ML090350505

Reply to Notice of Violation; EA-08-296, Inspection Report No. 05000361/2008013 and 05000362/2008013

ML090350505
Person / Time
Site:	San Onofre
Issue date:	01/19/2009
From:	Ridenoure R Southern California Edison Co
To:	Document Control Desk, NRC Region 4
References
EA-08-296, IR-08-13
Download: ML090350505 (4)

See also: IR 05000361/2008013

Text

SOUTHERN CALIFORNIA

n ED DISON An EDISON INTERNATIONAL&

Company Ross T. Ridenoure Senior Vice President

and CNO San Onofre Nuclear Generating

Station January 19, 2009 U.S. Nuclear Regulatory

Commission

Attn: Document Control Desk Washington, D.C. 20555 Subject: References:

Docket Nos. 50-361 and 50-362 Reply to Notice of Violation;

EA-08-296 Inspection

Report No. 05000361/2008013

and 05000362/2008013

San Onofre Nuclear Generation

Station, Units 2 and 3 Letter from Mr. E. E. Collins (NRC) to Ross T. Ridenoure (SCE) dated December 19, 2008 and LER 2008-006, dated September

17, 2008 Dear Sir or Madam: The reference

letter transmitted

the results of NRC Inspection

Report No.05000361/2008013

and 05000362/2008013

to Southern California

Edison (SCE). The Special Inspection

was conducted

between August 4, 2008 and December 11, 2008 at San Onofre Nuclear Generating

Station (SONGS), Units 2 and 3. The referenced

report also transmitted

a Notice of Violation (EA-08-296).

The attachment

to this letter provides the required response to the Notice of violation.

If you have any questions, please feel free to contact me or Mr. A. E. Scherer.Sincerely, Enclosure:

As stated cc: E. E. Collins, Regional Administrator, NRC Region IV G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 Mail Stop D45 P.O. Box 128 San Clemente, CA 92672 (949) 368-6255 PAX 86255 Fax: (949) 368-6183 Ross.Ridenoure@sce.com

J~t~DI

ENCLOSURE REPLY TO A NOTICE OF VIOLATION The Enclosure

to Mr. E. E. Collin's letter dated December 19, 2008, states in Part: During an NRC inspection

completed

on December 11, 2008, a violation

of NRC requirements

was identified.

In accordance

with the NRC Enforcement

Policy, the violation

is listed below: 10 CFR Part 50, Appendix B, Criterion

V, "Instructions, Procedures, and Drawings," states, in part, that activities

affecting

quality shall be prescribed

by documented

instructions, procedures, or drawings of a type appropriate

to the circumstances

and shall be accomplished

in accordance

with these instructions, procedures, or drawings.

Instructions

and procedures

shall include appropriate

quantitative

or qualitative

acceptance

criteria for determining

that important activities

have been satisfactorily

accomplished.

Contrary to the above, in March 2004, the licensee engaged in activities

affecting quality that were not prescribed

by documented

instructions

or procedures

of the type appropriate

to the circumstances.

Specifically, maintenance

and work control personnel

failed to develop appropriate

instructions

or procedures, and failed to include quantitative

or qualitative

steps to ensure the maintenance

activities

on safety-related

125 Vdc station battery Breaker 2D201 had been satisfactorily

completed.

The work plan described

in Maintenance

Order 03100406000

was incomplete

and lacked the steps necessary

to ensure that-electrical

connection

fasteners

on Breaker 2D201 upper stud to bus bar connections

were properly installed.

This failure resulted in the Unit 2 safety-related

Battery 2B008 being inoperable

between March 2004 and March 25, 2008.This violation

is associated

with a White significance

determination

process finding.

SCE RESPONSE TO VIOLATION BACKGROUND

AND EVENT SUMMARY On March 25, 2008, while performing

a weekly surveillance

of a 1 E battery, plant personnel

discovered

its voltage below the required value. SCE determined

the low voltage was caused by loose bolts to the DC breaker connecting

the battery to the source of the battery charging current, the 1 E 125 VDC bus. SCE determined

that the degraded electrical

connection

to the DC breaker was due to an inadequate

work plan and lack of checks during installation

in March 2004. A report of the event was submitted

on September

17, 2008 (LER 2008-013).

As discussed

with the Nuclear Regulatory

Commission

during the Special Inspection

Exit meeting on December 11, 2008, SCE does not contest the violation

or the NRC's determination

of its significance.

1. Reason for the Violation The SCE Root Cause Evaluation

for the maintenance

activity of the 2004 installation

of the DC breaker identified

two root causes leading to the deficient

work. First, SCE concluded

that the Work Order was not sufficient

in detail to match the significance

of the work activity.

SCE planner personnel

do not consistently

perform to the same set of standards.

In this case, the Maintenance

Order Planner did not include critical steps in the work plan and did not provide adequate instruction

to verify the tightness

of the breaker bolts. The work plan was reliant on a single barrier (the electrician's

performance)

to ensure proper tightening

of the bolts.SCE concluded

the event involved not only planners not meeting procedure expectations, but also electricians

not meeting expectations

for applying their skills/knowledge

in the conduct of their work. In addition, the supervisor

was not overseeing

work and verifying

critical steps were complete.

Underlying

these behaviors was a lack of accountability.

2. Corrective

Actions Taken and Results Achieved a. On March 25, 2008, SCE tightened

the loose connections

for 2D201 which restored battery 2B008 to Operable status.b. On March 25-26, 2008, SCE inspected

the bolt/connections

for the seven similar breakers and verified that they were tight.c. SCE revised appropriate

maintenance

procedures

to provide additional

assurance

that critical electrical

connections, as defined by procedure, disturbed during maintenance

activities

are restored to their design condition.

These changes include: o Additional

verifications

of connection

torque or tightness.

o Specification

of torque values in procedure

or work order instructions.

o Post maintenance

verification

testing to confirm the connection

is restored to design condition.

d. To assess the extent of condition, SCE reviewed over 1300 Maintenance

Orders for the electrical

portion of the Emergency

Diesel systems, the Auxiliary Feedwater

system and the 1 E electrical

system. This review covered the previous 3 years and focused on identifying

previously

performed

work in which the work plan lacked critical steps and verification.

e. Based upon the review described

in 2.d, SCE has initiated

inspection

of the limited set of connections

based upon the work plans that lacked critical steps and verification.

This effort is on-going.f. SCE has initiated

independent

reviews to find and correct deficiencies

of previously

planned Maintenance

Order work plans prior to issuance to the field.(This review includes the equipment

whose failure may initiate (a) a plant trip, (b)a 5% reduction

in load, (c) entry into a 72-hour or less Technical

Specification

required shutdown or (d) DG inoperability.)

g. To initially

address the issue of not meeting expectations, SCE has reviewed the lessons learned from this event with the planners, electricians

and supervisors

involved with the 2004 installation.

3. Corrective

Actions That Will Be Taken a. SCE recognizes

the importance

of its responsibilities

with respect to identifying

and correcting

significant

degraded conditions, not meeting expectations

and lack of accountability.

Consequently, the RCE that addressed

the causes of this event is being expanded and broadened.

Additional

Corrective

Actions are anticipated

that will further address the root causes and reduce the likelihood

of a future safety significant

equipment

functional

failure due to loose electrical

connections.

b. SCE is developing

training modules to train planners in planning fundamentals.

These modules will address the use of newly revised planning procedures

as well as other applicable

division and site procedures.

SCE anticipates

the program will be implemented

and training will begin in April 2009.4. Date When Full Compliance

Will Be Achieved Full compliance

with the Technical

Specifications

was achieved with the maintenance

performed

on March 25, 2008 and Battery 2B008 restored to Operable status.Full compliance

with 10 CFR 50 Appendix B, Criterion

V was achieved on December 31, 2008 when revised procedures (in 2.c) were issued.