IR 05000361/2008015

Stations - Exercise of Enforcement Discretion, NRC Inspection Report Nos. 05000361/2008015 and 05000362/2008015, and Investigation Report No. 4-2008-034

ML082770116
Person / Time
Site:	San Onofre
Issue date:	10/02/2008
From:	Hay M C NRC/RGN-IV/DRP/RPB-D
To:	Ridenoure R T Southern California Edison Co
References
4-2008-034, EA 08-239, IR-08-015
Download: ML082770116 (4)

Text

October 2, 2008

EA 08-239 Ross T. Ridenoure, 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 - EXERCISE OF ENFORCEMENT DISCRETION, NRC INSPECTION REPORT NOS. 05000361/2008015 AND 05000362/2008015, AND INVESTIGATION REPORT NO. 4-2008-034

Dear Mr. Ridenoure:

This refers to the investigation completed on July 8, 2008, by the NRC Office of Investigations at San Onofre Nuclear Generating Station to determine whether two instrumentation and control technicians employed by San Onofre Nuclear Generating Station willfully failed to follow blowdown bypass procedures. This letter represents the subject inspection report documenting the results of that investigation.

Based on the results of the investigation, the NRC determined that a willful violation of requirements occurred. The violation is categorized as a Severity Level IV violation.

Specifically, on August 2, 2005, two Instrumentation and Controls technicians failed to follow procedure SO23-11-9.712, Revision 5, "Surveillance Requirement Steam Generator E088 and E089 Blowdown Bypass Channel Functional Test," which required in step 6.2.2 "On FY4077, disconnect input lead 9 from the (+) terminal and input lead 10 from the (-) terminal." Contrary to procedure requirements, when the Instrumentation and Controls technicians could not locate the terminals identified in the procedure they decided to disconnect the leads upstream in the circuit at TB101 (terminals 7 and 8), which they believed were equivalent points and would accomplish the same intent. However, they were incorrect and their actions resulted in an unexpected alarm when the electrical circuit was broken.

The Confirmatory Order, dated January 11, 2008, that resulted from an alternative dispute resolution (ADR) mediation session involving willful violations, states in part, that for a period of 6 months following issuance of the Order, the NRC will grant enforcement discretion if the NRC concludes that the provisions of Section VII.B.4 of the Enforcement Policy have been met. NRC review of the violation concluded that the five criteria in Section VII.B.4 of the Enforcement Policy for exercising discretion are met, in that the violation: (a) was licensee-identified; (b) had the same or similar root cause as the original violations; (c) did not substantially change the safety significance or the character of the regulatory concern arising out of the previously Southern California Edison Company identified willful violations; (d) was immediately corrected; and (e) would not be categorized as a Severity level I violation.

The licensee has taken substantial corrective actions to address the specific aspects of the violations as documented in the Confirmatory Order, including: (1) performing a common cause evaluation involving the willful events to determine the root and contributing causes for the collective issues, (2) entering corrective actions for the root and contributing causes into the corrective action program, (3) conducting an independent safety culture assessment and incorporating the results into the corrective action program, (4) conducting ethics and integrity training for managers, supervisors and other employees, and (5) performing periodic sampling of repetitive rounds and log-keeping to deter and detect instances of noncompliance. The NRC plans to assess the adequacy of these corrective actions during upcoming inspections.

Based upon our review of these facts, the NRC is granting enforcement discretion, and will take no enforcement action for this violation.

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 document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/

Michael C. Hay, Chief Project Branch D Division of Reactor Projects

Docket: 50-361 50-362

License: NPF-10 NPF 15

Southern California Edison Company cc w/

Enclosure:

Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101

Gary L. Nolff Assistant Director-Resources City of Riverside 3900 Main Street Riverside, CA 92522 Mark L. Parsons Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522

Dr. David Spath, Chief Division of Drinking Water and Environmental Management California Department of Health Services 850 Marina Parkway, Bldg P, 2nd Floor Richmond, CA 94804 Michael J. DeMarco San Onofre Liaison San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 Director, Radiological Health Branch State Department of Health Services P.O. Box 997414 (MS 7610) Sacramento, CA 95899-7414 Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672

James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 34) Sacramento, CA 95814 Douglas K. Porter, Esq. Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770 A. Edward Scherer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899-7414 Mr. James T. Reilly Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

Chief, Radiological Emergency Preparedness Section National Preparedness Directorate Technological Hazards Division Department of Homeland Security 1111 Broadway, Suite 1200 Oakland, CA 94607-4052 Southern California Edison Company Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.gov) DRS Director (Roy.Caniano@nrc.gov) DRS Deputy Director (Troy.Pruett@nrc.gov) Senior Resident Inspector (Greg.Warnick@nrc.gov) Resident Inspector (John.Reynoso@nrc.gov)

Branch Chief, DRP/D (Michael.Hay@nrc.gov) Senior Project Engineer, DRP/D (Don.Allen@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov) DRS STA (Dale.Powers@nrc.gov) Mark Cox, OEDO RIV Coordinator (Mark.Cox@nrc.gov)

ROPreports SO Site Secretary (Heather.Hutchinson@nrc.gov) Chief, Allegation and Enforcement Staff (William.Jones@nrc.gov) Senior Enforcement Specialist (Mark.Haire@nrc.gov)

SUNSI Review Completed: ALF ADAMS Yes No Initials: ALF Publicly Available Non-Publicly Available Sensitive Non-Sensitive ML082770116 SPE:DRP/D C:DRP/D ACES RC DAllen MCHay MHaire KSFuller /RA/ /RA/ /RA/ /RA/ 09/11/2008 09/5/2008 09/8/08 09/11/08&10/1/08 OFFICIAL RECORD COPY T= Telephone E= E-mail F = Fax