ML13357A058
| ML13357A058 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/23/2013 |
| From: | Dapas M Region 4 Administrator |
| To: | Thomas J. Palmisano Southern California Edison Co |
| References | |
| EA-13-083 IR-12-009 | |
| Download: ML13357A058 (6) | |
See also: IR 05000361/2012009
Text
UNITE D S TATE S
NUC LEAR RE GULATOR Y C OMMI S SI ON
R E G IO N I V
1600 EAST LAMAR BLVD
AR L INGTON , TEXAS 7 60 11 - 4511
December 23, 2013
Mr. Tom Palmisano
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 - FINAL SIGNIFICANCE
DETERMINATION OF WHITE FINDING AND NOTICE OF VIOLATION, NRC
INSPECTION REPORT 05000361/2012009 AND 05000362/2012009
Dear Mr. Palmisano:
This letter provides you the final results of our significance determination of the preliminary
White finding identified in NRC Inspection Report 05000361/ 2012009; 05000362/ 2012009
(NRCs Agencywide Documents Access and Management System (ADAMS) Accession
ML13263A271) dated September 20, 2013. The finding involved the failure to verify the
adequacy of the thermal-hydraulic and flow-induced vibration design of the Unit 3 replacement
steam generators, which resulted in significant and unexpected steam generator tube wear and
the loss of tube integrity on Unit 3 Steam Generator 3EO-88 after 11 months of operation.
In a letter dated October 21, 2013, (ML13296A018), you provided a response to the NRC staff's
preliminary determination regarding this finding. Your response included your agreement that
the finding has low-to-moderate safety significance and is, therefore, appropriately
characterized as a White finding. After considering the information developed during the
inspection and the additional information you provided in your letter, the NRC has concluded
that the finding is appropriately characterized as White, a finding of low to moderate safety
significance.
You have 30 calendar days from the date of this letter to appeal the staffs determination of
significance for the identified White finding. Such appeals will be considered to have merit only
if they meet the criteria given in the IMC 0609, Attachment 2. If you choose to appeal, you must
send your appeal to the Regional Administrator, Region IV, 1600 East Lamar Blvd., Arlington,
Texas 76011-4511.
The NRC has also determined that the failure to verify the adequacy of the thermal-hydraulic
and flow-induced vibration design of the Unit 3 replacement steam generators is a violation of
10 CFR Part 50, Appendix B, Criterion III, Design Control, with an associated violation of
T. Palmisano -2-
Technical Specification 5.5.2.11, Steam Generator Program. The circumstances surrounding
the violation were described in detail in NRC Inspection Report 05000361/2012009 and
05000362/2012009. In accordance with the NRC Enforcement Policy, this violation is
considered an escalated enforcement action because it is associated with a White finding.
The NRC has concluded that the information regarding the reason for the violation is already
adequately addressed on the docket through detailed inspection reports and your response
letter dated October 21, 2013. Additional information regarding the reason for the violation is
not required, unless the description therein does not accurately reflect the reasons for the
violation or your position. However, you are required to respond to this letter and provide the
results of your evaluation of the extent of condition related to the reasons for the violation.
Specifically, if you determine that any reason for this violation may apply to work activities
during decommissioning and dry cask storage, including oversight of contractor activities, then
for each such reason, your reply should include: (1) the corrective steps that have been taken
and the results achieved, (2) the corrective steps that will be taken, and (3) the date when all
associated corrective actions will have been implemented. If you determine that no reason for
this violation could reasonably apply to decommissioning or dry cask storage activities, then
your reply should include a statement to that effect. You should follow the instructions specified
in the enclosed Notice when preparing your response.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response, will be made available electronically for public inspection in the
NRC Public Document Room or from ADAMS, accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction.
Sincerely,
/RA/
Marc L. Dapas
Regional Administrator
Dockets: 50-361, 50-362
Enclosure: Notice of Violation
cc w/encl:
Electronic Distribution for San Onofre
Nuclear Generating Station
T. Palmisano -3-
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S:\RAS\ACES\ENFORCEMENT\_EA CASES - OPEN\SONGS_EA-13-083_SG Tube Integrity
White Finding\Final Action\FINAL WHITE_EA-13-083_SONGS_12-13-13.docx
ADAMS No Yes SUNSI Review Complete Reviewer Initials: RSB
Publicly Available Non-publicly Available Sensitive Non-sensitive
Category: KEYWORD: EA-13-083
BHagar GWerner RLantz RSBrowder KSFuller
/RA/ /RA/ /RA/ /RA/ /RA/
12/11/13 12/11/13 12/10/13 12/10/13 12/11/13
HJGepford RCarpenter KKennedy SReynolds MLDapas
/RA/ /RA/ /RA/ N/A /RA/
12/12/13 12/12/13 12/16/13 12/23/13
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
NOTICE OF VIOLATION
Southern California Edison Docket No. 50-362
San Onofre Nuclear Generating Station License No. NPF-15
During an NRC inspection conducted on December 3, 2012, through June 7, 2013, 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 III, Design Control, states, in part, that design
control measures shall provide for verifying or checking the adequacy of design, such as
by the performance of design reviews, by the use of alternate or simplified calculational
methods, or by the performance of a suitable testing program.
Technical Specification 5.5.2.11, Steam Generator Program, Section b, Performance
criteria for SG [steam generator] tube integrity, states, in part, that steam generator tube
integrity shall be maintained by meeting the performance criteria for tube structural
integrity and accident induced leakage.
Technical Specification 5.5.2.11 b.1, Structural integrity performance criterion,
states, in part, that all in-service steam generator tubes shall retain structural
integrity over the full range of normal operating conditions, to include retaining a
safety factor of 3.0 against burst under normal steady state full power operation
primary-to-secondary differential pressure.
Technical Specification 5.5.2.11 b.2, Accident induced leakage performance
criterion, states, in part, that leakage shall not exceed 0.5 gallons per minute per
steam generator for a main steam line break accident.
Contrary to the above, design control measures were not established to provide for
verifying or checking the adequacy of certain designs. Specifically, on January 28 and
April 2, 2008, the licensees design control measures did not provide for verifying or
checking the adequacy of design Documents L5-04GA504 (SO23-617- 1-C157),
Evaluation of Tube Vibration, Revision 3, and L5-04GA521 (SO23-617-1- C683),
Three-Dimensional Thermal and Hydraulic Analysis, Revision 3, developed by
Mitsubishi, for the flow-induced vibration and thermal-hydraulic designs. As a result, the
licensee did not verify or check the output of the thermal-hydraulic code and input to the
vibration code to be in accordance with ASME Section III, Appendix N, Dynamic
Analysis Methods.
Consequently, the inadequate thermal-hydraulic and flow-induced vibration design
resulted in non-conservative flow conditions, which led to fluid-elastic instability of a
group of tubes in the Unit 3 replacement steam generators. This resulted in one tube
leaking, which prompted the licensee to shut down the plant on January 31, 2012. In
March 2012, in-situ pressure testing on Unit 3 steam generator 3EO-88 revealed that
eight tubes had failed to meet the performance criteria for structural integrity and
Enclosure
accident induced leakage. Specifically, during in-situ pressure testing, tubes R106C78,
R102C78, R104C78, R100C80, R107C77, R101C81, R98C80, and R99C81 in steam
generator 3EO-88 failed to meet the structural integrity criterion limit of three times the
normal steady state primary-to-secondary differential pressure of 5250 psig, with the
tubes failing at test pressures ranging from 2874 psig to 5026 psig. In addition,
tubes R106C78, R102C78, and R104C78 failed to meet the accident-induced leakage
criterion of not exceeding 0.5 gpm leakage per steam generator at a main steam line
break pressure of 3200 psig, with each tube having leakage rates of approximately
4.5 gpm, prior to exceeding 3200 psig.
This violation is associated with a White Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby
required to submit a written statement or explanation to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the
Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that
is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of
Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation;
EA 13-083." The reply should include a written explanation for the evaluated extent of
conditions. Particularly, if you determine that any reason for this violation may apply to work
activities during decommissioning and dry cask storage, including oversight of contractor
activities, then for each such reason, your reply should include: (1) the corrective steps that
have been taken and the results achieved, (2) the corrective steps that will be taken, and (3) the
date when all associated corrective actions will have been implemented. If you determine that
no reason for this violation could reasonably apply to decommissioning or dry cask storage
activities, then your reply should include a statement to that effect.
Your response may reference or include previous docketed correspondence, if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for Information may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
action as may be proper should not be taken. Where good cause is shown, consideration will
be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs Agencywide Documents Management System
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to
the extent possible, it should not include any personal privacy, proprietary, or safeguards
information so that it can be made available to the public without redaction. If personal privacy
or proprietary information is necessary to provide an acceptable response, then please provide
a bracketed copy of your response that identifies the information that should be protected and a
redacted copy of your response that deletes such information.
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If you request withholding of such material, you must specifically identify the portions of your
response that you seek to have withheld and provide in detail the bases for your claim of
withholding (e.g., explain why the disclosure of information will create an unwarranted invasion
of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request
for withholding confidential commercial or financial information). If safeguards information is
necessary to provide an acceptable response, please provide the level of protection described
in 10 CFR 73.21.
Dated this 23rd day of December 2013
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