ML19116A056
| ML19116A056 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/23/2019 |
| From: | Bauder D Southern California Edison Co |
| To: | Office of Nuclear Material Safety and Safeguards, NRC/OE, NRC Region 4 |
| References | |
| EA-18-155, IR 2018001, IR 2018005 | |
| Download: ML19116A056 (7) | |
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' 1,
. D~lig Bauder '
'Chief Nuclear Officer and
. !Vice Pr~~ident, Decommissioning EA-18-155 April 23, 2019 Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Docket Nos. 50-206, 50-361, 50-362 and 72-41 Reply to a Notice of Viol,ation, EA-18-155, and Statement of Method of Payment San Onofre Nuclear Generating Station (SONGS), Units 1, 2, 3, and ISFSI
REFERENCES:
- 1. Letter from Mr. Troy Pruett (NRC) to Doug Bauder (SCE) dated November 28, 2018,
Subject:
NRC Special lnsp,ection Report 050-00206/2018-005, 050-00361/2018-005, 050-00362/2018-005, and 072-00041/2018-001 and Notice of Violation, (ADAMS Accession No. ML18332A357)
- 2. Southern California Edison Company; San Onofre Nuclear Generating Station, Pre-Decisional Enforcement Conference Slides, dated January 24, 2019 (ADAMS Accession No. ML19023A033) .
- 3. Letter from Scott A. Morris (NRC) to Doug Bauder (SCE) dated March 25, 2019,
Subject:
Notice of Violation and Proposed Imposition of Civil Penalty - $116,000 and NRC Special Inspection Report 050-00206/2018-005, 050-00361 /2018-005, 050-00362/2018-005, [>£/6 i 072-00041/2018-001 (ADAMS Accession No. ML19080A208) _:z:Ebl Dear Sir or Madam TEbP
. µt-{s5Z../p Reference 1 transmitted the results of NRC Special Inspection Report Numbers 050-00206/2018-005, 050-00361/2018-005, 050-00362/2018-005, and 072-00041/2018-001 to Southern California Edison (SCE). The inspection was conducted on-site from September 7? C,JJ-1 (
10, 2018 to September 14, 2018 for the San Onofre Nuclear Generating Station (SONGS). The inspection was in response to the misalignment of a loaded spent fuel storage canister as N'1SS it was being downloaded into the storage vault at SONGS. Reference 1 discussed two apparent violations that were under consideration for escalated enforcement and provided SCE options for responding. SCE selected a Pre-Decisional Enforcement Conference which tJfll/0 was held on January 24, 2019 (Reference 2). Reference 3 issued a Notice of Violation resulting from the two issues discussed in Reference 1 and a Proposed Imposition of Civil Penalty to SCE. Reference 3 required SCE to reply to
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Ddcument Control Desk. . the violations in writing ~ithin 30 days. R~ference 3 also required $CE to provide a' statem~nt iridicating whe.n and by what methocl paymeri( was mape or to protest the imp9sitipn of the 1 - '. civfl penalty in whole o'r in part. *
- The enclosur~ to this letter provid~s SCE\s acceptance of and reply to the Notice .ofViolati~n provided in Referenee 3. ' * *
- r In addition, S.CE has chosen to pay the proposed c'ivil Penalty qf $116,000 and will not contest the Civil Perialty in whole o:r in part. SCE made the required payment to the NRC via wire payment on March 29, 2q19, 1 There are no new regulatory commitments in this letter or the Enclosure.
If you have any questions or require additional information, please contact me or Mr. Albert Bates, at (949) 368J945. Executed on 1/-Z/11 ff i. Sincerely,
Enclosure:
Reply to Notice of Violation EA-18-155 cc:
- Document Control Desk S. Morris, Regional Administrator, NRC Region IV M. Vaaler, NRC Project Manager, SONGS Units 1, 2 and 3
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~- J ENCLOSURE Reply to Notice of Violation EA-18~155
' r' Reply to
.=t Notice of Violation EA-18-155 BACKGROUND AND EVENT
SUMMARY
On January 22nd, 2018, the San Onofre Nuclear Generating Station (SONGS) began a fuel transfer campaign from the Units 2 and 3 spent fuel pools to a Holtec HI-STORM UMAX Independent Spent Fuel Storage lnstalla~ion (ISFSI). The campaign will Ultimately result in the transfer of 73 canisters to the ISFSI. On Friday, August 3, 2018, at approximately 12:45 PDT, workers at SONGS were lowering Multi-Purpose Canister (MPC) number 29 into a Cavity Enclosure Container (CEC) within the Independent Spent Fuel Storage Installation (ISFSI). Workers used a Vertical Cask Transporter (VCT) to perform the download operation. As the MPC was lowered, it came to rest on top of the shield fing and against the inner wall of the transfer cask. The VCT slings went slack indicating the' MPC was hung up. The VCT operator could not see the MPC as it was being lowered within the transfer cask. The spotter assigned to observe the MPC did not recognize the slack sling condition. The Cask Loading Supervisor (CLS), Rigger-in-Charge (RIC) and the Southern California Edison (SCE) ISFSI Project Oversight Specialist were located 150 feet away in a low radiation dose area and did not have a visible way to monitor the lowering of the MPC into the CEC. With the MPC supported by the shield ring, the crane and rigging no longer supported it. Dose rate measurements taken near the VCT indicated that the MPC had not been lowered to its fuliy downloaded condition. Actions were taken immediately to raise the VCT, regaining support of the MPC by the VCT. The MPC was then safely lowered past the shield ring and into storage at 14: 14 PDT. At that time, MPC number 30 was being prepared for transfer to dry storage in the SONGS Unit 3 Fuel Handling Building. The MPC was seismically restrained in the Unit 3 Fuel Handling Building and then closure welding was completed. Since that time, SONGS has suspended all fuel movement pending completion of cause evaluations and required corrective actions. SCE will not re~start fuel transfer operations until the NRC has reviewed SCE's corrective actions and SCE management is satisfied full readiness has been achieved to ensure safe and effective fuel transfer operations. This event was informally communicated to NRC Region IV on Monday, August 6, 2018. A late report was made to the NRC Headquarters Operations Center on Friday, September 14, 2018 in accordance with 10 CFR 72.75(d)(1 ). Following the event, Holtec completed a root cause evaluation in accordance with its corrective action program to determine causes and appropriate corrective actions to prevent
- recurrence. SCE reviEjwed and accepted Holtec's root cause evaluation. In addition, SCE completed an Apparent Cause Evaluation to examine how SCE's oversight failecj to prevent the event and a Common Cause Evaluation to examine issues related to fuel transfer in the 1
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areas of adryrinlstratioh, and 'problem identificatiori and resblution:. ;SC$'s Apparent Cause
'Evaluation and Common Cause Ev~luation also resulted. in cprredive actjons to prevent recµrrence of these problems. SCE also completed a.Root Gause Evaluation to .determine '1
. the causes of the late report to the _NRC Headquarters Operations Center.
- On March 25, 2019, -the NRC issued a Notice of Violation (NOV) ,and Proposed Imposition of Civil Penalty numbered EA-18-155 and requested a reply within 30 days. The reply to the Notice of Violation appears below.
DESCRIPTION OF VIOLATION 18-155-A
- 10 CFR i2.172(b)(3) requires, in part,*that each cas_k used by .the general licehsee conforms to the terms, conditions, and specifications of a Certificate of Compliance listed in 10 CFR 72.214. fo CFR 72.214 includes a list of all the approved spent fuel storage casks that can be ~tilized under the conditions specified in a specific Certificate of Compliance, including
- Amendment 2 of Certificate of Compliance 072-01040. Certificate of Compliance 072-01040, Amendment 2, Condition 4, "HEAVY LOADS REQUIREMENTS," requires, in part, that lifting operations outside of structures governed by 10 CFR Part 50 must be in accordance with Technical Specifications, Appendix A, Section 5.2.
Technical Specifications, Appendix A, Section 5.2.c.3 requires, in part, that the transfer cask, when loaded with spent fuel, may be lifted and carried at any height during multi-purpose canister transfer operations provided the lifting equipment is designed with redundant drop protection features which prevent uncontrolled lowering of the load. Contrary to the above, on August 3, 2018, the licensee failed to ensure that the redundant drop protection features were available to prevent uncontrolled lowering of the load during multi-purpose canister transfer operations. Specifically, the licensee inadvertently disabled the redundant important-to-safety downloading slings while lowering canister 29 into the storag~ vault. During the approximately 45-minute time-fram?, the canister rested on a shield ring unsupported by the redundant downloading slings at approximately 18 feet above the fully seated position. This failure to maintain redundant drop protection placed canister 29 in an u*nanalyzed condition because the postulated drop of .a l0aded spent fuel canister is not analyzed in the final safety analysis report. SCE REPLY TO VIOLATION 18-155-A
- 1. Reason for the Violation The Root Cause Evaluation identified a Root Cause that Holtec Management failed to recognize the complexity and risks associated with fuel transfer operation while using a relatively nevy system desig'n (UMAX) when performing a long duration campaign and thus did not implement necessary program improvements. Contributing causes included:
- Inadequate procedure content
- Inadequate design review process
- Poor communication protocols
- A Continuous Learning Environment not established for use of Operating Experience
- Inadequate training pmgram 2
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}°he APP~r~n~ C~u~e ~/i:!IUatid_rJ J9~ntifi~.q._?h *tPPe.r~nt y~USE/ ofSCE failif)~l to e_stablish: a*
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A low thresho*id for Corr:edive Actio6 Program entries,.not ~nfotced
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- 2. Oorrective;Actions Tc1ken.;and-Resuits A,chje~$d.
Corrective actions r~lated ~o proo~d;µre. -coD,tE/int a.nd QO!iltrq!, Jr$.ining and ;q\1alifiqc1tiohs, and the us~ of the C,ofrectiv~,Acti~n Pr:b.~t;arp (C;P) ,w~re qescrfb_~d:in o.et_~i]'i~ SQ$'s*t~ply to a N9tibe of Viol_ation dated. t~;e6$riil:ier"i6,: :2pH~ {AG>AM$ A.cd~ssi9h N<:f Ml-18362A148). In additio,n, c6rrective-a¢tions relc;1tei.dltq*~~-~9h,'citt,fc~U.$Efs fqentified in ifem 1, above, are described 'in. SC)=;ifpre§eptation :for-tii~ 'dc:itiuaJ-y 24; *2ot~rPte::.pcici~ional Enforcement
- Conference (ADAMS Accession J\Jp; Jy1)_
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Finally, ~s an additional* correctiv¢iaQ{ipfifr~m th~ App~rent c~u.$~ Eval1,1ation,;sc1{has taken action to require enhanced load f)lQnitoring;~q.uiprrj~nt',,if)C,luc;ling foag monitoring shackles with remote indication:*and *a1ahns, cameras and ,monitc:ks iristalied .fo observe a downloading remot~ly; ~hd itag-'irne indidto'r ihst~lled oh. th~:*MPC for physica*1 . *. verification of downi6adlmg.
- 3. Corrective Actions Thaf\/Vili Be Taken
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- None.
- 4. Dat~ When Full ComplJ.c;1nGe Will Se Achieved Full.*
compliance was achieved . on.Augµst i B, 2018, when the \/CT rE)gained .
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o{the MPG. DESCRIPTION OF VIQLA;flON 18-155~:s
.* 1~ CFR ?f. 75(9)(1) req~ires, in part,,fhat ~~9h Hcen.S~El §i~~II no,\ffy th.~ N.RC within 2~Lnours after the discovery pf *an e.vent'involving* spent fue*1 in whi¢h. irnportarit-tq-safety equipment is dis~bled or fi:ii!s to fun:ctign a*$ design.edwh!;lrt: (I) th"e,eq~i.prneint is.r:equ.ired by C~rtifJc~te: of Compliance to be availa.ble and operc::1oie to* mitigate the c6n$equenpes of an acciderft and {ii) no redund~nt ~q1,1iprneht Was ~va1lable anc;i :9per~bie* .to p:etf9rrt{ihe r'~qu1re<:;I $~{ety funGtion.
Contrary t9 the above, frq:tn August 6 ~o §:epte.r,b\ar"141 2018,, to~ 1.ice.n,~~e failed to nptify the NRC within the requirnp tiroe,p.eriod.a~er ttie 01~*qovery qfart\ event .inVpl\tLng §j;fent fuE?J *in which_ ilTlportant,.to~sqf~ty e*q \:Jipm.eht was ~)§}3bl~q ,Qr' f$Hetj 'fer fUJ\ttion .:c\$ tje§igrigd, When: . (i) the equipment was-requiretf t?Y .Qerti{ioate ef Cor;npli~n};e lb lb~ $v~ilc3.bi~ a:mo oper~bl~ to mitigate_ tl;le consequences of an ac~igeflt; and (ii) no requntj'3nt eqi.Jiphient was avallal~le and operable to perforrhth~ required s~fetffUfl_0~f0n. , : * . * . :- * .
- Spedfical!y, the licensee fail~<;l *t9 nq~iftth~ :NIRQ.\Nithin~he, jeqUir~9 trr;ne. perio,9 c;ifter a'n *event '
that pc;;curred OIJ Atlgul?t 3, 20113; in wl'li~h .th~ 'lic*~11see;.ina_dveft$iitly di$clole.d. '~h~ red.!Jhdant imp9f1ant-fo-saf:ety d.qwnloAding slin:gs ,whil~ !Pwering spent fi.;(~i q_q:n_i§for 29 into :the ,stgr~rn1e vauit, which res,Ultrd i~ ti')~ qrzini$.t.~:r 1;~s;t1ng prt$_ :~hi~I~ ;r:in_g: 1:i'l'i$~:pe9q~,(ij l;)y JJ:jg r~g:~n'.d~r*t . a clownloading slings at PPRJOXimate,ly 1 .feet, apqy.~ the J~lly se9-teg po$.ition f©r 'approxim~tely 4!? minutes., th~se ~ling{?re reqµiretl by *Certificat¢ Mcompliatice 072;bf0Ao., All:lendment
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i' '2, Cor;idition 4, and T~~h-nicc!I Specifita~ion 5.2.c.3 to.be availc;1ble and operable during canister transfer ope,rptions, .a!ld no redundant equipment was available and operabie to pefrform the required safety function. ' . : : : ; .SCE REPLY TO VIOLAtlON 18-155-8
- 1. Reason for the Violation The Root Cause Evaluation on Reportability identified a root ca~se that management failed to recognize the transition to fuel transfer operations as requiring the integration, familiarization, and appliccition of 10CFR72. 75 reporting requirements into plant processes. Contributing causes included:
- Lack of procedural guidance related to Part 72 reporting
- Lack of a conservative bias for reporting 2 .. Corrective Actions Taken and Results Achieved Corrective actions related to each of the causes identified in item 1, above, are described in SCE's presentation for the January 24, 2019 Pre-Decisional Enforcement Conference (ADAMS Accession No. ML19023A033), slides 60 - 67.
- 3. Corrective Actions That Will Be Taken None.
- 4. Date When Full Compliance Will Be Achieved Full compli~nce was achieved on September 14, 2018, when the required report was submitted.
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