, 2012 333 IPM8M Personnel Contamination Monitor November 14, 2011
305 IPM8M Personnel Contamination Monitor November 18 2011

3RE7 813 Radwaste Discharge Liquid Radiation Monitor February 1, 2011

3RE7 808G Plant Vent Monitor May 16, 2011 3RY7865A1 Containment Purge/Plant Vent Stack Wide Range Gas January 11, 2012

AUDITS,
SELF-ASSESSMENTS, AND SURVEILLANCES NUMBER TITLE DATE
SCES-002-011 SONGS Nuclear Oversight Division - Radiation Protection and Radioactive Material Control Audit June 10, 2011
Attachment 1
MISCELLANEOUS TITLE DATE Radiation Monitoring System (RMS) Health Recovery Plan
201842965 May 5, 2012
Radiation Monitoring System (RMS) Health Recovery Plan
201842965 July 13, 2012

Section 2RS6: Radioactive Gaseous and Liquid Effluent TreatmentPROCEDURES

NUMBER TITLE REVISION SO123-ODCM OffSite Dose Calculation Manual 5
SO123-III-5.1.23 Units 2/3 Effluent Program 32
SO123-III-5.6.23 Units 2/3 Spent Fuel Building and South Yard Facility 3 SO123-VII-20.9 Radiological Surveys 16 NUCLEAR NOTIFICATIONS NUMBER
201819745
201986628
202066976
201968167
201902943
201252276
201147182
201398775
10
CFR 50.75(g) RECORDS NUMBER
Survey 120118-020 Survey 120118-025Survey 120425-022
RELEASE PERMITS NUMBER
1G-058-0 1G-090-0 1L-365-3
SAMPLE OBSERVATIONS SAMPLE TITLE DATE TO75 Misc. Waste Condensate Monitor Tank Liquid Sample July 24, 2012

2RT7 822 Spent Fuel Pool Vent Exhaust Air Sample (Tritium) July 24, 2012

COMPENSATORY SAMPLING UNIT MONITOR DATE 2 2RT7865 Plant Vent Stack (WRGM) November 14-17, 2011
Attachment 1 2 2RT6759 Steam Generator Blow Down (2SGE088) October 3-7, 2011 3 3 RT6753 Steam Generator Blow Down (3SGE089) January 3-11, 2012
IN-PLACE FILTER TESTING RECORDS SYSTEM TEST DATE Control Room Emergency Air Cleaning - ME419 Filter Test May 3, 2012
Control Room Emergency Air Cleaning - ME419 Carbon Sample April 24, 2012
Control Room Emergency Air Cleaning - ME418 Filter Test March 20, 2012
Control Room Emergency Air Cleaning - ME418 Carbon Sample October 25, 2011 AUDITS,
SELF-ASSESSMENTS, AND SURVEILLANCES NUMBER TITLE DATE
200819630 SONGS Radiation Monitoring System (RMS) Performance Trending Program, NN#
200819630 April 5, 2011
201842965 Radiation Monitoring System (RMS) Health Recovery Plan May 8, 2012
Results of Radiochemistry Cross Check Program (4Q11) November 11, 2011
Results of Radiochemistry Cross Check Program (2Q11) May 13, 2011
Results of Radiochemistry Cross Check Program (4Q10) November 12, 2010
Results of Radiochemistry Cross Check Program (2Q11) May 14, 2010
MISCELLANEOUS NUMBER TITLE DATE
2010 Annual Radioactive Effluent Release Report April 26, 2011
2011 Annual Radioactive Effluent Release Report April 13, 2012
DCE 201-986-628 Rad Monitor Set Point Not per Transmittal July 3, 2012
Setpoint Transmittal, Units 2 and 3 Gas Monitors December 20,1999 Setpoint Transmittal, Units 2 and 3 Gas Monitors December 6, 2010 Liquid RETS/ODCM EAL Threshold Value Determination at SONGS March 19, 2009
Gaseous RETS/ODCM EAL Threshold Value Determination at SONGS March 19, 2009
2011 Dose Parameters for San Onofre Units 2 and 3 January 27, 2011
Attachment 1
2011 Dose Parameters for San Onofre Nuclear Generating Station South Yard Facility and North Industrial Area February 8, 2011
2010 Dose Assessment, San Onofre Units 2/3 January 27, 2011

Section 2RS7: Radiological Environmental Monitoring Program

PROCEDURES NUMBER TITLE REVISION SO123-IX-1.4.1 Groundwater Monitoring 4 SO123-XV-3.5 ISS2 Groundwater Protection Initiative-Voluntary Communication Protocol 1 SO123-GPI-1 Groundwater Protection Initiative 0 SO123-IX-1.2 Air Sampling 17
SO123-IX-1.3 Environmental TLD Exchange 11 SO123-IX-1.4 Drinking Water 13 SO123-IX-1.8 Soil Sampling 11
NUCLEAR NOTIFICATIONS NUMBER
201053677
201112069
201112164
201429176
201594817
201871271
201884089
201887870
201963867
202070068
202058941
AUDITS,
SELF-ASSESSMENTS, AND SURVEILLANCES NUMBER TITLE DATE
SCES-008-10 2010 Environmental ODCM Audit September 17, 2010
GEL Laboratories QA Audit SONGS REMP 2010 March 8, 2012
GEL Laboratories QA Audit SONGS REMP 2011 February 15, 2011 CALIBRATION AND MAINTENANCE RECORDS NUMBER TITLE DATE
800633017 REMP Pressurized Ion Chamber-1 October 11, 2011
800384877 REMP Pressurized Ion Chamber-2 May 25, 2011
800067152 REMP Pressurized Ion Chamber-3 March 30, 2011
800385024 REMP Pressurized Ion Chamber-5 April 16, 2011
Attachment 1
800351076 REMP Pressurized Ion Chamber-6 November 10, 2011800685214 Primary Meteorological Tower Calibration January 13, 2012
800632022 Primary Meteorological Tower Calibration September 15, 2011800611239 Primary
Meteorological Tower Calibration June 28, 2011
800678416 Backup Meteorological Tower Calibration April 3, 2012
MISCELLANEOUS TITLE REVISION 2010 Annual Radiological Environmental Operating Report San Onofre Nuclear Generating Station 0 2011 Annual Radiological Environmental Operating Report San Onofre Nuclear Generating Station 0 2011 SONGS Land Use Census 0 2010 SONGS Land Use Census 0
2010 Annual Radiological Effluent Release Report San Onofre Nuclear Generating Station 0 2011 Annual Radiological Effluent Release Report San Onofre Nuclear Generating Station 0 2010 Annual Quality Assurance Report for the Radiological Environmental Monitoring Program (REMP) 0 North Industrial Area Groundwater Extraction Monitoring Plan 2

Section 2RS8: Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

PROCEDURES NUMBER TITLE REVISION RC7919 NTD Lesson Plan: Overview of Packaging & Transportation of Radioactive Waste 1 SO123-VII-8 Control of Radioactive Material 15 SO123-VII-8.1 Solid Radioactive Waste Stream Analysis for Classification and Typification 20 SO123-VII-8.1.14 Radioactive Material Container Labeling 4 SO123-VII-8.2 Shipment of Radioactive Material 29
Attachment 1 SO123-VII-8.2.12 Shipment of Radioactive Waste for Land Disposal at Energy Solutions Bulk Waste Disposal and Treatment Facilities at Clive, Utah 7 SO123-VII-8.5.1 Radwaste Process Control Program 10 SO123-VII-8.5.4 Transfer of Waste/Radioactive Material to a Processing Container 9 SO123-VII-8.16 Radioactive Equipment and Material Storage (REMS) 6 SO123-VII-20.9.2 Material Release Surveys 13
AUDITS,
SELF-ASSESSMENTS, AND SURVEILLANCES NUMBER TITLE DATE
SOS-001-12 Surveillance Report: Radioactive Material Control September 26, 2008
4Q10 Health Physics Division Performance Assessment Report January 31, 2011
1Q11 Health Physics Division Performance Assessment Report May 6, 2011
2Q11 Health Physics Division Performance Assessment Report July 31, 2011
4Q11 Health Physics Division Performance Assessment Report January 27, 2012
1Q12 Health Physics Division Performance Assessment Report May 2, 2012 RADIOACTIVE MATERIAL SHIPMENTS NUMBER TITLE DATE 10-3001 Radioactive Material; Excepted Package;
LQ-7; UN2910 July 1, 2010
10-6007 Radioactive Material; Excepted Package;
LQ-7; UN2910 June 22, 2010 11-6106 Radioactive Material;
LSA-II;
UN 3321 December 15, 2011 11-6107 Radioactive Material;
LSA-II;
UN 3321 November 29, 2011
2-2014 Radioactive Material;
LSA-II;
UN 3321 July 24, 2012
2-4049 Radioactive Material;
LSA-II;
UN 3321 July 24, 2012
2-6006 Radioactive Material; Type A; UN2915 May 14, 2012
Attachment 1 MISCELLANEOUS NUMBER TITLE REVISION / DATE WMG6055-RE-121 Characterization, Classification and Shielding Analysis Report 2
Chapter 11 of San Onofre 2&3 Final Safety Analysis Report: Radioactive Waste Management 22
San Onofre Nuclear Generating Station 2010 Annual Radioactive Effluent Release Report 0
San Onofre Nuclear Generating Station 2011 Annual Radioactive Effluent Release Report 0
Summary of Low Level Radioactive Waste in Storage as of 12/31/2011 December 31, 2011

Section 4OA1: Performance Indicator VerificationPROCEDURES

NUMBER TITLE REVISION
EPSD-1 Emergency Action Level Technical Bases 1
SO123-VIII-0.301 Emergency Telecommunications Testing 5
SO123-VIII-0.401 Emergency Preparedness Performance Indicators 2
SO123-VIII-1 Recognition and Classification of Emergencies 33, 34, 35, 36 SO123-VIII-10.3 Protective Action Recommendations 12 SO123-VIII-30.7 Emergency Notifications 13
SO123-VIII-40.100 Dose Assessment 14
SO123-XVIII-10 Siren -
Community Alert System, System Description and Operational Guide 16 SO123-XVIII-10.1 Siren -
Community Alert System, Biweekly Siren Test 11 SO123-XVIII-10.3 Siren -
Community Alert System, Quarterly Growl Test 15
SO123-XVIII-10.4 Siren -
Community Alert System, Response to a Report of an Inadvertent Siren Activation 7 SO123-XVIII-10.5 Siren -
Community Alert System, Annual Activation Test Procedures 11 SO123-XVIII-10.6 Siren -
Community Alert System, Inspection and Maintenance 11
Attachment 1 SO123-XV-5.3 Maintenance Rule Program 13 MISCELLANEOUS NUMBER TITLE REVISION / DATE
San Onofre Nuclear Generating Station Emergency Plan 34
Control Room Logs July 2011-January 2012Units 2 and 3 Control room logs November 2011

Section 4OA2: Identification and Resolution of ProblemsPROCEDURES

NUMBER TITLE REVISION SO23-XX-30 Work Process Procedure 9
SO123-I-1.3 Work Activity Guidelines 42
SO123-I-1.7 Work Order Preparation and Processing 52 NUCLEAR NOTIFICATIONS NUMBER
201505375
201047382
202176793
202141812
202131873
201944122
200758654
202021253
201912250
201899262
2128842
WORK ORDERS NUMBER
800727968
800558556
800945489
800813756
800908219
MISCELLANEOUS NUMBER TITLE DATE
System Health Report 1st Quarter 2012

Section 4OA3: Event Follow-Up

PROCEDURES NUMBER TITLE REVISION SO23-3.30.1 ECCS Online Valve Test 9
SO23-13-3 Earthquake 9
Attachment 1 NUCLEAR NOTIFICATIONS NUMBER
202041701
202115025
202057369
DRAWINGS NUMBER TITLE REVISION
SD-SO23-740 Safety Injection, Containment Spray and Shutdown Cooling Systems 22 MISCELLANEOUS NUMBER TITLE REVISION / DATE
Seismic Walkdown Checklist (SWC)

Section 4OA5: Other Activities

DRAWINGS NUMBER TITLE REVISION 20031 Typical Hold-Down Details for Equipment Units 2 & 3 19
23850 Diesel Generator Building Floor Plans Units 2 & 3 29
35042 Unit 2 Diesel Generator Building Conduit & Tray Plan 11
23856 Diesel Generator Building Sections and Details Sheet 1
30136 Unit 2 One Line Diagram 480V Motor Control Center 21 10251 Diesel Generator Building Units 2 & 3 4 SO23-302-4-2-28-1 Base Channel Mounting Holes
SO23-403-12-65-7 Emergency Diesel Genrator - Stewart & Stevenson Svcs
SO23-411-22-98-3 Penetration Seals Diesel Generator Building Unit 3
SO23-411-22-83-5 Penetration Seals Diesel Generator Building Unit 2
SO23-411-22-86-8 Penetration Seals - Radwaste Building - Common
25173 Auxiliary Building - Radwaste Storage Tank Area Units 2 & 3 11
Attachment 1 MISCELLANEOUS NUMBER TITLE REVISION / DATE
NEI 12-07 Visual Inspection
SA PENS RW009127B3001C Wall, Ceiling, and Floor Seals Visual Inspection

Section 4OA7: Licensee-Identified Violations

PROCEDURES NUMBER TITLE REVISION SO123-III-5.2.23 Unit 2/3 Liquid Effluents 21
NUCLEAR NOTIFICATIONS NUMBER
201841920
MISCELLANEOUS TITLE DATE STOP LIGHT (for NN# 201841920) February 17, 2012
Prompt Investigation (for NN# 201841920)
Operations Log Entries Report February 1-3, 2012
Chemistry Log Report February 3, 2012
Attachment 2 BIENNIAL REQUALIFICATION INSPECTION DOCUMENT REQUEST From: Kelly Clayton
Operations Engineer, NRC RIV
817-200-1216 To: Dennis Brill
Requalification Supervisor, SONGS
949-368-3011 Subject: Information Request to Support July and August 2012 Licensed Operator
Requalification Program Inspection (IP 71111.11B) A. The following information is requested in order to support inspection preparation activities.
These items are listed by section as they appear in the inspection module

(i.e., 2.02, 2.04, etc.).

Requested materials should be sent either electronically or hardcopy in order to arrive at the Region IV office no later than July 27, 2012. * Electronically:
To:
Kelly Clayton (kelly.clayton@nrc.gov) cc:
Sean Hedger (sean.hedger@nrc.gov) cc:
Nick Hernandez (Nicholas.hernandez@nrc.gov) * Hardcopy to: US Nuclear Regulatory Commission, Region
IV 1600 E. Lamar Blvd Arlington,
TX 76011 ATTN:
Kelly Clayton General Requests: * List of licensed operators (SRO & RO) by crew (operating & staff) * Training and Operations Department organization charts (with qualified LOR evaluators identified) * Procedures that identify process for revising and maintaining LO continuing training program up-to-date * List of outstanding LOR program changes * List of plant events and industry operating experience incorporated into LOR program since last BRQ * Audits and/or self-assessment reports addressing the licensed operator requalification training program * Last two years of simulator review committee (or equivalent) meeting minutes * Last two years of CRC (or equivalent) meeting minutes 02.03:
Biennial Requalification Written Examination Quality * The current and approved biennial written examination schedule * The current requalification cycle written examination results for both SRO & RO that have already been administered up to the week prior to the inspection team arrival onsite. * All written examinations that have been approved for administration up to and including the week before the inspection team is onsite.
This will need to have
A2- 2 - Attachment 2 adequate password protection if e-mailed or double envelope protection if mailed via regular mail per
NUREG-1021. * The current requalification cycle examination methodology (sample plan) 02.04:
Annual Requalification Operating Test Quality * The schedule for the operating tests (JPMs & scenarios) to be given the week of
July 30 (week team is onsite) * The operating tests (JPMs & scenarios) (password protected and provide separately via telephone at later date) to be given the week of July 30 (week team is onsite) * Current requalification cycle operating tests (SRO & RO) and results up to the week prior to the inspection team arrival onsite. * All of the previous year's (2011) NRC-required annual operating tests. * Current requalification cycle operating test methodology (sample plan) * All portions of the UFSAR that identify operator response times for time critical operator actions 02.05:
Licensee Admin of Requalification Exams * All procedures used to administer the annual operating test * All procedures used to assess operator performance * All procedures that describe conduct of simulator training * All procedures used to test, operate, and maintain the simulator 02.06:
Requalification Examination Security * Submit any tracking tools that you use as a means to prevent excessive overlap on the written examinations and also meet the intent of sampling all required topics on a periodic basis. * Submit any tracking tools that you use as a means to prevent excessive overlap on the operating tests and also meet the intent of sampling all required malfunctions (including major events, instrument/component malfunctions, TS calls, etc.) on a periodic basis. * All procedures that describe examination security, including procedures used to develop the examinations that include guidelines on overlap between examinations in current exam cycle tests and prior year examinations * List of all condition reports since the last biennial requalification inspection related to examination security and overlap 02.07:
Licensee Remedial Training Program * List of remedial training conducted or planned since last requalification exams (includes training provided to operators to enable passing requalification exams and training provided to correct generic or individual weaknesses observed during previous requalification exam cycle) * Remediation plans (lesson plans, reference materials, and attendance documentation) 02.08:
Conformance with Operator License Conditions * All procedures and program documentation for maintaining active operator licenses, tracking training attendance, and ensuring medical fitness of licensed operators
A2- 3 - Attachment 2 * All procedures and associated documentation that supports reactivation of any SRO/RO license (operating or staff crew) since the last biennial inspection 02.09:
Simulator Performance * For the following cases, send the most recent transient test packages, which may be electronic or in paper single test packages and shall be complete with test procedures for each test, the acceptance criteria, and results.
For each transient test, the reference chart should be included, or an equivalent subject matter expert review, versus the simulator results with a write-up for any differences beyond the
ANSI 3.5 standard requirements. o Transient test 8, Max RCS rupture with LOSP o Transient test 6, Main turbine trip (no reactor trip) o
Transient test 10, Stuck open PORV o
Steady State tests for 50 percent and 100 percent power * All Simulator Management and Configuration Procedures if not already provided for Section 02.05 above. * Simulator Discrepancy Report summary list for all open DR's.
For closed DR's, summary list for those items closed between July 2010 and July 2012. * Malfunction Tests for Main Steam and Main Feed Line breaks.
If these are included in an SBT package, then the review of that package would be acceptable. * Test packages for Moderator Temperature Coefficient and Integral Rod Worth (tested in order to verify core physics parameters).
This shall include the applicable reference graphs from the plant physics data book (electronic or other means as available) as well as the test procedures used and the acceptance criteria with results. 02.10:
Problem Identification and Resolution * A summary report of all condition reports related to operator actions/errors in the control room * Any revised requalification training that was based on licensed operator performance issues B. The following information is requested in order to support the onsite inspection activities.
Requested materials should be available to the inspection team, either electronically or hardcopy, upon site arrival on July 30, 2012. 02.02:
Exam Results /
02.03 and 02.04:
Written Exam and Op Test Quality * All Operating tests (JPMs & scenarios) to be given in all subsequent weeks after onsite week * All results up to the day the team leaves the site. 02.08:
Conformance with Operator License Conditions * Access to licensed operators' records (operating and staff crews) * Access to licensed operators' training attendance records * Access to licensed operators' medical records
A2- 4 - Attachment 2 02.09:
Simulator Performance * Simulator discrepancies (DR's) from July 2010 through July 2012.
This should include all open DR's and DR's that have been closed, including the documentation/justification for closure. * Acceptance test documentation, including hardware and software model revisions at the time of acceptance (as available). * Documentation that validates current models, including the thermal-hydraulics and neutronics models, to the actual plant. * All current model deficiencies, including FSAR versus design differences in the simulator (any documentation on this) * Summary list of modifications from July 2010 through July 2012. * Plant Modifications (both hardware and software) completed on the Simulator by due date from July 2010 through July 2012. * Simulator Differences Lesson Plan used in training (current to July 30, 2012). * The complete book of all Simulator annual performance test packages (usually in a single book, but may be electronic or in single test packages), complete with all transient tests, steady state tests, and malfunction tests. This should also include the test procedures for each test, the acceptance criteria, and results.
For each transient test, the reference chart should be included, or an equivalent subject matter expert review, versus the simulator results with a write-up for any differences beyond the
ANSI standard requirements. * All test packages used to verify core physics parameters (such as MTC, IRW).
The applicable reference graphs from the Plant physics data book (electronic or other means as available) should also be included as well as the test procedures used and the acceptance criteria with results. * All Simulator test, configuration management, and related documents available in the room for inspectors to review.
This includes training needs, analysis packages, simulator review committee meeting minutes, etc. * Current copy of ANSI 3.5 Standard you are committed to for simulator testing. 02.10:
Problem Identification and Resolution * All condition reports related to operator actions/errors in the control room C. San Onofre Nuclear Generating Station is required to send the final results summary and any remaining exams and operating tests that have not been reviewed to the Regional Office lead inspector for this inspection for final review and comparison against the Significance Determination Tools in order to communicate the exit results for the inspection.
Attachment 3 The following items are requested for the Public Radiation Safety Inspection at San Onofre (July 23rd thru July 27th, 2012 ) Integrated Report
2012004 Inspection areas are listed in the attachments below. Please provide the requested information on or before June 29, 2012.
Please submit this information using the same lettering system as below.
For example, all contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled "1- A," applicable organization charts in file/folder "1- B," etc. If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report. In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting. If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies.
Enter a note explaining in which file the information can be found. If you have any questions or comments, please contact Natasha Greene at (817)200-1154 or Natasha.Greene@nrc.gov. Currently, the other inspectors will be Larry Ricketson at (817)200-1165, Louis Carson at (817)200-1221, and John O'Donnell at (817)200-1441.
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011.
A3- 2 - Attachment 3 5.
Radiation Monitoring Instrumentation (71124.05) Date of Last Inspection:
June 10, 2011 A. List of contacts and telephone numbers for the following areas: 1. Effluent monitor calibration 2. Radiation protection instrument calibration 3. Installed instrument calibrations 4. Count room and Laboratory instrument calibrations B. Applicable organization charts C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support and LERs, written since date of last inspection, related to:
1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey instruments, electronic dosimeters, teledosimetry, personnel contamination monitors, or whole body counters 2. Installed radiation monitors D. Procedure index for: 1. Calibration, use and operation of continuous air monitors, criticality monitors, portable survey instruments, temporary area radiation monitors, electronic dosimeters, teledosimetry, personnel contamination monitors, and whole body counters 2. Calibration of installed radiation monitors E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes. 1. Calibration of portable radiation detection instruments (for portable ion chambers)
2. Whole body counter calibration 3. Laboratory instrumentation quality control F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection, related to the following programs: 1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey instruments, electronic dosimeters, teledosimetry, personnel contamination monitors, whole body counters 2. Installed radiation monitors
3. Effluent radiation monitors 4. Count room radiation instruments NOTE: The lists should indicate the significance level of each issue and the search criteria used. G. Offsite dose calculation manual, technical requirements manual, or licensee controlled specifications which lists the effluent monitors and calibration requirements H. Current calibration data for the whole body counter's
A3- 3 - Attachment 3 I. Primary to secondary source calibration correlation for effluent monitors. J.
A list of the point of discharge effluent monitors with the two most recent calibration dates and the work order numbers associated with the calibrations 6. Radioactive Gaseous and Liquid Effluent Treatment (71124.06) Date of Last Inspection:
December, 9, 2010 A. List of contacts and telephone numbers for the following areas: 1. Radiological effluent control 2. Engineered safety feature air cleaning systems B. Applicable organization charts C. Audits, self assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to: 1.
Radioactive effluents 2.
Engineered Safety Feature Air cleaning systems D. Procedure indexes for the following areas 1.
Radioactive effluents 2.
Engineered Safety Feature Air cleaning systems E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes
1. Sampling of radioactive effluents 2. Sample analysis 3. Generating radioactive effluent release permits
4. Laboratory instrumentation quality control
5. In-place testing of HEPA filters and charcoal adsorbers
6. New or applicable procedures for effluent programs (e.g., including ground water monitoring programs) F. List of corrective action documents (including corporate and subtiered systems) written since date of last inspection, associated with: 1.
Radioactive effluents
2.
Effluent radiation monitors 3.
Engineered Safety Feature Air cleaning systems NOTE: The lists should indicate the significance level of each issue and the search criteria used. G. 2010 and 2011 Annual Radioactive Effluent Release Report
H. Current Copy of the Offsite Dose Calculation Manual I. Copy of the 2010 and 2011 interlaboratory comparison results for laboratory quality control performance of effluent sample analysis
A3- 4 - Attachment 3 J. Effluent sampling schedule for the week of the inspection K. New entries into 10
CFR 50.75(g) files since date of last inspection L. Operations Dept (or other responsible dept) log records for effluent monitors removed from service or out of service M. Listing or log of liquid and gaseous release permits since date of last inspection N. For technical specification-required air cleaning systems, the most recent surveillance test results of in-place filter testing (of HEPA filters and charcoal adsorbers) and laboratory testing (of charcoal efficiency) 7. Radiological Environmental Monitoring Program (71124.07)
Date of Last Inspection:
August 6, 2010 A. List of contacts and telephone numbers for the following areas: 1. Radiological environmental monitoring 2. Meteorological monitoring B. Applicable organization charts C. Audits, self assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to: 1. Radiological environmental monitoring program (including contractor environmental laboratory audits, if used to perform environmental program functions) 2. Environmental TLD processing facility 3. Meteorological monitoring program D. Procedure index for the following areas: 1. Radiological environmental monitoring program 2. Meteorological monitoring program E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes 1. Environmental Program Description 2. Sampling, collection and preparation of environmental samples
3. Sample analysis (if applicable)
4. Laboratory instrumentation quality control
5. Procedures associated with the Offsite Dose Calculation Manual 6. Appropriate QA Audit and program procedures, and/or sections of the station's QA manual (which pertain to the REMP) F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection, related to the following programs: 1. Radiological environmental monitoring 2. Meteorological monitoring
A3- 5 - Attachment 3 NOTE: The lists should indicate the significance level of each issue and the search criteria used. G. Wind Rose data and evaluations used for establishing environmental sampling locations H. Copies of the 2 most recent calibration packages for the meteorological tower instruments I. Copy of the 2010 and 2011 Annual Radiological Environmental Operating Report and Land Use Census, and current revision of the Offsite Dose Calculation Manual J. Copy of the environmental laboratory's interlaboratory comparison program results for 2010 and 2011, if not included in the annual radiological environmental operating report K. Data from the environmental laboratory documenting the analytical detection sensitivities for the various environmental sample media (i.e., air, water, soil, vegetation, and milk) L. Quality Assurance audits (e.g., NUPIC) for contracted services
M. Current NEI Groundwater Initiative Plan and status
8. Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation (71124.08) Date of Last Inspection:
August 6, 2010 A. List of contacts and telephone numbers for the following areas: 1. Solid Radioactive waste processing
2. Transportation of radioactive material/waste B. Applicable organization charts (and list of personnel involved in solid radwaste processing, transferring, and transportation of radioactive waste/materials) C. Copies of audits, department self-assessments, and LERs written since date of last inspection related to: 1. Solid radioactive waste management 2. Radioactive material/waste transportation program D. Procedure index for the following areas: 1. Solid radioactive waste management 2. Radioactive material/waste transportation E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes 1. Process control program 2. Solid and liquid radioactive waste processing
3. Radioactive material/waste shipping
4. Methodology used for waste concentration averaging, if applicable 5. Waste stream sampling and analysis
A3- 6 - Attachment 3 F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection related to: 1. Solid radioactive waste 2. Transportation of radioactive material/waste NOTE: The lists should indicate the significance level of each issue and the search criteria used. G. Copies of training lesson plans for 49CFR172 subpart H, for radwaste processing, packaging, and shipping H. A summary of radioactive material and radioactive waste shipments made from date of last inspection to present I. Waste stream sample analyses results and resulting scaling factors for 2010 and 2011 J. Waste classification reports if performed by vendors (such as for irradiated hardware) Although it is not necessary to compile the following information, the inspector will also review: K. Training, and qualifications records of personnel responsible for the conduct of radioactive waste processing, package preparation, and shipping