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05000361/FIN-2012005-0131 December 2012 23:59:59San OnofreNRC identifiedFailure to Provide Complete and Accurate Information Regarding Auxiliary Feedwater System OperabilityThe inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, for the failure of the licensee to provide complete and accurate information in all material respects in operability and reportability review supporting documents. Specifically, on September 29, 2011, the licensee did not provide information that was complete and accurate in all material respects, in that Evaluation Report FAI/11-0655, Evaluation of Potential Cooling of the SONGS Steam Line for the AFW Turbine, used inaccurate information to inappropriately determine that the turbine-driven auxiliary feedwater pump was operable, the condition was not reportable per the requirements of 10 CFR 50.73, and the compensatory measures implemented on May 5, 2011, could be removed. The compensatory measures were improperly removed on October 27, 2011. This violation has been entered into the licensees corrective action program as Nuclear Notification NN 202280026. The failure of the licensee to provide complete and accurate information related to the operability of the AFW system was a performance deficiency. The significance determination process is not suited to assess the significance of a violation of 10 CFR 50.9 because it affected the ability of the NRC to perform its regulatory oversight function and, as such, it was assessed using traditional enforcement. This violation was determined to be a Severity Level IV violation based on NRC Enforcement Policy examples provided in Section 6.9. No crosscutting aspect was assigned because the performance deficiency was assessed using traditional enforcement
05000361/FIN-2012004-0230 September 2012 23:59:59San OnofreNRC identifiedFailure to Update the Final Safety Analysis Report for Solid Radioactive WasteThe inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71, Maintenance of Records, Making of Reports, paragraph (e) which states, in part, Each person licensed to operate a nuclear power reactor shall update periodically, the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. Contrary to the above, from 1985 to June 2012, the licensee failed to update the Final Safety Analysis Report to assure that the information included in the report contains the latest information developed. Specifically, since its construction in 1985, the licensee stored a significant source of radioactivity in the Multi-Purpose Handling Facility (South Yard Storage Facility), but failed to describe the source, volume, and storage of radioactive equipment in the Final Safety Analysis Report. The licensee has entered this violation into their corrective action program as Nuclear Notification NN 202076593. The inspectors determined that the failure to update the Final Safety Analysis Report as required by 10 CFR 50.71(e), Maintenance of Records, Making of Reports is a performance deficiency. This performance deficiency was dispositioned using traditional enforcement because failing to update a Final Safety Analysis Report had the potential to adversely impact the NRCs ability to perform its regulatory function. The performance deficiency is characterized as a Severity Level IV violation in accordance with the NRC Enforcement Policy, Section 6.1.d.3. Since this issue was dispositioned using traditional enforcement, there is no cross-cutting aspect
05000361/FIN-2012002-0431 March 2012 23:59:59San OnofreLicensee-identifiedLicensee-Identified ViolationThe inspectors reviewed a Severity Level IV non-cited violation committed by a radiography boundary guard for leaving his boundary post without approval. San Onofre Nuclear Generating Station Technical Specification 5.5.1.1.a requires procedures to be established, implemented, and maintained covering the applicable procedures recommended by Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors, Section 7.e, includes radiation protection procedures for access control to radiation areas. Procedure SO123-VII-20.10.7, Radiography Health Physics Controls, section 6.1.3.2 states that Radiography boundary guard duties are to guard the boundary and prevent personnel from crossing the posted Radiation Area boundary for radiography. Contrary to the above, on November 29, 2010, a radiography boundary guard did not guard the radiography boundary. Specifically, the radiography boundary guard left the radiography boundary post between radiographic shots without being properly relieved. This issue was documented in the licensees corrective action program as Nuclear Notification NN 201219666. This violation is being treated as a non-cited violation in accordance with Section 2.3.2 of the NRC Enforcement Policy because the licensee identified the violation and promptly reported it to the NRC, it was an isolated action of an employee in a low-level position without management involvement, it was not caused by a lack of management oversight, and the licensee took appropriate remedial action commensurate with the circumstances.
05000361/FIN-2012002-0731 March 2012 23:59:59San OnofreLicensee-identifiedLicensee-Identified ViolationThe inspectors reviewed a Severity Level IV problem consisting of two non-cited violations committed by an instrumentation and control technician for attempting to readjust a potentiometer to its original position without proper documentation and failing to notify the control room of a plant status control error. Technical Specification 5.5.1.1.a requires procedures to be established, implemented, and maintained covering the applicable procedures recommended by Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors, Section 1.c, includes typical safety-related activities that should be accomplished in accordance with written procedures, such as equipment control. Procedure SO123-XV-15 , Maintaining Plant Status Control, Section 6.4.1 requires that plant manipulations are only made via an approved tracking document and Section 6.6.1 requires that the Shift Manager must be informed of any actual or suspected plant status control error. Contrary to the above, on March 28, 2011, plant manipulations were made without an approved tracking document and the Shift Manager was not informed of an actual plant status control error. Specifically, an Instrumentation and Control technician manipulated the Channel A potentiometer without an approved tracking document and failed to notify the Shift Manager of the plant status error. This was entered into the licensees corrective action program as NN 201393301. The licensee subsequently verified the operability of both Channels A and B and took actions to prevent potential cross-train errors for future instrumentation and control work. This violation is being treated as a non-cited violation in accordance with Section 2.3.2 of the NRC Enforcement Policy because the licensee identified the violation and promptly reported it to the NRC; it was an isolated action of an employee in a low level position without management involvement; it was not caused by a lack of management oversight; and, the licensee took appropriate remedial action commensurate with the circumstances.
05000361/FIN-2011005-0531 December 2011 23:59:59San OnofreLicensee-identifiedLicensee-Identified ViolationUnit 2, Technical Specification 5.5.1.1, Procedures, states, in part, written procedures shall be established, implemented, and maintained covering the following activities: (a) The applicable procedures recommended in (NRC) Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, Section 7.e(4), states, in part, that radiation protection procedures should be written for contamination control. Procedure SO123-VII-20, Health Physics Program, Revision 14, Section 6.10.6.5 requires, in part, individuals entering a radiologically controlled area sign-up on the appropriate radiation exposure permit acknowledging that they agree to comply with the radiological controls specified on the radiation exposure permit. Radiation Exposure Permit 200101, Revision 13, requires, in part, that paper coveralls be worn inside contamination areas. Procedure SO123-VII-20.10, Radiological Work Planning and Control, Revision 14, Section 6.9.3 states, in part, that the health physics technician in the field can authorize and implement a field change if the work can be safely controlled by increasing or decreasing the protective clothing requirements. Contrary to the above, on December 31, 2009, a senior health physics technician failed to comply with the radiological controls specified in Radiation Exposure Permit 200101. Specifically, the technician was observed in a posted contamination area without paper coveralls or appropriate protective clothing. The technician instead wore rubber gloves and placed masslin cloth towels under his feet as he worked. The technician\'s noncompliance with the terms of the radiation exposure permit was not the result of any field change authorized under San Onofre Nuclear Generating Station procedures. Accordingly, the technician\'s non-compliance with the radiation exposure permit resulted in a violation of San Onofre Nuclear Generating Station procedures tied to Technical Specification 5.5.1.1. This issue was entered into the licensees corrective action program as Nuclear Notification NN 200727341. The licensee observed the health physics technician actions on a video camera and licensee management immediately launched a review. This violation is being treated as a non-cited violation in accordance with Section 2.3.2 of the NRC Enforcement Policy because the licensee identified the violation and promptly reported it to the NRC; it was an isolated action of an employee without management involvement; it was not caused by a lack of management oversight; and, the licensee took appropriate remedial action commensurate with the circumstances.
05000361/FIN-2011404-0131 March 2011 23:59:59San OnofreNRC identifiedSecuritySECUIRTY
05000361/FIN-2010003-1230 June 2010 23:59:59San OnofreLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50.71(e) requires that the licensee periodically update the Final Safety Analysis Report, as provided in subsequent paragraphs. Subparagraph 50.71(e)(4) requires subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months and these revisions must reflect all changes up to a maximum of 6 months prior to date of filing. Contrary to the above, on March 30, 2010, the licensee identified that they had failed to update their Updated Final Safety Analysis Report to maintain consistency with their design documentation. Specifically, the licensee determined that the piping material used in construction of portions of the emergency core cooling system and the auxiliary feedwater system and the associated piping maintenance was not consistent with Updated Final Safety Analysis Report Appendix 3A (3A.1.44). The Updated Final Safety Analysis Report specified that the systems would be constructed using low carbon content stainless steel piping; however, the licensee used high carbon content stainless steel piping. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not repetitive or willful and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. The issue was entered into the licensees corrective action program as Nuclear Notification NN 200856130.
05000361/FIN-2010006-0430 June 2010 23:59:59San OnofreNRC identifiedFailure to Report Conditions That Could of Prevented Fulfillment of Safety FunctionThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73, \"Licensee Event Report System,\" in which the licensee failed to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria. On January 26, 2010, the valve which isolates nonseismic piping from condensate storage tank T-120 failed its in-service test when the hand wheel stem snapped after a leveraging device was used in an attempt to close the valve. This isolation valve, 2HV5715, must be closed within 90 minutes of an operating basis earthquake in order to prevent the loss of condensate storage tank T-120 water inventory from a line break in the nonseismic portion of the condensate system. The failure of this valve resulted in a condition prohibited by Technical Specification 3.7.6 and therefore was reportable. This finding was entered into the licensee\'s corrective action program as Nuclear Notification 200888616, and the licensee was taking actions to send a licensee event report to the NRC for this event. The inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management, and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding was determined to have a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program in that the licensee failed to appropriately evaluate corrective maintenance as a basis for past operability.
05000361/FIN-2010002-1031 March 2010 23:59:59San OnofreNRC identifiedFailure to Report a Safety System Functional FailureThe inspectors identified a noncited violation of 10 CFR 50.73, Licensee Event Report System, associated with the failure of nuclear regulatory affairs personnel to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria as specified. Specifically, nuclear regulatory affairs personnel failed to submit a licensee event report within 60 days following discovery of a complete loss of spent fuel pool cooling event that occurred on February 13, 2007. This issue was entered into the licensees corrective action program as Nuclear Notifications NNs 200740135 and 200733257. The finding is greater than minor because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done the regulatory function is impacted. The inspectors reviewed this issue in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\\\'s regulatory ability was affected. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. Since the inadequate reportability determination had been made in 2007, and the licensees reportability program has undergone significant revision since this time, the inspectors determined that this was not reflective of current licensee performance and therefore did not have a crosscutting aspect associated with it
05000361/FIN-2010002-1131 March 2010 23:59:59San OnofreNRC identifiedFailure to Obtain a License Amendment for a Technical Specification Basis ChangeThe inspectors identified a noncited violation of 10 CFR 50.59, Changes, Test, and Experiments, for the failure of licensing personnel to obtain a technical specification license amendment for a change made to the technical specification bases concerning the emergency chilled water system. Specifically, in 1996, licensing personnel implemented a technical specification bases change for Limiting Condition for Operation 3.7.10, Emergency Chilled Water, which changed the intent and application of the technical specification, and added wording which allowed a period of time for required support systems to be inoperable without declaring the emergency chillers inoperable. This issue was entered into the licensees corrective action program as Nuclear Notifications NNs 200747320 and 200758329. The finding is greater than minor because the failure to follow the requirements of 10 CFR 50.59 and receive prior NRC approval for changes in licensed actions impacted the NRCs regulatory ability. The inspectors reviewed this issue in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. Since the bases change was made in 1996, the inspectors determined that this was not reflective of current licensee performance and therefore did not have a crosscutting aspect associated with i
05000361/FIN-2010002-0931 March 2010 23:59:59San OnofreNRC identifiedFailure to Notify the NRC Within Eight Hours of a Nonemergency EventThe inspectors identified a noncited violation of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to notify the NRC Operations Center within 8 hours following discovery of an event meeting the reportability criteria as specified. Specifically, on December 23, 2009, the licensee failed to notify the NRC Operations Center within 8 hours after the discovery of an event or condition that resulted in a condition where the spent fuel pool cooling system was prevented from fulfilling its safety function of residual heat removal with the complete core off loaded. This issue was entered into the licensees corrective action program as Nuclear Notification NN 200733257. The finding is greater than minor because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done the regulatory function is impacted. The inspectors reviewed this issue in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\\\'s regulatory ability was affected. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program because the licensee failed to thoroughly evaluate problems such that the resolutions addressed causes and extent of conditions as necessary. This includes properly classifying, prioritizing, and evaluating for operability and reportability conditions adverse to qualit
05000361/FIN-2009004-0130 September 2009 23:59:59San OnofreNRC identifiedFailure to Submit Complete Revisions to Updated Final Safety Analysis Report for Penetration Seal ChangesThe inspectors identified a noncited violation of 10 CFR 50.71(e)(4) for the failure of licensing personnel to submit revisions to the Updated Final Safety Analysis Report reflecting changes to the Unit 2 safety equipment building emergency core cooling pump room piping penetration that were in place for more than 24 months. Specifically, for the reporting periods between (1) July 2005 and June 2007; and (2) July 2007 and June 2009, licensing personnel failed to submit complete revisions to the Updated Final Safety Analysis Report reflecting the removal of the boot seal from the Unit 2 emergency core cooling system train B pump room penetration. This seal was removed in July 2005 and was left in this condition as discovered by the inspectors in August 2009. This finding was entered into the licensees corrective action program as Nuclear Notification NN 200550985. The failure of licensing personnel to submit revisions to the Updated Final Safety Analysis Report to describe changes to the Unit 2 safety equipment building emergency core cooling pump room piping penetration that were in place for more than 24 months was a performance deficiency. The finding was determined to be applicable to traditional enforcement because the NRCs ability to perform its regulatory function was potentially impacted by the licensees failure to update the Updated Final Safety Analysis Report in a timely manner. The finding was determined to be a Severity Level IV violation in accordance with Section D.6 of Supplement I of the NRC Enforcement Policy. The finding is more than minor because the degraded flood barrier is associated with the external events attribute of the mitigating systems cornerstone and adversely affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding is determined to have very low safety significance because the finding did not result in a loss of operability or functionality. This finding has a crosscutting aspect in the area of problem identification and resolution because the licensee failed to take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity (P.1(d))(Section 1R01)
05000361/FIN-2009004-0430 September 2009 23:59:59San OnofreSelf-revealingFailure to Notify the NRC within Required TimeframeA self-revealing noncited violation of 10 CFR 50.72 was identified for the failure to notify the NRC in the time required after computer engineering personnel discovered an event requiring an eight hour notification. Specifically, on July 13, 2009, Nuclear Regulatory Affairs personnel failed to notify the NRC, within 8 hours after the discovery of a loss of the ability to activate 10 Community Alert Sirens located on the Camp Pendleton Marine Corp Base. The NRC was notified of the loss of the ability to activate the Community Alert Sirens, approximately 24 hours late, on July 14, 2009. This finding was entered in the licensee\'s corrective action program as Nuclear Notification NN 200501125. The failure to notify the NRC of an event in the time required by 10 CFR 50.72 was a performance deficiency. The finding was determined to be applicable to traditional enforcement because the NRCs ability to perform its regulatory function was potentially impacted by the licensees failure to report the event. The finding is associated with the emergency preparedness cornerstone. The finding was determined to be a Severity Level IV violation in accordance with Section D of Supplement I of the NRC Enforcement Policy. The finding is not suitable for evaluation using the significance determination process, but has been reviewed by NRC management and is determined to be a finding of very low safety significance. The finding has a crosscutting aspect in the area of problem identification and resolution associated with corrective action program because computer engineering personnel failed implement the corrective action program at an appropriate threshold for identified issues (P.1(a))
05000361/FIN-2008013-0631 December 2008 23:59:59San OnofreNRC identifiedFailure to Submit LER for Condition Prohibited by Technical SpecificationThe team identified a Severity Level IV noncited violation of 10 CFR Part 50.73 for the failure of the licensees regulatory compliance organization to submit a required Licensee Event Report within 60 days after discovering an event requiring a report. Specifically, compliance personnel failed to properly assess the past operability of the safety-related 125 Vdc Battery 2B008, which had been inoperable for greater than the technical specification allowed outage time. This issue was entered into the licensees corrective action program as Nuclear Notification 200059017. The finding was determined to be applicable to traditional enforcement because the NRCs ability to perform its regulatory function was potentially impacted by the licensees failure to report the events. The finding was determined to be a Severity Level IV violation in accordance with Section D.4 of Supplement I of the NRC Enforcement Policy. The finding has a crosscutting aspect in the area of problem identification and resolution associated with CAP because the licensee failed to thoroughly evaluate problems such that the resolutions address causes and extent of conditions. This includes properly classifying, prioritizing, and evaluating for operability and reportability conditions adverse to quality (P.1(c)) (Sections 2.1.6 and 3.6)
05000361/FIN-2003003-0330 June 2003 23:59:59San OnofreNRC identifiedChange to EAL C3 resulting in decrease in effectiveness of EP in violation of 10 CFR 50.54(q)

Between March 3 and April 25, 2003, the licensee implemented a change to Emergency Action Level C3 which constituted a decrease in effectiveness of the emergency plan because two conditions which would previously have resulted in site area emergency classification would not be classified by the revised emergency action level. Implementation without prior NRC approval of changes to the emergency plan which constitute reduction in the effectiveness of the plan was a noncited violation of 10 CFR 50.54(q)

The finding was evaluated using NUREG-1600, "General Statement of Policy and Procedure for NRC Enforcement Actions," Section IV, because licensee reductions in the effectiveness of its emergency plan impact the regulatory process. The finding had greater than minor significance because deletion of conditions indicative of a site area emergency has the potential to impact safety. The finding was determined to be a noncited Severity Level IV violation because the emergency action level change constituted a failure to implement an emergency planning standard and did not constitute a failure to meet an emergency planning standard as defined by 10 CFR 50.47(b). This finding has been entered into the licensee's corrective action program as Action Request 030400514.