IR 05000361/2010001
| ML100621410 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/03/2010 |
| From: | Collins E Region 4 Administrator |
| To: | Ridenoure R Southern California Edison Co |
| References | |
| IR-10-001, FOIA/PA-2011-0157 | |
| Download: ML100621410 (13) | |
Text
rch 3, 2010
SUBJECT:
ANNUAL ASSESSMENT LETTER - SAN ONOFRE NUCLEAR GENERATING STATION (NRC INSPECTION REPORTS 05000361/2010001 and 05000362/2010001)
Dear Mr. Ridenoure,
On February 17, 2010, the NRC staff completed its performance review of San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 2009. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.
This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "Official Use Only--Security Information" will include the security cornerstone review and resultant inspection plan.
SONGS Units 2 and 3 operated in a manner that preserved public health and safety and fully met all cornerstone objectives.
The NRC continues to identify performance problems in human performance and problem identification and resolution. This is the fifth consecutive assessment cy cle where substantive cross-cutting issues were identified in both of these cross-cutting areas. Corrective actions you have taken to address these substantive cross-cutting issues have been ineffective.
Plant performance for Unit 2 for the most recent quarter was within the Regulatory Response column of the NRC
=s Action Matrix, based on one White finding in the Mitigation Systems cornerstone. The finding involved the failure to establish appropriate instructions for replacement of a safety-related battery output breaker resulting in the battery being inoperable between March 2004 and March 2008. The NRC was informed on October 19, 2009, of your staff's readiness for our review of your actions to address the White finding. In December 2009, the NRC conducted supplemental inspection IP 95001, "Inspection For One or Two White Inputs in a Strategic Performance Area," and concluded that the White finding will remain open because some corrective actions were not fully developed and there is a lack of assurance that your corrective actions will be effective. Unit 3 plant performance remained in the Licensee Southern California Edison Company - 2 -
Response Column of the NRC's action matrix, based on all inspection findings having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green).
In our mid-cycle assessment letter dated September 1, 2009, we advised you of a continuing substantive cross-cutting issue in the area of Human Performance associated with two components, the component of resources involving the theme of failing to provide adequate design documentation, procedures and work instructions; and the component of work practices in the theme of ineffective use of human error prevention techniques. Also during the mid-cycle assessment period the NRC identified an additional theme in the area of human performance in the component of decision making associated with a theme of failing to use conservative assumptions. During this assessment period, the NRC identified four or more findings in each of these cross-cutting themes. Based on these inspection results we determined that your corrective actions have not demonstrated performance improvement to close these substantive cross-cutting issues. Additionally during th is assessment period the NRC identified a new human performance theme with four findings in the component of work practices associated with ensuring supervisory and management oversight of work activities.
Also in our mid-cycle assessment letter the NRC advised you of a continuing substantive cross-cutting issue in the area of Problem Identification and Resolution associated with the corrective action program component involving instances of failing to thoroughly evaluate problems such that the resolutions effectively address the causes and extent of conditions. During this assessment period the NRC identified five findings with this theme, therefore this problem identification and resolution substantive cross-cutting issue will remain open. Additionally during this assessment period the NRC identified two new problem identification and resolution themes in the component of the corrective action program. One new theme, with four findings, was associated with implementing the corrective action program with a low threshold for identifying issues. The other new theme, which also had four findings during the assessment period, was associated with taking appropriate corrective actions to address safety issues in a timely manner, commensurate with their safety significance.
During this assessment period existing performance problems have persisted and new ones have emerged. These include 4 persistent themes and 3 additional themes associated with longstanding substantive cross-cutting issues in Human Performance and Problem Identification and Resolution. NRC recognizes that you have established a site improvement plan to facilitate organizational and operational improvement. In addition, the NRC plans to conduct additional inspections, above the baseline inspection program, to evaluate the effectiveness of your performance improvement efforts. The NRC plans to conduct periodic pub lic meetings in 2010, beginning with the End of Cycle meeting scheduled for March 24, 2010, to discuss your progress in improving performance. In subsequent assessment periods, the NRC will consider closing the substantive cross-cutting issues in Human Performance and Problem Identification and Resolution when your performance has demonstrated through sustained improvement that your corrective actions have been effective.
In the 2008 Annual Assessment Letter dated March 4, 2009, the NRC required you to conduct an independent assessment of the safety culture at SONGS. The NRC reviewed the results of that assessment, and also performed focus group interviews to validate the results, and Southern California Edison Company - 3 -
identified differences between our assessment and yours. In addition, allegations concerning SONGS are at 10 times the national median. Trends in allegations claiming discrimination and retaliation, as well as anonymous allegations, have increased significantly over previous years. As a result of our assessment of your safety conscious work environment, the NRC issued a chilling effect letter on March 2, 2010. The purpose of the chilling effect letter is to verify that you are taking appropriate actions to ensure SONGS is a workplace that fosters an environment where employees feel free, and are encouraged, to raise safety concerns. The chilling effect letter requested specific actions from you to address these issues.
On January 11, 2008, the NRC issued a Confirmatory Order to you as the result of a successful alternative dispute resolution mediation session related to falsification of firewatch certification sheets. Corrective actions have been taken, and some have been effective. The NRC will perform a follow up inspection following receipt of your letter discussing your basis for concluding that the Order has been satisfied.
Also, the recent NRC inspection to follow up on corrective actions for the White finding discussed above was unable to conclude that your corrective actions were fully developed and would be effective. The NRC will perform another supplemental inspection IP 95001 for the White finding when your staff informs us that you are ready for our review.
The enclosed inspection plan details the inspections, less those related to security scheduled through June 30, 2011. The NRC intends to conduct an NRC inspection procedure IP 50001,
"Steam Generator Replacement Inspection" in the fall of 2010 concurrent with the Unit 3 steam generator replacement outage. The NRC also plans to conduct inspections in addition to baseline inspections to review the effectiveness of your performance improvement initiatives. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last nine months of the inspection plan are tentative and may be revised at the mid-cycle review.
In accordance with 10 CFR 2.390 of the NRC
=s A Rules of Practice,@ a copy of this letter and its enclosure will be made 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).
If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Ryan Lantz at 817-860-8173 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/ R. Caniano for Elmo E. Collins Regional Administrator
Southern California Edison Company - 4 -
Docket Nos. 50-361, 50-362 License Nos. NPF-10, NPF-15
Enclosure: San Onofre Nuclear Generating Station Inspection / Activity Plan
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 Gary H. Yamamoto, P.E., Chief Division of Drinking Water and Environmental Management
1616 Capitol Avenue, MS 7400 P.O. Box 997377 Sacramento, CA 95899-7377
Michael J. DeMarco San Onofre Liaison
San Diego Gas & Electric Company 8315 Century Park Ct. CP21C 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
Southern California Edison Company - 5 -
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
Albert R. Hochevar
Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128
Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414
Sacramento, CA 95899-7414
R. St. Onge Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128
Chief, Technological Hazards Branch FEMA Region IX 1111 Broadway, Suite 1200
Oakland, CA 94607-4052
Walter F. Ekard Chief Administrative Officer San Diego County 1600 Pacific Coast Highway, Suite 209
San Diego, CA 92101
The Honorable Steven Weinberg, Mayor City of Dana Point 33282 Golden Lantern, Suite 203
Dana Point, CA 92629 Southern California Edison Company - 6 -
The Honorable Dr. Londres Uso, Mayor City of San Juan Capistrano
32400 Paseo Adelanto San Juan Capistrano, CA 92675
Joe Tait, City Manager City of Dana Point 33282 Golden Lantern, Suite 203
Dana Point, CA 92629
David Adams, City Manager City of San Juan Capistrano 32400 Paseo Adelanto San Juan Capistrano, CA 92675
Jeremy Kirchner, Emergency Services Coordinator City of Dana Point 33282 Golden Lantern, Suite 203
Dana Point, CA 92629
The Honorable Jim Dahl, Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672
Nancy Ward, Acting Regional Director Federal Emergency Management Agency, Region IX 1111 Broadway, Suite 1200
Oakland, CA 94607-4052
George Scarbrough, City Manager City of San Clemente 100 Avenida Presidio San Clemente, CA 92672
Penny Leinwander, Senior Health Physicist Department of Health Services Environmental Management Branch 1616 Capitol Avenue, MS 7402
Sacramento, CA 95899-7377 Southern California Edison Company - 7 -
Peg Taylor (Interim), Manager Radiological Preparedness Unit Governor~s Office of Emergency Services 3650 Schriever Avenue Mather, CA 95655
Susan Asturias, Sr. Emergency
Services Coordinator San Diego County Office of
Emergency Services 5555 Overland Avenue, Suite 1911 San Diego, CA 92123 Moustafo Abou-Taleb
Radiological Coordinator Governor's Office of Emergency Services Radiological Preparedness Unit 3650 Schriever Avenue Mather, CA 95655
Vicki Osborn Senior Program Coordinator Orange County Sheriff
~s Department/ Emergency Management Bureau 2644 Santiago Canyon Road Silverado, CA 92676
Jim Russell, Emergency Planning Officer City of San Clemente 910 Calle Negocio, Suite 100 San Clemente, CA 92673
Mike Cantor; Emergency Planning Officer City of San Juan Capistrano
32400 Paseo Adelanto San Juan Capistrano, CA 92675 Ziad Mazboudi, Senior Civil Engineer City of San Juan Capistrano
32400 Paseo Adelanto San Juan Capistrano, CA 92675-3679
Kenneth Kramer, District Superintendent Orange Coast District
California Department of Parks & Recreation 3030 Avenida del Presidente San Clemente, CA 92672 Southern California Edison Company - 8 -
Steve Long, Chief Ranger Orange Coast District
California Department of Parks & Recreation 3030 Avenida del Presidente San Clemente, CA 92672
Lynne Seabloom Emergency Preparedness Coordinator Oceanside Fire Department
300 N. Coast Highway Oceanside, CA 92054 Terry Garrison; Battalion Chief Oceanside Fire Department 300 N. Coast Highway.
Oceanside, CA 92054 Mike Drake Deputy Assistant Chief of Staff Operations and Training Marine Corps Base P.O. Box 555021 Camp Pendleton, CA 92055-5021
Patricia Gentry, REHS Program Manager Environmental Health County of Orange 1241 E. Dyer Road, Suite 120
Santa Ana, CA 92705
Donna Boston, Emergency Manager Orange County Sheriff's Department Homeland Security Division Emergency Management Bureau 2644 Santiago Canyon Road
Silverado, CA 92676
Sara Kaminske, Assistant Emergency Manager Orange County Sheriff's Department
Homeland Security Division Emergency Management Bureau 2644 Santiago Canyon Road
Silverado, CA 92676 Southern California Edison Company - 9 -
Katrina Faulkner, Senior Program Coordinator Orange County Sheriff's Department
Homeland Security Division Emergency Management Bureau 2644 Santiago Canyon Road
Silverado, CA 92676 Southern California Edison Company - 10 -
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov) Deputy Regional Administrator (Chuck.Casto@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)
Branch Chief, DRP/D (Ryan.Lantz@nrc.gov) Senior Project Engineer, DRP/D (Don.Allen@nrc.gov)
Senior Resident Inspector (Greg.Warnick@nrc.gov)
Resident Inspector (John.Reynoso@nrc.gov)
Branch Chief, DRS/TSB (Michael.Hay@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Regional State Liaison Officer (Bill.Maier@nrc.gov) RA Administrative Assistant (Lucy.Owen@nrc.gov)
DRA Administrative Assistant Anita.Tannenbaum@nrc.gov) Branch Chief, DRS/EB1 (Thomas.Farnholtz@nrc.gov) Branch Chief, DRS/EB2 (Neil.OKeefe@nrc.gov)
Branch Chief, DRS/PSB1 (Michael.Shannon@nrc.gov)
Branch Chief, DRS/PSB2 (Greg.Werner@nrc.gov)
Branch Chief, DRS/OB (Mark.Haire@nrc.gov)
OEDO RIV Coordinator, Primary (Leigh.Trocine@nrc.gov) Director, DIRS, NRR (Frederick.Brown@nrc.gov) Director, DORL, NRR (Joseph.Giitter@nrc.gov)
Deputy Director, DORL, NRR (Robert.Nelson@nrc.gov)
Chief, PLB IV, DORL, NRR (Michael.Markley@nrc.gov)
NRR Project Manager (Fred.Lyon@nrc.gov)
RidsNrrDirslpab Resource@nrc.gov ROPreports.Resource@nrc.gov Congressional Affairs Officer (Jenny.Weil@nrc.gov)
mortensengk@INPO.org
File located: R_Reactors\EOC2009\SONGS.doc SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials RL Publicly Avail Yes No Sensitive Yes No Sens. Type Initials RL C:DRP/D D:DRS D:DRP RA RLantz RJCaniano DDChamberlain ECollins /RA/ /RA/ /RA/ /RA/RCaniano for 3/3/2010 3/3/2010 3/3/2010 3/3/2010 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax Southern California Edison Company - 11 -
Inspection / Activity Plan Page 1 of 2 02/18/2010 10:37:42 Report 22 04/01/2010-06/30/2011 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site San Onofre SGR U3-STEAM GENERATOR REPLACEMENT - UNIT 3 2 3 IP Steam Generator Replacement Inspection 50001 01/01/2010 12/31/2010 TSB-52B-BIENNIAL PI&R 9 2, 3 IP Identification and Resolution of Problems 71152B 04/05/2010 04/09/2010 2, 3 IP Identification and Resolution of Problems 71152B 04/19/2010 04/23/2010 EB2-05T-TRIENNIAL FIRE PROTECTION 4 2, 3 IP Fire Protection [Triennial]
7111105T 06/14/2010 06/18/2010 2, 3 IP Fire Protection [Triennial]
7111105T 06/28/2010 07/02/2010 RP678GPI-RADIATION SAFETY TEAM INSPECTION 3 2, 3 IP Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative 2515/173 08/02/2010 08/06/2010 2, 3 IP Radioactive Gaseous and Liquid Effluent Treatment 71124.06 08/02/2010 08/06/2010 2, 3 IP Public Radiation Safety 71124.07 08/02/2010 08/06/2010 2, 3 IP Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 71124.08 08/02/2010 08/06/2010 2 IP Occupational Exposure Control Effectiveness 71151-OR01 08/02/2010 08/06/2010 2 IP RETS/ODCM Radiological Effluent 71151-PR01 08/02/2010 08/06/2010 EXAM-INITIAL EXAM 5 2 INITIAL EXAM-SONGS (10/2010)
X02445 09/20/2010 09/25/2010 3 INITIAL EXAM UNIT 3-SONGS (10/2010)
X02446 09/20/2010 09/25/2010 2 INITIAL EXAM-SONGS (10/2010)
X02445 10/18/2010 10/29/2010 3 INITIAL EXAM UNIT 3-SONGS (10/2010)
X02446 10/18/2010 10/29/2010 PSB2-08P-INSERVICE INSPECTION - U3 3 3 IP Reactor Coolant System Dissimiliar Metal Butt Welds 2515/172 10/12/2010 10/22/2010 3 IP Inservice Inspection Activities - PWR 7111108P 10/12/2010 10/22/2010 EP-1-BIENNIAL EP PROGRAM INSPECTION 1 2, 3 IP Radiological Environmental Monitoring Program 7111402 11/15/2010 11/19/2010 2, 3 IP Emergency Response Organization Augmentation Testing 7111403 11/15/2010 11/19/2010 2, 3 IP Emergency Action Level and Emergency Plan Changes 7111404 11/15/2010 11/19/2010 2, 3 IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 11/15/2010 11/19/2010 2, 3 IP Drill/Exercise Performance 71151-EP01 11/15/2010 11/19/2010 2, 3 IP ERO Drill Participation 71151-EP02 11/15/2010 11/19/2010 2, 3 IP A lert & Notification System 71151-EP03 11/15/2010 11/19/2010 RS12-OCCUPATIONAL RADIATION SAFETY 2 2, 3 IP Radiological Hazard Assessment and Exposure Controls 71124.01 11/01/2010 11/05/2010 2, 3 IP Occupational ALARA Planning and Controls 71124.02 11/01/2010 11/05/2010 2 IP Occupational Exposure Control Effectiveness 71151-OR01 11/01/2010 11/05/2010 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Inspection / Activity Plan Page 2 of 2 02/18/2010 10:37:42 Report 22 04/01/2010-06/30/2011 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site San Onofre RS12-OCCUPATIONAL RADIATION SAFETY 2 3 IP RETS/ODCM Radiological Effluent 71151-PR01 11/01/2010 11/05/2010 BRQ-OPERATOR REQUAL INSPECTION 3 2, 3 IP Licensed Operator Requalification Program 7111111B 11/01/2010 11/05/2010 EP1-BIENNIAL EP EXERCISE INSPECTION 3 2, 3 IP Exercise Evaluation 7111401 04/11/2011 04/15/2011 2, 3 IP Emergency Action Level and Emergency Plan Changes 7111404 04/11/2011 04/15/2011 2, 3 IP Drill/Exercise Performance 71151-EP01 04/11/2011 04/15/2011 2, 3 IP ERO Drill Participation 71151-EP02 04/11/2011 04/15/2011 2, 3 IP A lert & Notification System 71151-EP03 04/11/2011 04/15/2011 RP123-RADIATION SAFETY 2 2, 3 IP Radiological Hazard Assessment and Exposure Controls 71124.01 04/11/2011 04/15/2011 2, 3 IP Occupational ALARA Planning and Controls 71124.02 04/11/2011 04/15/2011 2, 3 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 04/11/2011 04/15/2011 EB1-21-COMPONENT DESIGN BASIS INSPECTION 1 2, 3 IP Component Design Bases Inspection 7111121 06/13/2011 07/15/2011 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.