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
UNITED STATES NU C LE AR RE G ULATO RY C O M M I S S I O N 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 cycle 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 staffs 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 NRCs 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 this 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 public 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 ARules 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 Sheriffs Department Homeland Security Division Emergency Management Bureau 2644 Santiago Canyon Road Silverado, CA 92676 Sara Kaminske, Assistant Emergency Manager Orange County Sheriffs 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 Sheriffs 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 -
Page 1 of 2 San Onofre 02/18/2010 10:37:42 Inspection / Activity Plan Report 22 04/01/2010 - 06/30/2011 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site SGR U3 - STEAM GENERATOR REPLACEMENT - UNIT 3 2 3 01/01/2010 12/31/2010 IP 50001 Steam Generator Replacement Inspection TSB-52B - BIENNIAL PI&R 9 2, 3 04/05/2010 04/09/2010 IP 71152B Identification and Resolution of Problems 2, 3 04/19/2010 04/23/2010 IP 71152B Identification and Resolution of Problems EB2-05T - TRIENNIAL FIRE PROTECTION 4 2, 3 06/14/2010 06/18/2010 IP 7111105T Fire Protection [Triennial]
2, 3 06/28/2010 07/02/2010 IP 7111105T Fire Protection [Triennial]
RP678GPI - RADIATION SAFETY TEAM INSPECTION 3 2, 3 08/02/2010 08/06/2010 IP 2515/173 Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative 2, 3 08/02/2010 08/06/2010 IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment 2, 3 08/02/2010 08/06/2010 IP 71124.07 Public Radiation Safety 2, 3 08/02/2010 08/06/2010 IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 2 08/02/2010 08/06/2010 IP 71151-OR01 Occupational Exposure Control Effectiveness 2 08/02/2010 08/06/2010 IP 71151-PR01 RETS/ODCM Radiological Effluent EXAM - INITIAL EXAM 5 2 09/20/2010 09/25/2010 X02445 INITIAL EXAM-SONGS (10/2010)
3 09/20/2010 09/25/2010 X02446 INITIAL EXAM UNIT 3-SONGS (10/2010)
2 10/18/2010 10/29/2010 X02445 INITIAL EXAM-SONGS (10/2010)
3 10/18/2010 10/29/2010 X02446 INITIAL EXAM UNIT 3-SONGS (10/2010)
PSB2-08P - INSERVICE INSPECTION - U3 3 3 10/12/2010 10/22/2010 IP 2515/172 Reactor Coolant System Dissimiliar Metal Butt Welds 3 10/12/2010 10/22/2010 IP 7111108P Inservice Inspection Activities - PWR EP-1 - BIENNIAL EP PROGRAM INSPECTION 1 2, 3 11/15/2010 11/19/2010 IP 7111402 Radiological Environmental Monitoring Program 2, 3 11/15/2010 11/19/2010 IP 7111403 Emergency Response Organization Augmentation Testing 2, 3 11/15/2010 11/19/2010 IP 7111404 Emergency Action Level and Emergency Plan Changes 2, 3 11/15/2010 11/19/2010 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 2, 3 11/15/2010 11/19/2010 IP 71151-EP01 Drill/Exercise Performance 2, 3 11/15/2010 11/19/2010 IP 71151-EP02 ERO Drill Participation 2, 3 11/15/2010 11/19/2010 IP 71151-EP03 Alert & Notification System RS12 - OCCUPATIONAL RADIATION SAFETY 2 2, 3 11/01/2010 11/05/2010 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 2, 3 11/01/2010 11/05/2010 IP 71124.02 Occupational ALARA Planning and Controls 2 11/01/2010 11/05/2010 IP 71151-OR01 Occupational Exposure Control Effectiveness This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Page 2 of 2 San Onofre 02/18/2010 10:37:42 Inspection / Activity Plan Report 22 04/01/2010 - 06/30/2011 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site RS12 - OCCUPATIONAL RADIATION SAFETY 2 3 11/01/2010 11/05/2010 IP 71151-PR01 RETS/ODCM Radiological Effluent BRQ - OPERATOR REQUAL INSPECTION 3 2, 3 11/01/2010 11/05/2010 IP 7111111B Licensed Operator Requalification Program EP1 - BIENNIAL EP EXERCISE INSPECTION 3 2, 3 04/11/2011 04/15/2011 IP 7111401 Exercise Evaluation 2, 3 04/11/2011 04/15/2011 IP 7111404 Emergency Action Level and Emergency Plan Changes 2, 3 04/11/2011 04/15/2011 IP 71151-EP01 Drill/Exercise Performance 2, 3 04/11/2011 04/15/2011 IP 71151-EP02 ERO Drill Participation 2, 3 04/11/2011 04/15/2011 IP 71151-EP03 Alert & Notification System RP123 - RADIATION SAFETY 2 2, 3 04/11/2011 04/15/2011 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 2, 3 04/11/2011 04/15/2011 IP 71124.02 Occupational ALARA Planning and Controls 2, 3 04/11/2011 04/15/2011 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation EB1-21 - COMPONENT DESIGN BASIS INSPECTION 1 2, 3 06/13/2011 07/15/2011 IP 7111121 Component Design Bases Inspection This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.